5. Reasonableness of Requested Compensation

UCS requests $61,261.50 for its participation in this proceeding, as follows:

Work on Proceeding
Attorney/Staff	Year	Hours		Hourly Rate	Total
Alan Nogee	2006	0.50		$240.00	$120.00
Alan Nogee	2007	6.25		$260.00	$1,625.00
Alan Nogee	2008	3.50		$270.00	$945.00
John Galloway	2006	8.45		$130.00	$1,098.50
John Galloway	2007	9.25		$140.00	$1,295.00
Cliff Chen	2006	14.25		$115.00	$1,638.75
Cliff Chen	2007	219.25		$120.00	$26,310.00
Cliff Chen	2008	103.75		$130.00	$13,487.50
Chris Busch	2007	42.50		$175.00	$7,437.50
Chris Busch	2008	15.50		$180.00	$2,790.00
Laura Wisland	2008	15.50		$125.00	$1,937.50
Work on Proceeding Total:		438.70			$58,684.75
Preparation of NOI and Compensation Request10
Attorney/Staff	Year	Hours		Hourly Rate	Total
John Galloway	2006	5.00		$65.00	$325.00
John Galloway	2007	0.40		$70.00	$28.00
Cliff Chen	2006	1.00		$57.50	$57.50
Cliff Chen	2008	21.00		$65.00	$1,365.00
Laura Wisland	2008	2.50		$62.50	$262.50
Intervenor Compensation Matters Total:			29.90		$1,931.75
Travel
Attorney/Staff	Year	Hours		Hourly Rate	Total
Cliff Chen	2008	3.00		$65.00	$195.00
Laura Wisland	2008	3.00		$62.50	$187.50
Chris Busch	2007	3.00		$87.50	$262.50
Travel Total:		9.00			$645.00
UCS' Total Requested Compensation:					$61,261.50

NRDC requests $ 124,310.00¹¹ for its participation in this proceeding, as follows:

Work on Proceeding
D.07-09-017
Attorney/Staff	Year	Hours		Hourly Rate	Total
Audrey Chang	2006	11.50		$115.00	$1,322.50
Audrey Chang	2007	71.00		$150.00	$10,650.00
Subtotal:		82.50			$11,972.50
D.08-03-018
Attorney/Staff	Year	Hours		Hourly Rate	Total
Audrey Chang	2007	162.25		$150.00	$24,337.50
Audrey Chang	2008	33.50		$155.00	$5,192.50
Kristin Grenfell	2007	106.25		$170.00	$18,062.50
Kristin Grenfell	2008	22.00		$175.00	$3,850.00
Peter Miller	2007	57.50		$100.00	$5,750.00
Devra Wang	2007	92.00		$160.00	$14,720.00
Devra Wang	2008	14.50		$165.00	$2,392.50
Subtotal:		488.00			$74,305.00
D.08-10-037
Attorney/Staff	Year	Hours		Hourly Rate	Total
Audrey Chang	2008	51.50		$155.00	$7,982.50
Kristin Grenfell	2008	105.25		$175.00	$18,418.75
Noah Long	2008	23.75		$150.00	$5,275.00
Peter Miller	2008	52.75		$100.00	$5,275.00
Subtotal:		233.25			$35,238.75
Work on Proceeding Total:		803.75			$121,516.25
Preparing NOI and Request for Compensation
Attorney/Staff	Year	Hours		Hourly Rate	Total
Audrey Chang	2006	2.50		$57.50	$143.75
Kristin Grenfell	2008	20.00		$87.50	$1,750.00
Noah Long	2008	12.00		$75.00	$900.00
Intervenor Compensation Matters Total:			34.50		$2,793.75
NRDC's Total Requested Compensation:					$124,310.00

In general, the components of compensation requests 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.

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 by UCS and NRDC. 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.

5.1. Hours and Costs Related to and Necessary for Substantial Contributions

5.1.1. UCS' Hours and Costs

UCS documented its claimed hours by presenting a daily breakdown of the hours of its representatives, accompanied by a brief description of each activity. In general, the hourly breakdown reasonably supports the claim for total hours. We have several concerns with information reflected in UCS' timesheets.

UCS routinely sent two representatives to attend the proceeding's events (conferences, meetings, workshops), which represents an inefficient effort on the part of UCS. We believe it is unreasonable to compensate costs incurred by the second or third person in these cases, and reduce UCS' time, as follows:

UCS' Table 1: Participation in the proceeding's events
Name	Year	Hours Disallowed
John Galloway	2006	3.00
John Galloway	2007	1.00
Chris Busch	2007	21.50
Chris Busch	2008	2.00

These reductions are based on the staff's level of involvement in the proceeding. Cliff Chen, Senior Energy Analyst, led UCS' participation, prepared comments, developed policy positions and arguments, and performed modeling analysis. He devoted considerably more hours to the proceeding than the rest of the team, and we allow all of his hours for these events.

We note further that in the course of the proceeding, UCS staff spent a significant amount of time in internal communications discussing, coordinating, and planning its participation. In addition, UCS' representatives claim compensation for reviewing each other's documents. We assume that it was, in part, due to UCS' internal protocol and, in part, due to the fact that two new staff members, Wisland and Busch, needed some additional time for the information exchange with incumbent members. While these activities can help individual team members to come up with solutions or create a document, they also ring of duplication of each other's tasks and some unproductive efforts. As an example of this practice, we note Alan Nogee's claimed time for reviewing NRDC/UCS joint comments.

Certain inefficiency also appears, for example, in the area of UCS' participation planning. Cliff Chen led UCS' participation, planned, and coordinated work of the team, and developed its policy positions and arguments. He spent initially about 14 hours on the issues of planning UCS' participation. However, several other representatives also planned UCS' participation, which we consider to be a duplicative inefficient effort.

The table at Appendix B describes our findings and reductions in this area.

UCS' Table 2: Excessive Internal Communications and Internal Duplicative or Non-Productive Efforts
2006 Hours	Chen	Galloway	Nogee		Busch	Wisland
4/19/06 (internal communication)
Requested		0.30	0.30
Allowed		0.15	0.15
Disallowed (50%)		0.15	0.15
4/19/06 (internal communication)
Requested		0.60
Allowed		0.30
Disallowed (50%)		0.30
11/7/0612 (internal communication)
Requested	1.00	1.00
Allowed	0.50	0.50
Disallowed (50%)	0.50	0.50
11/13/06 (communication of Chen and Galloway (UCS) and Wang(NRDC))
Requested	0.75	0.75
Allowed	0.37	0.37
UCS' Table 2: Excessive Internal Communications and Internal Duplicative or Non-Productive Efforts
Disallowed (50%)	0.38	0.38
11/13/06 (reading draft of PHC statement)
Requested		0.60
Allowed		0.00
Disallowed (100%)		0.60
Disallowed in 2006	0.88	1.93	0.15
2007 Hours	Chen	Galloway	Nogee		Busch	Wisland
1/25/07 (internal communication)
Requested		0.50	0.50
Allowed		0.25	0.25
Disallowed (50%)		0.25	0.25
1/26/07 (internal communication)
Requested	0.5013	0.50
Allowed	0.25	0.25
Disallowed (50%)	0.25	0.25
2/7/07 (internal communication and case management14)
Requested	1.50	1.50+1.50
Allowed	0.75	0.75
Disallowed	0.75	2.25
3/27/09 (internal communication)
UCS' Table 2: Excessive Internal Communications and Internal
UCS' Table 2: Excessive Internal Communications and Internal Duplicative or Non-Productive Efforts
Duplicative or Non-Productive Efforts
Requested		1.00
Allowed		0.50
Disallowed		0.50
5/25/07 (internal communication)
Requested	0.50	0.50
Allowed	0.25	0.25
Disallowed (50%)	0.25	0.25
10/26/07 (internal communication)
Requested	1.00		1.00	1.0015
Allowed	0.33		0.33	0.33
Disallowed (2/3)	0.67		0.67	0.67
10/31/07 (internal communication and review of NRDC/UCS' filing)
Requested				2.2516
Allowed				0.0
Disallowed (100%)				2.25
11/15/07(internal communication)
Requested	0.25		0.25
Allowed	0.13		0.13
Disallowed (50%)	0.13		0.13
8/5, 10/29, 12/3, and 12/29/07 Reviewing NRDC/UCS' comments
UCS' Table 2: Excessive Internal Communications and Internal Duplicative or Non-Productive Efforts
Requested			4.50
Allowed			0.00
Disallowed (100%)			4.50
Disallowed in 2007	2.05	3.5	5.55	2.92
2008 Hours	Chen	Galloway	Nogee	Busch		Wisland
2/22/08 (internal communication)
Requested	0.25		0.25
Allowed	0.13		0.13
Disallowed (50%)	0.13		0.13
5/28/08 (internal communication)
Requested	0.25		0.25
Allowed	0.13		0.13
Disallowed (50%)	0.13		0.13
9/15/08 (internal communication)17
Requested	0.50					0.50
Allowed	0.25					0.25
Disallowed (50%)	0.25					0.25
9/19/08 (internal communication)
Requested	0.50					0.50
Allowed	0.00					0.00
Disallowed (100%)	0.50					0.50
9/24/08 (internal communication)
Requested	0.75			0.75		0.75
Allowed	0.00			0.00		0.00
Disallowed (100%)	0.75			0.75		0.75
UCS' Table 2: Excessive Internal Communications and Internal Duplicative or Non-Productive Efforts
6/1 and 10/1/08 Reviewing NRDC/UCS' comments
Requested			3.0
Allowed			0.00
Disallowed (100%)			3.0
Disallowed in 2008	1.76		3.26	0.75		1.50

The table below summarizes disallowances from Appendix B:

UCS' Table 2: Summary of UCS' Table 2
Name	Year	Hours Disallowed
Cliff Chen	2006	0.88
Cliff Chen	2007	2.05
Cliff Chen	2008	1.76
John Galloway	2006	1.93
John Galloway	2007	3.50
Chris Busch	2007	2.92
Chris Busch	2008	0.75
Alan Nogee	2006	0.15
Alan Nogee	2007	4.55
Alan Nogee	2008	3.26
Laura Wisland	2008	1.50

Further, we cross-checked NRDC's and UCS' timesheets and noticed certain discrepancies in the entries related to communications between these intervenors or their participation in the same events (workshops, hearings, etc). We make reductions to achieve a consistency in this area, and adjust Cliff Chen's time, as follows:

UCS' Table 3: Consistency between NRDC's and UCS' timesheets and Coordination of Efforts
Date (2007)	Hours Requested	Hours Allowed	Hours Disallowed
3/16/07	0.50	0.25	0.25
4/12/07	6.00	5.00	1.00
4/13/07	5.00	4.75	0.25
4/20/07	5.00	4.00	1.00
6/22/07	6.00	4.50	1.50
7/6-7/9/0718	8.50	6.50	2.00
8/21/07	7.50	5.25	2.25
9/21/07	3.75	3.50	0.25
10/31/07	0.75	0.50	0.25
11/14/07	4.25	3.00	1.25
2007 Total:	47.25	37.25	10.00
Date (2008)	Hours Requested	Allowed	Disallowed
5/6/08	7.00	4.0019	3.00
10/4/08	0.75	0.50	0.25
2008 Total:	7.75	4.50	3.25

We note that UCS failed to allocate its hours by issues, as we require.²⁰ In D.09-02-028, we directed UCS to comply in its future requests for intervenor compensation with our requirement to allocate the time by issues.

The Commission stated:

UCS did not allocate its time and costs among issues, making it difficult to determine the reasonableness of the aggregate hours claimed. ...We caution UCS, as we have done in connection with intervenor compensation claims it has filed in other Commission proceedings, that future claims will include disallowances for failure to allocate time and costs by issue. (D.09-02-028 at 8).

In the absence of the proper time allocation, we have to analyze the reasonableness of the request based on, among other things, the amount and complexity of the research and analysis necessary to produce documents for the record, the fact that two or more intervenors were working on the jointly filed documents, and the fact that on some issues NRDC/UCS provided a limited contribution (see Section 3 of this decision). Our analysis of UCS' claims in terms of these factors warrant additional reduction to the number of hours claimed. In determining the necessary reductions, however, we also pay attention to the fact that UCS' requests rates at the low ranges and waives direct costs, and the fact that the claimed amount is modest compared to the proceeding's length and the overwhelming number of the issues, comments and events involved in it. Therefore, to produce a more reasonable result in terms of the time spent on preparing documents in this proceeding, we disallow only an additional 3% of the requested time spent on the proceeding's merits.

UCS claims almost 30 hours for the preparation of the notice of intent to claim intervenor compensation and for the request for compensation. We compensate 26.5 for these matters due to UCS' failure to provide allocation of the time by issues and to the fact that the NOI and claim do not appear to require any extraordinary time consuming analysis or research that would justify excessive hours. Our reductions are reflected in the award.

UCS requests compensation for travel between its offices in Berkeley and Sacramento. We consider travels within the radius of approximately 120 miles (one way) to and from San Francisco Bay Area routine and not compensable.

After the reductions listed above, it appears that UCS' time devoted to the proceeding is reasonable and commensurate with UCS' contributions.

5.1.2. NRDC's Hours and Costs

In line with our analysis of UCS' time requested for compensation, we analyze NRDC's timesheets. NRDC documented its claimed hours by presenting a daily breakdown of the hours of its representatives, accompanied by a brief description of each activity. In general, the hourly breakdown reasonably supports the claim for total hours.

From the point of view of the efficiency of the NRDC team's work in this proceeding, there are a few areas of concern that we address in the award. The most apparent is internal repetitiveness of certain activities by the team members. For example, Noah Long's timesheets covering the period of time from 9/16/2008 to 10/7/2008 (claimed contributions to D.08-10-037) practically mirror entries in Kristin Grenfell's time records. Considering that Long contributed to the proceeding much less time than Grenfell, we disallow 19.75 hours of his time for the above period of time, to address the inefficiency problem.

Further, on June 1, 2007, Audrey Chang and Kristin Grenfell spent 1.50 hours each on reviewing a MAC report section on the electricity sector. We disallow 1.50 hours of Kristin Grenfell for that activity, since it appears that the related comments were prepared by Chang.

We also disallow the total of 8.25 hours of Kristin Grenfell's time spent on activities that were not necessary for NRDC's contributions to this proceeding. These hours include 2.0 hours (12/4/2007) spent on editing comments filed a day before on December 3rd, 4.0 hours (5/7/2008) spent on drafting a letter for possible GWAC sign-in regarding allowance allocation, 2.00 hours (10/17/2008) spent on attending the Commission's voting on the final decision on GHG regulatory strategies, and 0.25 hours (10/20/2008), spent communicating with Commissioner Douglas regarding the interim opinion.

NRDC's timesheets frequently fail to indicate the issue that the subject task addresses, in violation of the provisions of Rule 17.4(b). Miller often describes his communications simply as "calls" or "emails," Chang and Wang often report communications with parties ("stakeholders"), without indicating issues addressed in the communications and the parties' names or affiliation. All this precludes us from determining if these activities related to the work performed and were necessary for NRDC's contributions claimed in this proceeding. To address these deficiencies, we disallow the time spent on communications where issues are not identified (and not easily identifiable), as reflected in the summary below:

NRDC's Table 1: Summary of Hours Spent on Communications for Which Issues Are Not Identified
Name	Year	Hours Requested	Disallowed
Chang	2006	5.50	5.50
Chang	2007	16.75	16.75
Chang	2008	4.75	4.75
Wang	2007	2.50	2.50
Miller	2007	2.00	2.00

Based on the cross-checking of NRDC's and UCS' timesheets, we make a few adjustments of Audrey Chang's time, as follows:

NRDC's Table 2: Consistency between UCS' and NRDC's timesheets and Coordination of Efforts
Date/event (Chang (2007))	Hours Requested	Allowed	Disallowed
April 6th	1.25	1.00	0.25
April 19th	7.00	6.50	0.50
Total Disallowed (2007):			0.75

We also have efficiency concerns when NRDC claims compensation for two or more people when they prepare the same document. For example, October 31, 2007 comments on allowance allocation were prepared by three NRDC staff members: Chang, Grenfell, and Wang. Chang and Wang spent one hour each preparing an outline for the opening comments. These representatives also prepared the November 14, 2007 reply comments, and Chang and Wang each prepared an outline for the comments. While sometimes this is a legitimate practice, engaging several people to produce a single document results in duplication of their efforts. We do not make a conclusion as to whether engaging several people in creating one document was necessary for every document produced by NRDC, but we believe it is not fair to have ratepayers bear the burden of paying for this practice. Reading of the same documents, reviewing and editing each other's work, and, in addition, numerous internal meetings, discussions, and email exchanges that normally accompanied the preparation of NRDC's comments, created excessive efforts and required more time than would normally be needed for one person's work on a document. To cure the likely probability of excessive hours that resulted from the fact that team members appear to have been engaged in the same activities for the same documents, we reduce NRDC's hours by 5%.

Like UCS, NRDC failed to allocate its hours by issues. We direct NRDC to comply in its future requests for intervenor compensation with our requirement to allocate the time by issues. We are, therefore, confined, as in the case with UCS, to determining the reasonableness of the claim based on the amount and complexity of research and analysis necessary to prepare documents for the formal records, the extent of NRDC's contributions, and the fact that its positions did not always prevail. We also note that the documents were prepared by two or more intevenors jointly. Based on our considerations of these factors, we find NRDC's claimed hours excessive and disallow an additional 12% of the time NRDC requests for its work on the merits.

We allow 26.50 hours instead of the requested 34.50 for NRDC's preparation of the notice of intent to claim compensation and the request for compensation. We believe that the allowed time is what is reasonably required for a claim of limited complexity. We commend NRDC for providing detailed references to the record of the proceeding in support of the substantial contributions claims. We note, however, that NRDC did not allocate its time by issues. Our reductions are reflected in the award.

After the reductions listed above, it appears that NRDC's time devoted to the proceeding was reasonable.

5.2. Intervenor Hourly Rates

5.2.1. Alan Nogee

Alan Nogee is an Energy Program Director of the UCS. For his work in 2006, UCS requests the same rate ($240) that we adopted in D.08-12-017. For his work in 2007, UCS requests two authorized increases: a 5% step increase and 3% cost-of-living adjustment (COLA). The resulting rate (rounded to the nearest $5.00) is $260. For Nogee's work in 2008, UCS requests a 3% COLA, which results in the rate of $270. We adopt the requested rates.

5.2.2. John Galloway

John Galloway is UCS' Senior Energy Analyst. Relying on D.08-12-017, UCS requests the rate of $130 for Galloway's work in 2006, and $140 for his work in 2007, relying on D.08-12-017. However, that decision approved the rates of $125 and $130 respectively, and we adopt the same rates here.

5.2.3. Cliff Chen

Cliff Chen is a Senior Energy Analyst for UCS. UCS requests for his work in 2006 the rate of $115, adopted in D07-06-032. For his work in 2007, UCS requests the rate of $120 adopted in D.08-12-017. For Chen's work in 2008, UCS requests two authorized increases: 5% step increase and 3% COLA, with the result of $130. We approve the requested rates.

5.2.4. Chris Busch

Chris Busch is a Climate Economist for UCS. In this proceeding he appeared before the Commission for the first time. UCS requests the rates of $175 and $180 for his work in 2007 and 2008, respectively. Busch has a PhD (2006) in economics and nine years of professional experience. We adopt the rates of $160 and $165 for the years 2007 and 2008, respectively. In analyzing Busch's experience, we note his experience that had some degree of relevance to issues before the Commission occupied between five and six years. He worked as Senior Research Associate in a study analyzing GHG benefit estimates of a major carbon sequestration project in Costa Rica (1998-1999); as a graduate student researcher he co-authored two chapters of Managing Greenhouse Gas Emissions in California (2005-2006); and, as a Climate Economist, he analyzed climate policies in California and the Western United States and prepared research documents for decision makers and policy makers (2006-2008). Busch also worked on the market impact of demand side management rebates for electronic ballasts in fluorescent lights (1997). Busch's work on the valuation of a Beach Recreation Project (2000-2002), and on modeling deforestation in the Yucatán (2000-2002) is not sufficiently relevant to issues before the Commission. We find that the rates of $160 for his work in 2007) and $170 for 2008 are reasonable, and we adopt them here.²¹

5.2.5. Laura Wisland

Laura Wisland is an Energy Analyst in the Clean Energy Program at UCS. She appeared before the Commission for the first time in this proceeding. UCS requests the rate of $125 for her work in 2008. Laura Wisland joined UCS in 2008. She has an M.P.P. from the Goldman School of Public Policy at the University of California at Berkeley (2008), and a Bachelor's degree in Environmental Public Policy from the University of North Carolina. Prior to joining UCS, Wisland worked as a demand response analyst for Pacific Gas and Electric Company (PG&E) and worked on rules to develop a tradable energy credit market for the California RPS as an energy intern with the Commission. From 2003 to 2004, Laura Wisland served as an Assistant Director and from 2004 to 2006 as a Director, of the California Hydropower Reform Coalition. We approve the requested rate of $125 and note that it is at the lower end for experts with comparable years of experience.

5.2.6. Audrey Chang

NRDC requests rates for Audrey Chang that we approved earlier, and we grant the request.²²

5.2.7. Kristin Grenfell

NRDC requests an hourly rate of $170 for the year 2007 and $175 for the year 2008 for attorney Kristin Grenfell. In D.09-05-018, we approved the rates of $145 and $150 for her work in 2007 and 2008, respectively, as NRDC requested in that proceeding (R.06-04-010). In this proceeding, NRDC provides more detail on Grenfell's experience. NRDC states that Grenfell had a year and a half of experience as an attorney when she began working for NRDC at the beginning of 2007, and that by mid-2008 she had a total of three years of experience as an attorney (NRDC does not specify what was Grenfell's attorney practice area prior to her work for NRDC). In addition, she has more than five years of work experience in energy and environmental issues. While working at a private law firm in 2005 and 2006, she billed out at over $300 per hour. The requested rates are commensurate with Grenfell's experience and, although they are higher than her previously requested rates, they are still at the low end of the rate range adopted in D.08-04-010. We approve the requested rates.

5.2.8. Noah Long

NRDC requests an hourly rate of $150 for this attorney's work in 2008. Long has not had an established hourly rate with the Commission. Long has a JD from Stanford University Law School, an MSc from the London School of Economics, and a BA in Government and Environmental Studies. He is a first year attorney but has been working in the energy policy area for five years. The rate of $150 is at the lowest end of the 2008 hourly rate range set in D.08-04-010 for attorneys with up to two years of experience. We adopt the requested rate.

5.2.9. Peter Miller

NRDC requests an hourly rate of $100 for its expert Peter Miller's work in 2007 and 2008. Miller has over 20 years of experience in the development and analysis of energy efficiency programs and policy. He served on the California Board for Energy Efficiency from 1997 to 2000 and has presented testimony on energy policy to the U.S. Senate and House of Representatives, the Northwest Power Planning Council, and other administrative and legislative bodies. In D.09-05-018 we approved the rate of $100 for his work in 2008. We note that in D.06-04-005 we approved a higher rate of $150 for his work in 2005. NRDC explains that Miller requests a substantially discounted non-profit billing rate in this proceeding. We adopt this rate.

5.2.10. Devra Wang

D.08-10-011 approved the rate of $160 for expert Devra Wang's work in 2007. NRDC requests the same rate for 2007 and the rate of $165 for her work in 2008, representing a 3% COLA, allowed in D.08-04-010. We adopt these rates, as NRDC requests.

5.3. Direct Expenses

Both parties waived direct expenses incurred in the course of their work on this proceeding.

¹⁰ Travel and intervenor compensation document preparation time is compensated at the ½ professional hourly rate.

¹¹ Due to a calculation error, NRDC requests $124,166.25. We correct the error here.

¹² Timesheets in this case combine the actual communication with other activities, and show 1.50 hours for Chen and 1.20 hours for Galloway. We assume the communication lasted 1 hour.

¹³ Chen's timesheet shows 1 hour for the communication combined with other activities. We assume the actual communication was for the same length of time (0.50) for each participant.

¹⁴ Galloway's timesheet shows 3.00 hours for two different activities: a communication and an activity described as "case management." We assume the actual communication lasted the same time (1.50) for each participant. We compensate 50% of the communication time and we disallow the case management time.

¹⁵ Busch's timesheet shows 5.00 hours for the communication combined with other activities. We assume the actual communication lasted the same amount of time (1.00 hour) for each participant.

¹⁶ Busch's timesheet combines several activities in his 10/31/07 entry (3.00 hours): reviewing a draft of the NRDC/UCS filing, meeting with Chen to discuss UCS positions, and conference call with NRDC to finalize. The 2.25 hours is calculated based on Chen's timesheet reflecting that the conference took 0.75 hours (3.00-0.75=2.25).

¹⁷ This and the following two discussions concerned NRDC/UCS opening comments that were prepared by Chen.

¹⁸ During this period of time, Chen was summarizing and reviewing opening comments on the Joint Staff GHG Reporting proposal. On July 7, 2007, Audrey Chang of NRDC read and summarized these comments and shared her summary of the comments with UCS. She claims two hours for these tasks. To cure certain duplication of the parties' efforts we reduce Chen's time by 2.00 in 2007.

¹⁹ We note that NRDC attended the May 6, 2008 workshop for just two hours.

²⁰ D.98-04-059 at 48.

²¹ Compare to NRDC's expert Sheryl Carter, who appeared before the Commission since at least 2003, had 13+ years of the relevant experience, and received an hourly rate of $175 in 2007 (D.09-02-026); or to expert Jim Helmich, who appeared before the Commission since at least 2003, had 13+ years of the relevant experience, and received the rate of $175 in 2007 (D.09-04-027).

²² D.08-10-011 approved the rates of $115 and $150 for the years 2006 and 2007, respectively. D.09-05-018 approved the rate of $155 for the year 2008.