6. Productivity

Decision 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. We also note that in a proceeding involving hundreds of participants, it is virtually impossible for any party to completely avoid some duplication of the work of other parties. The Commission has noted that duplication may be practically unavoidable in a proceeding such as this where many stakeholder groups are encouraged to participate.

6.1. NRDC

NRDC's says its focus in this and other proceedings is on policies that ensure a reliable, affordable, and environmentally sustainable energy resource portfolio that has lasting benefits to ratepayers. NRDC acknowledges it can be difficult to quantify its contribution in monetary terms, but argues its contributions to the ambitious goals set forth in the strategic plan will result in energy and monetary savings to ratepayers. Therefore, we find that NRDC's participation in this proceeding was demonstrably productive.

6.2. CEC

CEC says the guiding principle in its work is to ensure that the Commission's EE programs achieve real energy savings, thus reducing greenhouse gas emissions, reducing the need for new fossil fuel generation, and saving ratepayers money. Although CEC cannot identify precise monetary benefits to ratepayers stemming from its contributions to these proceedings, it contends that the long-term energy efficiency savings goals adopted by the Commission will, if implemented by the IOUs wisely, save ratepayers considerable sums. Therefore, we find that CEC's participation in this proceeding was demonstrably productive.

6.3. WEM

WEM says it would be impossible to assign an exact amount of ratepayer dollar value to WEM's participation, so the Commission should treat this compensation request as it has treated similar past requests with regard to the difficulty of establishing specific monetary benefits associated with other parties' participation.

Nonetheless, WEM points to some specific recommendations that will likely yield ratepayer savings. The primary WEM recommendations were for the Commission to take charge of developing the Strategic Plan to avoid cost of litigation if the utilities had remained in charge and promoting energy efficiency in reducing the need for more expensive supply-side resources. Other recommendations that will likely lead to greater energy savings include involving public, nonprofit agencies to avoid the need for utility incentives, and reducing peak load, HVAC and lighting demands. WEM also states there are non-monetary benefits for providing for more inclusive collaboration amongst all California entities in energy efficiency. Therefore, we find that WEM's participation in this proceeding was demonstrably productive.

6.4. Greenlining

Greenlining did not specifically address its productivity and is cautioned that in future RFCs it must explicitly address this requirement. We are able to infer from Greenling's NOI and Request similar elements to the productivity discussions above. Greenlining submits it provided unique and critical advocacy at all phases addressing consumer protections for low-income and minority ratepayers. To the extent that it cannot identify precise monetary benefits to ratepayers stemming from its contributions to these proceedings, the Commission has recognized above that the long-term energy efficiency savings goals adopted by the Commission will, if implemented by the IOUs wisely, save ratepayers considerable sums. This will have a disproportionately positive impact on the low-income ratepayers on whose behalf Greenling advocates. Therefore, we find that Greenlining's participation in this proceeding was demonstrably productive.