I&E also disagrees with argument that the rate commitments in the Aqua’s APA are not relevant in this proceeding. I&E asserts that conclusion regarding Aqua’s rate stabilization contradicts the mandate in the which Final Implementation Order requires supporting documents that explain how the rate stabilization plan may potentially impact existing customers of the acquiring utility to be filed with the rate stabilization plan in a Section 1329 proceeding. at 13-14 (citing Id. Final Implementation at 27). I&E also questions comparison of the instant proceeding to the Order Aqua’s PAWC/Scranton acquisition. I&E asserts that because the instant proceeding is both a Section 1102 and a Section 1329 proceeding and requires the filing of supporting documents to establish the basis of a rate stabilization plan, comparison of this Aqua’s case with the PAWC/Scranton case has no bearing. I&E therefore concludes that the Commission should deny the instant Application because Aqua failed to justify its rate stabilization plan as required by Section 1329. I&E R. Exc. at 14-15. c. Replies to Exceptions OCA’s Aqua’s In its Reply to Exception No. 2, while the OCA did not take a Aqua’s position on whether the rate restrictions in APA constitute a rate stabilization Aqua’s plan, the OCA nonetheless echoes argument that unlike the PAWC/Scranton I&E’s proceeding, Application was filed under both Sections 1102 and 1329 and Aqua’s requires ratemaking rate base to be determined in this proceeding. OCA R. Exc. at 1011. The OCA argues that because Aqua requested in its Application that the lesser of the purchase price or the average of the two fair market values be used as the ratemaking rate base in the instant proceeding, comparison of the instant proceeding with the Aqua’s PAWC/Scranton proceeding is misplaced and should be rejected. Id. Furthermore, the OCA asserts that failure to provide supporting Aqua’s documents or information regarding the rate restrictions in the APA makes it all the more
I&E also disagrees with Aqua’s argument that the rate commitments in the APA are not relevant in this proceeding. I&E asserts that Aqua’s conclusion regarding rate stabilization contradicts the mandate in the Final Implementation Order which requires supporting documents that explain how the rate stabilization plan may potentially impact existing customers of the acquiring utility to be filed with the rate stabilization plan in a Section 1329 proceeding. Id. at 13-14 (citing Final Implementation Order at 27). I&E also questions Aqua’s comparison of the instant proceeding to the PAWC/Scranton acquisition. I&E asserts that because the instant proceeding is both a Section 1102 and a Section 1329 proceeding and requires the filing of supporting documents to establish the basis of a rate stabilization plan, Aqua’s comparison of this case with the PAWC/Scranton case has no bearing. I&E therefore concludes that the Commission should deny the instant Application because Aqua failed to justify its rate stabilization plan as required by Section 1329. I&E R. Exc. at 14-15. c. OCA’s Replies to Aqua’s Exceptions In its Reply to Aqua’s Exception No. 2, while the OCA did not take a position on whether the rate restrictions in Aqua’s APA constitute a rate stabilization plan, the OCA nonetheless echoes I&E’s argument that unlike the PAWC/Scranton proceeding, Aqua’s Application was filed under both Sections 1102 and 1329 and requires ratemaking rate base to be determined in this proceeding. OCA R. Exc. at 1011. The OCA argues that because Aqua requested in its Application that the lesser of the purchase price or the average of the two fair market values be used as the ratemaking rate base in the instant proceeding, Aqua’s comparison of the instant proceeding with the PAWC/Scranton proceeding is misplaced and should be rejected. Id. Furthermore, the OCA asserts that Aqua’s failure to provide supporting documents or information regarding the rate restrictions in the APA makes it all the more