PPL Calls For Ban On Door-to-Door Sales Even After Pandemic Restrictions Lifted

Consumer Advocate Proposes Prohibiting Suppliers From Using Third-Party Agents, Vendors For Door-to-Door Sales

OCA Proposes Prohibiting Door-to-Door Sales In Counties With Vaccination Rate Of Less Than 70%

June 22, 2021

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Reporting by Paul Ring • ring@energychoicematters.com

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In comments to the Pennsylvania PUC concerning the consideration of ending the current COVID-related prohibition on residential door-to-door retail energy sales, PPL Electric Utilities Corporation (PPL Electric) said that the PUC should, "strongly consider bolstering the Commission’s regulations on door-to-door sales or prohibiting the practice altogether even after the moratorium on door-to-door sales is subsequently lifted."

"[D]oor-to-door sales are such a high-pressure sales practice, especially for low-income and older customers, that their continued use even after the COVID-19 pandemic should be carefully evaluated. Indeed, prior to the moratorium, PPL Electric received many complaints from its customers about door-to-door sales," PPL Electric said

"[F]rom April 20, 2021, to May 6, 2021, PPL Electric conducted a survey of its customers’ experiences with shopping for competitive electric generation supply service. PPL Electric found that Low-income customers, are far more likely to note door-to-door salespersons as sources of information for shopping, which suggests that such customers are more at risk when door-to-door sales practices are abused. It is Low-income customers who stand to benefit the most from making a well-informed shopping decision, and door-to-door sales simply do not allow for customers to weigh all of their shopping options and make a reasoned choice," PPL Electric said

To the extent the PUC permits door-to-door sales, PPL Electric proposed several conditions, including a requirement that the supplier report to the utility the identity of any third-party vendor used in such sales

"PPL Electric ... recommends that the Commission amend its reporting requirements under Section 111.14(a)-(b) of the Commission’s regulations, 52 Pa. Code § 111.14, such that the supplier be required to provide the Bureau of Consumer Services ('BCS') and the local distribution company with the name of the vendor who is conducting the door-to-door sales and marketing activity. This will prevent bad actor vendors from switching to another EGS after the vendors are found to be violating the Commission’s regulations. Such a modification benefits the local distribution companies (by having relevant information if a customer calls to complain), the suppliers (by having relevant information about vendors they should not hire), customers (by reducing the number of bad actor vendors conducting door-to-door sales), and the Commission (by reducing the number of bad actor vendors and, by extension, informal and formal complaints)," PPL Electric said

PPL Electric also proposed additional training requirements and certain health and safety measures, including masking, social distancing, etc., for door-to-door sales

In separately filed comments, the Office of Consumer Advocate strongly recommended that the commission continue to halt the practice of door-to-door sales until, "long-standing concerns with the sales method are addressed and alleviated."

To the extent the PUC permits door-to-door sales, the OCA proposed that door-to-door marketing not be permitted in any county with a vaccination rate under 70%, and that suppliers not be allowed to use any third-party vendor or agent for door-to-door sales (requiring the use of internal employees only)

Specifically, OCA recommended door-to-door sales only be permitted in counties with at least 70% of its adult population having been fully vaccinated. OCA said that as of June 16, 2021, 61.1% of Pennsylvanians have received their first dose of vaccination and 57.8% of Pennsylvanians 18 and older have been fully vaccinated

Additionally, the OCA recommended that the Commission consider prohibiting suppliers from contracting with third-party vendors to send third-party agents door-to-door. The PUC should require that the suppliers send their own employees as sales agents to conduct such sales, OCA said

"[T]he training of third-party sales agents is often more difficult for suppliers to conduct and track the completion of. This is particularly important now given the extra layer of concern due to the COVID-19 pandemic and the additional safety measures that should be required of sales agents going door-to-door during a global pandemic," OCA said

OCA also proposed that all supplier agents remain 6ft. to 10ft. away from the customer’s door throughout the interaction, and that no cards or paperwork be exchanged.

Due to this distancing proposal, OCA noted it may be difficult for marketers to provide certain required materials, or for customers to read such materials (such as an ID badge)

As such, "OCA recommends that sales agents enhance the visibility of their identification badges and read-out a statement that identifies the sales agent and his/her purpose for knocking and asks the customer if they are comfortable with them remaining on their property to discuss the supplier’s products and services."

Further, the OCA recommended that the sales agent should be required to initiate the door-to-door interaction with the following statement:

"I am an agent of [blank], a licensed supplier of electric/gas energy asking if you want to hear a sales presentation on my products and services. You are under no obligation to purchase my products and services to have your current electric and gas service continue. Are you comfortable to talk to me about the potential benefits of my product or service? If so, you may ask me to leave your property at any time."

Docket No. M-2020-3019254

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