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Retail Suppliers Seek Waiver To Allow Door-to-Door Sales With "Touchless" Enrollment Process

June 12, 2020

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Copyright 2010-20
Reporting by Paul Ring •

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SFE Energy Ohio, Inc. and StateWise Energy Ohio LLC ('collectively, 'StateWise'), petitioned the Public Utilities Commission of Ohio ('PUCO' or 'Commission') for a waiver of PUCO's March 17, 2020 directive requiring competitive providers of retail electric service ('CRES') and competitive retail natural gas service ('CRNGS') to suspend all door-to-door marketing activity in Ohio

StateWise said that it, "has developed a state-of-the-art, comprehensive, touchless in-person marketing system and corresponding monitoring protocols (the 'Marketing Proposal') that exceeds the public health and safety standards set forth by the Ohio Department of Health ('ODOH') for similarly situated businesses. As such, StateWise respectfully requests the Commission grant StateWise’s Application and issue an order waiving the Suspension Order’s restrictions to permit StateWise to conduct door-to-door marketing activity consistent with the Marketing Proposal set forth below."

StateWise said that, "The Marketing Proposal provides at least five layers of protection against the spread of COVID-19 during door-to-door marketing, including: (1) detailed daily health assessments, temperature checks, questionnaires, and verification photographs that are documented, reviewed, and approved before any sales representative enters the field; (2) extensive Personal Protective Equipment ('PPE') requirements including masks, face shields, gloves, and hand sanitizer, which are documented and approved prior to any sales representative entering the field; (3) in-field social distancing and physical barrier protocols, including the encouragement of solicitations through storm or screen doors if applicable, and prohibiting indoor multi-unit dwelling solicitations such that all interactions occur outdoors where ventilation is maximized; (4) a touchless enrollment system utilizing StateWise’s proprietary software systems; and (5) location tracking capabilities to ensure accountability, security, and contact tracing to the extent necessary."

"Collectively, this five-point Marketing Proposal incorporates the highest standards of protection -- above and beyond ODOH requirements -- in a manner that accounts for the full cycle of a door-to-door solicitation, from before a marketer leaves the office, to the sales interaction itself, and after a sales interaction is completed," StateWise said

StateWise said that, "it is important to note that all door-to-door sales interactions as contemplated in the Marketing Proposal would occur outside, typically on a front porch, outside a front door of someone’s home, or through a storm door, glass door, or other screen. At this time, if granted a waiver to conduct door-to-door marketing as described herein, StateWise will (1) instruct and encourage sales representatives to perform solicitations through storm or screen doors where applicable and feasible, and (2) prohibit its sales representatives from conducting door-to-door marketing indoors, such as multi-dwelling units or apartment complexes, until further guidance from ODOH and/or the Commission."

StateWise's proposed door to door program includes the following:

Daily Health Assessment

"As a preventative and proactive measure, StateWise will require each individual sales representative who seeks to conduct door-to-door marketing to review and complete a daily assessment form ('Daily Health Assessment Form') prior to beginning work, a copy of which is provided as Exhibit A: Daily Health Assessment Form. The Daily Health Assessment Form requires each sales representative to respond 'yes' or 'no' to a series of 12 questions designed to elicit whether that representative is experiencing any of the known COVID-19 symptoms; whether the representative had contact with someone who tested positive for COVID-19; or whether that representative has traveled anywhere outside of the United States -- not simply known hot spots -- within the previous 14 days. The Daily Health Assessment Form also requires that each sales agent submit to a temperature check which is logged on the assessment form and submitted electronically to StateWise for review, approval, and retention," StateWise said

"To ensure that sales representatives are completing the Daily Health Assessment Form, all sales representatives that wish to conduct door-to-door marketing activity will be required to send a scanned copy of the Daily Health Assessment to StateWise’s compliance team for review and approval. If a sales representative answers one or more questions with 'yes,' it will trigger an automatic rejection and the sales representative will be sent home immediately, placed on a list of restricted agents as described below, and not authorized to conduct marketing activity," StateWise said

Daily Agent Photograph

"In addition, before any particular sales representative is approved to conduct door-to-door marketing, the sales representative must send StateWise a photograph of the sales agent wearing his or her Personal Protective Equipment ('PPE') including gloves, mask, face shield, and hand sanitizer ('Daily Agent Photograph'). The Daily Agent Photograph must include the sales representative holding a copy of his or her Daily Health Assessment Form. StateWise’s compliance team will review each Daily Agent Photograph every day to confirm that each photograph is accurate, new, and unique to that specific day, that each sales representative is equipped with Personal Protective Equipment, and that each representative is holding the Daily Health Assessment Form in the photo. A sales agent will only be authorized to conduct door-to- door activities if those materials are provided to StateWise for review, and are approved by StateWise’s compliance team," StateWise said

Restricted Agent Classifications

"As an additional layer of monitoring and oversight to ensure compliance with the above protocols, StateWise will keep and maintain a list of approved agents and those that are restricted based on StateWise’s review of the Daily Health Assessment and Daily Agent Photograph. Agents that fail to submit a Daily Health Assessment or Daily Agent Photograph, or agents that submit inaccurate or incomplete materials will be placed on the restricted list, along with agents that fail the temperature check or have answered 'yes' to one of the Daily Health Assessment questions. To prevent any attempts to work-around the above-referenced daily health monitoring system, StateWise will implement a block with its Third Party Verification ('TPV') vendor which will prevent a restricted sales agent from being able to complete a sale. In this manner, only approved sales agents that comply with the above protocols will be allowed to submit sales, ensuring accountability and preventing sales agents from circumventing the above procedures," StateWise said

Personal Protective Equipment

"In an effort to assist StateWise’s vendors and sales representatives with streamlined, easy access to necessary PPE, StateWise will provide to each vendor a 'PPE Request Form' which contains a list of PPE available upon request from StateWise, and the individual to contact to place those orders or otherwise ask questions regarding StateWise’s marketing procedures. StateWise will be providing its vendors with free latex gloves and masks as a courtesy and to encourage widespread use of those items without the burden of any additional cost to the vendor or sales representatives," StateWise said

In-Field Safety Standards

"In addition to the above-referenced 'pre-marketing' precautions and monitoring protocols, including completion of the Daily Health Assessment, Daily Agent Photograph, and provision of PPE and applicable fact sheets, StateWise’s sales representatives will be required to abide by a rigorous set of in-field safety protocols that go above and beyond ODOH guidance for similarly situated retail business operations," StateWise said, with such provisions listed below:

Touchless Enrollment

StateWise said that it has developed a comprehensive touchless door-to-door enrollment procedure which maintains social distance, avoids signing or exchanging copies of sales agreements and other materials ('Touchless Enrollment'). The Touchless Enrollment process begins with a sales representative approaching a potential customer’s door with the above-referenced PPE, knocking or ringing the doorbell, and then stepping back six feet from the door to wait for the potential customer to approach. To the extent the potential customer has a screen door or storm door arrangement, sales representatives will be instructed and encouraged to conduct the solicitation with those physical barriers in place and/or otherwise maintain six feet of distance between any potential customer with whom the sales representative interacts.

Further details concerning the touchless door-to-door enrollment were filed under seal

StateWise also said that in order to sign the sales agreement, a customer may elect a 'touchless' signing process whereby the customer will receive either a text/SMS or email prompting them to review and sign the agreement electronically on their personal mobile device. Otherwise, a customer may elect to sign on the sales representative’s electronic device after reviewing all of the agreement terms and conditions. Customers must affirmatively scroll through the agreement, then click 'accept terms and conditions,' or otherwise to click 'decline' to reject the enrollment at their discretion.

StateWise said, "In order to maintain social distance and avoid close contact during the exchange of a business card, StateWise has developed an 8.5 x 11 full page card that can be prominently displayed at the beginning of a customer interaction, or left at the customer’s doorstep or window. The font is large and easy to read and will ensure that customers are fully aware of StateWise’s representatives’ credentials even at a distance or through a screen or storm door arrangement without necessitating any close contact. See Exhibit E: Large Business Card. If requested by the customer, StateWise’s representatives will leave a paper copy of the terms and conditions with the customer."

Required TPV Call

"Immediately following completion of the Touchless Enrollment process, the sales representative will leave the premises and then StateWise’s TPV vendor will initiate an outbound call to the customer’s phone number to perform a live TPV as currently required under Ohio Administrative Code 4901:1-21-06 and 4901:1-29-06," StateWise said

Case No. 20-1137-GE-WVR

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