Finally, the OCA argued that, since the Fuel-Switching program is solely designed as a load growth program, it does not meet the requirements for a DSM program. Accordingly, the OCA maintained that, rather than invest in load growth programs, the DSM program goals would be better met by directing the proposed budget of $2.29 million towards the CRP Home Comfort Program. OCA M.B. at 21; OCA R.B. at 8. b. Recommendation ALJs’ In their Recommended Decision, the ALJs found that they agreed with the OCA that proposed Efficient Fuel-Switching program will increase gas demand PGW’s and consumption within service territory and, as such, should not be part of PGW’s Phase II DSM Plan. The ALJs stated that while they understood that goal PGW’s PGW’s for this program is to help small and mid-sized commercial and industrial customers improve the overall net energy efficiency of their buildings, they agreed with the OCA that this proposal is a load growth program for PGW that would increase, rather than reduce, existing natural gas usage. The ALJs concluded that unlike EDCs such as UGI Electric or PECO, who shifted load off of themselves to natural gas as part of their energy efficiency plans, the end result of proposal will be to shift load away from PGW’s PECO Electric (the EDC in service territory) to itself. According to the ALJs, PGW’s this is clearly a load growth program. R.D. at 126. The ALJs maintained that the General Assembly has established that the purpose of an energy efficiency program is reduce energy demand and EDC’s “to consumption within the service territory of each electric distribution company in this 66 Pa. C.S.A. § 2806.1(a). The ALJs concluded that, although PGW Commonwealth.” is an NGDC rather than an EDC, they agreed with the OCA that the stated purpose of energy efficiency, even as it relates to PGW, should be to reduce the own energy utility’s demand and consumption. The ALJs found that since proposal will only have the PGW’s
Finally, the OCA argued that, since the Fuel-Switching program is solely designed as a load growth program, it does not meet the requirements for a DSM program. Accordingly, the OCA maintained that, rather than invest in load growth programs, the DSM program goals would be better met by directing the proposed budget of $2.29 million towards the CRP Home Comfort Program. OCA M.B. at 21; OCA R.B. at 8. b. ALJs’ Recommendation In their Recommended Decision, the ALJs found that they agreed with the OCA that PGW’s proposed Efficient Fuel-Switching program will increase gas demand and consumption within PGW’s service territory and, as such, should not be part of PGW’s Phase II DSM Plan. The ALJs stated that while they understood that PGW’s goal for this program is to help small and mid-sized commercial and industrial customers improve the overall net energy efficiency of their buildings, they agreed with the OCA that this proposal is a load growth program for PGW that would increase, rather than reduce, existing natural gas usage. The ALJs concluded that unlike EDCs such as UGI Electric or PECO, who shifted load off of themselves to natural gas as part of their energy efficiency plans, the end result of PGW’s proposal will be to shift load away from PECO Electric (the EDC in PGW’s service territory) to itself. According to the ALJs, this is clearly a load growth program. R.D. at 126. The ALJs maintained that the General Assembly has established that the purpose of an EDC’s energy efficiency program is “to reduce energy demand and consumption within the service territory of each electric distribution company in this Commonwealth.” 66 Pa. C.S.A. § 2806.1(a). The ALJs concluded that, although PGW is an NGDC rather than an EDC, they agreed with the OCA that the stated purpose of energy efficiency, even as it relates to PGW, should be to reduce the utility’s own energy demand and consumption. The ALJs found that since PGW’s proposal will only have the
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