VIA HAND DELIVERY. Re: Joshua S. Foster v. Appalachian Power Company P.S.C. Case No E-C. Dear Ms. Ferrell: July 17,2015

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1 A unit OfAmerican Electric Power Appalachian Power 20 Box 198G Charlesrw Vfll Appalachiani'oww cam July 17,2015 VIA HAND DELIVERY Ingrid Ferrell Executive Secretary Public Service Commission of West Virginia 201 Brooks St. P.O. Box 812 Charleston, West Virginia Re: Joshua S. Foster v. Appalachian Power Company P.S.C. Case No E-C Dear Ms. Ferrell: Please find enclosed for filing in the above-styled case an original and twelve (12) copies of the ANSWER OF DE~ENDA~~, A ~ ~ A L A ~ ~ A ~ NU, in the above-referenced proceeding. A copy was mailed to Complainant Joshua Foster on this date, and a copy was hand delivered to PSC staff attorney, Lucas Head, on this date. Thank you for your attention to this matter. Enclosures cc: Lucas Head Joshua S. Foster

2 PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CASE NO E-C JOSHUA S. FOSTER, Complainant, v. APPALACHIAN POWER COMPANY, Defendant. ANSWER Appalachian Power Company ( APCO or the Company ), files the following as its Answer to the complaint filed in this case: On July 9,2015, Joshua S. Foster (hereinafter referred to as Complainant ), filed a formal complaint stating the Company denied him service when he s never had service in his name. The Complainant further stated he was sent a letter advising him all he had to do was pay the deposit and requested the electric on. The previous account at 3551 Clover Dr. Charleston, was in the name of Ronnie White and was disconnected for nonpayment on September 24, Service was disconnected again on March 26, 2015 and June 23, 2015 for excessive use. Mr. White has also reapplied several times but never paid his debt causing the orders to cancel. Since September 24, 2014, there has been 5,247 kwh of excessive use on the meter. The Company has confirmed with the landlord that Ronnie White still resides here and that Joshua Foster is a friend to a relative of Ronnie White.

3 The Complainant first filed an informal complaint with the WV PSC; RFA 2015R The following response was given regarding the RFA and Company s response has not changed: The Company is holding the service requested under Joshua Foster until he provides proof of household change. Previous issues at 3551 Clover Dr. in Charleston were accumulated under the name of Ronnie White, whose service spanned from 03/23/2009 to 09/24/2014. Since the account closed, Ronnie has reapplied 4 times, as recently as Each time he did not meet his old debt requirement, so the orders were subsequently cancelled. Joshua Foster applied for service on 06/19. We found the meter was illegally connected on 06/23/2015. We also spoke to the owner of the property, who stated that Ronnie was still in and out of that address. The consistent resident here was his unnamed sister, who is still there currently. Joshua Foster is a friend of the sister s daughter. There are a few resolutions: 1.) Joshua Foster can provide proof of household change-we are requesting proof of previous address by lease or utility bill to span at least a year, and a copy of his lease for the Clover Dr. address. 2.) Ronnie White can apply for service with our company elsewhere, and his balance will follow. After that account goes active, we will release for anyone at 3551 Clover. 3.) Ronnie can take care of his balance. After we confirm payment, we will release for anyone at Clover. 4.) If the household has not changed, then Ronnie should reapply for service. We will accept $ down plus a deposit, and agree to bill the remainder on the first statement. Ronnie can contact the COC and check for his eligibility on further arrangements after he is hilled again. The lease agreement the Complainant attached to the complaint is not considered valid, it is not a verified document. Furthermore, the Company has already confirmed with the landlord that the household has not changed. No deposit payment has been received. WHEREAS, there was no wrongdoing by the Company and the Company has provided options to the Complaint to obtain service, the Company respectfully requests that this complaint be dismissed and removed from the docket

4 Respectfully submitted, APPALACHIAN POWER COMPANY Defendant P.O. Box 1986 Charleston, West Senior Counsel for Appalachian Power Company Dated this 17th day of July, 20 15

5 VERIFICATION STATE OF WEST VIRGINIA, ) COUNTY OF KANAWHA, TO-WIT: 1 Dorothy E. Philyaw, Regulatory Consultant Associate, for Appalachian Power Company, after being duly sworn, states upon her information and belief that the facts and allegations contained in the foregoing Answer are true. 4. p+ -borothy E. Philyaw Taken, subscribed and sworn to before me on the 17th day of July, 2015 My commission expires: my Hi2?%\ (SEAL)

6 CERTIFICATE OF SERVICE I, Gina E. Mazzei-Smith, Counsel for Appalachian Power, do hereby certify that true copies of APCO S ANSWER, was served upon Complainant through the regular course of the United States Postal Service, postage prepaid, this 17th day of July, 2015 addressed as follows: Joshua S. Foster 3551 Clover Dr. Charleston, West Virginia and a copy of APCO S ANSWER was hand delivered, addressed to: Lucas Head Public Service Commission of WV 201 Brooks St. Charleston, West Virginia 25323