3. Adequacy of Representation

CARE asserts that it is the only intervenor that will act specifically on behalf of residential customers who reside in the affected low-income communities of color where there are QF facilities. For example, there are QF facilities in Pittsburg, Long Beach, Los Angeles, Blythe, San Francisco, Santa Clara, San Jose and Medicine Lake Highlands. CARE alleges that these are geographic communities that will bear the disparate environmental and socioeconomic burden of the price this proceeding establishes for QF facilities. In addition, CARE will be the only intervenor representing members that include photo voltaic self suppliers of electricity who provide an avoided cost to the utility. Therefore, these CARE members have a direct interest in the rate established for QF facilities.

CARE argues that it is the only intervenor that can effectively represent the residential ratepayers in the geographic communities surrounding the QF facilities and the photo voltaic self suppliers of electricity. While there are other intervenors, such as the Commission's Office of Ratepayer Advocates (ORA), who represent ratepayers in general, CARE specifically represents the ratepayers who will be affected by the price established for QFs - both as ratepayers and as suppliers.

The Commission has found that participation in Commission proceedings by parties representing the full range of affected interests is important. Such participation assists the Commission in ensuring that the record is fully developed and that each customer group receives adequate representation. (See, for example, Ruling issued July 7, 1999, page 3, in A.98-09-003, et al.) Based on CARE's representations in its NOI, it is reasonable to assume that CARE has knowledge and experience that may support and complement the work of other intervenors.