4. Compensation for Hours Devoted to TURN's February 2009 Compensation Request

TURN claims 19.6 hours for preparing its February 2009 compensation request. That request covers work performed over parts of six years by several representatives. In these circumstances, assembling the requisite documentation and writing the request in less than 20 hours seems commendably efficient.

However, TURN also claims 9.8 hours that its outside counsel devoted to counsel's part in preparing TURN's earlier (June 2004) compensation request in this proceeding. This claim is troubling because we expect all time spent preparing a compensation request to be part of that request. TURN explains the omission as attributable to TURN's receipt of the relevant invoice from outside counsel some time after TURN filed the request. Considering the long pendency of the request, we do not understand why TURN did not simply file a supplement requesting the additional hours. We therefore reject this untimely claim.

Another question regarding the "Request Preparation" category concerns whether we should conform to our long-established practice of compensating these hours at only 50% of the representative's approved hourly rate. The rationale for this practice is that request preparation is mostly a matter of bookkeeping, not requiring the representative's legal or other expertise. TURN argues that the rationale does not apply to this proceeding, where TURN had to use its own and outside counsel's legal expertise to the fullest, precisely to defend its claim for compensation before the Commission and ultimately before the California Court of Appeal.

We reject TURN's argument, which does not hold for the hours initially spent preparing its compensation request (13.5 hours by TURN staff and 6.1 hours by outside counsel regarding the 2009 request). The initial preparation of this request was little removed from the effort involved in most requests for compensation, so in today's decision, we compensate these hours at 50% of the approved hourly rates.