AECA

AECA requests compensation in the amount of $101,082.75 as set out below. This amount constitutes 61.6% of its total cost of participation.

Attorneys Fees

Peter W. Hanschen, 250.5 hours at $300/hour $ 75,150.00

Economic Consultant Fees:

Steven Moss, 206 hours at $130/hour $ 26,780.00

Richard McCann, 131 hours at $130/hour $ 17,030.00

AECA Executive Director's Participation

Michael Boccadoro, 170.2 hours at $125/hour $ 21,275.00

Other Costs

Local travel/transportation $ 673.76

Photocopying $ 6,735.74

Postage $ 942.27

Courier/Messenger $ 366.48

Telecommunications $ 323.61

Facsimile $ 1,253.82

Computer Research $ 208.45

Total Fees and Expenses $ 164,095.38

61.6% of Total Fees and Expenses $ 101,082.75

Attorneys and Paralegal-Project Manager Fees

Scott Fielder, 71.48 hours at $150/hour $ 10,722.00

James S. Adams, 66 hours at $37.50/hour $ 2,475.00

Expert Witness Fees and Costs

Bruce Biewald, 166 hours at $110/hour $ 18,260.00

Expert Witness Expenses $ 1,085.87

Costs $ 6,939.69

(Including copying, postage, and travel expense incurred by Fielder)

Total Fees and Expenses $ 62,186.56

Attorneys Fees

Robert Finkelstein, 4.5 hours at $235/hour $ 1,057.50

Theresa Mueller, 273.25 hours at $205/hour $ 56,016.25

Michael Florio, 2.0 hours at 290/hour $ 580.00

Expert Witness Fees and Expenses

William Marcus, 271.0 hours at $145/hour $ 39,295.00

Gayatri Schilberg, 481.5 hours at $105/hour $ 50,557.50

Jeff Nahigian, 239.75 hours at $85/hour $ 20, 378.75

Ron Faubion, 32.15 hours at $50/hour $ 1,607.50

JBS Expenses $ 1,772.57

Jacob Pous, 360.5 hours at $125/hour $ 45,062.50

Sara Coleman, 45.5 hours at $100/hour $ 4,550.00

Don Martin, 37 hours at $45/hour $ 1,665.00

DUCI expenses $ 4,236.78

Other Costs

Photocopying $ 3,969.47

Postage $ 1,005.81

Facsimile $ 355.70

Federal Express/Delivery costs $ 857.41

Telephone $ 576.62

Computer research (Lexis charges) $ 53.88

Total Fees and Expenses $ 407,099.45

Fees

James Weil, 396.4 hours at $200/hour $ 79,280.00

Costs

Photocopying $ 1,081.86

Postage $ 642.94

Travel (tolls, parking, mileage, transportation) $ 839.85

Facsimile and Telephone $ 274.37

Expense Adjustment $ (9.05)

Total Fees and Expenses $ 97,204.97

5.1 Overall Benefits of Participation

Section 1801.3(f) provides, in part, that the Commission should administer the intervenor compensation statute "in a manner that avoids unproductive or unnecessary participation that duplicates the participation of similar interests otherwise adequately represented..."

Duplication

In D.98-04-059, the Commission interpreted the goal of reducing duplication with some flexibility, especially in multiparty cases such as this general rate case.


"The Commission has recognized that administering this standard requires flexibility. In multiparty proceedings, parties' positions likely will overlap. However, a party that is basically aligned with other parties may make its own suggestions, adopted by the Commission, that provide measurable and significant ratepayer benefits. Such participation, at least to that extent, seems compensable under this standard, especially in light of § 1802(h). (D.98-04-059, at p. 32.)

The May 20, 1998 ALJ ruling advised the parties that to the extent their efforts merely duplicated those of other parties, they were at risk of receiving reduced or no compensation for those efforts. The ruling further advised the parties to coordinate to the extent possible to avoid unnecessary duplication.

A major general rate case will have many participants, and most have the same goal of convincing the Commission to set PG&E's authorized revenue requirement at what they believe to be the lowest reasonable level. Necessarily, there may be some overlap in the parties' participation. The parties seeking compensation explain that they took all reasonable steps to keep duplication to a minimum and to ensure that when it did occur, the work complemented and assisted the showing of other parties. Furthermore, the parties have reduced their requests to reflect duplication, where appropriate. Because of these efforts and the showings of the four participants requesting compensation, we do not believe that these requests should be further reduced for duplication.

Productive Representation

In D.98-04-059, the Commission adopted a requirement that a customer must demonstrate that its participation was "productive," as that term is used in § 1801.3, where the Legislature gave the Commission guidance on program administration. (See D.98-04-059, at pp. 31-33, and Finding of Fact 42). In that decision, we discuss the fact that participation must be productive in the sense that the costs of participation should bear a reasonable relationship to the benefits realized through such participation. Customers are directed to demonstrate productivity by assigning a reasonable dollar value to the benefits of their participation to ratepayers. This exercise assists us in determining the reasonableness of the request and in avoiding unproductive participation.

AECA

In this phase of PG&E's general rate case, the Commission set a revenue requirement for PG&E. AECA states it believed that PG&E's requested increase was greatly inflated, and if approved, would have a direct effect on the rate charged agricultural customers. Therefore, AECA participated both in this phase of the general rate case, as well as in the rate design phase, where it had focused its energy in past general rate cases.

Because AECA coordinated with other intervenors to avoid duplication, AECA focused on investigating PG&E's corporate policy underlying its filing and also offered policy testimony on reliability issues. The ALJ's proposed decision discussed much of this policy testimony, and the adopted decision did so as well. (See D.00-02-046, at p. 45.) In addition, AECA supported the alternate decision which the Commission adopted.

Although it is difficult to specifically quantify these benefits, through AECA's participation, the Commission had a record on which to assess PG&E's corporate policy, and to put PG&E's requested revenue requirement increase in proper context. AECA's testimony also contributed to the Commission's overall understanding and consideration of one of the most fundamental issues in the case, that is, the need to improve and maintain system reliability, and the ratepayer cost to do so. However, AECA did not make as full of a showing on productivity as we would have liked. To account for this, we reduce AECA's award by 10%, or by $9,492.07. We find AECA's participation was productive in that the adjusted costs it claims for its participation were less than the overall benefits realized.

Redwood

Redwood states that that its adopted recommendations will reduce ratepayer costs by about $47 million if the Humboldt Bay nuclear plant is decommissioned early. Moreover, Redwood states that ratepayers may also avoid future costs as a result of the timely collection of funds for the Diablo Canyon nuclear plant's eventual decommissioning.

Although we cannot precisely quantify the dollar amount of Redwood's participation, Redwood's participation was productive because the benefits realized from its participation fall in the millions of dollars. We therefore find that Redwood's participation was productive in that the costs it claims for participation were less than the benefits realized.

TURN

TURN states that there can be no doubt that its participation in this general rate case was productive, because the total amount of compensation it seeks is substantially less than some of the smaller revenue reductions achieved through its participation. For example, TURN's contribution on the gas distribution expense helped to achieve a $2 million reduction in PG&E's revenue requirement. TURN also states that it was primarily responsible for the Commission's rejection of PG&E's requested $282 million revenue increase for depreciation expenses.

We find that TURN's participation was productive in that the costs it claims for participation were less than the benefits realized. TURN participated in many issues in this large case, and the two examples discussed above demonstrate the cost-effectiveness of its participation.

Weil

Weil states that his participation in this general rate case was productive, because the total amount of compensation he seeks is substantially less than the revenue reductions achieved through his participation. For example, Weil's efforts resulted in a $468,000 savings in postage expenses, and a $1 million savings in estimated uncollectibles. Weil's efforts are also partially responsible for a $5,189,000 reduction in the business attraction and retention activities revenue requirement, and are also largely responsible for $7,390,000 savings due to reduced breach of contract costs. Additionally, Weil enumerates other monetary and nonmonetary benefits which resulted from his participation. We find that Weil's participation was productive in that the costs he claims for participation were less than the benefits realized.

5.2 Hours Claimed

All four intervenors documented the claimed hours by presenting a daily breakdown of the hours spent for their advocates' (attorneys and paralegals) time, with a brief description of each activity. Also, the claimed hours are segregated by issue where feasible. All four intervenors also documented the claimed hours of their experts by presenting a breakdown of hours spent, although in some cases the breakdown was not a daily breakdown. The hourly breakdowns presented by these four intervenors reasonably support their respective claims for total hours.

Several specific issues merit mentioning briefly. First, several intervenors have charged for advocate fees for general activities that could not reasonably be divided by issue. These include activities such as reviewing the application, hearing transcripts, the proposed and alternate decisions, etc. We find such an allocation appropriate in a case of this magnitude and complexity, where it is difficult to segregate each task by issue because one task could embrace many issues (i.e. reviewing the initial application, proposed and alternate decisions, etc.)

Second, AECA has not allocated its activities by issue. Because we find that AECA made a substantial contribution to the issues it participated in, and do not reduce the hours of claimed compensation further than AECA has reduced them, AECA's failure to properly allocate its time by issue does not present a problem in this request. However, in future requests, AECA should more specifically allocate its time by issue in the event the Commission finds AECA did not substantially contribute to a given issue.

Finally, Weil requests compensation for his participation in advice letter compliance filings connected to this general rate case. Weil explains that his protest to PG&E's compliance advice letter raised three issues: the disparity between text and tables regarding uncollectibles rate, a proposed Gas and Electric Supply memorandum account, and a proposed gas refund plan. In response to Weil's protest, PG&E modified the gas refund plan and filed an amended advice letter. The modifications satisfied Weil's concern, he notified the Energy Division that he would not protest the amended advice filing, and the refund plan is now underway.

Weil submits that he made a substantial contribution to the modified gas refund plan, and requests compensation for 50% of his time spent on the protest and subsequent communications with PG&E. Weil does not concede compensation for the other two issues raised by the advice letter, but agrees that any compensation request must await a Commission resolution or decision.

Because Weil substantially contributed to the advice letter on the requested issue, the advice letter is a compliance filing which relates to this general rate case, and the time spent for this effort is reasonable, we approve Weil's inclusion of time spent on the advice letter in his compensation request. (See generally D.98-11-049, which granted Weil compensation for his participation in the advice letter process.)

5.3 Hourly Rates

AECA

AECA seeks $300/hour for work performed by its attorney Peter W. Hanschen in 1998, $325/hour for work performed in 1999, and $350/hour for work performed in 2000.8 AECA states that during the course of the proceeding, Hanschen changed law firms, having first been a partner at Graham & James LLP, and later a partner with Morrision & Foerster LLP. AECA represents that the rates above are the rates Hanschen billed AECA.

AECA states that these rates are comparable to the rates charged by others with commensurate experience and expertise. Hanschen has practiced in the energy area and before this Commission for more than 25 years. He was formerly an attorney in PG&E's legal department and was the head of its regulatory section. He has represented AECA since its founding ten years ago, and is familiar with energy issues and how they relate to agriculture.

AECA does not cite to our past decisions addressing Hanschen's hourly rate. In D.96-08-040, 67 CPUC2d 562, addressing numerous compensation requests in the electric restructuring proceeding, the Commission approved similar hourly rates for Hanschen and Florio, TURN's most experienced attorney. (See 67 CPUC2d at p. 578-79, approving $250/hour for Hanschen for 1995 and 1996, and 67 CPUC2d at p. 591, approving $250/hour for Florio in 1995 and $260/hour for 1996.) The latest Commission decision addressing Hanschen's rate is D.98-10-051, where the Commission approved Hanschen's requested hourly rate of $250/hour for work performed in 1996 and 1997.

In D.99-11-049, the Commission approved a $300 hourly rate for Florio for his professional work performed during the fiscal year July 1, 1998 through June 30, 1999. This rate was in part based on the average partner rate of $309/ hour in an Of Counsel survey of reported ranges of partner hourly rates. We therefore find Hanschen's hourly rate of $300/hour falls within a reasonable range for work performed in 1998, even though it is a substantial increase (20%) over the hourly rate we approved for Hanschen in 1997. However, given that $300/hour is a substantial increase in Hanschen's approved hourly rate, we do not believe it appropriate to increase this hourly rate further for work performed in 1999 and 2000 in this proceeding. This result is also consistent with the hourly rate we approve below for Florio for work performed in 1999 and 2000. We therefore approve an hourly rate of $300/hour for all of Hanschen's professional work in this proceeding.

The Commission's policy is to compensate travel time at half of the approved hourly rate. Hanschen bills his full hourly rate for travel time on May 27, 1998 and February 17, 2000. Since these billings do not specifically segregate travel and professional time, we direct that five hours billed on these dates should be compensated at half of Hanschen's hourly rate, and reduce AECA's award accordingly. In future compensation requests, AECA should segregate and appropriately bill for its travel time.

AECA seeks $130/hour for work performed by Steven Moss and Richard McCann, economic consultants from M. Cubed. Moss is a co-founder with M. Cubed and a former principal with Foster Associates, Inc. He has presented testimony and conducted analysis on economic, environmental and energy issues before various California legislative and regulatory bodies, including the Commission, and has led studies into the economic characteristics and water usage patterns of Central Valley agriculture. Prior to joining Foster Associates, Moss was on the staff of the U.S. House of Representatives and the U.S. Office of Management and Budget. He holds a B.S. from the University of California, Berkeley, and a Master of Public Policy from the University of Michigan, Ann Arbor.

McCann, a partner in M. Cubed, specializes in environmental and energy resource economics and policy. He has testified before the Commission, as well as other regulatory agencies. McCann received a Ph.D in Agriculture and Resource Economics from the University of California, Berkeley. Prior to joining M. Cubed, McCann held professional positions with Foster Associates, QED Research, Inc. and Dames & Moore.

AECA's request states that the Commission has found Moss' and McCann's rates to be reasonable in other Commission proceedings, but does not state what those other proceedings were, or what hourly rate was approved. In the most recent decision addressing Moss' hourly rate, D.98-10-051, the Commission approved $100/hour for Moss' work performed in 1996 and 1997. The Commission also approved an hourly rate of $100 for both Moss and McCann for work performed in 1994 and 1995. (See 67 CPUC2d at 579.) Moss and McCann have not sought an increase in this $100 hourly rate for several years, nor have they addressed in this filing why such an increase is appropriate here. We believe that an increase of 30% is excessive, and find more reasonable a rate of $120/hour for professional work performed by Moss and McCann during 1998 in this proceeding. This increase in hourly rate reflects additional experience both experts have gained in participating in Commission proceedings, as well as inflation costs.

AECA also seeks $125/hour for the work of Executive Director Michael Boccadoro. We found that rate reasonable in D.98-10-051 and we apply it here. However, Mr. Boccadoro billed his full hourly rate for 6.1 hours spent on June 29, 1998 for traveling to and attending a meeting with intervenors, and did not segregate these activities. Other intervenors billed between 2-3 hours to prepare for and attend this same meeting. Therefore, we determine that 3 hours of Boccadoro's time should be billed at half the hourly rate for travel, and reduce the award accordingly. In future applications, AECA should segregate and appropriately charge for its travel time.

Redwood

Redwood seeks $150/hour for work performed by its attorney, Scott L. Fielder. Redwood seeks compensation for 74% of Fielder's hours spent on professional services, excluding hours spent on non-productive issues. Redwood also appropriately seeks compensation for half of Fielder's hourly rate for hours spent on travel and compensation-related activities.

Fielder was awarded a J.D. from Southwestern University School of Law in 1978. He has practiced criminal law and civil litigation for approximately 19 years. During that time, he has also tried many nuclear power plant cases before this Commission and the Atomic Licensing Safety Board. $150/hour is a reasonable hourly rate, and we approve this rate for the professional work Fielder performed in this proceeding.

Redwood seeks $110/hour for professional services rendered by Bruce Biewald. Biewald received a B.S. in Architecture, Building Technology, and Energy Use in Buildings in 1981 from the Massachusetts Institute of Technology. He attended Harvard University Extension School in 1989/90, taking graduate courses in micro and macroeconomics. Since 1996, Biewald has been president of Synapse Energy Economics, Inc. in Cambridge, Massachusetts. He is a consultant on a wide variety of energy and economic issues, including nuclear and fossil power plant costs and performance, nuclear plant decommissioning and radioactive waste issues. In 1986, he testified before this Commission on Diablo Canyon decommissioning cost and collection issues. Biewald has also testified before numerous other state utility commissions, and the Federal Energy Regulatory Commission. A rate of $110/hour is reasonable, in the range of rates we approve for AECA's and TURN's respective experts, and we approve it for Biewald's professional work performed in this proceeding.

Redwood has also attached receipts for other costs incurred and billed by Biewald, including airplane, hotel, shuttle, and meal costs. These costs total $1,085.87, and we approve them as reasonable.

Redwood seeks $75/hour for professional work performed by its paralegal-project manager James S. Adams, and half of this hourly rate for travel time. Redwood seeks compensation for 74% of Fielder's hours spent on professional services, excluding hours spent on non-productive issues. We have previously found this $75/hour rate reasonable, and we apply it here.

TURN

TURN seeks $250/hour for Finkelstein for work performed in 1998 and $265/hour for work performed in 1999, and half the 1999 hourly rate for work performed on intervenor compensation issues. TURN seeks $205/hour for work performed by Mueller in 1997-98. TURN seeks $290/hour for work performed by Florio for 1997-98 and $300/hour for work performed in 1999-2000. We have already approved these rates in other proceedings for similar work. We approve these rates again here.

Marcus, Principal Economist for JBS Energy, and Schilberg, Senior Economist, bore primary responsibility for presenting TURN's testimony on all issues except depreciation. Marcus' testimony addressed policy issues as well as electric and gas capital as well as administrative and general expenses, among other issues. Schilberg's testimony focused primarily on service quality and tree trimming issues. Whenever possible, Marcus and Schilberg delegated work related to the specific review of PG&E's testimony, workpapers, and data request responses to Nahigian and Faubion. JBS Energy allocated its time to the following tasks: NOI, application review, and testimony development; hearing assistance and preparation; briefing assistance; and review of proposed and alternate decision and related comments. JBS billed TURN for half of the time JBS employees spent on travel.

TURN seeks $145/hour, $105/hour, and $85/hour for work performed in 1997 and 1998 by Marcus, Schilberg, and Nahigian respectively, and $150/hour, $110/hour, and $95/hour for work performed in 1999 by these three persons. We have already approved these rates in other proceedings for similar work and approve these rates again here.

TURN seeks $50/hour for work performed by Faubion. TURN states that Faubion performed much the same work for JBS Energy as did Helmich, his predecessor. This work includes preliminary analysis of data request responses and other tasks related to the preparation and presentation of JBS Energy's final testimony or draft sections of TURN's brief. TURN states that although Fabion does perform clerical tasks as well, JBS Energy only billed TURN for that portion of Fabion's time devoted to tasks that are more "professional" in nature. TURN justifies Faubion's requested $50/hour by stating that the Commission, in D.98-08-016, has previously approved a $45/hour rate for similar work done by Helmich in 1996 and 1997, and increased that rate to $50/hour (albeit for one hour of work) in D.99-02-006.

In D.99-11-006, at p. 14, we declined to award any compensation for Faubion because Utility Consumers Action Network sought compensation for clerical work performed by Faubion. However, TURN requests compensation for Faubion's professional services rendered in a Commission proceeding, which TURN characterizes as work similar to that performed by Helmich. We only increased Helmich's compensation award from $45 to $50/hour (for only one hour of work at the higher rate) after he had participated in many Commission proceedings. Because this is the first compensation award for Faubion, we find an hourly rate of $45/hour reasonable.

Jacob Pous and Diversified Utility Consultants, Inc. (DUCI)

About one quarter of the total revenue requirement increase which PG&E originally sought related to changes in its depreciation practices. TURN retained DUCI to undertake a detailed review of PG&E's depreciation practices. This is the first time TURN seeks compensation from the Commission for DUCI.

TURN seeks $125/hour for work performed by Jacob Pous, Principal of DUCI. Pous bore primary responsibility for developing and presenting TURN's depreciation testimony and also assisted with preparing the briefs on depreciation issues. Pous delegated work to lower priced firm members at DUCI when appropriate to minimize the total cost of service to TURN. TURN states that DUCI charged TURN $125/hour for Pous' work.

Pous graduated from the University of Missouri with a B.S. in Engineering in 1972, and obtained a M.A. in Management from Rollins College in 1980. Pous has also completed a series of depreciation programs sponsored by Western Michigan University, and has attended numerous other utility related seminars.

Since 1972, Pous has worked in the utility field, first as an employee of Kansas City Power & Light Company, then in an independent consulting engineering firm. After ten years with that firm, Pous resigned to create DUCI in 1986. As a principal of DUCI, Pous has presented and prepared many electric, gas, and water analyses in both retail and wholesale proceedings, with clients (including public utility commissions) throughout the United States.

TURN submits that Pous' qualifications are similar to those of Marcus, the Principal Economist for JBS Energy. In D.00-05-006, the Commission discussed Marcus' qualifications: Marcus graduated from Harvard College with an A.B. magna cum laude in Economics in 1974, and received a M.A. in Economics from the University of Toronto in 1975. Marcus has been directly involved in the field of energy and policy and utility regulation for over twenty years, and has appeared often before this Commission.

Marcus has much more experience appearing before this Commission than does Pous. We award Marcus a rate of $145/hour for work performed in 1997 and 1998, and $150/hour for work performed in 1999. Pous' requested rate of $125/hour, which is below Marcus' current rate, is reasonable given that this is Pous' first appearance before this Commission and we approve it for the work performed in this proceeding.

TURN seeks $100/hour for work performed by Sara Coleman in this proceeding. Coleman is a Certified Public Accountant licensed to practice in Texas where DUCI is located. Coleman has worked three years with the public accounting firm of Arthur Andersen, and three and a half years as a regulatory accountant with the Texas Public Utilities Commission. To demonstrate the reasonableness of its request, TURN refers to D.96-08-040, 67 CPUC2d 562, addressing compensation requests in the electric restructuring proceeding. The decision includes a broad survey of the range of expert fees incurred by intervenors in that proceeding. The Commission noted that the range of approved hourly rates for expert witness-related work on behalf of qualifying intervenors was $100 to $175 in 1995. (67 CPUC2d at p. 580.)

Coleman has regulatory experience, although this is the first time Coleman has appeared in this Commission's proceedings. TURN's requested hourly rate of $100/hour for work performed by Coleman in this proceeding in 1998 is reasonable and we approve it.

TURN seeks $45/hour for work performed by Don Martin in this proceeding. TURN states that Martin has extensive experience in computer modeling and data management. Since being employed by DUCI, Martin has assisted Pous in analyzing numerous depreciation studies. TURN submits that in the data intensive field of performing and critiquing depreciation studies, Martin's work is especially valuable. TURN believes Martin's work is similar to that performed by Helmich for JBS Energy in 1997, and should establish the reasonableness of the requested hourly rate for Martin's work in 1998. We agree that $45/hour is a reasonable rate for Martin's work in this proceeding.

Enhancement

TURN seeks a 25% enhancement (calculated as $19,224.69) to its baseline compensation request for the portion of the fee award covering work which TURN and DUCI performed on depreciation-related issues. TURN believes this enhancement is appropriate because of the exceptional results it achieved on depreciation issues.

After the Commission has determined an appropriate base level of compensation, the Commission has, in certain cases, awarded an enhancement, or upward adjustment to that base level. In D.88-02-056, at pp. 3-4, the Commission set forth factors that can be considered in making this determination.

The Commission has awarded TURN an enhancement to all or part of its base compensation on many occasions. (See D.88-02-056 [25% enhancement based on the dollar amount involved and TURN's level of success]; D.93-04-048 [20% enhancement based on TURN's degree of success, the novel and complex issues, TURN's efficiency and skill, and the contingent nature of the litigation]; D.94-09-022 [35% enhancement based on the substantial dollars involved, TURN's degree of success, the complexity and risks involved, the contingent nature of the litigation, and the exceptional skill of TURN's attorney]; D.96-09-024, 67 CPUC2d 678, 690-91 [25% enhancement for TURN's 1995 work on Phase 1 issues based on the substantial dollars involved, TURN's degree of success, the difficulty and complexity of the litigation, TURN's efficiency, and the contingent nature of the litigation.])

TURN's requested 25% enhancement for its work performed on depreciation-related issues is justified. TURN achieved a remarkable degree of success on these issues, because without TURN's work, PG&E's proposed changes to its depreciation parameters, and particularly to its net salvage values, would have resulted in an increase of as much as $282 million in PG&E's depreciation and amortization expense. In D.00-02-046, the Commission instead authorized PG&E no increase for these items. TURN's participation on these issues was also efficient, because one attorney was assigned to the depreciation issues, as well as many of other issues. TURN's enhancement request is also justified because the depreciation issues concerned substantial dollars (depreciation accounted for about one quarter of PG&E's initial requested increase in revenue requirement.) Finally, TURN's scope of work, and therefore its risks, were larger than usual. The risks were even greater because TURN was working with a consultant firm that had never before appeared before this Commission. For these reasons, we grant TURN a 25% enhancement for both its attorney and consultant time spent on depreciation-related issues.

Weil

Weil requests an hourly rate of $200 for professional work performed in 1999 and $220 for such work performed in 2000. We follow D.00-07-015 and establish Weil's compensation rate at $200/hour for professional time in 1999, and $220 for such work performed in 2000. Weil's rate for travel and compensation-related activities is half of the above hourly rates.

5.4 Other Costs

All intervenors request reimbursement for copying, postage, travel and other miscellaneous expenses incurred during their participation in this proceeding. With two exceptions set forth below, these costs are reasonable in a case of this magnitude and should be compensated in full. AECA requests compensation for $6,735 for photocopying expenses. The requested expense is excessive and far greater than other intervenors' requests for such expenses. For example, TURN's photocopying expenses are approximately $4,000, while Redwood and Weil each request approximately $1,000 for photocopying. The scope of AECA's participation falls roughly somewhere between that of TURN's and the other intervenors'. We therefore limit AECA's photocopying charges to a reasonable level of $3,000. We apply similar rationale in reducing AECA's request for fascimile expenses from $1,253.82 to $800.

7 Redwood made an inadvertent $0.24 cent mathematical error in calculating its requested compensation for Adams. These figures correct that error. 8 AECA bills 0.1 of an hour for work performed in early 1999 at the 1998 hourly rates.

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