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.

UCS claims that it consistently coordinated its efforts in this proceeding with other parties to avoid duplication of effort and ensure efficiency. Any duplication that occurred was unavoidable due to parties' sometimes similar interests, and the overwhelming number and scope of issues addressed in this proceeding. UCS coordinated with several parties over the course of this proceeding, and jointly filed its comments with Environmental Defense Fund (ED), Western Resource Advocates (WRA), and/or GPI but mostly with NRDC.

NRDC asserts that its compensation should not be reduced for duplication of the other parties' efforts. NRDC claims it was one of only a few non-profit environmental groups that participated in the proceeding, and NRDC made a concerted effort to avoid duplication with other parties with similar interests in environmental issues. NRDC coordinated and collaborated very closely with UCS, and coordinated with other groups whenever its views were similar enough to submit joint comments. NRDC asserts that even in the instances of the joint comments, it provided its expertise focused on issues unique to NRDC among environmental groups, such as energy efficiency.

We agree with NRDC and UCS that in a proceeding involving multiple participants, it is virtually impossible to completely avoid some duplication of the work of other parties. We find, however, that NRDC and UCS each and jointly 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. (Section 1802.5.)

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.