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IGS Energy Seeks Pennsylvania PUC Order Allowing Resumption Of Door-to-Door As Well As Public Event Marketing; IGS Details Proposed 'Touchless' Experience

June 22, 2020

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Copyright 2010-20 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Interstate Gas Supply, Inc. d/b/a IGS Energy petitioned the Pennsylvania PUC for a partial recission of the Commission’s March 16, 2020 Emergency Order ('Order'), which suspended door-to-door and other in-person marketing, with IGS specifically asking the PUC to rescind that portion of the order that would restrict IGS from engaging in door-to-door, public event, and in-person sales and marketing activities in those counties that have gone to the 'Green Phase' under the Governor’s phased 'Process to Reopen Pennsylvania'

As previously reported, the PUC previously allowed in-store marketing to resume under certain conditions

"IGS now believes that a responsible and measured return to all three forms of person-to-person marketing can be safely engaged without putting potential customers or marketing personnel in danger. IGS has developed processes and procedures that will ensure that all applicable safety standards are maintained, thus minimizing the risk of the spread of COVID-19," IGS said

In the petition, IGS detailed its sale process and various protective measures

"IGS has thoughtfully considered what it believes to be the optimal approach to door-to-door and other in-person marketing during the Green Phase. It begins with IGS’s Home Energy Consultants ('HEC') who are salaried professionals and are employed directly by IGS. They are not commissioned, part-time employees of a marketing firm. Moreover, IGS HECs are geographically located within close proximity to the customers to whom they market, and they are trained and retrained on a repeating cycle over time. The HECs are required to monitor themselves for symptoms, including body temperature, daily, and to report any anomaly to their supervisor. Any doubt in an HEC’s health is resolved in favor of the HEC not having customer contact until their status is resolved. If there are symptoms, arrangements are made for the employee to receive appropriate healthcare. IGS simply will not put an HEC into the field if there is any doubt about their health," IGS said

"IGS’ HECs have at their disposal the means to provide a 'touchless' experience for customers. First, HECs will be provided with a safety package of Personal Protective Equipment ('PPE'), that will include masks, gloves, antiseptic gel, antiseptic wipes, and a no-touch hook. These kits will be replenished on a regular basis. Throughout the entire sales process the HEC’s will wear masks. At all times during the sales process, HECs are forbidden from entering a customer’s residence and will not market in enclosed multi-unit premises units such as apartment buildings," IGS said

"The sales experience begins with the HEC using a no-touch hook to knock on the customer’s door or to ring the bell. The HEC then steps back to the appropriate social distance to address the customer. The sales presentation and process is guided by the HEC’s iPad, and at the conclusion, if the customer wishes to enroll, an electronic link is sent to the customer via email so the customer can confirm the enrollment on the customer’s own mobile device or computer," IGS said

"The iPad not only facilitates the sales transaction, but it also provides a record of where and when the HECs have interacted with each customer, so that in the event of any future concern about contacts, the tracing process will be more easily managed. IGS’ iPad experience is equipped with GPS tracking and accordingly could be used for this purpose. This capability can also be used to ensure that HECs are marketing only to the customers on their list of prospects. The entire customer experience can take place at the required social distance, even from behind a screen door, so the customer never needs to leave the comfort of their porch, or even leave their residence in a door-to-door setting, or remain closer than six feet in any other setting," IGS said

"To the extent that a customer does not possess a mobile device or computer, our HECs are trained to provide their own tablet to the customer, after wiping it down, so the customer can complete the transaction. Once returned, the tablet is once again wiped down. IGS has prepared a series of training videos for its employees describing the required procedures for the entire sales process," IGS said

"By-appointment in-person marketing will most often take place at a place of business that is already permitted to be open and so all protocols for such businesses and buildings will be observed. HECs will wear PPE and will maintain required distancing. Any document necessary to complete a transaction will be transmitted electronically, so there is no need for any contact or close-proximity encounters. As with door-to-door marketing, if at any time the customer feels uncomfortable with the experience, the HEC’s are trained to provide the customer with a sanitized business card and to immediately exit the premises and complete any further discussion on the telephone," IGS said

"In the Green Phase, public events of less than 250 people are permitted, and to the extent such events may include opportunities for event marketing, the process would be much the same as for an in-person meeting. Customers would deal with HECs on a one-at-a-time basis, while maintaining social distancing and wearing masks as required. Enrollments would occur as in a door-to-door setting and all protocols would be followed," IGS said

"With regard to door-to-door marketing, IGS believes and therefor avers that its process is at least safe for both customers and HECs as any typical retail encounter. Such encounters are permitted in the Green Phase in a greater number of establishments and in greater concentration than previously permitted. With IGS’ touchless process, and because the HECs will never enter a customer’s residence, concerns regarding the potential spread of COVID-19 are amply mitigated," IGS said

"With regard to 'by-appointment marketing', to Commercial and Industrial customers, those businesses are also permitted to be open during the Green Phase and with the safeguards discussed, will present no additional risk. The same is true for event marketing. While not a priority for IGS, there may be opportunities in gatherings of less than 250 people for marketing IGS products. Nonetheless, if the Commission believes that additional safeguards are necessary, IGS is certainly willing to entertain them," IGS said

"Unlike many employers in this uncertain time, IGS did not furlough its HECs and has retained them on its payroll. Unfortunately, they are being underutilized, which places a strain on IGS’ operations. The recent expansion of the list of Green Phase counties coupled with IGS’ desire and need to recruit customers creates an urgency, and IGS renews its request that the Commission reach a determination at the earliest possible date. IGS would note that both New Jersey and Ohio10 have recently lifted the temporary restrictions on door-to-door marketing. Like Pennsylvania, these states were some of the first to restrict in-person marketing and now are also leading the way back. Pennsylvania should join them at the vanguard by providing for a measured and responsible return to in-person marketing," IGS said

Docket No. M-2020-3019254

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