4. Contributions of Other Parties

Section 1801.3(f) requires an intervenor to avoid participation that unnecessarily 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 if its participation materially supplements, complements, or contributes to that of another party if that participation makes a substantial contribution to the Commission order. DRA was the only other party representing the interests of ratepayers. Although in some instances the positions of TURN and DRA were similar, TURN's participation did not unnecessarily duplicate that of DRA.