SPILMAN THOMAS & BATTLE,,,,,
January 8,2016
H A HAND DELIVERY
Ms. Ingrid Ferrell
Executive Secretary
Public Service Commission of West Virginia
201 Brooks Street
Charleston, West Virginia 25301
Re:
I T-G~TSCASE NO. 15-0676-W-42T
WEST VIRGINIA-AMERICANWATER COMPANY
Rule 42T application to increase
water rates and charges.
9 C j - r
Dear Ms. Ferrell:
Please find enclosed for filing on behalf of SWVA, Inc. and the West Virginia Energy
Users Group in the above-referenced matter an original and twelve (12) copies o f the “Reply
Brief of SWVA, Inc. and the West Virginia Energy Users Group.’t
If you have any questions regarding this filing, please contact me.
Sincere1
d#&
Lee F. Feinberg (WV SMe Bar #1173)
Susan J. Riggs (WV State Bar #5246)
[email protected]
[email protected]
Barry A. Naum (WV State Bar #12791)
Derrick Price Williamson
Spilman Thomas & Battle, PLLC
1100 Bent Creek Boulevard, Suite 101
Mechanicsburg, PA 17050
[email protected]
[email protected]
LFF.~ds:80anio
Enclosures
cc: Certificate of Service
Spilrnan Center
300 Kanawha Boulevard, East
wwwspilmanlawcom
West Virginia
Post Office Box 273
Charleston,WestVirginia 25321 0273
3043403800
3043403801 fax
North Carolina
Pennsylvania
Virginia
PUBLIC SERVICE COMMISSION
OF WEST VIRGINIA
CHARLESTON
CASE NO. 15-0676-W-42T
WEST VIRGINIA-AMERICAN WATER COMPANY
Rule 42T application to increase water rates and charges
REPLY BRIEF OF SWVA, INC. AND
THE WEST VIRGINIA ENERGY USERS GROUP
Lee Feinherg (WV State Bar iil173)
Susan J. Riggs (WV State Bar #5246)
SPILMAN THOMAS & BATTLE, PLLC
300 Kanawha Blvd., East
Charleston, WV 25301
Phone: 304.340.3867
Fax: 304.340.3801
lfeinherp@,s~ilmanlaw.com
sripgs@,spilmanlaw.com
Derrick Price Williamson
Barry A. Naum (WV State Bar #12791)
SPILMAN THOMAS & BATTLE, PLLC
1100 Bent Creek Blvd., Suite 101
Mechanicsburg, PA 17050
Phone: 117.795.2741
Fax: 717.795.2743
[email protected]
bnaum@,spilmanlaw.com
Counsel to SWVA, Inc. and the West Virginia
Energy Users Group
Dated: January 8,20 16
PUBLIC SERVICE COMMISSION
OF WEST VIRGINIA
CHARLESTON
CASE NO. 15-0676-W-42T
WEST VIRGINIA-AMERICAN WATER COMPANY
Rule 42T application to increase water rates and charges
REPLY BRIEF OF SWVA, INC. AND
THE WEST VIRGINIA ENERGY USERS GROUP
I.
INTRODUCTION
West Virginia-American Water Company ("WVAW or "Company") in this case claims
that "a public 'tipping point' appears to have been reached on the need for infrastructure
replacement and renewal," and accordingly proposes an unprecedented $32.1 million base rate
increase.'
Ignoring the fact that this "tipping point" did not just arrive overnight due to
unforeseen occurrences or circumstances outside of the Company's control, WVAW now asks
the Commission to deviate from time-tested, just, and reasonable ratemaking principles in order
to reward the Company for its long-standing infiastructure failure. And while calling the
inherent rate shock that its proposal portends for customers "strong medicine" (as if ratepayers
deserve a huge increase in rates),' WVAW accuses the intervening parties of failing to provide
an "impartial analysis" of the Company's mournful condition?
Just a cursory review of the Company's Initial Brief reveals that WVAW has only one
unilateral concern in proposing to foist a $32.1 million rate increase on customers: the financial
condition of the Company and its shareholders. Even in WVAW's half-hearted lip service (less
1
Company Initial Brief ("I.B."), p. 1 1 (citing WVAW Ex.JLM-R, p. 2).
*Id.
- at 16.
3
Id. at 8.
-
1
than two pages of a 59-page argument) of "managing the rate impact," the Company's only
conclusion is, essentially, that the Commission should not manage the rate impact and should
instead balance everything in favor of the Company's "earnings problems," under the guise that
this will benefit e ~ e r y o n e .WVAW
~
apparently believes that the intervening parties should be
"impartial" participants in the Company's revenue enhancement scheme, while at the same time
WVAW's interpretation of "fairness and sound ratemaking"' means giving the Company what it
wants. The irony in this would be comical, if not for the deleterious impact that WVAWs
request would have for their captive customers.
To be clear, however, the clever words "tipping point" are those of the Company's
witness, Mr. McIntyre, attempting to sway the Commission into thinking that the public supports
the rate increase that it seeks. Nothing could be further from the truth. The intervening parties
representing the West Virginia public resoundingly concur that the rate increase sought by
WVAW in this case should be rejected. Specifically, these parties concluded the following:
"The Commission should find that the proposed rate increase is
neither just nor reasonable and should be rejected."6
"The Commission should only allow a nominal rate increase
because the residents of the County and City are entitled to
reasonable and affordable rates[.]"7
Due, in part, to the overwhelming and unanimous public
opposition to the proposed rate increase requested . . . the County
and the City moved to intervene[.]"*
d
See _
id. at
_
_16-18.
Id. at
13, 56;see also id. at 27,28,40 (indicating what the Company believes is "fair" or "unfair").
6
Advocates for a Safe Water System I.B., p. 20.
7
Kanawha County Commission and City of Charleston I.B., p. 1 (emphasis in original).
Kanawha County Commission and City of Charleston I.B., p. 2.
2
"The CAD is troubled by the Company embarking upon an
accelerated smart meter replacement program at a cost of $17
million . . . , No cost benefit analysis was performed before
beginning the meter replacements[.19
"This is not a state that can absorb such a dramatic rate
increaser.
"The economic reality of the proposal is far more significant for
those who have to pay the increase, especially for industrial and
manufacturing entities like SWVA and WVEUG members for
whom the increase will actually equate to hundreds of thousands of
dollars each year.""
Viewed impartially, the best evidence provided by WVAW and the other parties indicates
that the things requested by the Company are simply unnecessary and would in fact result in an
unfair and unjust result for the West Virginia public. SWVA and WVEUG" have already
addressed in full the reasons that the Company's request must fail; however, certain arguments
presented in the WVAW Initial Brief warrant response. To that end, SWVA and WVEUG
respectfully submit the f~llowing.'~
11.
REPLY ARGUMENT
A.
The Company Has Failed to Show that the Extraordinary Measures that It
Has Requested are Necessary or Reasonable.
In support of its $32.1 million rate increase, WVAW has requested, among other things,
Commission approval of the following measures: (1) use of Future Test Year ("FTY") data for
estimating revei~ues;'~
and (2) a 10.75 percent Return on Equity. SWVA and WVEUG have
9
CAD I.B., p. 1 (further noting, "The public outcry in opposition to this program was dramatic[.]").
lo
CAD LB., p. 2
'I
SWVA & WVEUG LB., p. 14.
I2
WVEUG members include Bayer Cropscience and The Chemours Company.
13
The decision to not address each and every argument presented by WVAW should not be interpreted as agreement
with those positions.
I'
See generallv Company I.B., pp. 5-10.
3
already fully addressed these requests in their Initial Brief; however, regardless of WVAW's
proclaimed need for these extraordinary measures, the record and the evidence show that they
are neither necessary nor reasonable, and in fact would produce an unjust result for the
Company's ratepayers and the West Virginia public.
1.
The Comuanv does not need the incentive o f the FTY to continue
investment in infrastructure.
WVAW lauds the FTY as a means to "incentivize the increased capital infusion for the
Company's infrastructure
need^."'^
Given, however, the self-proclaimed infrastructure
requirements that the Company faces, it is certainly reasonable to wonder what additional
incentive WVAW needs to do its job and meet its statutoni obligations. To the extent any extra
incentive might be needed (beyond providing safe and reliable water service), the Commission
has already provided it: the Allowance for Funds After Construction ("AFFAC").
I'he Company does not like the AFFAC, especially in comparison with the FTY,
AFFAC works, and - with one modification - will give WVAW every opporhmity that it needs
to be made financially whole. WVAWs only criticism of the AFFAC is that it "has not been as
beneficial as it might have been because of the Company's inability to book the equity portion of
investment under GAAP."16 That's it; that is the entirety of WVAWs complaint with the
AFFAC. But as the evidence demonstrably indicates, this GAAP booking issue is simply a
problem of accounting, not a revenue or ratemaking problem. In real, economic, revenue terms,
the AFFAC has performed well. As SWVA and WVEUG have explained, AFFAC gives the
15
l6
Id. at I .
Id. at 13,
4
Company the fair opportunity, over time, to be made fully whole, because WVAW is able to and did - include debt and equity carrying costs in its revenue req~irement.'~
WVAW might
orefer the FTY approach, or some iteration of the Distribution System
Improvement Charge ("DSIC"), as a replacement of the AFFAC in order to avoid regulatory lag,
but the AFFAC provides exactly what it was designed to provide and what the Company actually
needs."
The only modification needed to make the Company fully whole over the appropriate
time necessary is the ability to defer the equity portion of the AFFAC adjustment in order to
recover it in future rates.
If the state of WVAW's infrastructure has reached a "tipping point," as the Company
claims, then it has all the incentive that it needs to continue to invest heavily in system
improvements and replacements. The AFFAC, generously awarded by the Commission, adds
incentive upon incentive, with a full and fair opportunity for WVAW to recover the costs of
these investments. The Commission should not countenance any veiled threats to forego
infrastructure investments (and thereby cease to meet its legal obligation as a monopoly utility
service provider) if WVAW doesn't get its way.
The Comuanv's request for the use of the FTY would result in unjust
and unreasonable rate sltock for customers.
2.
In support of the FTY, WVAW cites the National Association of Regulated Utility
Commissioners' ("NARUC") opinion that the FTY constitutes a "best practice.""
Notwithstanding the fact that the FTY remains the minority position among states that regulate
water utilities:'
NARUC is not charged, as the Commission is, with the regulation of West
"See
-SWVA & WVEUG I.B., p. 10 (citing SWVA & WVEUG Ex. RAB-D, pp. 8-9).
18
See_
id. at 10-11.
_
19
Company I.B., p. 6 .
"SWVA & WVEUG I.B., p. 8 (citing SWVA & WVEUG Ex. RAB-D, p. 1 I).
5
Virginia utilities or the balancing of interests between West Virginia utilities, their customers,
and the West Virginia public. Irrespective of the NARUC view, the critical question that must
be answered in this case is whether the use of the FTY by a West Virginia utility in West
Virginia would be just and reasonable. As S W A and WVEUG have demonstrated, when
balancing the interest of W A W in its ability to earn its authorized return against the interests of
the Company's ratepayers, it is self-evident that the FTY approach would create unjust and
unreasonable rates - a result that the Commission should not condone.
The Company has provided absolutely no analysis of the express impact that its FTY
proposal would have on ratepayers, instead relying solely on arguments that the FTY is just best
for WVAW and its shareholders. The fact, however, is that inclusion of the FTY in the
Company's base rate filing alone created a prospective impact in customer rates of over $13
million, or 12 percent higher than the traditional Historical Test Year ("HTY") approach." Even
under the Company's revised revenue request, this impact is dramatic, bringing rate shock upon
customers of approximately 26 percent or more.22
WVAW criticizes the intervening parties in this case for their "strong attachment,"
"inflexible adherence," and "wedded" posture to the traditional HTY approach employed by the
Commis~ion,2~
primarily on the suggestion that these parties do not recognize that the HTY has
been "unsuccessful in predicting rate year costs."24 But the HTY has been acknowledged by the
Commission as a fair and reasonable approach to revenue calculatior1,2~and this is a critical point
that the Company has not adequately addressed, particularly in comparison with the unfairness
*I
SWVA & WVEUG I.B., p. 13.
22
See id. at 13, 14.
___
23
Company I.B., pp. 7,8,10.
24
Id. at 9.
-
25
SWVA & WVEUG I.B., p. 7 (citing Re Contel, 1990 WL 488661, p. 3).
6
that would result from application of the FTY. The continued employment of the HTY in the
context of the Company's base rate revenues would mean the difference in millions of dollars of
rate impact to customers as compared to the FTY - and even under the Company's HTY
approach, ratepayers would still suffer an unprecedented rate increase? While WVAW argues
that the Commission "is not constrained by the inflexible adherence to traditional ratemaking
principle^,"^^ the legitimate constraints of insuring reasonableness and fairness indeed dictate
that the FTY approach should not be employed when a fair and reasonable HTY approach
already exists.
Finally, the Company's suggestion that it now faces "unusual or unique" circumstances
warranting use of the FTY, including declining customer usage and loss of customers in addition
to the infrastructure
is baseless. As an initial matter, SWVA and WVEUG share the
concern of Staff and CAD that the Company's actual usage has probably not declined at all, but
has instead actually increased in recent ~ e a r s . 2But
~ even if WVAW's claims of declining usage
are accurate, there is nothing unusual ahout a utility, such as WVAW, losing customers and
experiencing such declines when that utility has extremely high rates and has very recently been
involved in, and has been blamed for, a very serious breach of public health?' It certainly might
be "unique" (if true), but that special status does not warrant foisting a huge rate increase on the
ratepayers who have suffered the severe and costly consequences of, and certainly did not cause,
the public health injury. Nor is there anything "unusual" or "unique" about the deteriorating
26
_
See_
id. at 13, 14.
27
Company I.B., p. 10
28
Id. at 9.
-
See Staff I.B., pp. 35-36 (noting that residential usage has begun to trend upward, with a minimum level in late
CAD I.B., pp. 4-5 (coocurring that metered sales to residential customers have increased
2013or early 2014);
by 26.19 million gallons in 2014 after two years of relatively level consumption).
29
&t
CAD I.B., p. 5 (noting that metered consumption to residential customers actually continued to increase in
2015, even in the midst ofthe Freedom Industries chemical spill).
'O
7
infrastructure of the WVAW system, particularly given that the Company has always maintained
a responsibility for its infrastructure and has (presumably) been aware of this condition for
decades (notwithstanding the Company's self-adulation for three whole years of increased
infrastructure investment3').
3.
The Companv's reguest for a 10.75 percent ROE is unjustified and
unreasonable.
In its Initial Brief, WVAW presents an argument for the 10.75 percent ROE
recommended by its expert witness, Dr. Vander Weide, in large part on the supposed basis that
this recommendation was "not challenged" or was "ignored."32 The suggestion that the
Commission should simply adopt the Company's ROEbecause the other parties did not entirely
challenge each and every detail of its ROEanalysis is nonsense, particularly considering that ROE
analysis is, in WVAWs own acknowledgment, an exercise of judgment based on expert witness
estimates and guidance.33
Still, for no purpose other than to be inflammatory, the Company criticizes the SWVA
and WVEUG cross examination of Staff witness Mr. Allen, who testified that the process of
developing an ROE is "an art, not a science" depending upon an individual expert's j~dgment.3~
. still undeniably true,
Regardless of how "folksy" or "dismissive" WVAW may think this is,35.it IS
and regardless of how "unassailable" WVAW thinks its own witness, Dr. Vander Weide, may
have
31
it is still true for Dr. Vander Weide's ROEestimation.
Company I.B., p. 11.
_
See_id. at 24.
33 _
See_
id. at 21 (citing Mountaineer Gas Co., Case No. 11-1627-G-42T (Order entered Oct. 31,2012), p. 7).
32
34
Id. at 22 (citing Nov. 2 Tr., p. 43).
__
''Id.
36
Id. at 23.
8
To put a finer point on it, however, the "unassailable" analysis of the Company's ROE
witness certainly was assailed. For example, as noted by SWVA and WVEUG, Dr. Vander
Weide relied on an illogical comparison of natural gas utilities when developing his ROE for
WVAW and did not examine any comparable water companies.37 Although still possibly
overstating the potential overall ROE for WVAW, Staff witness Mr. Allen at least properly
corrected Dr. Vander Weide's partiality for a higher risk comparison and presented a more
accurate comparison of similar utilities engaged in the provision of water service. Furthermore,
while Dr. Vander Weide derived an inflated ROE of 10.75 percent based on these dissimilar
natural gas utilities, the Company provided no analysis of how a 10.75 percent ROE would
compare with other West Virginia utilities (including natural gas, and even electric, companies).
As noted by SWVA and WVEUG, a 10.75 percent ROE would be hugely inconsistent with the
ROEtrend in West Virginia?'
Therefore, given the disparity in risk analysis provided by the Company, particularly in
comparison with other water utilities and utilities in general within West Virginia, there is no
logical or reasonable justification for adopting the overstated recommendation of WVAWs ROE
analyst.
Instead, the Commission should use the ROE analysis provided by Staff
-
and
augmented by SWVA and WVEUG - and derive an authorized ROE for the Company of no
more than 9.49 percent.
B.
SWVA and WVEUG Support an Overall Revenue Increase for WVAW in
the Range of $5 million to $9 million.
In their respective Initial Briefs, CAD and Staff have presented arguments calling for
significant reductions in the overall revenue increase for WVAW (under the traditional HTY
'' SWVA & WVEUG I.B., pp. 4-5
38
Id. at 6.
-
9
approach). Specifically, after adjustments, CAD has recommended an increase of no more than
$1.8 million, based on a 9.0 percent ROE (which translates into a $5.11 million increase at a
hypothetical 10.0 percent
ROE),^^ and Staff has recommended an increase in base revenues of
approximately $10.9 million, based on the 9.49 percent ROEdiscussed above!'
SWVA and WVEUG have reviewed the adjustments made by the CAD and Staff and
believe that these revised revenue projections are reasonable and fair. Furthermore, given that
the Company has unjustly benefitted - to the tune of millions of dollars - from its decision to
disregard a direct Commission Order on depreciation, a significant reduction from WVAW's
adjusted HTY revenue request of approximately $1 8.8 million is independentlyj~stified.~'
As argued in their depreciation case briefs, SWVA and WVEUG support the CAD'S
position that the Company's gross violation of a Commission Order to its sole benefit should
result in a going level depreciation expense reduction in
case of $7,470,195:'
That
adjustment and Staft's adjustments on all other issues43would result in an overall increase in
revenues of approximately $5 million.
In their Reply Brief in the depreciation case, SWVA and WVEUG proposed an
alternative to the CAD position: that the Commission might consider dismissing the entire
depreciation case.
39
A dismissal would have the effect of reducing WVAW's going level
CAD I.B., p. 3, Table 1.
Staff I.B., p. 3.
41
See generally "Initial Brief of The West Virginia Energy Users Group and SWVA, Inc.," Case No. 15-0674-WSD<Filed Dec. 7, 2015) ("SWVA & WVEUG Depreciation I.B.");
"Reply Brief of The West Virginia Energy
Users Group and SWVA, Inc.," Case No. 15-0674-WS-D (Filed Dec. 23, 2015) ("SWVA & WVEUG Depreciation
R.B.").
42
SWVA& WVEUG Depreciation I.B., p. 5.
43
And specifically accepting Staffs ROE of 9.49 percent, despite SWVA and WVEUG witness Mr. Baudino's
testimony that the ROE could be lower than 9.49 percent.
10
depreciation expense in
case by $3,491,534.44 That adjustment and Staffs adjustments on all
other issues would result in an overall increase in revenues of approximately $9.0 million.
C.
The Commission Should Reject Any Proposal for a Distribution System
Improvement Charge.
As noted in SWVA and WVEUG's Initial Brief, the issue of an Infrastructure
Replacement Program ("IRP") surcharge was first raised by Staff in the context of Direct
Testimony filed on September 25, 2015.4'
Seizing on this late proposal, the Company
subsequently offered a counter-proposal for a DSIC.46 Citing the very real procedural concerns
raised by SWVA and WVEUG in the course of this proceeding related to due process concerns,
however, Staffs Initial Brief indicated that Staffs proposal for an IRP surcharge is now,
appropriately, withdrawn!'
As such, and irrespective of any arguments that either Staff or the
Company may have offered in their Initial Briefs in support of the IRP/DSIC concept, the
Commission should reject any request now made by the Company for such a surcharge
mechanism. For all of the reasons cited by SWVA and WVEUG, and conceded by Staff,
approval of an IRP or DSIC mechanism arising out of this case would be unjust and
unreasonable for WVAW customers and the West Virginia public.
III.
CONCLUSION
in this case, WVAW prophesies of desperate times and accordingly calls for desperate
measures. While an infrastructure problem (of long standing) may exist on the WVAW system,
calm reasoning and an acknowledgment of the steps already taken by the Commission warrant
measures that portend far less risk to those who must, of necessity in a regulated monopoly
l4 SWVA
& WVEUG Depreciation R.B., p. 4.
45
SWVA & WVEUG I.B., p. 17.
46
See_
id.
_
41
StaffLB., p. 18.
11
environment, bear the weight of WVAW's infrastructure improvement efforts: the Company's
ratepayers. The solution to the Company's problem is not found in forcing ratepayers to absorb
an unprecedented rate increase - even in the name of a "one shot, one kill" attempt that would
result in "friendly fire" ratepayer casualties. Rather, the solution is found in a reasonable, fair,
and just application of ratemaking principles and mechanisms that have proven to work in
balancing the interests of &
parties,
l
and not just WVAW and its shareholders. Specifically, in
this instance, the solution is: (1) continued use of the AFFAC, with an adjustment to permit the
Company to defer the equity portion of the AFFAC adjustment in order to recover it in future
rates; (2) continued employment of the HTY approach for calculating base rate expenses; ( 3 ) an
authorized ROE of not more than 9.49 percent; and, (4) an increase in revenues to WVAW of $5
million to $9 million.
12
WHEREFORE, SWVA, Inc. and the West Virginia Energy Users Group respectfully
request the Commission:
Reject West Virginia-American Water Company's request for a $32.1 million
increase in this case;
Reject West Virginia-American Water Company's request for use of Future Test
Year treatment for calculation of revenues;
Reject West Virginia-American Water Company's request for a 10.75 percent
Return on Equity;
Reject the proposed $18.8 million increase, based on Historical Test Year data;
Adopt an authorized Return on Equity for West Virginia-American Water
Company of not more than 9.49 percent;
Continue the Allowance for Funds After Construction mechanism approved for
West Virginia-American Water Company in Case No. 10-0920-W-42T;
Permit West Virginia-American Water Company to defer post in-service
depreciation expense on investments under the Allowance for Funds After
Construction mechanism to be recognized as recoverable expenses for future
proceedings; and,
Reject any request for implementation of an Infrastructure Replacement Program
or Distribution System Improvement Charge.
Respectfully submitted this 8'h day ofJanuary, 2016.
W
Lee Feinberg (WV State Bar No. 1173)
Susan J. Riggs (WV State Bar No. 5246)
SPILMAN THOMAS & BATTLE, PLLC
Spilman Center
300 Kanawha Blvd., East
Charleston, WV 25301
Phone: 304.340.3867
Fax: 304.340.3801
Ifeinberg@,s.soilmanlaw.com
sriggs@,s.soilmanlaw.com
13
Derrick Price Williamson
Barry A. Naum (WV State Bar No. 12791)
SPILMAN THOMAS & BATTLE, PLLC
1100 Bent Creek Blvd., Suite 101
Mechanicsburg, PA 17050
Phone: 717.795.2741
Fax: 717.795.2743
dwilliamson@,spilmanlaw.com
bnaum@,spilmanlaw.com
Counsel to SWVA, Inc., and the West Virginia Energy
Users Group
14
CERTIFICATE OF SERVICE
I, Lee F. Feinberg, counsel to SWVA, Inc. and the West Virginia Energy Users Group do
hereby certify that on this 8" day of January 2016, a copy of the foregoing "Reply Brief of
SWVA, Inc. and the West Virginia Energy Users Group" was served upon the parties and/or
counsel of record in this proceeding as follows:
VIA HAND DELIVERY
David Sade, Esquire
Staff Attorney
Public Service Commission of West Virginia
201 Brooks Street
Charleston, WV 25301
Counsel for Commission Staff
VIA U.S. MAIL
John Philip Melick, Esquire
Christopher L. Callas, Esquire
Stephen N. Chambers, Esquire
Jackson Kelly PLLC
P.O. Box 553
Charleston, WV 25322
Counsel for West Virginia-American
Water Company
Andrew T. Gunnoe, Esquire
Kanawha County Commission
P.O. Box 3627
Charleston, WV 25336
and
Marc J. Slotnick, Esquire
Bailey & Wyant, PLLC
P.O. Box 3710
Charleston, WV 25337
Counsel for Kanawha County
Commission and Kanawha County
Regional Development Authority
Tom White, Esquire
Consumer Advocate Division
700 Union Building
723 Kanawha Boulevard, East
Charleston, WV 25301
Counselfor Consumer Advocate
Division
Paul R. Sheridan, Esquire
429 McKinley Avenue
Charleston, WV 25314
Counselfor Advocates for a Sa@ Water
System
Paul D. Ellis, Esquire
Mandi Kay Carter, Esquire
City of Charleston
501 Virginia Street, East
Charleston, WV 25301
Counselfor City of Charleston