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, 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.

WEM asserts that it has contributed substantial dollar benefits to ratepayers but notes that it would be impossible to assign an exact ratepayer dollar value to its participation. In particular, WEM asserts that it encouraged more accurate conservation need estimates; advocated for greater use of preferred resources (such as reasonably priced renewables and the lowest cost resource, energy efficiency) to avoid future penalties for unnecessary GHG emissions and to avoid higher costs (and GHG emissions); proposed that utilities cover "contingencies" with a short delay in aging power plant retirements as an alternative to building expensive new fossil-fuel power plants; and urged the Commission to prevent over-procurement by utilities. WEM 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 ratepayers benefit where a greater use of preferred resources is encouraged. We also agree that the outcome of the proceeding was improved by WEM's participation. Thus, we find that WEM's efforts have been productive.