a. Met Ed and Penelec as Curtailment Service Providers (1) Positions of the Parties Met Ed and Penelec propose the selection of curtailment service providers to secure and manage demand response programs. FirstEnergy RB at 3; FirstEnergy St. 3-R at 8. Specifically, these curtailment service providers will register load for commercial, industrial and government sector customers for Met Ed’s and Penelec’s demand response programs. Met Ed’s September 21, 2009 Plan at 73; Penelec’s September 21, 2009 Plan at 70. In addition, Met Ed and Penelec propose to act as curtailment service providers themselves. Met Ed’s September 21, 2009 Plan at 78; Penelec’s September 21, 2009 Plan at 75. FirstEnergy explains as follows: Both Met-Ed’s and Penelec’s clearly state that Met-Ed and Penelec, acting as a [curtailment service provider] within the PJM program, will fill the gap between the total MWs needed for compliance with Act 129, less the amount expected from the Voluntary Load Reduction Program, less the amount committed by [curtailment service provider’s] registration under the Industrial Demand ‘Commercial Response Program-[Curtailment Service Provider] Mandatory’ program the Mandatory Load Reduction Program. Witness Parish testified that Met Ed and Penelec are offered as an alternative to the development of a competitive [curtailment service provider] demand program, essentially as a contingency plan, to ensure that Met Ed and Penelec are able to secure the level of demand reduction needed in the event that the Industrial Demand ‘Commercial Response Program-[Curtailment Service Provider] Mandatory’ program does not result in the MWs needed. FirstEnergy St. 2-R at 9-10; FirstEnergy MB at 49-50
a. Met Ed and Penelec as Curtailment Service Providers (1) Positions of the Parties Met Ed and Penelec propose the selection of curtailment service providers to secure and manage demand response programs. FirstEnergy RB at 3; FirstEnergy St. 3-R at 8. Specifically, these curtailment service providers will register load for commercial, industrial and government sector customers for Met Ed’s and Penelec’s demand response programs. Met Ed’s September 21, 2009 Plan at 73; Penelec’s September 21, 2009 Plan at 70. In addition, Met Ed and Penelec propose to act as curtailment service providers themselves. Met Ed’s September 21, 2009 Plan at 78; Penelec’s September 21, 2009 Plan at 75. FirstEnergy explains as follows: Both Met-Ed’s and Penelec’s clearly state that Met-Ed and Penelec, acting as a [curtailment service provider] within the PJM program, will fill the gap between the total MWs needed for compliance with Act 129, less the amount expected from the Voluntary Load Reduction Program, less the amount committed by [curtailment service provider’s] registration under the ‘Commercial Industrial Demand Response Program-[Curtailment Service Provider] Mandatory’ program the Mandatory Load Reduction Program. Witness Parish testified that Met Ed and Penelec are offered as an alternative to the development of a competitive [curtailment service provider] demand program, essentially as a contingency plan, to ensure that Met Ed and Penelec are able to secure the level of demand reduction needed in the event that the ‘Commercial Industrial Demand Response Program-[Curtailment Service Provider] Mandatory’ program does not result in the MWs needed. FirstEnergy St. 2-R at 9-10; FirstEnergy MB at 49-50