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Retail Supplier Seeks Waiver of TPV Requirement for Novel Sales Approach Said To Be Not Contemplated By Rules

October 2, 2014

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Copyright 2010-14 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

IGS Energy has petitioned the Public Utilities Commission of Ohio for a waiver from the third party verification rules applicable to door-to-door electric and natural gas sales, contained in Revised 4901:1-29-06(D)(6)(b) and 4901:1-21-06(D)(1)(h), for what it described as a type of sales transaction not contemplated by the rules.

"IGS has developed a process for customer enrollment that utilizes IGS employee Home Energy Consultants ('HEC') equipped with sophisticated technology that enables customer enrollment at the home of the customer ('HEC Enrollment')," IGS Energy said.

"HEC Enrollment is not a type of customer enrollment currently contemplated under either the CRES or CRNG rules given it uses technology that was not available when the CRES and CRNG rules were created, nor was the technology contemplated at the time of the development of CRES and CRNG rules. The HEC Enrollment conducts an electronic enrollment with the customer via a mobile internet procotol [sic]," IGS said.

Specifically, with an HEC Enrollment:

(a) The customer enrolls in a CRES or CRNG product through the HEC's tablet computer;

(b) The tablet computer has a GPS mechanism that allows IGS to track the exact time and location of a customer enrollment and retain detailed records of the same;

(c) The GPS in the tablet computer also allows IGS to track the time and location of all customer solicitations made by the HEC, regardless of whether the sale to the customer is effectuated;

(d) When a sale is effectuated, the tablet computer utilized with an HEC Enrollment verifies the customer's consent to the terms and conditions via an electronic signature of the customer;

(e) The tablet computer also verifies via an electronic signature that the customer consents and acknowledges the specific statements set forth in the OAC 4901:1-29-06(D)(6)(A) acknowledgement form;

(f) The HEC Enrollment process also gives the customer the option to receive a physical copy of the terms and conditions and applicable acknowledgement form. The consented to terms and conditions are either physically provided to the customer at the time of sale or, upon the customers verified consent, emailed to the customer's inbox immediately upon the customer enrolling in the CRES and CRNG product.

IGS Energy said that in addition to the processes described above, the HEC Enrollment process also contains the following, "enhanced consumer protections," beyond what is required in the CRES and CRNG rules:

(a) The IGS HECs are direct employees of IGS and not independent contractors;

(b) The IGS HECs are compensated primarily with base pay (including benefits), and sales commission only represents a small portion of the HEC total compensation;

(c) The IGS HECs are assigned to specific geographic sales territories in which they are responsible for making sales only in those territories;

(d) Customers that enroll in a CRNG or CRES product after an HEC Enrollment receive a follow-up phone call from IGS requesting feedback on the HEC Enrollment process including asking specific questions about the HEC and the HEC sales presentation;

(e) After each HEC solicitation the HEC leaves behind a business card with information on how the customer can provide specific feedback on the HEC at the IGS webpage.

The HEC Enrollment process also is in compliance with all other consumer protection rules and requirements set forth in 4901:1-29, 4901:1-21 and all other applicable state and federal consumer protection rules and statutes, IGS said.

IGS Energy said that the waiver of the TPV requirement will benefit customers because, among other reasons, "[t]hrough its own customer satisfaction surveys, IGS has found that with a knowledgeable HEC, the customer satisfaction statistics show that customer feels the third-party TPV is redundant and time consuming, given that TPVs often take more than ten minutes and ask for information already provided to the HEC during the sale."

"A waiver of the TPV requirements for the HEC Enrollment process will encourage the development of a long term HEC customer relationship rather than just a single interaction as often the case with traditional door-to-door sales. Longer term customer relationships create greater accountability for the sales agents and facilitate the offering of value added products and services, in addition to natural gas and electric commodity," IGS Energy said.

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