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.

Reid asserts that he contributed his unique analysis and work product to the PRG, including the use of his Black model. Among the PRG members, Reid holds a M.S. degree in Applied Economics and Finance, completed courses in risk management, regulation, negotiation, and project management. He developed financial models and testified in the Commission proceedings. Reid asserts that his contributions were different from the work of other PRG members as he focused on subject areas consistent with his expertise, and provided independent estimates of the cost-effectiveness of various contracts. Because Reid is an economist, his work tended to focus on the underlying economics of various utility proposals, while other group participants focused on other aspects of PG&E's proposals.

Reid indicates that he collaborated with a number of PRG members during the subject period of time. Reid's time records reflect his communications with the Energy Division and Division of Ratepayer Advocates' staff. Reid also communicated with representatives of The Utility Reform Network and Coalition of California Utility Employees. Reid notes that he does not request compensation for many of these communications.

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.