6. Reasonableness of Requested Compensation

Reid requests $17,149.50 for participation in this proceeding, as follows:

Work on Proceeding
Attorney/Staff	Year	Hours	Hourly Rate	Total
L. Jan Reid	2008	27.0	$185	$ 4,995.00
L. Jan Reid	2009	65.7	$185	$12,154.50
Subtotal Hourly Compensation:				$17,149.50
Total Requested Compensation				$17,149.50

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

To determine whether the requested compensation is reasonable, we first assess whether the hours claimed are related to the work performed and necessary for the substantial contribution.

Reid documented his claim of 92.7 hours by presenting a daily listing of the hours he spent on this proceeding, accompanied by a brief description of each task and the specific issue the task addressed. Reid's breakdown of claimed hours by issue is as follows:

Reid's Allocation of Time by Major Issue
Issue Category	2008 Hours	2009 Hours	Total
General Work	.30	16.9	17.2
Imperial Valley Renewables		36.7	36.7
Project Viability		12.1	12.1
RPS Plans		26.7	26.7
Total Hours	.30	92.4	92.7

The 92.7 hours claimed by Reid represents all of the time spent on this proceeding for which he seeks compensation. Reid voluntarily excludes time for the preparation of his NOI and the request for intervenor compensation.

Although we find in general that Reid made several substantial contributions to this proceeding, Reid failed to itemize his time in a way that allows us to easily or readily determine what portion of his 92.7 hours are related to his substantial contributions. With some effort here we are able to draw the necessary relationships and the resulting reduction in hours is described above. In future claims, however, we urge Reid to be more diligent in his allocation of time by issue, to avoid the potential for erroneous disallowances, or disallowances based on our difficulty with the claim.²⁰

6.2. Intervenor Hourly Rates

We next consider if Reid's claimed fees are comparable to the market rates paid to experts with comparable training and experience and offering similar services. Reid requests hourly rates of $185 for work performed in 2008 and 2009. We previously approved Reid's 2008 hourly rate of $185 in D.08-11-053. Pursuant to ALJ-235, which disallows cost of living adjustment increases for the 2009 work of intervenors, we apply the 2008 rate to Reid's work performed in 2009.

6.3. Direct Expenses

Reid has no direct expenses for which he seeks compensation.

²⁰ Parties may discuss presentation of intervenor compensation claims with the Commission's Public Advisor.