Mabel Morris' letter {Sept. 9} regarding due process in water-and-sewer matters deserves some clarification. While the Water and Sewer Utility Administration does not come under the jurisdiction of the Public Service Commission, municipal law provides general guidance for appeal of water bills, and the utility operates under a more definitive adjudicatory procedure to ensure due process.

If a customer is not satisfied with the decision rendered after a meeting with the chief of water measurement and billing, he is instructed to send a written request for a hearing to the administrator of the utility, in the Department of Public Works. The case is then investigated by the Special Investigations and Appeal Unit to determine whether any mistakes were made by the water-billing staff. If an error was made, a decision in favor of the customer is reached immediately, with or without a hearing.

If the government's position is validated, then the appeal unit sets up a hearing, which is conducted according to the standards required by the Administrative Procedures Act. Because current D.C. law does not specify an adjudicatory process for water bill appeals, the hearing is viewed from the position of the customer; the government must prove that it is right.

However, to reduce public concern about this process, last month we proposed legislation that would establish the procedure in the law. This same legislation would also establish an interest charge similar to that imposed on electric and gas bills.

While we do not have a bill-of-rights handbook like those of the other utilities, we do have a Water and Sewer Customer Handbook that will be mailed to all customers beginning this month.

Senior citizens are a pressing concern of the water-and-sewer utility. While we have several ways to help the elderly with financial difficulties, and a phone call will suspend any action on a water bill prior to completion of an investigation, many senior citizens remain uninformed or reluctant to take advantage of certain services. We feel that we must do more. A working group from four city agencies is developing a program to identify, inform and help senior citizens who have problems paying water bills.

Water-and-sewer revenues in the District primarily pay for cleaning up the Potomac. The cost for operating the Wastewater Treatment Plant at Blue Plains accounts for approximately 65 cents of each dollar collected on a water bill. In most large U.S. cities, the majority of the costs go to the provision of water rather than the treatment of waste water. Providing a clean environment is an expensive process. Contrary to Mrs. Morris' belief, we cannot earn a profit because it is prohibited by the enterprise fund concept, which requires that we operate with a balanced budget.

If we have given the impression of being "imperious," as suggested by Mrs. Morris, then we apologize. We appreciate all suggestions and comments, including criticisms, regarding our operations because they make us work harder to serve the public better.

WALLACE WHITE

Administrator

Water and Sewer Utility Administration

Washington