ACEEE’s formal comments, as filed with the Senate Finance Committee, support the adoption of fair cost recovery mechanisms and in particular on ending the current “penalty depreciation” treatment of building equipment under which heating, cooling, lighting and other equipment connected to buildings is depreciated over about a 40 year period (based on the life of a building) when in fact this equipment has an average service life of 15-20 years. Specific data and suggested language are provided.