Details for: PGE Comments on Draft Resolution E-4871.pdf


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Erik Jacobson
Director
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B23A
P.O. Box 770000
San Francisco, CA 94177
Fax: (415) 973-1448

July 31, 2017

California Public Utilities Commission - Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102

Subject:

Comments of Pacific Gas and Electric Company on Resolution E4871, DDB San Francisco Requesting Approval of the Five-Year
Marketing, Education, and Outreach Strategic Roadmap and the
2017-2018 Joint Consumer Action Plan

Dear Energy Division Tariff Unit:
In consultation with DDB San Francisco (“DDB”), Pacific Gas and Electric Company
(“PG&E”) files these comments in support of draft Resolution E-4871 (“the Draft
Resolution”). The Resolution requests approval of DDB San Francisco’s Five-Year
Marketing, Education, and Outreach Strategic Roadmap, 2017-2018 Joint Consumer
Action Plan, and budget for October 2016 to September 2019.
PG&E appreciates the Commission’s and Energy Division’s timely consideration of the
Roadmap, Consumer Action Plan, and budget, and fully supports the Draft Resolution.
PG&E urges the Commission to adopt the draft Resolution at its August 10, 2017
meeting, with the changes proposed below.
Section 3(c) Submission of Brand Health Tracking Study
Section 3(c) of the Resolution states that “DDB will submit a brand health tracking study
on October 5 and April 5 of each year.” DDB has indicated that it agrees with this
statement and wants to further clarify that the tracking study will help DDB understand
how Energy Upgrade California communications are impacting key metrics (awareness,
familiarity, intent, and motivation) that were defined in the Roadmap. Longer term, DDB
also will track the population distributions among the various segments to understand if
the campaign has caused any shift between segments; e.g., have people been
convinced to the extent that, over time, they are increasingly counted among one of the
more active segments?





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PG&E Comments on Draft Resolution E-4871 -2- July 31, 2017 Section 3(d) Submission of Segmentation Study The Draft Resolution states that “DDB will submit a segmentation study update on April 5 of each year.” DDB has indicated that it agrees with the value of periodic segmentation study updates. However, DDB disagrees with the annual timing of the updates because mindsets don’t change frequently enough to be captured in annual updates. In a category such as energy, segmentations are generally conducted every three to five years. However, DDB will continually monitor public attitudes and will update the segmentation schedule, should that be warranted. Section 3(e) Statewide Implementer Administrative Expense and Estimated Budget The Draft Resolution accepts DDB’s recommendation to remove “Statewide Implementer Administrative Expense” from the Statewide ME&O budget, and explains that “DDB should still be able to provide statewide implementer administrative expenses broken out, if requested by the CPUC staff or as part of a financial audit.” DDB agrees, and will be able to break out administrative expenses, if required. The final DDB budget, for activities from October 2016 to September 2019, should be changed from $73,318,314 to $68,186,032. The larger Statewide ME&O budget of $73,318,314 reflects a 4% budget allocation of $2,127,404 for evaluation, measurement, and valuation expenses (“EM&V”) expenses, and a 3% budget allocation of $2,727,441 for IOU administrative expenses. The overall allocation of the Statewide ME&O budget can be found in D.16-09-020, Ordering Paragraph 5.1 PG&E requests that the Commission revise the resolution to reflect the EM&V and IOU administrative expenses as outside the DDB contract, and authorize each utility to collect its assigned percentage in rates. Conclusion PG&E, in consultation with DDB San Francisco, respectfully requests that the Commission consider the above comments and accept PG&E’s clarifications in finalizing Resolution E-4871. /S/ Erik Jacobson Director, Regulatory Relations 1 Full amount can be seen in detail in AL G-3770 / E-4939, and PG&E specific budget can be seen in AL 3783-G / 4963-E.
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PG&E Comments on Draft Resolution E-4871 -3- Cc: Edward Randolph, Director, Energy Division Service List for A.12-08-007 Energy Division Tariff Unit Hal Kane, Energy Division Rory Cox, Energy Division Matt Perry, DDB San Francisco Michael Shue, DDB San Francisco Melissa W. Kasnitz, Center for Accessible Technology July 31, 2017
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