Appendix A. According to the OCA, the Large C&I customers are being asked to bear almost forty-six percent of the costs of the Phase II Plan. Plan at 145, Appendix See D. Therefore, the OCA states that, unlike the discrepancy between revenues and costs cited by DII, there is extremely close alignment between usage and costs under the Phase II Plan for these customers. OCA R.B. at 5. In its Reply Brief, the OSBA first notes that it has no objection to proposed Phase II Plan filing as modified by the Settlement. The OSBA Duquesne’s states that DII did not offer any testimony on the record in this proceeding and filed its proposal for the first time in its Main Brief. The OSBA avers that, since the Company’s proposal represents a complex balance of programs involving all rate classes, DII essentially is requesting that Duquesne and DII did not file “go back try again.” Since testimony and did not offer any specific criteria for a more equitable allocation in its Main Brief, the OSBA assumes that DII would oppose any such revised plan submitted by the Company. OSBA R.B. at 3-4. The OSBA states that DII offers no specific complaints regarding Plan. The OSBA avers that DII does not identify any specific program Duquesne’s targeted at Large C&I customers which it believes should be eliminated or reduced, nor does it identify any specific rates of other rate classes that should be increased in order to offset the proposed reduction for Large C&I customers. According to the OSBA, DII does not identify any particular assumptions made by the Company which demonstrate a bias to over-assigning costs to Large C&I customers. In light of the lack of any credible record evidence, the OSBA submits that request should be summarily rejected. Id. DII’s at 4-5. Notwithstanding this position, the OSBA states that, if the Commission requires additional reasons for rejecting proposal, based on own brief, there is DII’s DII’s no evidence that the proposed energy savings measures for the Large C&I customers are
Appendix A. According to the OCA, the Large C&I customers are being asked to bear almost forty-six percent of the costs of the Phase II Plan. See Plan at 145, Appendix D. Therefore, the OCA states that, unlike the discrepancy between revenues and costs cited by DII, there is extremely close alignment between usage and costs under the Phase II Plan for these customers. OCA R.B. at 5. In its Reply Brief, the OSBA first notes that it has no objection to Duquesne’s proposed Phase II Plan filing as modified by the Settlement. The OSBA states that DII did not offer any testimony on the record in this proceeding and filed its proposal for the first time in its Main Brief. The OSBA avers that, since the Company’s proposal represents a complex balance of programs involving all rate classes, DII essentially is requesting that Duquesne “go back and try again.” Since DII did not file testimony and did not offer any specific criteria for a more equitable allocation in its Main Brief, the OSBA assumes that DII would oppose any such revised plan submitted by the Company. OSBA R.B. at 3-4. The OSBA states that DII offers no specific complaints regarding Duquesne’s Plan. The OSBA avers that DII does not identify any specific program targeted at Large C&I customers which it believes should be eliminated or reduced, nor does it identify any specific rates of other rate classes that should be increased in order to offset the proposed reduction for Large C&I customers. According to the OSBA, DII does not identify any particular assumptions made by the Company which demonstrate a bias to over-assigning costs to Large C&I customers. In light of the lack of any credible record evidence, the OSBA submits that DII’s request should be summarily rejected. Id. at 4-5. Notwithstanding this position, the OSBA states that, if the Commission requires additional reasons for rejecting DII’s proposal, based on DII’s own brief, there is no evidence that the proposed energy savings measures for the Large C&I customers are