Archive for March 2015

HB 489 Gathering REP Support

As reported in Energy Choice Matters, HB 489 seems to have gathered some REP support which will be reflected in a soon-to-be filed Committee Substitute.  HB 489 governs disclosures related to REP smart thermostats.

Rule Waiver Request

IGS logo-energy

I read with interest IGS’ filing yesterday seeking a waiver from the TPV requirement for a Door to Door sale found at 25.474(f)(3).  They also seek a waiver from the authorization disclosure requirements found in (f)(2) which require the authorization disclosures to be delivered using a written LOA or telephonically.  I would suggest that the waiver from (f)(2) is not required as 25.471(d)(8) already defines “in writing” as written words memorialized on paper or sent electronically.  Therefore, it would seem that an LOA presented on an Ipad would comply with this requirement.  So, it is really the TPV requirement that needs to be waived.

I’m not so sure the PUCT will be willing to grant such a waiver.  While the sales process IGS described appears thorough, it suffers from the same limitation that a regular paper LOA suffers from; namely that the sales agent can falsify the LOA and sign on behalf of the customer.  Since devious sales agents can enter any email address for the customer, there is no way to confirm that the information entered by such agent is correct or belonging to the actual end use customer.

Even though IGS described some very good practices with respect to the employment of its agents, and while imperfect as a guard against such agent fraud, requiring a TPV for all door-to-door sales does add an extra layer of protection for the customer and allows for ease of review if and when a complaint is filed.  Given the ease with which such fraud can occur with door-to-door sales, I’d suspect the PUCT will reject IGS’ waiver request.

House State Affairs Committee Meeting on 3/11/2015

The House State Affairs Committee will consider the following electric related bills

HB 489         Anchia

Relating to customer protections related to smart thermostat services marketing and contracts.

HB 1092        Turner, Sylvester         

Relating to an annual report of residential electric customer complaints.


The full notice of this public hearing can be found at