D.C. Court Reviews DSM Rate Treatment

Fortnightly Magazine - September 1 1995
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The District of Columbia Court of Appeals has upheld parts of a decision by the District of Columbia Public Service Commission (PSC) disallowing 25 percent of actual and projected

demand-side management (DSM) costs claimed by Potomac Electric Power Co. in a recent rate case. While agreeing that Potomac had failed to justify 100-percent recovery of its DSM costs, the court remanded the case to the PSC for a better explanation of why 25 percent represents an appropriate amount for the disallowance. The court supported the PSC's finding that the utility had failed to show 1) why actual costs for some programs were greater than projected costs, and 2) why the level of total expenditures, as opposed to some lesser amount, was necessary to implement the DSM programs. Potomac Electric Power Co. v. District of Columbia Pub. Service Commission, No. 94-AA-799, June 19, 1995 (D.C.Ct.App.).


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