How to Prove Public Need for a Proposed Service ?
In Yellow Cab Company v. Public Utility Commission, 673 A.2d 1015, 1018 (Pa. Cmwlth. 1996), this Court noted that the Commission has held that a public demand or need for an applicant's proposed service must be proved through witnesses comprising a representative sampling of the public that will use the service; such witnesses must be legally competent and credible; their testimony must be probative and relevant to the application, and they must articulate a demand/need for the type of service embodied in the application. Re Blue Bird Coach Lines, Inc., 72 Pa.P.U.C. 262 (1990).
An applicant is not required to show demand for its service at every point in the proposed territory; it is sufficient to show that need exists within the area generally served. Morgan Drive Away, Inc. v. Pennsylvania Public Utility Commission, 99 Pa. Commw. 420, 512 A.2d 1359 (Pa. Cmwlth. 1986).