Exceptions and Replies Both Columbia and I&E excepted to the ruling. ALJ’s Columbia’s Exceptions seek clarification regarding the recommendation, while ALJ’s I&E’s Exceptions seek reversal of this recommendation. Additionally, I&E filed Replies to Exceptions, while Columbia, the OCA, and Cause-PA filed Replies to Columbia’s I&E’s Exceptions. The Exceptions and the associated Replies to Exceptions are addressed below. a. Exceptions and the Replies to Exceptions of Columbia, I&E’s the OCA and CAUSE-PA I&E excepts to the recommendation that the Commission adopt the ALJ’s positions of Columbia, the OCA, and CAUSE-PA. I&E submits that none of these positions accomplish the directive that the Parties the issue of Commission’s “address” the Hardship Fund in the matter before us. I&E Exc. at 4-5, 8. I&E points out that, in its the Commission rejected argument that it could not fund its USECP Order, Columbia’s Hardship Fund through voluntary resources and noted that every other natural gas distribution company and electric distribution company has done so. at 5 (citing Id. at 39-40). As a result, I&E reasons that it is logical to conclude that USECP Order use of its USP Rider to collect $375,000 for its Hardship Fund, which is akin Columbia’s to mandatory funding, is inconsistent with the at 5. USECP Order. Id. I&E posits that it is plausible that search for voluntary funding Columbia’s for the Hardship Fund could continue for an indefinite period. I&E points out that Columbia has been collecting mandatory funds through its USP Rider since the settlement of its 2012 base rate case and still has yet to find additional voluntary resources sufficient to replace this mandatory funding. I&E reasons that Columbia could simply state in its next base rate case that it has not had sufficient time to secure
Exceptions and Replies Both Columbia and I&E excepted to the ALJ’s ruling. Columbia’s Exceptions seek clarification regarding the ALJ’s recommendation, while I&E’s Exceptions seek reversal of this recommendation. Additionally, I&E filed Replies to Columbia’s Exceptions, while Columbia, the OCA, and Cause-PA filed Replies to I&E’s Exceptions. The Exceptions and the associated Replies to Exceptions are addressed below. a. I&E’s Exceptions and the Replies to Exceptions of Columbia, the OCA and CAUSE-PA I&E excepts to the ALJ’s recommendation that the Commission adopt the positions of Columbia, the OCA, and CAUSE-PA. I&E submits that none of these positions accomplish the Commission’s directive that the Parties “address” the issue of the Hardship Fund in the matter before us. I&E Exc. at 4-5, 8. I&E points out that, in its USECP Order, the Commission rejected Columbia’s argument that it could not fund its Hardship Fund through voluntary resources and noted that every other natural gas distribution company and electric distribution company has done so. Id. at 5 (citing USECP Order at 39-40). As a result, I&E reasons that it is logical to conclude that Columbia’s use of its USP Rider to collect $375,000 for its Hardship Fund, which is akin to mandatory funding, is inconsistent with the USECP Order. Id. at 5. I&E posits that it is plausible that Columbia’s search for voluntary funding for the Hardship Fund could continue for an indefinite period. I&E points out that Columbia has been collecting mandatory funds through its USP Rider since the settlement of its 2012 base rate case and still has yet to find additional voluntary resources sufficient to replace this mandatory funding. I&E reasons that Columbia could simply state in its next base rate case that it has not had sufficient time to secure
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