December 28,2015

Bv Hand Delivery

Ms.Ingrid Ferrell

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Executive Secretary West Virginia Public Service Commission 201 Brooks Street Charleston, WV 25301 Re: Joyce Ann Zornes Application for Certflcate of Convenience and Necessity Case No. 15-1908-MC-C Dear Ms. Ferrell: Please find enclosed herewith for filing in the above-referenced case the original and twelve (12) copies of Haul'n Trash's Response to Waste Management's Request of Denial of Temporary Authority, petitions signed as of 12/28/2015 and Facebook webpage posts by residents in support and seeking alternative service providers.

Truly yours,

Joice Ann Zornes Owner Enclosures Cc :

Linda Bouvette, Esq./w./enc. Edward J. George, Esq./w./enc. Petition w/ signatures as of 12/28/15 Facebook post in support and seeking alternative service.

Applicant, Joyce Zornes, owner of Haul’n Trash, with respect and humility before the Commission, files this Response t o Waste Management of West Virginia’s Response in Opposition to Haul’n Trash’s Request for Emergency Temporary Authority. In support of the following I have enclosed printouts of Haul’n Trash’s Facebook page as well as petitions signed as of 12/28/2015. Haul’n Trash asserts pursuant to Public Service Commission’s Rules and Regulations, Waste Management has untimely filed their response on December 28,2015 as Haul’n Trash’s Request for Emergency Temporary Authority was filed on December 23,2015. According to PSC of WV’s rules and regulations, any motion filed in protest after publication must be done within three (3) days, unless allowed by Commission due to holiday hours. Also, WMWV’s response in itself states, Waste Management currently provides solid waste

transportation service in “parts” of Boone County under P.S.C. M.C. Certificate No. 7460. It is not denied that Waste Management is fully operational in the “parts” of Boone County which it is certificated to operate, but is affirmed that Waste Management does exclude parts of its certificated area or raises the rates in these certain areas, as they are off the “beaten path” of their certificated area. It is understood that Waste Management is a multi-million-dollar corporation, run by a board of directors with all necessary equipment and knowledge of operation for “urban” service, but Boone County is not an “urban” area. In fact, the majority of Boone County is unincorporated just as the greater part of West Virginia is unincorporated and being so many of the residents live on the mountainside, down in a valley, or across a creek sometimes with no adequate bridge to cross, all reasons Waste Management informs residents of these areas that service is unavailable or will cost more, all of which should be proof enough that current certificate holder(s) service is inadequate. Even the current commercial customers of WMWV are dissatisfied as t o the frequency of service. Not t o mention, P.S.C of WV’s rule 3.21(d) states, No reference to unincorporated communities shall be made in certificates or

permits issued by the Commission. Again, Boone County excluding Madison, Danville, Sylvester, and Whitesville is an unincorporated area. Haul'n Trash being a local startup has intimate knowledge and familiarity with such unincorporated areas and the residents that will be hindered by the denial of any type of certificate, in essence, prejudicing the consumers and Haul'n Trash. Furthermore, WMWV is certificated in other areas outside Boone County, in which its customers are dissatisfied and seeking alternative providers. Waste Management believes that the granting of Haul'n Trash's Temporary or Permanent Authority will be detrimental to Waste Management only because they have knowledge of Customer's dissatisfaction with current service. I ask, how can one (1) county in a country of 48 contiguous states serviced by Waste Management be detrimental t o its operation, unless service is inadequate enough that residents want to switch to a better service provider. With respect to West Virginia Code and the rules and regulations set by P.S.C. of W.V. Haul'n Trash has not and will not operate until certificated by the Commission. I ask that all information be taken into heavy consideration. Submitted with Honor, Truth, Humility, and Respect,

190fi.w H urn Trash owner

BEFORE THE PUBLIC SERVICE COMMlSStON OF WEST VIRGINIA CASE NO. 15-1908-MC-C JOYCE ANN ZORNES Application for Certificate of Convenience and Necessity CERTIFICATE OF SERVICE

I, Joyce Ann Zornes, owner of Haul’n Trash, do hereby certify that a true and exact copy of the RESPONSE TO WASTE MANAGEMENT’S REQUEST OF DENIAL OF TEMPORARY AUTHORITY has been served upon the following this 28thday of December, 2015:

By Hand Delivery: Linda Bouvette, Esquire Public Service Commission 201 Brooks Street Charleston, West Virginia 25301 Email: /bo~~tt.lce@,orc.stote. wv,~g. Staff Attorney

By Regular US. Mail: Edward 1. George, Esquire Robinson & McElwee, PLLC Attorney for Waste Management Inc. P.O. Box 1791 Charleston, WV25326

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JO~CJA.Zornes (Owner)

ul’n Tras

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This Petition is in response to Waste Managemenrs protest for Haul’n Trash’s certificate of necessity to service Boone county. Our reasonsfor certification are listed below: o

Residents of Boone countv would rather have a local company service their needs

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Some residents in the county are inaccessibleto Waste Management

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Solid waste from Boone county will have t o be transported t o a landfill owned and operated by Waste Management

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Waste Management will be paid tipping fees for all waste hauled to their landfills

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It is unconstitutional t o monopolize an industry; WM operates in 90% of the states in

America o

Every man and woman has a right to provide a way of life and work

We the People of Boone county, the undersigned, protest the denial of Haul’n Trash‘s certification for the above reasons or any other unspecified reason.

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Robie Little Ricky Lee Kirk Like Reply Message . December 11 al7:48pm Rosie Dearien Sergent Do you have carry tr as h can to the roa another lady are over 60 and it would be hard to get the garbage Like Reply . Message. December 20 at 12:07am Haul'n TRASH no you do not have to carry it to the curb. we will get your trash from whatever spot you designate. Like Reply December 20 at 12:28am Rosie Dearien Sergent Thank you for your quick replay. Like . Reply Message. December 20 at 9:lOam Chat (35)

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naurn I K A J n K osie uearien sergent yo are very welcome, and we thank vou for vour consideration and inter st Line Keply uecember zu at 5 j / p m

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Todd Newel1 Do you pick up in st Albans? ? Like ' Reply ' Message. December 21 at 6:45am Haul'n TRASH at the moment we are unable to run in that area but we are . .,~*~,making the necessary amendments to our certificate that will allow us to. Like. Reply. December 21 at 10:39am ger Goff Do you pick up near Hurricane. It is a rural route not in city limits Like . Reply . Message . December 22 at 9:43am Haul'n TRASH We are currently in the process to amend our certificate of necessity to indude other counties as well. we will contact all our out of county interested parties as our cetiicate is amended. thank you for your consideration. Like . Reply December 22 at 2:23pm Ginger Goff Thank yw. Please let me know as soon as you know anything Like . Reply . Message . December 22 at 2:26pm Haul'n TRASH Ginger Goff you are very welcome and yes we will Thank you. Like . Reply ' December 22 at 2:27pm

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Dempsey Dickson Do you run in Scott Depot I Teays Valley? Like ' Reply ' Message. December 23 at 7:OIam Haul'n TRASH sorry to inform you at the moment we do not have a route in that area, but we are working on amending our certificate to include that area. thank you for your interest and consideration. 1 . December 23 at 1:19pm Like . Reply . Debbie Williams Do you pick up in prenter? Like . Reply . Message . December 26 at 7:22am :

Haul'n TRASH yes we have routes in Prenter Like . Reply . December 26 at 11:I Oam Debbie Williams OK thanks Like Reply. Message ' December 26 at 1::loam

T Haul'n TRASH Debbie Williams you're welcome. Thank you for your _..,.interest and consideration. Like. Reply. December26 at 11:18am

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Erica Shea Andrews M a t are the restrictions on the amount of trash a person can have7 Like Reply Message Decem6&%%ho 35am

weight under 50 Ibs, Like. Reply ' December26 at ll:15am Kimberly Eastep Do you pick up in ridgeview? Like Reply Message . December 26 at 11:50am Haul'n TRASH yes we have routes in Ridgeview Like ' Reply . 1 ' December 26 at 12:13pm Kimberly Eastep Ok how do I sign up for trash service Like . Reply Message. December 26 at 12:ZOpm Haul'n TRASH Kimberly Eastep there is a signup button on the top of our FB homepage or visit www.haulntrash.com. Thank you for your interest and consideration.

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Like Reply Remove Preview . December 26 at 2:OOpm Write a reply. Melissa Coley Gay Do you pick up in Peytona?? Like . Reply ' Message. December 26 at 1:57pm Haul'n TRASH yes we pick up in Peytona Like Reply. December 26 at 2:Olpm Melissa Coley Gay Radne Hili?? Like . Reply Message December 26 at 2:Olpm Melissa Coley Gay What days?. Like ' Reply. Message . December 26 at 2:Olpm Haul'n TRASH Melissa Coley Gay yes we also sewice Racine Hill. Our days for that area are Mon and Tues., but to inform you we are unable to perform right now as we are inbetween hearings for our last certification. Waste Management is trying to get our certificate denied, but we will receive it and begin our routes asap. Like ' Reply. December 26 at 2:lEpm Melissa Coley Gay Please let me know.. I signed the petition that was on FB.. Like Reply . Message . December 26 at 2:21pm Write a reply Tracy Wallace Harris Will you pick up in Van? 1 . December 26 at 10:39pm Like . Reply. Message. Haul'n TRASH Yes we have routes in Van. Like Reply . 15 hrs Chat (35)

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Haul'n TRASH Ashley Daniels you're very welcome and we thank you for your consideration. you can sign up by way of our FB homepage or call 304-837-8297, also www.haulntrash.com

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Like . Reply ' Remove Preview ' 14 hrs Tiffany N Jonathon Shaffer Crosslanes/nitro area Like. Reply. Message ' 12 hrs

. Haul'n TRASH sony to inform you at the moment we do not have routes in this area, but we are in the process of amending our certificationto include this area. if you are interested please enter your informationthrough our signup button and we will keep your info... See More Like . Reply . 12 hrs Tiffany N Jonathon Shaffer Well my address is considered nitro Like . Reply. Message . 12 hrs Kathy Goldsberry Dolin Madison? Like . Reply Message . 1Inrs ".....I.Haul'n TRASH yes we service Madison as well

Like Reply . 10 hrs Chambers Jessica Do you pick up in Chapmanville/Crawley area? Like Reply Message. 9 his

i Haul'n TRASH We are currently amending our certificate to include your area. Like . Reply

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1 . 4 hrs

Chambers Jessica Great! I will check back! Like . Reply. Message . 3 hrs Haul'n TRASH Chambers Jessica thank you for your interest and consideration. Like . Reply . 2 hrs Write a reply Lora Woodrum Messer James Adkins Like . Reply . Message 1 hr '

James Adkins I already talked tothem Like. Reply. Message. 1 hr Write a reply Chat (35)

ut the ChapmanvilleICrawle

Elizabeth Watkins If you pick up off 40th street in nitro please let me mnOw Like . Reply. Message. 53 mins

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