6. Productivity

One of the requirements for receiving intervenor compensation is that an intervenor's advocacy is necessary for a fair determination of the proceedings. In D.98-04-059, the Commission further defined this standard as requiring the party to weigh the costs of its participation against the benefits of that participation.

CARE submits that in a policy proceeding such as this one with concerns about environmental and economic benefits, it is extremely difficult to derive a monetary benefit from CARE's participation. CARE states that its contributions to the Commission's Greenhouse Gas reduction policy framework will help protect customers from financial risks associated with the likelihood of the federal regulation of greenhouse gases. CARE believes that the magnitude of such risks could easily be on the order of billions of dollars. Moreover, it contends that the Commission's adoption of certain of CARE's positions and recommendations regarding performance incentives and penalties will ensure that the net societal benefits associated with this Decision and related successor decisions will be enhanced. Given the scale of IOU investments and customer costs that are likely to be influenced by the Decision, CARE submits that its work in Application 07-02-026 can be expected to save ratepayers many times the cost of its participation in this proceeding, thus confirming that CARE's overall participation was productive.

In this light, we agree that the benefits of CARE's participation have other social benefits which, though hard to quantify, are substantial. Thus, we find that CARE's efforts have been productive.