Significant Financial Hardship

Only those customers for whom participation would impose a significant financial hardship may receive compensation. Section 1802(g) defines "significant financial hardship as either":

"that the customer cannot without undue hardship afford to pay the costs of effective participation, including advocate's fees, expert witness fees, and other reasonable costs of participation, or that, in the case of a group or organization, the economic interest of the individual members of the group or organization is small in comparison to the costs of effective participation in the proceeding.

DRA's request for compensation includes its showing of financial hardship. DRA states that:

"Although the medical baseline allowance issue is of critical importance to individuals with disabilities, the cost of participating in the proceedings would have been prohibitive for individual energy consumers and in excess of the benefit each individual might receive from participation in the proceedings. Individuals with disabilities experience a much higher rate of poverty than those without disabilities and therefore participating in the Commission's proceeding would have been extremely burdensome if not impossible for these individuals."

DRA's members are residential customers whose individual interests in this proceeding are small relative to the costs of participation and the cost of DRA's participation in Commission proceedings substantially outweighs the benefit to any individual customer it represents. DRA meets the requirements of § 1802(g).