With regard to CAUSE-PA’s argument that the heating proposal de facto would the high number of PGW service PGW retorted that there is “reduce terminations,” no validity to this claim. PGW alleged that if a customer cannot pay his or her CRP asked-to-pay bill, then whether or not the home receives LIURP weatherization services will not make a difference because the CRP bill will be the same with or without the weatherization services. PGW concluded that the electric heating proposal de facto would not fulfill the regulatory purposes CAUSE-PA and TURN rely on in their et al. support of the proposal. PGW also contended that the reference to Section 58.4(d) of the Commission Regulations does not apply in this case because this section discusses pilot programs achieving the purposes of residential low income usage 52 Pa. “for reduction.” Code § 58.4(d). PGW argued there is no legal mandate in the LIURP Commission’s Regulations for PGW to implement CAUSE-PA’s electric heating proposal. de facto PGW R.B. at 86. The OCA is not opposed to CAUSE-PA’s electric heating de facto proposal. OCA M.B. at 84. I&E did not object to the electric heating proposal. de facto I&E R.B. at 25. The OSBA, PICGUG and the CAC did not take any specific position regarding the proposal. 2. Recommendation ALJs’ The ALJs recommended denial of the electric heating proposal de facto advocated by CAUSE-PA because they did not believe it was an effective use of resources. Moreover, they did not think it is workable under the circumstances because the proposal failed to take into consideration the fact that many of the affected customers already have large arrearages. R.D. at 186. First, the ALJs noted that CRP program is a percentage of income PGW’s program which requires CRP customers to pay a specific amount based on their level of
With regard to CAUSE-PA’s argument that the de facto heating proposal would “reduce the high number of PGW service terminations,” PGW retorted that there is no validity to this claim. PGW alleged that if a customer cannot pay his or her CRP asked-to-pay bill, then whether or not the home receives LIURP weatherization services will not make a difference because the CRP bill will be the same with or without the weatherization services. PGW concluded that the de facto electric heating proposal would not fulfill the regulatory purposes CAUSE-PA and TURN et al. rely on in their support of the proposal. PGW also contended that the reference to Section 58.4(d) of the Commission Regulations does not apply in this case because this section discusses pilot programs “for achieving the purposes of residential low income usage reduction.” 52 Pa. Code § 58.4(d). PGW argued there is no legal mandate in the Commission’s LIURP Regulations for PGW to implement CAUSE-PA’s de facto electric heating proposal. PGW R.B. at 86. The OCA is not opposed to CAUSE-PA’s de facto electric heating proposal. OCA M.B. at 84. I&E did not object to the de facto electric heating proposal. I&E R.B. at 25. The OSBA, PICGUG and the CAC did not take any specific position regarding the proposal. 2. ALJs’ Recommendation The ALJs recommended denial of the de facto electric heating proposal advocated by CAUSE-PA because they did not believe it was an effective use of resources. Moreover, they did not think it is workable under the circumstances because the proposal failed to take into consideration the fact that many of the affected customers already have large arrearages. R.D. at 186. First, the ALJs noted that PGW’s CRP program is a percentage of income program which requires CRP customers to pay a specific amount based on their level of
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