response provider proposals. Verified, d. Describe how you coordinated with DRA and other parties to avoid duplication or TURN did how your participation supplemented, complemented, or contributed to that of not another party: engage in excessive In this proceeding TURN engaged in several communications with ORA, as well as with other parties to the proceeding, in order to better identify issues that require for the TURN’s input. In the Working Group process, TURN focused on certain issues related to claimed generation capacity (hard trigger) and T&D capacity valuation. TURN's compensation in this proceeding should not be reduced for duplication of the showings of other parties. In a proceeding involving multiple participants, it is virtually impossible for TURN to completely avoid some duplication of the work of other parties. In this case, TURN took all reasonable steps to keep such duplication to a minimum, and to ensure that when it did happen, our work served to complement and assist the showings of the other parties. Any incidental duplication that may have occurred here was more than offset by TURN’s unique contribution to the proceeding. Under these circumstances, no reduction to our compensation due to duplication is warranted given the standard adopted by the Commission in D.03-03-031. Additional Comments on Part II: # Comment CPUC Discussion Intervenor’s Partial Contribution The Commission has interpreted the Section 1802 Verified definition, in conjunction with Section 1801.3, so as to effectuate the intent to encourage effective legislature’s and efficient intervenor participation. The statutory provision of or in as interpreted by “in whole part,” multiple Commission decisions on intervenor compensation requests, has established as a general proposition that when a party makes a substantial contribution in a multi-issue proceeding, it is entitled to compensation for time and expenses even if it does not prevail on some of the issues. See, for example, (awarding TURN full compensation in CTC proceeding, even though TURN did not prevail on all issues); D.98-08-016, pp. 6, 12 (awarding TURN full compensation in SoCalGas PBR proceeding); pp. 4-7, 10 (awarding TURN full compensation even though we unsuccessfully opposed settlement). The standard for an award of intervenor compensation is whether TURN made a substantial contribution to the not whether TURN prevailed on a Commission’s decision, particular issue, or on every issue. For example, the
response provider proposals. d. Describe how you coordinated with DRA and other parties to avoid duplication or how your participation supplemented, complemented, or contributed to that of another party: In this proceeding TURN engaged in several communications with ORA, as well as with other parties to the proceeding, in order to better identify issues that require TURN’s input. In the Working Group process, TURN focused on certain issues related to generation capacity (hard trigger) and T&D capacity valuation. TURN's compensation in this proceeding should not be reduced for duplication of the showings of other parties. In a proceeding involving multiple participants, it is virtually impossible for TURN to completely avoid some duplication of the work of other parties. In this case, TURN took all reasonable steps to keep such duplication to a minimum, and to ensure that when it did happen, our work served to complement and assist the showings of the other parties. Any incidental duplication that may have occurred here was more than offset by TURN’s unique contribution to the proceeding. Under these circumstances, no reduction to our compensation due to duplication is warranted given the standard adopted by the Commission in D.03-03-031. Verified, TURN did not engage in excessive for the claimed Additional Comments on Part II: # Intervenor’s Comment CPUC Discussion Partial Contribution The Commission has interpreted the Section 1802 definition, in conjunction with Section 1801.3, so as to effectuate the legislature’s intent to encourage effective and efficient intervenor participation. The statutory provision of “in whole or in part,” as interpreted by multiple Commission decisions on intervenor compensation requests, has established as a general proposition that when a party makes a substantial contribution in a multi-issue proceeding, it is entitled to compensation for time and expenses even if it does not prevail on some of the issues. See, for example, (awarding TURN full compensation in CTC proceeding, even though TURN did not prevail on all issues); D.98-08-016, pp. 6, 12 (awarding TURN full compensation in SoCalGas PBR proceeding); pp. 4-7, 10 (awarding TURN full compensation even though we unsuccessfully opposed settlement). The standard for an award of intervenor compensation is whether TURN made a substantial contribution to the Commission’s decision, not whether TURN prevailed on a particular issue, or on every issue. For example, the Verified