6. 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.

UCS states that in a policy proceeding such as the subject rulemaking, particularly one concerned as much with environmental benefits as economic benefits, it is extremely difficult to estimate the monetary benefits of UCS's participation. UCS states that its contributions to critical renewable energy rules and regulations will benefit ratepayers. The Legislature found that increasing the amount of renewable energy resources "may promote stable electric prices, protect public health, improve environmental quality, stimulate sustainable economic development, create new employment opportunities, and reduce reliance on imported fuels," among other benefits.¹⁹ UCS further asserts that its work materially assisted the Commission in developing RPS program requirements what will result in the development of cost-effective renewable resources and as such has contributed to more productive and efficient expenditure of the billions of dollars of RPS-related expenditures. The UCS's work, therefore, can be expected to save ratepayers many times the cost of UCS's participation. We find that, in general, its participation was productive.

¹⁹ California Pub. Util. Code § 399.11(b); see also § 399.11(c).