SUMMARY: We recommend that the Department take no action in this docket because the existing incentive system has created some of the most successful efficiency programs in the country. The straw proposal would be unlikely to improve incentives to invest in efficiency because (a) unlike the existing system, it would not bear a specific relationship to efficiency efforts, (b) it would create new economic risks and shift risks that are more easily borne by utilities, including rate volatility, to families, (c) it would create a single issue rate mechanism, and (d) it could have substantial adverse impacts on low-income consumers.