4. Financial Hardship

Section 1802 (g) provides in relevant part that "significant financial hardship" in the case of a group such as GSMOL means that the economic interest of the individual members is small in comparison to the costs of effective participation.

GSMOL states in its July 13, 2001 request for compensation that it is a voluntary nonprofit mutual benefit corporation that depends entirely upon membership dues and voluntary contributions for its existence. Membership is $15.00 per year, which entitles its approximately 30,000 members to receive a newsletter that is published every month and representation in cases such as this investigation. GSMOL states that for the calendar year 1999 its donations and membership fees were approximately $495,000, and its total expenses, which included most of its cost of participation in this proceeding, were approximately $508,000. It is clear to us that GSMOL has a financial hardship under § 1802(g). Even were GSMOL to devote itself primarily to participating in this proceeding, there would be little remaining in its budget for any other activity. Furthermore, the cost of effective participation would greatly exceed any possible benefit as reflected in the bills of individual members.