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.

Regarding contributions by other parties, we agree with TURN and UCS that in a proceeding involving multiple participants, it is virtually impossible to completely avoid some duplication of the work of other parties. TURN and UCS state that they took all reasonable steps to keep duplication to a minimum and to ensure that the work of each served to supplement, complement, or contribute to the showing of the other active parties in this proceeding. (§ 1802.5.) TURN and UCS state that they collaborated closely with other parties throughout this proceeding, coordinating analysis, preparation of comments, and discussions with other parties. TURN and UCS jointly prepared an Application for Rehearing of D.07-05-028. TURN and UCS would have found it counterproductive to have taken any additional steps to reduce duplication in a proceeding such as this where high-quality, quickly delivered analysis and recommendations were critically important.

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.