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.

Aglet contributed to the proceeding in a manner that was efficient and did not repeat the work of other parties. Specifically, Aglet coordinated its efforts with DRA, TURN, and UCAN. (See D.08-07-046, at 12, that TURN, UCAN, and Aglet "appear to have coordinated on many issues.") Aglet also participated in settlement negotiations that were ultimately successful.

The time sheets submitted by Aglet for James Weil indicate coordination efforts (conference calls and joint filings of joint motions) with DRA, TURN, and UCAN. To avoid duplication issues, Aglet, TURN, and UCAN agreed that Aglet would focus on attrition issues, which allowed TURN and UCAN to devote their resources to other issues. TURN submitted very little testimony regarding attrition or post-test year ratemaking. UCAN's showing concentrated on SDG&E, leaving SoCalGas attrition issues to Aglet and other customer representatives. The Commission affirms Aglet's assertion that it made significant efforts to avoid duplication in this proceeding.

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.