8 MAY 17 11:50 AM FAX TX OK * * 8. Facsimile Cover Sheet. Alyson Zerbe Pennsylvania Public Utility Commission

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1 P.01 TRANSACTION REPORT MAY TUE 11:51 AM 8 8 FOR: 8 8 SEND DATE START RECEIVER TX TIME PAGES TYPE NOTE M DP MAY 17 11:50 AM FAX TX OK TOTAL : SOS PAGES: Phone: Fax#: Website: (717) (717) irrc@irrc.state.pa.us independent REGULATORY REVIEW COMMISSION 333 MARKET STREET, 14 T11 FLOOR, HARRISBURG, PA To: Agency: Phone Fax: # of Pages: Alyson Zerbe Pennsylvania Public Utility Commission /i ;7// -ç RE: PA Public Utility Commissions Regulation # (IRRC #3061) Section 5.1(j) of the Regulatory Review Act (71 PS a(j)) requires us preceding our public meeting upon receipt. Please distribute this material to the apdropriate regulatory staff as soon as possible. FaxS

2 P.01 TRANSACTION REPORT MAY TUE 11:52 AN FOR: SEND DATE START RECEIVER TX TINE PAGES TYPE NOTE M DP MAY 17 11:51 AN FAX TX OK 724 TOTAL : 36S PAGES: 5 Phone: (717) Fax #: (717) irrc@irrc.state.pa.us Website: INDEPENDENT REGULATORY REVIEW COMMISSION 333 MARKET STREET, l4 FLOOR, HARRISBURG, PA To: Agency: Phone Fax: #of Pages: 5 Honorable Robert M. Tomlinson, Chairman Senate Consumer Protection & Professional Licensure Committee /7/i R: PA Public Utility Commission s Regulation # (IRRC #3061) Section 5.1(j) of the Regulatory Review Act (71 P.S a(j)) requires us preceding our public meeting, upon receipt. Please distribute this material to the approdriate regulatory staff as soon as possible. Fax5

3 P.01 TRANSACTION REPORT MAY TUE 11:53 AM FOR: SEND DATE START RECEIVER TX TIME PAGES TYPE NOTE M# DP MAY-17 11:52 AM FAX TX OK 725 4( TOTAL 37S PAGES: K U S Phone: Fax#: Website: (717) (717) irrc@irre.state.pa.us INDEPENDENT REGULATORY REVIEW COMMISSION 333 MARKET STREET, 14 FLOOR, HARRIsBIJRG, PA To: Agency: Phone Fax: # of Pages: Honorable Lisa M. Boscola, Minority Chairman Senate Consumer Protection & Professional Licensure Committee s/i /i S RE: PA Public Utility Commission s Regulation # (IRRC #3061) Section 5.1(j) of the Regulatory Review Act (71 P.S a(j)) requires us preceding our public meeting, upon receipt. Please distribute this material to the apropriate regulatory staff as soon as Dossible. FaxS

4 ( Po1 TRANSACTION REPORT NAY TUE 11:54 AN )I( FOR: ;l( SEND ) DATE START RECEIVER TX TINE PAGES TYPE NOTE N DP )I( NAY 17 11:53 AN FAX TX OK 726 TOTAL : 555 PAGES: 5 Phone: Fax: Website: (717) (717) irrc@irrc.state.pa.us INDEPENDENT REGULATORY REVIEW COMMISSION 333 MARKET STREET, 1 41 FLOOR, HARRISBURG, PA To: Honorable Robert Godshall, Chairman Agency: House Consumer Affairs Committee Phone Fax: #of Pages: s RE: PA Public Utility Commissions Regulation # (IRRC #3061) Section 5.1(j) of the Regulatory Review Act (71 P.S. 745,5a(j)) requires us preceding our public meeting, upon receipt. Please distribute this material to the appropriate regulatory staff as soon as possible. FaxS

5 P.01 TRANSACTION REPORT MAY TUE 11:55 AM FOR: SEND DATE START RECEIVER TX TIME PAGES TYPE NOTE M DP )K MAY 17 11:54 AN FAX TX OK 727 TOTAL : 435 PAGES: 5 Phone: (717) Fax#: (717) Website: wwirrcstatepa.us INDEPENDENT REGULATORY REVIEW COMMISSION l4 FLOOR, HARRTSBURG, PA MARKET STREET, To: Honorable Peter Daley, Minority Chairman Agency: House Consumer Affairs Committee Phone Fax: #ofpages: RE: PA Public Utility Commission s Regulation # (IRRC #3061) Section 5.1(j) of the Regulatory Review Act (71 P.S. 745.Sa(j)) requires us preceding our public meeting, upon receipt. Please distributeihi material to the appropriate regulatory staff as soon as possible. FaxS

6 Assistant General Counsei Michael S. Swerling Direct DaI: A Ex&on Company Enclosure 4ichae1 S. SwerIing - 4j2 Very Truly Yours, Please do not hesitate to contact me at should you have any questions regarding this filing. Enclosed please find the Comments of PECO Energy Company to the Final Form Regulation regarding Implementation of the Alternative Energy Portfolio Standards Act of2004, which was submitted to the independent Regulatory Review Commission ( IRRC ) by the Pennsylvania Public Utility Commission on March 22, Dear Chairman Bedwick: PUC DocketNo.L : IRRC# 3061 Re: Implementation of the Alternative Energy Portfolio Standards Act of Market Street, 14th Floor Chairman George D. Bedwick Independent Regulatory Review Commission Harrisburg, PA Via (irrc@irrc state pa us) May 17,2016 PhiIadeIpha, PA Market Street, S23-1 PEcOS PECO Energy Company EMBARGOED MATERIAL

7 2 Implementation of the Alternative Energ Portftlio Standards Act of 2004, Docket No. L (Final Rulemaking Order submitted TRRC, to March 22, 2016). customer generation with customer load (e.g., the independent load requirement and the 200 % supporting continued market growth for renewable facilities and using net metering rules to align Commission s revisions to the AEPS Regulations achieve a reasonable and lawful balance, Commission s obligations under Chapter 75 of the Public Utility Code. PECO believes that the between: 1) protecting customers against excessive retail rate subsidies; and 2) fulfilling the resources in Pennsylvania and believes an appropriate and lawful balance must be struck PECO supports opportunities to enhance the market for clean alternative energy proceeding. competing industry comments submitted by a large group of diverse stakeholders in this Portfolio Standards Act ( AEPS Act ). The Final Form Regulation accomplishes this despite Commission on its efforts to improve clarity and ensure consistency with the Alternative Energy regulations, 52 Pa. Code 75.1 et seq. ( AEPS Regulations ). PECO commends the comments in support of the proposed amendments to Chapter 75 of the Commission s March 22, 2016, PECO Energy Company ( PECO or the Company ) hereby submits its Commission ( 1RRC ) by the Pennsylvania Public Utility Commission ( Commission ) on Pursuant to the Final Form Regulation submitted to the Independent Regulatory Review Comments of PECO Energy Company to the Final Form Regulation PORTFOLIO STANDARDS A CT OF 2004 IMPLEMENTATION OF THE ALTERNATIVE ENERGY : DOCKET NO. L PENNSYLVANIA PUBLIC UTILITY COMMISSION BEFORE THE

8 While PECO supports approval of the Final Form Regulation, the Company believes regulation may be required to address key issues (related to the fair allocation of costs among that, as the renewable marketplace continues to advance and mature, further review and 2 The 200% size limitation for privately owned distributed generation systems is a constructive addition to the 3 Commission s existing policy, which applies a 110% system limit to leased systems. This policy was adopted in Net Metering-Use of Third Party Operators, Docket No. M (Final Order entered March 29, 2012). that generate sufficient revenues for electric distribution companies to continue to develop support for alternative energy and distributed generation, allocation of costs between netmetering and non-net metering customers on a fair and reasonable basis, and rate designs As such, the legal framework in Pennsylvania must continue to appropriately balance approximately 1,500 installations are in the process of being interconnected. net metering customers, representing over 63 MW of installed capacity. Additionally, the development of new distributed generation and increase both the number of customergenerators and volume of customer-generated electricity. Specifically, PECO has over 3,300 magnitude of this subsidization Continues to increase. AEPS obligations continue to drive distribution service from net metering customers to other distribution customers, and the Pennsylvania s net metering framework continues to facilitate a shift of the costs of of the grid. Even with the changes proposed by the Commission in this proceeding, to match cost causation. Put differently, no customer pays more than their fair share for use greatest extent possible, customers pay for the services they receive through rates designed PECO believes that Commission policy should continue to ensure that, to the generation and customer cross-subsidization. customers), including net metering, rate design, distribution revenues, the impacts of distributed size limitation). 2

9 PECO appreciates the opportunity to comment on the Final Rulemaking Order and IlL CONCLUSION 2301 Market Street, S May 17, 2016 michael.swerling@exeloncorp.com Michael S. Swerli.Pa. No ) Phone: (215) Assistant GiTeral Counsel PECO Energy Company Philadelphia, PA Respec 1ully submitted, Regulation. asks that IRRC favorably consider its comments and approve the Commission s Final Form and operate the reliable electric distribution networks on which all customers rely.