CforAT, in conjunction with While the Final Decision declined to adopt Verified. TURN, addressed the issue of a budget cap for the health care/health appropriate caps for services CBO category, it did retain a healthcare/health services revenue cap for each individual CBO, CBOs in order to reduce the finding the cap to be more feasible “revenue risk that this category of to implement and administer than a budget CBOs could create a Final Decision at pp. 18-19. The cap.” disproportionately large draw revenue cap adopted had previously been on the fund. TURN/CforAT proposed by CforAT and other consumer Reply Comments, filed on groups. Final Decision at p. 19. See also June 30, 2017, at p. 5. Final Decision at p. 23, discussing party input on this issue. In comments on the PD, ORA The Commission did not Verified. grant ORA’s requested for the first time request. Final Decision at p. 24. that various Commission divisions, including but not limited to ORA, be given the authority to audit CTF participants. CforAT (along with other parties) opposed this request. CforAT/TURN Reply comments on PD, filed on January 8, 2018, at pp. 3-4. Duplication of Effort (§ 1801.3(f) and § 1802.5): CPUC Intervenor’s Assertion Discussion Yes Verified. a. Was the Office of Ratepayer Advocates a party to 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 were generally similar to those of TURN. On a number of CforAT’s issues, but not all, positions were also similar to those of CforAT’s CalNonprofits. On various issues position also corresponded with CforAT’s those of other parties, including AT&T. d. claim of non-duplication: Verified. Intervenor’s Throughout Phase 3 of the proceeding, CforAT coordinated closely with TURN and also coordinated with CalNonprofits to the extent that our positions were similar. CforAT and TURN prepared various filings jointly in order to avoid duplication of effort; where we filed separately, we coordinated in order to ensure that our work complemented or supplemented each other rather than duplicate each other. PART III: REASONABLENESS OF REQUESTED COMPENSATION
CforAT, in conjunction with TURN, addressed the issue of appropriate caps for healthcare/health services CBOs in order to reduce the risk that this category of CBOs could create a disproportionately large draw on the fund. TURN/CforAT Reply Comments, filed on June 30, 2017, at p. 5. While the Final Decision declined to adopt a budget cap for the health care/health services CBO category, it did retain a revenue cap for each individual CBO, finding the “revenue cap to be more feasible to implement and administer than a budget cap.” Final Decision at pp. 18-19. The revenue cap adopted had previously been proposed by CforAT and other consumer groups. Final Decision at p. 19. See also Final Decision at p. 23, discussing party input on this issue. Verified. In comments on the PD, ORA requested for the first time that various Commission divisions, including but not limited to ORA, be given the authority to audit CTF participants. CforAT (along with other parties) opposed this request. CforAT/TURN Reply comments on PD, filed on January 8, 2018, at pp. 3-4. The Commission did not grant ORA’s request. Final Decision at p. 24. Verified. Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Office of Ratepayer Advocates 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: CforAT’s positions were generally similar to those of TURN. On a number of issues, but not all, CforAT’s positions were also similar to those of CalNonprofits. On various issues CforAT’s position also corresponded with those of other parties, including AT&T. Verified. d. Intervenor’s claim of non-duplication: Throughout Phase 3 of the proceeding, CforAT coordinated closely with TURN and also coordinated with CalNonprofits to the extent that our positions were similar. CforAT and TURN prepared various filings jointly in order to avoid duplication of effort; where we filed separately, we coordinated in order to ensure that our work complemented or supplemented each other rather than duplicate each other. Verified. PART III: REASONABLENESS OF REQUESTED COMPENSATION
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