Duke Energy will have another chance to argue its case for using banked savings to meet energy efficiency incentive targets with the Public Utilities Commission of Ohio (PUCO), according to a recent Hannah Report. The Commission had previously ruled that Duke Energy could count “energy efficiency savings in excess of statutory benchmarks toward meeting the higher benchmarks in subsequent years,” but not toward “shared savings incentive targets set up to reward the utility for substantially exceeding the annual benchmarks.” In that decision, the PUCO said that as those benchmarks rose every year, allowing Duke to use banked savings would eliminate the company’s incentive “to exceed the benchmarks.” The PUCO granted Duke Energy’s request for rehearing, in which the company noted “a list of prior cases and decisions that recognized its ability to count banked savings toward incentive goals.”