19473_Authority_Oct-opt

municipalauthorities.org │ 6 1 2 private property, exposing authorities to risks and responsibilities beyond their core mission of providing safe and reliable water service. The bill also introduces ambiguity by requiring authorities to assist customers in identifying "wasteful inefficiencies," a term that is not defined in HB 1213. Water usage patterns vary significantly based on household size, occupancy, seasonal activities, medical needs, business operations, and countless other factors. Without clear statutory guidance, authorities could be placed in the position of making subjective judgments regarding customer water use practices and personal choices. Such determinations are beyond the expertise and intended function of municipal authorities. Although we appreciate that the bill has been revised from the prior legislative session by increasing the notification threshold from 50% to 200% above average usage, significant implementation concerns remain. Many municipal authorities do not bill customers monthly and may not maintain billing systems that calculate usage in the manner prescribed by HB 1213. Compliance could require modifications to billing software, reporting protocols, and customer service procedures, resulting in additional costs that ultimately would be borne by ratepayers. The bill also leaves uncertainty regarding the definition and scope of the term "utility customer." In many cases, the party receiving the water bill is not the individual occupying or directly using the property. Multifamily housing, tenant-occupied properties, commercial facilities, and industrial operations frequently involve ownership and billing arrangements that complicate customer communication and raise questions regarding compliance. Importantly, municipal authorities are already taking meaningful steps to address the concerns that motivated this legislation. Authorities routinely provide educational materials regarding leak detection and water conservation, assist customers in understanding unusual water usage, and invest in Advanced Metering Infrastructure and related technologies that can provide near real-time usage information and customizable leak alerts. These approaches empower customers while preserving the appropriate division of responsibilities between authorities and property owners. While HB 1213 is well-intentioned, it creates a new statutory obligation that extends municipal authority responsibilities beyond the public water system and into the diagnosis of conditions occurring on private property. In doing so, it introduces uncertainty, liability concerns, operational challenges, and additional costs without adequately accounting for the diverse operational realities of Pennsylvania's water systems. PMAA recognizes the importance of improving customer awareness and encouraging responsible water use. A more effective approach would preserve flexibility for municipal authorities to implement notification programs that reflect their individual systems, customer communication practices, and available technology. Supporting voluntary, locally designed solutions would allow authorities to continue addressing unusual water usage while avoiding unintended mandates that may increase costs or create confusion regarding the responsibilities of water providers and property owners. For these reasons, we respectfully ask that you oppose HB 1213 P.N. 1361. PMAA welcomes the opportunity to work with the General Assembly on alternative approaches that promote water conservation, customer awareness, and leak detection while preserving local flexibility and avoiding unnecessary mandates on municipal authorities. Thank you for your consideration of our comments.