incentives decrease and the non-incentives remain the same or increase, the ratio of incentives to non-incentives will increase. Id. PPL argues that if it simply increases incentives for a measure in order to increase the ratio of incentives to non-incentives, PPL would be overpaying incentives, and would have to reduce the number of measures rebated—and hence, the total savings—in order to absorb the additional costs. at 41-42. PPL states that it believes Id. the ratio of Phase II incentives to non-incentives is reasonable based on the mix of measures and programs in its EE&C Plan, but will closely monitor its incentive and costs to ensure they are appropriate, and will propose changes to its Phase II Plan if necessary. at 42. Id. Finally, with regard to conclusion that the Commission not rely PPLICA’s on the TRC analysis to evaluate Phase II Plan, PPL asserts that this request should PPL’s be rejected because it is inconsistent with Act 129 and Commission precedent. PPL notes that Act 129 directs the Commission to use a TRC test to analyze the benefits and costs of the EE&C plans, and that the affirms Phase II Implementation Order Commission’s this requirement. at 43. Id. ii. Disposition We agree with PPL that PPLICA provided no evidence in this proceeding to support a conclusion that projected ratio of incentive to non-incentive costs is PPL’s inappropriate. While PPLICA avers that slightly higher level of incentive costs PPL’s relative to non-incentive costs suggests an inefficient allocation of dollars between customer incentives and CSP payments, PPLICA has failed to provide any evidence to challenge the specific methodology used by PPL in assessing the cost-effectiveness of the individual Phase II programs proposed by the Company, or of the Phase II Plan as a whole. Furthermore, as PPL argues, PPLICA offered no suggestions for specific changes
incentives decrease and the non-incentives remain the same or increase, the ratio of incentives to non-incentives will increase. Id. PPL argues that if it simply increases incentives for a measure in order to increase the ratio of incentives to non-incentives, PPL would be overpaying incentives, and would have to reduce the number of measures rebated—and hence, the total savings—in order to absorb the additional costs. Id. at 41-42. PPL states that it believes the ratio of Phase II incentives to non-incentives is reasonable based on the mix of measures and programs in its EE&C Plan, but will closely monitor its incentive and costs to ensure they are appropriate, and will propose changes to its Phase II Plan if necessary. Id. at 42. Finally, with regard to PPLICA’s conclusion that the Commission not rely on the TRC analysis to evaluate PPL’s Phase II Plan, PPL asserts that this request should be rejected because it is inconsistent with Act 129 and Commission precedent. PPL notes that Act 129 directs the Commission to use a TRC test to analyze the benefits and costs of the EE&C plans, and that the Commission’s Phase II Implementation Order affirms this requirement. Id. at 43. ii. Disposition We agree with PPL that PPLICA provided no evidence in this proceeding to support a conclusion that PPL’s projected ratio of incentive to non-incentive costs is inappropriate. While PPLICA avers that PPL’s slightly higher level of incentive costs relative to non-incentive costs suggests an inefficient allocation of dollars between customer incentives and CSP payments, PPLICA has failed to provide any evidence to challenge the specific methodology used by PPL in assessing the cost-effectiveness of the individual Phase II programs proposed by the Company, or of the Phase II Plan as a whole. Furthermore, as PPL argues, PPLICA offered no suggestions for specific changes
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