3. Adequacy of Representation

TURN asserts that it is the only intervenor that will act specifically on behalf of residential and small commercial customers in this rehearing phase of the proceeding. The Commission's Division of Ratepayer Advocates (DRA) is a party, but DRA does not represent the specific interests of small customers.

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 in ensuring 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 DRA or others. TURN also plans to coordinate, as much as possible, with DRA and other intervenors in order to avoid unnecessary duplication of effort.