distribution plant based on customer count. As a position, OCA “compromise” recommended that the Commission allocate 100% of primary plant on a demand basis and apply the minimum size study to allocate secondary plant on a customer and OCA’s demand basis. OCA M.B. at 77-82. The OCA further argued that the Parties have misinterpreted the 2010 Order that NARUC has updated its cost of service principles since Commission’s issuing the 1992 NARUC Manual, and argued that its recommendation reflects a compromise. OCA R.B. at 33-38. The OSBA, PPLICA and REG supported position on COSS PPL’s allocation and believe that it is consistent with the NARUC Manual and reflects a more realistic operation of system than the OCA counterproposal. PPL’s The OSBA stated that its primary focus in this case has been to determine whether the COSS presented by the Company conformed to the COSS approved by the Commission in the 2010 base rate case. The OSBA concluded that it did, and therefore, there was no need to re-litigate it in this proceeding. OSBA M.B. at 7. REG agreed with the classification of distribution plant as Company’s partially customer-related and partially demand-related, and the allocation of Company’s the plant. This, REG argued, is consistent with the disposition of the Commission’s last rate case as well. REG M.B. at 4-5. Company’s PPLICA argued in favor of the COSS, which it believed Company’s properly allocates primary distribution facilities costs in both a customer and demand component and is consistent with NARUC policies. PPLICA characterized the OCA approach as density analysis with no meaningful relation to the cost of “a results-driven service principles historically applied by the Commission and supported by NARUC.”
distribution plant based on customer count. As a “compromise” position, OCA recommended that the Commission allocate 100% of primary plant on a demand basis and apply the OCA’s minimum size study to allocate secondary plant on a customer and demand basis. OCA M.B. at 77-82. The OCA further argued that the Parties have misinterpreted the Commission’s 2010 Order that NARUC has updated its cost of service principles since issuing the 1992 NARUC Manual, and argued that its recommendation reflects a compromise. OCA R.B. at 33-38. The OSBA, PPLICA and REG supported PPL’s position on COSS allocation and believe that it is consistent with the NARUC Manual and reflects a more realistic operation of PPL’s system than the OCA counterproposal. The OSBA stated that its primary focus in this case has been to determine whether the COSS presented by the Company conformed to the COSS approved by the Commission in the 2010 base rate case. The OSBA concluded that it did, and therefore, there was no need to re-litigate it in this proceeding. OSBA M.B. at 7. REG agreed with the Company’s classification of distribution plant as partially customer-related and partially demand-related, and the Company’s allocation of the plant. This, REG argued, is consistent with the Commission’s disposition of the Company’s last rate case as well. REG M.B. at 4-5. PPLICA argued in favor of the Company’s COSS, which it believed properly allocates primary distribution facilities costs in both a customer and demand component and is consistent with NARUC policies. PPLICA characterized the OCA approach as “a results-driven density analysis with no meaningful relation to the cost of service principles historically applied by the Commission and supported by NARUC.”
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