5. 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.

As a general matter, TURN asserts that it took all reasonable steps to keep duplication to a minimum, and to ensure that when it did happen, TURN's work served to complement and assist the showings of the other parties. TURN further asserts that any incidental duplication that may have occurred here was more than offset by TURN's unique contributions to the proceedings.

More specifically, TURN first notes that with respect to the avoided cost issues in Phase 1 of R.04-04-025, DRA did not participate and TURN was the sole representative of the residential and small commercial ratepayers of PG&E, SCE, SDG&E, and SoCalGas. Second, TURN points out that in the GHG phase of
R.04-04-003 this Commission directed all parties to set forth their position on all of the substantive issues presented. Consistent with our directive each party, including TURN, submitted separate comments and participated independently in the workshops. Finally, TURN relates that during the 2006 Update Phase, TURN, DRA and the utilities were the only active parties. While TURN and DRA represented overlapping interests, TURN notes that it collaborated closely with DRA to minimize duplication, and jointly prepared and filed two sets of comments. TURN asserts that this coordination reduced both entities' workload and resulted in increased efficiency. In addition, this coordination allowed TURN and DRA to address different issues. By way of example, TURN notes that it did not address the proper functioning of the SPM cost-effectiveness test because it knew that DRA would comprehensively address that issue.

We agree with TURN's assessment and, regarding contributions by other parties, further note that in a proceeding involving multiple participants, it is virtually impossible to completely avoid some duplication of the work of other parties. TURN states that it took all 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 active party in this proceeding, DRA.
(§ 1802.5.) TURN states that it collaborated closely with DRA throughout these proceedings, coordinating discovery, analysis, and discussions. We therefore find that there was no unnecessary duplication of effort in these proceedings.