C.3. Adequacy of Representation

AECA states that it will represent and advocate the interests of agricultural customers. As noted above, the Commission has found that participation in Commission proceedings by parties representing the full range of affected interests is important. Moreover, customers with a specific concern (e.g., agricultural interests) have the potential to reasonably distinguish this interest from the interests represented by other groups. Further, it is reasonable to conclude that AECA has knowledge and experience that may support and complement the work of others.

AECA states that as part of a later significant financial hardship showing it "will also address issues related to whether it represents customer interests that would otherwise be underrepresented in this proceeding and include data that will enable the Commission to affirm, update or otherwise address the 61.6% compensation factor adopted for AECA in previous compensation awards." (AECA NOI, page 3.) AECA should do so in order to fully support its request for compensation. Failure to do so could result in a delay or denial of a future award.