residential and small commercial markets through the implementation of programs, such as the whole house audits/retrofit and the small “comprehensive” commercial direct install programs. Duquesne notes that further review of projected administrative budgets shows that its or common management costs to “portfolio” implement the Plan are approximately $3 million, or approximately five percent of the Plan budget. Table 6A. According to Duquesne, the remaining $19.5 million of See administrative costs, or approximately thirty-three percent of the authorized budget, are for CSP performance payment fees and other direct program implementation costs. Therefore, Duquesne opines that stated concern about the level of Plan costs being DII’s paid to the CSPs is unjustified. Duquesne states that the CSPs Company’s Company’s are projected to receive approximately $19.5 million of the Phase II Plan Company’s budget, compared to the projected $28 million in customer incentives. at 13-14. Id. b. Disposition While the judicious and effective use of customer-provided funds is a paramount concern, we do not find undeveloped challenge of Phase II DII’s Duquesne’s Plan based on the overall ratio of the total incentive and non-incentive costs to be convincing. In its reply, the Company has provided the specific cost breakdown of its projected administrative costs, which we accept as reasonable. DII has failed to recommend a specific modification to the Phase II Plan and has not presented Company’s any evidence that the ratio of incentive to non-incentive costs set forth in the Company’s Phase II Plan is improper. Also, DII did not offer an alternative to the ratio proposed by the Company. Absent evidence developed in the record of this proceeding to challenge the specific estimates proposed by Duquesne, we reject assertions on this issue. DII’s 4. Ability to Bid Savings into PJM Markets a. Positions of the Parties
residential and small commercial markets through the implementation of “comprehensive” programs, such as the whole house audits/retrofit and the small commercial direct install programs. Duquesne notes that further review of projected administrative budgets shows that its “portfolio” or common management costs to implement the Plan are approximately $3 million, or approximately five percent of the Plan budget. See Table 6A. According to Duquesne, the remaining $19.5 million of administrative costs, or approximately thirty-three percent of the authorized budget, are for CSP performance payment fees and other direct program implementation costs. Therefore, Duquesne opines that DII’s stated concern about the level of Plan costs being paid to the Company’s CSPs is unjustified. Duquesne states that the Company’s CSPs are projected to receive approximately $19.5 million of the Company’s Phase II Plan budget, compared to the projected $28 million in customer incentives. Id. at 13-14. b. Disposition While the judicious and effective use of customer-provided funds is a paramount concern, we do not find DII’s undeveloped challenge of Duquesne’s Phase II Plan based on the overall ratio of the total incentive and non-incentive costs to be convincing. In its reply, the Company has provided the specific cost breakdown of its projected administrative costs, which we accept as reasonable. DII has failed to recommend a specific modification to the Company’s Phase II Plan and has not presented any evidence that the ratio of incentive to non-incentive costs set forth in the Company’s Phase II Plan is improper. Also, DII did not offer an alternative to the ratio proposed by the Company. Absent evidence developed in the record of this proceeding to challenge the specific estimates proposed by Duquesne, we reject DII’s assertions on this issue. 4. Ability to Bid Savings into PJM Markets a. Positions of the Parties