VIII. 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 that participation. This showing assists us in determining the overall reasonableness of the request.

A. 280 Citizens

280 Citizens did not quantify the benefits of its participation to ratepayers, noting that the Commission has recognized that it can be difficult, if not impossible, to assign specific ratepayer benefits to the contributions of intervenors in proceedings involving non-economic issues where no revenue requirement, revenue allocation, or rate design is at issue. (See D.01-11-023.) We agree that it is difficult to assign specific ratepayer savings to 280 Citizens contribution in this proceeding. Nonetheless, it is clear that ratepayers have benefited because 280 Citizens' participation assisted the Commission in updating its EMF mitigation policy, improving utilities' design guidelines, and recommending a procedure for continuing to assess new scientific data. 280 Citizens also points out that the likely capital costs of electric facilities affected by EMF mitigation measures significantly exceed 280 Citizens' compensation request. The Commission finds that 280 Citizens' participation in this proceeding has been productive.

B. Kheifets

Kheifets' states that her participation provided a unique expertise on EMF issues, as she was the only party to be a member of both national and international research groups and committees on EMF. Kheifets states that her most valuable contribution was to focus attention on the adequacy of the current low-cost/no-cost reduction measures and policies adopted worldwide.

We agree. Although Kheifets cannot identify precise monetary benefits to ratepayers, her participation reinforced our adoption of low-cost/no-cost mitigation policies. As a consequence, utility spending on mitigation measures is made more efficient, and effective, and thus ratepayers benefit. Thus, we find that Kheifets efforts have been productive.

C. CCAE

CCAE contends that CCAE's cost of participation significantly exceeds the expected capital expenditures and EMF mitigation measures associated with future electric utility facilities. CCAE also points out that this proceeding dealt with policy issues rather than specific revenue requirements and thus assigning a dollar value to participation is impractical.

CCAE is correct, as we cannot assign specific dollar values to its participation. However, we find that CCAE's recommendations assisted us in determining how to apply mitigation costs to different customer classes, and in a methodology for reviewing utility design guidelines. We expect that improvements in utility design guidelines will result in significant savings to ratepayers. Thus, we find that CCAE's efforts have been productive.