8. Productivity

D.98-04-059 directed customers to demonstrate productivity by assigning a reasonable dollar value to the benefits of their participation to ratepayers. (D.98-04-059 at 34-35.) The costs of a customer's participation should bear a reasonable relationship to the benefits realized through its participation. This showing assists us in determining the overall reasonableness of the request.

Sustainable Conservation submits that they worked efficiently through the electronic filing and serving of its documents by using the Commission's e-file system to reduce costs. Sustainable Conservation incurred minimal postage costs, but makes no request for reimbursement.

Sustainable Conservation states that its emphasis in this proceeding has been to represent customers with a concern for the environment and sustainable agricultural practices, particularly renewable energy that reduces methane emissions. This focus distinguished the organization's interest from the interests represented by other consumer and environmental advocates who intervened in this case, according to Sustainable Conservation. Through its participation, Sustainable Conservation enhanced the Commission's understanding of the issues that should be considered as the Commission deliberates on how to increase the amount of small renewable distributed generation in California. Although a monetary benefit to taxpayers cannot be precisely identified, we agree that through Sustainable Conservation's participation, many social benefits are addressed which, though hard to quantify, are substantial. Thus, we find that Sustainable Conservation's efforts have been productive.

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