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.
In a proceeding involving multiple participants, it is virtually impossible to completely avoid some duplication of the work of other parties. GPI 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 active parties in this proceeding. (§ 1802.5.) GPI further states that it coordinated its efforts with those of the other parties. Given the unique contributions GPI made and the perspective they represented, we find no unnecessary duplication.