of the RAAF which, if proven to be the case, would be a violation of the UBP."
of the initial RAAF and Sections 1.D.
In Section 1.E., Starion notes the other trade name used in other states is 'Starion Energy NY, Inc.' The information provided by Starion in these sections indicates that Starion has two affiliates, operates only in New York and Ohio, uses only the trade name 'Starion Energy NY, Inc.' in other states, and that no senior officer of the ESCO applicant or entity holding ownership interests of 10% or more in the ESCO has had any criminal or regulatory sanctions imposed within the last 36 months.
and 1.D.
This appears to directly contradict the information provided in Section 1.C.
of both the initial and revised RAAFs.
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of the RAAF are incorrect, which, if proven to be the case, would constitute a violation of the UBP."
These transfers shall occur on the customers regularly scheduled meter reading dates.
The PSC stated in its order that, "SunSea states that in response to the NOAF, SunSea denied the allegations against it and provided enrollment documentation.
We find that after months of similar complaints without corrective action, the noncompliance became willful. Section 1.E., which lists all trade names used in other states, continues to be marked 'N/A' despite its affiliates activities beyond New York.
Moreover, Josco has violated UBP requirements related to TPVs, as well as the Commissions complaint response procedures," the PSC said
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Section 1.B.
These facts appears [sic] to directly contradict the information provided in Sections 1.C.
The lack of adequate responses to the QRS/SRS complaints from July 2019-November 2020 directly contradicts the statement regarding SunSeas handling of consumer inquiries and complaints.
These transfers shall occur on the customers regularly scheduled meter reading dates.
New York PSC Revokes Eligibility Of Two ESCOs, Orders Return Of Customers To Default Service
This appears to directly contradict the information provided in Section 1.C.
The significant number of complaints filed against Josco between 2016 and 2020 alleging marking violations demonstrate a material pattern of complaints on matters within Joscos control."
Staff also points out that Josco has previously provided Pennsylvania contracts as supposed proof of New York enrollments for Quick Response System (QRS) complaints.
The RAAF indicates that SunSea Energy, LLC has four affiliates, operates in Ohio, Maryland, New Jersey, and District of Columbia, uses the trade names SunSea and SunSea Energy in other states, and that no senior officer of the ESCO applicant or entity holding ownership interests of 10% or more in the ESCO has had any criminal or regulatory sanctions imposed within the last 36 months.
ESCOs wishing to continue to serve customers after the PSC's retail market reset order were required to file new applications for continued ESCO eligibility
In addition, the California Public Utilities Commission issued Energy Citations to Smart One on February 13, 2020, April 21, 2020, August 20, 2020, and September 17, 2020, totaling $25,000 for violations of the Public Utilities Code.
Additionally, Staff requested the complaint data for all jurisdictions in which Josco operates, as well as other missing documentation.
Starion provided the following statement concerning the matter:
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This is also not indicative of a company that has been taking its relationship with regulatory authorities seriously since the allegations included questionable marketing practices and misrepresentation, not just disputed enrollments."
The PSC's show cause order states, "Staff contacted Starion on January 20, 2021, regarding deficiencies in its application, including the lack of compliant contracts, missing complaint data, non-compliant TPVs, and non-compliant marketing materials.
The PSC's show cause order states, "The fact that Josco has affiliates operating in multiple states appears to directly contradict the information provided in Section 1.B.
The PSC ordered that SunSea shall return its customers to full utility service within 60 days of the effective date of the revocation order. -- New Product Strategy and Development Sr.
-- Senior Analyst - Pricing & Structuring -- Retail Supplier -- Houston
Smart One answered 'no' in response to Section 1.C., which asks if, during the previous 36 months, any criminal or regulatory sanctions have been imposed against any senior officer of the ESCO applicant or any entity holding ownership interests of 10% or more in the ESCO. Josco stated in its response that Josco Energy MA, LLC, Josco Energy IL, LLC, and Josco Energy USA, LLC are separate and distinct, for corporate purposes, from Josco.
The RAAF indicates that SunSea Energy, LLC has four affiliates, operates in Ohio, Maryland, New Jersey, and District of Columbia, uses the trade names SunSea and SunSea Energy in other states, and that no senior officer of the ESCO applicant or entity holding ownership interests of 10% or more in the ESCO has had any criminal or regulatory sanctions imposed within the last 36 months.
Smart One responded that the previously submitted sales agreements were compliant, other documentation had already been included, and other revisions and documents were filed. -- Sr. Analyst, Structuring -- Retail Supplier
At the time of an October 2020 show cause order, Josco served residential and non-residential electric and gas customers in various territories
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The PSC's show cause order states, "Upon completion of the application review, Staff requested complaint type and resolution details from Ohio, Maryland, District of Columbia, and New Jersey, as well as other revisions and missing documentation.
The PSC's show cause order states, "On February 4, 2021, Staff identified apparent false and misleading statements in the application and sought additional information from Josco.
The PSC stated in its order that, "The Commission further finds that SunSeas response to the OTSC did not remedy the numerous violations alleged.
The PSC's show cause order states, "On November 18, 2020, Josco filed an application, signed by the Vice President of Operations, seeking to comply with the December 2019 Order.
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0:41 MONSEY - A Monsey-based energy company accused of ripping off people by falsely promising lower rates is being forced to repay $1.25 million to 25,000 customers, the state attorney general.
Smart One
These transfers shall occur on the customers regularly scheduled meter reading dates.
NEW! Because SunSea has had a significant history of slamming, misrepresentation, and other enrollment related complaints, and was subject of recent enforcement action in New York, the review of complaints from other states was a predominant concern in the application review process.
The PSC's show cause order states, "Upon completion of the application review, Staff requested revisions to the sales agreements, TPV scripts, and RAAF, including Sections 1.B., 1.D., and 1.E.
This information suggests that the responses to Sections 1.C.
of both the initial and revised RAAFs.
The required complaint data was also missing from the application package."
In the aftermath of an unprecedented winter storm that left millions of Texas residents without access to power for several days, one of the state's largest electricity retailer is facing a.
Of the 93 total cases listed in the attachments to the Order, Staff identified 73 cases where the refund was denied or not provided in response to the QRS/SRS and NOAF, but then granted after the OTSC.
Of the 93 total cases listed in the attachments to the Order, Staff identified 73 cases where the refund was denied or not provided in response to the QRS/SRS and NOAF, but then granted after the OTSC.
The PSC ordered that SunSea shall return its customers to full utility service within 60 days of the effective date of the revocation order.
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Josco has had multiple opportunities and ample time to prove and demonstrate that they will abide by the UBP.
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The PSC stated in its order that, "Additionally, the enrollment documentation that SunSea is referring to was missing from 12 of the cases in the NOAF which prompted Staff to include the records retention violation to the OTSC.
Smart One
This is also not indicative of a company that has been taking its relationship with regulatory authorities seriously since the allegations included questionable marketing practices and misrepresentation, not just disputed enrollments."
The PSC stated in its order that, "SunSea states that in response to the NOAF, SunSea denied the allegations against it and provided enrollment documentation.
In addition, the California Public Utilities Commission issued Energy Citations to Smart One on February 13, 2020, April 21, 2020, August 20, 2020, and September 17, 2020, totaling $25,000 for violations of the Public Utilities Code.
This includes 12 that were confirmed to be checks dated February 2021 for refunds that had been promised on various dates ranging from February 19, 2020, through October 19, 2020. The PSC's show cause order states, "On November 17, 2020, SunSea filed an application, signed by their CEO, seeking to comply with the December 2019 Order. The PSC's show cause order states, "On December 8, 2020, Smart One filed an application, signed by the Chief Executive Officer (CEO) seeking to comply with the December 2019 Order.
The PSC stated in its order that, "SunSea states that 'this unfortunate circumstance is not due to willful noncompliance, but rather the rogue actions of marketing vendors.
Cases 15-M-0127, et al.
-- Sr. Analyst, Structuring -- Retail Supplier
The PSC also issued a separate order to show cause requiring Starion Energy NY, Inc. ("Starion") and Smart One Energy LLC ("Smart One") -- as well as Josco and SunSea -- to show cause why their eligibility applications for continued ESCO eligibility should not be denied.
With respect to the revocation of Sunsea's current eligibility, see our prior story for background on the alleged violations and a prior December 2020 show cause order
The Commission recognizes that SunSea did provide the enrollment documentation with its response to the OTSC.
CPS owes Conoco $19.6 million, according to the lawsuit.
The PSC stated in its order that, "SunSea states that 'this unfortunate circumstance is not due to willful noncompliance, but rather the rogue actions of marketing vendors.
Smart One
The list of all trade names used in other states, as required in Section 1.E., was marked 'N/A.' The required complaint data was also missing from the application package."
NEW! ; 20-M-0589; 20-M-0446
The PSC said that it found Sunsea's response to the 2020 show cause order "unconvincing" and stated in its new order that, " The Commission finds that SunSea has violated the consumer protection provisions of the UBP and moreover has not adequately remedied these violations in response to consumer complaints, Staffs investigation, nor the Commissions OTSC [order to show cause].
Associate -- Retail Supplier -- DFW
Section 1.B.
The PSC's show cause order states, "On February 4, 2021, Staff identified apparent false and misleading statements in the application and sought additional information from Josco.
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Based on SunSeas history of QRS/SRS responses and its NOAF response, including prior denials of refunds, we find these new refunds to be an attempt at self-preservation because the OTSC required it, rather than a gesture of good faith." These facts appears [sic] to directly contradict the information provided in Sections 1.C.
and 1.D.
-- Senior Energy Intelligence Analyst
In fact, Josco has demonstrated the opposite, as proven by the fact that the complaint types remained the same over the course of four years and the QRS responses were consistently insufficient during that time, even when Staff provided multiple notices of violations and deficiencies."
The PSC stated in its order that, "Josco refers to its 'demonstrated commitment to compliance and customer service' with regard to its complaints in New York. NEW! The PSC stated in its order that, "Josco further claims that it has 'consistently worked and continues to work cooperatively and proactively with Staff to quickly and fairly address customer issues and complaints.'
The PSC stated in its order that, "Josco refers to its 'demonstrated commitment to compliance and customer service' with regard to its complaints in New York.
That, combined with the consistent complaints about misleading sales tactics and promises of rebates, rewards, and/or discounts, is not indicative of high standards of customer service."
Section 1.E., which requests the list of all trade names used in other states, was marked 'N/A.' Consequences against SunSea are appropriate as it has 'a material pattern of consumer complaints on matters within the ESCOs control,' failed to comply with 'federal, state, or local laws, rules, or regulations related to sales or marketing,' and has failed to comply with the marketing standards of UBP 10.5 The Commission finds that 116 complaints regarding SunSeas marketing practices over a 16 month period represents a material pattern of complaints on matters within SunSeas control. Section 1.E., which lists all trade names used in other states, continues to be marked 'N/A' despite its affiliates activities beyond New York.
The PSC stated in its order that, "SunSea also remarked that it strives 'to achieve the highest standards of customer satisfaction, and takes its compliance obligations, its relationship with regulatory authorities, and the handling of consumer inquiries and complaints very seriously.'
-- Energy Operations Analyst
-- New Product Strategy and Development Sr.
of both the initial and revised RAAFs.
of the RAAF are incorrect, which, if proven to be the case, would constitute a violation of the UBP."
The information provided by Smart One in these sections indicates that Smart One has no affiliates, uses no other trade names, has operated only in New York in the last 24 months, and has had no regulatory sanctions imposed in the last 36 months. Josco
The PSC ordered that SunSea shall return its customers to full utility service within 60 days of the effective date of the revocation order. ", The PSC's show cause order states, "Staff contacted Starion on January 20, 2021, regarding deficiencies in its application, including the lack of compliant contracts, missing complaint data, non-compliant TPVs, and non-compliant marketing materials.
of the initial RAAF and Sections 1.D.
Consequences against Josco are appropriate as it has 'a material pattern of consumer complaints on matters within the ESCOs control,' and has failed to comply with the marketing standards of UBP 10.
Because SunSea has had a significant history of slamming, misrepresentation, and other enrollment related complaints, and was subject of recent enforcement action in New York, the review of complaints from other states was a predominant concern in the application review process.
The Commission recognizes that SunSea did provide the enrollment documentation with its response to the OTSC. Copyright 2010-21 Energy Choice Matters.
An ESCO that provides false or misleading information in its eligibility application raises significant concerns regarding the companys ability to operate in conformance with the UBP and Commission orders.
-- Sr. Analyst, Structuring -- Retail Supplier
This is not indicative of a company working cooperatively with Staff and fairly addressing customer complaints."
Josco has had multiple opportunities and ample time to prove and demonstrate that they will abide by the UBP.
The RAAF indicates that SunSea Energy, LLC has four affiliates, operates in Ohio, Maryland, New Jersey, and District of Columbia, uses the trade names SunSea and SunSea Energy in other states, and that no senior officer of the ESCO applicant or entity holding ownership interests of 10% or more in the ESCO has had any criminal or regulatory sanctions imposed within the last 36 months.
The information provided by Smart One in these sections indicates that Smart One has no affiliates, uses no other trade names, has operated only in New York in the last 24 months, and has had no regulatory sanctions imposed in the last 36 months.
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"[T]he Commission finds Josco to have engaged in misleading and/or deceptive marketing tactics, including promising savings/discounts that did not materialize, posing as a utility employee, and marketing in English to consumers with limited English proficiency.
The information provided by Smart One in these sections indicates that Smart One has no affiliates, uses no other trade names, has operated only in New York in the last 24 months, and has had no regulatory sanctions imposed in the last 36 months.
The lack of adequate responses to the QRS/SRS complaints from July 2019-November 2020 directly contradicts the statement regarding SunSeas handling of consumer inquiries and complaints.
The PSC stated in its order that, "The Commission further finds that SunSeas response to the OTSC did not remedy the numerous violations alleged.
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This is also not indicative of a company that has been taking its relationship with regulatory authorities seriously since the allegations included questionable marketing practices and misrepresentation, not just disputed enrollments."
"Josco repeatedly claimed that it would implement improvements in its marketing and complaint handling procedures.
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-- Account Operations Manager -- Retail Supplier
Furthermore, SunSea has failed to comply with State laws related to sales or marketing as it continued to knowingly make unsolicited telemarketing sales calls during a declared State of Emergency."
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The PSC stated in its order that, "Additionally, the enrollment documentation that SunSea is referring to was missing from 12 of the cases in the NOAF which prompted Staff to include the records retention violation to the OTSC. NEW!
These transfers shall occur on the customers regularly scheduled meter reading dates.
The PSC stated in its order that, "SunSea states that 'this unfortunate circumstance is not due to willful noncompliance, but rather the rogue actions of marketing vendors.
Additionally, the Commission finds that SunSea engaged in misleading or deceptive conduct in marketing to New York customers, including making false or misleading representations regarding the rates or savings offered by SunSea." -- Sr. Analyst, Structuring -- Retail Supplier
In response, Starion provided additional information on February 17, 2021.
This includes 12 that were confirmed to be checks dated February 2021 for refunds that had been promised on various dates ranging from February 19, 2020, through October 19, 2020. Staff also points out that Josco has previously provided Pennsylvania contracts as supposed proof of New York enrollments for Quick Response System (QRS) complaints. Smart One answered 'no' in response to Section 1.C., which asks if, during the previous 36 months, any criminal or regulatory sanctions have been imposed against any senior officer of the ESCO applicant or any entity holding ownership interests of 10% or more in the ESCO. -- New Product Strategy and Development Sr.
With respect to the revocation of Sunsea's current eligibility, see our prior story for background on the alleged violations and a prior December 2020 show cause order
-- Sales Development Representative (SDR) -- Houston
This includes 12 that were confirmed to be checks dated February 2021 for refunds that had been promised on various dates ranging from February 19, 2020, through October 19, 2020.
However, Josco failed to address the fact that the Vice President of Operations signed the RAAF attesting that the information was true, complete, and accurate.
SunSea stated in its response that it is 'committed to making whole all customers which were identified in Appendix A and B to the OTSC as well as additional customers as a gesture of good faith.'
This appears to indicate that SunSea has failed to abide by marketing regulations in other states, in addition to the marketing concerns in New York.
Josco also repeatedly claimed that it would improve its complaint response practices, yet 17 of the 29 responses to complaints received during 2020 were inadequate and eight of those were during the second half of the year," the PSC stated in its order
Staffs review of the sales calls found that the majority of the agents spoke very quickly and merely completed the script and connected the customer to the TPV.
Providing these documents remedied the allegation of records retention violations, but not the deficient manner in which SunSea submitted QRS/SRS responses."
The complaint data provided included the types of complaints for Maryland and only the number of complaints for Ohio, New Jersey, and the District of Columbia."
The PSC stated in its order that, "Josco refers to its 'demonstrated commitment to compliance and customer service' with regard to its complaints in New York.
"Josco repeatedly claimed that it would implement improvements in its marketing and complaint handling procedures.
The PSC stated in its order that, "The Commission further finds that SunSeas response to the OTSC did not remedy the numerous violations alleged. The PSC stated in its order that, "SunSea also remarked that it strives 'to achieve the highest standards of customer satisfaction, and takes its compliance obligations, its relationship with regulatory authorities, and the handling of consumer inquiries and complaints very seriously.'
SunSea provided the requested complaint details on April 15, 2021, which indicated complaints related to slamming, misrepresentation, sales solicitation issues, and enrollment disputes.
This includes 12 that were confirmed to be checks dated February 2021 for refunds that had been promised on various dates ranging from February 19, 2020, through October 19, 2020.
This is also not indicative of a company that has been taking its relationship with regulatory authorities seriously since the allegations included questionable marketing practices and misrepresentation, not just disputed enrollments."
-- Sr. Analyst, Structuring -- Retail Supplier
of the RAAF which, if proven to be the case, would be a violation of the UBP." Because SunSea has had a significant history of slamming, misrepresentation, and other enrollment related complaints, and was subject of recent enforcement action in New York, the review of complaints from other states was a predominant concern in the application review process. Sic ] to directly contradict the information provided in Sections 1.C opportunities and ample time to and. Information on February 17, 2021 names used in other states, required... All jurisdictions in which Josco operates, as well as other missing documentation complaints without corrective action, the became. Transfers shall occur on the customers regularly scheduled meter reading dates -- NEW Product Strategy and Sr.... Violation of the RAAF which, if proven to be the case, would constitute a of... Which, if proven to be the case, would be a of. All trade names used in other states, was marked ' N/A. PSC that! 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