7. Reasonableness of Requested Compensation

Aglet requests $17,638.55 for its participation in these rulemakings, as follows:

Work on Proceeding
Attorney/Staff	Year	Hours	Hourly Rate	Total $
James Weil	2008	1.0	$300	300.00
James Weil	2007	5.7	$280	1,596.00
L. Jan Reid	2006	9.8	$155	1,519.00
L. Jan Reid	2007	71.5	$170	12,155.00
Subtotal Hourly Compensation:				$15,570.00
Preparation of NOI and Compensation Request (1/2 rate)
Attorney/Staff	Year	Hours	Hourly Rate	Total $
James Weil	2006	0.7	$130	91.00
James Weil	2008/2009	6.2	$150.00	930.00
L. Jan Reid	2006	2.5	$77.50	193.75
L. Jan Reid	2009	8.2	$92.50	758.50
Subtotal NOI and Compensation Request:				1,973.25
Expenses (Photocopying and Postage)				95.30
Total Requested Compensation				$17,638.55

In general, the components of this request must constitute reasonable fees and costs of the customer's preparation for and participation in a proceeding that resulted in a substantial contribution. The issues we consider to determine reasonableness are discussed below.

7.1. Hours and Costs Related to and Necessary for Substantial Contribution

We first assess whether the hours claimed for the customer's efforts that resulted in substantial contributions to Commission decisions are reasonable by determining to what degree the hours and costs are related to the work performed and necessary for the substantial contribution.

Aglet documented its claimed hours by presenting a breakdown of the hours of its attorneys, accompanied by a brief description of each activity. We here fully compensate Aglet for the hours it asserts are related to its general work in these rulemakings. We do however, make reductions to this claim where Aglet either failed to make a substantial contribution on an issue or requests compensation for hours which we find are excessive.

After the reductions listed below, the remainder of Aglet's hours and costs reasonably supports today's award for compensation.

CPUC Disallowances

Hours	Justification
2006-Reid	Aglet requests a total of 1.5 hrs of compensation for Reid's attendance at a PHC on June 26. We reduce the requested amount by .50 hrs to reflect the same amount of time logged by other intervenors in attendance at the same conference.
2006-Reid	Aglet requests 2.5 hrs of compensation for Reid's time spent drafting an NOI on July 25. We reduce this requested amount by 1.5 hrs (billed at ½ rate) to more closely reflect our standards of reasonableness.
2006-Reid	Aglet requests a total of 5.5 hrs of compensation for Reid's attendance at a workshop on RPS Transparency on Dec 15. We reduce this requested time by 1.0 hr to reflect the same amount of time logged by other intervenors in attendance at the same workshop.
2007-Reid	Aglet requests a total of 10.5 hrs for Reid's time writing and editing comments on IRPs of SMJUs. Although Aglet made a substantial contribution on this issue, we consider this amount of time to be excessive, given the product produced (3 pages). As such, we reduce the requested time for this task by 4.5 hrs.
Preparation of Intervenor Compensation	Aglet requests a total of 17.60 hrs for preparation of its request for intervenor compensation. We approve a more reasonable amount of 12.20 hours for this task. Upon review of the claim, Weil's hours are disproportionate. Aglet requests 6.7 hrs for his work in the proceeding and 6.90 hrs his work on intervenor claim preparation. To assist in the achievement of greater efficiency in this area, we encourage Aglet to use the standardized intervenor compensation forms and claim available on our website. To achieve our allowance, we reduce Weil's 2008/2009 time for compensation preparation by 3.1 hrs and Reid's 2009 hours by .8 hrs. The adjusted total more closely reflects our standards of reasonableness.

7.2. Intervenor Hourly Rates

We next take into consideration whether the claimed fees and costs are comparable to the market rates paid to experts and advocates having comparable training and experience and offering similar services.

The Commission has previously approved rates for both Weil and Reid for most of the years requested in this claim. We use those same rates here without further discussion. Aglet requests an hourly rate of $185 for Reid's work in 2009. We previously approve this same rate for Reid's work in 2008 in D.08-11-053. Pursuant to ALJ-235, we adopt this same rate for Reid's 2009 work here.

7.3. Direct Expenses

The itemized direct expenses submitted by Aglet include the following:

We find these costs reasonable and commensurate with the work performed and approve them here.