Folks:

I attach the Sierra Club's filing Friday, June 13, supporting a motion to reopen TrAILCo filed by Thomas Hildebrand -- a pro se intervenor who lives in Va but has a planned retirement home in WV. The Hildebrand motion and the materials on which it is based are also attached. The same motion was filed with -- and granted by -- the Virginia State Corporation Commission in Virginia's TrAILCo proceeding.

The underlying reason to reopen is simple -- PJM, the operator of the electric grid who in 2006 ordered Allegheny to build the Trail line, filed a May 21, 2008 "update" report with the Maryland PSC. The May 21, 2008 projects, under at least one scenario, that TrAILCo's line is not needed to avoid the 2006 RTEP's projection of reliabiilty issues in June 2011. In somewhat plainer English, the 2006 projection upon which TrAILCo's application was filed in March 2007 is now obsolete -- according to PJM's May 21, 2008 report.

As noted, Virginia's State Corporation Commission (equivalent to our PSC) reopened the TrAILCo case there, based on the Maryland filing by PJM. We will see what our own PSC does. If they decline to reopen, it is an important procedural flaw on the record for appeal. If they reopen and admit the report, they then have to grapple with the fact that it contradicts TrAILCo's case for "need", irrespective of the environmental impact.

Best regards,

Bill

---------- Forwarded message ---------- From: William V. DePaulo, Esq. william.depaulo@gmail.com Date: Fri, Jun 13, 2008 at 9:20 AM Subject: SIERRA CLUB RESPONSE IN SUPPORT OF HILDEBRAND MOTION TO REOPEN To: jwatkins@psc.state.wv.us

Dear Mr. Watkins:

I enclose a pdf copy of the Sierra Club's response in support of Thomas Hildebrand's June 11, 2008 motion to reopen the case to take judicial notice of the May 21, 2008 PJM report filed with the Maryland public service commission, which report has caused the Virginia State Corporation Commission to reopen the evidentiary proceeding relating to the TrAILCo application pending before it.

Copies of this submission are being filed with the Commission today and served on all parties.

Please call if you have any questions regarding this filing.

Very truly yours,

William V. DePaulo, Esq. 179 Summers Street, Suite 232 Charleston, WV 25301-2163 Tel: 304-342-5588 Fax: 304-342-5505 william.depaulo@gmail.com www.passeggiata.com