Under Ins. Code § 1861.10, who has standing to formally intervene in a California rate-approval proceeding before the Commissioner?

Why this is the answer

Ins. Code § 1861.10(a) confers extraordinarily broad standing — 'any person' may initiate or intervene in any proceeding under the Prop 103 chapter, may challenge a Commissioner action, and may seek to enforce the chapter. There is no requirement of competitive injury, agency status, or industry affiliation. The same provision authorizes the Commissioner to award reasonable advocacy and witness fees to an intervenor who makes a substantial contribution to the outcome. This intervenor-fee mechanism finances consumer advocacy groups (e.g., Consumer Watchdog) that routinely participate in rate filings. See Ins. Code § 1861.10.