specifically that this can only be information about when a customer can be done by a gas corporation not a returned to the gas utility and when service CTA. Joint Phase 2 Comments to the customer can be disconnected. at p. 31. at p. 135. Annual Fee: The Commission adopted an Advocated for adoption of an Noted annual fee for CTAs (in addition to a annual fee, as well as a registration fee) based on the costs of registration fee, to provide administering the registration program and resources for enforcement. the required consumer protection services Joint Phase 2 Comments at 22; for the Commission. D.18-02-002 at pp. Joint Reply Comments at pp. 79-80. Noted CTA Security Deposits: While the Supported the retention of Commission did not adopt the Joint deposit requirements following specific proposal for a deposit Consumers’ the Phase 1 Decision. Joint formula, it retained the obligation for all Phase 2 Reply Comments at p. CTAs to post financial resources with the 2. Commission. D.18-02-002 at pp. 18-21. Noted Opposed efforts to change the Applicability of Standards: The Phase 1 determination that Commission restated its determination that regulations should apply to all does not distinguish between core “SB 656 CTAs. CforAT Reply gas customers who take service as a Comments on PD at pp. 1-3. residential, commercial, or industrial D.18-02-002 at p. 153. customer.” Duplication of Effort (§ 1801.3(f) and § 1802.5): CPUC Intervenor’s Assertion Discussion a. Was the Public at the California Yes Verified Advocate’s Office Public Utilities Commission a party to the proceeding? b. Were there other parties to the proceeding with Yes Verified positions similar to yours? Noted c. If so, provide name of other parties: In Phase 1, CforAT worked closely with TURN and the Greenlining Institute to address issues of consumer protection. In allocating tasks among the consumer groups, CforAT retained a particular focus on concerns for customers with disabilities. Noted
specifically that this can only be done by a gas corporation not a CTA. Joint Phase 2 Comments at p. 31. Advocated for adoption of an annual fee, as well as a registration fee, to provide resources for enforcement. Joint Phase 2 Comments at 22; Joint Reply Comments at pp. Supported the retention of deposit requirements following the Phase 1 Decision. Joint Phase 2 Reply Comments at p. 2. Opposed efforts to change the Phase 1 determination that regulations should apply to all CTAs. CforAT Reply Comments on PD at pp. 1-3. information about when a customer can be returned to the gas utility and when service to the customer can be disconnected. at p. 135. Annual Fee: The Commission adopted an annual fee for CTAs (in addition to a registration fee) based on the costs of administering the registration program and the required consumer protection services for the Commission. D.18-02-002 at pp. 79-80. CTA Security Deposits: While the Commission did not adopt the Joint Consumers’ specific proposal for a deposit formula, it retained the obligation for all CTAs to post financial resources with the Commission. D.18-02-002 at pp. 18-21. Applicability of Standards: The Commission restated its determination that “SB 656 does not distinguish between core gas customers who take service as a residential, commercial, or industrial customer.” D.18-02-002 at p. 153. Noted Noted Noted Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Public Advocate’s Office at the California Public Utilities Commission 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: In Phase 1, CforAT worked closely with TURN and the Greenlining Institute to address issues of consumer protection. In allocating tasks among the consumer groups, CforAT retained a particular focus on concerns for customers with disabilities. Noted Noted