projects. Accordingly, we will approve modified rebate cap calculation for its PPL’s Custom Incentive Program. b. Exclusion of Internal Labor Costs i. Positions of the Parties PPLICA also takes issue with failure to explain language in its PPL’s black-line Phase II Plan indicating that the revised rebate cap calculation will exclude internal labor costs. Petition, Appendix A at 120, 136. PPLICA argues that, because See PPL did not conspicuously identify or substantiate this change in its Petition, it should be rejected on procedural grounds. at 10. PPLICA states that the Commission had Id. previously clarified that all proposed EE&C plan changes must be conspicuously identified to facilitate stakeholder and Commission review. at 10, 11 (citing Id. Petition of PPL Electric Utilities Corporation for Approval of its Energy Efficiency and Docket No. M-2009-2093216 (Order entered May 6, 2011) (May Conservation Plan, at 22). 2011 Phase I Plan Change Order) In addition, PPLICA contends that PPL did not adequately define “internal labor PPLICA states that it would not oppose this proposal if such costs are costs.” confined to the use of internal measure implementation or installation resources. However, PPLICA asserts that, if the definition of labor includes design “internal costs” and scoping costs, then the proposal should be rejected because PPL has failed to support it. at 10-11. PPLICA avers that Large C&I customers are more likely to retain Id. qualified full-time energy management professionals on staff than Residential or Small C&I customers, and that these internal personnel would be available to perform scoping and design work. Thus, PPLICA contends that any internal labor costs excluded from the Custom Incentive Program rebate cap should be limited to expenses for which all
projects. Accordingly, we will approve PPL’s modified rebate cap calculation for its Custom Incentive Program. b. Exclusion of Internal Labor Costs i. Positions of the Parties PPLICA also takes issue with PPL’s failure to explain language in its black-line Phase II Plan indicating that the revised rebate cap calculation will exclude internal labor costs. See Petition, Appendix A at 120, 136. PPLICA argues that, because PPL did not conspicuously identify or substantiate this change in its Petition, it should be rejected on procedural grounds. Id. at 10. PPLICA states that the Commission had previously clarified that all proposed EE&C plan changes must be conspicuously identified to facilitate stakeholder and Commission review. Id. at 10, 11 (citing Petition of PPL Electric Utilities Corporation for Approval of its Energy Efficiency and Conservation Plan, Docket No. M-2009-2093216 (Order entered May 6, 2011) (May 2011 Phase I Plan Change Order) at 22). In addition, PPLICA contends that PPL did not adequately define “internal labor costs.” PPLICA states that it would not oppose this proposal if such costs are confined to the use of internal measure implementation or installation resources. However, PPLICA asserts that, if the definition of “internal labor costs” includes design and scoping costs, then the proposal should be rejected because PPL has failed to support it. Id. at 10-11. PPLICA avers that Large C&I customers are more likely to retain qualified full-time energy management professionals on staff than Residential or Small C&I customers, and that these internal personnel would be available to perform scoping and design work. Thus, PPLICA contends that any internal labor costs excluded from the Custom Incentive Program rebate cap should be limited to expenses for which all
1360675.docx