CFC maintained throughout that • TOU rate structures should not be D.15-07-001 at pages 134, 315. mandatory or truly “mandatory” without an option to opt out. The Consumer Federation of The Commission agreed. D. Opening California’s does not adopt or support Comments on Rate Design mandatory TOU rate structures for Proposals Submitted Pursuant residential customers. to Rulemaking 12-06-013, page 14. Duplication of Effort (§ 1801.3(f) and § 1802.5): CPUC Intervenor’s Assertion Discussion Verified a. Was the Office of Ratepayer Advocates (ORA) a Yes. party to the proceeding? b. Were there other parties to the proceeding with Yes. Verified positions similar to yours? c. If so, provide name of other parties: TURN Yes, however various other parties such as Greenlining, CforAT, UCAN, and Vote Solar also maintained positions similar to CFC. d. claim of non-duplication: Although CFC Intervenor’s was not CFC took positions in this matter that reflect its consumer protection duplicative of the mission. While the IOUs and other entities with business interests in the work of other various aspect of demand response were more concerned with the costs parties, it is false and expenses relating to profit and loss, CFC steadfastly fought for to state that other residential consumers. parties were CFC communicated with parties on several occasions to discuss strategy merely interested and positions taken. Non-duplication was also discussed. in profit margins. The specific concerns of CFC and other intervenors were sufficiently divergent that there was very little overlap in positions taken on the issues. PART III: REASONABLENESS OF REQUESTED COMPENSATION (to be completed by Intervenor except where indicated) General Claim of Reasonableness (§ 1801 and § 1806):
• CFC maintained throughout that TOU rate structures should not be mandatory or truly “mandatory” without an option to opt out. The Commission agreed. D. does not adopt or support mandatory TOU rate structures for residential customers. D.15-07-001 at pages 134, 315. The Consumer Federation of California’s Opening Comments on Rate Design Proposals Submitted Pursuant to Rulemaking 12-06-013, page 14. 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: TURN Yes, however various other parties such as Greenlining, CforAT, UCAN, and Vote Solar also maintained positions similar to CFC. d. Intervenor’s claim of non-duplication: CFC took positions in this matter that reflect its consumer protection mission. While the IOUs and other entities with business interests in the various aspect of demand response were more concerned with the costs and expenses relating to profit and loss, CFC steadfastly fought for residential consumers. CFC communicated with parties on several occasions to discuss strategy and positions taken. Non-duplication was also discussed. The specific concerns of CFC and other intervenors were sufficiently divergent that there was very little overlap in positions taken on the issues. Although CFC was not duplicative of the work of other parties, it is false to state that other parties were merely interested in profit margins. PART III: REASONABLENESS OF REQUESTED COMPENSATION (to be completed by Intervenor except where indicated) General Claim of Reasonableness (§ 1801 and § 1806):
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