special cost recovery mechanisms within the DSM Plan. The OCA opines that if PGW wishes to implement a load growth initiative the program should be filed as a separate petition and the Company should propose a cost recovery mechanism other than the EE&C surcharge. The OCA asserts that the recommendation to deny ALJs’ PGW’s Efficient Fuel-Switching program was the correct decision. OCA R. Exc. at 29-30. In its Replies to Exceptions, CAUSE-PA states that while it did not take a position on Efficient Fuel-Switching pilot it avers that it would be inappropriate PGW’s for the Commission to sanction attempt to create and fund a voluntary EE&C PGW’s program while concurrently proposing to slash funding for LIURP. CAUSE-PA points out that PGW is obligated to run LIURP. CAUSE-PA states that while it supports voluntary EE&C programs, no such program should be run at the expense of PGW’s mandatory obligations. Simply stated, CAUSE-PA opines that full funding and PGW’s appropriate implementation of mandatory programs must be prioritized over voluntary and discretionary programs. CAUSE-PA R. Exc. at 19. d. Disposition Based upon our review of the evidence of record, we are in agreement with the recommendation of the ALJs to adopt the position of the OCA that proposed PGW’s Efficient Fuel-Switching program is in effect a load growth program that would result in increased natural gas usage in service territory and, as such, is not properly PGW’s included within this voluntary energy efficiency and conservation plan proposal of the Company. As pointed out by the OCA, on the electric side fuel switching has been considered an acceptable part of an energy conservation program because in that instance, the fuel switching results in reducing electricity usage as that usage is replaced by other energy sources. However, under the scenario in this proceeding, PGW’s proposal would instead result in an increase in the demand for natural gas in the service territory as alternative energy load transitions to natural gas usage. Company’s
special cost recovery mechanisms within the DSM Plan. The OCA opines that if PGW wishes to implement a load growth initiative the program should be filed as a separate petition and the Company should propose a cost recovery mechanism other than the EE&C surcharge. The OCA asserts that the ALJs’ recommendation to deny PGW’s Efficient Fuel-Switching program was the correct decision. OCA R. Exc. at 29-30. In its Replies to Exceptions, CAUSE-PA states that while it did not take a position on PGW’s Efficient Fuel-Switching pilot it avers that it would be inappropriate for the Commission to sanction PGW’s attempt to create and fund a voluntary EE&C program while concurrently proposing to slash funding for LIURP. CAUSE-PA points out that PGW is obligated to run LIURP. CAUSE-PA states that while it supports PGW’s voluntary EE&C programs, no such program should be run at the expense of PGW’s mandatory obligations. Simply stated, CAUSE-PA opines that full funding and appropriate implementation of mandatory programs must be prioritized over voluntary and discretionary programs. CAUSE-PA R. Exc. at 19. d. Disposition Based upon our review of the evidence of record, we are in agreement with the recommendation of the ALJs to adopt the position of the OCA that PGW’s proposed Efficient Fuel-Switching program is in effect a load growth program that would result in increased natural gas usage in PGW’s service territory and, as such, is not properly included within this voluntary energy efficiency and conservation plan proposal of the Company. As pointed out by the OCA, on the electric side fuel switching has been considered an acceptable part of an energy conservation program because in that instance, the fuel switching results in reducing electricity usage as that usage is replaced by other energy sources. However, under the scenario in this proceeding, PGW’s proposal would instead result in an increase in the demand for natural gas in the Company’s service territory as alternative energy load transitions to natural gas usage.