7. Reasonableness of Requested Compensation

GPI requests $118,926 for participation in these proceedings, as follows:

Work on Proceedings

Attorney/Staff

Year

Hours

Hourly Rate $

Total $

Gregory Morris, Expert

2006

92.0

220

20,240.00

Gregory Morris, Expert

2007

130.0

225

29,250.00

Gregory Morris, Expert

2008

72.5

230

16,675.00

Gregory Morris, Expert

2009

192.5

240

46,200.00

Valerie Morris, Research Associate

2006

15.0

31

465.00

Valerie Morris, Research Associate

2007

25.0

32

800.00

Zoë Harrold, Research Associate

2007

22.0

32

704.00

Zoë Harrold, Research Associate

2008

25.5

33

841.50

Subtotal Hourly Compensation:

115,175.50

NOI and Intervenor Compensation Preparation (1/2 rate)

Gregory Morris

2009

22.0

120

2,640.00

Subtotal NOI/Intervenor Compensation Preparation:

2,640.00

Expenses:

1,110.00

Total Requested Compensation:

$118,925.50

7.1. 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.

GPI documented its claimed hours by presenting a daily listing of the hours that Morris and GPI's Research Associates (RAs) spent on these proceedings, accompanied by a brief description of the work performed and the specific issue (identified by GPI) the task addresses. GPI breaks down Morris' 487 hours of professional time by task is as follows:

Issue

Requested Hours

% of Hours by Issue

Assigned Commissioner's Rulings- Comments on 7 Issues

66.0

14%

Report Spreadsheets

42.0

9%

Compliance Reports

73.5

15%

Resolution E-4052

17.5

4%

2007 Procurement Plans

67.5

14%

Renewable Energy Credit Definition

2.0

.004%

Short-Term Benchmarks

48.0

10%

Phase II Issues

26.5

5%

Comments on OIR

8.0

2%

Standard Terms and Conditions

4.5

.009%

2008 Procurement Plans

22.0

5%

Project Viability Calculator

39.5

8%

Imperial Valley/Contract Issues

70.0

14%

Totals

487.0

100%

For the most part, we find that GPI's listed hours are commensurate with the work it performed. We do note however, that GPI's claim contains multiple entries where Morris logs time for "completing, filing and serving" various pleadings. The filing and serving of documents are clerical tasks in nature and are not compensable. We caution GPI against the combining of multiple tasks in one entry. As such, we disallow 9 hours of Morris' 2006 work, 14.5 hours of Morris' 2007 work, 13.5 hours of Morris' 2008 work and 21.5 hours of Morris' 2009 work.

After the reductions we made to GPI's claim as described in Section 5, the remainder of hours are reasonable and should be fully compensated.

7.2. Intervenor Hourly Rates

We next consider if GPI's claimed hourly rates are comparable to the market rates paid to experts with comparable training and experience and offering similar services. GPI requests 2006, 2007 and 2008 hourly rates for Morris and its Research Associates which have previously been approved by the Commission. We apply these same rates here without further discussion.

Participant

Hourly Rate

Requested

Year Work Performed

Justification

Gregory Morris

$220

2006

D.06-08-013

Gregory Morris

$225

2007

D.08-09-036

Gregory Morris

$230

2008

D.08-11-029

Research Associate

$ 31

2006

D.06-08-013

Research Associate

$ 32

2007

D.08-09-036

Research Associate

$ 33

2008

D.08-11-029

GPI requests an increase of 4.35 percent, equal to $240, for the 2009 work of Morris. GPI acknowledges that Resolution ALJ-235 disallows cost-of-living (COLA) increases for intervenors, but argues that Morris has been representing GPI before the Commission for over 6 years and has never requested a step increase, although he has been a senior-level renewable-energy expert even before the beginning of his work at the Commission. Under these circumstances, applying a step-increase to the hourly rate for Morris is reasonable and is adopted here.

7.3. Direct Expenses

GPI requests compensation for the following direct expenses:

Excluding the disallowance of $428.50 from GPI's request for courier services, all other miscellaneous expenses are reasonable and commensurate with the work performed. We approve courier services only for GPI's October 13, 2006 and November 3, 2006 pleadings in R.06-05-027 as they were not filed electronically. With these two exceptions, all other filings of GPI's were served electronically, so the use of courier services is not justified.

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