B.4. Nature and Extent of Planned Participation

NRDC states that it will be an active participant, and has an extended history of working to minimize the societal costs of reliable energy services. NRDC says it will participate actively in all phases of this proceeding including hearings, plus submission of briefs and comments. NRDC further says it will coordinate its participation with other parties to avoid duplication.

NRDC 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. It makes a reasonable assertion that it will minimize unproductive or unnecessary participation. In future NOIs,NRDC 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.