Direct Testimony of Thomas M. Hildebrand - Consumer Advocate ...

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terms.” The TrAIL line will directly impact three States, PA, WV, and VA.
Several counties in Virginia have been aggressively arguing that any new high
voltage lines approved must be placed underground and there is the real
possibility that this may happen. To my knowledge, TrAILCo has not stated that
it will follow the same requirements (if underground lines are required) for
construction in West Virginia as is determined by the other impacted States. In
other words, if the line is required to be placed underground in VA, will TrAILCo
follow the same requirement in WV? If TrAILCo will not certify to the
Commission that it will follow the same installation approach in all States, this
represents an instance whereby a utility (not withstanding my belief that TrAILCo
is not a WV public utility) would be “furnishing underground electric distribution
under different terms for customers receiving the same class of service.”
9) Not withstanding my belief that TrAILCo is not a WV public utility, Para 10.4
states, “no direct or indirect expenditures may be included in a utility’s cost of
service for political advertising. Any expenditures for political advertising are
expressly disallowed.” To my knowledge, TrAILCo has not certified that all
costs associated with political advertising, public relations, etc. in newspapers
across WV to influence public opinion will not be filed to be recouped under
FERC rules and potentially charged to customers. This may be a violation of the
intent of para 10.4.
10)Not withstanding my belief that TrAILCo is not a WV public utility, para 10.5.4
states, “utility or its affiliate may not continue to engage in promotional practices
after January 1, 1997 unless a schedule regarding promotional practices has been
filed with the Commission. TrAILCo has clearly been engaged in an aggressive
attempt to sway public opinion using advertisements. I offer this for the
Commission to consider. In April of 2006, TrAILCo learned of FERC’s decision
that the cost for TrAIL would be allocated to all West Virginia ratepayers (See
Attachment 4, Supplemental Direct Testimony of Mark Mader before the PA
Public Utility Commission). In June 2006, two months later, TrAILCo sent spam
email to the public using carefully chosen words I believe were intended to
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