ARM: Texas PUC Should Not Eliminate Telephonic Verification Requirement for Door-to-Door Sales

The Public Utility Commission of Texas should not eliminate the telephonic verification requirement applicable to door-to-door electricity sales for small volume customers, the Alliance for Retail Markets said in comments to the PUCT concerning a rulemaking examining enrollments via hand-held electronic devices (Project 45625).

"With respect to the appropriate authorization and verification requirements for door-to-door enrollments employing hand-held electronic devices, ARM does not support the elimination of the telephone verification requirement for door-to-door enrollments in 16 TAC § 25.474(f)(3)," ARM said.

"The policy reasons justifying the adoption of this verification requirement for door-to-door enrollments in April 2004 continue to remain valid today. As noted by the Commission in its proposal for publication of the completely revamped version of 16 TAC § 25.474 in October 2003, 'requiring telephonic verification will enhance a REP's ability to efficiently enroll customers and reduce the number of customer cancellations and slamming complaints from door-to-door marketing." Upon adoption of this telephonic verification mandate, the Commission concluded the new requirements adopted in 16 TAC § 25.474(f)(3) 'will enhance customer protection by requiring a telephonic verification call to be completed for all door-to-door enrollments,'" ARM said