Eligibility for costs

Section 3.1 of Rule 022 currently provides that the Commission may award costs to an intervener or a group of utility customers that has a substantial interest in the subject matter of a proceeding and who does not have the means to raise sufficient financial resources to enable the intervener to present its interest adequately in the proceeding. 

Section 4 provides a list of types or classes of interveners that are ineligible to claim costs unless the Commission orders otherwise. 

1. Should eligibility for interveners and utility customer groups be expanded or reduced beyond the financial need criterion in Section 3.1?
2. If so, what change(s) should be made and why?
3. Should the list of ineligible interveners in Section 4 be changed?
4. If so, what change(s) should be made and why?
5. Does the current system allow costs awards to parties representing substantially the same interests and therefore result in duplicative funding?
6. If so, how is such duplication best addressed?
7. In the interests of accountability and transparency, what should the Commission do to ensure intervention adequately and fairly represents customers who will be impacted by a particular application?
8. For example, should eligibility for cost recovery by a customer group require a description of that group’s membership, governance structure and sources of funding?