I would like to draw attention to an important problem affecting all D.C. water-and-sewer users.

Even though the city-owned water-and-sewer utility is like any other utility -- except that the city rather than private stockholders owns it -- laws and regulations governing it are much different from those governing privately owned utilities. For example, if you are late paying your electric or gas bill, 1 percent interest is charged. But if you are only one day late paying your water-sewer bill, a whopping 10 percent penalty is assessed because the charge is treated like a tax.

If the electric, gas or telephone company cuts off service or takes any other action a customer feels is unfair, the customer can appeal to the Public Service Commission for an administrative hearing and can seek other administrative redress, even over billing disputes. But for water-sewer bills and other matters, the only redress, according to instructions on the back of the water-sewer bill, is to call an account representative and, if still dissatisfied, talk to his supervisor. Contrast this with the consumer bill-of-rights handbooks private utilities are required to send to customers.

Recently, an elderly person who lives in the District and also owns a rental property was sent a notice telling her that her rental property would have a city lien placed on it if she did not pay the water-sewer bill the tenant had failed to pay. The bill covered a period greater than a year and amounted to almost $1,200. She was given less than a month to pay the bill to avoid a lien. The notice was the first she had heard of the unpaid water-sewer bill.

The lack of due process in this entire setup is appalling. True, the other utilities are profit-making, and the city's water-sewer utility for many years ran a debt that had to be heavily subsidized by general revenues. But a few years ago, the D.C. Council doubled water-sewer rates over a two-year period, erasing the entire debt. Even after the council recently reduced the rates, the utility is still earning a profit.

The water-and-sewer utility, whose imperious attitude and broad powers duly anger D.C. residents, should be brought within that time-tested tradition of due process -- treating water-and-sewer matters in the same way as similar matters of any other utility.

MABEL E. MORRIS

Director, Federation of Citizens Associations

of the District of Columbia

Washington