3. NOI to Claim Compensation

Aglet filed an NOI to claim compensation in this proceeding as required by Section 1804(a). Aglet represents residential and customer interests that would otherwise be under-represented in this proceeding. While the Office of Ratepayer Advocates (ORA) was an active party, by charter ORA must represent the interests of all customers, not just residential and small commercial customers. The Utility Consumers Action Network (UCAN) also participated, representing only residential and small commercial customers, but UCAN did not actively participate in revenue allocation and rate design issues. Aglet and UCAN cooperated informally during the proceeding in order not to duplicate their efforts. We find that Aglet represented ratepayers who otherwise would have been under-represented, and that Aglet's efforts did not duplicate the efforts of others.