IV. Discussion We note that any issue that we do not specifically address has been duly considered and will be denied without further discussion. It is well settled that the Commission is not required to consider, expressly or at length, each contention or argument raised by the parties. Consolidated Rail Corporation v. Pa. PUC, 625 A.2d 741 (Pa. Cmwlth. 1993); see also, generally, University of Pennsylvania v. Pa. PUC, 485 A.2d 1217 (Pa. Cmwlth. 1984). A. Legal Standards As the proponent of a rule or order, the Company has the burden of proof in this proceeding in accordance with Section 332(a) of the Public Utility Code (Code), 66 Pa. C.S. § 332(a). Courts have held that “[a] litigant’s burden of proof before administrative tribunals as well as before most civil proceedings is satisfied by establishing a preponderance of evidence which is substantial and legally credible.” Samuel J. Lansberry, Inc. v. Pa. PUC, 578 A.2d 600 (Pa. Cmwlth. 1990), alloc. denied, 529 Pa. 654, 602 A.2d 863 (1992). That is, the Company’s evidence must be more convincing, by even the smallest amount, than that presented by the other Parties. SeLing Hosiery, Inc. v. Margulies, 364 Pa. 45, 70 A.2d 854 (1950). Additionally, this Commission’s decision must be supported by substantial evidence in the record. More is required than a mere trace of evidence or a suspicion of the existence of a fact sought to be established. Norfolk & Western Ry. Co. v. Pa. PUC, 489 Pa. 109, 413 A.2d 1037 (1980). B. Duquesne’s Petition In its Petition to modify its SMP, Duquesne proposed to install an ADMS to achieve enhanced communication, outage restoration and voltage monitoring
capabilities, Bill Ready costs should be recovered through the SMC. According to Duquesne, the OCA does not offer any basis to differentiate Bill Ready from other smart meter functionalities for purposes of recovery through the SMC. Duquesne R. Exc. at Next, Duquesne states that Bill Ready capability has the potential to benefit all customers contrary to the OCA’s assertions. Duquesne notes that Bill Ready will allow suppliers to offer competitive rates that may save customers money as it facilitates TOU rates which may encourage customers to shop and to reduce consumption. Duquesne opines that these customer benefits provide further support for recovering Bill Ready costs through the SMC. Duquesne further states that the OCA’s argument that customers receive no benefit from Bill Ready is without merit because Bill Ready provides customers with the choice to avail themselves of TOU rate offerings at any time. Duquesne opines that whether customers actually decide to shop or elect TOU rates is irrelevant because facilitating shopping provides alternatives to customers. Duquesne asserts that by directing EDCs to include Bill Ready functionalities in their smart meter plans, the Commission clearly viewed the customer benefits of Bill Ready as justifying the associated cost. Duquesne R. Exc. at 4-5. Duquesne further maintains that there is no reasonable mechanism in place to recover Bill Ready costs from EGSs. Duquesne explains that there are several obstacles to recovering these costs from EGSs as this would be a complex process. Duquesne asserts that EGSs enter and exit the market creating uncertainty for recovery and that some EGSs may not want Bill Ready functionality for product offerings, and therefore, would not be willing to pay for Bill Ready costs. Duquesne avers that for the first time in its Exceptions, the OCA introduces a proposal for recovering Bill Ready costs by incorporating them into the Technical Support and Assistance Charge in the Company’s Supplier Tariff. Duquesne requests that the OCA’s cursory suggestion must be rejected because it is untimely and not part of the record in this proceeding.