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LAW OFFICES BRESNAN & HERDER R. Rex Herder, Jr. Joseph E. Bresnan 311 Lindenwold Avenue Ambler, PA 19002 (215) 646-4440 FAX (215) 641-9563 June 11.2007 James J. McNulty Secretary PA Public Utility Commission North Office Bldg. P.O. Box 3265 Harrisburg, PA 17105-3265 RE: PA Public Utility Commission v. Borough of Ambler Water Dept. No. R-00062017C0004 Dear Secretary McNulty: Enclosed you will find in triplicate a tariff supplement reflecting the mandatory six month suspension of tariff rates by operation of law, in addition to a second one reflecting the 60 day extension to allow for the mediation process. Both are being served upon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine Hoover, Esq. Office of Small Bus. Advocate Dennis Kalbarczyk Richard Shorin Mame Nunez Jerome Caplan Theresa McSpadden JUN 2 1 2007 to Pi o m —t-o cr CD- cr m 3> r-o o •* po rn o m < rn o

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Page 1: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

LAW OFFICES

BRESNAN & HERDER

R. Rex Herder, Jr. Joseph E. Bresnan

311 Lindenwold Avenue Ambler, PA 19002

(215) 646-4440 FAX (215) 641-9563

June 11.2007

James J. McNulty Secretary PA Public Utility Commission North Office Bldg. P.O. Box 3265 Harrisburg, PA 17105-3265

RE: PA Public Utility Commission v. Borough of Ambler Water Dept. No. R-00062017C0004

Dear Secretary McNulty:

Enclosed you will find in triplicate a tariff supplement reflecting the mandatory six month suspension of tariff rates by operation of law, in addition to a second one reflecting the 60 day extension to allow for the mediation process. Both are being served upon all parties of record, as shown on the enclosed certificate of service.

Very truly yours,

'eph E. Bresnan

JEB/ed Enclosures cc: Charles Shields, Esq.

Christine Hoover, Esq. Office of Small Bus. Advocate Dennis Kalbarczyk Richard Shorin Mame Nunez Jerome Caplan Theresa McSpadden JUN 2 1 2007

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Page 2: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

Joseph E. Bresnan, Esq. Atty. ID #44017 BRESNAN & HERDER 311 Lindenwold Ave. Ambler, PA 19002 (215) 646-4440

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RE: PA Public Utility Commission v. Borough of Ambler Water Dept. No. R-00062017COO(#

CERTIFICATE OF SERVICE

I hereby certify that on this twelfth day of June, 2007, true and correct copies of

the Borough of Ambler's Tariff Supplements, in the above referenced matter were served

by first class mail upon the following persons:

Mame P. Nunez 516 S.Bethlehem Pike Ambler, PA 19002

Dennis Kalbarczyk Utility Rate Resources 910 Piketown Rd. Harrisburg, PA 17112

Jerome Caplan 311 Gentry Lane Ambler, PA 19002

Theresa E. McSpadden 408 Stuart Lane Ambler, PA 19002

Charles Shields, Esq. Office of Trial Staff PA Public Utility Comm. P.O. Box 3265 Harrisburg, PA 17105

Office of Small Business Advocate Commerce Bldg., Suite 1102 300 N. Second Street Hamsburg, PA 17101

Richard Shorin 255 Ridings Way Ambler, PA 19002

Christine Maloni Hoover, Esq. Counsel for Office of Consumer Advocate 555 Walnut St., 5 lh Floor Harrisburg, PA 17101

Date: Jseph E. Bresnan, Esquire

'Solicitor. Ambler Borough

C:\Sh3redUOE\AMBLER\PUC.2007RateIncreasc\cen.serv.tari ir.supp.6.12,07.doc

Page 3: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

BOROUGH OF AMBLER SUPPLEMENT No. 33 WATER - PA P.U.C. No. 5

TariffNo. 1

BOROUGH OF AMBLER. WATER DEPARTMENT DfVfSION

Servicing customers outside the Borough of Ambler in the Townships of Upper Dublin, Whitemarsh, Whitpain, and Lower Gwynedd. all in Montgomery County, Pennsylvania.

The application of rates proposed in Supplement No. 33 to Tariff Water-Pa. P.U.C. No. 5 filed to become effective May 16, 2007, is hereby suspended until December 16, 2007, by operation of law at Docket No. R-62017. Presently effective rates contained in Tariff Water - Pa. P.U.C. No. 5 and supplements thereto, will continue in effect until otherwise amended.

Issued: May 16. 2007 Issued in compliance with Title 66 PAC.S. § 1308 (d)

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Page 4: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

BOROUGH OF AMBLER SUPPLEMENT No. 33 WATER-PA P.U.C. No. 5

TariffNo.2

BOROUGH OF AMBLER. WATER DEPARTMENT DIVISION

Servicing customers outside the Borough of Ambler in the Townships of Upper Dublin, Whitemarsh, Whitpain, and Lower Gwynedd, all in Montgomery County, Pennsylvania.

The application of rates proposed in Supplement No. 33 to Tariff Water-Pa. P.U.C. No. 5 filed to become effective December 16, 2007, is hereby suspended until May 15, 2008, to allow for agreed medication by the parties at Docket No. R-62017. Presently effective rates contained in Tariff Water - Pa. P.U.C. No. 5 and supplements thereto, will continue in effect until otherwise amended.

Issued: June 12, 2007 Issued in compliance with Title 66 PAC.S. § 1308 (d) and 52 PA-ADC 69.392 (d)(2)

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Page 5: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

R. Rex Herder, Jr. Joseph E. Bresnan

LAW OFFICES

BRESNAN & HERDER

311 Lindenwold Avenue Ambler, PA 19002

(215) 646-4440 FAX (215) 641-9563

June 19,2007

James J. McNulty Secretary PA Public Utility Commission North Office Bldg. P.O. Box 3265 Harrisburg, PA 17105-3265

RE: PA Public Utility Commission v. Borough of Ambler Water Dept. No. R-00062017C0004

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Dear Secretary McNulty:

Enclosed you will find in triplicate, the Borough's Answer to Office of Trial Staffs Motion to Compel Discovery. The Answer will be served all parties, as shown on the enclosed certificate of service. I have also enclosed an extra copy for time stamp and return in the envelope provided. Thank you.

Very truly yours.

Joseph I T Bresnan

JEB/ed Enclosures cc: Charles Shields, Esq.

Christine Hoover, Esq. The Honorable Charles E. Rainey

Page 6: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION

Pennsylvania Public Utility Commission

Borough of Ambler- Water Dept. R-00062017

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BOROUGH OF AMBLER'S ANSWER TO OFFICE OF TRIAL STAFF MOTION TO COMPEL DISCOVERY

The Borough of Ambler, by and through its counsel. Joseph E. Bresnan and pursuant to 52 Pa. Code s. 5.342, responds as follows to the Office of Trial Staffs Motion to Compel:

1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. By way of further answer, trial staff represented that no motion would

be filed if substantive answers were received to a majority of their outstanding requests. However, the instant motion was filed without any further dialogue from trial staff or statement of an intention to file.

5. Admitted. However, such answers have now all been supplied by email and overnight delivery.

6. Admitted. By way of further answer, answers were not yet completed by Borough staff and the consultant.

7. All such requests have been answered. 8. OTS-RB-10-D, requesting the system map, has been answered, since it was

included in the overnight delivery sent from the undersigned's office on June 18, 2007.

9. See answer 8. By way of further answer, it is anticipated that all parties will sign a confidentiality agreement.

10. As of June 18, 2007, the Borough did object to any use by trial staff of its consultant's cost of service study, deeming it proprietary. The undersigned inquired by email of trial staff whether it would accept the document in .pdf format. Trial staff has elected to not reply to that and other emails from the undersigned. However, upon a re-reading of the request at issue, it does not specify a particular format, and accordingly, the document will be promptly forwarded to trial staff in .pdf format, rendering this and all aspects of the motion to compel moot.

FOLDER JUL 2 - 2007

Page 7: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

11. Such confidentiality agreement is forthcoming. 12. No such relief is required, as the motion to compel is moot by virtue of the

Borough's answers having been submitted to the requestor.

Respectfully submitted,

Jseph .̂ Bresnan Solictor, Borough of Ambler Bresnan & Herder 311 Lindenwold Ave. Ambler, PA 19002 (215)646-4440 Atty. ID 44017

Date: June 19, 2007

Page 8: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

BEFORE THE PENNSYLVANIA PUBUC UTILITY COMMISSION

Docket No. R-00062017C0001

Pennsylvania Public Utility Commission

v.

Borough Of Ambler -Water Department

CERTIFICATE OF SERVICE

I hereby certify that on this 19Ul day of June, 2007, true and correct copies of the Borough

of Ambler's Answer to Office of Trial Staff Motion to Compel Discovery, in the above

referenced matter was served by first class mail upon the following persons:

The Honorable Charles E. Rainey Administrative Law Judge

Pennsylvania PUC PO Box 3265 Harrisburg, PA 17105-3265

Christine Maloni Hoover, Esq. Counsel for Office of Consumer Advocate

555 Walnut St., 5!h Floor Harrisburg, PA 17101

Charles Shields, Esq. Office of Trial'Staff

PA Public Utility Comm. P.O. Box 3265

Hamsburg, PA 17105

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Date:

RE. Bresnan, Esq. tomey I.D. No. 44017

Solicitor, Ambler Borough Bresnan & Herder 311 Lindenwold Ave. Ambler, PA 19002

Page 9: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

R. Rex Herder, Jr. Joseph E. Bresnan

LAW OFFICES

BRESNAN & HERDER

311 Lindenwold Avenue Ambler, PA 19002

(215) 646-4440 FAX (215) 641-9563

James J. McNulty Secretary PA Public Utility Commission North Office Bldg. P.O. Box 3265 Harrisburg, PA 17105-3265

July 11,2007

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RE: PA Public Utility Commission v. Borough of Ambler Water Dept. No. R-00062017

Dear Secretary McNulty:

Enclosed is a revised Tariff 2 which is issued to correct a typographical error in the previously forwarded copy. The previous document incorrectly stated the new effective date, which has been changed from May 15 to February 14 to reflect the addition of 60 days for mediation to the previous effective date of December 16th. Also, the word "mediation" was incorrectly spelled in the prior document. I apologize for any inconvenience. A Certificate of Service is also enclosed.

JEB/ed Enclosures cc: Charles Shields, Esq.

Christine Hoover, Esq. Marilyn J. Kraus Mame Nunez Dennis Kalbarczyk Richard Shorin Jerome Caplan Theresa E. McSpadden Office of Small Business Advocate

Very tj^ly your;

Joseph E. Bresnan

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Page 10: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

BOROUGH OF AMBLER

TariffNo.2

SUPPLEMENT No. 33 / n WATER - PA P.U.C. No. 5,

U D

BOROUGH OF AMBLER, WATER DEPARTMENT DIVISION

Servicing customers outside the Borough of Ambler in the Townships of Upper Dublin, Whitemarsh, Whitpain, and Lower Gwynedd, all in Montgomery County, Pennsylvania.

The application of rates proposed in Supplement No. 33 to Tariff Water-Pa. P.U.C. No. 5 filed to become effective December 16. 2007, is hereby suspended until February 14, 2008, to allow for agreed mediation by the parties at Docket No. R-62017. Presently effective rates contained in Tariff Water - Pa. P.U.C. No. 5 and supplements thereto, will continue in effect until otherwise amended.

Issued: June 12, 2007

DOCUMEM , FOLDER

Issued in compliance with Title 66 PAC.S. § 1308 (d) and 52 PA-ADC 69.392 (d)(2)

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Page 11: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

Joseph E. Bresnan, Esq. Atty. ID #44017 BRESNAN & HERDER 311 Lindenwold Ave. Ambler, PA 19002 (215) 646-4440

RE: PA Public Utility Commission v. Borough of Ambler Water Dept. No. R-00062017

CERTIFICATE OF SERVICE

I hereby certify that on this eleventh day of July, 2007, true and correct copies of

the Borough of Ambler's Revised Tariff Supplement, in the above referenced matter

were served by first class mail upon the following persons:

Marne P. Nunez 516 S. Bethlehem Pike Ambler, PA 19002

Dennis Kalbarczyk Utility Rate Resources 910 Piketown Rd, Harrisburg, PA 17112

Jerome Caplan 311 Gentry Lane Ambler, PA 19002

Theresa E. McSpadden 408 Stuart Lane Ambler, PA 19002

Marilyn J. Kraus Office of Consumer Advocate 555 Walnut St., 5 th Floor Harrisburg, PA 17101

Charles Shields, Esq. Office of Trial Staff PA Public Utility Comm. P.O. Box 3265 Harrisburg, PA 17105

Office of Small Business Advocate Commerce Bldg., Suite 1102 300 N. Second Street Harrisburg, PA 17101

Richard Shorin 255 Ridings Way Ambler, PA 19002

Christine Maloni Hoover, Esq. Counsel for Office of Consumer Advocate 555 Walnut St., 5 lh Floor Harrisburg, PA 17101

Date: ? ' ( < ' H J/̂ geph E. Bresnan, Esquire

licitor. Ambler Borough

C:VSharedUOE\AMBLER\PUC.2007Raielncrease\cert.serv,tariff.supp.revised.6.12.07.doc

Page 12: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

LAW OFFICES

BRESNAN & H E R D E R 311 LINDENWOLD AVENUE

AMBLER, PA 19002

R. REX HERDER, JR. ( 2 1 5 ) 646-4440 JOSEPH E. BRESNAN FAX (215) 641-9563

July 11,2007

Bv First Class Mail and Fax The Honorable Charles E. Rainey, Jr. R P O t l l / r ~ Commonwealth of Pennsylvania ^ ^ t i v PA Public Utility Commision Office of Administrative Law Judge J g 2007

"-SA 17105 ^^SSSSHSSP^ RE: PUC v. Borough of Ambler

No. R-00062017

Dear Judge Rainey:

I am here forwarding by fax and regular mail Ambler's pre-hearing memorandum in the above-captioned matter. If you do not accept the fax and concurrent mailing as satisfying the "in hand" requirement, please have your staff call my office at the above number and the memorandum will be sent today by overnight delivery.

Respectfully.

A* Joseph'E. Bresnan

JEB/ed Enclosure cc: Charles Shields, Esq.

Christine Hoover CD

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Page 13: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

9 9 BEFORE THE PENNSYLVANIA PUBLIC UTILITIES COMMISSION

Administrative Law Judge Charles Rainey

PENNSYLVANIA PUBLIC UTILITY COMMISSION

V No. 00062017

BOROUGH OF AMBLER

PREHEARING MEMORANDUM OF BOROUGH OF AMBLER

I. BACKGROUND

1. Ambler Borough provides water service to customers in the surrounding townships of Lower Gwynedd. Whitemarsh, Whitpain, and Upper Dublin, and to residents of Ambler Borough, all in the county of Montgomery.

2. On January 31, 2007, Ambler filed Supplement 33 to Water Pa PUC No. 5, to become effective April 16, 2007, containing proposed changes in rates, rules and regulations that would increase revenues by $454,798.00 per year.

3. Upon request from the Office of Consumer Advocate ("OCA"), Ambler agreed to a thirty day extension of the effective date, to May 16,2007.

4. Pursuant to an Order dated May 10, 2007, the Public Utility Commission ("Commission") instituted a formal investigation into Ambler's filing, and suspended Supplement 33 until December 16, 2007.

5. The effective date was extended another 60 days from December 16, 2007, until February 14, 2007. Due to an error, tariff 2 incorrectly listed this date as May instead of February, and is being revised presently.

6. A mediation session is scheduled in Harrisburg for July 19, 2007, and prior thereto, prehearing memoranda are due July 12, 2007.

II. REASONS FOR RATE INCREASE

7. Current rates are insufficient to cover the cost of providing service. 8. The reasons stated in the information in support of the rate filing, whicho

includes, inter alia, the construction of the new water tower on Loch Alsh_ Avenue, as well as, for reasons to be given through testimony and exhibits1

at the time of hearing. P̂* ^ „_

'~a' III. COMPLAINTS/INTERVENTIONS ^ £ .;J^

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Page 14: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

9. A formal complaint was filed by OCA (C004); and PUC trial staff has intervened. Additionally, customer complaints were filed by: Jerome Kaplan (C001); Richard Shorin (C002); Marne Nunez (COOS).

IV. ISSUES

10. Ambler will provide testimony and exhibits to demonstrate that current rates are not compensatory, do not cover the cost of providing service, and are just and reasonable. Given the broad reach of the discovery propounded by OCA and Trial Staff, Ambler cannot hazard any guesses as to issues that are seen by those objecting to the proposed increase.

V. WITNESSES

11. In addition to the witnesses identified below, Ambler reserves the right to call any other witness who can best address any issue identified through discovery or from information obtained from outside sources, or to rebut a position taken by any other party at evidentiary or public input hearings, or to address any issue raised by the administrative law judge at the time of hearing. Subject to such reservation, Ambler intends to call:

a. Dennis M. Kalbarczyk, Utility Rate Resources, 910 Piketown Rd, Harrisburg, PA 17112, on ratemaking issues.

b. Robert Schmauk, Gilmore and Associates, 350 E. Butler Ave., New Britain, PA, 18901, telephone 215-345-4330, on facilities and service issues.

VI. PROCEDURAL ISSUES

12. Ambler has reviewed several emails from the objecting parties and agrees to the proposed schedule as set forth in an email from trial staff sent on the afternoon of July 10, 2007. That proposed schedule, as simply "copied and pasted" from trial staffs email, is as follows:

July 19 Prehearing Conference

Aug. 14 (Tue) Distribute Borough Direct Testimony

Sept. 11 (Tue) Distribute Direct Testimony (all parties other than Company)

Oct. 2 (Tues) Distribute Rebuttal Testimony In-Hand (all parties)

Oct. 11 (Thur) Distribute Surrebuttal Testimony In-Hand

(all parties)

Page 15: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

Oct. 18-19 (Thur-Fri) Hearings in Harrisburg

Nov. 2 (Fri) Main Brief

Nov. 13 (Tue) Reply Brief

Respectfully submitted.

seph E. Bresnan, Esq. Solicitor, Borough of Ambler Attorney ID 44017 Bresnan & Herder 311 Lindenwold Ave. Ambler, PA 19002 (215)646-4440 fax (215) 641-9563 [email protected]

Page 16: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

R. Rex Herder, Jr. Joseph E. Bresnan

LAW OFFICES

BRESNAN & HERDER O R l G i r ^

311 Lindenwold Avenue Ambler, PA 19002

(215) 646-4440 FAX (215) 641-9563

James J. McNulty Secretary PA Public Utility Commission North Office Bldg. P.O. Box 3265 Harrisburg, PA 17105-3265

July 11,2007

DOCUMENT FOLDER

RECEIVED JUL 1 1 2007

PUBUG UTILITY CQMMI§SI9N SECRETARY'S iUftiAU

RE: PA Public Utility Commission v. Borough of Ambler Water Dept. No. R-00062017

Dear Secretary McNulty:

Enclosed you will find in triplicate, the Borough's Answer to Office of Consumer Advocates Interrogatories, Set III, along with an attachment not a part of the e-mailed answers. Also enclosed is a revised answer to a previous interrogatory. No. 9, Set II. The Answers will be served all parties, as shown on the enclosed certificate of service. I have also enclosed an extra copy for time stamp and return in the envelope provided. Thank you.

Very truly yours,

Jo'seph£!E. Bresnan

JEB/ed Enclosures cc: Charles Shields, Esq.

Christine Hoover, Esq. Marilyn J. Kraus The Honorable Charles E. Rainey

Page 17: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

€1 BEFORE THE ORIGINAL

PENNSYLVANIA PUBLIC UTILITY COMMISSION

Pennsylvania Public Utility Commission

v. Docket No. R-00062017

Borough Of Ambler-Water Department

Borough of Ambler's Set of Answers to the Office of Consumer Advocate's Interrogatories, Set III

Attached hereto, in sequential order, are the answers of the Borough of Ambler

to the Office of Consumer Advocate's Interrogatories, Set III, each preceded by a

restatement of the interrogatory and a statement of the individual(s) providing answers

thereto. Relevant documents are attached.

Respectfully submitted,

BRESNAN & HERDER 311 Lindenwold Avenue Ambler, PA 19002 (215) 646-4440 (215) 641-9563 (Fax)

JUL 1 3 20«

DOCUMENT FOLDER

rseph E. Bresnan, Esquire 'A Attorney I.D. 44017

Counsel for Borough of Ambler Water Department

Dated: July 2007

RECEIVED JUL 11 2 W

Page 18: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

r^^MBLER BOROUGH WATER 4 ^ DOCKET R-00062017

SET III INTERROGATORIES

PENNSYLVANIA PUBLIC UTILITY COMMISSION v.

BOROUGH OF AMBLER - WATER DEPARTMENT DOCKET NO. R-00062017

INTERROGATORIES OF THE OFFICE OF CONSUMER ADVOCATE SET III

I. Provide the following information related to the distribution system valves:

ANSWER: Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created June 22, 2007

a. The number of valves categorized by age, size and location.

• The attached confidential "Summary of Street Intersection Roster and Valve Inventory" document reveals number of valves categorized by size and location. Additionally, it summarizes total valves by municipality. Ambler Borough Water does not have available any listings of valves by age. We can safely say that approximately 70 percent of the valves in our distribution system are over 50 years old. Valves in certain parts of Ambler (Lindenwold Street, parts of Butler Avenue) and numerous valves that were in the Bodenstein system are over 100 years old.

b. All written records of valve exercising that indicate which valves require maintenance or replacement (i.e., number and location of valves that failed to fully open, etc.) and

• Due to perceived expense, manpower requirements and the concern about repair work that may be created we initiated a modest valve exercising program this year. While our goal is to make accessible all valves, determine high and low risk valves to exercise and utilize Borough workforce to exercise same this new preventive maintenance project reflects only the very early stages of this new program. As such, records do not exist relative to which specific valves require maintenance or replacement but in any case, all valves will require exercising, and beyond determining valve replacement by age of valve, it is anticipated that some valves will "fail" during the course of such exercising. We provide the following history as it relates to the past ten years for valves that failed and had to be replaced:

Page 19: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

• PUC^TMBLER BOROUGH WATER DOCKET R-00062017

SET III INTERROGATORIES

1. Bethlehem Pike and Willow Avenue (4") 2. Knight Road and Francis Avenue (4") 3. Highland Avenue and Summit Avenue (6") 4. Madison Avenue and Hartranft Avenue (6") 5. Loch Alsh Avenue and Farm Lane (8") 6. Hartranft Avenue and Madison Avenue (6") 7. Belmont Avenue and Hendricks Street (6") 8. Spring Garden Street and Brookside Avenue (4") 9. Bethlehem Pike (between Ellerslie & Stuart) (6") 10. Ambler Road and Orchard Lane (6") 11. Spring Avenue and Elliger Avenue (4") 12. Madison Avenue and Spring Avenue (4") 13. Poplar Street and York Street (6") 14. S. Main Street and Orange Avenue (4' ,)

c. A copy of any studies conducted indicating the extent of necessary valve replacements.

• We have not conducted any studies specifically as regards to valve replacement but, however, are working under a general rule of thumb to identify and prioritize valve replacement based upon the age of these valves.

Page 20: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

: ^ ^ M B L E R BOROUGH WATER fl) pua_ DOCKET R-00062017

SET III INTERROGATORIES

2. Refer to Schedule 1-15. Provide a detail of the $32,500 cost of the valve maintenance program that lists the estimate of each individual cost item included in this estimate, including estimate of Borough labor, outside labor, materials, etc.

ANSWER: Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created June 22, 2007

The valve maintenance program will encompass (1) locating valves; (2) fully exercising valves; (3) maintaining detailed valve records; and (4) scheduling and performing needed repairs both proactively and as valve failures might occur. The $32,500 annual cost of the valve maintenance program is a cyclical annual program to address the 858-pIus valves in our distribution system. The development of the estimate is as follows:

Estimated labor cost to expose and exercise a vale is estimated at $100 of labor per valve of which the Borough estimated that 50 would be done at a total labor cost of $5:000. The Borough estimates that the cost to perform extensive maintenance such as repacking and new seals would cost $2,500 per value. Due to the age ofthe values it was estimated that 12 values would be refurbished at a cost of $30,000. In order to provide some context to the scope of the work the total cost for the full replacement of a 12" and 10" value approximates $10,000 and S9,500 each, respectively.

Page 21: BRESNAN & HERDER - PUCupon all parties of record, as shown on the enclosed certificate of service. Very truly yours, 'eph E. Bresnan JEB/ed Enclosures cc: Charles Shields, Esq. Christine

: ^ k l B L E R BOROUGH WATER 4 ) PUC' _ DOCKET R-00062017

SET III INTERROGATORIES

3- Is the Borough going to hire additional employees to perform the new valve maintenance program?

ANSWER: Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created June 22, 2007

• Because we never have had a formalized valve maintenance program, we are taking a cautious approach. Initially, we intend to utilize Borough employees to locate and make accessible all valves in our distribution system. As we proceed, and have a better concept of the time needed to evaluate and exercise our entire distribution system, it is our intention to fully assess our need to hire a dedicated employee for this program or to contract out our valve exercising program to work crews whose expertise is valve exercising.

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:^IMBLER BOROUGH WATER © PUC^_ DOCKET R-00062017

SET 111 INTERROGATORIES

4. Are valve replacements going to be made by Borough employees or independent contractors?

ANSWER: Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created June 22,2007

• Whether Borough employees will be able to undertake valve work is based upon the size ofthe job and the size of the valves themselves. We have the capability to handle 4", 6" and S'1 valves using Borough employee labor. Valves that are 10" or 12" in size are beyond our capability, and those jobs will be contracted out. Also, at times, we probably will need to contract out so as to not interrupt the supply of water to our customers for an extended period of time should there be a large section of pipeline affected.

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^ J C v. AMBLER BOROUGH W A T E ^ DOCKET R-00062017

SET III INTERROGATORIES

5. Refer to Schedule E-3, specifically tbe 520,000 original cost claim for 1st year valve replacements. List the number, size and location of valves that the Borough expects to replace and the basis for this projection.

ANSWER: Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created June 22, 2007

The following three valve replacement projects are considered to be highest priority by Ambler Borough Water due specifically to the advanced age of the valves. The Borough will select from valve replacements listed to be undertaken during the first year of the program and will schedule completion of the remaining valve replacement projects in subsequent years:

• Lindenwold Terrace (80+ year old valves): $ 19,944 Line Stop Clamps/purchase/contracted installation 2-12" Gate Valves/purchase/contracted installation Excavations/restorations

• Lindenwold Avenue (80+ year old valves): $ 27,648 Line Stop Clamps/purchase/contracted installation 4- 10" Gate Valves/purchase/contracted installation Excavations/restorations

• Butler Avenue (80+ year old valves): $ 32,160 Line Stop Clamps/purchase/contracted installation 5- 10" Gate Valves/purchase/contracted installation Excavations/restorations

Costs are based on the following estimates:

12" Line Stop Clamp - purchase & contracted installation $ 5,200 12" Gate Valve- purchase $ 1,245 12" Valve installation (labor & equipment) - contracted $ 1,550 Excavation & restoration $ 1,977

10" Line Stop Clamp - purchase & contracted installation $ 4,800 10" Gate Valve - purchase $ 985 10" Valve installation (labor & equipment) - contracted $ 1.550 Excavation & restoration $ 1,977

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Z^^MBLER BOROUGH WATER 4 ) DOCKET R-00062017

SET 111 INTERROGATORIES

6. With respect to the $20,000 capital claim for valve replacements, indicate, other than the cost of valves, what other cost items (labor, etc.) are included in this claim.

ANSWER: Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created June 22, 2007

See Answer #5

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PUC BLER BOROUGH WATER DOCKET R-00062017

SET III INTERROGATORIES

7. Refer to the response to OCA Interrogatory Set I I , No. 29 related to unaccounted for water. For each year (2004, 2005 and 2006) provide the numbers referenced in that response, specifically, the total gallons of water pumped per the SCADA system, total gallons of water sold and total gallons of water related to hydrant flushing.

ANSWER; Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created June 22,2007

2004: Total Gallons Water Pumped: 621,363,053 Total Gallons Sold: 532,282,950 Total Gallons Hydrant Flushing: 52,170,006 Total Gallons Unaccounted For: 36,910,002 (6% unaccounted)

2005: Total Gallons Water Pumped: 645,312,156 Total Gallons Sold: 526,282,550 Total Gallons Hydrant Flushing: 78,655,310 Total Gallons Unaccounted For: 40,374,110 (7% unaccounted)

2006: Total Gallons Water Pumped: 620,306,185 Total Gallons Sold: 469,259,330 Total Gallons Hydrant Flushing: 70,419,085 Total Gallons Unaccounted For: 80,627,770 (13% unaccounted)

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o ORIGINAL

PENNSYLVANIA PUBLIC UTILITY COMMISSION v.

BOROUGH OF AMBLER - WATER DEPARTMENT DOCKET NO. R-00062017

INTERROGATORIES OF THE OFFICE OF CONSUMER ADVOCATE SET HI

QUESTION #1

ATTACHMENT

RECEIVED JUL I 1 2007

PA PUBUC UTILITY COMMISSION

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

SUMMARY OF STREET INTERSECTION ROSTER & VALVE INVENTORY

MUNICIPALITY TOTALS MUNICIPAL 4" I 6" 8" 10" 12" TOTALS

AMBLER BOROUGH 122 72 15 10 0 219

LOWER GWYNEDD TOWNSHIP 18 39 40 1 7 1.05

UPPER DUBLIN TOWNSHIP 102 116 125 1 9 353

WHITEMARSH TOWNSHIP 12 30 28 5 1 76

WHITPAIN TOWNSHIP 13 50 42 0 0 105

TOTALS —> 267 307 250 17 17 858

GRAND TOTAL ---> 858

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

AMBLER BOROUGH INTERSECTION STREET AT VALVES

NO. 4" 6" 8" 10" 12" 1 ANDERSON LANE TENNIS AVENUE 1

2 ARTMAN ROAD CHERRY LANE 1 3 ARTMAN ROAD OVERLOOK ROAD 2

4 BANNOCKBURN AVE.. MAIN STREET 1 5 BANNOCKBURN AVE. S. SPR'G GARDEN ST 1 6 BANNOCKBURN AVE. CHURCH STREET 1

7 BEECHMONT ROAD CANDY LANE 1 1 8 BEECHMONT ROAD OVERLOOK ROAD 3

9 BELMONT AVENUE MAIN STREET 1 10 BELMONT AVENUE SPRING GARDEN ST. 1 11 BELMONT AVENUE RIDGE AVENUE 1 1 12 BELMONT AVENUE HENDRICKS STREET 1 2 13 BELMONT AVENUE GLEN MAWR 2

14 BETHLEHEM PIKE MT. PLEASANT AVE. 3 15 BETHLEHEM PIKE TENNIS AVENUE • 1 16 BETHLEHEM PIKE VALLEYBROOK ROAD 2 17 BETHLEHEM PIKE FORESTAVENUE 1 18 BETHLEHEM PIKE FAIRVIEW AVENUE 1 19 BETHLEHEM PIKE BUTLER AVENUE 1 20 BETHLEHEM PIKE WOODLAND AVENUE 1 21 BETHLEHEM PIKE LINDENWOLD AVE. 1 22 BETHLEHEM PIKE EUCLID AVENUE 2

. 23 BETHLEHEM PIKE MATT!SON AVENUE 1 24 BETHLEHEM PIKE CHURCH STREET 2

25 BUTLER AVENUE WISSAHICKON CREEK 2 26 BUTLER AVENUE LOCUST STREET 1 1 27 BUTLER AVENUE CHESTNUT STREET 2 28 BUTLER AVENUE MAPLE STREET 2 29 BUTLER AVENUE MAIN STREET 1 1 1 30 BUTLER AVENUE SPRING GARDEN ST. 2 31 BUTLER AVENUE CAVALIER DRIVE 1 32 BUTLER AVENUE RIDGE AVENUE 2 1 33 BUTLER AVENUE YORK STREET 1

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

AMBLER BOROUGH INTERSECTION STREET AT VALVES

NO. 4" 6" 8" 10" 12" 34 BUTLER AVENUE LINDENWOLD AVE. 1 2 35 BUTLER AVENUE RACE ST (PARK AVE.) 1 1 36 BUTLER AVENUE HENDRICKS STREET 2 37 BUTLER AVENUE WOODLAND AVENUE 1 38 BUTLER AVENUE ROSEMONT AVENUE 2

0 39 CANDY LANE MT. PLEASANT AVE. 1 40 CANDY LANE WALKER ROAD 1

41 CENTER STREET CHESTNUT STREET 1 42 CENTER STREET LOCUST STREET 1

43 CHERRY LANE TENNIS AVENUE 3 2 44 CHERRY LANE HAYWOOD DRIVE 1

45 CHESTNUT STREET WISSAHICKON AVE. 1

46 CHURCH STREET SW END (AWTP) 1 47 CHURCH STREET MAIN STREET 4 48 CHURCH STREET SOUTHERN AVENUE 1 49 CHURCH STREET HIGHLAND AVENUE 2 50 CHURCH STREET TRINITY AVENUE 1 51 CHURCH STREET ROSEMARY AVENUE 1

52 COVE ROAD EDGEWOOD DRIVE 3 53 COVE ROAD TENNIS AVENUE 1

54 DOC'S COURT MT. PLEASANT AVE. 1 1

55 EDGEWOOD DRIVE HENDRICKS STREET 1 1

56 EUCLID AVENUE PARK AVENUE 3 57 EUCLID AVENUE NORTH STREET 4

58 FAIRVIEW AVENUE HENDRICKS STREET 1 59 FAIRVIEW AVENUE ROSEMONT AVENUE 3

60 -OREST AVENUE MAIN STREET 1 2 61 =ORESTAVENUE SPRING GARDEN ST. 1

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# 4 AMBLER BOROUGH WATER DEPARTMENT

MONTGOMERY COUNTY, PENNSYLVANIA STREET INTERSECTION ROSTER

& VALVE INVENTORY

AMBLER BOROUGH INTERSECTION STREET AT VALVES

NO. 4" 6" 8" 10" 12" 62 FORESTAVENUE RIDGE AVENUE 1 1 63 FORESTAVENUE SCHOOL STREET 1 64 FORESTAVENUE WALNUT LANE 1 65 FOREST AVENUE HENDRICKS STREET 1 2 66 FOREST AVENUE GLEN MAWR DRIVE 1

67 FULLING MILL ROAD TENNIS AVENUE 1

68 GREENWOOD AVE. LINDENWOLD AVE. 1 69 GREENWOOD AVE. MATTISON AVENUE 2

70 GRISTMILL COURT HENDRICKS STREET 1

71 HAYWOOD ROAD TENNIS AVENUE 1

72 HECKLER STREET HENDRICKS STREET 2 1 73 HECKLER STREET ROSEMONT AVENUE 3

74 HENDRICKS STREET MT. PLEASANT AVE. 2 1 . 75 HENDRICKS STREET WALKER ROAD 1

76 HENDRICKS STREET TENNIS AVENUE 2 77 HENDRICKS STREET VALLEYBROOK ROAD 1

78 HIGHLAND AVENUE S. SPRING GARDEN ST. 1 79 HIGHLAND AVENUE PARK AVENUE 2

80 LEMON STREET ROSEMARY AVE. 1 81 LEMON STREET TRINITY AVENUE 1

82 LINDENWOLD AVE. RACE STREET 2 83 LINDENWOLD AVE. POPLAR 1 84 LINDENWOLD AVE. PARK AVENUE 2 1 85 LINDENWOLD AVE. NORTH STREET 1

86 LOCUST STREET WISSAHICKON AVE. 1 .

87 VIA IN STREET MT. PLEASANT AVE. 1 88 VIAIN STREET TENNIS AVENUE 1 1 89 I WAIN STREET WALNUT STREET 1 2

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

AMBLER BOROUGH INTERSECTION STREET . AT VALVES

NO. 4" 6" 8" 10" 12" 90 MAIN STREET RACE STREET 1

12"

91 MAIN STREET POPLAR STREET 0 92 MAIN STREET ORANGE AVENUE 2

93 MAPLE AVE. WISSAHICKON AVE. 1 1

94 MATTISON AVENUE POPLAR STREET t 95 MATTISON AVENUE WATER STREET 2 96 MATTISON AVENUE PARK AVENUE 3 1 97 MATTISON AVENUE NORTH STREET 2

98 MT. PLEASANT AVE. RAILROAD 1 99 MT. PLEASANT AVE. N. SPR'G GARDEN ST. 4 100 MT. PLEASANT AVE. NORTH RIDGE AVE. 1 101 MT. PLEASANT AVE. PLEASANT ACRES DR. 1 102 MT. PLEASANT AVE. REIFFS MILL ROAD 3 103 MT. PLEASANT AVE. OVERLOOK ROAD 1

104 NORTH STREET WOODLAND AVENUE 2 1 105 NORTH STREET ROSEMARY AVENUE 2 106 NORTH STREET TRINITY AVENUE 0

107 ORANGE AVENUE ROSEMARY AVE. 2 108 ORANGE AVENUE S. SPR'G GARDEN ST. 2 109 ORANGE AVENUE TRINITY AVENUE 1

110 OVERLOOK ROAD WALKER ROAD 1

111 PARK AVENUE ROSEMARY AVENUE 1 1 112 PARK AVENUE TRINITY AVENUE 1-113 PARK AVENUE SOUTHERN AVENUE 1 114 PARK AVENUE @ WELL NO.. 11 DRIVE 3

115 POPLAR STREET ROSEMARY AVENUE 0 116 POPLAR STREET RIDGE AVENUE 0 117 POPLAR STREET YORK STREET 2

118 RACE STREET 3PRING GARDEN ST. 1 2 119 =?ACE STREET f RIDGE AVEUE 2

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

LOWER GWYNEDD TOWNSHIP INTERSECTION STREET AT VALVES

NO. 4" | 6" | 8" ] 10" 12" 1 ALENE ROAD "BETHLEHEM MKE i • 2 ALENE ROAD JUDIE LANE 1 2 3 ALENE ROAD JUDIE LANE 2 2

4 BETHELEHEM PIKE DAGER ROAD 1 2 5 BETHELEHEM PIKE SHEBLE LANE 1 6 BETHELEHEM PIKE SPRINGWOOD LANE 2 3 7 BETHELEHEM PIKE LOCUST LANE 1 1 8 BETHELEHEM PIKE MONTGOMERY ROAD 1 1 1 9 BETHELEHEM PIKE MT. PLEASANT AVE 3

10 BETHELEHEM PIKE JOHNS LANE 1 11 BETHELEHEM PIKE THE MEADOWS 3

12 BROOKSIDE AVENUE KNIGHT ROAD 1 2 13 BROOKSIDE AVENUE N SPRING GARDEN ST 3

14 CEDAR LANE MT. PLEASANT AVE 1 15 CEDAR LANE MONTGOMERY ROAD 1

16 DAGER ROAD HOUSTON ROAD 3 17 DAGER ROAD KYLE LANE 2

18 DAVIS ROAD HAYS LANE 1 2 19 DAVIS ROAD JUDIE LANE 3 20 DAVIS ROAD MARIE ROAD 1

21 FOUKLE AVENUE KNIGHT ROAD 1 22 FOUKLEAVENUE PENN-AMBLER ROAD 1 2

23 FRANCIS AVENUE KNIGHT ROAD 1 1 24 FRANCIS AVENUE N SPRING GARDEN ST 3

25 GWYNMAPLE DR. (PRIVAT TENNIS AVENUE

26 HAMILTON ROAD JUDIE LANE 2 2

27 HOOVER AVENUE KNIGHT ROAD 1 28 HOOVER AVENUE PENN-AMBLER ROAD 2

29 HOUSTON ROAD KNIGHT ROAD 1 1 1 30 HOUSTON ROAD MARION AVENUE 1 31 HOUSTON ROAD PENN-AMBLER ROAD 3 32 HOUSTON ROAD THE MEADOWS 1

33 JOHNS LANE KENILWORTH DRIVE 4 34 JOHNS LANE SUSQUEHANNA ROAD 1 1

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9 A M B L E R BOROUGH WATER DEPARTMENT

MONTGOMERY COUNTY, PENNSYLVANIA STREET INTERSECTION ROSTER

& VALVE INVENTORY

LOWER GWYNEDD TOWNSHIP INTERSECTION STREET AT VALVES

NO. 4" | 6" 8" [ 10" | 12" 35 JUDIE LANE MARIE ROAD 4

36 LOCUST LANE LOCUST LANE 2 2 1 37 LOCUST LANE POPLAR COURT 3

38 KNIGHT ROAD MT. PLEASANT AVENUE 1 39 KNIGHT ROAD MARION AVENUE 1 40 KNIGHT ROAD NORMA ROAD 1

41 MARION ROAD NORMA ROAD 2 42 MATHERS ROAD PENN-AMBLER ROAD 3

43 MONTGOMERY ROAD MT. PLEASANT AVENUE 1

44 TENNIS AVENUE SUSQUEHANNA ROAD 1 1 3

TOTALS —> 18 39 40 1 7

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#

AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

UPPER DUBUN TOWNSHIP INTERSECTION STREET AT /ALVf

NO. 4" 6" 8" 10" 1 ALBERT LANE VAN SANT LANE 3

2 ALGONQUIN PASS ARROWHEAD TRAIL 1 3 ALGONQUIN PASS SEMINOLE GARDENS 2

4 AMBLER ROAD BETHLEHEM PIKE 0 5 AMBLER ROAD ORCHARD LANE 1 6 AMBLER ROAD ELLERSLIE AVENUE 2 7 AMBLER ROAD STUART LANE 1 8 AMBLER ROAD RANDOLPH AVENUE 1

9 ARDROSS AVENUE BETHLEHEM PIKE 1 10 ARDROSS AVENUE CEDAR ROAD 1 11 ARDROSS AVENUE DOUGLAS STREET 0

12 ARGYLE AVENUE BETHLEHEM PIKE 2 2 13 ARGYLE AVENUE CEDAR ROAD 2 14 ARGYLE AVENUE DOUGLAS STREET 3 1

15 ASH GROVE AT CREEK DRIVE 2 1 4

16 ARROWHEAD TRAIL CHEROKEE CIRCLE 1 1 17 ARROWHEAD TRAIL. CHIPPEWA RIDGE 3 18 ARROWHEAD TRAIL IROQUOIS WAY 2

19 ARROWHEAD TRAIL SENECA RUN 1 1 20 ARROWHEAD TRAIL SUSQUEHANNA RD. 3

21 BANNOCKBURN AVE BETHLEHEM PIKE 2 22 BANNOCKBURN AVE CHURCH STREET 2 23 BANNOCKBURN AVE RENFREW-AVENUE 2 24 BANNOCKBURN AVE TRINITY PLACE 1

25 BARTON DRIVE VICTOR LANE 3

26 BELLAIRE AVENUE VILLA DRIVE 2 27 BELLAIRE AVENUE HIGHLAND AVENUE 1 3 28 BELLAIRE AVENUE INVERNESS AVENUE 8 29 BELLAIRE AVENUE RANDOLPH AVENUE 2 30 BELLAIRE AVENUE HARTRANFT AVE. 2

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

UPPER DUBUN TOWNSHIP INTERSECTION STREET . AT VALVE

NO. 4" 6" 8" 10" 12" 31 BELLAIRE AVENUE PROSPECT AVENUE 3

32 BETHLEHEM PIKE PENNSYLVANIA AVE. 1 33 BETHLEHEM PIKE WASHINGTON LANE 0 34 BETHLEHEM PIKE MONTGOMERY AVE. 2 35 BETHLEHEM PIKE SPRING AVE (OR. LA.] 3 1 36 BETHLEHEM PIKE PROSPECT AVENUE 1 37 BETHLEHEM PIKE ELLERSLIE AVENUE 1 38 BETHLEHEM PIKE HARTRANFT AVENUE 1 39 BETHLEHEM PIKE STUART LANE 1 40 BETHLEHEM PIKE RANDOLPH AVENUE 1 1 41 BETHLEHEM PIKE BROOKWOOD DRIVE 5 42 BETHLEHEM PIKE INVERNESS AVENUE 0 43 BETHLEHEM PIKE HIGHLAND AVENUE 1 1 1 45 BETHLEHEM PIKE LINDENWOLD AVE. 2 46 BETHLEHEM PIKE LOCH ALSH AVENUE 1 47 BETHLEHEM PIKE HOMESTEAD LANE 1 48 BETHLEHEM PIKE BUTLER PIKE 2 2 49 BETHLEHEM PIKE FAIRVIEW AVENUE 2 50 BETHLEHEM PIKE HAGUES MILL ROAD 1 2 1 51 BETHLEHEM PIKE WILLOW AVENUE 1 1 1 52 BETHLEHEM PIKE TENNIS AVENUE 1 1

53 BOOTH LANE CEDARROAD 1 2 54 BOOTHLANE HEATHER ROAD 3

55 BUTLER PIKE MORRIS ROAD 2 1 56 BUTLER PIKE MEADOWBROOK AVE 1 57 BUTLER PIKE CAVENDISH DRIVE 3 58 BUTLER PIKE HAGUES MILL ROAD 1

59 CAVENDISH DRIVE HAMSTEAD DRIVE 2 60 CAVENDISH DRIVE MEADOWBROOK AVE 1 1

61 CEDAR ROAD LINDENWOLD TER'CE 0 62 CEDAR ROAD LOCH ALSH AVENUE 2 1 1 63 CEDAR ROAD MEADOWBROOK AVE 1 64 CEDAR ROAD FOREST CREEK DR. 1 2 65 : E D A R ROAD HOFFMAN ROAD 1 2

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A M B L E R BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

UPPER DUBUN TOWNSHIP INTERSECTION STREET AT VALV

NO. 4" 6" 8" 10" 12" 66 CEDAR ROAD SUSQUEHANNA RD. -

67 CHURCH STREET ROSEMARY AVENUE 0 68 CHURCH STREET TRINITY AVENUE 2 69 CHURCH STREET HIGHLAND AVENUE 1 70 CHURCH STREET SOUTHERN AVENUE 1

71 CLAIR MARTIN PLACE ROSE VALLEY WAY(2 2

72 CREEK DRIVE HIGHLAND AVE. 3 73 CREEK DRIVE RED MAPLE GROVE 3 74 CREEK DRIVE BASSWOOD GROVE 1 1 2 75 CREEK DRIVE BLACKHAWK LANE 1 2 76 CREEK DRIVE SPICEBUSH LANE 0 77 CREEK DRIVE FT WASHINGTON AV. 3 78 CREEK DRIVE TUPELO GROVE 2 3 2

79 DONNA DRIVE TRESSLER DRIVE 2 1

80 DOUGLAS STREET LOCH ALSH AVENUE 1 1 81 DOUGLAS STREET MEADOWBROOK AVE 3 1

83 ELLIGER AVENUE MONTGOMERY AVE. 0 84 ELLIGER AVENUE SPRING AVENUE 2 2 85 ELLIGER AVENUE PROSPECT AVENUE 2 2 86 ELLIGER AVENUE HARTRANFT AVE. 2 1

87 FARM LANE HIGHLAND'AVENUE 1 2 88 FARM LANE VILLA DRIVE - 1 1 89 FARM LANE MELISSA DRIVE 1 2 90 FARM LANE SCHIAVONE DRIVE 1 2 91 FARM LANE LOCH ALSH AVENUE 1 2

92 FT WASHINGTON AVE PENNSYLVANIA AVE. 1 93 FT WASHINGTON AVE WALNUT LANE 0 94 FT WASHINGTON AVE MONTGOMERY AVE. 2 95 FT WASHINGTON AVE SPRING AVENUE 2 2 96 FT WASHINGTON AVE PROSPECT AVENUE 1 1 97 FT WASHINGTON AVE HIGHLAND AVENUE 3

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A M B L E R BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

UPPER DUBUN TOWNSHIP INTERSECTION STREET AT VALVE

NO. 4" 6" 8" 10" 12" 98 FT WASHINGTON AVE THOMAS DRIVE 1 99 FT WASHINGTON AVE LOCH ALSH AVENUE 6

100 FT WASHINGTON AVE HAWTHORNE LANE 1 101 FT WASHINGTON AVE SUSQUEHANNA RD. 2

102 GLENCOE AVENUE HARTRANFT AVENUE 2 103 GLENCOE AVENUE RANDOLPH AVENUE 2 3

104 HADDON PLACE WALLACE DRIVE 2

105 HARTRANFT AVE. MADISON AVENUE 1 2

106 HAWTHORNE LANE TRESSLER DRIVE 2 2

107 HAZEL WOOD DRIVE VICTOR LANE 4

108 HEATHER ROAD (2) HOFFMAN ROAD 6

109 HIGHLAND AVENUE TRINITY PLACE 2 HIGHLAND AVENUE VAN SANT LANE 2 1

110 HIGHLAND AVENUE SUMMIT AVENUE 1 1 111 HIGHLAND AVENUE MADISON AVENUE 1 2 112 HIGHLAND AVENUE STEVENS DRIVE 3

113 INVERNESS AVENUE S.E. TURNAROUND 1

114 IROQUOIS WAY TENNIS AVENUE 1 4

115 KENYON DRIVE THOMAS DRIVE 4

116 LOCUST ROAD PROSPECT AVENUE 1 117 LOCUST ROAD SPRING AVENUE 4

118 MADISON AVENUE MONTGOMERY AVE. 1 119 MADISON AVENUE SPRING AVENUE 2 2 120 MADISON AVENUE PROSPECT AVENUE 2 2

121 MEISEN COURT ROSE VALLEY WAY 1 1

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A M B L E R B O R O U G H W A T E R D E P A R T M E N T MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

UPPER DUBUN TOWNSHIP INTERSECTION STREET AT VALVE

NO. 4" 6" 8" 10" 12" 122 MELISSA DRIVE SHADY PLACE 1 . 2 123 MELISSA DRIVE THELMA LANE 1 2 124 MELISSA DRIVE WINDSOR PLACE 1 2

125 MONTGOMERY AVE WASHINGTON LANE 1 1 126 MONTGOMERY AVE SUMMIT AVENUE 1 2

127 MORRIS ROAD WILLOW ROAD 1 2

129 NASH DRIVE VICTOR LANE 3

130 PENNSYLVANIA AVE SUMMIT AVENUE 2

131 PROSPECT AVENUE WASHINGTON LANE 1 3 132 PROSPECT AVENUE SUMMIT AVENUE 2 2

133 QUINARD COURT ROSE VALLEY WAY 1

134 RENFREW AVENUE TRINITY PLACE 2

135 ROSE VALLEY WAY S.E. TURNAROUND 1 2

136 SPRING AVENUE WASHINGTON LANE 2 2 137 SPRING AVENUE SUMMIT AVENUE 2 2

138 STEVENS DRIVE WALLACE DRIVE 1 2

139 SUMMIT AVENUE WALNUT LANE 2

140 SUSQUEHANNA ROAD 20 WILLOW AVENUE 3

141 WILLOWMERE LANE WILLOW AVENUE 1 3

TOTALS --> 102 116 125 1 9 GRAND TOTAL---> 353

11/05/98 STINTSUD

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0 AMBLER BOROUGH WATER DEPARTMENT

MONTGOMERY COUNTY, PENNSYLVANIA STREET INTERSECTION ROSTER

& VALVE INVENTORY

WHITEMARSH TOWNSHIP INTERSECTION

NO. STREET AT VALVE INTERSECTION

NO. 4" 6" 8" 10" 12" 1 ALTER ESTATE PRIVATE STREET 3

2 BEECH ROAD MORRIS ROAD 1 2 3 BEECH ROAD SPRUCE ROAD 3

4 BETHLEHEM PIKE MATHERS ROAD 2 5 BETHLEHEM PIKE MORRIS ROAD 1 6 BETHLEHEM PIKE Southwest ofMORRIS ROAD 1 7 BETHLEHEM PIKE @ Railroad 2

8 BUTLER PIKE HAMPTON LANE 1 9 BUTLER PIKE NORRISTOWN ROAD 2 11 BUTLER PIKE Southwest of SKIPPACK PIKE 1 12 BUTLER PIKE WHITPAIN DRIVE 1 13 BUTLER PIKE MEADE ROAD 1 14 BUTLER PIKE RIDINGS WAY , 2 . 1 15 BUTLER PIKE GRAYSTONE ROAD 1 16 BUTLER PIKE SYCAMORE LANE 1 17 BUTLER PIKE JEFRON DRIVE 1 18 BUTLER PIKE DETWEILER LANE 1 19 BUTLER PIKE CAREY DRIVE 1

20 DORSAM WAY SKIPPACK PIKE 2 1 21 DORSAM WAY @ Branch to Alter Estate 1 23 DORSAM WAY @ Turnaround 1

-24 HAMPTON LANE Southeast.to Turnaround 2

25 JOSHUA ROAD TOLAND DRIVE 1 26 JOSHUA ROAD Private Road to Northwest 1

JOSHUA ROAD SKIPPACK PIKE 1

27 LAFAYETTE AVENUE MORRIS ROAD & Southwest 2 28 LAFAYETTE AVENUE SKIPPACK PIKE & Northeast 2

29 MILITIA HILL ROAD SKIPPACK PIKE 1 30 MILITIA HILL ROAD TOLAND DRIVE 3

31 MILITIA WAY SKIPPACK PIKE (Rte 73) 1 32 MILITIA WAY @ Turnaround 1

33 MILL SPRING DRIVE MORRIS ROAD 1

34 MORRIS ROAD WILLOW ROAD 1 2 35 VIORRIS ROAD SHEAFF LANE 3 36 MORRIS ROAD WISSAHICKON CREEK BR. 2

• 37 PENNSYLVANIA AVENUE SUMMIT AVENUE 1

38 ; 3HEAFF LANE 3KIPPACK PIKE (Rte 73) 1 1 39 5HEAFF LANE \ WHITEMARSH VALLEY ROAD 1 1 40 J 3HEAFF LANE \ A/ILLIAMS ROAD 1 2 41 J 3HEAFF LANE \ A/OODCOCK LANE 1 1

11/05/98 STINTSWH

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY. PENNSYLVANIA STREET INTERSECTION ROSTER

& VALVE INVENTORY

WHITEMARSH TOWNSHIP INTERSECTION

NO. STREET AT VALVE INTERSECTION

NO. 4" 6" 8" 10": 12" 42 SHEAFF LANE @ Valve Pit 2

43 SKIPPACK PIKE @ WISSAHICKON CREEK 2

44 SPRUCE ROAD WILLOW ROAD 4

TOTALS 12 30 28 5 1

GRAND TOTAL --> 76

11/05/98 STINTSWH

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

WHITPAIN TOWNSHIP INTERSECTIOfv J STREET AT VALV

NO. 4 , , 6" 8" 10" 12" 1&2 ALDRIN DRIVE (2) BATLESON ROAD

4 , ,

4

3 BATLESON ROAD BETSY LANE 1 2 4 BATLESON ROAD MORRIS ROAD 1 5 BATLESON ROAD COLLINS PLACE 1 2 6 BATLESON ROAD . MT. PLEASANT AVE. 1

7 BETSY LANE MERCER HILL ROAD 1 3 8 BETSY LANE GILLIN ROAD 1 2 9 BETSY LANE MORRIS ROAD 1 2

10 BROOKFIELD LANE HOGAN LANE 3

11 BUTLER PIKE SPLITRAIL LANE 3

12 DETWEILER LANE GORDON ROAD 2

13 FOXFIELD COURT RIDINGS WAY 1 2

14 GILLIN ROAD MERCER HILL ROAD 3 -

. 15 GRAYSTONE ROAD HOGAN LANE 1 16 GRAYSTONE ROAD JEFRON LANE 3 17 GRAYSTONE ROAD GORDON ROAD 2 18 GRAYSTONE ROAD PADDOCK ROAD 3

19 HEDGEROW COURT SPLITRAIL LANE 1 5

20 HOGAN LANE RIDINGS LANE 2 1

21 IVY ROAD SKIPPACK PK (Rte 73) 2 1 22 IVY ROAD WHITPAIN DRIVE 3

23 JEFRON DRIVE PADDOCK ROAD 3

24 MAPLE AVENUE MT. PLEASANT AVE. 2 1 2 25 MAPLE AVENUE OAK STREET 3

25 VIEADE ROAD BUTLER PIKE 1 26 VIEADE ROAD SKIPPACK PIKE 1 2 27 VIEADE ROAD i WHITPAIN DRIVE 3

28 f V1T.PLEASANT AVE. RAILROAD AVENUE 4 1 2

11/05/98 STINTSWN

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AMBLER BOROUGH WATER DEPARTMENT MONTGOMERY COUNTY, PENNSYLVANIA

STREET INTERSECTION ROSTER & VALVE INVENTORY

WHITPAIN TOWNSHIP INTERSECTION STREET AT JALVB

NO. 4" 6" 8" 10" 12"

29 OAK STREET RAILROAD AVENUE 1 2

30 RAILROAD AVENUE TENNIS AVENUE 1 1

31 RIDINGS WAY RIDINGS WAY 1 2 32 RIDINGS WAY WOLF LANE 1 3

33 SPLITRAIL LANE HEDGEROW COURT 1 5

TOTALS - > 13 50 42 0 0

GRAND TOTAL —> 105

11/05/98 STINTSWN

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PENNSYLVANIA PUBLIC UTILITY COMMISSION v.

BOROUGH OF AMBLER - WATER DEPARTMENT DOCKET NO. R-00062017

INTERROGATORIES OF THE OFFICE OF CONSUMER ADVOCATE SET H

REVISED ANSWERS TO INTERROGATORIES SET I I

QUESTION 9

BY

AMBLER BOROUGH WATER DEPARTMENT

JUNE 21, 2007

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C v. AMBLER BOROUGH WAT DOCKET R-00062017

SET n INTERROGATORIES

9. Provide copies of all laboratory analyses that the Company has had performed on these active water supply sources for all primary and secondary contaminates covered by the Pennsylvania's Safe Drinking Water Act. Also provide laboratory analyses of samples taken to comply with the lead/copper rule.

ANSWER: Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created May 23, 2007

Currently, active water supply sources are obtained from Wells 2, 4, 6, 7, 8, 9, 11, 12, and 14. (Whitemarsh Pumping Station has been down for repairs since 2004, however we do perform a raw water - total organic carbon — analysis, monthly).

Lead/Copper Rule laboratory analyses from 2003 are attached. Lead/Copper Rule laboratory analyses are scheduled to be taken again during the Fall of 2007.

Attached are Sample Analysis Reports for:

Arsenic (annually) Date sampled: 2/8/06 Nitrate/Nitrite (annually) Date sampled: 7/6/06 THM & HAA (designated secondaries) Dates sampled: 2006 VOC's (annually) Date sampled: 2/5/07 TOC's (monthly) Date sampled: 2//21/07 General Chemistry (annually) Date sampled: 1/31/07

A complete set of SOC's (sampled annually) for the year 2006 will be produced once copies are obtained from the lab.

ANSWER: Philip Benigno, Water Superintendent Ambler Borough Water, 122 E. Butler Ave., Ambler, PA 19002 Answer Created June 22, 2007

(Please note: PADEP requires sampling of SOC's every three years from four designated source locations. Our next sampling period will be the second and third quarters of 2009. Therefore, the four lab sampling analyses of SOC's taken in 2006 which were included in our Response to Set I I Interrogatories provide complete current information regarding SOC's)

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0 BEFORE THE

PENNSYLVANIA PUBLIC UTILITY COMMISSION

Pennsylvania Public Utility Commission

v.

Borough Of Ambler-Water Department

Docket No. R-00062017

ORIGINAL

CERTIFICATE OF SERVICE

I hereby certify that on this 11 th day of July, 2007, true and correct copies of the Borough

of Ambler's Answer to Office of Consumer Advocate's Interrogatories, Set III, in the above

referenced matter was served by first class mail upon the following persons:

The Honorable Charles E. Rainey Administrative Law Judge

Pennsylvania PUC PO Box 3265 Harrisburg, PA 17105-3265

Christine Maloni Hoover, Esq. Counsel for Office of Consumer Advocate

555 Walnut St., 5 lh Floor Harrisburg, PA 17101

Charles Shields, Esq. Office of Trial Staff

PA Public Utility Comm. P.O. Box 3265

Harrisburg, PA 17105

RECEIVED JUL I 1 3

WPUBLIG UTILITY

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0 Marilyn J. Kraus

Senior Regulatory Analyst Office of Consumer Advocate

555 Walnut St., 5 th Floor Harrisburg, PA 17101

Date:

Joseph E. Bresnan, Esq. Attorney I.D. No. 44017 Solicitor, Ambler Borough Bresnan & Herder 311 Lindenwold Ave. Ambler. PA 19002

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PRE-HEARING CONFERENCE/MEDIATION ATTENUANCE S H E E T

Docket No. R-00062017

Case Name Pennsylvania Public Utility Commission v.

The Borough of Ambler

Location HBG

T E N ^ I

CHECK THOSE WHICH APPLY:

Pre-Hearing Conference Held [?YES • N O

Pre-Hearing Conference Concluded dfYES • N O

Transcript Due • Y E S • N O

Mediation Concluded • Y E S QJ'NO

Further Mediation Session Needed • Y E S Efao t , Estimated Add'l Days

Date July 19, 2007 REMARKS:

Mediator Herbert Nurick

ALJ Charles E. Rainey, Jr.

J Ul a 4 ZOO/ Court Reporter Commonwealth Reporting Company

Names, Addresses and Telephone Numbers of Parties or C o u n ^ r t ^ ^ w S ' P ^ ^ ^ ' O A l PLEASE PRINT CLEARLY W W ™ l W S BUREAU

Incomplete Information May Result In Delay Of Process

Name and Telephone Number Address Appearing for

.City State Zip

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E-mail A d d r e s s ^ ^ ^ j ^ Q ^ ^ ^ Fax Number:^70^-77a-^5*7"7

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Check this box if additional parties or attendees appear on back of form.

Reporter's Signature

#519245 Attendance Sheet - PHC/Mediation Session

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Case Name:

; H E R P E R S O N S IN A T T E N D A N C I

Docket No.

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