6. Reasonableness of Requested Compensation

L. Jan Reid requests $16,539.00 for his participation in this proceeding, as follows:

Work on Proceeding
Intervenor	Year	Hours	Hourly Rate	Total
L. Jan Reid	2008	80.20	$185	$14,837.00
L. Jan Reid	2009	9.20	$185	$1,702.00
Total Requested Compensation				$16,539.00

Reid does not claim compensation for his time spent preparing the NOI, request for intervenor compensation, and for his direct expenses.

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.

6.1. 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. Reid documented his claimed hours by presenting a daily breakdown of the hours, accompanied by a brief description of each activity. The hourly breakdown reasonably supports the claim for total hours. We have but a few concerns.

Considering the nature of Reid's protest and response to PG&E's motion, we believe that approximately 22.50 hours of work on these documents is excessive: they repeat, in general, each other, and Reid's position presented there did not involve a time-consuming research or analysis. To come up with the reasonable amount of time required to prepare documents of the same complexity and length, we reduce Reid's hours by 15% or 3.35 hours.

We find unreasonable spending approximately 18.90 hours on writing Reid's testimony. This four-page document repeats Reid's original position regarding the application, summarizes the PG&E/Reid settlement, and requests its approval. To reflect hours reasonably required to prepare Reid's testimony, we reduce his time spent on this task by 50% or 9.50 hours.

We noticed instances of clerical tasks, which we do not compensate (sending documents on October 9 and 22, November 3 and 7, and December 3, 2008, and January 16, 2009). The timesheet combines these tasks with professional tasks. We assume that a clerical task required a minimum of
5 minutes, and disallow the total of 30 minutes (5 minutes x 6 tasks), accordingly.

6.2. Intervenor Hourly Rates

Reid requests and we approve, an hourly rate of $185.00 for his work in 2008 and 2009, the same rate we adopted in D.09-11-027.