Vir%inc), - Pennsylvaniadistribution system reliability and reduce outages in a cost-effective...

Vir%inc),

Wallace BSc Nurick La.

Alessandra L. Hylander Direct Dial: 717.237.5435 ahylander@mcneeslaw.com

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 dlawrence@paoca.org lburge@paoca.org

Richard A Kanaskie, Esq. Bureau of Investigation and Enforcement PO Box 3265 400 North Street, 2nd Floor West Harrisburg, PA 17120 rkanaskie@pa.gov

Steven Gray, Esq. Sharon Webb, Esq. Office of Small Business Advocate 300 North Second Street, Suite 202 Harrisburg, PA 17101 sgray@pa.gov swebb@pa.gov

Joseph L Vullo, Esq. Burke Vullo Reilly Roberts 1460 Wyoming Avenue Forty Fort, PA 18704 jlvullo@aol.com

Patrick M. Cicero, Esq. Elizabeth R Marx, Esq. PA Utility Law Project 118 Locust Street Harrisburg, PA 17101 emarxpulp@palegalaid.net pulp@palegalaid.net

Eric Epstein 4100 Hillsdale Road Harrisburg, PA 17112 epstein@efmr.org

Kenneth L Mickens, Esq. 316 Yorkshire Drive Harrisburg, PA 17111-6933 kmickens11@verizon.net

David R. Wooley, Esq. Keyes, Fox & Weidman LLP 436 14th Street, Suite 1305 Oakland, CA 94612 dwooley@kfwlaw.com

Jacob Schlesinger, Esq. Keyes, Fox & Wiedman LLP 1400 16th Street 16 Market Square Suite 400 Denver, Co 80202 schlesinger@kfwlaw.com

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 dclearfield@eckertseamans.com dodell@eckertseamans.com sstoner@eckertseamans.com

Mark Szybist, Esq. 1152 15th St. NW, Suite 300 Washington, DC 20005 mszybist@nrdc.org

Michael Panfil, Esq. 1875 Connecticut Ave., N.W. #600 Washington, DC 20009 mpanfil@edf.org

John Finnigan, Esq. 128 Winding Brook Lane Terrace Park, OH 45174 jfinnigan@edf.org

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 minott@cleanair.org lwelde@cleanair.org bhartung@cleanair.org

Heather M. Langeland, Esq. PennFuture 200 First Avenue, Suite 200 Pittsburgh, PA 15222 langeland@pennfuture.org

Christopher T. Wright, Esq. Post & Schell PC 17 North Second Street 12th Floor Harrisburg, PA 17101-1601 cwright@postschell.com

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 ppolacek@mcneeslaw.com abakare@mcneeslaw.com ahylander@mcneeslaw.com

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.