As people's counsel for the District, the statutory advocate for utility consumers, I want to follow up on the Oct. 21 letter from Pepco President William J. Sim and Marc Fisher's Oct. 7 Metro column, "Must Trees Bear Burden for Pepco?" Last Friday's high winds, which downed trees and knocked out power in isolated spots in the area, shows that this is an issue that is not going away.

D.C. residents can live in a city of beautiful trees without sacrificing reliable electric service, but right now some regard Pepco's tree-trimming tactics as overly aggressive. They point to aesthetically displeasing results, such as the Rhode Island Avenue NE corridor. Other people believe that Pepco's "vegetation management" is a small price to pay to avoid power outages.

What is needed is a coherent and comprehensive plan for vegetation management and electric service reliability. That plan must include input from all concerned parties: Pepco; the District Department of Transportation, the Office of the People's Counsel and the Public Service Commission; and representatives of affected neighborhoods.

An independent "referee" should oversee the creation of such a plan and have the authority to ensure accountability. A comprehensive plan, which would be filed with the Public Service Commission, would allow Pepco to publicly indicate, annually and by neighborhood, how it will manage and trim vegetation to ensure system reliability. The plan would provide for timely notice to affected neighborhoods so that residents' concerns and recommendations could be addressed.

This approach would hold Pepco accountable to the Office of the People's Counsel, the Public Service Commission and consumers. District neighborhoods would have their trees, aesthetically trimmed, and a greater likelihood of electric service after a storm. In other words, no ugly trees and the lights would stay on.

ELIZABETH A. NOEL

People's Counsel

Office of the People's Counsel

Washington