TURN demonstrated that the Commission Verified D.15-12-047, pp. Compare should reject proposed changes to 29-30 PD, pp. 27-28 PG&E’s with the Proposed Decision (PD) and Alternate and APD, pp. 29-30 Proposed Decision (APD), which would (showing no change, have subjected the CHANGES CBOs to consistent with TURN’s more onerous requirements regarding recommendation); see customer consent to disclosure of utility D.15-12-047, p. 3, also, account information than currently fn. 34 (noting TURN’s applicable to the CHANGES program. opposition to PG&E’s ORA also addressed this issue, but TURN comments re CHANGES and ORA provided unique analyses CBOs, which ORA also supporting rejection of position. opposed) PG&E’s (See ORA Reply Cmts on CHANGES TURN Reply Cmts on PD/APD, 12/14/15, pp. 1-5). CHANGES PD/APD, 12/14/15, pp. 1-5 Duplication of Effort (§ 1801.3(f) and § 1802.5): CPUC Discussion Intervenor’s Assertion a. Was the Office of Ratepayer Advocates (ORA) a party to Yes Verified the proceeding? Yes Verified b. Were there other parties to the proceeding with positions similar to yours? Verified c. If so, provide name of other parties: positions overlapped to various degrees with the following parties: Office TURN’s of Ratepayer Advocates (ORA), Center for Accessible Technology (CforAT), Greenlining Institute (Greenlining), National Consumer Law Center (NCLC), California Housing Partnership Corporation (CHPC), and the Natural Resources Defense Council (NRDC).
TURN demonstrated that the Commission should reject PG&E’s proposed changes to the Proposed Decision (PD) and Alternate Proposed Decision (APD), which would have subjected the CHANGES CBOs to more onerous requirements regarding customer consent to disclosure of utility account information than currently applicable to the CHANGES program. ORA also addressed this issue, but TURN and ORA provided unique analyses supporting rejection of PG&E’s position. (See ORA Reply Cmts on CHANGES PD/APD, 12/14/15, pp. 1-5). Compare D.15-12-047, pp. 29-30 with PD, pp. 27-28 and APD, pp. 29-30 (showing no change, consistent with TURN’s recommendation); see also, D.15-12-047, p. 3, fn. 34 (noting TURN’s opposition to PG&E’s comments re CHANGES CBOs, which ORA also opposed) TURN Reply Cmts on CHANGES PD/APD, 12/14/15, pp. 1-5 Verified 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’s positions overlapped to various degrees with the following parties: Office of Ratepayer Advocates (ORA), Center for Accessible Technology (CforAT), Greenlining Institute (Greenlining), National Consumer Law Center (NCLC), California Housing Partnership Corporation (CHPC), and the Natural Resources Defense Council (NRDC). Verified
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