We are not persuaded that the limited and temporary waiver granted in the Smart Meter Implementation Order constitutes a blanket waiver. All discussion of meter testing waivers in the Smart Meter Implementation Order was in the context of meters replaced at customer request ahead of a deployment schedule. Customers that request accelerated deployment of smart meters incur costs for the installation of their smart meters. The Smart Meter Implementation Order recognized that waiving legacy meter testing when the customer requests accelerated smart meter deployment would provide an offset to the customer cost against the cost of the requested accelerated deployment. It is such a limited and temporary waiver that was granted on a blanket basis. Duquesne Light has provided no facts or law to persuade us to expand that decision or our interpretation of that decision in this proceeding. Duquesne Light has alleged in its Reconsideration Petition that, by misinterpreting our Smart Meter Implementation Order, we have begun to impose requirements on the EDCs that are inconsistent with the way the EDCs have been interpreting that order. Reconsideration Petition at 1-3. We disagree. Duquesne Light has not noted any EDC relying on the interpretation that Duquesne Light is espousing. While Duquesne Light points to PPL as an example, it is clear that PPL has not relied on Duquesne Light’s interpretation. Where there is an inconsistency between an EDC’s interpretation of a Commission order and the Commission’s own interpretation of that order, it does not necessarily follow that the Commission has misinterpreted its own order. In fact, Pennsylvania courts have held that an “administrative agency is peculiarly fitted to interpret its own orders.” W. J. Dillner Transfer Co. v. Pa. PUC, 107 A.2d 159, 162 (Pa. Super. Ct., 1954). Consequently, a court will not set aside an agency’s construction of its own order “unless the result is clearly erroneous, arbitrary, and unsupported by evidence.” Dillner at 162. We are not persuaded that the limited and temporary waiver granted in the Smart Meter Implementation Order applies to the waivers requested by Duquesne Light in its original Waiver Petition (or in the Reconsideration Petition) at this docket.
reason to address “as found” testing for legacy meters outside a SMP proceeding, and we decline to treat the components of smart meter deployment on a piecemeal basis. PPL, which Duquesne Light seeks to rely upon, addressed its meter testing concerns in its own SMP. In order to consider Duquesne Light’s new waiver proposal, there is no need for rescission, amendment, or reconsideration of the Waiver Order, and it would be inappropriate for us to do so. Accordingly, we will not address the merits of the new proposal at this time outside Duquesne Light’s SMP. Duquesne Light does not need an individual waiver to avoid having to test legacy meters replaced early at customer request. Waivers of any other legacy meter testing must be considered in the context of a smart meter plan which will allow a full consideration of the record, merits, benefits, and costs concerning any such alternatives. VII. Conclusion We conclude that Duquesne Light has not established any legal, justifiable, or reasonable basis for reconsideration or revision of our Waiver Order, and we shall therefore deny the Reconsideration Petition on its merits. We stand by our original interpretation in the Waiver Order that the Smart Meter Implementation Order did not waive all Section 57.20(h) meter testing for all legacy meters being replaced by smart meters. If stakeholders wish to pursue further interpretation, clarification, or reconsideration of the question regarding whether the Smart Meter Implementation Order waived all Section 57.20(h) meter testing for all legacy meters being replaced by smart meters, they are directed to do so at that docket. If Duquesne Light Company wishes to pursue an alternative to compliance with Section 57.20(h) in terms of the new proposal set out in its Reconsideration Petition or in terms of another alternative, it should do so in the context of it Smart Meter Plan proceeding; THEREFORE,