Report 2022-115 Recommendation 12 Responses

Report 2022-115: Electricity and Natural Gas Rates: The California Public Utilities Commission and Cal Advocates Can Better Ensure That Rate Increases Are Necessary (Release Date: August 2023)

Recommendation #12 To: Public Advocates Office

To ensure that it consistently and appropriately executes its protests of general rate case applications and advice letters, Cal Advocates should develop written policies and procedures by February 2024 that provide staff with direction on the steps staff must take when reviewing and filing protests on general rate case applications.

6-Month Agency Response

Protests to general rate case applications are standard pleadings that generally recommend the issues that should be within the scope of the CPUC's proceeding. Through discovery, we may determine that some, most or all of the identified issues may not need to be litigated. Protests are application-specific and are simply placeholders until we have time to conduct more research via discovery or analyses to determine the issues we will fully litigate.

We have prepared a written guide, "Reviewing and Filing Protests to General Rate Case Applications." This guide has been distributed and is accessible online to all Public Advocates Office staff.

California State Auditor's Assessment of 6-Month Status: Pending

Cal Advocates provided a two-page guide that reiterates the CPUC's rules for the basis for a protest, the timing of a protest, and what to include in a protest. However, the guide does not include specific guidelines to ensure that all staff consistently assess which proposed costs to protest on general rate case applications. Until it does so, we will continue to report this recommendation as not fully implemented.

60-Day Agency Response

Protests to general rate case applications are standard pleadings that generally recommend the issues that should be within the scope of the CPUC's proceeding. Through discovery, we may determine that some, most or all of the identified issues may not need to be litigated. Protests are application-specific and are simply placeholders until we have time to conduct more research via discovery or analyses to determine the issues we will fully litigate. We will strive to develop written policies and procedures February 2024. However, given our resources and current and anticipated workload, we may need to look to the end of September 2024.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2022-115

Agency responses received are posted verbatim.