BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 201
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          SENATE THIRD READING
          SB 201 (Speier)
          As Amended July 19, 2001
          Majority vote 

           SENATE VOTE  :27-10  
           
           UTILITIES AND COMMERCE     11-6 APPROPRIATIONS      14-6        
           
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          |Ayes:|Wright, Calderon,         |Ayes:|Migden, Alquist, Aroner,  |
          |     |Canciamilla, Cardenas,    |     |Cedillo, Corbett, Correa, |
          |     |Diaz, Jackson, Nation,    |     |Goldberg, Papan, Pavley,  |
          |     |Papan, Reyes, Simitian,   |     |Simitian, Thomson,        |
          |     |Wesson                    |     |Washington, Wiggins,      |
          |     |                          |     |Wright                    |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Pescetti, Bill Campbell,  |Nays:|Bates, Ashburn, Daucher,  |
          |     |John Campbell, La Suer,   |     |Robert Pacheco, Runner    |
          |     |Leonard, Maddox           |     |Zettel                    |
           ----------------------------------------------------------------- 

           SUMMARY  :  Deletes the repeal of the provisions in the Public  
          Utilities Code (PU Code) that provide for an independent  
          division within the California Public Utilities Commission  
          (CPUC) chartered with representing public utility consumers in  
          CPUC proceedings.  
          Specifically,  this bill  :

          1)Removes the January 1, 2002 sunset date of PU Code Section  
            309.5 and retains the independent Office of Ratepayer  
            Advocates (ORA) beyond that date.

          2)Provides additional conditions upon ORA in discovery matters  
            by requiring that any discovery dispute be decided by the  
            President of CPUC or an assigned commissioner in   writing, and  
            requiring that the division agree to meet and confer with a  
            regulated entity prior to filing a complaint at CPUC. 

           EXISTING LAW  provides for an independent consumer representative  
          within CPUC consisting of and chartered with:

          1)A director appointed by the Governor.









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          2)Assignment of personnel to the division sufficient to ensure  
            that customer and subscriber interests are fairly represented  
            in all significant proceedings.

          3)Separation of advocacy personnel from any advisory role to any  
            decision maker on the same case or proceeding.

          4)Discovery rights inclusive of the division's ability to compel  
            the production or disclosure of any information it deems  
            necessary to perform its duties from entities regulated by  
            CPUC, with a resolution process in place for any objections to  
            such requests by an assigned commissioner, or in the absence  
            of a proceeding, by the president of CPUC.

          5)A separate budget allocation from that of CPUC to be utilized  
            exclusively by the division in the performance of its duties.

          FISCAL EFFECT  :  None

           COMMENTS  :  This bill expanded the staffing and funding for ORA  
          and provided that the Director of ORA have a salary at least  
          equal to 90% of the salary of the CPUC commissioners.  The  
          Assembly amended these provisions out of this bill.

          ORA was created by statute in 1996 and became independent from  
          CPUC in January of 1997.  Up to that time a division existed  
          within CPUC representing consumer interests, and the division's  
          budget and personnel were determined by CPUC.  It was determined  
          that a conflict was apparent by having consumer interests  
          represented by a division of a state agency where there was no  
          independence.  PU Code Section 309.5 provided for ORA's  
          independence, its separate budget allocation and for the  
          presumption that staffing should be adequate to fairly represent  
          consumer interests in CPUC proceedings.  The enabling language  
          also provided ORA with significant discovery rights before CPUC,  
          but with a check and balance provision in the event that an  
          entity regulated by CPUC objected to providing responses to  
          discovery requests.  In proceedings with an assigned  
          commissioner, objections to ORA discovery requests are to be  
          decided by the assigned commissioner.  Where no proceeding is  
          yet open or prior to assignment of a commissioner, such  
          objections will be resolved by the president of CPUC according  
          to the existing statute.

          Since 1997, ORA participated in proceedings opened by CPUC, by  








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          other parties, and in cases, initiated by ORA itself.  CPUC has  
          upheld that, "ORA shall have discovery rights, as do other  
          parties to the proceeding.  It may also rely on Section 309.5  
          (e)?" (Decision (D.) 01-02-041).  PU Code Section 309.5 (e) is  
          the portion which provides ORA broader rights to compel  
          production or disclosure of "any information it deems necessary  
          to perform its duties", subject to review of any objections by  
          an assigned commissioner or president of CPUC.  Finally, PU Code  
          Section 309.5 carried a sunset date of January 1, 2002, unless  
          extended by statute.  This bill seeks to repeal the sunset and  
          enhance ORA staffing.  There is no opposition to this bill.

          In its support letter, California State Employees Association  
          (CSEA) expresses its concern "with the gradual phasing out of  
          the Office of Ratepayer Advocates", citing that "Several years  
          ago this office took the brunt of severe budget cuts and has  
          never fully recovered."  CSEA's letter is particularly cogent,  
          as absent this legislation, independent consumer representation  
          disappears at CPUC just as the specter of competition is proving  
          to be a failure in the energy markets and to be virtually  
          non-existent in the local telecommunications market in this  
          state.  Many states actively pursue market abuse prevention and  
          service quality assurances through special consumer advocacy  
          agencies and California would be left far behind most other  
          states regarding utility consumer advocacy without ORA's  
          existence.  In Illinois, recent legislation created hundreds of  
          new positions and a special unit of the Attorney General's  
          office specifically to handle telecommunications consumer  
          protection areas (energy consumer protection advocacy already  
          existed there) in the rate de-regulated environment.  

          Market changes in California in gas, electricity and  
          telecommunications have created complex situations for  
          consumers.  There has been a dramatic rise in consumer  
          complaints about market abuse, poor service quality and lack of  
          competition for basic services in the telecommunications area.   
          ORA contributed significantly to a market abuse complaint case  
          raised in 1998 by Utility Consumer Action Network (UCAN), and in  
          the presiding officer's decision in that case (C. 98-04-004),  
          the areas specifically addressed by ORA testimony were upheld.   
          Subsequently, ORA filed two complaints on its own after initial  
          investigation, one dealing with a Prompted Repeat Dialing  
          Service and one dealing with long repair intervals for basic  
          residential telephone service.  In both of these two latter  
          cases, ORA had to independently conduct discovery over initial  








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          objections of a regulated utility, and this bill clarifies the  
          legislative intent regarding the scope of ORA's discovery rights  
          . 

          Absent ORA's existing discovery rights, numerous market abuses  
          and violations of existing law might never have come to light  
          despite widespread consumer complaint about various  
          telecommunications services.  Virtually all residential and most  
          small commercial consumers in California are still faced with a  
          monopoly providing them with their basic telephone service and  
          with only one utility offering them gas or electric service.   
          The types of market abuse and service neglect these market  
          structures can facilitate, render independent consumer  
          representation a desirable necessity in CPUC proceedings.

          While ORA advocates in other ways, it is largely vested with a  
          responsibility to adequately and fairly represent utility  
          consumer interests in evidentiary proceedings.  This bill  
          ensures ORA's continued ability to perform such advocacy by  
          eliminating the sunset provision.  This bill seeks to clarify  
          the legislative intent behind Section 309.5 by eliminating  
          language that has been interpreted by some entities to limit  
          ORA's role to open CPUC proceedings.  Since CPUC has upheld  
          ORA's ability to file complaints and initiate proceedings in  
          various decisions and orders, this change is intended to clarify  
          the statute to prevent further misinterpretation.  This  
          clarification is similar to that proposed in AB X2 57 (Wiggins)  
          for Section 11652 of the PU Code relating to municipal utility  
          district voting requirements, which was also subject to numerous  
          interpretations.  

          ORA performs a necessary consumer advocacy role unique by virtue  
          of its independence and its position as a state office.  The  
          change in regulatory focus from rate-setting to market-based  
          regulation has demonstrated a need to prevent market abuse and  
          deteriorated service quality.  ORA is uniquely positioned beyond  
          the interests of consumer groups with stated constituencies and  
          private funding requirements as an independent state office.   
          The continuation of ORA's role will provide a much needed  
          benefit to hard hit utility consumers in this state and the  
          staff augmentation provided for in this bill will best serve  
          those long term consumer interests.


           Analysis Prepared by  :  Kelly Boyd / U. & C. / (916) 319-2083 








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