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Texas REP Alleges That Certain Allegations In Customer Complainant's Motions, "Appear To Be Artificial Intelligence Hallucinations"

January 14, 2026

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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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In response to a motion filed by a customer who has filed a pro se formal complaint at the Texas PUC, BKV-BPP Retail LLC alleged that, "BKV Energy also notes that many of the allegations contained in both this motion and many of Mr. Sorrells's [complainant] other motions are inaccurate and appear to be artificial intelligence hallucinations."

As previously reported, the customer's complaint generally alleges that BKV-BPP Retail disconnected the customer at various points, and alleges that BKV-BPP Retail did not properly document, memorialize in writing, or provide notice of amounts included or excluded from a deferred payment plan, allegedly contrary to rule. The customer's complaint also generally alleges that disconnections have occurred without "meaningful" notice

Based on the case's procedural schedule, BKV-BPP Retail has not yet filed a formal response to the complaint, but, as previously reported, BKV-BPP Retail has made filings objecting to certain emergency relief sought by the complainant

See more background here

With regards to the alleged use of AI by the complainant, BKV Energy specifically cited the complainant's continued allegation that the disconnection protections under 16 TAC § 25.483(j) prevent disconnection during a freeze warning. BKV Energy cited a filing by the complainant which avers that text from the PUC's rules contains specific language for a "freeze warning" protection

BKV Energy said that the rule has no such requirement or language

16 TAC § 25.483(j) provides that:

A REP having disconnection authority under the provisions of subsection (b) of this section must not authorize a disconnection for nonpayment of electric service for any customer in a county in which an extreme weather emergency occurs. A REP must offer residential customers a deferred payment plan upon request by the customer that complies with the requirements of §25.480 of this title (relating to Bill Payment and Adjustments) for bills that become due during the weather emergency.

(1) The term "extreme weather emergency" means a day when:

(A) the previous day’s highest temperature did not exceed 32 degrees Fahrenheit, and the temperature is predicted to remain at or below that level for the next 24 hours anywhere in the county, according to the nearest National Weather Service (NWS) reports; or

(B) the NWS issues a heat advisory for a county, or when such advisory has been issued on any one of the preceding two calendar days in a county

Although not specifically discussed by BKV Energy, it appears that the rule's language that, "the previous day’s highest temperature did not exceed 32 degrees Fahrenheit, and the temperature is predicted to remain at or below that level for the next 24 hours anywhere in the county," is not the definition of a "freeze warning" as used by the NWS (which describes the warning using various language, such as forecast temperatures below 32 degrees only for "several hours", or, on the same NWS webpage, a "long period of time")

The complainant in a filing with the Texas PUC alleged that the rule text is as follows [all sic]:

Rule Text: "A REP having disconnection authority pursuant to subsection (h) of this section must not authorize a disconnection for nonpayment Of electric service for any customer in a county in which an extreme weather emergency occurs. An extreme weather emergency means a day when... the National Weather Service issues a freeze warning, freeze watch, or a heat advisory for a county..."

Among other things, the actual rule text does not include the phrase "freeze warning, freeze watch"

BKV Energy in response issued interrogatories to the complainant, including the following:

• Please state whether this text [the complainant's language which the complainant represented was the rule's text] was generated using artificial intelligence.

• Please identify each document filed in this proceeding drafted in whole or in part using generative artificial intelligence. For each document identified, please state whether you verified the accuracy of each rule or statute citation.

Docket 59122

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