panels). The requested waivers and the justification for the waivers are set forth in Appendix A to the Petition. Petition at 13. No Party opposed waiver request for 52 Pa. Code §§ 58.9, 58.11, PGW’s and 58.16. However, several Parties were opposed to waiver request for 52 Pa. PGW’s Code §§ 58.4(a), 58.10, and 58.14. Specifically, the OCA, CAUSE-PA, TURN, et al. and the CAC opposed waiver request of 52 Pa. Code § 58.4(a). The OCA, PGW’s CAUSE-PA and TURN, opposed waiver request of 52 Pa. Code § 58.10, et al. PGW’s while only the OCA opposed waiver request of 52 Pa. Code § 58.14. PGW’s With regard to requested waiver of 52 Pa. Code § 58.5 (relating to PGW’s program funding), while no Party objected to this waiver request, the OCA expressed concerns about administrative cost levels. Nonetheless, because CRP PGW’s PGW’s Home Comfort program is projected to yield a positive TRC and because PGW expects a rise in the percentage of LIURP funds for customer installations once cost reductions are identified and implemented, the concern became a non-issue. PGW M.B. at 79. OCA’s 1. Exemption Pursuant to 52 Pa. Code § 58.18 waiver request relies on the exemption provision set forth in PGW’s Section 58.18 of the LIURP Regulations. Section 58.18 allows a covered Commission’s utility alleging special circumstances to seek an exemption for its usage reduction program from the LIURP Regulations. 52 Pa. Code § 58.18. a. Positions of the Parties PGW averred that its LIURP has operated within the DSM Plan since its inception in 2011, and is consistent with the goals set forth in the LIURP Commission’s Regulations at 52 Pa. Code § 58.1. According to PGW, its CRP Home Comfort program
panels). The requested waivers and the justification for the waivers are set forth in Appendix A to the Petition. Petition at 13. No Party opposed PGW’s waiver request for 52 Pa. Code §§ 58.9, 58.11, and 58.16. However, several Parties were opposed to PGW’s waiver request for 52 Pa. Code §§ 58.4(a), 58.10, and 58.14. Specifically, the OCA, CAUSE-PA, TURN, et al. and the CAC opposed PGW’s waiver request of 52 Pa. Code § 58.4(a). The OCA, CAUSE-PA and TURN, et al. opposed PGW’s waiver request of 52 Pa. Code § 58.10, while only the OCA opposed PGW’s waiver request of 52 Pa. Code § 58.14. With regard to PGW’s requested waiver of 52 Pa. Code § 58.5 (relating to program funding), while no Party objected to this waiver request, the OCA expressed concerns about PGW’s administrative cost levels. Nonetheless, because PGW’s CRP Home Comfort program is projected to yield a positive TRC and because PGW expects a rise in the percentage of LIURP funds for customer installations once cost reductions are identified and implemented, the OCA’s concern became a non-issue. PGW M.B. at 79. 1. Exemption Pursuant to 52 Pa. Code § 58.18 PGW’s waiver request relies on the exemption provision set forth in Section 58.18 of the Commission’s LIURP Regulations. Section 58.18 allows a covered utility alleging special circumstances to seek an exemption for its usage reduction program from the LIURP Regulations. 52 Pa. Code § 58.18. a. Positions of the Parties PGW averred that its LIURP has operated within the DSM Plan since its inception in 2011, and is consistent with the goals set forth in the Commission’s LIURP Regulations at 52 Pa. Code § 58.1. According to PGW, its CRP Home Comfort program
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