6. Reasonableness of Requested Compensation

CMRAA's claims its reasonable costs for participating in this proceeding totaled $24,058. CMRAA notes that because it did not prevail on all issues, yet did provide a substantial contribution to the final decision, it is discounting the

request by 20%. Thus, CMRAA requests $19,246⁴ for its participation, as follows:

Advocate	Year	Hours	Rate	%	Amount
Bruce Stanton, Attorney	1999, 2000	39.2	$175.00	80%	$5,488.00
Jeff Nahigian, Economist	1999	60.5	$ 90.00	80%	$4,356.00
Jeff Nahigian, Economist	2000, 2001	120	$ 95.00	80%	$9,120.00
				Subtotal	$18,964.00
Copies/Postage/ Delivery			$352.85	80%	$282.28
				Total	$19,246.28

6.1 Hours Claimed

CMRAA documented the claimed hours by presenting a daily breakdown of hours with a brief description of each activity. We note that CMRAA has reported travel and compensation request preparation hours separately from professional time, but has incorrectly charged these hours at the full hourly rate, not at one-half the hourly rate. We will adopt CMRAA's voluntary reduction of 20% of its hours. With that adjustment, the hours claimed are reasonable.

6.2 Hourly Rate

CMRAA requests $175 per hour for its attorney, Bruce Stanton. Stanton has practiced since 1982, specializing in the field of mobilehome law and represented the industry in I.93-10-022 in 1994-96. In light of this experience, $175/hour is a reasonable compensation rate for Stanton.

CMRAA requests rates of $90/hour for 1999 and $95/hour for 2000-2001 for Jeff Nahigian, a Senior Economist with JBS Energy, Inc. Nahigian's hourly rates were approved by the Commission in D.00-05-017 and in D.01-06-076, and we rely on them here.

Our normal practice is to compensate at half the full hourly rate time spent on travel or preparation of the intervenor compensation request. (D.98-04-059, 79 CPUC 2d 628, 688.) Here, Nahigian, an advocate that is compensated at a lower hourly rate, drafted CMRAA's compensation request. When a less highly compensated advocate has prepared the request for compensation, we have awarded compensation at the full hourly rate and we do so here. (See D.98-12-053 at 13.)

6.3 Other Costs

Other costs necessary for participation in this proceeding were out-of-pocket expenses for copies, postage, and Federal Express delivery amounting to $352.85, about 2.6%. The total amount claimed for these costs is reasonable considering the duration and substance of the proceeding and we will not apply the 20% reduction to them.