Consum Adv v. PUC; Apl of: Aqua PA Wastewater Inc

Summary

The Court held that the statutory requirements for obtaining a certificate of public convenience remain applicable to acquisitions under Section 1329. It ruled that the Commission could consider transaction benefits arising from the acquiring utility’s size and fitness, and that the Commission properly considered rate impacts as one component of the overall public-benefits assessment without treating them as a categorically known harm. The Court reversed the Commonwealth Court and remanded for review of whether the Commission’s factual findings were supported by substantial evidence.