utility.com's comments on standardized third-party authorization form

All:

In light of the comments already provided by numerous parties, utility.com
would like to submit the following concerns regarding the standardized
third-party authorization form.  They tend to echo many of the salient
points made by Preferred Energy Services, Commonwealth, SPURR, New West
Energy, and DGS.

*  Simplify the form:
This authorization form is very burdensome for customers, especially
residential ones.  Rick Kohl has a good suggestion - we should develop a
simpler, easy-to-follow, and appropriate form for residential customers.
That way, we can eliminate the references to agents and consultants and
Directors of Facilities which a typical residential customer probably
doesn't have.  This form, in a modified format, should only be used for
commercial customers.

*  Notarization requirement:
The notarization requirement is equally burdensome and a barrier to customer
choice.  This places an unnecessary burden on customers who want to select a
new energy service provider.  Not only is there an additional cost to the
customer who is looking to save money, this requirement is an inconvenience.


*  Allow ESPs to reformat authorization form:
Providing that the text is identical to the final agreed-upon authorization
form, ESPs should have the ability to reformat and present this form in a
way that is easy for the customer to understand and complete.  As long as
the ESP provides the required information to the UDC, the manner in which
the ESP gets it should not be a concern to the UDCs.  An ESP should also
have the ability to present this form to the customer electronically and
remit to the UDC electronically (i.e., via e-mail).

Thanks.

David Bayless
utility.com

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