Robin L. Moter
7070 Midland Trail West
Hines, WV 25958
November 12, 2015
Ms. Ingrid Ferrell
Executive Secretary
Public Service Commission of West Virginia
201 Brooks Street
P. 0. Box 812
Charleston, WV 25323
RE:
Robin L. Moter v. Appalachian Power Company
P.S.C. Case No. 15-1756-E-C
Dear Ms. FerrellL
Today in the mail, Ireceived a certified letter (copy enclosed) from Gina E. MazzeiSmith, Senior Counsel for Appalachian Power.
If you will note, the letter is their answer for my complaint against Appalachian Power
noted above. I n the answer it states that on April 3, 2015, that APCO and Wheeling
Power Company (WPCo) together filed a petition of the Commission‘s consent and
approval for the Companies (both APCO & WPCo) to enter an arrangement with their
affiliate, American Electric Power Service Corporation (AEPSC), pursuant to WV Code
24-2-12 (case no 15-0514-E-PC). The companies filed a petition in Case No. 15-0514E-PC to gain approval to execute a work authorization and begin operating under the
Homeserve Master Services Agreement (“Agreement”).
Pursuant to the Agreement, HomeServe will offer the Companies’ residential customers
certain optional programs for the repair of their domestic infrastructure and related
systems.
On September 16, 2015 the Commission granted its consent for the Companies to enter
into a contract with an affiliated company relating to services provided to the
Companies’ customers in connection with home warranty programs that the Companies’
customers may purchase.
It states in the letter that APCo would like to point out that customers are, in fact,
responsible for the equipment from the point of attachment to Company facilities to the
customers’ homes. This is not a new requirement. Additionally, the services that are
being offered to customer through HomeService are completely optional services.
Customers are under no obligation whatsoever to purchase them. I f the Complainant
does not want to purchase any of those services, she is not required to do so. At this
point they request the Complaint be dismissed.
Iam also enclosing an E-mail from Terry Eads, with the West Virginia Public Service
Commission. If you will note, he is stating the Commission Order date is in 20@ n%
2015; via Case No 99-1758-E-PC stating that the Commission discontinued
practice of providing this limited amount of free wire. It also states that i
with that requirement, APCo published the following in newspapers of gen
circulation in its service territory:
NOTTCE APPALACHIAN POWER COMPANY D/B/A AMERICAN ELEORIC
EFFEcTlVE SEPTEMBER 7,2000, APPALACHIAN POWER COMPANY WILL
THE PRACTICE OF INSTALLINGSERVICE ENTRANCE FACILITIES FOR RESIDENTTAL
CUSTOMERS FREE OF CHARGE. THE PUBLIC SERVICE COMMISSION OF
(“COMMISSION) ISSUE AN ORDER ON THE 2gm OF FEBRUARY, 2000, WHICH
OUTLINES THE COMMISSIONS INTERPRUA TTON OF THE TERM “CUSTOMER SERVICE
CUSTOMERS WUI THERHUID OR THE EQUIVALENT POINT WHERE THE SERVICE
DROP ATTACHED TO THE SERVICE ENTRANCE CABLE CONNECTED TO THE METER‘:
THE CUSTOMER WILL BE RESPONSIBLE FOR PROVIDING AND INSTALLING OR
HAVING INSTALLED THESERVICEENTRANCE CXBLE FROM THE COMPANYS POINTOF
ATTACHMENT THE WEATHERHEAD OR EQUIVALENT POINT TO THE MUER BASE
Therein lies my point of contention. Iam a retired supervisor with Verizon with over 20
years service. I know that when a customer calls to set up new service, as Idid in
December 2005, (while still living in Virginia), Iwas not made aware of this policy. I
know that you have to let the customer, ie me, know of any and all conditions in
regards to new service and nothing was stated to me concerning this.
I f you will note, the dates on the paperwork Ihave received are all different and if in
fact it went into effect in 2000, Ishould have been made aware of this. Which Iwas
not.
Considering all of the confusing information Ihave received from APCo and the PSC I
wonder if anyone knows the true date (if there is one) that this applied. Idid not see
anything in the paper since I have been here from 15 December 2005 to present.
Iwould like to see the notices’ that were published in the paper as it says, date of
publication, name of newspaper and photo of ad.
It appears to me this case is definitely not closed and I am going to continue to fight for
my rights as a citizen of this state. You see, Ihave a college degree and Iam not your
typical West Virginian (which there is nothing wrong with that) but Iam very literate in
dealing with money and worked as a CPA in the legal department of Verizon. Iknow
what looks right and smells right and this does not,
If you look at the paperwork from Homeserve, it shows they cover everything from
meter boxes, weatherheads to inside wiring, water heaters, HVAC, exterior water lines,
etc. This is nothing more than a extended warranty on your home like the rip offs
concerning cars on tv.
Oh by the way, when I called the PSC and spoke to Lynn Scott, Administrative Secretary
to Terry Eads, she admitted to me she got the post card concerning this and had no
idea what it was about either and she works there for the Director of the PSC. I s it me
or does that sound and smell fishy to you?
I would like an answer to this letter no later than 22 November 2015.
Robin L. Moter
cc
Enclosures
Utilities Division
The Utilities Division provides accounting, financial, economic and other technical analysis of
Commission cases and processes rate and other filings made by electric and natural gas utilities, solid
waste carriers, taxis, limousine services. household goods movers, wrecker operators and COmmerCial
solid waste facilities. This Division is also responsible for addressing formal customer complaints filed
against natural gas and electric utilities and informal complaints dealing with other regulated utility
services. The Utilities Division Staff specializes in matters related to telecommunications and cable
television regulation.
The Utilities Division also prepares original financial and statistical reports, including reports on utility
earnings, rate comparisons, gas and electric supplyldemand forecasts and low income rate discount
programs.
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internal form.
4 \"
tions Section
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Fax
(304) 340-0462
Informal Complaints
Consumer Assistance
Carla Nelson
Supervisor
Bridgitt Carpenter
Consumer Affairs Technician
Shannon Foutche
Consumer Affairs Technician
Cynthia Pauley
Consumer Affairs Technician
Teresa Sanders
Consumer Affairs Technician
11/6/2015
:?E: [PSC Employee Contact] case number for APCO making customer responisble for w... Page 1 of 2
COMPOSE
RE: [PSC Employee Contact] case number for APCO making customer responisble for weatherhead I meter base at
entrance IIPCO x
lnbox (51
impMsnt
Sent Mail
DiaHE
swm lv
Trash
AARONS (4)
AARPII]
I
Eads, Teny [email protected] WY us>
Nov 9 (3 days ai
to me
Mr. Momr
Bared on your note t o me, Ipresume your question is a iervlfof the recent offer by APCo to provide insurance for the service entrance,
your home. As their pmgrem indicates. a home’s sewice entrance equipment is the custome<r rerponribillfy. If the home I served from by an
service drop. the electric utiliw owns, installs and maintains the iesvice drop exfending from the nearest poletothe point on your home where
utility ( h e aftaches <a
. the house. If tho home is ruppWd underground, the “titi* is rerpMILiblefox the underground $emicedrop to the mete8 b
house. Any weatherhead, conduit, remice entrance conductor or other apparafui (atherthan the meter bare) lrom the point where their ~ e r v i i
terminates a t fhe house. is supplied, inrialled and owned by the cuifomei and therefore the cuitomer’r rerponiibility.
A W O N 18)
APCO(2)
BECKLEY ARM (2)
BEEN VERIFiEO
for fhe masf pait, this is not e new arrangement for electric ufitifier in %heState. Howevei, prior to September 7,2000. APCo (and mnly
war providing residential customer$With thew/i?.&
from the weatherhead dawn to the meter bare at no charge. By Commission Oider date
2000 in Care No. 99-1758-E-PC, the Commission discontinued APCo’r practice of providing this lbmiied amount of free wire. In approving this ch
Commisiim reqviied that APCo proYidelegainatiiefofhe public of thechange. In accordmce withthafrequirement,APCapvblirhedthefollo
newrpaperr of genera8 circulation in ill service territory:
BLUE CROSS 133)
CAPITAL ONE (30)
CiTiZENS
CONTINENTIALFi
COURT
OiSCOUNTS
NOTICE: Appolochion Power Compooy d/b/o Ameriton EIeRrIc P w e r - Effective September 7, 20W.Appolochion mower Cornpony 1
will dlsronfinve theProRice of Inrtolllng service entronrr f o c i l i U ~for
~ reridentiel rurtomer9lreeof rhorge. The Public Service Commirrlon of
I”C0mmirrlon”)hwe on order on the 2 8 ojFebcbruory, 2000, which outliner the Comm~im‘9hle~preloll~n
01 the term “rurromerrcrvlceou
corfomer’r “weotherheod, or the equivolentpolnt where the service drop offothcd to the lervl~eentrance coble connected to the
n
Corcomer will be r e r p o n r l b l ~ l o r p r o v gondimtolling or having installed the service enfrome roble from the Company's polm of attochme
the weotherhead or equivalent paint, lo the mete, bo%
i hopefhiranrwerryourinqviry. Should you haveanyadditional question% feelfreetorontacl me
11/12/2015
Checkout Success
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11 18I ... 1 1/5/2015
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ABOUT
SSL CERTIFICATES
https://www.homeserveusa.comimail/aepappalachi~power/thank-you?order-n m = 5 11 18 1... 11/5/20] 5
YOUR ENCLOSED DECLARATION PAGE IS AN INTEGRAl PART W YWR SERVICE AGREEMENT
AND ALONG W H THESE TERMS AND CONDITIONS AND ARBITRATION INSERT CONSTITUTE
YOUR ENTIRE AGREEMENT
€XlEfWR UEClT%bl WE l E ~ b N D C O N ! J ~ D N S
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NOTICE: WE PAY PERSONS NOT EMPLOYED By us FOR THE SALE, ADVERTISPIG,
INSPECTON, OR PROCESSHG OF A RESIDEWIAL S W C E CONTRACT UNDER T W
OCCUPATDNS CODE 613m3M
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ARBITRATION OR SMALL CLAIMS ACTIONS.
THIS ARBITRATION PROVISION DOES NOT APPLY TO RESIDENTS OF
OREGON AND WYOMING.
OR PRAYERS FOR RELIEF MAY BE MAINTAINED IN ANY
ARBITRATION HELO UNDER THIS AGREEMENT. NO AAA RULE
WILL APPLY IF IT CONFUCTS WITH THE PROWIONS OF
THIS AGREEMENT. IN ADDITION, NOTWITHSTANDING ANY
CONTRARY PROVISION IN THE AAA RULES, THE ARBITRATOR
WILL BE WOUND TO APPLY LEGAL PRINCIPLESAND THE LAWS
THAT GOVERN THIS AGREEMENT, AND W E S NOT HAVE THE
POWER TO AWARD ANY RELIEF THAT IS NOT AUTHORIZED BY
SUCH LAWS
WE HOPE TO MAKE YOU A HAPPY CUSTOMER. BUT IF WERE’S
A h ISSUE THAT hEEOS TO WE RESOLVED, THIS SECTOh
OUTLINES WHAl’S EXPECTED OF ALL OF US > O . h Y l T ? ,
AMCR.CIVV AAKHAAl I h C
.Ab or ” S Ah11 riOMt-SkNW .SA
REPARMANAGCMChI COUP vIOMESiR/C or A V O , L S I&.
AGRFF 1 0 1 l t S O . W llsSPull:> Oh.” H) + hA. hhll H hl) hti
i R B l R A T O h O I l I h S M h ~ i C r ~ \ U S C O . R llI<CHC S h O . l S S E
OK . J H I h L H H I l I I A l O h Ah11 O l n F H I’H0CkI)JWS Ahl’
DirTCRENT PLT AN ARBiTRAlOR CAh AIIARD VOL T n C SAME
DAMAGES AND R t i EF AND MUST K h O R TnE SAME TCRMS ih
~MSAGREEIECNIA S A C O J H l WO-.U IF T l r E .AY.A..OASFOH
A h A A A W OF ATlOHhtYS SFFS Ah AIIHI(iIAI0H CAh AAAKI)
I ~ C M1 0 0 vn n s o N L AGHI~E n m r
A. THE FEDERALARHITRATIONACT(9U.S.C. $5 1 ETSEO.)AND NOT
ANY STATE LAW APPLIES TO THIS AGREEMENT. EXCEPT FOR
SMALLCWMS COURTCASESTHATOUALIFYANYDISPUTETHAT
IN ANY WAY RELATES TO OR ARISES OUT OF THIS AGREEMENT
ORFROMANY OTHERAGREEMENTBEMEN US, ORSERWCES
OR BFNEFITS
RFCFIVF OR CI AIM TO
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NORTH AMERICAN WARRANTY INC. OR HOMESERVE. WALL HE
KESOI.JIUBVOhF ORMOKt NI L l K A l AH8 I H A l O K S H l l O K C
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S h t l l OR PROVOLR ARB TRAl O h AhD T n i S PARAGQAPn
% % A t . I + T . I l O C . & M S I t A l AKOSIAl Ah* Ilk11 NC.uIIihC
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HEARING IN-PERSON OR BY PHONE.
C THIS AGREEMENT DOES NOT ALLOW CLASS OR COLLECnVE
ARBITRATIONS EVEN IF THE AAA PROCEDURES WOULD.
NOlWITHSlANDING ANY OTHER PROVISION OF THIS
AGREEMENT, THE ARBITRATOR SHALL NOT HAVE THE POWER
TO DETERMINE THAT CLASS ARBITRATION IS PERMISSIBLE
THE AREITRATOR ALSO ShALL hOT HAVE THE WWER TO
PRESIDE OVER CLASS OR COLLECTIVE ARWlTRATlOh. OR TO
AWARD ANY FORM OF CLASSWIDE OR COLLECTIVE REMEDY.
INSTEAD, THE ARBITRATOR SHALL HAVE POWER 10 AWARD
MONEY OR INJUNCTIVE RELIEF ONLY IN FAVOR Of THE
INDIVIDUALPARTY SEEKING RELIEF AND OhLY TO THE EXTENT
NECESSARY TO PROVIDE RELIEF WARRANTED BY THAT
PARTY’S INDIVIDUAL CLAIM NO CLASS OR REPRESEhTATIVE
OR PRNATE ATTORNEY GENERAL THEORIES OF rlABlllTY
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wil l i h C \I_ I AS1 30 LAYS N ADIANCC CT h#’AT h G 1nL
A R B l R A l O h A n c O r k S l 10 M D I H A l t - A I I S P - r k MA(
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7 ,~C T I L O O R NOl1WA.K ‘lOhhFCI.C..’
W851 A I I h i k C A
DEPARTMENT. THE NOTICE MUST DESCRIBE THE NATURE
OF THE CLAIM AND THE RELIEF BEING SOUGHT. IF WE ARE
UNABLE TO RESOLVE OUR DISPUTE WlTHlN 30 DAYS, EITHER
PARTY MAY THEN PROCEEDTO FlLEACLAlM FORARBITRATION.
HOMESERVE WlLL PAY ANY FlLlNG FEE, ADMINISTRATION,
SERVICE OR CASE MANAGEMENT FEE, AND ARBITRATOR
FEE THAT THE AAA CHARGES YOU FOR ARBITRATION OF THE
DISPUTE, UP TO A MAXIMUM OF $1.500 PROVIDED, HOWEVER,
THAT THE ARBITRATOR MAY AWARD COSTS AND EXPENSES
TO ANY PARTY. IF ALLOWED BY LAW. IF YOU PROVIDE US WlTH
SIGNED WRITTEN NOTICE THAT YOU CANNOT PAY THE FILING
FEE, HOMESERVE WILL PAY THE FEE DIRECTLY TO THEAAA.
~~~~
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E I F FOR SOME REASON THE PROHIBITION ON CLASS
ARBITRATIONS SET FORTH IN SUBSECTION C CANNOT WE
ENFORCED, THEN THE AGREEMENT TO ARBITRATE WILL NOT
APPLY.
F IF FOR ANY REASON A CLAIM PROCEEDS IN COURT RATHER
THAN THROUGH ARBITRATION. YOU, NORTH AMERICAN
WARRANTY, INC. AND HOMESERVE AGREE THAT THERE WILL
NOT WE A JURY TRIAL. YOU, NORTH AMERICAN WARRANTY.
INC. AND HOMESERVE UNCONDITIONALLY WAIVE ANY
RIGHT TO TRIAL BY JURY IN ANY ACTION, PROCEEDING OR
COUNTERCLAIM ARISING OUT OF OR RELATING IN ANY WAY
TO THIS AGREEMENT OR FROM ANY OTHER AGREEMENT
BETWEEN US, OR THE SERVICES OR BENEFITS YOU RECEIVE
OR CLAIM TO BE OWE0 FROM NORTH AMERICAN WARRANTY,
INC. OR HOMESERVE, INCLUDING AS TO CLAIMS ASSERTED
AGAINST ANY OF THE OFFICERS, DIRECTORS, MANAGERS,
EMPLOYEES,AGENTS,AFFILIATES.INSURERS, CONTRACTORS,
SUCCESSORS OR ASSIGNS OF NORTH AMERICAN WARRANTY.
INC. OR HOMESERVE, AS WELL AS THE ADMINISlRATOR,
SERYlCEAGREEMENTADMINISTRATOR, 1SSUER OR PROVIDER.
[NOTE: IF YOU ARE AN EXISTING CUSTOMER THIS PROVISION
SHALL BECOME EFFECTIVE AS OF YOUR FIRST ANNUAL
RENEWAL OCCURRING AFTER [MONTH. DAY. YEAR].]
Page 1 of 9
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1 Repair Plan Details
1
HomeServe USA Repair Management Corp. I"HomeServe"J,with corporate offices located at 601
Merritt 7,6th Floor, Norwalk, CT 06851, is an independent company separate from Appalachian
Powerand offers this optional service plan as an authorized representative of the service
contract provider, North American Warranty, Inc., 175 West Jackson Blvd., Chicago, II 60604.
Your choice of whether to participate in this service plan will not affect the price, availability or
terms of service from Appalachian Power.
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Why Choose HomeServe USA?
Over 2 million homeowners covered
$0 deductible
Local, licensed ond insured technicians
One-year guarantee on all covered repairs
30-day money-bock guarontee
HomeServe USA Repair Management Corp. VHomeServe")is an independent company
separate from Appa/achianPower.
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Corporate Office: 601 Merritt 7, Norwolk CT 06851
0Copyright 2015 HomeServe USA. All rights reserved.
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11/5/2015