PGW also indicated that it will measure overall home savings because the health and safety measures do not directly produce savings. PGW Reply Comments at 56. In the Data Request to PGW, we asked if the Company will Commission’s “treat any heating situations under the pilot if the household also has health and safety de facto PGW responded that the health and safety pilot is not designed to treat de facto issues?” heating situations but that a customer could potentially receive treatment for the heater under LIURP and/or as health and safety measures under the pilot. PGW further clarified that the costs of treating the non-functioning heater would still be governed by cost effectiveness standards. PGW Response at 1. TURN state that heating customers should be a priority under the et al. de facto pilot, that response to the question neither reveals nor justifies PGW’s Commission’s why the pilot does not address heating situations, and that customers in a de facto de heating situation could not conceivably fall within the top 50% of normalized facto usage. TURN further believe that PGW should develop and make available et al. avenues for customers to access the pilot and that the Commission should order de facto PGW to provide access, explore service restoration terms, and coordinate heating de facto treatment efforts with PECO, the EDC in service territory. TURN et al. PGW’s Additional Comments at 6-7. CAUSE-PA points out that often cost of repairing or replacing a furnace may “the exceed the cost-effectiveness standards for and that the inoperable systems pose LIURP” a tremendous threat to the health and safety of low-income customers. CAUSE-PA believes PGW should be required to develop a plan to address heating and de facto suggests coordination with the LIHEAP Crisis Interface program. CAUSE-PA further recommends that PGW should required to form a Universal Service Advisory “be Committee per 52 Pa. Code § CAUSE-PA Additional Comments at 3-4. 58.16.”
PGW also indicated that it will measure overall home savings because the health and safety measures do not directly produce savings. PGW Reply Comments at 56. In the Commission’s Data Request to PGW, we asked if the Company will “treat any de facto heating situations under the pilot if the household also has health and safety issues?” PGW responded that the health and safety pilot is not designed to treat de facto heating situations but that a customer could potentially receive treatment for the heater under LIURP and/or as health and safety measures under the pilot. PGW further clarified that the costs of treating the non-functioning heater would still be governed by cost effectiveness standards. PGW Response at 1. TURN et al. state that de facto heating customers should be a priority under the pilot, that PGW’s response to the Commission’s question neither reveals nor justifies why the pilot does not address de facto heating situations, and that customers in a de facto heating situation could not conceivably fall within the top 50% of normalized usage. TURN et al. further believe that PGW should develop and make available avenues for de facto customers to access the pilot and that the Commission should order PGW to provide access, explore service restoration terms, and coordinate de facto heating treatment efforts with PECO, the EDC in PGW’s service territory. TURN et al. Additional Comments at 6-7. CAUSE-PA points out that often “the cost of repairing or replacing a furnace may exceed the cost-effectiveness standards for LIURP” and that the inoperable systems pose a tremendous threat to the health and safety of low-income customers. CAUSE-PA believes PGW should be required to develop a plan to address de facto heating and suggests coordination with the LIHEAP Crisis Interface program. CAUSE-PA further recommends that PGW should “be required to form a Universal Service Advisory Committee per 52 Pa. Code § 58.16.” CAUSE-PA Additional Comments at 3-4.