B.2. Customer Status

NRDC claims that it is a Category 3 customer since it is a "representative of a group or organization authorized pursuant to its articles of incorporation or bylaws to represent the interests of residential customers." (§ 1802(b).) In support, NRDC states that it is a non-profit membership organization with a long-standing interest in minimizing the societal costs of the reliable energy services that a healthy California economy requires. NRDC reports that it has participated in many Commission proceedings over the last two decades with particular interest in energy efficiency programs, renewable energy resources and other sustainable energy alternatives. NRDC says that it is a formally organized group authorized pursuant to its bylaws to represent the interests of its members, nearly all of whom are residential customers. Its Bylaws specifically authorize it to represent members' interests in regulatory and judicial proceedings, with a copy of the relevant items attached to its NOI (e.g., Bylaw § 1.02(a); Certificate of Incorporation at Part Two). NRDC further states that over 110,000 of its members live and purchase utility services in California, and it is certain that at least 40,000 of these members are residential customers of one of the three major California investor owned utilities.

NRDC is a Category 3 customer.