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's participation did not unnecessarily duplicate efforts of other parties. In a proceeding involving multiple participants, it is virtually impossible to completely avoid some duplication of the work of other parties; however, UCS made a diligent and effective effort to minimize the duplication in a variety of ways. Among other things, UCS coordinated its work with California Wind Energy Association, Natural Resources Defense Council, Center for Energy Efficiency and Renewable Technologies, etc. UCS also filed joint comments on June 1, 2009, with Green Power Institute. Another evidence of the effort to avoid duplicating its participation with other parties' was UCS's distinctive position on or unique approach to, the proceeding's issues.
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.