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Retail Suppliers Seek Waiver To Allow Door-to-Door Sales With "Touchless" Enrollment Process
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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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June 12, 2020
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Copyright 2010-20 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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