4. Contributions of Other Parties

Section 1801.3(f) requires an intervenor to avoid participation that unnecessarily 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 if its participation materially supplements, complements, or contributes to that of another party, if that participation makes a substantial contribution to the Commission order.

TURN specifically partnered with UCAN to avoid any duplication and combined resources to jointly litigate this application. The hourly summaries demonstrate that TURN staff performed the vast majority of the work in litigating on behalf of both organizations. Duplication is not an issue due to the manner in which TURN coordinated testimony, responses to SDG&E motions, case management activities, and hearing participation with DRA. The compensation request for TURN/UCAN in this proceeding should not be reduced for duplication of the showings of other parties.

Regarding contributions by other parties, we agree with TURN/UCAN that in a proceeding involving multiple participants, it is virtually impossible to completely avoid some duplication of the work of other parties. TURN states that it took all 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 very active party in this proceeding, DRA. (§ 1802.5.) TURN states that it collaborated closely with DRA throughout this proceeding.

After we have determined the scope of a customer's substantial contribution, we then look at whether the compensation request is reasonable.