6. Contributions of Other Parties

Section 1801.3(f) requires an intervenor to avoid participation that duplicates that of similar interests otherwise adequately represented by another party, or participation unnecessary for a fair determination of the proceeding. Section 1802.5, however, allows an intervenor to be eligible for full compensation where its participation materially supplements, complements, or contributes to the presentation of another party if that participation makes a substantial contribution to the Commission order.

Aglet submits that it contributed to these proceedings in a manner that did not repeat the work of other parties. As a matter of policy, Aglet states that it does not participate in Commission proceedings where it is likely to hold the same positions as other customer representatives such as TURN and DRA. For example, Aglet says it did not serve testimony in Phase 3 of the long-term plan proceeding, R.06-02-012, because Aglet's showing would likely have duplicated the showings of TURN and DRA.

Aglet and TURN were the sole parties to represent only residential and small commercial customers. Although the DRA was also an active party, it represents the interest of all customers, not only residential and small commercial customers. Aglet asserts it made a conscious effort to avoid duplication of the DRA's work in its showing. Aglet worked with DRA to reduce its costs of participation by producing joint filings with DRA on the issues of contract price, benchmarks, cost recovery and contract pre-approval. In addition, Aglet says it conferred with TURN on several occasions on the issue of short-term contract benchmarks.

We affirm that Aglet took reasonable steps to keep duplication to a minimum and to ensure that its work served to supplement, complement, or contribute to the showing of the other very active parties in these rulemaking proceedings. No reduction for duplication is warranted.

After we have determined the scope of a customer's substantial contribution, we then look at whether the amount of the compensation request is reasonable.

6.1. Allocation of Time by Major Issue

Aglet breaks down its compensation by major issue as follows:

Cost Category	Requested Compensation Hours
General Work	13.4
Issue Specific Work:
Commercial Operation	2.1
Contract Pre-Approval/Cost Recovery	5.1
Integrated Resource Plans	11.7
Price Benchmarks	15.4
Reporting	5.9
Short Term Market Price Referent	25.2
Transparency	9.2
Issues Sub-Total	74.6
Total	88.0