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. The costs of a customer's participation should bear a reasonable relationship to the benefits realized through its participation. (D.98-04-059, at 34-35.) This showing assists us in determining the overall reasonableness of the request. In D.98-04-059, the Commission adopted a requirement that a customer must demonstrate that its participation was "productive," as that term is used in § 1801.3 (at 31-33).

The Commission directed customers to demonstrate productivity by assigning a reasonable dollar value to the benefits of their participation to ratepayers. While NRDC contributions can be difficult to quantify in monetary terms, NRDC's focus on policies that ensure a reliable, affordable and environmentally sustainable energy resource portfolio should have lasting benefits to ratepayers.

If the energy savings goals as adopted by D.08-07-047 are met, NRDC estimates savings from 2012-2020 will reduce GHG emissions by approximately 5.0 to 7.6 million metric tons of carbon dioxide. NRDC also projects that avoided regulatory costs due to reductions in GHG emissions would reach $150 million to $228 million. NRDC estimates that if the energy efficiency goals are met and net benefits per kilowatt-hour saved are similar to the average for IOU programs from the start of the 2006-2008 program cycle to present day, these goals will produce a net benefit of over $2 billion.

NRDC's participation and contribution in the PRG process is likewise difficult to quantify in monetary terms. We can foresee, however, that ensuring a fair and transparent solicitation process, developing criteria for third-party and local government programs, and reviewing program submittals within PRG process will enhance energy efficiency programs leading to increased savings for ratepayers.

We believe NRDC's participation in this proceeding was productive.