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. (D.98-04-059, pp. 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.

7.1. NRDC's Productivity

NRDC states that its emphasis in this proceeding has been to improve the effectiveness of the water-energy efficiency pilot programs and increase net benefits to customers. It concedes it cannot identify precise monetary benefits to ratepayers. However, NRDC claims, its focus on policies that ensure a reliable, affordable and environmentally sustainable energy resource portfolio should have lasting benefits to ratepayers. We agree that to the extent energy usage is lowered through water-energy efficiency programs, ratepayers benefit monetarily by avoiding increased energy procurement costs. We also agree that these programs, improved through NRDC's participation, have other social benefits which, though hard to quantify, are substantial. Thus, we find that NRDC's efforts have been productive.

7.2. TURN's Productivity

Akin to NRDC's contribution, TURN's contributions to D.07-12-050 were directed primarily at policy matters, rather than the establishment of specific rates, funding levels, or disputes over particular dollar amounts. As such, it is naturally difficult to quantify the precise monetary benefits to ratepayers resulting from TURN's efforts here.

However, TURN contends that its participation yielded some significant tangible and quantifiable monetary benefit to the rate payers and we agree. For instance, TURN contends that it saved PG&E's ratepayers $2,447,063, the entire amount of PG&E's contribution to the pilot activities ordered by D.07-12-050. PG&E had initially proposed to collect these funds from ratepayers. The record of the proceeding confirms that TURN's efforts substantially contributed to the discussions leading to PG&E's revised proposal to ultimately use existing, unspent EE funds instead of raising new revenues by collecting these funds from the ratepayers. The record also shows TURN saved the ratepayers of SDG&E and SoCalGas $25,000 (each) by successfully opposing both utilities' motions for authorization to spend this amount on start-up activities prior to the Commission's approval of each utility's pilot activities. The Commission agreed with TURN that such spending authorization would be premature. (Assigned Commissioner's Ruling, February 15, 2007, p. 6.)

Aside from these quantifiable benefits, TURN also contends that its active participation benefited ratepayers by overall shaping and directing of a meaningful public policy debate, leading to the establishment of EE policies. TURN contends its participation benefited the ratepayers by raising multitude of significant issues and affecting the discussion such that a full record is developed here.

We find that TURN's efforts were highly productive in yielding a number of significant, quantifiable, and less quantifiable benefits to the ratepayers by its active role leading to the D.07-12-050, as well as in some specific and substantial monetary savings as discussed above.