Details for: PGE AL 5263-E-A.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

September 5, 2018

Advice 5263-E-A
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

Supplemental: Residential Rate Reform Advice Letter with PG&E’s
targets for adopted goal metrics, CCA coordination plan, and ME&O
plan changes based on statewide campaign integration

In compliance with Ordering Paragraph 7 of Resolution E-4882, Pacific Gas and
Electric Company (PG&E) hereby submits and requests approval of this Supplemental
Tier 2 advice filing regarding revisions to PG&E’s marketing, education and outreach
(ME&O) plan based on integration with the statewide campaign.
On July 3, 2015, the California Public Utilities Commission (Commission or CPUC)
issued decision (D) 15-07-001. In compliance with that decision, on November 1, 2016,
PG&E filed Advice Letter 4949-E that included a three-year Residential Rate Reform
proposal for ME&O efforts to be initiated in 2017 and continue through the default of
customers to time-of-use (TOU) rates in 2019. On March 15, 2017, PG&E filed a
supplemental Advice Letter to provide additional details as requested by Administrative
Law Judge McKinney at the February 6, 2017 Prehearing Conference.
On December 14, 2017, the Commission issued Resolution E-4882 which approved,
with modifications, PG&E’s time-of-use (TOU) marketing education and outreach plan
for 2017-2019. Resolution E-4882, Ordering Paragraph 7 requires PG&E to file a Tier 2
Advice Letter containing targets for the goal metrics adopted by the Resolution, a
proposal on how PG&E intends to coordinate with CCAs in its service territory, and any


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Advice 5263-E-A -2- September 5, 2018 revisions to the plan based on integration with the statewide campaign and input from the statewide consultant and ME&O Working Group.1 At the time of filing Advice Letter 5263-E on March 30, 2018, PG&E did not have sufficient statewide ME&O campaign information to be able to assess what changes may be appropriate for PG&E’s ME&O plan based on statewide efforts. At that time, PG&E required information from DDB’s blueprint updates and media plans that were under development. In a March 1, 2018 discussion with Energy Division staff, PG&E was advised to indicate the status of statewide ME&O information and file a supplemental Advice Letter once more sufficient information was available regarding the statewide ME&O blueprint updates, media plan, and budget. PG&E now submits this supplemental Advice Letter and requests its approval. In its 2018 Rate Design Window Supplemental Testimony, filed on August 17, 2018, PG&E included additional information, including Phase 1 TOU survey results, and refinements to its ME&O plan. Plans may need to be adjusted based on additional data and lessons from PG&E’s Phase 1 TOU Transition, SDG&E’s implementation and/or from guidance provided by the Commission on other implementation issues addressed in the 2018 RDW proceeding. However, PG&E’s initial results are very encouraging, with customers reporting high levels of awareness and understanding of TOU, the transition mechanics and rate choices, with several results exceeding Goal Metric Targets. Customers are also beginning to understand the context for TOU. Status of PG&E’s ME&O Plans Based on Statewide Residential Rate Reform Efforts. PG&E does not anticipate making changes to its ME&O plan in response to the statewide campaign information that is currently available. The statewide and IOU campaigns have been developed to address unique marketing objectives, and PG&E will continue to coordinate with DDB in support of a positive end-to-end customer experience. 1 Based on recommendation of Energy Division staff, PG&E submitted a letter to the Energy Division Director on January 2, 2018 for correction of typographical errors in Resolution E-4882 related to the number of goal metrics that require targets. The revised resolution indicated “We agree with PG&E’s proposed modification stating that only goal metrics will require targets and have adjusted the ordering paragraph accordingly.” (Resolution E-4882, p. 43.) While this language indicates that the Commission clearly intended to modify the relevant ordering paragraphs (OP) to address this matter, OP #4 and #7 still indicate that targets are required for all metrics (goal and tracking). A corrected resolution has not yet been issued, but based on discussions with staff and the clear intent to change the number; PG&E has set initial targets for the 10 goal metrics.
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Advice 5263-E-A -3- September 5, 2018 The objectives of the statewide campaign are markedly different from those of PG&E’s local efforts, though they share complementary themes as described in the table below: Statewide Campaigns Statewide Vision Statewide Peak-Shifting Local Campaigns Awareness: “Handholding” the customer through the mechanics of the transition Understanding: Comprehension and internalization Engagement: Behavior change, involvement and feeling in control Retention Objectives • Communicate California’s energy vision and provide context to rate change • Educate all Californians on the benefits of and ways to shift their energy usage away from peak usage times2 Objectives Alert customers to the transition and drive awareness of TOU, why this is happening, the fact that they have a choice of rate plans, and that the transition is risk-free (bill protection) Drive understanding of what this personally means to the customer, what are the implications for their bill, which actions they can/should take, reinforcing how the rate works, their choices, and bill protection, emphasizing how they can manage their bill and be successful on a TOU. Encourage taking action by reducing and/or shifting energy, encouraging small/easy actions that can be sustained and do not overwhelm the customer. Reinforcing how to be successful on TOU, the benefits of sustained action and energy consciousness. The statewide campaign intends to prime customers through a Vision phase, followed by a Peak Shifting phase focused on positive energy management behaviors. This Peak Shifting phase will provide the environmental context for TOU rates, i.e. why time matters – a message that is also critical to PG&E’s customer communications. This part of the campaign has not yet been shared with the IOUs, however PG&E will consider ways to incorporate elements of the Peak Shifting message into its communications. Changes to IOU messages would require careful consideration and testing, as the Phase 1 TOU Transition communications were thoroughly researched among customers and are driving high levels of customer awareness and understanding of the transition. In addition, PG&E plans to look to the Evaluator (IPSOS)3 to understand their recommendations regarding incorporating DDB’s environmental context messaging, as IPSOS will be responsible for overall evaluation. 2 Decision 17-12-023. Decision addressing Statewide Marketing, Education and Outreach for Residential Rate Reform. December 14, 2017. pg 9-11. DDB-4 Advice Letter. Submission of DDB's RRR/TOU ME&O Blueprint Update. April 16, 2018. pg 15. Both the Decision and DDB’s Advice Letter identify a two-track approach for the campaign: Statewide and IOU-based. 3 IPSOS was chosen through an RFP process, with a contract finalized July 24, 2018.
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Advice 5263-E-A -4- September 5, 2018 In addition, PG&E plans to continue proactive coordination with DDB and its affiliated agencies throughout the campaign, particularly regarding community-based organization (CBO) outreach, public relations and media relations. This coordination is in fact already happening through Working Group meetings, during which the IOUs and the statewide agencies have discussed potential coordination points for CBO outreach, as well as keyword selection for paid search campaigns to minimize bidding overlap. Finally, PG&E recommends evaluating the scale of the statewide campaign following SDG&E’s transition, as well as the IOUs’ initial pilot load-shifting results, to ensure that the statewide campaign continues to be a cost-effective investment to helping the state meet its goals. Protests Pursuant to CPUC General Order 96-B, Section 7.5.1, PG&E hereby requests the protest period be waived. Effective Date PG&E requests that this Tier 2 advice filing become effective concurrent with original advice letter 5263-E, which is April 29, 2018. 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 Rulemaking (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 Attachments cc: Service List R.12-06-013 Laura Fernandez, Braun Blaising Smith Wynne, P.C.,
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39E) Utility type: ELC GAS PLC ✔ HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Yvonne Yang Phone #: (415)973-2094 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 5263-E-A Subject of AL: Supplemental: Residential Rate Reform Advice Letter with PG&E’s targets for adopted goal metrics, CCA coordination plan, and ME&O plan changes based on statewide campaign integration Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual ✔ One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Resolution E-4882 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: Yes Yes ✔ No ✔ No 4/29/18 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 proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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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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