5. Contributions of Other Parties

Section 1801.3(f) requires an intervenor to avoid participation that duplicates that of similar interests otherwise adequately represented or for participation that is not necessary for a fair determination of the proceeding. Section 1802.5, however, allows full intervenor compensation for participation that materially supplements, complements, or contributes to that of another party if that participation makes a substantial contribution to the Commission decision.

The Commission agrees with TURN that, as the only organization who both represented the interests of consumers and supported the Joint Proposal for D.06-07-029, its work was neither unnecessary nor duplicative of the work of any other party.

The Commission also agrees with TURN that its work for D.07-09-044 and D.07-12-052 was neither unnecessary nor duplicative of the work of any other party. TURN explains how it only participated in those aspects of the proceeding related to the interests of consumers. Furthermore, TURN states that it consulted with other parties representing the interests of consumers, such as Division of Ratepayer Advocates and Aglet Consumer Alliance, to avoid addressing the same issues with the same concerns.