4. Financial Hardship

In its NOI, San Luis Obispo Mothers for Peace asserted financial hardship. On April 9, 2003, ALJ Cooke ruled that San Luis Obispo Mothers for Peace had not yet met the significant financial hardship condition, and was required to make a showing of financial hardship in its request for compensation. San Luis Obispo Mothers for Peace supplemented its June 17, 2004 request for compensation to make this showing.³

An intervenor seeking compensation must show that, without undue hardship, it cannot pay the reasonable costs of effective participation in the proceeding. A participant representing consumers (Category 1) or a representative authorized by a customer (Category 2) must disclose the customer's finances to the Commission to make this showing. In the case of groups or organizations (Category 3), significant financial hardship is demonstrated by showing that the economic interest of individual members is small compared to the overall costs of effective participation. (§ 1802(g).) Such a finding is normally made in the ALJ's preliminary ruling on the customer's eligibility for compensation. (§ 1804(b).)

To qualify for a finding of significant financial hardship under Category 3, the relevant category for San Luis Obispo Mothers for Peace, the group must demonstrate that effective participation in this proceeding cost well in excess of typical bills for its individual members. In order to make that finding, we need to know the cost of participation and the average bills of the members of the organization, as well as the financial situation of the organization.

The average monthly bill of San Luis Obispo Mothers for Peace's member is less than $50, therefore, the economic interests of San Luis Obispo Mothers for Peace's individual members are small in comparison to the costs of effective participation in Commission proceedings. In addition, the cost of San Luis Obispo Mothers for Peace's participation in Commission proceedings substantially outweighs the benefit to an individual customer it represents. San Luis Obispo Mothers for Peace's members are residential customers whose individual interests in this proceeding small relative to the costs of participation. We find that San Luis Obispo Mothers for Peace has met the requirement to demonstrate significant financial hardship.

San Luis Obispo Mothers for Peace has satisfied all the procedural requirements necessary to make its request for compensation.