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PUCT Commissioners at "Impasse" on TDU Fee Disclosure for Prepay Products
September 16, 2011
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The PUCT has deferred until its next open meeting consideration of a standard form Prepaid Disclosure Statement (PDS) after having reached an "impasse" regarding the disclosure of certain TDU fees on the statement.
As previously reported (9/9), Staff had been seeking Commission guidance on several threshold issues regarding the PDS, including the disclosure of TDU fees, prior to drafting a recommended proposal for adoption.
Commissioner Kenneth Anderson said that certain TDU fees, such as Move-Ins and Priority Move-Ins, should be disclosed on the PDS because at some TDUs, these fees are as high as 1/3 of the maximum allowable connection balance of $75 (absent the REP requiring TDU fees to be paid on top of the $75 which is permitted). Customers need to be aware that their initial prepayment may not provide as many days of service as expected because of these one-time TDU fees, Anderson said, especially considering the accelerated disconnection timeline under the prepaid model.
Anderson would limit the TDU fees required to be listed on the PDS to a subset of those recommended by Texas ROSE and TLSC, with Anderson specifically citing standard and priority Move-In charges as needing to be included. The discussion of what additional fees, if any, Anderson may believe should be included was not clear, however, because Texas ROSE in its initial comments recommended disclosure of standard and priority, "out-of-cycle meter read and move-in and move-out transactions," but in reply comments Texas ROSE said that the PDS should include, "standard and priority TDU charges for move-in and move-out and disconnection and reconnection."
Chairman Donna Nelson expressed concern that requiring such TDU fees to be disclosed in the PDS, while there is no obligation to disclose them in a similar manner for a post-pay product (with such fees only listed in the Terms of Service), may lead customers to incorrectly believe such TDU fees do not apply to post-pay service.
As a result, customers may enroll onto a post-pay product incorrectly believing it to be cheaper due to the absence of the listed TDU fees. Nelson came into the meeting believing that the PDS should only state that TDU fees may apply to the initial connection balance, and that it should direct customers to contact the REP for specific amounts.
Discussing TDU fees more generally, Anderson said that with the full deployment of advanced meters, discretionary service charges should be set to zero, with any remaining costs of discretionary services recovered in base rates.
Furthermore, Anderson said that the notion of "priority" services, such as Priority Move-In, no longer make sense in an environment with advanced meters since the service can be completed without rolling a truck (except where communication with the meter fails).
Both the zeroing-out of discretionary service charges, and the timelines for completion of discretionary services under advanced meters, are being addressed by stakeholders in several projects, as previously reported.
Nelson and Anderson did agree on a threshold issue regarding the language for the PDS, finding that REPs shall be required to use the standard form language on the PDS, except that REPs may add their own language to the PDS (but not alter the standard form language), with such REP language added in italics.
Both Commissioners also agreed that the PDS forms should be separate for residential and commercial service.
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