8. Productivity

GPI submits that although the decisions in this and predecessor rulemakings did not offer GPI the opportunity to demonstrate specific monetary benefits to residential customers, it argues that the enactment of the Commission's RPS program is premised, in part, on the assumption of reduced risks of price spikes to ratepayers. In addition, GPI believes that some of the most important benefits of the RPS program are in the areas of environmental and health improvements, and that these benefits will only arises should the rules and procedures adopted in these proceedings eventually lead to the achievement of the RPS program goals. In the absence of explicitly defined financial benefits, GPI states that the Commission has previously recognized the overall benefit of the participation of consumer and environmental intervenors where that participation assisted the Commission in developing a record on which to assess the reasonableness of the utility's operations, and in particular, its preparedness and performance in the future.

While we cannot quantify the benefits of GPI's substantial contributions, we believe it is likely that the future benefits to ratepayers will exceed the amount awarded to GPI by today's decision. We find that GPI's participation in these proceedings have been productive.