volumes delivered into the gathering system would be minimal and should not be an issue. R.D. at 86 (citing PNG R.B. at 15-16). Whether the Proposed Producer Retainage Charge is Appropriate Policy for the Unique Situation Presented in this Proceeding Finally, the ALJ rejected PIOGA’s argument that the proposed charge would exacerbate the decline of conventional wells and potentially jeopardize the provision of safe and reliable service or result in a slippery slope. According to the ALJ, despite making this assertion, PIOGA has failed to provide any actual data or analysis to support this conclusion. The ALJ lauded Peoples’ substantial capital investments to replace at-risk pipe in order to address safety and reliability of its system including the gathering system. R.D. at 86-87. The ALJ found no merit in PIOGA’s argument because PIOGA has stipulated in this proceeding that the charge will not have a material effect on the production from existing wells or the production from new wells. Therefore, the ALJ disagreed with PIOGA’s claim that the proposed retainage charge is poor policy. The ALJ concluded that the proposed producer charge would properly balance the interests of both the Company’s customers and the producers, especially, because there is currently no balance in the charges. R.D. at 89. Exceptions, Replies and Dispositions In its Exceptions, PIOGA generally criticizes Peoples’ “about-face” position on this matter, the timing of the request, and the procedure used by Peoples in requesting the proposed producer retainage charge in the instant proceeding. Exc. at 1-4. PIOGA requests that the Commission reject the ALJ’s recommendation and approve either of the OCA’s retainage rate proposals, which are: (1) an additional 2.0% gathering retainage charge assessed to transportation customers on volumes delivered on the
volumes delivered into the gathering system would be minimal and should not be an issue. R.D. at 86 (citing PNG R.B. at 15-16). Whether the Proposed Producer Retainage Charge is Appropriate Policy for the Unique Situation Presented in this Proceeding Finally, the ALJ rejected PIOGA’s argument that the proposed charge would exacerbate the decline of conventional wells and potentially jeopardize the provision of safe and reliable service or result in a slippery slope. According to the ALJ, despite making this assertion, PIOGA has failed to provide any actual data or analysis to support this conclusion. The ALJ lauded Peoples’ substantial capital investments to replace at-risk pipe in order to address safety and reliability of its system including the gathering system. R.D. at 86-87. The ALJ found no merit in PIOGA’s argument because PIOGA has stipulated in this proceeding that the charge will not have a material effect on the production from existing wells or the production from new wells. Therefore, the ALJ disagreed with PIOGA’s claim that the proposed retainage charge is poor policy. The ALJ concluded that the proposed producer charge would properly balance the interests of both the Company’s customers and the producers, especially, because there is currently no balance in the charges. R.D. at 89. Exceptions, Replies and Dispositions In its Exceptions, PIOGA generally criticizes Peoples’ “about-face” position on this matter, the timing of the request, and the procedure used by Peoples in requesting the proposed producer retainage charge in the instant proceeding. Exc. at 1-4. PIOGA requests that the Commission reject the ALJ’s recommendation and approve either of the OCA’s retainage rate proposals, which are: (1) an additional 2.0% gathering retainage charge assessed to transportation customers on volumes delivered on the
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