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1 THOMAS. LONG, NIESEN & KENNARD ~ ~1I{)rners and Counsellors a," aw THOMAS T. NIESEN Direct Dial: October 18, 2013 Via Electronic Filing Rosemary Chiavetta p Secretary Commonwealth Keystone Building 400 North Street P. O. Box 3265 Harrisburg, PA Re: Docket No. R , et al. Pa. P.U.C., et al. v. Pennsylvania American Water Company Dear Secretary Chiavetta: We are counsel to the Pittsburgh Water and Sewer Authority in the above matter and are submitting for filing the Authority's Statement Of Non-Opposition and Request for Bill Message Re Wastewater Cost Recovery in regard to the Joint Petition for Settlement of Rate Investigation, which is being submitted to the Public Utility Commission today by Pennsylvania American Water Company and other parties. Copies of the Authority's Statement of Non-Opposition and Request for Bill Message are being served upon the persons and in the manner set forth on the certificate of service attached to it. Very truly yours, THOMAS, LONG, NIESEN & KENNARD By cc: Certificate of Service (w/encl.) James L. Good (w/encl.) Clliavetta (Statement Re Joint Settlement).wpd 2 LOCUST STREET SUITE P.O. Box HARRISBURG, " 1

2 Before The PENNSYLVANIA PUBLIC UTILITY COMMISSION v. Docket No. R et al. Pennsylvania American Water Company STATEMENT OF THE PITTSBURGH WATER AND SEWER AUTHORITY IN NON-OPPOSITION TO JOINT PETITION FOR SETTLEMENT OF RATE INVESTIGATION AND REQUEST FOR BILL MESSAGE RE WASTEWATER COST RECOVERY TO ADMINISTRATIVE LAW JUDGES ANGELA T. JONES AND DARLENE D. HEEP: AND NOW, comes the Pittsburgh Water and Sewer Authority ("PWSA"), by its attorneys, and, pursuant to Ordering Paragraph No.4 of Order #7 Hearing Cancellation, submits the following Statement ofn on-opposition and Request for Bill Message Re Wastewater Cost Recovery in regard to the Joint Petition for Settlement of Rate Investigation ("Joint Petition") submitted to the Public Utility Commission ("Commission") by the Joint Petitioners. 1 Introduction 1. This proceeding concerns Supplement No. 279 to PA WC's Tariff Water Pa. P.U.C. No.4 and original Tariff Wastewater No. 15, which proposed a combined annual increase in water and wastewater revenue of$58,618,355, or 10.1%. 1 The Joint Petitioners are Pennsylvania-American Water Company the Bureau and Enforcement, the Office of Consumer Advocate, the Office of Small Business Advocate, the Commission on Economic Opportunity, and the Pennsylvania-American Water Large Users Group.

3 2. PWSA is a Pennsylvania municipal authority providing water and wastewater service to more than 300,000 residents in the City of Pittsburgh ("City") and surrounding areas. Under a long-standing arrangement dating to the late 1950s, the City equalizes the rates for water service to South Hills residents who are P A WC water customers such that South Hills residents pay no more for water service than they would if they were water service customers of PWSA. The present annual cost of the equalization payment to PWSA is $2,148, Through Supplement No. 279, PAWC proposed increases in rates, inter alia, to approximately 25,000 water customers in the City's South Hills area (Zone 1 customers), which would increase the equalization payments presently implemented through PWSA. PWSA intervened in the lnatter with an objective of minimizing the PA WC water rate increase, if any, to South Hills residents and, thus, minimizing the equalization payments for South Hills residents. 4. PWSA presented the written direct and surrebuttal testimony of James L. Good 2 which asked the Commission to carefully investigate, inter alia, PA WC's proposed allocation of wastewater costs to water operations pursuant to Act 11 of In regard to any allocation of wastewater costs to water operations, PWSA proposed that P A WC should provide a message printed directly on customer bills clearly identifying the portion of its water rate that is used to pay its wastewater revenue requirement in other parts ofpa WC's service area. 3 Statement of Non-Opposition 5. PWSA does not oppose the terms and conditions of the proposed settlement, as set forth in the Joint Petition filed by the Joint Petitioners. PWSA does not oppose the 2 PWSA Statement Nos. 1 and I-SR. 3 PWSA Statement No. I-SR at

4 allocation of $5,411,134 of wastewater revenue requirement to water customers as identified at paragraph of the Joint Petition. Request For Bill Message Re Wastewater Cost Recovery 6. While PWSA does not oppose the proposed allocation of$5,411,134 of wastewater revenue requirement to water customers, PWSA submits that it would be reasonable and appropriate for P A we to provide a message printed directly on customer bills clearly identifying the portion of its water rate that is used to pay its wastewater revenue requirement in other parts of PAWC's service area as proposed in the testimony ofmr. Good The portion of the water rate used to cover wastewater revenue would be easy to determine. Joint Petitioners explain in paragraph 1 O.d. of the Joint Petition that the increase in Zone 1 water rates to cover the cost of the allocated wastewater revenue requirement is less than one percent. There would not need to be a separate calculation for each bill, but rather a simple statement on the bill that a certain cents of the rate per 100 gallons of water usage is for the purpose of wastewater cost recovery in other parts ofpawc's service territory. 8. The bill message would provide for transparency, promote the public interest and be a significant benefit to PA WC's customers, as it would enable them to see and understand what portion of their water service rate is being used to subsidize costs related to the provision of safe and reliable wastewater service in other parts of PA WC's service territory. The Commission has characterized transparency as the free flow of information to all parties. 5 Indeed, the Commission in 4 PWSA Statement No. l-sr at 5. 5 In Re Electric Distribution Companies, Docket Nos. L and M (Order entered December 16,2004)

5 other proceedings has recognized the benefits of transparency in matters involving public utilities. 6 Transparency and free flow of information support PWSA's proposed bill message, 9. Accordingly, PWSA submits that, as part of its final resolution of this proceeding, the Commission should direct P A WC to include a message printed directly on customer bills clearly identifying the portion of its water rate that is used to pay its wastewater revenue requirement in other parts ofpawc's service area. WHEREFORE, the Pittsburgh Water and Sewer Authority presents the foregoing Statement of Non-Opposition to the Joint Petition for Settlement of Rate Investigation and Request for Bill Message Re Wastewater Cost Recovery. Respectfully submitted, B& ~ Thomas T. Niesen, E P A Attorney ID # Charles E. Thomas~ Ill, Esq. PA Attorney ID # THOMAS, LONG, NIESEN & KENNARD 212 Locust Street, Suite 500 P.O. Box 9500 Harrisburg, PA Attorneys for The Pittsburgh Water and Sewer Authority 6 See, e.g., In Re Pennsylvania American Water Company, Docket No. A F0136 (Tentative Opinion and Order entered August 22, 2007), slip op. at 22 (where the Commission explained that corporate transparency is an important regulatory tool used to monitor many significant activities of Pennsylvania's regulated Re Natural Gas Distribution Companies and Promotion a/competitive Retail Markets, Docket No. L (Revised Final Rulemaking Order entered June 23,2011), slip op. at 21 (where the Commission revises the mechanics for the shifting of gas procurement costs from base rates to the price to compare with the objective of making the shift more transparent and easier to understand for consumers)

6 Before The PENNSYLVANIA PUBLIC UTILITY COMMISSION v. Docket No. R et al. Pennsylvania American Water Company CERTIFICATE OF SERVICE I hereby certify that I have this 18 th day of October, 2013, served a true and correct copy of the foregoing Statement of Non-Opposition and Request for Bill Message Re Wastewater Cost Recovery, upon the persons and in the manner set forth below: BY AND FIRST CLASS MAIL, POSTAGE PREPAID Honorable Angela T. Jones Administrative Law Judge Suite Philadelphia P A angelj ones@)pa.gov Honorable Darlene Davis Heep Adnlinistrative Law Judge Pennsylvania Public 1Jtility Commission Philadelphia, PA dheep@)pa.gov Anthony C. DeCusatis, Esquire Thomas P. Gadsden, Esquire Brooke McGlinn, Esquire Morgan, Lewis & Bockius, LLP 1701 Market Street Philadelphia, P A adecusatis@)morganlewis.conl tgadsden@)lnorganlwis.com bmcglinn@morganlewis.com Seth A. Mendelsohn, Esquire Susan Simms Marsh, Esquire Pennsylvania American Water Company 800 Hersheypark Drive Hershey, P A seth.nlendelsohn@)an1water.com sllsan.marsh(a)anlwater.com

7 Candis A. Tunilo, Esquire Christy M. Appleby, Esquire Brandon Pierce, Esquire Office of Consumer Advocate 555 Walnut Street Forum Place, 5 th Floor Harrisburg, PAl ctunilo(ivpaoca.org ~appleby@1paoca.org bpi erce@paoca.org Elizabeth Rose Triscari, Esquire Office of Small Business Advocate Suite 1102, Commerce Building 300 North Second Street Harrisburg, P A etri scari(a>pa. gov Allison C. Kaster, Esquire Heidi Wushinske, Esquire Bureau of Investigation & Enforcement 400 North Street, Second Floor West Harrisburg, PA akaster@pa.gov hwushinske(mpa. goy Joseph L. Vullo, Esquire Burke, Vullo, Reilly, Roberts 1460 Wyoming Avenue Forty Fort, PA jlvullo@aol.com Barry A. N alun, Esquire Derrick Price Williamson, Esquire Spilman, Thomas & Battle, PLLC 1100 Bent Creek Boulevard, Suite 101 Mechanicsburg, P A bnaum@~spiln1anlaw.coln dwillian1son(2v,spihnanla w.con1 Charis Mincavage, Esquire Adeolu A. Bakare, Esquire McNees Wallace & Nurick LLC 100 Pine Street P.O. Box 1166 Harrisburg, PA cn1incavage@nlwn.com abakare(mnlwn.con1 Doris Miller 115 Woodside Trail Dingmans Ferry, PA Deedee417pa@hotmail.colTI J ane Neufeld P.O. Box 873 Dingmans Ferry, PA jneufl OO@gmail.com Thomas T. Niesen PA Attorney ID # 31379