In Section 1.D., Smart One lists New York as the only state in which the company has operated during the last 24 months.
Associate -- Retail Supplier -- DFW
--Editing by Patrick Reagan.
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The PSC ordered that SunSea shall return its customers to full utility service within 60 days of the effective date of the revocation order. -- Sr. Analyst, Structuring -- Retail Supplier
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.
-- Energy Operations Analyst
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.
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
-- Sales Development Representative (SDR) -- Houston
The OTSC directed Josco to provide four pieces of information pertaining to the 13 listed complaint cases, including: enrollment documentation, disconnect dates, cost analysis, and refund information.
It stated that 'the company only operates in New York State and the companys complaint data is on file with [Staff].'"
The PSC said that Josco's response to the 2020 show cause order was "unconvincing" and said, "The Commission finds that Josco 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].
-- Energy Operations Analyst
An incomplete response was also provided with respect to the complaint data, which only included the number of complaints each month for New York and Ohio."
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.
of the RAAF which, if proven to be the case, would be a violation of the UBP."
As part of its review, Staff contacted a representative at the customer service number that Josco listed on its RAAF, and was informed by the representative that Josco does in fact operate in multiple states."
-- Energy Advisor
of the initial RAAF and Sections 1.D.
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of the initial RAAF and Sections 1.D. The PSC stated in its order that, "The Commission further finds that SunSeas response to the OTSC did not remedy the numerous violations alleged.
Section 1.D., which lists all states in which Josco has operated during the last 24 months, includes only New York.
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Because Josco has had a significant history of complaints and enforcement action in New York, the review of complaints from other states was a predominant concern in the application review process.
Moreover, the corrective action eventually taken to terminate a marketing vendor did not address these complaints which originated with an entirely different vendor."
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.
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.
"Josco repeatedly claimed that it would implement improvements in its marketing and complaint handling procedures.
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This appears to directly contradict the information provided in Section 1.C.
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."
of the initial RAAF and Sections 1.D.
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This is not indicative of a company working cooperatively with Staff and fairly addressing customer complaints."
The OTSC directed Josco to provide four pieces of information pertaining to the 13 listed complaint cases, including: enrollment documentation, disconnect dates, cost analysis, and refund information. The PSC stated in its order that, "Turning to the marketing provisions of the UBP, SunSea violated the UBP by failing to remove customers from its marketing database after the customers asked to no longer be called by SunSea.
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.'
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of the RAAF, which requests a list of energy affiliates including upstream owners and affiliates, refers to an Attachment that now lists Joscos affiliates as Josco Energy MA, LLC, Josco Energy IL, LLC, and Josco Energy USA, LLC.
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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.'
The PSC's show cause order states, "Upon completion of the application review, Staff requested revisions to the sales agreements, TPV scripts, the complaint data from all jurisdictions in which Smart One operates, and other missing documentation.
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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.' These transfers shall occur on the customers regularly scheduled meter reading dates.
Providing these documents remedied the allegation of records retention violations, but not the deficient manner in which SunSea submitted QRS/SRS responses."
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.
-- Senior Analyst - Pricing & Structuring -- Retail Supplier -- Houston
"Starion is in the process of reviewing the Public Service Commissions Order to Show Cause and will respond accordingly."
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.
-- Energy Advisor
Cases 15-M-0127, et al.
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.'
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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 November 17, 2020, Starion filed an application, signed by Starions Chief Operating Officer (COO), seeking to comply with the December 2019 Order.
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."
of the RAAF which, if proven to be the case, would be a violation of the UBP."
; 20-M-0589; 20-M-0446
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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.
In Section 1.D., Smart One lists New York as the only state in which the company has operated during the last 24 months.
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-- Energy Operations Analyst
TORONTO, Nov. 12, 2021 (GLOBE NEWSWIRE) -- Just Energy Group Inc. ("Just Energy" or the "Company") (TSXV:JE; OTC:JENGQ), a retail energy provider specializing in electricity and natural . ; 20-M-0589; 20-M-0446
AUG 2 6 2016 Version Revised 03/10/16 PA PUBLIC UTILITY COMMISSION SECRETARY'S BiinFai BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION Application of Josco Energy USA, LLC for approval to offer, render, furnish, or supply natural gas supply services as a(n) Supplier/ to the public in the Commonwealth of Pennsylvania {Pennsylvania). 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.
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. -- Account Operations Manager -- Retail Supplier
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's show cause order states, "Josco filed a revised RAAF on April 15, 2021.
The New York PSC has issued separate orders revoking the ESCO eligibility of Josco Energy Corp ("Josco") and SunSea Energy, LLC ("SunSea").
Moreover, the corrective action eventually taken to terminate a marketing vendor did not address these complaints which originated with an entirely different vendor."
Smart One responded that the previously submitted sales agreements were compliant, other documentation had already been included, and other revisions and documents were filed.
"Josco repeatedly claimed that it would implement improvements in its marketing and complaint handling procedures.
We find that after months of similar complaints without corrective action, the noncompliance became willful.
"[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.
With respect to the revocation of Josco's current eligibility, see our prior story for background on the alleged violations
of the RAAF which, if proven to be the case, would be a violation of the UBP."
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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.
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of the RAAF, which requests a list of energy affiliates including upstream owners and affiliates, refers to an Attachment that now lists Joscos affiliates as Josco Energy MA, LLC, Josco Energy IL, LLC, and Josco Energy USA, LLC.
-- Senior Energy Intelligence Analyst
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These facts appears [sic] to directly contradict the information provided in Sections 1.C.
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.
and 1.D.
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.
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."
Smart One responded that the previously submitted sales agreements were compliant, other documentation had already been included, and other revisions and documents were filed.
The Commission recognizes that SunSea did provide the enrollment documentation with its response to the OTSC.
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.
The PSC's show cause order states, "Upon completion of the application review, Staff requested revisions to the sales agreements, TPV scripts, the complaint data from all jurisdictions in which Smart One operates, and other missing documentation.
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.
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On August 2, 2019, the Maryland Public Service Commission issued its Order Suspending Retail Supply License, Imposing Civil Penalty, and Directing the Transfer of Service against Smart One.
The PSC's show cause order states, "Upon completion of the application review, Staff requested revisions to the sales agreements, TPV scripts, the complaint data from all jurisdictions in which Smart One operates, and other missing documentation.
Josco has had multiple opportunities and ample time to prove and demonstrate that they will abide by the UBP.
Furthermore, the website named on Joscos RAAF, www.joscoenergy.com, indicates that Josco provides service in Illinois, Maryland, New Jersey, New York, Ohio, and Pennsylvania.
These facts appears [sic] to directly contradict the information provided in Sections 1.C.
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."
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.
of the RAAF which, if proven to be the case, would be a violation of the UBP."
-- Senior Analyst - Pricing & Structuring -- Retail Supplier -- Houston
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In response, Starion provided additional information on February 17, 2021.
These transfers shall occur on the customers regularly scheduled meter reading dates.
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].
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.
of the RAAF, which requests a list of energy affiliates including upstream owners and affiliates, was marked 'N/A.'
The PSC's show cause order states, "On November 17, 2020, Starion filed an application, signed by Starions Chief Operating Officer (COO), seeking to comply with the December 2019 Order.
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 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.
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.
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. 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. -- Sr. Analyst, Structuring -- Retail Supplier
Section 1.B. 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.
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.
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."
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.
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.'
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."
of the RAAF which, if proven to be the case, would be a violation of the UBP." Further modifications to its sales agreements were requested on March 1, 2021, which Starion provided on March 10, 2021."
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.
Joscos response included the enrollment documentation and images of refund checks, but no disconnect dates or cost analyses.
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 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.
Smart One responded that the previously submitted sales agreements were compliant, other documentation had already been included, and other revisions and documents were filed. 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 lists all trade names used in other states, continues to be marked 'N/A' despite its affiliates activities beyond New York.
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."
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This appears to directly contradict the information provided in Section 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.
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.
It stated that 'the company only operates in New York State and the companys complaint data is on file with [Staff].'"
Access additional case information on PACER Use the links below to access additional information about this case on the US Court's PACER system. Contradictory evidence was also found as part of the Massachusetts Attorney Generals lawsuit, filed on October 16, 2018, against Starion Energy Inc., two of its principals, including Ruzhdi Dauti, who is named on the RAAF as the president of Starion, and various marketing entities for violations of Massachusetts law.
In Section 1.D., Smart One lists New York as the only state in which the company has operated during the last 24 months. 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 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 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.
The PSC stated in its order that, "Turning to the marketing provisions of the UBP, SunSea violated the UBP by failing to remove customers from its marketing database after the customers asked to no longer be called by SunSea.
; 20-M-0589; 20-M-0446
We find that after months of similar complaints without corrective action, the noncompliance became willful. The PSC's show cause order states, "Upon completion of the application review, Staff requested revisions to the sales agreements, TPV scripts, the complaint data from all jurisdictions in which Smart One operates, and other missing documentation.
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."
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