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Arizona State Law Journal

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The purpose of this article is to analyze how the political system of public utility regulation operates and to develop a model of advocacy for quality representation of low-income consumer groups in these proceedings." My focus will not be on specific techniques for persuading regulators in particular situations, but rather will be on analytic methods for planning a persuasive presentation to a commission. ...

This article develops a framework for case planning; it does not craft a trial plan for every possible public utility commission case. It is impossible to predict with certainty how a particular commission is going to rule in a specific case. Even within the same commission, there may be differences from one regulatory context to another or in the commission's treatment of one utility compared to another. Because the focus of this article is on general methods for preparing a case, an attorney will have to adapt this model to the particular circumstances of a case.