5. Contributions of Other Parties

Section 1801.3(f) requires an intervenor to avoid unnecessary participation that duplicates that of similar interests otherwise adequately represented by another party, or 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.

We note that some amount of duplication is unavoidable on all sides of contentious issues in a proceeding with such a broad scope. However, by focusing its comments on issues to which it could present unique research, analysis or arguments, we find that GPI took reasonable steps to avoid duplication to the extent possible, and to complement and assist the work of other parties.