6. Reasonableness of Requested Compensation

TURN requests $87,958.29 for its participation in this proceeding, as follows:

ITEM	AMOUNT
Attorney Services	$87,751.25
Direct Expenses	$207.04
Total Expenses Claimed	$87,958.29

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.

As set forth in Appendix A of TURN's request for compensation, TURN documented its claimed hours by presenting a daily breakdown of the hours of its attorneys, accompanied by a brief description of each activity. The hourly breakdown reasonably supports the claim for total hours.

6.2. Market Rate Standard

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.

With the exception of the requested rates for 2006 for its attorney Hayley Goodson, and 2007 for its attorneys Michael Florio and Marcel Hawiger, the hourly rates that TURN requests for its attorneys were previously approved by the Commission in the decisions as set forth in the following table:

Name	2004 Rate	2005 Rate	2006 Rate
Michel P. Florio	$470 - D.05-01-029	$470 - D.05-11-031	$485 - D.06-11-031
Marcel Hawiger	$270 - D.05-04-031	$270 - D.06-04-029	$280 - D.06-10-018
Hayley Goodson	$190 - D.05-01-007	$190 - D.05-01-007	n/a

For Goodson's 2006 rate, TURN requests an hour rate of $195. This rate represents a 3% increase over the authorized 2004-2005 rate of $190, rounded to the nearest $5 increment.

For Florio's 2007 rate, TURN requests an hourly rate of $500. This rate represents a 3% increase over the authorized 2006 rate for Florio, rounded to the nearest $5 increment.

For Hawiger's 2007 rate, TURN requests an hourly rate of $290. This rate represents a 3% increase over the authorized 2006 rate for Hawiger, rounded to the nearest $5 increment.

D.07-01-009 adopted, among other things, a 3% cost-of-living adjustment (COLA) for work performed in calendar year 2006, and a 3% COLA for work performed in 2007. Consistent with D.07-01-009, TURN's request for a 3% increase to Goodson's 2004-2005 rate, and a 3% increase to the 2006 rates of Florio and Hawiger are justified. We adopt an hourly rate of $195 for Goodson for 2006, an hourly rate of $500 for Florio for 2007, and an hourly rate of $290 for Hawiger for 2007.

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.

TURN points out that it is difficult to establish a specific dollar amount for the quantifiable benefits to ratepayers in this proceeding. However, as a result of TURN's participation, ratepayers will not be forced to pay for system expansions at Otay Mesa. TURN's advocacy also prevented the elimination of the peaking rate. In addition, TURN reduced the utilities' recovery of the citygate pooling costs from $2 million to $500,000, which amounts to a savings of $1.5 million for ratepayers.

We find that TURN's participation in this proceeding was productive, and bears a reasonable relationship to its participation.

6.4. Direct Expenses

The itemized direct expenses submitted by TURN include costs for photocopying, postage, telephone charges, and attorney expenses related to parking, which total to $207.04. Appendix B of TURN's compensation request provides a cost breakdown of these expenses. We find these costs to be reasonable, and commensurate with the work performed.