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(6) APPLIANCE DEALER/CONTRACTOR PROGRAM.--Under
this program, which was designed to encourage replacing
electric or older gas appliances with new gas
appliances, People's paid dealer/contractors and
customers to install new gas appliances. In 1990, this
program was discontinued. The expenditures listed
below for the 1992, 1993, and 1994 taxable years relate
to a "Gas Space Conditioning Allowance Program", which
was designed to convert on-main customers from electric
space conditioning equipment to gas space conditioning
equipment. This latter program was targeted at
existing gas consumers, offering an allowance to help
defray the higher "first costs" of gas space
conditioning equipment. For the respective taxable
years in issue, expenditures for these programs were
$84,120, $28,436, $16,630, $8,701, $52,000, $50,250,
and $27,000.
(7) ELECTRIC RESISTANCE REPLACEMENT PROGRAM.--
Under this program, which was designed to encourage
customers to replace electric appliances with gas
appliances by subsidizing the installation of gas
appliances, People's paid residential customers to
switch to gas heat from electric heat. In 1990, this
program was bifurcated into two programs, one for
residential customers and the other for commercial
users. For the respective taxable years in issue,
these programs' expenditures were $2,170,942,
$2,510,076, $3,091,036, $3,486,573, $3,364,740,
$2,452,452, and $2,380,931.
The largest single category of FEECA expenditures consisted
of subsidies for people who bought gas appliances from People's
or an affiliate (collectively referred to as People's). The
percentages of program expenditures that were subsidies were:2
Taxable Year Percentage
1988 69
1989 79
2 These percentages were stipulated by the parties as
"minimum percentages". The record, however, does not allow us to
find a greater percentage.
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