PPLPPL Corporation

Adjustments to arrive at a non-GAAP performance measure should be presented as a separate adjustment and clearly explained. Please refer to question 102.11 of our Compliance and Disclosure Interpretations; Non-GGAP Financial Measures. Please revise future filings accordingly.

The reconciliation of our non-GAAP financial measure, “Earnings from Ongoing Operations” to the most comparable GAAP measure of “Net Income” for each Registrant is provided for each period presented on page 52. Each reconciling adjustment (referred to as a special item) is separately presented on an after-tax basis with the related tax impact disclosed next to each item.

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The tax impact for each separate reconciling adjustment is included to comply with Question 102.11 of the Division of Corporation Finance’s Compliance and Disclosure Interpretations (C&DI) on Non-GAAP Financial Measures that were issued in May 2016.

We respectfully acknowledge the Staff’s comments; however, we believe our current presentation is aligned with the intent of the guidance in Question 102.11 as the income tax effect of each reconciling adjustment is shown separately in a succinct and transparent manner, and results in both the pre-tax and after-tax impacts of each adjustment being easily determinable based on the information presented.

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Gross margins appear to represent a non-GAAP financial measure. Please tell us why you believe that gross margin is presented in accordance with GAAP. If gross margin is a non-GAAP financial measure, please provide a reconciliation of the differences between the non-GAAP financial measure with the most directly comparable financial measure calculated and presented in accordance with GAAP and the other disclosures

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required by Item 10(e) of Regulation S-K. Also, the use of titles or descriptions of non- GAAP financial measures should not be the same as, or confusingly similar to, titles or descriptions used for GAAP financial measures. Please refer to Item 10(e) of Regulation S-K. Please revise the title of this non-GAAP financial measure in future filings. Financial Statements 5. Income and Other Taxes

to your comment, in future filings we will revise the titles of these non-GAAP measures to “U.K. Adjusted Gross Margins”, “Kentucky Adjusted Gross Margins” and

“Pennsylvania Adjusted Gross Margins” to further differentiate these measures from GAAP financial measures.

Financial Statements

5. Income and Other Taxes Read in the reply ↗

Please tell what consideration you gave to disclosing the information required by ASC 740-10-50-15 and 15A. 13. Commitments and Contingencies

For the disclosure of unrecognized tax benefits (“UTBs”) in the financial statements for the period ended December 31, 2017, the Registrants considered the following requirements detailed in ASC 740-10-50-15 and 15A:

A tabular reconciliation of the total amounts of UTBs, which includes the beginning and end of period balances, the gross amounts of the increases and decreases in UTBs as a result of tax positions taken during the current and/or prior periods and the reductions to the UTBs relating to settlements with taxing authorities and/or as a result of a lapse of the applicable statute of

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limitations;

The total amount of unrecognized tax benefits that, if recognized, would impact the effective tax rate;

The total amount of interest and penalties recognized in the statement of operations and the statement of financial position;

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We note that you are unable to predict the outcome of the Cane Run Environmental Claims or the E.W. Brown Environmental Claims. Please tell us what consideration you gave to disclosing an estimate of the possible loss or range of loss for these matters or that such an estimate cannot be made. Please refer to ASC450-30-50-4.

The reasonable possibility that the total amounts of UTBs would significantly increase or decrease within 12 months of the reporting date; and Read in the reply ↗