(Id. ) Further, the trial court found that Hobart sexually stalked a female coworker and that the award would force Hobart's victim to continue working with him. (Id. at 699a.) The FOP argues that these considerations are beyond the trial court's scope of review.
As previously mentioned, the trial court's scope of review is one of narrow certiorari. This narrow review precludes the use of public policy considerations to vacate an arbitration award. See Pa. State Police v. Pa. State Troopers Ass'n (Smith & Johnson) , 559 Pa. 586, 741 A.2d 1248, 1252-53 (1999). In rejecting the application of public policy considerations, our Supreme Court opined:
We are unable to accept this position. Broadening the narrow certiorari scope of review to include a provision which *726would allow the courts to interfere with an arbitrator's award whenever that award could be deemed to be violative of "public policy"-however that nebulous concept may be defined by a particular appellate court-would greatly expand the scope of review in these matters. If we were to adopt the ... recommendation to include this ill-defined term within the narrow certiorari scope of review, we would markedly increase the judiciary's role in Act 111 arbitration awards. This would undercut the legislature's intent of preventing protracted litigation in this arena.
While we agree that the convenience to the Commission, the financial impact on the Department and its taxpayers, and the underlying facts of the arbitration are matters beyond the scope of the trial court's review, we do not conclude that these considerations are reversible error. The crux of the trial court's decision centered on the fact that the award compelled the Department to commit an illegal act. The discussion regarding the burden to the Department and the taxpayers is auxiliary to that main holding, independent of the trial court's conclusion.
C. Error in Factfinding
In the same vein, we also dispose of the FOP's third argument-that the trial court erred by basing its decision on an incorrect factual finding. Specifically, the FOP takes issue with the trial court finding that Hobart "sexually stalk[ed] victims, including a fellow officer," and that reinstating Hobart would compel the Commission to force a victim to work with Hobart. (R.R. at 699a.) Although the parties agree that this finding is unsupported by record evidence, we determine that it played no significant part in the trial court's conclusion that reinstating Hobart would compel the Commission to commit an illegal act.
D. Substituting Judgment
Finally, the FOP argues that the trial court erred by substituting its judgment for that of the arbitrator. Specifically, the FOP argues that the trial court "felt the arbitrator should have considered the results and impact of his decision." (Appellant's Br. at 17.) By analyzing the results and impact of the award-including the burden to the Department and the taxpayers-the FOP argues that the trial court replaced the arbitrator's judgment with its own.
It is well-settled that a court may not substitute its own judgment for that of an arbitrator. See Sch. Dist. of Phila. v. Cmwlth. Assoc. of Sch. Adm'rs, Teamsters Local 502 , 160 A.3d 928, 933 (Pa. Cmwlth.), appeal denied , --- Pa. ----, 172 A.3d 591 (Pa. 2013). Here, we conclude that did not happen. Rather, the trial court evaluated ramifications of award implementation not contemplated by the arbitrator. The trial court sought to answer if the award compelled the Commission to commit an illegal act. The arbitrator provided no judgment with respect to this question. While the trial court unnecessarily explored other ramifications of the award-e.g. , the burden to the Department and the taxpayers-these considerations were peripheral to the central conclusion. The trial court, therefore, did not substitute its judgment for that of the arbitrator.
IV. CONCLUSION
For the reasons set forth above, we reject the majority of the FOP's contentions on appeal. Nonetheless, because implementation of the arbitrator's award in this case is possible if Hobart's access to JNET, CLEAN, and PennDOT's system is restored, we will vacate the trial court's award and remand with direction that the *727trial court stay the matter to allow the Department and Hobart to pursue with the appropriate agencies restoration of Hobart's access to those systems.
ORDER
AND NOW, this 31st day of October, 2018, the order of the Court of Common Pleas of Berks County (trial court) is VACATED, and the matter is REMANDED to the trial court for further proceedings consistent with the accompanying opinion.
Jurisdiction relinquished.
DISSENTING OPINION BY SENIOR JUDGE PELLEGRINI
The Court of Common Pleas of Berks County's (trial court) decision reversing the arbitration is cogent and well-reasoned. I wish I could affirm that decision. The majority opinion amending the arbitrator's decision in an attempt to make it more palatable is imaginative but impermissible. Yet I still wish I could join. However, because I am obligated to do so, I would reverse the trial court and reinstate the arbitrator's award. Let me explain.
I.
The underlying facts are not in dispute. Charles Hobart (Hobart) was a police officer for the Northern Berks Regional Police Commission (Commission). Hobart had a file at work containing approximately 80 pages of documents that included photographs of women in lingerie, bathing suits and other revealing attire. Several of the photographs showed women with exposed breast and vaginal areas and some showed women in bondage. Included within the file were several pages from the Pennsylvania Justice Network (JNET) system1 containing photographs and information of five civilians and a fellow female police officer in the department. There is no dispute that Hobart used these photographs for masturbation in the Department's men's room.
There is also no dispute that because of his misuse of the JNET system, Hobart's access to the Department of Transportation (PennDOT), JNET and the Commonwealth Law Enforcement Assistance Network (CLEAN)2 portals, which all police officers need to perform their jobs, was permanently revoked.
Notwithstanding all this, the arbitrator found there was not just cause for Hobart's termination, even though his access to the portals was permanently revoked and he may never be able to use those systems to apprehend criminals, which essentially means that he cannot give full value of his services for the salary that is paid to him by taxpayers.
If this were the outcome of a jury trial, I would reverse the jury's verdict because no reasonable person could find that Hobart's conduct in gathering pictures from official sources - including those of a fellow female police officer - so that he could masturbate in the Department's men's room, causing him to be permanently banned from access to the PennDOT, JNET and CLEAN portals necessary for *728an officer to perform his job, is not just cause for dismissal.
Even though I would hold that no reasonable person would agree with the arbitrator's outcome, I cannot do what any reasonable person would do and reverse the arbitrator because this Court is forced to apply the narrow certiorari test rather than the judgment notwithstanding the verdict (nov)/error of law standard that the General Assembly provided to be used in reviewing public employee grievance arbitration, including grievance arbitration involving police officers. Now let us take a look at the statutory standard for courts to use to review arbitration awards.
II.
A.
In the Uniform Arbitration Act of 1980 (UAA), 42 Pa.C.S. §§ 7301 - 7362, the General Assembly set forth the scope of judicial review of public sector agreements, including employee grievance arbitration of disputes. Section 7302(b) of the UAA provides the standard of review for grievance arbitrations arising out of a public collective bargaining agreement. Quoted in full, it provides:
(a) General rule.-An agreement to arbitrate a controversy on a nonjudicial basis shall be conclusively presumed to be an agreement to arbitrate pursuant to Subchapter B (relating to common law arbitration) unless the agreement to arbitrate is in writing and expressly provides for arbitration pursuant to this subchapter or any other similar statute, in which case the arbitration shall be governed by this subchapter.
(b) Collective bargaining agreements.-This subchapter shall apply to a collective bargaining agreement to arbitrate controversies between employers and employees or their respective representatives only where the arbitration pursuant to this subchapter is consistent with any statute regulating labor and management relations.
(c) Government contracts.-This subchapter shall apply to any written contract to which a government unit of this Commonwealth is a party to the same extent as if the government unit were a private person, except that where a contract to which the Commonwealth government is a party provides for arbitration of controversies but does not provide for arbitration pursuant to any specified statutory provision, the arbitration shall be governed by this subchapter.
(d) Special application.-
(1) Paragraph (2) shall be applicable where:
(i) The Commonwealth government submits a controversy to arbitration.
(ii) A political subdivision submits a controversy with an employee or a representative of employees to arbitration.
(iii) Any person has been required by law to submit or to agree to submit a controversy to arbitration pursuant to this subchapter.
(2) Where this paragraph is applicable a court in reviewing an arbitration award pursuant to this subchapter shall, notwithstanding any other provision of this subchapter, modify or correct the award where the award is contrary to law and is such that had it been a verdict of a jury the court would have entered a different judgment or a judgment notwithstanding the verdict.
42 Pa.C.S. § 7302 (emphases added).
The reason I cannot apply the judgment nov/error of law standard that governs *729grievance arbitrations, including those involving police officers, is because our Supreme Court has issued several decisions that preclude applying the legislatively prescribed mandate. First, a short history of the development of standards of review regarding appeals from grievance arbitration awards is in order.
B.
Our Supreme Court has continued to apply the "essence test" standard of review3 in the context of grievance arbitration under the Public Employe Relations Act (Act 195),4 though recognizing the UAA judgment nov/error of law standard is what the General Assembly has said is to be used in reviewing all public sector grievance arbitration cases, because it views the essence test as essentially the same as the judgment nov scope of review. The Supreme Court held in Community College of Beaver County v. Community College of Beaver County, Society of the Faculty (PSEA/NEA) , 473 Pa. 576, 375 A.2d 1267, 1273 (1977), that the "introduction of the 'n.o.v.' concept ... is hardly a radical change, nor does it dictate that a much closer or different scrutiny of an arbitration award will be available than under the [essence test]." This case, however, was decided under the Arbitration Act of 1927, which had a judgment nov standard, but did not expressly apply to public sector collective bargaining agreements as did the UAA. See Pennsylvania State Education Association v. Appalachia Intermediate Unit 08 , 505 Pa. 1, 476 A.2d 360, 362-63 (1984) (holding that the *730section of the UAA governing power of a reviewing court to modify or correct an arbitration award is a substantial reenactment of the corresponding provision of the Arbitration Act of 1927). In considering a motion for judgment nov, the court must view the evidence and all reasonable inferences that arise from the evidence in a light most favorable to the verdict winner. The court can enter judgment nov only if "no two reasonable persons could fail to agree that the verdict is improper." Northwest Savings Association v. Distler , 354 Pa.Super. 187, 511 A.2d 824, 825 (1986).
Our Supreme Court has, through a variety of exceptions, albeit by a different name but with the same goal - the public policy exception,5 which replaced the core functions test,6 which replaced the manifestly unreasonable test7 - made the essence test the same as the judgment nov/error of law test.
III.
A.
However, what is before us is the review of an Act 1118 grievance arbitration award. Our Supreme Court has applied the narrow certiorari test rather than the essence test to police and firefighter grievance arbitrations, notwithstanding that the UAA provides for a judgment nov/error of law standard for all arbitrations.
Act 111 was enacted following a 1968 constitutional amendment to amend *731Article III, Section 319 of the Pennsylvania Constitution that provided an exception to the prohibition of the delegation of a municipal function to a private individual by authorizing the General Assembly to enact legislation to allow a private arbitrator to set the terms and conditions of employment for police and firefighters. Grievance arbitration, however, was not constitutionally prohibited prior to this amendment. This is evident by the requirement of mandatory grievance arbitration contained in Act 195 which would not have been possible if it were unconstitutional. Erie Firefighters Local No. 293 of the International Association of Firefighters v. Gardner , 406 Pa. 395, 178 A.2d 691 (1962).
It outlines a procedure for uniformed personnel to engage in such bargaining that culminates in binding interest arbitration pursuant to specified procedures. Through those procedures, a collective bargaining contract or an interest arbitration award would govern the terms and conditions of employment. The provisions of Act 111 deal mainly with interest arbitration and the resolution of grievances are barely mentioned in Act 111 except for one brief reference in Section 1, 3 P.S. § 217.1, that mentions "settlement of grievances".10 Unlike Section 903 of Act 195,11 Act 111 does not expressly mandate grievance arbitration. See also Upper Makefield Township v. Pennsylvania Labor Relations Board , 717 A.2d 598, 601-03 (Pa. Cmwlth. 1998), aff'd on other grounds , 562 Pa. 113, 753 A.2d 803 (2000). Until the Pennsylvania Supreme Court's decision in Betancourt , there was a dispute over whether Act 111 even provided for grievance arbitration. See Pennsylvania State Police v. Pennsylvania State Troopers' Association (Betancourt) , 540 Pa. 66, 656 A.2d 83, 87 (1995).
There is no scope of review for arbitration awards contained in Act 111. No scope of review was needed, though, since Section 7 of Act 111 states that "[n]o appeal [from an arbitration award] shall be allowed to any court." 43 P.S. § 217.7(a). Shortly after Act 111 was enacted, our Supreme Court in City of Washington v. Police Department of Washington (Washington Arbitration) , 436 Pa. 168, 259 A.2d 437, 441 (1969), held that the narrow certiorari *732scope of review applied to an appeal of an Act 111 interest arbitration award.
At that time, the narrow certiorari test was common. There were many categories of administrative decisions where the General Assembly had stated there should be no right of appeal to a court from that administrative determination. Other statutes were silent as to whether a party had the right to appeal the administrative decision. Even though the statute prohibited any appeal or did not authorize an appeal, our Supreme Court dealt with this matter by adopting rules that addressed each of those situations. It provided for a narrow certiorari scope of review for appeals brought when the statute said there would be no appeal from an agency decision. However, where the statute was silent on the right to appeal, our Supreme Court adopted a broad certiorari standard, similar to the administrative agency scope of review. No matter which standard of review applied, an appeal was by petition for allowance of appeal and not by right. This is why the narrow certiorari test was applied to review police and firefighter arbitration awards.
After Article V, Section 9 of the Pennsylvania Constitution12 was adopted in 1968, providing for the right of appeal of all common pleas and administrative agency decisions, the narrow and broad certiorari standards of review were abandoned as no longer necessary and the rules that created those standards are no longer extant. All other appeals previously not permitted were now allowed under the statutory standard of review, such as that in the Administrative Agency Law.13 The only appeals for which the vestigial court-created narrow certiorari standard still apply are appeals from police and firefighter arbitration awards.14
B.
The issue of whether police grievance arbitration awards as opposed to interest arbitration awards were governed by narrow certiorari was not decided until almost 30 years after the enactment of Act 111. In Betancourt , our Supreme Court, while acknowledging that Act 111 provided detailed procedures for interest arbitration and how it was to be conducted, provided no such direction for grievance arbitration. The Court decided that since Act 111 purportedly authorized grievance arbitration for police and firefighter personnel, it was the intent of the General Assembly in Act 111 to impose a restraint on judicial activism in order to ensure swift resolution of disputes involving police and firefighters that made the narrow certiorari standard applicable, not the judgment nov/error of law/essence test. It stated:
We are not persuaded that the legislature intended grievance arbitration awards to be subject to broader judicial review than are interest arbitration awards. There is no indication, either in the Act itself or in the history of the Act, that the legislature intended appeals from grievance arbitration awards to be *733subject to greater judicial involvement than interest arbitration awards. We will not now allow a scope of review [essence test] which is markedly broader than narrow certiorari for Act 111 grievance arbitration. To do so would allow the courts to interfere impermissibly with the legislative scheme as the courts would be able to alter Act 111 arbitration awards by means of an unauthorized expansion of the proper scope of review. Such a result would run counter to the legislature's intent. Thus, we hold that the proper scope of review is narrow certiorari.
Betancourt , 656 A.2d at 89 (emphasis in original).
As a result of Betancourt, the application of the narrow certiorari test means that courts could not review arbitrator decisions that reinstate police officers who engage in illegal conduct. See Pennsylvania State Police v. Pennsylvania State Troopers Association (Smith) , 559 Pa. 586, 741 A.2d 1248 (1999) (holding that the Court could not disturb an arbitrator's reinstatement of a state trooper who jammed his loaded, police-issued weapon into his ex-girlfriend's mouth and threatened to kill her, as well as later being arrested that day for driving under the influence, simple assault, and making terroristic threats, charges to which he subsequently pleaded guilty); City of Philadelphia v. Fraternal Order of Police, Lodge No. 5 , 711 A.2d 1060 (Pa. Cmwlth. 1998) (holding that the Court could not disturb an arbitrator's reinstatement of a Philadelphia police officer who crashed her police cruiser into parked cars while under the influence of alcohol and cocaine).
Not only did the Betancourt decision limit the ability of courts to review disciplinary decisions involving criminal conduct, it also limited the ability of courts to review an arbitration award in which an arbitrator has essentially rewritten the parties' agreement or issued an award that is so illogical that the parties never intended the result. For example, in Bensalem Township v. Bensalem Township Police Benevolent Association , 803 A.2d 239 (Pa. Cmwlth. 2002), we held that we could not review an arbitrator's award that clearly violated the provisions of the collective bargaining agreement. In that case, the township discharged a police officer who was subsequently reinstated by an arbitrator. The collective bargaining agreement prohibited an arbitrator from awarding monetary relief in excess of one year. The narrow certiorari test prevented the Court from examining an arbitrator's award that not only reinstated the police officer, but awarded him 21 months' back pay and benefits - nine months more than the parties authorized under the collective bargaining agreement.
C.
I respectfully urge our Supreme Court to reexamine its holding in Betancourt. Making any attempt to divine the intent from Act 111 as to what standard of review should apply is unwarranted. This is especially so when the General Assembly has provided in the UAA, 42 Pa.C.S. § 7302, in plain and mandatory language, that the judgment nov/error of law standard should be used to review all collective bargaining grievance arbitrations. This was not an accident. When adopting the National Uniform Arbitration Act, the General Assembly inserted 42 Pa.C.S. § 7302 into that act to set the judgment nov/error of law standard. It could not be clearer.
Because the UAA is clear as to the standard of review in grievance arbitration cases, it is not necessary to discuss the factors relied on in Betancourt to justify its adoption of the narrow certiorari test. However, a short discussion of the factors *734relied on in Betancourt to find that the narrow certiorari test applied are in order. One factor mentioned in Betancourt is that courts would impermissibly interfere with police and firefighter arbitration awards and those appeals would get bogged down in the courts if the judgment nov/error of law/essence test applied. That fear is simply not warranted. Even though the judgment nov/error of law standard allows slightly more judicial oversight than the essence test, it is not an intrusive scope of review. This test was formulated so courts would be deferential to arbitration awards and intervene only where an arbitrator clearly did not satisfy his obligation to interpret the collective bargaining agreement or acted in a way that no reasonable person could accept the outcome. Moreover, the same judicial procedures essentially are followed regardless of whether the arbitration award is reviewed under the narrow certiorari scope of review or the essence test, and the essence test is not mired in protracted litigation.
Finally, applying the narrow certiorari test does not serve the public interest because it does not allow courts to review arbitration awards to determine whether an award sanctions a police officer's conduct that harms the public, breaches the public trust or brings discredit on the ability of the police department to carry out its functions. If the judgment nov/error of law test applies, courts could review the decision of the arbitrator, a private party, to determine if his decision was against public policy. See Philadelphia Housing Authority v. American Federation of State, County and Municipal Employees, District Council 33, Local 934 , 617 Pa. 69, 52 A.3d 1117 (2012) (holding that an arbitration award reinstating an employee discharged for acts constituting sexual harassment violated well-defined and dominant public policy). Courts could also review the conduct in this case to determine whether any reasonable person would arrive at the same decision that this arbitrator did.
Now to this appeal and why I am compelled to dissent.
IV.
In this case, the trial court concluded that the arbitrator exceeded his powers by ordering the Commission to return Hobart to his position when he would not have access to PennDOT, JNET and CLEAN records. The trial court also found that because Hobart would be in the area where the computers were located, he could potentially see data that he was not entitled to see, risking the Commission's continued access to those portals. The trial court found that Hobart sexually stalked a female coworker and that the award would force Hobart's victim to continue working with him.15
The majority, while substantially agreeing with the trial court, nonetheless vacated the order because it found it was premature to decide whether the award putting Hobart back to work compels the Commission to be at risk for losing access to PennDOT, JNET and CLEAN's systems, as well as potential criminal liability if Hobart happens to see any protected data generated by those systems. It then modified the trial court's order finding just cause to dismiss by ordering that until such a time that Hobart and the Department have exhausted all avenues of relief to regain Hobart's access to PennDOT, JNET and CLEAN's systems, the *735question of whether the award can be implemented without violation of law cannot be decided finally. It then vacated the trial court's order and remanded the matter to the trial court with instruction to stay the matter until Hobart and the Department have exhausted all avenues to reinstate Hobart's access to these systems, at which time the trial court may then consider the question of whether the Commission can implement the award without violating the law. The net effect is that if Hobart does not get his permanent revocations to PennDOT, JNET and CLEAN's systems reversed, then the arbitrator's decision will be reversed.
I disagree with the majority because nothing that the arbitrator ordered would cause the Commission to commit an illegal act.16 Nothing in the arbitrator's award requires that the Commission give Hobart access to those portals, only that it continue to employ him as a police officer. Under the award, it is up to the Commission to fashion a position in which Hobart would not have access to that information. While not having access to those portals would limit his usefulness and cause expense and difficulty within the Commission, to fashion such an award does not require the Commission to perform an illegal act. Unfortunately, under the narrow certiorari test, added expense and inconvenience does not justify a reversal of the arbitrator's award.
While the arbitrator's award is unreasonable, under the narrow certiorari standard, because the arbitrator had the right to determine whether there was just cause for termination, the award did not order the Commission to do anything illegal and there was no deprivation of anyone's constitutional rights, I would reinstate the arbitrator's award and reverse the trial court. Accordingly, I respectfully dissent.