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Vir%inc),
Wallace BSc Nurick La.
Alessandra L. Hylander Direct Dial: 717.237.5435 [email protected]
Pine Street • PO Box 1166 • Harrisburg, PA 17108-t166 717,232.8000 • Fax: 717.237.5300
September 22, 2017
Rosemary Chiavetta, Secretary Pennsylvania Public Utility Commission Commonwealth Keystone Building 400 North Street, 2nd Floor Harrisburg, PA 17120
VIA ELECTRONIC FILING
RE: Petition of PPL Electric Utilities Corporation for Approval of its Long-Term Infrastructure Improvement Plan for the Period January 1, 2018 — December 31, 2022; Docket No. P-2017-2622393
Dear Secretary Chiavetta:
Please find enclosed for filing with the Pennsylvania Public Utility Commission ("PUC" or "Commission") a copy of the Comments of the PP&L Industrial Customer Alliance ("PPLICA") as previously filed on September 20, 2017, in the above-referenced proceeding. Per correspondence from the Secretary's Bureau, the Certificate of Service filed with the Comments has been corrected. The Comments are otherwise unmodified from the prior filing.
Thank you.
Very truly yours,
McNEES WALLACE & NURICK LLC
By 1--146Giti1CLU.,
Alessandra L. Hylander
Counsel to the PP&L Industrial Customer Alliance
Enclosures cc: Certificate of Service
www.McNeesLaw.com Harrisburg, PA • Lancaster. PA • Scranton. PA • State College, PA • Columbus, OH • Frederick. MD • Washington, DC
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a true copy of the foregoing document upon the
participants listed below in accordance with the requirements of 52 Pa. Code § 1.54 (relating to service
by a participant).
VIA E-MAIL AND FIRST CLASS MAIL
Darryl A. Lawrence, Esq. Lauren M. Burge, Esq. Office of Consumer Advocate 555 Walnut Street Forum Place, 5th Floor Harrisburg, PA 17101 1921 [email protected] [email protected]
Richard A Kanaskie, Esq. Bureau of Investigation and Enforcement PO Box 3265 400 North Street, 2nd Floor West Harrisburg, PA 17120 [email protected]
Steven Gray, Esq. Sharon Webb, Esq. Office of Small Business Advocate 300 North Second Street, Suite 202 Harrisburg, PA 17101 [email protected] [email protected]
Joseph L Vullo, Esq. Burke Vullo Reilly Roberts 1460 Wyoming Avenue Forty Fort, PA 18704 [email protected]
Patrick M. Cicero, Esq. Elizabeth R Marx, Esq. PA Utility Law Project 118 Locust Street Harrisburg, PA 17101 [email protected] [email protected]
Eric Epstein 4100 Hillsdale Road Harrisburg, PA 17112 [email protected]
Kenneth L Mickens, Esq. 316 Yorkshire Drive Harrisburg, PA 17111-6933 [email protected]
David R. Wooley, Esq. Keyes, Fox & Weidman LLP 436 14th Street, Suite 1305 Oakland, CA 94612 [email protected]
Jacob Schlesinger, Esq. Keyes, Fox & Wiedman LLP 1400 16th Street 16 Market Square Suite 400 Denver, Co 80202 [email protected]
Daniel Clearfield, Esq. Deanne M. O'Dell, Esq. Sarah C Stoner, Esq. Eckert Seamans Cherin & Mellott, LLC 213 Market Street, 8th Floor Harrisburg, PA 17101 [email protected] [email protected] [email protected]
Mark Szybist, Esq. 1152 15th St. NW, Suite 300 Washington, DC 20005 [email protected]
Michael Panfil, Esq. 1875 Connecticut Ave., N.W. #600 Washington, DC 20009 [email protected]
John Finnigan, Esq. 128 Winding Brook Lane Terrace Park, OH 45174 [email protected]
VIA EMAIL ONLY Joseph Otis Minott, Esq. Logan Welde, Esq. Benjamin Z. Hartung, Esq. Clean Air Council 135 S 19th Street, Suite 300 Philadelphia, PA 19103 joe [email protected] [email protected] [email protected]
Heather M. Langeland, Esq. PennFuture 200 First Avenue, Suite 200 Pittsburgh, PA 15222 [email protected]
Christopher T. Wright, Esq. Post & Schell PC 17 North Second Street 12th Floor Harrisburg, PA 17101-1601 [email protected]
Alessandra L. Hylander
Counsel to PP&L Industrial Customer Alliance
Dated this 22" day of September, 2017, at Harrisburg, Pennsylvania.
BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION
Petition of PPL Electric Utilities Corporation for Approval of its Long-Term Infrastructure Docket No. P-2017-2622393 Improvement Plan for the Period January 1, 2018 through December 31, 2022
COMMENTS OF THE PP&L INDUSTRIAL CUSTOMER ALLIANCE
I. INTRODUCTION
On August 31, 2017, PPL Electric Utilities Corporation ("PPL" or "Company") filed a
Petition for Approval of its Long-Term Infrastructure Improvement Plan ("PPL Petition") for the
period of January 1, 2018, through December 31, 2022. This second Long-Term Infrastructure
Improvement Plan ("LTIIP" or "Plan") would replace PPL's initial LTIIP, which the Company
filed after the Pennsylvania Public Utility Commission's ("PUC" or "Commission") issuance of a
Final Implementation Order at Docket No. M-2012-2293611 ("Implementation Order"). The
Implementation Order set forth the Commission's procedures for complying with the requirements
of Act 11 of 2012 ("Act 11"). This proposed second LTIIP would replace PPL's initial LTIIP,
which is set to expire on December 31, 2017.1 Under this second LTIIP, PPL proposes to "continue
its accelerated repair, improvement, and replacement of aging infrastructure." PPL Petition, p. 1.
Act 11 provides utilities with an opportunity to implement a Distribution System
Improvement Charge ("DSIC") to recover reasonable and prudent costs incurred to repair,
improve, or replace distribution system property meeting certain eligibility requirements. The
eligibility requirements are defined in Section 1351 of the Public Utility Code. 66 Pa. C.S. §
PPL's current LTIIP was approved on January 10, 2013, at Docket No. P-2012-2325034.
1351(1). As a precondition to the implementation of cost recovery via a DSIC, a utility must file
an LTIIP in accordance with the provisions of Section 1352 of the statute. Id. at § 1352(a).
Consistent with the procedures set forth in the Implementation Order, the PP&L Industrial
Customer Alliance ("PPLICA") hereby submits the following Comments in response to the
Petition filed by PPL on August 31, 2017.
II. COMMENTS
PPLICA has reviewed the LTIIP to determine whether PPL's proposal is consistent with
Section 1352 of the Public Utility Code and the Commission's Implementation Order. The
Implementation Order established that the utility bears the burden of proof as to whether the
proposed long-term plan and associated expenditures are reasonable and cost effective and are
designed to maintain safe, adequate, and reliable service to consumers in conformance with
Section 1352(a). Implementation Order, p. 22. PPL's LTIIP proposes approximately $903.13
million of investment into distribution assets. Second LTIIP, p. 16. These significant expenditures
follow the previous investments made in DSIC-eligible property between 2013 and 2017, which
amount to approximately $685 million.2 Id. at 12.
Although the LTIIP proposes substantial expenditures, it appears that PPL has allocated
the $903.13 million across a portfolio of equipment and facility investments designed to improve
distribution system reliability and reduce outages in a cost-effective manner. Accordingly, based
on the representations and data provided in the LTIIP, PPLICA does not object to the Company's
proposed LTIIP at this time.3 However, several components of PPL's LTIIP require further
monitoring and review.
2 This figure includes PPL's forecasted spend for 2017. 3 Although PPLICA does not object to PPL's LTIIP as filed, PPLICA will participate in any subsequent adjudication or alternate review process initiated by the Commission.
2
PPLICA submits that the scope of investment projected for the LTIIP, which exceeds the
investment under the current LTIIP by $218 million (or approximately 32%), requires thorough
examination to ensure that the completed capital improvements remain reasonably consistent with
projections outlined in the LTIIP and limited to eligible assets. The Commission should conduct
ongoing reviews of any methodology applied by PPL to measure cost-effectiveness, including
prioritization processes, asset health indices, and the Company's use of performance indicators
such as the System Average Interruption Frequency Index ("SAIFI"), the Customer Average
Interruption Duration Index ("CAIDI"), or the System Average Interruption Duration Index
("SAIDI") to assess program impacts. PPL Petition, p. 8; LTIIP, pp. 4, 9, & 12. Furthermore, the
Commission must ensure that only eligible investments are included in the LTIIP and the DSIC.
The Commission has recognized the necessity to develop a stringent review process for the LTIIP,
both in acknowledging its statutory obligation to initiate a Rulemaking to establish procedures for
the five-year periodic review of LTIIPs and in further agreeing to promulgate regulations
establishing standards to for amending LTIIPs. See Implementation Order, p. 21. Accordingly,
while PPLICA does not oppose PPL's LTIIP at this time, PPLICA encourages the Commission to
develop robust procedures to ensure that PPL's future implementation of the LTIIP remains
reasonably consistent with the projected capital improvements, and that PPL's calculation of the
DSIC includes only eligible projects.
3
III. CONCLUSION
WHEREFORE, the PP&L Industrial Customer Alliance respectfully requests that the
Pennsylvania Public Utility Commission consider these Comments in disposing of PPL's proposed
Long-Term Infrastructure Improvement Plan.
Respectfully submitted,
McNEES WALLACE & NURICK LLC
By PINYVki, (0/ Pamela C. Polacek (Pa. I.D. o. 78276) Adeolu A. Bakare (Pa. I.D. No. 208541) Alessandra L. Hylander (Pa. I.D. No. 320967) 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Phone: (717) 232-8000 Fax: (717) 237-5300 [email protected] [email protected] [email protected]
Counsel to the PP&L Industrial Customer Alliance
Dated: September 20, 2017
4
aeoLummt,„ 0
Alessandra L. Hylander
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA ) ) ss:
COUNTY OF DAUPHIN
Alessandra L. Hylander, being duly sworn according to law, deposes and says that she is
Counsel to the PP&L Industrial Customer Alliance, and that in this capacity she is authorized to
and does make this Affidavit for them, and that the facts set forth in the foregoing Comments are
true and correct to the best of her knowledge, information and belief.
SWORN TO and subscribed
before me this 20th day
of September, 2017.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
(SEAL) NOTARIAL SEAL
Lisa R. Barker, Notary Public City of Harrisburg, Dauphin County
My Commission Expires Nov. 5, 2020
APPENDIX A
PP&L INDUSTRIAL CUSTOMER ALLIANCE
Air Products and Chemicals, Inc. General Dynamics-OTS Scranton
Harristown Enterprises, Inc. Hercules Cement Company
Linde LLC SAPA Extrusions, Inc. TIMET North America
Wegmans Food Markets, Inc.