Jonathan Nase

Member

Jonathan has extensive experience in Pennsylvania administrative law, particularly public utility law. He has represented a wide range of clients, including public utilities (large and small); boroughs, counties, and other municipal corporations; real estate developers and other public utility consumers; and even medical marijuana providers. He has experience in every regulated utility industry in Pennsylvania: water, wastewater, steam, gas, electric, transportation, and telecommunications. Jonathan has assisted clients in completing complex transactions and has represented them in litigation before the Pennsylvania Public Utility Commission, the Pennsylvania Department of Health, and the Pennsylvania Office of Open Records, as well as the Commonwealth Court of Pennsylvania and the Supreme Court of Pennsylvania. Jonathan has also written articles about public utility law and has presented at conferences for attorneys, local government officials, engineers, and consultants.

Jonathan has a broad range of experience in both the public and private sectors. He served as a staff attorney for the Pennsylvania General Assembly for ten years before entering private practice. He subsequently returned to government service with the Pennsylvania Public Utility Commission, where he served as a Deputy Director in the Office of Special Assistants. Jonathan joined Cozen O’Connor in 2017.

Jonathan earned his law degree from the Duke University School of Law and his undergraduate degree from American University.

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Experience

Mergers and Acquisitions

  • Obtained Pennsylvania Public Utility Commission approval of KKR Infrastructure's acquisition of Clearway Energy's district steam and chilled water systems in Pittsburgh and Harrisburg. Commission approval was one of only two required regulatory approvals for the $1.9 billion transaction. (PA PUC Docket No. A-2021- 3029619).

  • Represented SUEZ in Pennsylvania Public Utility Commission approval of the $15 billion combination of SUEZ into Veolia. Pennsylvania was one of five state regulatory approvals required for the transfer of control of SUEZ's regulated water/wastewater companies. (PA PUC Docket No. A-2021- 3026515).

  • Represented SteelRiver Infrastructure Fund North America LP in its $4.25 billion sale of Peoples Natural Gas Company LLC and Peoples Gas Company LLC to Aqua America, Inc. (now Essential Utilities, Inc.), including negotiation of regulatory provisions of the purchase and sale agreement and obtaining required regulatory approvals from the Pennsylvania Public Utility Commission (PA PUC Docket No. A-2018-3006061).

  • Represented SUEZ Water Pennsylvania, Inc. in its acquisition of the assets of the Kensington Water Company, a public water utility in Franklin County, Pa. (PA PUC Docket Nos. A-2019-3012193 & A-2019-3012194).

  • Represented Hercules Intermediate Holdings LLC in obtaining PA PUC approval of the transfer of control of Laurel Pipe Line Company, L.P., from Buckeye Partners, L.P. to IFM Global Infrastructure Fund (PA PUC Docket No. A-2019-3011685).

  • Represented Clearway Energy in its acquisition of the combined heat and power plant of Duquesne University, including negotiation of relevant agreements and obtaining a Pennsylvania Public Utility Commission Chief Counsel Opinion that steam service from the plant would not be jurisdictional public utility service.

  • Represented Pennsylvania-American Water Company in its $92 million fair market value rate base acquisition of the wastewater system of Exeter Township, Berks County, Pa. (PA PUC Docket No. A-2018-3004933).

Rate Cases

  • Represented Pennsylvania-American Water Company in its 2020 Base Rate Proceeding before the Pennsylvania Public Utility Commission, which was fully litigated with strong opposition from the Pennsylvania Office of Consumer Advocate and the Pennsylvania Office of Small Business Advocate, among others, who argued against a rate increase because of the economic circumstances caused by the COVID-19 pandemic. In a 152-page Opinion and Order, the PUC approved an annual revenue increase of $70.5 million, finding that PAWC was constitutionally entitled under the Takings Clause to a return on and of its investment in providing service to the public. To mitigate the impact on low-income customers, PAWC implemented enhanced customer assistance programs and delayed utility service terminations for non-payment (PA PUC Docket No. R-2020-3019369).

  • Represented Hidden Valley Utility Services, L.P., in a case seeking PUC approval to raise water and wastewater rates for the first time in more than 13 years (PA PUC Docket Nos. R-2018-3001306 and 3001307).

  • Represented Peoples Natural Gas Company LLC in its successful challenge to Duquesne Light Company's attempt to increase its back-up service rate for combined heat and power projects by 220 percent (PA PUC Docket No. R-2108-3000124).

News

Cozen O'Connor Promotes 27 to Membership

May 01, 2019

Cozen O'Connor is pleased to recognize 27 attorneys with the promotion to member: Dylan Alper, Philip J. Berens, Alison Weintraub Berson, Evan Berquist, Alexandra Campau, Alissa K. Christopher, Matthew D. Clyde, Rachel Collins Clarke, Michael A. Corgan, Matthew L. Elkin, Nicole M. Ellis, Alex H. Hayden, David S. Huard, Haryle Kaldis, David Kirchblum, Matthew Evan Lewitz, Jesse Ryan Loffler, Samantha L. Mazo, Lindsey A. Miller, Jeffrey M. Monhait, Jonathan Nase, Jacqueline Promislo, Shelby K. Riney, Kelly Shinn, Terri A. Sutton, Daniel P. Thiel, and Laura Zulick.

Publications

PA PUC Votes 3-2 to Regulate Landlords as Gas Pipeline Operators [Alert]

January 10, 2025

David Zambito discusses the January 8, 2025, vote asserting jurisdiction over Pennsylvania landlords as gas pipeline operators if they have behind-the-meter gas distribution systems on their properties.

PA Commonwealth Court Reverses PUC, Upholds Some Municipal Permitting Fees

May 04, 2022

The Commonwealth Court of PA reversed the PUC's declaratory order, arguing permitting fees were permissible because they do not “constitute utility regulation.”

Pennsylvania Public Utility Commission to Require Diversity Reporting

April 25, 2022

The Pennsylvania Public Utility Commission will be requiring major jurisdictional public utilities to file annual diversity reports beginning March 2023.

What’s at Stake When the Supreme Court of Pennsylvania Takes on Smart Meters? Issues and Impacts [Alert]

November 18, 2021

Jonathan Nase discusses three consolidated cases that the Pennsylvania Supreme Court will hear oral arguments for in December that may impact utilities in the commonwealth.

Buyer and Seller Beware: Does Your Purchase/Sale of a Business Include a Public Utility? [Alert]

October 18, 2021

Jonathan P. Nase discusses why both the buyer and the seller must do their due diligence identifying any permits, licenses, or certificates that must be transferred to the buyer (or otherwise obtained by the buyer) at or before closing.

Continuing the “Return to Normalcy” at the Pennsylvania Public Utility Commission [Alert]

July 19, 2021

David P. Zambito and Jonathan P. Nase discuss the PUC's various orders gradually ending the emergency measures it took in response to the COVID-19 pandemic.

Pennsylvania Public Utility Commission Further Defines Qualifying Alternative Energy Sources [Alert]

May 13, 2021

Jonathan Nase discusses the PUC's Act 40 and Act 114 implementation orders regarding alternative energy sources.

Pennsylvania Public Utility Commission Enters a New Phase in Responding to the COVID-19 Pandemic [Alert]

March 15, 2021

David P. Zambito and Jonathan P. Nase discuss the additional steps toward returning to pre-COVID-19 pandemic procedures for collecting amounts due for public utility service in Pennsylvania.

Pennsylvania Public Utility Commission Rules Two Municipal Permitting Fees Are Preempted by State Law [Alert]

February 23, 2021

Jonathan Nase discusses the PUC decisions in response to Armstrong Telecommunications Inc. Petition for Declaratory Order.

Phase 2 of the Moratorium on Utility Shut-offs in Pennsylvania Extended [Alert]

February 22, 2021

Jonathan Nase discusses the emergency order generally prohibiting the termination of public utility service by electric, natural gas, water, wastewater, telecommunications, and steam utilities, and encouraging the impacted utilities to reconnect service to customers previously terminated, to the extent it could be done safely.

Regulating Troubled or Failing Monopolies: Ordering One Public Utility to Acquire Another [Alert]

February 19, 2021

Jonathan Nase discusses a provision in the Pennsylvania code that gives the PUC authority to order a proximate capable public utility to acquire a small water or sewer utility that is struggling to remain viable.

What is This? The Importance of Procedure in Pennsylvania Public Utility Commission Proceedings [Alert]

February 04, 2021

Jonathan Nase discusses the differences between the Pennsylvania Public Utility Commission’s procedural rules, the General Rules of Administrative Practice and Procedure, and the Pennsylvania Rules of Civil Procedure.

Pennsylvania Public Utility Commission Enters Phase 2 of the Moratorium on Utility Shut-Offs [Alert]

October 19, 2020

David P. Zambito and Jonathan P. Nase discuss Chairman Gladys Brown Dutrieuille's modifications to the emergency order.

Industry Sectors

Education

  • Duke University School of Law, J.D., with honors, 1985
  • American University, B.A., 1982
  • Pennsylvania