Significant Financial Hardship

As discussed above, Local 483 may be eligible under any of the three categories of "customer" identified by section 1802(b). In the Intervenor Compensation Order we articulated a bifurcated approach to "financial hardship."⁸ Entities seeking eligibility under categories (i) and (ii) - participants representing consumers generally and representatives expressly authorized to represent a consumer or group of consumers, respectively - must meet a "cannot afford to pay" standard. This standard requires a customer to provide detailed financial information, under seal, for Commission review. Local 483 has not made such a showing.

Entities seeking eligibility pursuant to category (iii) - an organization authorized by its by-laws - may utilize a "comparison" test, in which the cost of participation is compared to the economic interest of the individual members of the organization. Local 483 has made a hardship claim more appropriate to

customer status under category (iii): a representative of a group or an organization authorized in its articles of incorporation or bylaws to represent the interests of residential customers. The proposed budget for participation described below is several orders of magnitude larger than the annual costs for an average residential ratepayer of SDG&E or SoCalGas. Since Local 483 is acting as a representative of its members in their capacities as residential ratepayers, this is a sufficient showing to establish financial hardship under § 1802(g). We will not require any further detail of individual members' utility bills.