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.

IAG states that it coordinated its efforts with the DRA, TURN and the Greenlining Institute (Greenlining) on several occasions in an attempt to avoid duplication of efforts and also to reiterate the scope of its planned participation on the Lundy Project. IAG submits that no duplication of efforts occurred in this proceeding as none of the other parties presented testimony regarding the
Lundy Project. In addition, IAG alleges that no other party introduced evidence on this subject or provided for the cross-examination of witnesses.

In its NOI, IAG indicated that it would not participate in the rate design portion of the case because of the likelihood of duplication of efforts with other parties. IAG's argued that its efforts would be directed only to the revenue requirement phase of the proceeding, an area where IAG believed its presentation would be unique and not be duplicated by the other parties.

We affirm that IAG 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 active parties in this proceeding. As such, no reduction for duplication is warranted.

We have determined the scope of a customer's substantial contribution. We now examine the reasonableness of the compensation request.