This is a Statement of Principles ("Principles") for Marketing Retail Electricity and Natural Gas to residential and small business customers ("Customers"). BlueRock Energy adopts these Principles to reflect their desire to give full and fair disclosure in marketing energy products to Customers. It is our intent that these Principles will help:

• protect Customers;
• build and maintain Customer confidence in the retail electricity and natural gas industry;
• promote the effective transition to full retail competition;
• enhance efficient retail market operation by clarifying standards and promoting certainty;
• promote ongoing cooperation between the retail energy industry, regulatory authorities, and Customers;
• raise awareness of and promote compliance with the provisions applicable to the marketing of retail electricity and natural gas in the New York Uniform Business Practices Act; and,
• Remain flexible and responsive to changing patterns of marketing behavior and the changing nature of the industry.

Training of Marketing Representatives
BlueRock Energy shall ensure that the training of their marketing representatives includes:

1. Knowledge of this Principles and provisions of the New York Uniform Business Practices;
2. Knowledge of BlueRock’s products and services;
3. Knowledge of BlueRock’s rates, payment options and the customers’ right to cancel, including the applicability of an early termination fee;
4. Knowledge of the applicable provisions of the Home Energy Fair Practices Act that pertains to residential customers; and,
5. The ability to provide the customer with a toll-free number from which the customer may obtain information about BlueRock’s mechanisms for handling billing questions, disputes, and complaints.

In Person Contact with Customers

BlueRock marketing representatives who contact customers in person at a location other than BlueRock’s place of business for the purpose of selling any product or service offered by BlueRock will, as soon as possible and prior to describing any products or services offered for sale by BlueRock:

a. Produce identification, to be visible at all times thereafter, which:

1. Prominently displays in reasonable size type face the full name of the marketing representative;
2. Displays a photograph of the marketing representative and depicts the legitimate trade name and logo of BlueRock;
3. Provides BlueRock’s telephone number for inquiries, verification and complaints.

b. Shall identify BlueRock as an independent energy marketer. During the sales presentation, the marketing representative must also state that if customer purchases natural gas and/or electricity from BlueRock that the customer’s utility will continue to deliver their energy and will respond to any leaks or emergencies.

c. BlueRock’s marketing representative shall leave the premises of a customer when requested to do so by the customer or the owner or occupant of the premises.

d. BlueRock’s marketing representative will provide the customer with written information regarding our products and services immediately upon request which shall include the BlueRock’s name and telephone number for inquiries, verification and complaints.

e. Where it is apparent that the customer’s English language skills are insufficient to allow the customer to understand and respond to the information conveyed by BlueRock or where the customer or another third party informs BlueRock’s marketing representative of this circumstance, BlueRock shall either find a representative in the area who is fluent in the customer’s language to continue the marketing activity in his/her stead or terminate the in-person contact with the customer.

Telephone Contact with Customers

BlueRock marketing representatives who contact customers by telephone for the purpose of selling any product or service offered by the ESCO shall:

a. Provide BlueRock’s marketing representative’s first name and, on request, the identification number;

b. State the name of BlueRock on whose behalf the call is being made;

c. Never represent that the BlueRock’s marketing representative is an employee or representative or acting on behalf of a distribution utility. In addition, BlueRock’s marketing representative must clearly indicate that taking service from BlueRock will not affect the customer’s distribution service and such service will continue to be provided by the customer’s distribution utility;

d. State the purpose of the telephone call;

e. Where it is apparent that the customer’s English language skills are insufficient to allow the customer to understand and respond to the information conveyed by the BlueRock representative or where the customer or another third party informs the BlueRock marketing representative of this circumstance, the BlueRock marketing representative will immediately transfer the customer to a representative who speaks the customer’s language, if such a representative is available, or terminate the call; and,

f. Remove Customers’ names from the marketing database upon Customers’ request.

Conduct

BlueRock shall:

a. Not engage in misleading or deceptive conduct as defined by State or federal law, or by Commission rule, regulation or Order;

b. Not make false or misleading representations including misrepresenting rates or savings offered by BlueRock;

c. Provide the customer with written information, upon request, or with a website address at which information can be obtained, if the customer requests such information via the internet;

d. Use reasonable efforts to provide accurate and timely information about services and products. Such information will include information about rates, contract terms, early termination fees and right of cancellation consistent with Section 2 of the UBP and any other relevant Section;

e. Ensure that any product or service offerings that are made by BlueRock contain information written in plain language that is designed to be understood by the customer. This shall include providing any written information to the customer in a language in which the ESCO representative has substantive discussions with the customer or in which a contract is negotiated;

f. Investigate customer inquiries and complaints concerning marketing practices within five days of receipt of the complaint; and,

g. Cooperate with the Department and PSC regarding marketing practices proscribed by the UBP and with local law enforcement in investigations concerning deceptive marketing practices.

Dispute Resolution

BlueRock will maintain an internal process for handling customer complaints and resolving disputes arising from marketing activities and shall respond promptly to complaints forwarded by the New York State Public Service Commission.

Version: October 19, 2009