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 Aglet that in a proceeding involving multiple participants, it is virtually impossible to completely avoid some duplication of the work of other parties. Aglet 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 parties in this proceeding, DRA and TURN. (§ 1802.5.) Aglet states that it collaborated closely with DRA and TURN throughout the mediation sessions held from January 10, 2007 to May 14, 2007. We find that Aglet has reasonably avoided duplicating the work of other participants.

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.