5. 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.

DisabRA, Greenlining, and A W.I.S.H. claimed that they each collaborated closely with each other and other intervening parties, when appropriate, throughout this proceeding, coordinating meetings and filings, workshops, analysis of applications, and discussions with parties. Each explained that the modest overlaps between the intervening parties do not reflect excessive duplication, rather such seeming overlaps are evidence of active cooperation and coordination to facilitate constructive and efficient public dialogue.

This proceeding required high-quality and quickly delivered public policy analysis and recommendations, all of which were critically important to the process leading to the final decision. To that end, DisabRA, Greenlining, and A W.I.S.H. state that they each took all reasonable steps to coordinate with all parties while keeping duplication to a minimum and to ensure that its work served to supplement, complement, or contribute to the showing of the other very active parties in this proceeding. The record of the proceeding, as well as the requests detailing the work, generally confirms this. The record is clear that Greenlining and A W.I.S.H. were the leading intervenors with broader interests and issues they championed on behalf of the low-income customers. DisabRA, as the advocacy group for persons with disabilities, played a formidable role in the proceeding to assure the unique interests of low-income persons with disabilities were not overlooked.

We agree with the intervenors that in this proceeding which involved multiple participants, it was virtually impossible to completely avoid some duplication of the work of other parties. Moreover, the record shows that DisabRA, Greenlining, and A W.I.S.H. each made a substantial contribution in their respective roles, in this consolidated proceeding, by constructively adding to the discussion while minimizing unnecessary duplication.