What is the ORA?

I keep running across references to the ORA/DRA, which stands for Office of Ratepayer Advocates (formerly Division of Ratepayer Advocates). Spokespersons from ORA are frequently quoted in news stories about water issues, and they seem to get involved in various legal proceedings in front of the California Public Utilities Commission (CPUC). Who are these people?

Turns out, ORA is an agency within an agency. ORA is mandated under state law, and is described as an independent entity within the CPUC advocating on behalf of utility ratepayers. In other words, the ORA is charged with protecting the interests of ratepayers vs. utility companies like Cal-Am. You read that right...ORA exists within the CPUC to advocate for consumers. Isn't that what the CPUC does? According to its website, the CPUC's mission is to "serve the public interest by protecting consumers and ensuring the provision of safe, reliable utility service and infrastructure at reasonable rates."

So if a utility company, let's say, Cal-Am, wants to add a surcharge to water bills to pay for some project, it must apply to the CPUC for permission. The ORA then (usually) takes the other side, and argues against the increase. But it's part of the CPUC, so it's kind of arguing to itself. I guess the point is that the utility comes in with all of its reasons why it needs the increase, and somebody has to say why the increase is unreasonable. Seems like a strange system.