6. Reasonableness of Requested Compensation

GPI requests $62,001 for its participation in this proceeding, as follows:

Work on Proceeding
Attorney/Staff	Year	Hours	Hourly Rate	Total
Gregory Morris	2006	13	$ 220.00	$ 2,860.00
Gregory Morris	2007	217	$ 230.00	$49,910.00
Gregory Morris	2008	21.5	$ 240.00	$ 5,160.00
Valerie Morris	2007	34.5	$ 32.00	$ 1,104.00
Zoë Harrold	2007	16	$ 32.00	$ 512.00
Subtotal:				$59,546.00
Preparation of NOI and Compensation Request
Attorney/Staff	Year	Hours	Houly Rate		Total
Gregory Morris	2008	18.5	$ 120.00		$ 2,220.00
Subtotal Hourly Compensation:					$61,766.00
Expenses					$ 235.00
Total Requested Compensation					$62,001.00

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. GPI documented its claimed hours by presenting a daily breakdown of the hours of its staff, accompanied by a brief description of each activity. The hourly breakdown reasonably supports the claim for total hours and those hours are reasonable given the scope of the proceeding, and the strong participation by the GPI.

6.2. Hourly Rates

We next consider 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.

Dr. Morris acted in Phase 2 as both technical expert and participating party as Director of GPI. Dr. Morris is a renewable energy analyst and consultant with 25 years of diversified experience and accomplishments in the energy and environmental fields. He is a nationally recognized expert on biomass and renewable energy, climate change and GHG emissions analysis, integrated resources planning, and analysis of the environmental impacts of electric power generation. Dr. Morris holds a BA in Natural Science from the University of Pennsylvania, an MSc in Biochemistry from the University of Toronto, and a PhD in Energy and Resources from the University of California.

Dr. Morris has been actively involved in electric utility restructuring in California throughout the past decade. He served as editor and facilitator for the Renewables Working Group to this Commission in 1996, consultant to the California Energy Commission's Renewables Program Committee, and consultant to the Governor's Office of Planning and Research on renewable energy policy during the energy crisis years, and has provided expert testimony in a variety of regulatory and legislative proceedings, as well as in civil litigation.

In D.06-08-013, the Commission approved an hourly rate for GPI Director Dr. Morris of $220 for 2006. GPI's Request for Phase 2 includes work performed by Dr. Morris during 2006, 2007, and 2008 in support of D.07-09-017 and D.08-03-018. Since we previously adopted the 2006 rate for Dr. Morris, we approve its use here, as requested by GPI. For 2007, for Dr. Morris GPI requests a 3% cost-of living adjustment increase, which results in the rate of $225.00 (we round expert's hourly rates to the nearest $5.00⁷), the rate already adopted in D.08-09-036. For the year 2008, GPI also requests the of 3% cost-of-living adjustment, which results in the rate of $230.00. These rates are consistent with the guidelines and rate ranges set forth in D.07-01-009 and D.08-04-010 and are adopted here.

In, D.07-12-007, the Commission approved an hourly rate for Research Associates Valerie Morris and Zoë Harrold of $31 in 2006. GPI proposes a 3% increase in the rate (to $32/hour) for the work of Valerie Morris and Zoë Harrold, who participated in Phase 2. These rates are consistent with the guidelines set forth in D.07-01-009, and adopted here.

6.3. Productivity

D.98-04-059 directed customers to demonstrate productivity by assigning a reasonable dollar value to the benefits of their participation to ratepayers. The costs of a customer's participation should bear a reasonable relationship to the benefits realized through their participation. This showing assists us in determining the overall reasonableness of the request.

GPI's emphasis in Phase 2 has been to provide information and insights about many aspects of the Commissions' GHG recommendations, particularly with respect to treatment of renewable resources. It concedes it cannot identify precise monetary benefits to ratepayers. However, the Commission's recommendations regarding design and implementation of a GHG regulatory framework are premised, in part, on the assumption of reducing future costs of compliance with AB 32. We agree with GPI that the Commission's recommendations to ARB, improved by GPI's participation, will lead to the achievement of the state's GHG reduction goals to produce these substantial benefits, even though they are hard to quantify. Thus, we find that GPI's participation has been productive.

6.4. Direct Expenses

The itemized direct expenses submitted by GPI cover $235 in expenditures for photocopying, postage and courier deliveries. The cost breakdown included with the request shows these miscellaneous expenses to be commensurate with the work performed. We find these costs reasonable.

⁷ D.07-01-009, p. 8.