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
states that input from the participating stakeholders resulted in a more creative and robust portfolio than would have otherwise been possible, and that such a collaborative process increased the likelihood of success in implementing the portfolio. Revised Plan at 12-13. PPL intends to continue to meet with stakeholders as needed, but not less than twice annually until May 31, 2016. Id. at 13. The OCA asserts that PPL’s Phase II Plan will benefit greatly from the continuation of stakeholder meetings, but recommends that the Commission direct PPL to hold such meetings at least quarterly rather than twice annually. OCA MB at 24-25; RB at 9-10. PPL does not agree with the OCA’s proposal, contending that the stakeholder process utilized during Phase I and in the preparation of Phase II was very successful. PPL asserts that a minimum of two stakeholder meetings per year, plus the Company’s quarterly Act 129 EE&C reports, are sufficient to keep stakeholders informed of the progress of PPL’s EE&C programs, particularly since both the Company and stakeholders have become familiar with the Commission’s Act 129 processes, and have significant experience regarding the operation of the Company’s Plan. PPL MB at 59. Moreover, PPL states that, if the Company proposes significant changes to its EE&C Plan during Phase I or Phase II, stakeholders will have the ability to discuss or comment on the changes through the stakeholder process or before the Commission, as applicable. Id. In addition, PPL argues that additional meetings would only serve to increase administrative costs, and would take PPL staff time away from implementing the Phase II Plan. Id. b. Disposition We agree that PPL’s proposed semi-annual stakeholder meetings plus its quarterly Act 129 EE&C reports will be sufficient to keep stakeholders informed of