Contrary to the implication of such cost recovery proposals, Duquesne’s RME Program descriptions generally exclude C&I customers from participation. Duquesne St. No. 3, p. 4. In addition, no party to the proceeding envisions Large C&I customer eligibility for RME Programs. As evidenced by the plain language of Duquesne’s RME proposals and the clarifications offered by CNE, FES, and Dominion, Large C&I customers are ineligible for participation in Duquesne’s proposed RME programs. If the Commission should decline to approve Duquesne’s proposal to recover RME program costs through a POR discount, then the Commission must ensure that any approved mechanism for recovering RME program costs complies with the Public Utility Code and principles of cost causation. Because Large C&I customers are ineligible for RME programs, they must not be charged these costs. Stipulation of DII and OSBA. It See, e.g., would be unjust, unreasonable, and inconsistent with cost causation principles for DII to recover costs from customers that are ineligible to participate in such programs. Large C&I customers are ineligible to participate in RME programs and would receive no corresponding benefits from these programs. Shopping statistics reflect that any additional incentives for Large C&I shopping are unnecessary. Therefore, the Commission should reject any proposal to collect RME Program costs from ineligible customer classes, particularly Large C&I customers. h. EGS Parties’ Position The EGS Parties note Duquesne’s proposal to recover the costs of the ROA from winning suppliers on a basis and point out that, while this approach appears to be pro-rata reasonable if the Commission imposes an style assignment program, the cost could FE Order grow if the auction process is retained. If the auction wins the day, then customers must share in the costs since they benefit from these programs. (TJB St. No. 1, p. 6:4-8). The SOR should be paid for by participating suppliers on a customer “per acquired (e.g. $10/customer acquired) only so the cost responsibility is directly applied to
Contrary to the implication of such cost recovery proposals, Duquesne’s RME Program descriptions generally exclude C&I customers from participation. Duquesne St. No. 3, p. 4. In addition, no party to the proceeding envisions Large C&I customer eligibility for RME Programs. As evidenced by the plain language of Duquesne’s RME proposals and the clarifications offered by CNE, FES, and Dominion, Large C&I customers are ineligible for participation in Duquesne’s proposed RME programs. If the Commission should decline to approve Duquesne’s proposal to recover RME program costs through a POR discount, then the Commission must ensure that any approved mechanism for recovering RME program costs complies with the Public Utility Code and principles of cost causation. Because Large C&I customers are ineligible for RME programs, they must not be charged these costs. See, e.g., Stipulation of DII and OSBA. It would be unjust, unreasonable, and inconsistent with cost causation principles for DII to recover costs from customers that are ineligible to participate in such programs. Large C&I customers are ineligible to participate in RME programs and would receive no corresponding benefits from these programs. Shopping statistics reflect that any additional incentives for Large C&I shopping are unnecessary. Therefore, the Commission should reject any proposal to collect RME Program costs from ineligible customer classes, particularly Large C&I customers. h. EGS Parties’ Position The EGS Parties note Duquesne’s proposal to recover the costs of the ROA from winning suppliers on a pro-rata basis and point out that, while this approach appears to be reasonable if the Commission imposes an FE Order style assignment program, the cost could grow if the auction process is retained. If the auction wins the day, then customers must share in the costs since they benefit from these programs. (TJB St. No. 1, p. 6:4-8). The SOR should be paid for by participating suppliers on a “per customer acquired (e.g. $10/customer acquired) only so the cost responsibility is directly applied to