A. information requested by Communications Division staff Greenlining argued that the in order to monitor competition Commission should require in the California carriers to report data at the telecommunications markets.” census block level. Opening Final Decision at pp. 192-193, Brief at p. 16. Ordering Paragraphs 1 and 2. While the Final Decision did not specifically require collection of data regarding subscriber and deployment data, it did authorize the Communications Division to request that information in the future. Id. Duplication of Effort (§ 1801.3(f) and § 1802.5): CPUC Intervenor’s Assertion Discussion a. Was the Office of Ratepayer Advocates (ORA) a party Yes Verified to the proceeding? b. Were there other parties to the proceeding with positions Yes Verified similar to yours? c. If so, provide name of other parties: Verified Center for Accessible Technology ORA, TURN d. claim of non-duplication: Verified Intervenor’s work in this proceeding was different from that of ORA or the Greenlining’s other consumer advocates, in that it focused on service quality impacts on communities of color and low income communities. This perspective influenced many of the positions Greenlining took in the proceeding. Throughout the proceeding, Greenlining remained in regular contact with advocates from ORA, TURN, and the Center for Accessible Technology, to ensure that work was not duplicative. Where parties agreed, Greenlining’s they coordinated rather than merely echoing each other. In fact, 5.7% of reported hours are related to emails or phone calls regarding Greenlining’s coordination of efforts. When possible, Greenlining coordinated on joint filings and ex parte meetings to avoid duplicative efforts. While litigating this proceeding, Greenlining coordinated closely with other intervenors and parties to avoid or minimize duplication of its work. For example, Greenlining often took the lead on creating initial drafts for Joint
A. Greenlining argued that the Commission should require carriers to report data at the census block level. Opening Brief at p. 16. information requested by Communications Division staff in order to monitor competition in the California telecommunications markets.” Final Decision at pp. 192-193, Ordering Paragraphs 1 and 2. While the Final Decision did not specifically require collection of data regarding subscriber and deployment data, it did authorize the Communications Division to request that information in the future. Id. Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to the proceeding? Yes Verified b. Were there other parties to the proceeding with positions similar to yours? Yes Verified c. If so, provide name of other parties: Center for Accessible Technology ORA, TURN Verified d. Intervenor’s claim of non-duplication: Greenlining’s work in this proceeding was different from that of ORA or the other consumer advocates, in that it focused on service quality impacts on communities of color and low income communities. This perspective influenced many of the positions Greenlining took in the proceeding. Throughout the proceeding, Greenlining remained in regular contact with advocates from ORA, TURN, and the Center for Accessible Technology, to ensure that Greenlining’s work was not duplicative. Where parties agreed, they coordinated rather than merely echoing each other. In fact, 5.7% of Greenlining’s reported hours are related to emails or phone calls regarding coordination of efforts. When possible, Greenlining coordinated on joint filings and ex parte meetings to avoid duplicative efforts. While litigating this proceeding, Greenlining coordinated closely with other intervenors and parties to avoid or minimize duplication of its work. For example, Greenlining often took the lead on creating initial drafts for Joint Verified