6. Duplication

Section 1801.3(f) provides that an intervenor will not be compensated for participation that (1) duplicated that of other parties representing similar interests, or (2) is unnecessary for a fair determination of the proceeding. However, if there is overlapping participation between parties, § 1802.5 provides that an intervenor may be eligible for compensation if its participation materially supplements, complements, or contributes to the presentation of other parties.

GPI believes no reduction for duplication of effort is warranted because it not only coordinated its efforts with other parties to avoid duplication of effort, but in several cases, it filed joint pleadings with other parties in an effort to avoid duplication.

We make no reductions to GPI's claim for duplication of effort as we find that GPI neither duplicated the work of other parties representing similar interests nor participated in this proceeding in a way that was unnecessary for a fair determination of the proceeding.

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