7. Productivity

D.98-04-059 directed customers to demonstrate productivity by assigning a reasonable dollar value to the benefits of their participation to ratepayers. 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 notes that its work towards D.06-07-029 dealt primarily with the allocation of costs and benefits among different types of customers. TURN asserts that at minimum there were tens of millions of dollars in costs at stake over a period of 10 years. TURN argues that it was overall successful in assuring that bundled service customers would not be forced to bear an excessive share of the costs of constructing new generation projects that provide reliability benefits to all customers, both bundled and unbundled. Through its advocacy, TURN claims to have assured small bundled service customers a reasonable degree of protection from cost shifting. The Commission agrees with TURN that the protection afforded to this class of consumer, in part through TURN's participation, is substantial, although difficult to quantify. Thus the Commission finds that TURN's efforts have been productive.

TURN states that its work in D.07-09-044 and D.07-12-052 dealt primarily with broad policy issues and as such is extremely difficult to quantify. TURN noted its overall participation in Phase II of the proceeding and particularly its work in assuring that the utilities would not receive authorization to procure an unnecessarily large amount of new conventional resources. The Commission agrees with TURN that its participation, while not easily quantifiable, had real and substantial effects on ratepayer costs. Thus the Commission finds that TURN's efforts have been productive.