A.3. Adequacy of Representation
TURN asserts that Aglet and TURN are the only intervenors exclusively representing the interests of residential customers, who by number represent the vast majority of applicant's customers.5 TURN states that the Commission's Office of Ratepayer Advocates (ORA) will represent the interests of all classes of customer, but that only "TURN and Aglet are the sole representatives of the residential class." (TURN NOI at page 2.)
The Commission has found that participation in Commission proceedings by parties representing the full range of affected interests is important. Such participation assists the Commission ensure that the record is fully developed and that each customer group receives adequate representation. (See, for example, Ruling issued July 7, 1999, page 3, in A.98-09-003, et al.) Based on its long history of successful participation before the Commission, it is reasonable to conclude that TURN has knowledge and experience that may support and complement the work of ORA or others.
5 Aglet is not an appearance in this proceeding at this time.
