5. Reasonableness of Requested Compensation

Reid requests $34,889.20 for his participation in PG&E's PRG and CAMG, between July 1, 2010, to September 30, 2011, as follows:

Work on Proceeding
Expert	Year	Hours	Hourly Rate	Total
L. Jan Reid	2010	118.20	$185.00	$21,867
L. Jan Reid	2011	65.60	$185.00	$12,136.00
Subtotal:				$34,003.00
Preparation of NOI and Compensation Request
L. Jan Reid	Year	Hours	Hourly Rate	Total
	2011	9.209	$92.50	$851.00
Subtotal:				$851.00
Expenses				$35.20
Total Requested Compensation				$34,889.20

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.

5.1. 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 his hours, accompanied by a brief description of each activity. Reid also indicates what types of information and documents he reviewed and commented on for the PRG and CAMG. The hourly breakdown reasonably supports the claim for total hours.

5.2. Intervenor Hourly Rates

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.

Reid seeks an hourly rate of $185.00 for the work performed in 2010. This rate was previously adopted in D.11-03-019. He requests the same hourly rate of $185.00 for the work performed in 2011, which was also adopted in D.11-08-015. We confirm these rates.

5.3. Direct Expenses

The itemized direct expenses submitted by Reid include costs of copying and envelopes. The cost breakdown included with the request shows the miscellaneous expenses to be commensurate with the work performed. In general, these costs are reasonable; however, we were surprised by the large (228) number of copies of the intervenor compensation request. The Commission encourages electronic filing and e-mail service, where paper copies are required only for the assigned administrative law judge and commissioner.¹⁰ Six large envelopes indicated in Reid's claim appear to be unnecessary, as well. While we are not making any disallowances at this time, we warn Reid that if in the future requests similar costs are not either justified or waived as negligible, we will disallow them.

⁹ We note there was a minor typographical error in the number of hours. According to the time records, it should be 9.20 hours; the requested dollar amount, too, corresponded to 9.20 hours of work. Reid erroneously indicated 9.60 hours. We correct the error here.

¹⁰ Order Instituting Rulemaking at 25-26.