PENNSYLVANIAPUBLIC UTILITY COMMISSION

Harrisburg, PA 17105-3265

Public Meeting held October 2, 2014

Commissioners Present:Robert F. Powelson, ChairmanJohn F. Coleman, Jr., Vice ChairmanJames H. Cawley, StatementPamela A. WitmerGladys M. Brown

UGI Utilities, Inc.- Gas Division, UGI Utilities, Inc.-Electric Division, UGI Penn Natural Gas, Inc., and UGI Central Penn Gas, Inc., Universal Service and Energy Conservation Plan for 2014-2017 Submitted in Compliance with 52 Pa. Code § 54.74 and § 62.4.

Docket No. M-2013-2371824

TENTATIVE ORDER

BY THE COMMISSION

On July 1, 2013, UGI Utilities, Inc.- Gas Division (UGI Gas), UGI Penn Natural

Gas, Inc. (UGI PNG), UGI Central Penn Gas, Inc. (UGI CPG), and UGI Utilities, Inc.-

Electric Division (UGI Electric) (collectively referred to herein as “UGI” or “Company”)

filed its universal service and energy conservation plan (USECP) for 2014 through 2016

in accordance with the Commission’s regulations at 52 Pa. Code §§ 54.71 - 54.78 and §§

62.1 - 62.8, relating to electric universal service and energy conservation reporting

requirements. On August 1, 2014, UGI filed an amended USECP for 2014-2017

(Proposed 2014-2017 Plan). By this Tentative Order, we will tentatively approve UGI’s

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Proposed 2014-2017 Plan, consistent with this order, and solicit comments from

interested parties.

I. BACKGROUND

The Electricity Generation Customer Choice and Competition Act (Electric

Competition Act), 66 Pa.C.S. §§ 2801-2812, became effective on January 1, 1997. The

Natural Gas Choice and Competition Act (Gas Competition Act), 66 Pa.C.S. §§ 2201-

2212, became effective on July 1, 1999. The primary purpose of these Competition Acts

was to introduce competition into the retail electric and natural gas generation markets.

These two Competition Acts established standards and procedures for the restructuring of

the electric and natural gas utility industries. While opening the markets to competition,

the Acts also include several provisions relating to universal service to ensure that

electric and natural gas service remains available to all customers in the Commonwealth.

The universal service provisions of the Competition Acts, among other things, tie

the affordability of electric and natural gas service to a customer’s ability to maintain

utility service. The Competition Acts define “universal service and energy conservation”

as the policies, practices and services that help low income customers maintain utility

service. The term includes customer assistance programs (CAPs), usage reduction

programs, service termination protections and consumer education. 66 Pa.C.S. §§ 2202

and 2803. The Competition Acts commit the Commission to continuing, at a minimum,

the policies, practices and services that were in existence as of the effective date of the

laws. 66 Pa.C.S. §§ 2203(7) and 2802(10). Finally, the Competition Acts require the

Commission to ensure that universal service and energy conservation services are

appropriately funded and available in each utility distribution territory. 66 Pa.C.S.

§§ 2203(8) and 2804(9).

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The General Assembly has acknowledged the importance of helping low-income

customers maintain utility service. Under the Competition Acts, universal service

programs are subject to the administrative oversight of the Commission, which must

ensure that the utilities run the programs in a cost-effective manner. 66 Pa.C.S.

§§ 2203(8) and 2804(9). Although the Competition Acts do not define “affordability,”

the Commission’s Policy Statement provides guidance on affordable payments. 52 Pa.

Code §§ 69.261-69.267. The Commission balances the interests of customers who

benefit from the programs with the interests of the customers who pay for the programs.

See Final Investigatory Order on CAPs: Funding Levels and Cost Recovery

Mechanisms, Docket No. M-00051923 (Dec. 18, 2006), (Final CAP Investigatory

Order), at 6-7.

To help meet these requirements, the Commission promulgated the Universal

Service and Energy Conservation Reporting Requirements regulations (Reporting

Requirements). 52 Pa. Code §§ 54.71- 54.78 (electric) and §§ 62.1 - 62.8 (gas). These

Reporting Requirements require each natural gas distribution company (NGDC) serving

more than 100,000 residential accounts and each electric distribution company (EDC)

serving more than 60,000 residential accounts to submit an updated USECP every three

years to the Commission for approval. 52 Pa. Code §§ 54.74 and 62.4. UGI Gas, UGI

PNG, and UGI CPG are jurisdictional NGDCs; UGI Electric is a jurisdictional EDC.

As of June 30, 2014, the number of residential customers served and the number

of customers enrolled into CAP by UGI companies were as follows:

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Table 1

Residential Class Size1 and CAP Enrollment2 as of June 30, 2014

UGI Companies Residential Customers CAP Enrollment

UGI Gas 326,058 7,193UGI PNG 147,790 5,756UGI CPG 68,740 2,156

UGI Electric 54,228 2,121Totals 596,816 17,226

II. HISTORY

The Company’s most recent USECP was its 2011-2013 Plan, approved by the

Commission at Docket No. M-2010-2186052, by order entered on October 31, 2011.3 A

six-year evaluation of UGI Gas and UGI PNG’s universal service and energy

conservation efforts was completed in July 2012, by Applied Public Policy Research

Institute for Study and Evaluation (APPRISE) (2012 APPRISE Universal Service

Evaluation). Because USECPs are not mandated for UGI CPG and UGI Electric since

they don’t have more than 100,000 and 60,000 residential accounts, respectively, they

were not included in the 2012 APPRISE Universal Service Evaluation. Additionally,

APPRISE conducted the third party evaluation of LIURP in 2013, as outlined in the

regulations at § 62.6(a) (2013 APPRISE LIRUP Evaluation). Although UGI CPG and

UGI Electric are not required to have a LIURP program, they have voluntarily operated,

reported and evaluated LIURP in the same manner as UGI Gas and UGI PNG

historically. All four companies were included in the 2013 APPRISE LIURP Evaluation.

In compliance with Commission regulations, UGI submitted its 2014-2016 Plan

on July 1, 2013, and served the Office of Consumer Advocate (OCA), the Pennsylvania

1 Proposed 2014-2017 Plan at 1-2. 2 As reported to the Commission’s Bureau of Consumer Services (BCS)3 UGI CPG is not mandated to file a USECP because it is below the 100,000 customer threshold for an NGDC, UGI Electric also is not mandated to file a USECP because it is below the 60,000 customer threshold for an EDC.

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Utility Law Project (PULP), the Office of Small Business Advocate (OSBA) and the

Bureau of Investigation and Enforcement (BIE).

On June 27, 2014, the Commission issued a Secretarial Letter to all utilities

providing a revised USECP filing schedule. As part of the new filing schedule, UGI’s

USECP for 2014-2016 was extended to include 2017. On August 1, 2014, UGI filed and

served an amended USECP for 2014 through 2017 for all four utilities

III. DISCUSSION

As detailed below, UGI’s Proposed Plan for 2014-2017 complies, in part, with

applicable provisions in the Public Utility Code, 66 Pa.C.S. §§ 101 et seq., Commission

regulations and Commission policy statements. The Plan contains all of the components

cited in the definition of universal service at 66 Pa.C.S. §§ 2202. The Plan also meets the

requirements at 66 Pa.C.S. §§ 2203(8), which mandate that universal service programs be

available in each large NGDC service territory and that the programs be appropriately

funded.4 Finally, the Plan, in part, meets the submission and content obligations of the

Universal Service Reporting Requirements at 52 Pa. Code §§ 54.74 and 62.4, the Low

Income Usage Reduction Program (LIURP) regulations at 52 Pa. Code §§ 58.1-58.18 and

the CAP Policy Statement at 52 Pa. Code §§ 69.261-69.267.

IV. CONTENTS OF UGI’s PROPOSED 2014-2017 PLAN

A. Requirements

The Reporting Requirements at Section 62.4(b) require utilities to include the

following information for each component of their universal service plans:

4 UGI CPG is not a large NGDC but has voluntarily filed a USECP in conjunction with UGI Gas and UGI PNG. Section 2804(9) of the Electric Competition Act contains similar mandates for large EDCs. UGI Electric is not a large EDC but has voluntarily filed a USECP in conjunction with UGI Gas and UGI PNG.

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Program description;

Eligibility criteria;

Projected needs assessment;

Projected enrollment levels;

Program budget;

Plans to use community-based organizations;

Organizational structures;

Explanation of any differences between the last approved plan and the

implementation of that plan;

Outreach and intake efforts;

Explanation of steps used to identify low-income customers with arrears and to

enroll then in an appropriate program; and

Explanation of the integration of the various universal service programs.

The following sections provide a summary of the information provided by UGI

regarding its Proposed 2014-2017 Plan.

B. Modifications to the Universal Service Programs in the Proposed

2014 - 2017   Plan

Pursuant to Section 62.4(a)(3) of the Reporting Requirements, UGI reports the

following changes from its 2011-2013 Plan:

1. CAP

o Setting a customer’s monthly CAP bill amount based on percent of income

or average monthly bill, whichever is lower.

o Requiring CAP agencies to identify high usage CAP participants/applicants

and provide these customers with an energy education session.

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o Providing additional information and routine metrics for CAP agencies to

meet in order to improve UGI’s ability to monitor performance.

o CAP eligibility now includes a review of a customer’s history with CAP. If

a customer had previously defaulted from the program, he/she will only be

eligible to reapply for CAP if the reason for the default has been cured.

Customers who voluntarily leave the CAP program will not be eligible to

reapply for a period of one year, except in situations of demonstrated

hardship.

o Only non-LIHEAP recipients must recertify annually for CAP. When

LIHEAP and CAP income guidelines are consistent, CAP customers who

receive a LIHEAP grant annually are only required to recertify for CAP

every three (3) years.

o Bi-monthly meter reading requirement has been eliminated.

o Customers will receive a minimum pre-program arrearage forgiveness

amount of $10 monthly.

o Pre-program arrearage forgiveness will not be applied if the customer’s

account balance is a credit or if the forgiveness will result in a credit.

Withheld forgiveness will be applied to an account when it will not result in

a credit to the customer’s account.

o CAP credits will be applied monthly.

o The maximum CAP credit limit has been eliminated.

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2. LIURP

o UGI Gas proposes to eliminate the Conservation Pilot Program.

o UGI Gas proposes to make the Rehabilitation Pilot Program a permanent

part of its LIURP, and the Company proposes to extend the program to all

UGI companies.

3. Customer Assistance and Referral Evaluation Services (CARES) – UGI’s

description of its CARES Program contains no material differences between the

Proposed 2014-2017 Plan and the previous three-year Plan.

4. Operation Share Energy Fund

o UGI has revised the distribution of company contributions to its hardship

funds based on low-income demographics within each company’s customer

base.

O A matching funds component has been added to the UGI CPG hardship

fund.

C. Program Descriptions

UGI’s Proposed Plan contains four components that help low income customers

maintain utility service. The four components are as follows: (1) CAP, which provides

discounted rates for low income residential customers; (2) LIURP, which provides

weatherization and usage reduction services to help low income customers reduce their

utility bills; (3) CARES, which provides referral services for low income, special needs

customers; and (4) a Hardship Fund, entitled Operation Share Energy Fund, which

provides grants to customers with hardships, who have an inability to pay the full amount

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of their energy bills and have annual incomes at or below 200% of the Federal Poverty

Income Guidelines (FPIG).

With these four programs in place, UGI’s Proposed 2014-2017 Plan meets this

requirement of the Competition Acts. We shall review each program below.

In addition to our analysis of the Proposed 2014-2017 USECP, BCS also reviewed

122 informal complaints from UGI’s CAP customers opened between January 1, 2013

and December 31, 2013. From this review, staff identified additional potential areas of

concern and potential deficiencies inherent in UGI’s CAP programs as detailed below.

1. Customer Assistance Program

CAP offers discounted gas and electric bills to low income customers who are not

able to pay their gas or electric service bills in full. UGI funds its CAP programs through

residential base rates and/or a universal service fund rider. In addition to reduced utility

bills, CAP customers receive 1/36th of pre-program arrearages forgiven for each month

of on-time and in-full CAP payments. At a minimum, compliant CAP customers receive

$10 of pre-program arrearage forgiveness per month. However, arrearage forgiveness

will not be applied if the forgiveness would result in a credit or a credit already exists in a

customer’s account.5

To be eligible for UGI’s CAP, a customer must have income at or below 150% of

the FPIG and be a residential customer of a UGI company. Customers who had been

previously enrolled and been removed from UGI’s CAP must have cured the reason for

their previous dismissal from the program to be eligible for re-enrollment. Some

customers voluntarily leave CAP when the CAP bill is higher than the actual usage bill,

then want to reenroll when the actual usage bill becomes higher. UGI requires those who

5 Withheld forgiveness will be applied when the credit balance is cured. Proposed 2014-2017 Plan at 16.

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voluntarily leave CAP to stay out for a minimum of 12 months. UGI will waive its stay

out provision for customers who have experienced a demonstrated hardship (ex. sudden

loss of income or other financial/personal setback).

UGI calculates a customer’s monthly CAP bill based on a percentage of the

household’s gross income or the average annual bill for the residence,6 whichever is more

affordable. The percentage of income CAP Payment is shown in Table 2.

Table 2

Calculating Percentage of Income for CAP Payment Amount

Household Income

According to the FPIG

Monthly Income % to Pay

0-50% FPIG 7% of Household’s monthly income51-100% FPIG 8% of Household’s monthly income101-150% FPIG 9% of Household’s monthly income

If a customer’s percentage of income amount exceeds the average annual bill for the

residence, the average bill for the residence will be used as the customer’s CAP payment

amount. The minimum monthly CAP payment amount is $25 for heating accounts and

$15 for non-heating accounts. UGI does not have an annual limit for CAP credits.7

Thus, UGI CAP customers will be billed the same amount per month, regardless of

usage. CAP credits are applied monthly with each full CAP payment.

UGI contracts with a number of non-profits to administer its CAP program. These

organizations are responsible for accepting CAP applications, verifying eligibility,

explaining the benefits of the program to customers, referring participants to other

programs, monitoring accounts, and providing energy education sessions to high energy

6 UGI reports that, if 12 months of usage data is not available for the residence, the average annual bill is determined by using the average bill for all residential customers. Proposed 2014-2017 Plan at 11.7 Section 62.2 of the Reporting Requirements defines CAP credits as the “difference between the amount billed at the standard residential rate and the amount billed at the CAP rate.”

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users. In addition, the CAP administering agencies provide education to customers about

usage reduction/energy conservation and household budgeting. Recertification for CAP

is also handled by the CAP administering agencies, but UGI processes the appeals for

reconsideration from customers removed from the program within 30 days.

To remain in a UGI CAP program, participants must:

Make monthly CAP payments.

Apply for LIHEAP grants and direct the payment to the UGI company.8

Participate in weatherization programs, if eligible, and conserve energy.

Provide access to the household’s meter, if required.

Participate and comply with other programs recommended by the agency.

Report changes of family size and/or income immediately.

Apply for assistance grants when eligible.

One or more of these requirements may be waived by UGI or its CAP administering

agencies if the customer is experiencing extraordinary circumstances.

CAP customers who receive LIHEAP grants and direct them to UGI annually will

only be required to provide income documentation for recertification once every three

years.9 CAP customers who do not have a LIHEAP grant issued to UGI will be required

to provide income documentation annually to verify that household income is at or below

150% of the FPIG.

8 Failure to apply for LIHEAP may lead to removal from CAP. Proposed 2014-2017 Plan at 20.9 In a meeting with BCS on August 6, 2014, UGI staff explained that CAP applicants are not required to provide income documentation if they have received and directed a LIHEAP grant to UGI within the past 12 months. In these instances, UGI will use the income listed on the application to determine the customer’s CAP payment amount.

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a. CAP Enrollment Limits

UGI proposes to serve a maximum of 26,000 eligible low-income customers

through its CAP programs. Proposed 2014-2017 Plan at 11. The CAP enrollment limits

for each UGI company is shown in Table 3.

Table 3

Maximum CAP Enrollment Limits for UGI Companies

Companies Maximum CAP EnrollmentUGI Gas 10,000UGI PNG 7,500UGI CPG 6,000

UGI Electric 2,500Total 26,000

During the approval process for its 2011-2013 USECP, UGI explained that the

CAP enrollment limits were previously approved by the Commission in other, unrelated

proceedings. The 10,000 maximum enrollment level for UGI Gas,10 the 7,500 enrollment

limit for UGI PNG,11 the 6,000 enrollment limit for UGI CPG12 and the 2,500 enrollment

ceiling for UGI Electric13 were all approved by the Commission. UGI Reply Comments

at 22-23, Docket No. M-2010-2186052. In UGI’s 2011-2013 USECP Final Order, we

directed the Company to continue to monitor need projections and to petition the

Commission to increase CAP enrollment numbers, if necessary. See UGI’s 2011-2013

USECP Final Order, Docket No. M-2010-2186052 (October 31, 2011), at 36.

10 See Petition of UGI Utilities, Inc. – Gas Division to Expand Participation in UGI’s Low Income Self-Help Program, Docket No. P-2008-2066708 (December 4, 2008).11 See Pa. PUC, et al. v. UGI PNG, Docket No. R-2008-2079660 (August 27, 2009).12 See Pa. PUC, et al. v. UGI CPG, R-2008-2079675 (August 27, 2009).13 See Petition of UGI Utilities, Inc. – Electric Division to Expand Participation in UGI-ED’s Customer Assistance Program, Increase the Maximum Allowed Discounts, and Implement a Funding Mechanism to Recover Certain Associated Costs, Docket No. P-2008-2066579 (December 4, 2008).

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Although the UGI companies have not yet neared the CAP enrollment limits

shown above, we question whether maintaining these CAP enrollment limits is

appropriate. In recent USECP proceedings, the Commission has encouraged utilities to

increase CAP enrollment.14 In particular, we approved Duquesne Light’s plan to

automatically enroll customers into CAP upon receipt of a LIHEAP grant. See Duquesne

Light 2014-2016 USECP Final Order, Docket No. M-2013-2350946 (March 6, 2014),

at 8-9. We are not aware of any other NGDC or EDC that maintains CAP enrollment

limits. Low-income households within UGI’s service territory should not be denied CAP

because the maximum number of customers has been reached and the Company is in the

process of petitioning the Commission for an increase to its enrollment limit.

Proposed Resolution: We recommend that UGI petition the Commission to remove limits

to CAP enrollment levels for all of its companies. In the interim, UGI should not wait

until the limits are reached before addressing increased demand.

b. Tariff Language

BCS, in consultation with the Commission’s Bureau of Audits, identified language

in UGI’s tariffs that is no longer applicable for UGI Gas (LISHP Rider), UGI PNG

(Universal Service Program Rider), and UGI CPG (Universal Service Program Rider).

Specifically, the language referencing the CAP shortfall calculation (i.e., less LIHEAP

energy assistance received) needs to be corrected. DPW’s current policy prohibits

applying LIHEAP grants toward CAP shortfalls or pre-program arrearages.15

In a footnote in the Proposed 2014-2017 Plan, the Company clarifies that it

currently applies LIHEAP according to DPW’s most recent LIHEAP State Plan:

14 See, e.g., PGW 2014-2016 USECP Final Order, Docket number M-2013-2366301 (August 22, 2014) at 64-69. 15 LIHEAP Fiscal Year 2014 Final State Plan §601.45.

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The UGI Companies[] interpret existing tariff language applying LIHEAP energy assistance received to the CAP shortfall or CAP Credit amount as being applicable only to the extent permitted under the Final [LIHEAP] State Plan, as amended. The Final State Plan in effect as of the Filing Date hereof does not permit the application of LIHEAP payments to CAP shortfall; therefore, the UGI Companies do not apply LIHEAP energy assistance received as a calculation offset to CAP shortfall amount. Rather, consistent with the Final State Plan, any LIHEAP energy assistance received is directly reflected in the CAP customer payment amounts (or “asked to pay” amounts) utilized in the calculation.

Proposed 2014-2017 Plan at 15.16

While the Commission appreciates UGI’s clarification that it does not apply

LIHEAP grants toward shortfall amounts, we are still concerned that the language in its

tariff rider does not reflect DPW’s current policy or UGI’s practices.

Proposed Resolution: We propose that UGI update its tariff language to reflect its current

practices, consistent with DPW’s current LIHEAP policy.17

c. Arrearage Forgiveness

On page 16 of the Proposed 2014-2017 Plan, UGI states that “[c]ustomers will not

receive [1/36th monthly arrearage] forgiveness if they are not current with their payments

but will receive forgiveness once they bring payments up to date.” In informal

discussions with BCS, UGI reported that this statement does not reflect current policy.

UGI stated that it applies arrearage forgiveness for each timely and in-full monthly

payment, regardless of any existing CAP arrears. In addition, it applies arrearage

forgiveness retroactively for any months missed once the CAP account is paid in-full.

16 Further clarification regarding UGI Gas’s LISHP Rider is provided on pages A-3 and A-4 of the Proposed 2014-2017 Plan.17 Utility operations must adhere to the utility’s tariffs. If not, either the tariff must be changed or the operations must be changed. It is well settled that public utility tariffs must be applied consistently with their language. See, e.g., PPL v. Pa. PUC, 912 A.2d. 386 (Pa. Cmwlth. 2006).

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Proposed Resolution: In its comments to this order, UGI should clarify its arrearage

forgiveness policy and confirm that CAP customers can receive forgiveness for timely

and full monthly payments, regardless of arrears, and retroactively once the account is

caught up.

c. Receipt of LIHEAP and Recertification

As noted above, UGI’s Proposed 2014-2017 Plan explains that CAP customers

who receive LIHEAP and direct it to a UGI company annually will only be required to

provide income verification once every three years to recertify for CAP. If UGI does not

receive a LIHEAP grant for a CAP customer, then he or she must provide income

documentation annually to verify that household income is at or below 150% of the

FPIG. Proposed 2014-2017 Plan at 18-19. However, UGI also states that it may remove

a CAP participant from the program for refusal to apply for LIHEAP. Proposed 2014-

2017 Plan at 20.

From this description, it appears that UGI requires its CAP customers to recertify

only once every three years if they receive LIHEAP, or annually if they do not. It is

unclear why UGI has an annual recertification policy for customers who do not receive a

LIHEAP grant or for households that do not direct their LIHEAP grant to UGI, when

either of these situations could make them ineligible to participate in CAP.

Proposed Resolution: In its comments to this order, UGI should clarify whether

customers are allowed to remain in the CAP program and recertify if, within the past 12

months, they have not applied for LIHEAP or directed their LIHEAP grant to UGI.18

18 “A receipt of a LIHEAP Cash or Crisis grant within the last 12 months when the LIHEAP income guidelines are the same as CAP, however, such participants will be required to provide income documentation every three years” Proposed 2014-2017 Plan at 18.

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d. Reminding CAP Customers to Recertify

If a CAP customer fails to recertify within two billing cycles after UGI notifies

him or her that it is time to recertify, the customer’s CAP payment will increase to the

household’s average bill amount. UGI will adjust future payments to the discounted CAP

amount for those customers recertifying late, but the customer must pay any bills already

issued at the higher rate. Proposed 2014-2017 Plan at 19.

In our review of 122 informal complaints filed at the Commission by UGI

customers in 2013, we found 19 instances where customers complained of high CAP

payments as a result of being charged budget billing because they failed to recertify.

Most of these customers reported being unaware of the reason their CAP payments

increased and did not know they had failed to recertify. Company responses to these

complaints suggest that UGI sends only one recertification letter to CAP customers

before switching them to budget billing.

The Commission supports UGI’s policy of keeping customers on CAP at the

budget bill rate if they fail to recertify. This allows customers to continue to receive

arrearage forgiveness for monthly payments and other CAP benefits. However, we

question whether UGI’s recertification notification procedure is sufficient. UGI could

provide additional notifications to customers before and, if necessary, after a

recertification deadline. Additional reminders to recertify could decrease the number of

CAP customers defaulted to budget billing and reduce the amount of time these

customers remain on budget billing. There are a number of methods that UGI could

utilize to provide these reminders. The Commission offers these suggestions:

Recertification letters sent to CAP customers 30 and 10 days prior to a

recertification deadline.

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A CAP agency representative could attempt a telephone contact shortly before and

after the recertification deadline to inform the customer that the agency has not

received the recertification documentation and that the household will soon be

switched to budget billing.

Proposed Resolution: In its comments to this order, UGI should address how it could be

more effective in reminding customers to recertify for CAP before and after the

recertification deadline.

e. Requiring Notarization of No Income Statements

In its Proposed 2014-2017 Plan, UGI does not explain its policy and procedures

for addressing situations where a CAP applicant or participant reports zero income.

However, in our review of 122 informal complaints filed at the Commission by UGI

customers in 2013, we found 2 instances where a UGI CAP customer who reported zero

income was required to provide a notarized “zero income” statement. Both customers

were enrolled in UGI Electric’s CAP program.

We have previously addressed the requirement for a customer to provide a

notarized “zero income” statement. In the PECO 2013-2015 USECP Final Order, the

Commission directed that statements of zero income need not be notarized. See PECO

2013-2015 USECP Final Order, Docket No. M-2012-2290911 (April 4, 2013), at 39-41.

Many utility companies allow customers who report no source of income to enroll in

CAP if they provide documentation of how they meet monthly expenses. None of these

companies require that the forms be notarized. A few examples:

Duquesne Light’s CAP program requires households reporting no income to

complete a zero income form. This form requires the customer to identify all

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household members, explain how household expenses are met, and gives

Duquesne Light permission to verify their income with government agencies.

This form must be signed and dated. Duquesne Light’s 2014-2016 USECP at 6-7,

Docket No. M-2013-2350946.

PECO Energy Company’s CAP program requires that a customer must provide a

statement demonstrating how they meet monthly expenses if the customer or any

household member over the age of 18 claims no income. PECO’s Second

Amended 2013-2015 USECP at 13, Docket No. M-201 2-2290911.

Philadelphia Gas Works’ CAP program, entitled the Customer Responsibility

Program (CRP), requires customers reporting zero income to complete a form

explaining how they meet basic living expenses for housing, food, and utilities.

PGW does not require documentation of these living expenses, but will request

proof of housing expenses during periodic CAP reviews. The zero income form

requires contact information and a signature for any person or persons that provide

the household financial support, including the amount of support they provide

monthly. See PGW 2014-2016 USECP Final Order, Docket No. M-2013-

2366301 (August 22, 2014), at 26-29.

Proposed Resolution: Requiring a notarized letter of no income is not necessary to the

operation of UGI’s CAP. Such a requirement imposes financial and logistical burdens on

persons who lack the resources to appear before a notary public and/or to pay for notary

services. In its comments to this order, UGI should explain the company’s standard

policy and procedure when a CAP applicant or participant reports zero income. We also

encourage UGI to review zero income eligibility criteria utilized by other utility CAP

programs and consider revising its zero income requirements accordingly, if warranted.

In addition, UGI should ensure that all of its companies eliminate the notarization

requirement for zero income statements.

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f. Elimination of Maximum CAP Credit Limits

In its Proposed Plan, UGI proposes to eliminate the maximum limit of CAP credits

a customer can receive each year. This change was recommended by APPRISE.19

Proposed 2014-2017 Plan at 17; citing 2012 APPRISE Universal Service Evaluation at

86. The Company reports that it has not found excessive energy usage among its CAP

customers, which was the concern leading to the establishment of CAP credit limits.

Proposed 2014-2017 Plan at 17.

UGI proposes also to institute new CAP control features in response to the

elimination of the CAP credit limits. The Company would set annual threshold limits to

identify high usage customers. The proposed annual threshold limits for the UGI

companies are shown in Table 4.

Table 4

High Usage Thresholds for UGI Companies

Company High UsageUGI Gas 2,185 ccfUGI PNG 2,356 ccfUGI CPG 2,135 ccfUGI Electric 34,465 kwh

Proposed 2014-2017 Plan at 17.

UGI will monitor CAP participants who exceed these thresholds and require them

to speak with a CAP caseworker to discuss potential reasons for the customer’s high

19 APPRISE reported that UGI customers enrolling in CAP with incomes below 50% of the FPIG had an average energy burden of 16%; compared to an energy burden of 8% for customers who had incomes between 50% and 150% of the FPIG. APPRISE noted that CAP customers with incomes below 50% of the FPIG were more likely to exceed their CAP credit limits. APPRISE recommended that UGI “consider increasing the maximum shortfall amount for customers in this poverty group to increase the affordability for these customers. Another option is to consider eliminating the maximum shortfall component.” 2012 APPRISE Universal Service Evaluation at 86.

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usage and to engage in an energy education session. UGI will refer those customers to

LIURP, if applicable, and continue to monitor household usage for additional outreach

and referral. CAP participants who refuse to participate in LIURP or fail to comply with

high usage controls will risk removal from the program. Proposed 2014 2017 Plan

at 17-18.

Without CAP credit limits, program participants will receive their full CAP

discount each month, regardless of energy usage. Though UGI describes its reasons for

eliminating the CAP credit limit, it does not identify how this change will impact the cost

of its CAP programs. The Commission is concerned that lack of consumption limits will

result in higher program costs that must be borne by non-CAP residential customers.

Proposed Resolution: In its comments to this order, UGI should explain if it anticipates

an increase to its annual CAP budget with the elimination of CAP credits limits and if

any of this increase is reflected in the projected CAP budgets listed in its 2014-2017

Proposed Plan.

2. Low Income Usage Reduction Program (LIURP)

UGI’s LIURP programs reduce energy consumption for eligible customers by

providing energy conservation measures and education. The purpose of LIURP is to

“reduce customer arrearage, collection and termination costs.” All customers enrolled in

LIURP receive a free “energy survey/audit.” Energy conservation measures provided by

UGI’s LIURP programs may include, but are not limited to, the following services:

insulation, furnace repair/replacement, attic ventilation, window replacement, caulking,

water heater repair/replacement, and energy education. Proposed 2014-2017 Plan at 22.

To be eligible for UGI’s LIURP program, a customer must be able to demonstrate

that:

20

The customer’s household income is at or below 150% of the FPIG;20

The customer is an active residential gas heating customer or an electrical

heating/non-heating customer;

The customer has above average annual consumption;

The customer has had continuous service for 12 months;

The customer’s premises is suitable for weatherization services21; and

The premises is the customer’s primary residence.

a. Rehabilitation Pilot Expanding and Becoming a Permanent Component of LIURP for

All UGI Companies

1. Evaluation as a pilot

UGI’s Rehabilitation Pilot currently is only available to UGI Gas customers. UGI

proposes to end the piloting phase of its Rehabilitation Program and make it a permanent

component of its LIURP and extend it to the other three UGI companies. The

Rehabilitation Program provides weatherization services to low-income housing that is

either in the construction or rehabilitation stage. The purpose of this pilot program was to

avoid future high energy use or arrearage problems in low-income dwellings. UGI Gas

reserved up to 10% of its annual LIURP budget for this program.

As directed by the Commission in its 2011-2013 USECP Order, UGI Gas

evaluated the Rehabilitation Pilot Program and tracked customer participation levels.

Tables 5 and 6 below show the key evaluation points of the Rehabilitation Pilot Projects:

20 A portion of LIURP participants, up to 20%, may have household incomes at 151%-200% of the FPIG, consistent with the Reporting Requirements.21 If a household has been previously weatherized, it will not be eligible for LIURP services until the payback period has expired. Proposed 2014-2017 Plan at 23. “Energy saving measures installed will be determined to have a simple payback of seven years with the exception of side wall insulation, attic insulation, space heating system replacement and water heating replacement which will have a simple payback of twelve years.” Proposed 2014-2017 Plan at 22.

21

Table 5

Customer Participation Levels in UGI Gas Rehabilitation Pilot

Company Number of Jobs CostUGI Gas 11 $46,158

Proposed 2014-2017 Plan at 25.

The cost indicated in the table above reflects material costs only. Installation labor was

provided by program volunteers. Proposed 2014-2107 Plan at 25. The average cost per

job was $4,196.18. This average cost is comparable with the $4,062.13 average job cost

from other NGDCs for LIURP jobs completed in 2012. 2012 Universal Service

Programs & Collections Performance Report at 33.

However, if labor costs had been included in calculating the average job cost for

the Rehabilitation Pilot, rather than offset by volunteer donations, the average job cost

would have been significantly higher. In order to truly compare the costs, UGI Gas

would need to provide an estimated savings figure from the labor.

Table 6

Energy Savings from UGI Gas Rehabilitation Pilot

A B C=B/A D E=C/D

Program Year

Number of Jobs

Completed

Estimated Annual

Natural Gas Usage

Reduction

Estimated Annual

Natural Gas Savings per

Job

Average Residential

Annual Natural Gas

Usage

Estimated Annual

Natural Gas Usage

Reduction2012 11 205 mcf 18.64 mcf 80.90 mcf 23%Proposed 2014-2017 Plan at 25 (internal citations omitted).

UGI Gas claims that the Rehabilitation Pilot Project resulted in energy savings of

approximately 23% from measures installed during the 2012 program year. Those

22

measures included ENERGY STAR rated high efficiency natural gas furnaces, hot water

heaters, upgraded insulation (attic, wall, floor), air sealing and energy efficient windows.

Proposed 2014-2017 Plan at 25. The energy efficient measures were installed either at

the time of construction or rehabilitation of low-income residential housing.

UGI Gas also contends that since the Rehabilitation Pilot produced higher savings

than the traditional UGI LIURP program, the results demonstrate that the savings

potential is greater at the time of new construction or rehabilitation, as opposed to

outright weatherizing existing houses.

UGI Gas does not indicate if all the jobs were performed on single family homes

or if any of the units were from multi-family premises. Further, there was no indication

from those results if the dwellings were owned or rented by qualifying low-income

customers. UGI states that it will collect all required LIURP information will be

collected for each dwelling in the Rehabilitation program. Proposed 2014-2017 Plan at

26. We agree that specific tracking of information regarding the Rehabilitation jobs is

necessary to evaluate all aspects of the program, and note that tracking for those jobs

should be separate from traditional LIURP job tracking.

While evaluating the results of the Rehabilitation Pilot Program, we note it may be

true that the potential for savings is greater at the time of new construction or

rehabilitation as compared to retrofitting an existing home, the Rehabilitation Pilot did

not take all relevant factors into account when determining the comparative cost-

effectiveness. Other NGDCs have produced energy savings in excess of 20% in their

traditional LIURP programs, and continue to do so while including labor expenses

according to historical data on file with the Commission.

Nevertheless, we conclude from our evaluation of the Rehabilitation Pilot Program

results that there are potential significant benefits provided to the low-income customer

23

receiving those weatherization services. This is the only LIURP weatherization program

that attempts to avoid future high usage and possible arrears by preemptively

implementing energy efficiency measures in a home.

2. Energy conservation education

Conservation education and behavior modification can play a key role in reducing

energy usage.22 UGI does not mention if its LIURP recipients also receive energy

conservation education as part of the Rehabilitation Pilot Program. This education could

be extremely beneficial in reducing usage and establishing good conservation habits and

practices before a customer becomes payment troubled. The educational approach may

have to be custom tailored to those situations, as the contractor who presents energy

conservation education to traditional LIURP customers has the established account

history from which to work and draw illustration.

Further, upon review of the 2013 APPRISE LIURP Evaluation, we note that the

education component of UGI’s LIURP program has been administered and reported

inconsistently by various contractors and has produced mixed results. 2013 APPRISE

LIURP Evaluation at 54-55. As outlined in Commission regulations and the LIURP

Codebook provided to NGDCs and EDCs by BCS for reference purposes, all companies

with LIURP programs are expected to report complete and accurate energy education-

related data, and we acknowledge that UGI has taken steps to ensure this practice is

followed in future reporting. 23

22 See, for example, the impacts of energy conservation education undertaken pursuant to Act 129, 66 Pa. C.S. § 2806.1, as evidenced by the use of home energy reporting programs in the large EDCs’s Act 120 portfolios. While Act 129 does not require that UGI Electric or the UGI NGDCs have Act 129 plans, the operation and impact of such conservation education efforts may be illustrative for UGI’s LIURP purposes. 23 Our review of recent LIURP results from all participating companies in the Commonwealth shows that UGI is not the only jurisdictional utility with LIURP administration, reporting, and results issues. More LIURP users are falling into the non-saver category. In order to understand the reasons for these increases, BCS is exploring current LIURP energy education programs and compiling best practices. These data will allow the Commission to develop strategies to combat/offset non-saver usage where possible. See, e.g., Duquesne USECP for 2014-2016, Docket No. M-2013-2350946 (March 6, 2014) at 39-40.

24

3. Eligibility for the Rehabilitation program

UGI states that as a permanent program and part of the 2014-2017 USECP, the

Rehabilitation Program jobs will have to meet the following eligibility criteria:

The housing that will receive the services must be low-income;

The house must have existing gas heat; and

The project must be coordinated with a Community Based Organization

(CBO).

In the 2014-2017 USECP, UGI does not provide the methodology by which it will

assess the low-income status of a particular project, but does limit the program to

residential rate housing units. UGI mentions that if the housing units are rental units,

only tenants with payment responsibilities would qualify. UGI Gas states it could also

provide funding for projects involving affordable housing programs like Low-Income

Housing Tax Credit (LIHTC) or HOME Investment Partnership Program (HOME). UGI

does not clarify if a new construction home, without previous gas heat, would still be

considered, or if only houses undergoing rehab would qualify. UGI does list some

potential CBOs for partnering: Neighbor Housing Services, Habitat for Humanity,

Housing Authorities and Community Development Offices. We encourage UGI to also

consider partnering with the EDCs and coordinating with their Act 129 programs, when a

common CBO is utilized.

4. Rehabilitation Funding

UGI reserves up to 10% of its current year LIURP budget for Rehabilitation

Project Funding and states that any budget amount not expended within that program

year will be returned to LIURP services funding.

25

Proposed Resolution: It is unclear if UGI Gas intends to expand the program to UGI

Electric because one of the eligibility criteria for the Rehabilitation Program is the

condition that the home have existing gas heat. We ask UGI to clarify this discrepancy in

the comments. We are inclined to allow UGI to continue and expand the Rehabilitation

Program to the other UGI companies, with the condition that program tracking is kept

separate from regular LIURP jobs and reporting. That way, future evaluations on cost-

effectiveness and energy savings can be made independently. We propose that the

budget be limited at a maximum of 10% of the LIURP budget proposed by each

company. Further, we suggest that UGI consider target marketing this niche program to

local builder associations, state and government agencies that operate and fund

revitalization programs and to the EDCs within its service territory to coordinate on Act

129 or LIURP jobs.

b. Conservation Pilot Program

UGI Gas proposes to discontinue its Conservation Pilot Program, which

contributes up to 5% of its LIURP funds toward energy conservation measures for

housing to low-income or transitional populations, such as half-way houses for drug and

other substance dependent individuals and shelters for abused women and children. The

Conservation Pilot Program was authorized as part of UGI’s 2011-2013 USECP. UGI

Gas reports it received minimal interest in the program and served only one recipient.

We acknowledge the noble intent of the Conservation Program, but note that non-

profit organizations that provide low-income housing services are usually classified as

small commercial accounts. These organizations will still have the opportunity to obtain

energy efficiency measures through the EDCs’ Act 129 programs.

26

It is unclear if UGI Gas reallocated any remaining funding for this pilot back into

the budget for traditional LIURP. According to UGI Gas’ reporting to BCS, in 2011 the

Conservation Pilot Program funded $50,000 to the Berks Women in Crisis Shelter. The

funds provided a new energy efficient heating system, insulation and additional energy

efficient measures at the property. In 2012, UGI Gas allocated an additional $25,000 to

the Berks Women in Crisis Shelter for energy efficiency measures. Neither the annual

LIURP reporting to BCS or the 2013 LIURP Evaluation conducted by APPRISE

provided any further details on this spending. In 2013, UGI Gas appears to have spent

$24,183.21 under the Conservation Pilot on the same organization.

Proposed Resolution: We propose to allow UGI to discontinue the Conservation Pilot

Program and reallocate any remaining funding back into the LIURP budget. Further, we

ask UGI Gas to provide additional details regarding the spent funds and an explanation of

why it funded the same organization for multiple years.

c. LIURP Eligibility

Like other LIURP programs, the Company has eligibility criteria that the low-

income customer must meet in order to qualify for weatherization services. According to

the 2013 APPRISE LIURP Evaluation, these are the usage thresholds, below which a

household will not be considered for LIURP:

o UGI Gas heating: 1,150 ccf

o UGI PNG heating: 1,300 ccf

o UGI CPG heating: 1,300 ccf

o UGI Electric non-heating: 6,000 kwh

o UGI Electric heating: 21,000 kWh

27

With the exception of the usage threshold for UGI Electric’s heating component,

the levels are comparable with the criteria required by other energy companies. UGI

Electric’s annual usage requirement of 21,000 kWh for heating jobs is the highest among

EDCs who participate in LIURP. However, since UGI Electric proposes to perform less

than 10 heating jobs in each of the years covered by this USECP, reducing that criterion

may not be necessary at this time. If UGI Electric is having difficulty qualifying LIURP

participants, it should consider lowering the threshold.

Another requirement for LIURP eligibility is that “the customer’s premises are

suitable for weatherization services”. 2014-2017 Proposed Plan at 23. UGI will

disqualify a home from receiving LIURP services if it has previously received

weatherization within the last seven years. We understand that UGI has this criteria

because program measures follow the 7 or 12 year payback period as outlined in the

LIURP regulations at § 58.11(a). However, there are times, such as when usage is

high or measures and/or technologies have advanced, where cost-effective savings can

be obtained prior to the payback period expiring. In these circumstances, we suggest

UGI take a more flexible approach in evaluating a customer’s eligibility, especially if

that customer has special needs, disabilities or is a senior.

Proposed Resolution: Since UGI Electric is not obligated to have a USECP, we do not

seek to impose any requirements beyond what the Company has proposed at this time.

We do propose that UGI should take a more flexible qualifying approach when assessing

a home that has had previous weatherization services. If usage levels or special

circumstances warrant, the company should consider allowing repeat LIURP

participation before the seven year stay out period expires.

28

d. Data Reporting

UGI states in the 2014-2017 USECP that it has developed a Customer Outreach

System (COS) to manage the LIURP and other low-income programs more efficiently.

Proposed 2014-2017 Plan at 24. UGI uses the COS to screen low-income customers for

eligible LIURP participants with high usage and/or arrears and to generate internal

reports and annual reports to the Commission to meet the LIURP reporting requirements.

The COS allows UGI staff and agency representatives to access selected customer

information, usage history and corresponding data and to input LIURP job details.

UGI has previously had some inaccurate or incomplete data in its LIURP reporting

to BCS. The 2013 APPRISE LIURP Evaluation reviewed the COS and LIURP program

administration, and found several areas where improvements could be made to the system

that would greatly increase both efficiency and available information. UGI has been

addressing many of the programming shortfalls in COS identified in the evaluation,

according to a recent status update provided to BCS.

For example, UGI’s COS did not have the capacity to code and track health and

safety measures. There was no method for tabulating the frequency of these measures,

although they are commonly installed on the majority of jobs in conjunction with typical

weatherization measures. In order to distinguish and monitor costs for health and safety

measures such as Carbon Monoxide (CO) detectors, smoke alarms, chimney cleaning and

gas dryer venting, UGI had to modify the COS, or track the measures and costs outside of

the system and report them separately. Increasingly, local code ordinances require

contractors to install these types of measures even though they do not provide any direct

weatherization or energy efficiency benefits.

UGI currently has a health and safety allowance of up to $1,500 per job. It is

becoming necessary to track these cost categories separately so BCS can remove them

29

when performing certain analysis on the LIURP data, similar to the methodology applied

to the LIURP administrative costs. We recognize that health and safety measures are

necessary and should be installed whenever needed and will continue to monitor the

impact on LIURP budgets.

Proposed Resolution: We ask UGI to provide in its comments the summary and status

updates from the 2013 APPRISE LIURP Evaluation regarding the COS so all parties may

have an opportunity to review the changes and progress and provide comments.

e. Quality Control and Training

According to the status update provided to BCS, UGI has responded to some of

the recommendations made in the 2013 APPRISE LIURP Evaluation, and has initiated a

quality control process. UGI is working with National Sustainable Structures Centers

(NSSC) to obtain further evaluations on contractor work quality and performance. While

the 2013 APPRISE LIURP Evaluation reviewed UGI’s overall LIURP program, the

NSSC project will delve into the internal processes and logistics of each agency in more

detail. During the project, which began in May 2013 and is expected to last through mid-

2015, NSSC will evaluate each agency that provides weatherization services for UGI and

review all of the internal processes associated with LIURP job completion, including

customer recruitment strategies, contractor shadowing and inspections, and data

reporting. NSSC will provide UGI with a final evaluation detailing their finding and

recommendations, which UGI will incorporate into a best practices policy for the

agencies.

One of the key areas that UGI and NSSC are focusing on is work quality. UGI

staff had recently attended a number of industry events in order to increase their

knowledge of weatherization practices. According to the 2013 APPRISE LIURP

Evaluation, “UGI does not provide specific technical procedures for LIURP and instead

30

instructs agencies to follow the PA WAP guidelines.”24 2013 APPRISE LIURP

Evaluation at 53. All of the agencies that provide LIURP services for UGI also provide

WAP weatherization services.

The LIURP regulations do not specify standards for work quality, and the WAP

program will be implementing new nationally developed and recognized Standard Work

Specifications (SWS) that go into effect July 1, 2015. Those new national quality control

standards provide a consistent platform for both weatherization programs to potentially

follow. In our opinion, this is an excellent opportunity to more closely align the two

weatherization programs and maximize the coordination and cost-effectiveness of both,

while maintaining high work quality standards. We are encouraged that UGI has

recognized and is striving for this level of work quality.

The 2013 APPRISE LIURP Evaluation also made recommendations regarding

gaps in contractor training. In interviews with the agencies, staff felt additional training

was needed in the areas of zonal pressure testing, combustion safety testing and energy

education. 2013 APPRISE LIURP Evaluation at 46.

The Commission supports increased coordination between the weatherization

programs and is exploring ways to ensure that the contractors receive the training

necessary to maintain the LIURP work quality levels consistent with the new SWS that

will be utilized in WAP, and to also keep up with technological advances as the field of

weatherization evolves. In addition, UGI is working with NSSC to ensure that all

contractors will be trained to consistently report and enter data back to UGI in the COS,

without grouping measures inappropriately or neglecting to include sufficient detail.

24 Work quality guidelines for the federal Department of Energy’s Weatherization Assistance Program (WAP), run by the Pennsylvania Department of Community and Economic Development (DCED) in the Commonwealth.

31

UGI provided BCS with a recent summary and/or status update regarding the 2013

APPRISE LIURP Evaluation recommendations relevant to the NSSC evaluation and

contractor work quality issues.

Proposed Resolution: We ask UGI to provide in its comments the summary and status

updates from the 2013 APPRISE LIURP Evaluation regarding the NSSC evaluation and

contractor work quality issues so all parties may have an opportunity to review the

changes and progress and provide comments. To the extent that additional training or

certifications may be required, UGI should also provide details on funding and budget

allocations for such training and certifications.

3. CARES Program

The CARES program assists customers who are experiencing temporary hardships

that result in an inability to pay their utility bills. Company representatives make

referrals to social service agencies and provide information regarding available programs.

Any UGI customer who has a delinquent balance or is experiencing a temporary hardship

that could lead to a loss of utility service is eligible for CARES.

Proposed Resolution: We are not proposing any changes to UGI’s CARES Program at

this time.

4. Operation Share Energy Fund

Operation Share is UGI’s hardship fund. It temporarily assists fixed or low

income customers through a crisis by paying their energy bill. CBOs are contracted by

UGI to determine the amount of the grant to be issued for each customer. Customers

32

enrolled in CAP are not eligible for Operation Share grants. To be eligible for an

Operation Share grant, customers must: 25

Have an active residential account with a UGI company;

Have not received an Operation Share grant within the last 12 months;

Have an outstanding utility bill balance;

Have a household income at or below 200% of the FPIG;

Provide information to demonstrate an inability to pay (including income and

expenses of all household members); and

Have contacted the company’s credit department to discuss options.

Every two dollars contributed by employees, customers, or outside sources are

matched by one dollar in energy vouchers from UGI. The funds go to the participating

CBOs to be disbursed to the UGI company of each qualifying customer. The number of

potential participants depends on the level of donations.

Table 7 identifies the Operation Share matching fund amounts for each UGI

company:

25 UGI companies or the CBOs may waive a requirement in extraordinary circumstances. Proposed 2014-2017 at 9.

33

Table 7

2014-2017 Matching Fund Limits

Company Matching FundsUGI Gas $38,500UGI PNG $22,000UGI CPG $12,000UGI Electric $10,000

The maximum amount of an Operation Share grant for all UGI companies is $400 per

household. However, UGI PNG and UGI CPG agencies may have some additional funds

from the Tennessee Gas Pipeline Settlement Proceeds.26 Any remaining settlement funds

will be used to provide Operation Share grants up to $800.

a. Operation Share Administrative Costs

Table 8 identifies the Operation Share administrative costs for each UGI company:

Table 8

Operation Share Administrative Costs

Company 2014 2015 2016 2017UGI Gas $1,400 $1,930 $1,930 $1,930UGI PNG $1,130 $1,100 $1,100 $1,100UGI CPG $1250 $600 $600 $600UGI Electric $350 $500 $500 $500

The Proposed Plan does not explain why Operation Share administrative costs for

UGI companies increase or decrease significantly from 2014 to 2015.

26 See Joint Petition of UGI-Gas UGI PNG, and UGI CPG For Expedited Approval to Contribute a Portion of Tennessee Gas Pipeline Company Settlement Proceeds to Operation Share, Docket No. P-2009-2149107 (February 1, 2010). The Order approving the Tennessee Gas Pipeline settlement directed that UGI Gas, PNG and CPG expend the residential portion of the settlement refund through the UGI Operation Share Fund.

34

Proposed Resolution: In its comments to this order, UGI should explain the increases or

decreases in Operation Share administrative costs for its companies from 2014 to 2015.

b. Requiring Proof of Household Expenses

To qualify for an Operation Share grant, UGI customers must verify their inability

to pay by providing “evidence of income and expenses of all members of the household.”

Proposed 2014-2017 Plan at 9. Applicants must also authorize the CBO, verbally or in

writing, to obtain their account information from the UGI company. Proposed 2014-2017

Plan at 9.

Considering that lowest income customers are the most in need of financial

assistance, any delay in the approval process could have serious financial consequences,

including loss of utility service. We are not aware of any other NGDC or EDC that

requires customers to provide evidence of household member expenses as a precondition

to qualify for a hardship fund grant.

The Commission supports requesting proof of household income and utility

account status to determine if there is a need for a hardship fund grant to help a customer

through a financial crisis. However, we question UGI’s policy of requiring customers to

also provide documentation of expenses for all household members. We are concerned

that requiring customers to provide verification of expenses incurred by each member of

the household may unreasonably delay the approval of Operation Share grants.

Proposed Resolution: In its comments to this order, UGI should explain what household

expenses customers must verify to qualify for an Operation Share grant. UGI should also

discuss whether it would consider eliminating this requirement or offering a less

burdensome alternative, such as allowing the customer to provide only a written

statement describing expenses for all household members.

35

D. Eligibility Criteria

The four components of UGI’s Proposed 2014-2017 Plan have slightly different

eligibility criteria. Table 9 below shows the eligibility criteria for each universal service

component.

Table 9

Eligibility CriteriaProgram Income Criteria Other Criteria

CAP 150% FPIG or less

Active residential heating or non-heating customer.

If previously in CAP, must have cured any prior default.

If left CAP voluntarily, must stay out of CAP for 12 months (exceptions made for demonstrated hardship).

LIURP

150% FPIG or less 20% of participants

may have income up to 200%

Residential customer, above average consumption, continuous service for 12 months and living in the primary residence.

Residence must be suitable for weatherization.

CARES Negative ability to pay

Temporary hardship; delinquent balance; or special need.

Operation Share 200% FPIG or less

Active residential customer faced with a hardship; outstanding balance; inability to pay energy bills.

Must not have received an Operation Share grant in the past 12 months.

Customers with delinquent balances must first contact the UGI company’s Credit Department.

Must not be enrolled in CAP

Proposed Resolution: We tentatively find that the eligibility requirements of UGI’s

Proposed 2014-2017 Plan continue to comply with the Commission’s CAP Policy

Statement.

36

E. Projected Needs Assessment

In accordance with 52 Pa. Code § 62.4(b)(3), UGI Gas and UGI PNG submitted a

needs assessment as those two UGI Companies have more than 100,000 residential

customers. The needs assessment is based on 2012 Census data.

Table 10

Needs Assessment

Total Residential Customers

Households* below150% FPIG

Percent Low Income Households

Proposed CAP Enrollment

Number Needing LIURP /Cost to Serve

UGI Gas 326,058 84,809 26% 10,000 4,158/$14.9MUGI PNG 147,790 48,409 33% 7,500 5,365/$19.6M

UGI Electric and UGI CPG are not required to submit a needs assessment.

We compared the LIURP Needs Assessment figures submitted in UGI’s Proposed

2014-2017 Plan with that of the approved Plan for 2011-2013. The numbers of

customers needing LIURP in the Proposed 2014-2017 Plan are significantly lower than

the figures stated in the 2011-2013 Plan, even though the numbers of residential

customers and those below the 150% threshold are much higher for 2014-2017. 2011-

2013 USECP Plan at B-1. At BCS’s request, UGI revised its Needs Assessment using

2012 Census data, rather than the 2008 Census data, but the numbers of those in need of

LIURP and the cost to serve that number remained unchanged. We conclude that the

calculation of the number of customers needing LIURP shown above cannot be accurate.

Proposed Resolution: In its comments, UGI should provide updated calculations and the

methodology used to arrive at the results, for both the number needing LIURP and the

cost to serve them, for 2014-2017 for both UGI Gas and UGI PNG.

37

F. Projected Enrollment Levels

Table 11 shows the Company’s enrollment projections for each program

component for the calendar years covered by the proposed Plan:

Table 11

Projected Universal Service Enrollments by Company by Year

2014 2015 2016 2017UGI Gas

CAP 7,500 8,500 9,250 10,000LIURP 94 93 93 93CARES 60 60 60 60Operation Share 140 193 193 193

UGI PNGCAP 6,000 6,500 7,000 7,500LIURP 132 121 121 121CARES 30 30 30 30Operation Share 113 110 110 110

UGI CPGCAP 2,750 4,000 5,000 6,000LIURP 71 71 71 71CARES 15 15 15 15Operation Share 125 60 60 60

UGI ElectricCAP 2,250 2,335 2,420 2,500LIURP 42 30 30 30CARES 15 15 15 15Operation Share 35 50 50 50

Proposed Resolution: We defer our concerns regarding enrollment numbers to our

discussion below regarding budgets.

38

G. Program Budgets

Table 12 below shows the proposed budget levels for UGI Companies’ universal

service components for 2014-2017 and their respective proposed universal service

program spending.

39

Table 12

Projected Universal Service Budgets by Company

2014 2015 2016 2017

UGI GasCAP $4,905,000 $5,559,000 $6,049,500 $6,540,000LIURP $660,224 $650,000 $650,000 $650,000CARES* $60,000 $60,000 $60,000 $60,000Operation Share* $29,400 $40,430 $40,430 $40,430Total $5,565,224 $6,209,000 $6,699,500 $7,190,000# of non-CAP Residential Customers 318,865 318,865 318,865 318,865Average Spending/Customer/Month $1.45 $1.62 $1.75 $1.88

UGI PNGCAP $4,554,000 $4,933,500 $5,313,000 $5,692,000LIURP $921,605 $850,000 $850,000 $850,000CARES* $25,000 $25,000 $25,000 $25,000Operation Share** $23,630 $23,100 $23,100 $23,100Total $5,476,735 $5,784,600 $6,164,100 $6,543,100# of non-CAP Residential Customers 142,034 142,034 142,034 142,034Average Spending/Customer/Month $3.21 $3.39 $3.62 $3.84

UGI CPGCAP $1,751,750 $2,548,000 $3,185,000 $3,822,000LIURP $500,000 $500,000 $500,000 $500,000CARES* $18,000 $18,000 $18,000 $18,000Operation Share** $26,250 $12,600 $12,600 $12,600Total $2,253,000 $3,048,600 $3,685,600 $4,322,600# of non-CAP Residential Customers 66,584 66,584 66,584 66,584Average Spending/Customer/Month $2.82 $3.82 $4.61 $5.41

UGI ElectricCAP $1,671,750 $1,734,905 $1,798,060 $1,857,500LIURP $147,403 $124,750 $124,750 $124,750CARES* $15,000 $15,000 $15,000 $15,000Operation Share* $7,350 $10,350 $10,350 $10,350Total $1,819,153 $1,859,655 $1,922,810 $1,982,250# of non-CAP Residential Customers 52,107 52,107 52,107 52,107Average Spending/Customer/Month $2.91 $2.97 $3.08 $3.17*These funds are not recovered in UGI’s base rates or its universal service fund surcharge. Therefore, they are not included in the “Total” rows above or the “Average Spending/Customer/Month” calculations.**Only Operation Share’s administrative costs are recovered for these companies.

40

a. LIURP Enrollment and Budget Projections for UGI Gas

The UGI Gas proposed LIURP budget noted above in Table 12 for 2014-2017,

would fund the program at the lowest levels since 1991, according to historical LIURP

data reviewed by BCS. We note in particular that:

Funding for LIURP in UGI Gas’ service territory is based on the Commission’s Order adopted August 17, 2006, in Docket Nos. A-120011F2000, A-125146F5000, and A-125146. Under the Commission’s direction, UGI Gas will increase LIURP spending to 0.2 percent of jurisdictional revenues for its gas division and will be permitted to recover 50% of the incremental amounts above $600,000 in its LISHP Rider until its next base rate case. Funding of the LIURP may be addressed and modified in UGI Gas’ next base rate proceeding.

Proposed 2014-2017 Plan at A-4.

However, the LIURP regulations at § 58.4(a)(c)(1) allow for adjustments to

program funding under specific circumstances.27 Based on BCS calculations and our

review of the LIURP Needs Assessment, we question whether the proposed LIURP

27 Section 58.4, relating to program funding, provides in pertinent part that:

(a) General guidelines for gas utilities. Annual funding for a covered natural gas utility’s usage reduction program shall be at least 0.2% of a covered utility’s jurisdictional revenues. Covered gas utilities shall submit annual program budgets to the Commission. A covered gas utility will continue to fund its usage reduction program at this level until the Commission acts upon a petition from the utility for a different funding level, or until the Commission reviews the need for program services and revises the funding level through a Commission order that addresses the recovery of program costs in utility rates.

* * *

(c) Guidelines for revising program funding. A revision to a covered utility’s program funding level is to be computed based upon factors listed in this section. These factors [include but are not limited to] the following:

(1) The number of eligible customers that could be provided cost-effective usage reduction services. The calculation shall take into consideration the number of customer dwellings that have already received, or are not otherwise in need of, usage reduction services.

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budget for UGI Gas is sufficient. We have discussed our concerns with the accuracy of

the LIURP Needs Assessment in the relevant section above and expect UGI to submit

revised numbers for those needing LIURP services for UGI Gas and UGI PNG. UGI

should address why it is not seeking a budget increase for 2014-2017 now, rather than

delaying any discussion of budget adjustments to when UGI Gas again files for a base

rate increase. We request comments on this matter.

UGI PNG has a proposed LIURP budget of $850,000 for each year of their

Proposed 2014-2017 Plan, as dictated in the UGI PNG Rate Settlement, Docket No.

R-2008-2079660. Proposed 2014-2017 Plan at A-4. UGI PNG reports the Number of

Payment-Troubled Customers as 14,348 in the Proposed 2014-2017 Plan. UGI Gas

reports 23,755 for the same category. Proposed 2014-2017 Plan at B-1. We do not

dispute these figures and used them to estimate a revised budget. For comparison

purposes, we divided the $850,000 budget for UGI PNG by the Number of Payment-

Troubled Customers (14,348). We took the resulting dollar figure of $59.24 per

Payment-Troubled Customer and applied the same calculation methodology to UGI Gas’

Number of Payment-Troubled Customers (23,755) to estimate a minimum yearly LIURP

budget of $1,407,246 for 2014-2017.

Proposed Resolution: In its comments, UGI Gas is directed to submit and explain the

revised LIURP Budget and corresponding enrollment figures for the 2014-2017 period

covered by this Proposed Plan. Concerns about the revised budget and enrollment

projections for UGI Gas may be addressed in the reply comments.

b. Enrollment and Budget Changes From 2014 to 2015

The Commission also questions why enrollment and budget levels for LIURP and

Operation Share increase or decrease significantly from 2014 to 2015. Specifically:

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LIURP jobs for UGI PNG decrease from 132 in 2014 to 121 in 2015, with a

corresponding budget decrease of $71,605 between years;

LIURP jobs for UGI Electric decrease from 42 jobs in 2014 to 30 jobs in 2015,

with a corresponding budget decrease of $22,653;

Operation Share grants for UGI Gas increase from 140 in 2014 to 193 in 2015,

with a corresponding budget increase of $11,030.

Operation Share grants for UGI CPG decrease from 125 in 2014 to 60 in 2015,

with a corresponding budget decrease of $13,650.

Operation Share grants for UGI Electric increase from 35 in 2014 to 50 in 2015,

with a corresponding budget increase of $3,000.

Proposed Resolution: In its comments to this order, UGI is directed to explain why

LIURP and Operation Share projected enrollments and budget change significantly from

2014 to 2015 for some companies.

c. Operation Share Enrollment and Budget Figures

According to the Proposed 2014-2017 Plan, for every two dollars customers,

employees or outside sources contribute to Operation Share, UGI will issue an additional

one dollar in energy vouchers, up to the committed matching funds contribution.

Proposed Plan at A-1, A-6, A-9, & A-12. Our understanding is that voluntary

contributions make up two-thirds of Operation Share vouchers and that UGI makes up

the remaining one-third. As a result, we would expect that if a UGI company expects to

spend $10,000 on matching funds for vouchers, then the total voucher budget would be

$30,000.

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We are not seeing this ratio in UGI’s Operation Share voucher budgets in its

Proposed 2014-2017 Plan. For example, UGI PNG reports it “will contribute one dollar

for every two dollars donated by a customer, employee or outside source, up to $22,000,

its total matching funds contribution.” Proposed 2014-2017 Plan at A-6. Based on this

description, we would assume that UGI PNG will contribute $22,000 to match $44,000 in

voluntary contributions, resulting in a voucher budget of $66,000. However, the

Operation Share budget on pages A-6 and A-7 of the Plan shows UGI PNG’s voucher

budget is $44,000 annually from 2015 through 2017. This suggests a 50/50 match with

voluntary contributions, not a one-third match. The voucher budgets for the other

companies similarly suggest a 50/50 match.

Through informal communications with UGI, BCS questioned the Operation

Share funding ratio. UGI provided the following response:

UGI’s Operation Share program is comprised of two funding sources, please see details below:

Voucher Funds – Include donations made by the Company, which is both the Initial Energy Funds and the *Matching funds. These funds are retained by UGI and vouchers are written towards accounts when funds are approved by the CBO.

* While UGI has an established matching component for its program; UGI is committed to donating the initial contribution and matching funds in its entirety. This donation will be allocated to the program regardless of the CASH donations received [from] our customers and employees.

Cash Funds – Includes CASH Donations received [from] customers and UGI employees. These funds are retained by the CBO in an Operation Share bank account. When grants are approved, the funds are sent to UGI to be applied directly to the customer account.

In the plan submitted on 8/1/2014, the projected participation levels and projected budgets outlined in the Appendix for the Operation Share

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programs are reflective of only the Company Voucher Commitments. The participation levels and budgets do not reflect additional donations and funding to the program that will be received in the form of CASH donations from customers and employees.

Below are updated charts that better reflect all program funds:

[Table 13]

UGI [Gas]

Year Projected Participation

Levels

Initial Contribution

(voucher)

MatchingFunds

(voucher)

Projected CASH

donations

Total Donations

2014 220 $40,000 $16,000 $32,000 $88,0002015 380 $38,000 $38,000 $76,000 $152,0002016 380 $38,000 $38,000 $76,000 $152,0002017 380 $38,000 $38,000 $76,000 $152,000

[Table 14]

[UGI] PNG

Year Projected Participation

Levels

Initial Contribution

(voucher)

Matching

Funds(voucher

)

Projected CASH

donations

Total Donations

2014 212 $25,000 $20,000 $40,000 $85,0002015 220 $22,000 $22,000 $44,000 $88,0002016 220 $22,000 $22,000 $44,000 $88,0002017 220 $22,000 $22,000 $44,000 $88,000

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[Table 15]

[UGI] CPG

Year Projected Participation

Levels

Initial Contribution

(voucher)

Matching

Funds(voucher

)

Projected CASH

donations

Total Donations

2014 137 $50,000 N/A $55,0002015 120 $12,000 $12,000 $24,000 $48,0002016 120 $12,000 $12,000 $24,000 $48,0002017 120 $12,000 $12,000 $24,000 $48,000

[Table 16]

[UGI] Electric

Year Projected Participation

Levels

Initial Contribution

(voucher)

MatchingFunds

(voucher)

Projected CASH

donations

Total Donations

2014 55 $10,000 $4,000 $8,000 $22,0002015 220 $22,000 $22,000 $44,000 $88,0002016 220 $22,000 $22,000 $44,000 $88,0002017 220 $22,000 $22,000 $22,000 $88,000

We note that the updated annual enrollment and budget projections for Operation

Share through 2017 that are significantly higher than the projections provided in its

Proposed 2014-2017 Plan. In addition, UGI does not explain why UGI CPG anticipates

no voluntary donations for its Operation Share program in 2014 or how that program will

have funds beyond the initial contribution.

Proposed Resolution: In its comments to this Order, UGI should explain why its

enrollment and budget projections for Operation Share have increased from the estimates

provided in its Proposed 2014-2017 Plan. It should also explain why UGI CPG

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anticipates no donations to its Operation Share program in 2014 and where the difference

between the initial contribution and total donations comes from.

H. Use of Community-Based Organizations (CBOs)

The Competition Acts direct the Commission to encourage utility companies to

use community-based organizations to assist in the operation of universal service

programs. 66 Pa.C.S. §§ 2203(8) and 2804(9). In accordance with these provisions, UGI

Companies use the CBOs listed below for CAP administration in their respective service

territories:

UGI Gas

Commission on Economic Opportunity –Hazleton Easton Area Neighborhood Center Lancaster CAP Lebanon County Christian Ministries Neighborhood Housing Services of Greater Berks, Inc. The Salvation Army –Allentown The Salvation Army—Harrisburg The Salvation Army—Reading

UGI PNG Columbia County Human Services Commission on Economic Opportunity Scranton Lackawanna Human Development Agency/SLHDA Social Service Assistance Program - S.T.E.P., Inc. Union-Snyder Community Action Agency TREHAB, Inc.

UGI CPG Central PA Community Action Program, Inc. Central Susquehanna Opportunities, Inc. Commission on Economic Opportunity Northern Tier Community Action Schuylkill County Community Action Social Service Assistance Program - S.T.E.P., Inc.

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The Salvation Army –East Stroudsburg The Salvation Army Service Center—Hamburg TREHAB, Inc. Union Snyder Community Action Agency Warren/Forest Economic Opportunity Council

UGI Electric Commission on Economic Opportunity

Proposed Resolution: We are not proposing any adjustments to UGI’s use of CBOs.

I. Organizational Structure of Universal Service Staff

The organizational structure for the UGI Companies’ Universal Services Programs

is as follows:

1 Full time Manager, Customer Accounting & Outreach Supervisor

1 Full time Senior Customer Outreach Representative

8 Full and one part time Customer Outreach Representatives

1 Full time Data Analyst (Universal Service Reporting)

Proposed Resolution: We are not proposing any adjustments to staffing. When combined

with the use of CBOs, we tentatively find the UGI Companies’ staffing levels to be

acceptable.

J. Integration of Universal Service Programs

To integrate universal service operations, the UGI Companies and contractors

screen, enroll and refer customers to any of the four universal service programs, as well

as to LIHEAP and state weatherization programs. The UGI Companies use a Customer

Outreach System to communicate and refer eligible customers.

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Proposed Resolution: We are not proposing any adjustments to UGI’s integration of

universal service programs.

V. Conclusion

The Commission tentatively finds that UGI’s Proposed 2014-2017 Plan, in large

measure, appears to comply with the universal service requirements of the Gas

Competition Act at 66 Pa.C.S. §§ 2203(7), 2202, and 2203(8), the Reporting

Requirements at 52 Pa. Code § 62.4, the LIURP regulations at 52 Pa. Code §§ 58.1-

58.18, and the CAP Policy Statement at 52 Pa. Code §§ 69.261-69.267. Further, while

there is no obligation on UGI CPG or UGI Electric to file USECPs, they have joined in

the UGI USECP filing. Their voluntary participation in the UGI USECP also appears to

comply, in large measure, with the universal service requirements of the Gas Competition

Act at 66 Pa.C.S. §§ 2203(7), 2202, and 2203(8), the Electric Competition Act at §§ 2801-

2812, the Reporting Requirements at 52 Pa. Code §§ 54.74 and 62.4, the LIURP

regulations at 52 Pa. Code §§ 58.1-58.18, and the CAP Policy Statement at 52 Pa. Code

§§ 69.261-69.267.

The Commission’s tentative partial approval of UGI’s Proposed 2014-2017 Plan

does not limit the Commission’s authority to order future changes to the Plan based on

evaluation findings, universal service data, rate-making considerations, or other relevant

factors. This Tentative Order sets forth the aspects that UGI will need to address prior to

our approval of the proposed Plan.

In particular, UGI is directed to address the following points consistent with the

discussion and directions herein:

1. Removing limits to CAP enrollment.

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2. Updating tariff language to reflect DPW’s current policy.

3. Clarify UGI’s arrearage forgiveness policy.

4. Clarify whether non-LIHEAP recipients are allowed to remain in the program and

recertify.

5. Address whether additional measures could be implemented to remind customers

to recertify for CAP before and after the recertification deadline.

6. Explain the company’s standard policy and procedure when a CAP applicant or

participant reports zero income and ensure that all of its companies eliminate the

requirement that CAP customers who report zero income must provide a notarized

statement.

7. Explain if the elimination of CAP credits will increase UGI’s annual CAP budgets

and whether this increase is reflected in the projected CAP budgets listed in its

2014-2017 Proposed Plan.

8. Continue the Rehabilitation Program as part of its regular LIURP program but to

track and report data from the Rehabilitation Program separately from the LIURP

data.

9. Clarify if the Rehabilitation Pilot will be extended to UGI Electric.

10. Discontinue the Conservation Pilot Program and reallocate any remaining funding

back into the LIURP budget.

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11. Provide details and an explanation regarding why previous Conservation Pilot

funds were spent on a single organization.

12. Provide in its comments the summary and/or status updates from the APPRISE

LIURP Evaluation regarding the COS.

13. Provide in its comments the summary and/or status updates from the APPRISE

LIURP Evaluation recommendations.

14. Explain increases or decreases in Operation Share administrative costs for UGI

Companies from 2014 to 2015.

15. Explain what household expenses customers must verify to qualify for an

Operation Share grant and discuss whether UGI would consider eliminating or

modifying this eligibility requirement.

16. Provide the methodology used to calculate the LIURP Needs Assessment for UGI

Gas and UGI PNG, and any revised LIURP Needs Assessment figures.

17. Submit the revised LIURP Budget and corresponding enrollment figures for UGI

Gas for the 2014-2017 period covered by this Proposed Plan.

18. Explain why LIURP and Operation Share projected enrollments and budget

change significantly from 2014 to 2015 for some UGI companies.

19. Explain why its enrollment and budget projections for Operation Share have

increased from the estimates provided in its Proposed 2014-2017 Plan and explain

the UGI CPG projections for 2014.

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Comments are due twenty (20) days after entry of this order, and reply comments

are due fifteen (15) days thereafter. If the comments and reply comments raise relevant

material factual issues, this matter may be referred, in whole or in part, to the OALJ for

hearing and decision; THEREFORE,

IT IS ORDERED:

1. That the revised Universal Service and Energy Conservation Plan for 2014-

2017 as filed by UGI Utilities, Inc. – Gas Division, UGI Utilities, Inc. – Electric

Division, UGI Penn Natural Gas, Inc., and UGI Central Penn Gas, Inc., on August 1,

2014 is tentatively partially approved as consistent with Title 66 of the Pennsylvania

Consolidated Statutes, Title 52 of the Pennsylvania Code, and Commission practice.

2. That a copy of this Tentative Order be served on UGI Utilities, Inc. - Gas

Division, UGI Utilities, Inc. - Electric Division, UGI Penn Natural Gas, Inc., and UGI

Central Penn Gas, Inc., the Office of the Consumer Advocate, the Office of Small

Business Advocate , the Bureau of Investigation and Enforcement, the Public Utility Law

Project, and Community Legal Services. That this Tentative Order also be served on the

active parties to the following dockets:

UGI USECP 2011-2013, Docket No. M-2010-2186052;

Petition of UGI Utilities, Inc. – Gas Division to Expand Participation in UGI’s

Low Income Self-Help Program, Docket No. P-2008-2066708;

Pa. PUC, et al. v. UGI Penn Natural Gas, Inc., Docket No. R-2008-2079660;

Pa. PUC, et al. v. UGI Central Penn Gas, Inc., R-2008-2079675; and

Petition of UGI Utilities, Inc. – Electric Division to Expand Participation in

UGI-ED’s CAP Increase the Maximum Allowed Discounts, and Implement a

Funding Mechanism to Recover Certain Associated Costs, Docket No.

P-2008-2066579.

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3. That comments to this Tentative Order shall be filed within 20 days of the entry

of this Order and that reply comments shall be filed within 15 days thereafter.

4. That one original signed copy of comments and reply comments shall be filed

with the Commission’s Secretary at: Pennsylvania Public Utility Commission P.O.

Box 3265, Harrisburg, PA 17105-3265. Alternatively, comments and reply comments

may be filed electronically through the Commission’s e-filing system, in which case no

paper copy needs to be filed with the Secretary provided that the comments are less than

250 pages.

5. That an electronic copy, in WORD® or WORD®-compatible format, of all

filed submissions, comments, and reply comments be provided to Joseph Magee, Bureau

of Consumer Services, jmagee@pa.gov, and to Louise Fink Smith, Law Bureau,

finksmith@pa.gov.

9. That the contact person for this Tentative Order is Joseph Magee, Bureau of

Consumer Services, 717-772-1204, jmagee@pa.gov.

BY THE COMMISSION,

Rosemary ChiavettaSecretary

(SEAL)

ORDER ADOPTED: October 2, 2014

ORDER ENTERED: October 2, 2014

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