4. Comments on Proposed Decision

The proposed decision of Commissioner Sandoval in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed on May 14, 2012 by Greenlining.18 Reply comments were filed on May 21, 2012 by TURN.

Greenlining's Comments observe that: "it is imperative that the Commission solicit and receive this input even without a formal forum."19 To realize this goal, Greenlining recommends amendments to the proposed decision. Specifically, Greenlining recommends that the "Commission must continue to solicit formal participation in proceedings by small business representatives, and strive to reduce the procedural barriers to participation..."20 Greenlining also recommends that the Commission "regularly and intentionally step out of the box of proceedings and hear directly from the wide and varied small business community about their needs and concerns."21 Greenlining approves of the Commission's proposal to rely on roundtable discussions, and identifies factors that will "ensure the utility of these roundtable discussions."22 Greenlining recommends the following:

1. Hold semi-annual or quarterly roundtables.23

2. Provide wide notice of the roundtables to solicit "participation from new voices."24

3. Track the number and kind of businesses that attend each roundtable to "help ensure diversity of perspective."25

4. Have at least one Commissioner at each roundtable.26

5. Hold roundtables a various locations around the state.27

6. Continue to solicit feedback from small business customers year-round.28

Finally, Greenlining cautions that holding roundtables as part of Small Business expositions would be less productive than a separate roundtable because "the target audiences for each are slightly different."29

In reply comments, TURN expressed support for Greenlining's positions. In addition, TURN asked that the "PD be modified to direct the BCO to work closely with the Public Advisor's office on outreach for the Roundtable Discussions."30

In response, we find Greenlining's suggestions concerning the planning of roundtables extremely helpful and will use them as a guide to planning our roundtables. Concerning Greenlining's recommendation that the Commission strive to hold business roundtables separate form expos, we advise the BCO to follow this recommended practice to the extent possible unless budgetary and personnel resource constraints made such an approach impractical. Concerning TURN's request, we decline to direct the BCO to work with the Public Advisor. These units of the Commission already work well together, and we are confident that the BCO will take whatever steps are necessary to ensure the success of their outreach efforts.

18 Opening Comments of the Greenlining Institute on the Proposed Decision, May 14, 2012.

19 Id. at 1.

20 Id. at 2.

21 Id.

22 Id. at 3.

23 Id.

24 Id.

25 Id. at 4.

26 Id.

27 Id.

28 Id. at 5.

29 Id.

30 TURN Reply Comments at 2.

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