Details for: PGE AL 5323-E.pdf

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Erik Jacobson
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

July 6, 2018

Advice 5323-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

PG&E's Outreach and Education Plan for Implementing the Super
User Electric Surcharge per Decision (D.)15-07-001

Pacific Gas and Electric Company (PG&E) hereby submits this Advice Letter requesting
a change to its marketing plan for the High Usage Surcharge (HUS or Surcharge),
formerly referred to as the Super User Electric Surcharge (SUE).
On July 3, 2015, the Commission approved D.15-07-001, Decision on Phase 1 of
Residential Rate Reform for Pacific Gas and Electric Company, Southern California
Edison Company, and San Diego Gas & Electric Company and Transition to Time-ofUse Rates (the Decision), that reforms residential electric rates during the years 2015 to
2020 and transitions customers to time-of-use rates.
The Decision adopted a SUE surcharge which is intended to send a message to highuse customers informing them their usage is significantly above typical household
usage and encouraging them to take steps to conserve. The surcharge, which began in
2017, is applied to customers’ usage above 400% of their baseline.
PG&E has previously filed Advice 4722-E, 4722-E-A and 4722-E-B detailing PG&E’s
outreach and education plan for implementing the SUE surcharge. The Commission
approved PG&E’s plan by disposition letter on August 24, 2016.
PG&E filed 4938-E to modify the Outreach and Education Plan for Implementing the
HUS per D.15-07-001. The Commission approved PG&E’s modifications to the plans
by disposition letter on November 8, 2016.
In this Advice Letter, PG&E is requesting two modifications: (1) that the Annual
Communications to customers incurring the Surcharge (stated in Section II. PostImplementation Phase, Item G, in Advice Letter 4722-E-A per D. 15-07-001) be
eliminated, and (2) that Item D, Quarterly Awareness for Customers with Potential to


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Advice 5323-E -2- July 6, 2018 Incur the Surcharge, be modified to a biannual rather than quarterly cadence for distribution. All other HUS customer communications as previously approved would remain unchanged. PG&E’s current outreach related to the High Usage Surcharge consists of: CUSTOMER COMMUNICATIONS: 1. Auto-Generated Letter informing the customer about HUS the first time it appears on their bill, and sent only once in a 12 month period 2. On-Bill Messaging notifying a customer of HUS on their bill 3. Bill Insert once a year for general awareness of HUS 4. HUS Awareness Letters sent quarterly to newly at-risk customers 5. Annual Communications about HUS “Price Increase” to customers who incurred the Surcharge 6. Monthly Alerts sent to customers who have signed up for High Usage Alert 7. Website Pages specific to HUS 8. IVR mention of HUS with directory to live agent OTHER OUTREACH EFFORTS RELATING TO HUS • Ongoing HUS awareness with Community Based Organizations • Training Customer Service Representatives at Call Centers and Local Offices including new service requests • Integrating HUS Messaging with CARE High Usage Outreach The two items from this list that are addressed in this Advice Letter are: Existing Requirement Requested Modification 4. HUS Awareness Letters sent quarterly to newly at-risk customers who have not previously received education about HUS Modify cadence to twice a year, since the relevance to customers is higher during the two times a year when the HUS is most likely to be incurred (i.e., in summer and month of December). 5. Annual Communications about HUS “Price Increase” to customers who incurred the Surcharge Eliminate. The Energy Division agreed that, given all of PG&E’s other HUS communications, another letter explaining a small change in HUS price is unnecessary, could cause needless customer confusion and anxiety, and does not align with SCE’s and SDG&E’s communication plans. The modified approach for the Annual Communications set forth in this Advice Letter resulted from discussions with the Energy Division and parallels a similar approach to HUS customer communications taken by the other two Investor-Owned Utilities (IOUs).
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Advice 5323-E -3- July 6, 2018 PG&E expects that these modest modifications will result in cost-savings without any negative impact on the customer experience. Modifications to the Outreach and Education Plan for Implementing the HUS Request #1 – Eliminate PG&E’s Annual HUS “Price Increase” Letter to Align with SCE and SDG&E and Avoid Customer Confusion and Anxiety In Advice Letter 4722-E-A per D.15-07-001 submitted on March 26, 2016, on page 28, and approved in August 24, 2016, the following text appears: G. Annual Communications to customers incurring the Surcharge On an annual basis, PG&E will provide direct mail and email communications to customers incurring the SUE surcharge. These communications will be utilized to provide customers with information on any changes to the SUE Surcharge, including the increase to the SUE rate ratio scheduled for 2018, and 2019. 1 Upon a more recent evaluation of the marketing, education and outreach plan for HUS and “At Risk” customers, PG&E discussed its recommendations with Energy Division, which concluded that, given all the other communications to HUS customers, an annual letter explaining a small change in the HUS price is unnecessary, and could possibly cause these customers needless confusion and anxiety. Neither Southern California Edison (SCE) nor San Diego Gas & Electric (SDG&E) sends such a letter as part of their HUS customer outreach. Approval of this Letter brings the three IOUs into alignment on this issue. The price increase per kilowatt hour for the High Usage Surcharge is part of a glide path of several price increases relating to PG&E’s the Tiered Rate Plan (Schedule E-1) which was adopted by the CPUC in D.15-07-001. The most recent change to E-1, included the required small increase to the HUS which applies to customers with usage over 400% in any given month, went into effect on March 1, 2018, per the rate ratio change glide path approved in D.15-07-001. To single out the increase for the High Usage Surcharge, when all tier prices are increasing, does not allow for complete transparency. When PG&E only calls out the price change for the High Usage Surcharge, customers will assume any negative bill impact is due to the HUS increase, not realizing that there were modest increases to all tiers due to revenue requirement changes. PG&E currently sends HUS customers two communications annually, a communication for general awareness (Bill Insert) and a communication when a customer reaches 400% of baseline in the first bill cycle over a twelve-month period (Auto Generated Letter). The Energy Division agreed that these two communications are adequate, and 1 This date puts PG&E’s SUE Surcharge concurrent with PG&E’s next tier narrowing glide path milestones (See D.15-07-001, mimeo, p. 278).
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Advice 5323-E -4- July 6, 2018 the approach presented in this submittal brings PG&E’s approach to HUS communications into better alignment with the other two IOUs. By modifying the HUS communications plan to remove the Annual “Price Increase” Communication, the overall HUS customer experience will be improved. Additional benefits include better management of costs by streamlining customer communications, while still leveraging the many other communications that keep HUS customers educated and informed. REQUEST #2 – Modify Cadence of HUS Awareness Letters to Twice a Year for Newly At-Risk Customers PG&E also requests that the cadence of the HUS Awareness Communication for “at risk” customers be changed from a quarterly to a biannual distribution. As defined in Advice Letter 4722-E-A, the Quarterly HUS Awareness Communication is a letter targeted to customers who had not previously received education and awareness of the potential impact to their bill with HUS. Given that HUS has now been in place for over a year, and the majority of customers have been educated, PG&E is recommending a biannual cadence for the Awareness Letter. The timing would be pre-summer and pre-winter, which is when the communications would be most relevant, because the two times a year when the highest occurrences of HUS happen are in the hot summer months and the month of December. There is no longer a need for “year-round” or “seasonal” customer segmentation with the awareness outreach since the “year-round” customers have received communications when they incurred the surcharge (Auto Generated Letter). A comparison of the current and proposed outreach plan follows: Previously Approved Outreach Plan
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Advice 5323-E -5- July 6, 2018 Proposed Changes to Outreach Plan for Post-Implementation Phase Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or E-mail, no later than July 26, 2018, which is 20 days after the date of this filing. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail:
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Advice 5323-E -6- July 6, 2018 Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date PG&E requests that this Tier 2 advice filing become effective on regular notice, August 5, 2018 which is 30 calendar days after the date of filing. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service list for R.12-06-013. Address changes to the General Order 96-B service list should be directed to PG&E at email address For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter filings can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations
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Advice 5323-E cc: -7- July 6, 2018 Service List R.12-06-013 Jason Keyes, Keyes, Fox & Wiedman LLP Brad Heavner, California Solar Energy Industries Association (CALSEIA)
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CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No. Pacific Gas and Electric Company (ID U39 E) Utility type: Contact Person: Yvonne Yang  ELC  GAS  PLC  HEAT Phone #: (415) 973-2094  WATER E-mail: and EXPLANATION OF UTILITY TYPE ELC = Electric PLC = Pipeline GAS = Gas HEAT = Heat (Date Filed/ Received Stamp by CPUC) WATER = Water Advice Letter (AL) #: 5323-E Tier: 2 Subject of AL: PG&E's Outreach and Education Plan for Implementing the Super User Electric Surcharge per Decision (D.)15-07-001 Keywords (choose from CPUC listing): Compliance, Billing, Surcharges AL filing type:  Monthly  Quarterly  Annual  One-Time  Other _____________________________ If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D. 15-07-001 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: ____________________ Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: No Confidential information will be made available to those who have executed a nondisclosure agreement: N/A Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential information: __________________________________________________________________________________________________ Resolution Required? Yes No Requested effective date: August 5, 2018 N No. of tariff sheets: N/A Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed: N/A Pending advice letters that revise the same tariff sheets: N/A Protests, dispositions, and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: California Public Utilities Commission Energy Division EDTariffUnit 505 Van Ness Ave., 4th Flr. San Francisco, CA 94102 E-mail: Pacific Gas and Electric Company Attn: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, CA 94177 E-mail:
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PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. Braun Blaising Smith Wynne P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Casner, Steve Cenergy Power Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand Ellison Schneider & Harris LLP Energy Management Service Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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