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.

CHCC states that it's difficult to assign a dollar value to its participation in this rulemaking which was focused on the benefits achieved through increased diversity. In addition, CHCC submits that its contributions to the D.11-05-019 will increase the success of the GO 156 program and overall procurement from WMDVBE businesses by the utilities. CHCC argues that its contributions to the Decision specifically include measures that will increase transparency in the program, increase education and outreach to WMDVBE's, and increase methods by which to include qualified WMDVBEs through capacity-building mechanisms, CHCC argues that the magnitude of the benefits resulting from the decision to WMDVBE's, including those represented by CHCC, while not quantifiable, will include tangible economic benefits to ratepayers that comes with increasing diversity in procurement. Accordingly, CHCC submits that its work in this rulemaking can be expected to save ratepayers many times the cost of its participation and asks that the Commission find that CHCC's participation was productive.

Since diversifying the supply chain results in local and statewide economic stimulus and job creation, particularly with respect to communities of color, the ratepayer savings along with these economic benefits are likely to exceed the cost of CHCC's participation in the proceeding. After the adjustments and disallowances we have made to this claim, we find that CHCC's efforts were productive.