DISSENTING OPINION BY
Judge PELLEGRINI.This matter arose when Southeastern Pennsylvania Transportation Authority (SEPTA) requested that the Philadelphia Commission on Human Relations (PCHR) dismiss seven separate complaints filed by individuals, both employees and passengers, between 2007 and 2009, claiming violations of the Philadelphia Fair Practices Ordinance (Ordinance), Section 9-1101 — 9-3210 of the Philadelphia Code, alleging that the PCHR lacked jurisdiction. After the PCHR denied dismissal, SEPTA sought a declaratory judgment with an attendant request for a preliminary injunction in the Philadelphia Court of Common Pleas (trial court) alleging that the Ordinance could not be enforced against it because it was a Commonwealth agency. The PCHR filed preliminary objections to the complaint alleging, inter alia, that it had jurisdiction over SEPTA, that jurisdictional challenges to local agency jurisdiction had to be resolved by the agency and after a decision on the merits, and that an appeal of the local agency’s decision could be taken to the courts. The trial court granted the PCHR’s preliminary objections and dismissed the, complaints because the PCHR’s investigations were still in progress, no judgment on the merits had been entered on any of the complaints, and SEPTA’s request for relief was premature. SEPTA contends, among other issues, that the trial court erred because SEPTA is a *564Commonwealth agency and the PCHR lacks jurisdiction to regulate its affairs.
The majority, in reversing the trial court, finds that SEPTA is a Commonwealth agency because SEPTA’s enabling legislation provides that SEPTA may “exercise the public powers of the Commonwealth as an agency and instrumentality thereof.” 74 Pa.C.S. § 1711. I respectfully dissent from the majority holding that the PCHR lacks jurisdiction to investigate complaints against SEPTA because:
• even though SEPTA “exercise[s] the public powers of the Commonwealth as an agency and instrumentality thereof,” that does not make it part of the Commonwealth for all purposes, or for that matter, any purpose. A1 that it means is that it is a separate and distinct entity and not part of the governmental entity that formed it.
• even if it was considered a commonwealth agency, the PCHR has jurisdiction over SEPTA.
I.
The difficulty in determining the status of SEPTA or, for that matter, any authority, is directly related to the reasons behind their creation and authorization by the General Assembly. Athough authorities owe their existence to the various units of government and them governing boards are appointed by those entities, they are not considered part of the normal governmental structure. Unlike municipal corporations that have “governmental” and “proprietary” functions, authorities engage only in the latter. Authorities are “public corporations, being corporate agencies engaged in the administration of civil government.” 1 Lighton v. Abington Township, 336 Pa. 345, 354, 9 A.2d 609, 613 (1939). Generally, authorities are established for the purpose of financing and managing various revenue producing projects of a public nature or other activities that are not considered to be part of core governmental activities; they are a governmental business venture, a form of quasi-privatization. The circumstances prompting their creations are usually for one or more of the following reasons:
• the need for an administrative agency to manage public enterprises which, in certain cases, have commercial characteristics, e.g., Metropolitan Transportation Authorities (SEPTA); Parking Authorities;
• the need for an agency which can cross governmental boundary lines for the effective handling of intercommunity problems, e.g., SEPTA;
• to avoid constitutional and statutory restrictions. For example, prior to the enactment of the amendment contained in A'ticle 9, Section 9 to the Pennsylva*565nia Constitution, local governments had very low debt limits, and creating authorities allowed them to finance public improvements without conflicting with the constitutional limits on debt. Prior debt limits were based on real estate values. Article 9, Section 9. (See Lesser v. Warren Borough, 237 Pa. 501, 85 A. 839 (1912)). More recently they are used to give funds to private developers which would be constitutionally proscribed by Article 9, Section 9 of the Pennsylvania Constitution.2 Also, they allowed cities to engage in activities not authorized by their respective municipal or county codes, e.g., public housing.3
Because of the need to get around these constitutional impediments, the legislation authorizing the creation of authorities contains language that the authority is not an agency of the governmental unit(s) that creates it and appoints its board members, but is considered an agency of the Commonwealth. Typical of the language contained in most acts is the language contained in Section 1711 of the Metropolitan Transportation Authorities Act, 74 Pa. C.S.A. § 1711, which states that:
An authority shall in no way be deemed to be the instrumentality of any city or county or other municipality or engaged in the performance of a municipal function, but shall exercise the public powers of the Commonwealth as an agency and instrumentality thereof.
While authorities may be denominated as an “instrumentalit[ies] of the Commonwealth,” that does not mean that they are automatically considered to be “the Commonwealth” for all purposes. Traditionally, to determine whether they .should be considered “the Commonwealth,” we have examined the intent of the General Assembly in enacting a particular piece of legislation that the authority said did not apply to them.
While it will be shown that SEPTA is not a Commonwealth agency under that test, I would suggest this test has been used so as not to implicate the constitutional and statutory restrictions that were sought to be avoided. However, we have never focused on what is meant by the term “agent or instrumentality of the Commonwealth.” All that term means is that an authority is a separate and distinct entity — a separate form of government— and not the creature, agent or representative of those governmental bodies organizing it. Like municipalities, counties and school districts, which are also agents and instrumentalities of the Commonwealth, authorities are just another form of government, not a Commonwealth agency.
A.
Just like authorities, municipalities are agents of the Commonwealth. In City of Pittsburgh v. Commonwealth, 468 Pa. 174, 360 A.2d 607 (1976), where our Supreme Court held that the Department of Corrections had to comply with local zoning, it noted that municipalities are agents of the Commonwealth. Quoting from Commonwealth v. Moir, 199 Pa. 534, 541, 49 A. 351, 352 (1901), it stated:
Municipal corporations are agents of the state, invested with certain subordinate *566governmental functions for reasons of convenience and public policy. They are created, governed, and the extent of their powers determined by the Legislature and subject to change, repeal or total abolition at its will.
Cf. Warren Borough v. Willey, 359 Pa. 144, 146, 58 A.2d 454, 455 (1948). See also Pa. Const., Art. 9, s 1; Cali v. City of Philadelphia, 406 Pa. 290, 177 A.2d 824 (1962).
City of Pittsburgh, 468 Pa. at 179, 360 A.2d at 610. See also Department of General Services v. Ogontz Area Neighbors Association, 505 Pa. 614, 483 A.2d 448 (1984), where a city was denominated as an “instrumentality” of the Commonwealth.
Similarly, the county is an agent of the state because its main purpose is to aid the state in the administration of justice, the keeping of legal records, the conduct of elections and the administration of poor relief. See Article IV, Section 4 of the Pennsylvania Constitution. Court of Common Pleas of Lackawanna County v. Pennsylvania Office of Open Records, 2 A.3d 810, 813 (Pa.Cmwlth.2010). “A county organization is created almost exclusively with a view to the policy of the state at large.... With scarcely an exception, all the powers and functions of the county organization have a direct and exclusive reference to the general policy of the State, and are in fact but a branch of the general administration of that policy.” Garr v. Fuls, 286 Pa. 137, 145, 133 A. 150, 153 (1926). Though over the years the counties have been granted some powers more commonly considered local and overlap with municipalities, at least for non-home rule counties, counties are still considered political subdivisions of the Commonwealth, not municipalities. Ricketts v. Allegheny County, 409 Pa. 300, 306, 186 A.2d 249, 253 (1962); Hartness v. Allegheny County, 349 Pa. 248, 250, 251, 37 A.2d 18, 19 (1944); Com. v. Brice, 22 Pa. 211 (1853); Commonwealth ex rel. Woods v. Walker, 305 Pa. 31, 156 A. 340 (1931).
Finally, school districts, the other major form of government, are considered agents of the Commonwealth to carry out the Commonwealth obligations under Article III, Section 14 of the Pennsylvania Constitution to “provide for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth.” “It is well established that the local school districts are merely agents of the Commonwealth to which the legislature has delegated authority in order to fulfill the state’s responsibility to provide public education.” Pennsylvania Federation of Teachers v. School District of Philadelphia, 506 Pa. 196, 199, 484 A.2d 751, 753 (1984); see also Chartiers Valley Joint Schools v. Allegheny County Board of School Directors, 418 Pa. 520, 211 A.2d 487 (1965); Wilson v. Philadelphia School District, 328 Pa. 225, 195 A. 90 (1937); Lysicki v. Montour School Dist., 701 A.2d 630 (Pa.Cmwlth.1997).
SEPTA also contends that because it has been given “sovereign immunity,” it somehow is part of the Commonwealth government,, which takes away the PCHR’s jurisdiction. First, just because the General Assembly has seen fit to give an agency “sovereign immunity” rather than “governmental immunity” means nothing; it is just a determination by the General Assembly as to what type of immunity fits that particular agency. Even though prior to the abolishment of court-created tort immunity the counties enjoyed sovereign immunity because they were subdivisions of the state, Hartness, they are now covered by the provisions of the Political Subdivision Tort Claims Act,4 not the Sovereign Immunity Act. If the Gener *567al Assembly wanted to enact a separate Authorities Act, say, making an exception to immunity common carrier liability, it could do so. Second, all tort immunity is sovereign immunity, no matter what it is called because no matter what version, it is enacted pursuant to Article I, Section 11 of the Pennsylvania Constitution which provides that “Suits may be brought against the Commonwealth in such manner and in such cases as the Legislature may by law direct” and that the Legislature’s authority “to choose cases in which the Commonwealth should be immune” encompasses political subdivisions because they are agents of the state. Carroll v. York County, 496 Pa. 363, 437 A.2d 394 (1981). Finally, “[w]hether an entity is the “Commonwealth government” for the purposes of jurisdiction or a “Commonwealth agency” for the purposes of immunity from suit in tort are totally distinct issues.” Quinn v. Southeastern Pennsylvania Transp. Authority, 659 A.2d 613, 616 (Pa.Cmwlth.1995).
Authorities, while separate and distinct entities from the entity that created them, do not have an exalted status that would make them Commonwealth agencies when municipalities, counties and school districts which carry out the Commonwealth’s responsibility to provide public safety, streets and highways, administration of justice and constitutionally-mandated education are not.
B.
I now return to a traditional analysis of whether SEPTA enjoys the same immunity that the Commonwealth enjoys because it is an instrumentality and agent of the Commonwealth. This is done by looking at legislative intent. The case most similar is Fisher v. Southeastern Pennsylvania Transportation Authority, 60 Pa.Cmwlth. 269, 431 A.2d 394, 397 (1981), where we addressed the issue of whether the General Assembly intended SEPTA to be considered “the Commonwealth” as that term is used in Section 1 of the Act of July 12, 1935, P.L. 677, as amended, 65 P.S. § 114, repealed by the Act of November 1, 2005, P.L. 327, No. 62, § 2, retroactive effective January 1, 2005, which deals with payment of salaries of employees in the reserve component of the military. That section provides that all officers and employees of the Commonwealth are entitled to a leave of absence from their duties without loss of pay when they are absent from work while in active service with the reserve units of the United States Armed Forces. Holding that SEPTA was not “the Commonwealth” and its employees were not entitled to back pay when absent from work while in the military service, we stated:
[W]e do not go so far as to suggest that whenever a legislative enactment refers to the ‘Commonwealth’, it means to embrace all authorities created by virtue of enabling acts. Furthermore, neither authorities nor municipalities are sovereign; they have no original or inherent or fundamental powers of sovereignty or of legislation; they have only the power and authority granted them by enabling legislation.... The legislature many years ago recognized the need for efficient and inexpensive mass transportation systems designed to alleviate serious traffic difficulties in the overcrowded metropolitan areas of the Commonwealth. Thus, SEPTA and other transportation authorities were created pursuant to legislative guidelines designed to provide independent operating powers with minimal local government interference. The grant of broad powers by the Legislature was meant to insure efficient operation of the integrated transportation networks, not to expand the already large and complex state bureau*568cratic system. We do not believe that the Legislature intended SEPTA to be a Commonwealth agency in the traditional sense or for SEPTA employees to be considered Commonwealth employees for purposes of other legislative enactments. (Emphasis added.)
431 A.2d at 396, 397.
As Fisher holds, SEPTA’s purpose was to insure efficient mass transit, not to include it in an already large state bureaucracy. SEPTA seems to recognize this when it wants to deny benefits to its employees, but changes its position to shield itself from claims of insidious discrimination. Moreover, while the PCHR has jurisdiction given to it by the Ordinance, the term “legislative enactment” is broad enough to encompass the Ordinance, especially when the Ordinance was enacted pursuant to a direct grant of power by the General Assembly to local governments to enact their own human relations ordinances to wipe out insidious discrimination.
II.
Even if it is considered to be part of the Commonwealth government, the PCHR would still have jurisdiction over claims of unlawful discrimination.5 Implicit in SEPTA’s argument is that if it is part of the Commonwealth government, then it would automatically be immune from jurisdiction from the PCHR because the Ordinance would not apply to it, and it only would be subject to the provisions of the PCHR. In Ogontz Area Neighbors Association, the issue before the Supreme Court was whether the Department of General Services was required to comply with the Philadelphia Zoning Code in establishing a mental health facility. In holding that it was, our Supreme Court observed that:
The conflict ... is not a contest between superior and inferior governmental entities, but instead a contest between two instrumentalities of the state. The legislature has the power to regulate both of these governmental entities, enlarging or restricting their authority to act; and, generally, the task of courts in these cases is to determine, through an examination of the enabling statutes applicable to each of the governmental entities, which the legislature intended to have preeminent powers. The problem, essentially, is one of statutory interpretation.
Ogontz, 505 Pa. at 622-623, 483 A.2d at 452. See also Pennsylvania Gaming Control Bd. v. City Council of Philadelphia, 593 Pa. 241, 263, 928 A.2d 1255, 1268 (2007). Ogontz holds that the “statutory construction rule that legislative intent may be determined by a consideration, inter alia, of the consequences of a particular interpretation, Statutory Construction Act, 1 Pa.C.S. § 1921(c)(6)” was to be used to determine what “instrumentality of the Commonwealth” was to be preeminent — in this case, the City of Philadelphia or SEPTA. Id., 505 Pa. at 622, 628, 483 A.2d at 455.
Before making that analysis, just as they have been authorized to enact zoning ordinances, Philadelphia and other local governments have been specifically authorized to enact legislation to establish a human relations commissions with powers similar to that of the Pennsylvania Human *569Relations Commission. 43 P.S. § 962.1(a) provides “the legislative body of a political subdivision may, by ordinance or resolution, authorize the establishment of membership in and support of a Local Human Relations Commission.”6 Subsection (d) goes on to provide that “the legislative bodies of political subdivisions shall have the authority to grant to local commissions powers and duties similar to those now exercised by the PHRC under the provisions of this act.”
The PCHR was established by the Philadelphia Home Rule Charter. The PHRC has been granted powers and duties similar but not identical to that of the Pennsylvania Human Relations Commission by the Philadelphia Fair Practices Ordinance, being more expansive because it covers more subjects of discrimination, e.g., sexual orientation. The net effect is that there is largely concurrent jurisdiction between the Philadelphia and Pennsylvania Human Relations Commissions with each to report to the other complaints within their respective jurisdictions. Section 7 of the Pennsylvania Human Relations Act, 43 P.S. § 957; Section 8.2 of the Pennsylvania Human Relations Act, 43 P.S. § 962.1(e). The Pennsylvania Human Relations Commission is also allowed to share its workload with the PHRC, presumably involving complaints against SEPTA, if someone decided to file with the PCHR. 43 P.S. § 957.
In this ease, under the statutory analysis test prescribed by Ogontz, the consequence of holding that SEPTA should be preeminent over the City would frustrate the General Assembly’s legislative scheme to give concurrent jurisdiction to both state and local human relations commissions over claims of invidious discrimination. On the other hand, if the City and the PCHR are preeminent, that would not interfere with SEPTA’s purpose of providing public transportation. All the consequence of the City’s and the PCHR’s preeminence means is that SEPTA would still have to respond to complaints, like private companies, of those choosing to file their claims of unlawful discrimination with that agency. The consequence is even less if considering that they would have to respond to many of those same complaints if a person would be forced to file with the Pennsylvania Human Relations Commission. Although the General Assembly’s desire for local commissions to have similar powers to the PCHR to root out insidious discrimination at the local level would have serious consequences in general, the consequences for SEPTA, specifically, would be de minimis, even if we were to consider it a state agency, which it is not. Of course, should the legislature determine that SEPTA should not be subject to local human relations regulations, it need only pass legislation to that effect.
Because SEPTA is not a Commonwealth agency and even if it was, it is still subject to the jurisdiction of the Philadelphia Commission on Human Relations, I respectfully dissent.
. There are a number of statutes authorizing the creation of authorities. Most authorities are formed under the Municipal Authorities Act of 1945, Act of May 2, 1945, P.L. 382, as amended, 53 P.S. §§ 301-374. The 1945 Act was repealed by the Act of June 19, 2011, P.L. 287; see now 53 Pa.C.S. §§ 5601-5623. The types of authorities created by local governments under its provisions are many, including School Authorities (issue bond to build schools and then lease them back to the school district); Water and Sewer Authorities, Airport Authorities and Recreation Authorities. Other statutes authorize local governments to create authorities for specific purposes, the most important being the Housing Authorities Law, Act of May 28, 1937, P.L. 955, as aniended, 35 P.S. §§ 1541-1568.1; the Parking Authorities Law, Act of June 5, 1947, P.L. 458, as amended, 53 P.S. §§ 341-356; the Economic Development Financing Law, Act of August 23, 1967, P.L. 1967, as amended, 73 P.S. §§ 371-376; and the Urban Redevelopment Law, Act of May 24, 1945, P.L. 991, as amended, 35 P.S. §§ 1701-1747. The Parking Authorities Law was also repealed by the Act of June 19, 2011, P.L. 287.
. Article 9, Section 9 of the Pennsylvania Constitution provides, in relevant part:
The General Assembly shall not authorize any municipality or incorporated district to ... obtain or appropriate money for, or to loan its credit to, any corporation, association, institution or individual.
. See generally Southeastern Pennsylvania Transportation Authority v. Union Switch & Signal, Inc., 161 Pa.Cmwlth. 400, 637 A.2d 662, petition for allowance of appeal denied, 538 Pa. 662, 648 A.2d 792 (1994).
. 42 Pa.C.S. §§ 8542-8564.
. SEPTA makes the absurd argument that because it operates throughout southeastern Pennsylvania, the Philadelphia Human Relations Commission does not have jurisdiction. That would base jurisdiction on the locus or, more accurately, the multi-locus of the company, not the locus of the act of claimed discriminations. Under SEPTA's position, the Pennsylvania Commission on Human Relations would not have jurisdiction over companies that operate in several states.
. Section 12.1 of the Pennsylvania Human Relations Act, Act of October 27, 1955, P.L. 744, as amended, added by Section 3 of the Act of January 24, 1966, P.L. (1965), as amended, 43 P.S. § 962.1.