Texas Consumer Advocates Press For Greater Disclosure of REP Fees in Electronic Door-to-Door Rulemaking, Seek Disclosure of Post-Contract "Rate" At Time of Enrollment

Texas consumer advocates have pressed for greater disclosure of fees charged by retail electric providers, in submitting comments on strawman proposals concerning door-to-door enrollments completed via electronic device.

Texas ROSE (Ratepayers' Organization to Save Energy) and Texas Legal Services Center (TLSC) said that, at the time of enrollment, "Customers should be fully informed about fees that a REP charges in addition to the advertised rate. Most important are fees that can be recurring like a fee for sending the customer a monthly bill in the mail and usage based fees and credits. The disclosure should specifically state when a product, plan, or package requires enrollment in electronic delivery of documents; and automatic payment mechanisms in order to avoid the payment of unnecessary fees."

Texas ROSE and TLSC further said that REPs should be required to disclose, at the time of enrollment, "the rate the customer will be charged when the contract expires, and the window of time the customer has to switch REPs and avoid paying both the early termination fee and a high temporary rate."

"The disclosure language should be amended to add a requirement that all of the above be explained and that the customer be informed of where information about all the fees can be found," Texas ROSE and TLSC said

In separately filed comments, the Office of Public Utility Counsel said that, "neither proposal requires the agent to notify the customer that early termination fees may apply for the customer's existing plan if they are still under contract. Therefore, OPUC recommends adding a requirement to notify the customer that early termination fees could apply if they switch to a new plan during an existing contract with another provider. Similarly, OPUC suggests including provisions regarding early termination fees to the customer education information provided in the current §25.474 (c) to better inform customers of potential fees they may incur."

Project 45625