C.4. Nature and Extent of Planned Participation

AECA does not specifically and separately identify the nature and extent to its planned participation. In stating its total estimated budget, however, AECA says: "In preparing testimony, general participation, appearances at hearings and cross-examination, and briefing, AECA estimates..." (AECA NOI, page 3.)

This statement is not unlike that of TURN and NRDC. As with TURN and NRDC, AECA meets the requirement that it state the nature and extent of its planned participation as far as it is possible to set out when the NOI is filed.

AECA does not, however, make a reasonable assertion that it will minimize unproductive or unnecessary participation. Future compensation, if any, may be influenced by the extent to which AECA avoids unproductive or unnecessary participation.

Also, in future NOIs AECA should-as should each interevenor-identify as specifically as it can the issues it intends to address in order to "help all parties to see whether others are planning to address the same issues." (Intervenor Compensation Program Guide, pages 6-7.) This might include, for example, citing the subset of issues identified in the Scoping Memo which it intends to address.