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
General Claim of Reasonableness (§ 1801 and § 1806): a. Intervenor’s claim of cost reasonableness: Due to high levels of poverty and low levels of employment, among other factors, people with disabilities are a population segment that is among the least likely to have access to high speed internet access at home or at work. Therefore CforAT’s constituency is more likely than average to rely on CBOs and other entities served by CTF to have access to advanced communications services in their local communities. Even as CforAT’s constituency benefits from the access offered by CTF’s recipients, few likely understand the importance of the program, and even fewer would be likely to directly participate before the Commission to address its importance. While it is difficult to assign a dollar figure to the value that CforAT’s constituents obtain by having access to advanced services through resources, there can be no doubt that this population directly benefits from the services offered by CTF recipients well beyond the cost of CforAT’s participation in this proceeding. CPUC Discussion Noted. b. Reasonableness of hours claimed: CforAT’s participation on Phase 3 Issues has been focused and constrained to issues of direct relevance to our constituency. CforAT has coordinated with other parties, including filing joint pleadings as appropriate, in order to represent the interests of our constituency efficiently. Verified, but see CPUC Disallowances and Adjustments in Part III.D, Item 3. c. Allocation of hours by issue: Given the limited total of hours claimed (spread over a number of years), CforAT has allocated all time on the merits of this portion of the proceeding simply to “Phase 3.” The totals are as follows: 2015: 10.3 hours allocated to “Phase 3” 2016: 4.0 hours allocated to “Phase 3” 2017: 9.5 hours allocated to “Phase 3” 2018: 5.2 hours allocated to “Phase 3” Total: 29.0 hours on Phase 3 Issues Verified, but see CPUC Disallowances and Adjustments in Part III.D, Item 3 for the 2016 allocated hours.