7. Productivity

In D.98-04-059, we 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.

TURN's contributions to R.04-04-025 and R.04-04-003 were directed primarily at policy matters, rather than the establishment of specific rates, funding levels, or disputes over particular dollar amounts. For example, TURN's efforts in Phase 1 and the 2006 Update Phase of this proceeding focused on ensuring that the avoided costs associate with energy efficiency programs are fairly and accurately valued, so as to promote the use of energy efficiency instead of more costly supply side resources. Thus TURN's participation benefited ratepayers because the establishment of energy efficiency policies can have a direct and lasting impact on customer rates.

While TURN appears to concede that it cannot identify precise monetary benefits to ratepayers, TURN claims its focus on policies will promote long-term rate stability, reduce risks to ratepayers and contribute to resource diversity that should help to mitigate the impact of future market dysfunction and have lasting benefits to ratepayers. We agree that appropriate energy efficiency and integrated resource planning policies practices will be essential to maintaining both low and stable rates. We also agree that these policies, improved through TURN's participation, have other social benefits which, though hard to quantify, are substantial. Thus, we find that TURN's efforts have been productive.