4. 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.

CFC actively avoided duplication with other parties by working with the other consumer groups to jointly address issues where their positions were in accord with each other. When CFC filed separately, it generally took positions that provided unique contributions enriching the Commission's deliberations and contributing to the proceeding.

On the issues where CFC's position coincided with that of other parties, we find that only limited duplication occurred, as discussed above, since CFC's recommendations or supporting argument materially supplemented, complimented, or contributed to the presentation of those parties. We conclude that it would have been virtually impossible to avoid some duplication among these parties, and, therefore, we decline to reduce the award further for unnecessary duplication of the effort.