iv. Additional WRAP Measures (a). Positions of the Parties CEO asserts that Low-income WRAP program should include more PPL’s direct measures for the low-income sector, as opposed to providing education measures. CEO contends that the lack of direct measures targeted at low-income customers under the program differs from the many and substantial direct measures offered to the other customer sectors under the Phase II Plan. CEO MB at 4. In addition to Company’s recommending the installation of a greater number of heat pump water heaters than that proposed by the Company (addressed above), CEO also recommends other direct measures be targeted at low-income customers. These include NEST “learning air sealing, smart strips, and energy information displays. thermostats,” infrared guided Id. In response, PPL provides reasons as to why none of proposed CEO’s measures should be adopted. With regard to the NEST thermostat, PPL asserts that it evaluated this device, but determined that it was not configured to work properly with air source heat pumps. PPL MB at 34. Moreover, PPL contends that the SWE and the Commission have maintained that the TRM does not allow heating mode savings for any type of programmable thermostat with an air source heat pump. PPL St. No. 1R at Id.; 26. PPL identifies further technical and operational issues regarding the NEST thermostat that would render it an inappropriate measure to include in its Phase II Plan. PPL MB at 33-34; PPL St. No. 1R at 26-27. With regard to infrared guided air sealing, PPL asserts that this measure would be cost prohibitive, and would not be part of the baseload WRAP job. Company’s PPL MB at 35; PPL St. No. 1R at 27-28. As for smart strips, PPL asserts that the
iv. Additional WRAP Measures (a). Positions of the Parties CEO asserts that PPL’s Low-income WRAP program should include more direct measures for the low-income sector, as opposed to providing education measures. CEO contends that the lack of direct measures targeted at low-income customers under the program differs from the many and substantial direct measures offered to the other customer sectors under the Company’s Phase II Plan. CEO MB at 4. In addition to recommending the installation of a greater number of heat pump water heaters than that proposed by the Company (addressed above), CEO also recommends other direct measures be targeted at low-income customers. These include NEST “learning thermostats,” infrared guided air sealing, smart strips, and energy information displays. Id. In response, PPL provides reasons as to why none of CEO’s proposed measures should be adopted. With regard to the NEST thermostat, PPL asserts that it evaluated this device, but determined that it was not configured to work properly with air source heat pumps. PPL MB at 34. Moreover, PPL contends that the SWE and the Commission have maintained that the TRM does not allow heating mode savings for any type of programmable thermostat with an air source heat pump. Id.; PPL St. No. 1R at 26. PPL identifies further technical and operational issues regarding the NEST thermostat that would render it an inappropriate measure to include in its Phase II Plan. PPL MB at 33-34; PPL St. No. 1R at 26-27. With regard to infrared guided air sealing, PPL asserts that this measure would be cost prohibitive, and would not be part of the Company’s baseload WRAP job. PPL MB at 35; PPL St. No. 1R at 27-28. As for smart strips, PPL asserts that the