c. Office of General Counsel i. Positions of the Parties Legal services to PPL Electric are provided by PPL Office of Corporation’s General Counsel (OGC), and jurisdictional FTY claim for OGC is $6.083 million. PPL’s I&E Exh. 2, Sch. 17 p. 2. According to I&E, claim is based on its HTY expense PPL’s increased by $1.2 million in estimated costs for outside counsel fees related to this proceeding. Because of this, I&E recommended a ratemaking allowance of $4.833 million for OGC expense, which is a $1.2 million reduction to claim. The basis for PPL’s adjustment is to eliminate the additional expense associated with outside counsel I&E’s for this proceeding since the Company also includes a claim for rate case expense in its pro forma adjustments. I&E M.B. at 38. PPL agreed with the adjustment but argued that it was more appropriate to eliminate the duplication from O&M expenses because the expense in question will be incurred by the OGC and then charged directly to PPL. PPL St. 8-R, at 41-42. PPL M.B. at 47. I&E acknowledged acceptance of the expense reduction, but PPL’s contended that it is appropriate to reflect the reduction as a part of the affiliate support allocation, and not as a rate case expense reduction. I&E M.B. at 39. I&E explained that keeping the expense as a part of affiliate support allocation will overstate the level PPL’s of OGC affiliate support dedicated to the provision of electric distribution service in years when there is no rate case. In other words, ratepayers will be allocated an Id. inflated portion of OGC expenses based upon rate proceeding expenses that are not provided annually or regularly by OGC. Further, the overstated level of OGC affiliate Id. support allocated to PPL in this proceeding will then be used in future proceedings to support similarly overstated OGC allocations. Id.
c. Office of General Counsel i. Positions of the Parties Legal services to PPL Electric are provided by PPL Corporation’s Office of General Counsel (OGC), and PPL’s jurisdictional FTY claim for OGC is $6.083 million. I&E Exh. 2, Sch. 17 p. 2. According to I&E, PPL’s claim is based on its HTY expense increased by $1.2 million in estimated costs for outside counsel fees related to this proceeding. Because of this, I&E recommended a ratemaking allowance of $4.833 million for OGC expense, which is a $1.2 million reduction to PPL’s claim. The basis for I&E’s adjustment is to eliminate the additional expense associated with outside counsel for this proceeding since the Company also includes a claim for rate case expense in its pro forma adjustments. I&E M.B. at 38. PPL agreed with the adjustment but argued that it was more appropriate to eliminate the duplication from O&M expenses because the expense in question will be incurred by the OGC and then charged directly to PPL. PPL St. 8-R, at 41-42. PPL M.B. at 47. I&E acknowledged PPL’s acceptance of the expense reduction, but contended that it is appropriate to reflect the reduction as a part of the affiliate support allocation, and not as a rate case expense reduction. I&E M.B. at 39. I&E explained that keeping the expense as a part of PPL’s affiliate support allocation will overstate the level of OGC affiliate support dedicated to the provision of electric distribution service in years when there is no rate case. Id. In other words, ratepayers will be allocated an inflated portion of OGC expenses based upon rate proceeding expenses that are not provided annually or regularly by OGC. Id. Further, the overstated level of OGC affiliate support allocated to PPL in this proceeding will then be used in future proceedings to support similarly overstated OGC allocations. Id.
1206360.docx