The following excerpt is from People of State of Cal. v. Tahoe Regional Planning Agency, 792 F.2d 775 (9th Cir. 1986):
In determining adequacy of representation, we consider whether the interest of a present party is such that it will undoubtedly make all the intervenor's arguments; whether the present party is capable and willing to make such arguments; and whether the intervenor would offer any necessary elements to the proceedings that other parties would neglect. Sagebrush Rebellion, 713 F.2d at 528; County of Fresno v. Andrus, 622 F.2d 436, 438-39 (9th Cir.1980). The applicant is required only to make a minimal showing that representation of its interests may be inadequate. Stringfellow, 783 F.2d at 827.
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