Definitions (CforAT Reply Brief), filed on January 11, 2016 at pp. 7-9. CforAT argued that any analysis of bill impacts should consider monthly bills in order to adequately assess the impact of bill volatility. CforAT Reply Brief at p. 10. CforAT argued that the reference to “unreasonable §745(c)(2) hardship” under and under “hardship” §745(d) have different meanings, and must include issues of health and safety as well as financial hardship. CforAT Opening Brief at p. 10. CforAT sought additional guidance on excluded customers under §745(c)(1). CforAT Comments on PD at pp. 8-9. TOU: D.17-09-036 (Section Verified 745 Decision 2): While the Commission does not CforAT argued that the make a direct statement regarding burden of proof on whether burden of proof, it applies the customers experience standard proffered by CforAT hardship is on the proponents throughout the Section 745 Decision of TOU rates, and that 2. Section 745 Decision 2 at See e.g. default TOU proposals p. find that the available 17 (“We cannot be adopted unless the evidence is insufficient to conclude proponents affirmatively that economically vulnerable demonstrate that they will customers in hot climate zones do not cause hardship as not experience unreasonable required by statute. CforAT economic hardship due to TOU Opening Brief on § 745 pp. 19, 22. see also id.at rates”), Issues, filed on June 15, The Commission agreed with 2017, at pp. 12-14, CforAT CforAT and other parties that bill Reply Brief on § 745 Issues, impacts for CARE/FERA customers filed on June 29, 2017 at p. in hot climate zones are quite high. 2. This assignment of the Section 745 Decision 2 at p. 16. The burden of proof is Commission thus ordered these foundational to all other customers to be excluded from the arguments. upcoming default TOU pilots based CforAT argued that on risk of unreasonable economic
Definitions (CforAT Reply Brief), filed on January 11, 2016 at pp. 7-9. CforAT argued that any analysis of bill impacts should consider monthly bills in order to adequately assess the impact of bill volatility. CforAT Reply Brief at p. 10. CforAT argued that the reference to “unreasonable hardship” under §745(c)(2) and “hardship” under §745(d) have different meanings, and must include issues of health and safety as well as financial hardship. CforAT Opening Brief at p. 10. CforAT sought additional guidance on excluded customers under §745(c)(1). CforAT Comments on PD at pp. 8-9. TOU: D.17-09-036 (Section 745 Decision 2): CforAT argued that the burden of proof on whether customers experience hardship is on the proponents of TOU rates, and that default TOU proposals cannot be adopted unless the proponents affirmatively demonstrate that they will not cause hardship as required by statute. CforAT Opening Brief on § 745 Issues, filed on June 15, 2017, at pp. 12-14, CforAT Reply Brief on § 745 Issues, filed on June 29, 2017 at p. 2. This assignment of the burden of proof is foundational to all other arguments. CforAT argued that While the Commission does not make a direct statement regarding burden of proof, it applies the standard proffered by CforAT throughout the Section 745 Decision 2. See e.g. Section 745 Decision 2 at p. 17 (“We find that the available evidence is insufficient to conclude that economically vulnerable customers in hot climate zones do not experience unreasonable economic hardship due to TOU rates”), see also id.at pp. 19, 22. The Commission agreed with CforAT and other parties that bill impacts for CARE/FERA customers in hot climate zones are quite high. Section 745 Decision 2 at p. 16. The Commission thus ordered these customers to be excluded from the upcoming default TOU pilots based on risk of unreasonable economic Verified
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