Pablos Suggests Worksheet to Eliminate TDU Fees from Prepaid Disclosure Statement

The PUCT will continue consideration of a standard form Prepaid Disclosure Statement after Commissioner Rolando Pablos proposed addressing TDU fee disclosures through a worksheet that encourages the customer to call the REP with specific questions on TDU fees, rather than listing the fees on the form itself (39357).

Chairman Donna Nelson does not believe that the TDU discretionary service fees should be listed on the Prepaid Disclosure Statement, since such fees are not disclosed (apart from the terms of service) for post-pay products and thus their listing may confuse customers. Commissioner Kenneth Anderson believes that the fees should be disclosed so customers understand their initial balance may be depleted more quickly than anticipated (possibly leading to disconnection) due to the initial balance being devoted to the discretionary TDU service charges rather than commodity supply (see 9/29).

If the REP does not charge discretionary service fees separately in addition to the initial connection balance, Pablos would not require the TDU fees to be listed on the disclosure statement. Pablos noted that such disclosure is administratively burdensome and requires a separate disclosure statement specific to each TDU service area, or requires a long and confusing list in a single form.

Instead, Pablos recommended that the disclosure statement direct customers to call the REP for specific discretionary service charges (as proposed by Nelson), but Pablos additionally recommended that the REP provide the customer, along with the Prepaid Disclosure Statement, a worksheet of questions to ask the REP, including questions regarding the amount of various TDU fees.

Nelson and Anderson were both open to this approach.

Specific language and questions for the worksheet are to be developed in collaboration with Staff and addressed at a future meeting.