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June 20, 2007


Debra Jacobson

I strongly share Nora's concern about the limitation of electronic filing to companies and lawyers. Why should an individual ratepayer (who often learns about a regulatory proceeding at the last minute) have to pay $20 or more to send a filing to the SCC when well-funded electric utility companies and their attorneys can file their briefs over the Internet?

According to the SCC's web site (http://www.scc.virginia.gov/division/clk/docfile.htm), their electronic filing program is an "experimental" pilot program. However, this so-called experimental program has been in effect for more than a year -- if not more.

So several questions arise: (1) Why wasn't the pilot program extended to the "general public" in the first place? (2) If the SCC has continued this so-called experimental program for more than a year, the SCC must have found it to be it successful, and it seems long overdue to extend the program to the public at large!

Debra Jacobson
Professorial Lecturer in Energy Law, The George Washington University Law School

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