Details for: PGE AL 5609-E.pdf


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Erik Jacobson
Director
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

August 2, 2019

Advice 5609-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California
Subject:

Updated program budget estimates and 2019-2021 Marketing
Education and Outreach (ME&O) Plans for the Disadvantaged
Communities Green Tariff (DAC-GT) and Community Solar Green
Tariff (CSGT) Programs

Purpose
Pursuant to Ordering Paragraphs (OPs) 5 and 6 of Resolution E-4999, Pacific Gas and
Electric Company (PG&E) submits this Tier 2 advice letter to submit updated program
budget estimates and the 2019-2021 Marketing Education and Outreach (ME&O) plans
for the Disadvantaged Communities Green Tariff (DAC-GT) and Community Solar
Green Tariff (CSGT) Programs.
Background
On June 3, 2019, the California Public Utilities Commission (Commission or CPUC)
issued Resolution E-4999, which approved with modification, Tariffs to Implement the
Disadvantaged Communities Green Tariff and Community Solar Green Tariff Programs.
OP 5 requires PG&E to submit a Tier 2 Advice Letter to provide updated program
budget estimates for the Disadvantaged Communities Green Tariff (DAC-GT) and
Community Solar Green Tariff (CSGT) Programs. OP 5 states:
These program budgets must cover programmatic costs for 2019 and 2020 and
must reflect all changes required to be made to each utility’s program
implementation plans in this Resolution. The revised budgets must include
funding for the independent evaluator for 2019-2020 as specified in this
Resolution ($176,000 each for PG&E and SCE and $48,000 for SDG&E). In
addition, the revised budgets must reflect any greenhouse gas (GHG) revenue
approved to be set aside by each utility for DAC-GT and CSGT in its 2019
Energy Resource Recovery Account (ERRA) Forecast Decision. Since each
utility’s revised program budgets will not have been submitted prior to when it
must submit its 2020 ERRA Forecast filing, each utility should set aside the
2019-2020 program funding requested in its implementation AL, adjusted by the
2019 GHG allowance revenue approved for that utility’s DAC-GT and CSGT





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Advice 5609-E -2- August 2, 2019 programs. PG&E, SCE, and SDG&E must submit a revision to their ERRA forecast filings no later than the November Update once updated 2019-2020 program budget amounts are approved by the Energy Division. In addition, OP 6 requires the Tier 2 Advice Letter to include the 2019-2021 Marketing Education and Outreach (ME&O) plan. OP 6 states: Each IOU’s ME&O plan should include separate sections on the Disadvantaged Communities Green Tariff and Community Solar Green Tariff programs and discuss specific timelines and methods for customer outreach, including coordination with community-based organizations and community sponsors. Details DAC-GT Budget The DAC-GT budget is provided below in Table 1. Note that the funding for the independent evaluator, and the Green-e Energy certification fees, are included in the Program Management category of expenses. Table 1 DAC-GT Budget for 2019-2020 1 Generation costs (1) 2 20% Discount Program Management IT Procurement Contact Centers 3 Admin Subtotal 4 Marketing & Outreach TOTAL $ $ $ $ $ $ $ $ 2019 269,271 1,933,495 82,038 2,284,805 151,775 $ 2,436,580 $ $ $ $ $ $ $ $ $ 2020 217,546 841,755 99,687 299,937 189,667 75,000 664,290 288,800 2,012,391 The DAC-GT budget increased for 2019 from $2.112 million to $2.437 million and decreased slightly for 2020 from $2.099 million to $2.012 million. The prior budget was filed in February 2019 in Advice Letter 5362-E-A. The reasons for the change in the 2019 and 2020 budgets are discussed below. Generation costs: Remained unchanged in 2019 and decreased in 2020 primarily due to a later program start than originally forecast. 20% Discount: Remained unchanged in 2019 and decreased in 2020 primarily due to a later program start than originally forecast, as well as a lower enrollment forecast.
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Advice 5609-E -3- August 2, 2019 Administrative costs: Increased in 2019 and 2020 due to increased labor rates, increased IT budget forecast, the addition of new program elements and features required in Resolution E-4999 such as Green-e Energy certification and GHG allowance retirement under the Voluntary Renewable Electricity Program of the California Air Resources Board, independent evaluator costs, and procurement of DACGT resources in 2019. Marketing and Outreach: Decreased in 2019 and increased in 2020. Budgets have been updated to better reflect the proposed tactics and timing outlined within the ME&O plan. Budgets submitted previously were preliminary, prior to a full ME&O plan being developed. CSGT Budget The CSGT Budget is provided below in Table 2. Note that the funding for the independent evaluator and the Green-e Energy certification fees are included in the Program Management category of expenses. Table 2 CSGT Budget for 2019-2020 1 Generation costs 2 20% Discount Program Management IT Procurement Contact Centers 3 Admin Subtotal 4 Marketing & Outreach TOTAL $ $ $ $ $ $ $ $ 2019 70,100 10,710 139,418 220,228 187,075 $ 407,303 $ $ $ $ $ $ $ $ $ 2020 387,283 2,153,000 282,186 40,000 2,862,469 279,400 3,141,869 The CS-GT budget increased for 2019 from $366 thousand to $407 thousand and decreased for 2020 from $3.244 million to $3.142 million. The prior budget was filed in February 2019 in Advice Letter 5362-E-A. The reasons for the change in the 2019 and 2020 budgets are discussed below. Generation costs and 20% Discount: Unchanged from prior estimate as the programs are not expected to launch until 2021. Administrative costs: Increased in both years due to increased labor rates, the addition of new program elements and features required in Resolution E-4999 such as Green-e
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Advice 5609-E -4- August 2, 2019 Energy certification and independent evaluator costs, and increased estimation of procurement labor. Marketing and Outreach: Remained largely similar in 2019 and decreased in 2020. Budgets have been updated to better reflect the proposed tactics and timing outlined within the ME&O plan. Budgets submitted previously were preliminary, prior to a full ME&O plan being developed. ERRA Budget Allocations In Decision 19-02-023, the Alternate Decision Adopting PG&E’s 2019 Energy Resource Recovery Account Forecast and Generation Non-Bypassable Charges Forecast and Greenhouse Gas Forecast Revenue and Reconciliation, the CPUC adopted a set-aside of $14.449 million from greenhouse gas (GHG) revenue for funding the DAC-GT and CSGT programs.1 The $14.449 set aside is significantly larger than the $2.843 million requested in this 2019 budget and the $5.154 million requested in this 2020 budget. For its 2020 ERRA Forecast filing2, as directed in Resolution E-4999 Ordering Paragraph (OP) 5, PG&E set aside the 2019-2020 program funding requested in its implementation advice letter, 5362-E-A, as shown below. 2020 ERRA Forecast (A.19-06-001) As directed in OP 5, PG&E will submit a revision to the 2020 ERRA forecast filing no later than the November Update once 2019-2020 program budget amounts are approved by the Energy Division. 1 2 D.19-02-023 p.10 A.19-06-001
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Advice 5609-E -5- August 2, 2019 2019 – 2021 Marketing Education and Outreach Plan Please find attached in Appendix A the Disadvantaged Community Green Tariff (DACGT) and Community Solar Green Tariff (CSGT) 2019-2021 Marketing Education and Outreach Plan. Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than August 22, 2019, which is 20 days after the date of this submittal. 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: EDTariffUnit@cpuc.ca.gov 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: PGETariffs@pge.com 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
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Advice 5609-E -6- August 2, 2019 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 submittal become effective upon September 2, 2019 which is 30 calendar days from the submittal date. 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.14-07-002 and R.12-11-005. Address changes to the General Order 96-B service list should be directed to PG&E at email address PGETariffs@pge.com. For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter submittals can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service lists for R.14-07-002 and R.12-11-005
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ADVICE LETTER S UM M A RY 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: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Annie Ho Phone #: (415) 973-8794 E-mail: PGETariffs@pge.com E-mail Disposition Notice to: AMHP@pge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Advice Letter (AL) #: 5609-E Tier Designation: 2 Subject of AL: Updated program budget estimates and 2019-2021 Marketing Education and Outreach (ME&O) Plans for the Disadvantaged Communities Green Tariff (DAC-GT) and Community Solar Green Tariff (CSGT) Programs 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-4999 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 9/2/19 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 1: N/A Pending advice letters that revise the same tariff sheets: N/A Discuss in AL if more space is needed. 1 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: EDTariffUnit@cpuc.ca.gov 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: PGETariffs@pge.com 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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APPENDIX A Disadvantaged Community Green Tariff (DAC-GT) & Community Solar Green Tariff (CSGT) 2019-2021 Marketing Plan Marketing Education and Outreach (ME&O) Plan PG&E referenced the guidance and requirements provided in the Disadvantaged Community Green Tariff (DAC-GT) and Community Solar Green Tariff (CSGT) Decisions and Resolution1 when developing the marketing implementation advice letter. PG&E developed the 2019-2021 marketing outreach plan to promote PG&E’s Green Saver (DAC-GT) and Local Green Saver (CSGT) programs. The marketing plan includes: A. Marketing Objectives B. Target Markets C. Outreach and Messaging Strategy D. Outreach Channels and Tactics E. Metrics and Evaluation Plans and Schedules F. Estimated Budget 1 D.18-06-027, D.18-10-007, and Resolution E-4999. Page 1 of 6
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2019-2021 DAC-GT (“Green Saver”) Marketing Plan A. Marketing Objectives • Drive residential customer enrollments in PG&E’s Green Saver program. • Promote related programs eligible to Green Saver customers (CARE/FERA/ESA) post-enrollment. B. Target Market • Residential Disadvantaged Community2 (DAC) customers who are eligible for/enrolled in either the California Alternate Rates for Energy (CARE) program or the Family Electric Rate Assistance (FERA) program. PG&E will identify CARE/FERA eligible customers in Disadvantaged Communities (an identifiable attribute in our marketing database) using the methodology currently in use by the PG&E low income team for acquisition: • CARE is targeted based on an established CARE propensity model that indicates likelihood of CARE eligibility. The model looks at 21+ attributes that are positive or negative indicators for CARE eligibility. For acquisition marketing purposes, we target Deciles 1-3 (most likely eligible), and Deciles 4 & 5 with specific Household Income flags. • FERA targeting leverages similar CARE attributes adjusting for Household Income and Household Size (≥ 3 people) differences. C. Outreach and Messaging Strategy PG&E will use a test and learn approach updating messages and channels to best resonate with customers and drive program enrollment. In addition, PG&E will apply learnings from existing CARE and Solar Choice marketing to maximize acquisition success. Outreach Strategy • Integrate Green Saver acquisition messaging with existing CARE/FERA and CBO outreach, where relevant. • Utilize tactics offering high conversion rates at a lower cost per acquisition. • Adjust outreach strategy based on learnings throughout the year. • Promote acquisition messages at key times of the year proven to have a higher take rate. Positioning Empowering customers to support clean energy within California AND save money through the PG&E Green Saver Program. _______________________ 2 Disadvantaged Community, for purposes of this program, are defined as census tracts that are among the top 25 percent most impacted census tracts statewide, using CalEnviroScreen 3.0 scoring. In addition, the 22 additional census tracts that do not have an overall ranking, but score among the highest 5 percent of CalEnviroScreen’s Pollution Burden category, are also included. Page 2 of 6
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D. Outreach Channels and Tactics PG&E will use a multi-touch, multi-wave marketing approach to reach Green Saver-eligible customers through the following direct outreach and targeted tactics: • Email/Direct Mail outreach: Promote the benefits of the program to capture interest and drive enrollments cost efficiently. Capitalize on seasonal messaging to be relevant and increase program interest (i.e. Earth Day and post-year-end holidays). • Owned assets/message integration: Leverage PG&E assets (relevant CARE/FERA marketing materials, pge.com website promotional spaces, newsletters, press releases etc.) to encourage enrollment. • Collateral: Develop brochures/fact sheets that may be used at relevant events and CBO outreach. • CBO Outreach: Tap into PG&E low income team’s existing/developing CBO relationships to educate and encourage enrollment. Relationships include 42 community outreach contractors and 9 community-based organizations throughout the service territory that currently support PG&E’s California Alternative Rates Energy (CARE) program. Partnering with community health outreach events, low-income home energy assistance program (LIHEAP) offices. • Website: PG&E will develop dedicated pages on pge.com as well as contribute program content to a statewide site page. The CPUC will host and maintain the statewide page and the IOUs will provide updates if/when individual IOU web page links change. • Cross Promotion of Related Programs: o Message integration: Green Saver enrolled customers not enrolled in CARE/FERA will be provided as a lead to our CARE team to incorporate into their acquisition outreach efforts. o Green Saver enrollment confirmation: PG&E will incorporate related Energy Savings Assistance (ESA) program messaging into the Green Saver enrollment confirmation notification to capitalize on an engaged customer touchpoint. Page 3 of 6
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E. Metrics and Evaluation Plans and Schedules PG&E will track and measure success using industry channel benchmarks and/or previous PG&E campaign performance metrics detailed below. Metrics Tactics Timing Year 1 -2019 25-27% open rate 2-3% Click rate Email Year 2 -2020 Year 3 - 2021 -Mar -Apr -Jun -Oct -Jan -Apr -April -Jan -Apr -Oct -Jan -Jun N/A Direct Mail Owned assets (pge.com advertisements, residential newsletter) 0.5% enrollment rate 0.01-0.02% click rate (pge.com ad) 0.50% residential newsletter N/A N/A Varies Ongoing Ongoing depending on starting in Jun Message Integration/CBO Outreach tactic type N/A -site visits March Ongoing -clicks to/on IOU program Website pages N/A Note: 2021 planned tactics/timing outlined above is pending budget approval. If requested budget submitted February 2020 is not approved, or a lesser budget amount is approved, tactics/timing are subject to change. F. Estimated Budget The proposed budget below includes outreach expenditures expected for 2019-2020. PG&E will monitor performance results throughout the year and optimize the plan accordingly to achieve an effective cost per acquisition. Tactics Year 1 - 2019 Year 2 -2020 Email/Direct Mail $75,000 $150,000 Message Integration $10,000 $20,000 Collateral for CBO Outreach $15,000 $10,000 Owned Assets N/A $10,000 P&GE Labor $49,400 $98,800 Statewide Website $2,375 N/A Total $151,775 $288,800 Note: Adjustments to the tactics and budgets will be made throughout implementation in efforts to maximize acquisition into the program. Statewide labor is PG&E labor only to provide program content and support CPUC executing on their website. Depending upon the timing of CPUC approval of this advice letter, some funds requested for 2019 may be shifted to 2020. Page 4 of 6
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PG&E labor is detailed within a separate budget spreadsheet provided as part of this filing. Vendor costs outlined above (non-PG&E labor/Statewide Website line items) are based on previous tactic costs for Solar Choice and CARE programs (related programs focused on achieving an efficient cost per acquisition.) At this time, PG&E will not be able to provide a line by line cost breakdown for proposed vendor costs. Vendor selection is not determined until after program marketing budgets are approved. 2019-2021 DAC-GT (“Local Green Saver”) Marketing Plan PG&E will support Local Green Saver program enrollment by developing educational materials and Community Based Organization (CBO) outreach targeting potential sponsors. Additionally, PG&E will set aside Marketing, Education and Outreach funds to support sponsor recruitment of customers as well as help facilitate customer and sponsor interaction via website resources to encourage program adoption. PG&E Sponsor Materials/CBO Support includes • PG&E’s website will provide potential sponsors and customers with Local Green Saver program benefits and direct sponsors to resources to get started. • Sponsor Fact sheet highlighting program eligibility, benefits and steps to becoming a sponsor. • CBO support facilitated through PG&E relationships, as noted in the Green Saver section above, will include information on the Local Green Saver program. CBO Sponsor Outreach to Customers PG&E proposes the following approach for allocating the budgeted CBO Sponsor Outreach amount to CBOs who request funding for their outreach to potential customers. PG&E must approve sponsor outreach plans with budget for approved plans to be allocated on a first come, first served basis. To allow fair access to sponsor budget, there is a cap budget per project (details included in budget section below.) Third Party Materials Review PG&E will review sponsor marketing materials before they are used to market to customers. All marketing materials must comply with the following: • • • The California Public Utility Commission's Community Choice Aggregation Code of Conduct, which includes marketing and outreach requirements relative to Community Choice Aggregation. Must be truthful, accurate and not false or misleading. Be in conformance with PG&E’s brand and logo usage guidelines. Timing and Budget Tactics CBO Sponsor Outreach* Year 1 - 2019 $150,000 Year 2 -2020 $225,000 Page 5 of 6
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Fact Sheet $10,000 $5,000 P&GE Labor $24,700 $49,400 Statewide Website $2,375 N/A Total $187,075 $279,400 *Note: Available budget is capped at $15,000 per project. Depending upon the timing of CPUC approval of this advice letter, some funds requested for 2019 may be shifted to 2020. Cost estimates for sponsor outreach must be considered preliminary until more details about the outreach efforts of the sponsor are defined. The cost estimated above assumes small grassroots outreach for 4-5 months per sponsor for approximately 10 projects in 2019 and approximately 15 projects in 2020. PG&E labor Includes time to communicate program to CBO’s encouraging sponsor interest, review sponsor/developer marketing materials and PG&E website page development. Page 6 of 6
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PG&E Gas and Electric Advice Submittal List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Cameron-Daniel, P.C. 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 East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Engineers and Scientists of California 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 Peninsula Clean Energy Pioneer Community Energy Praxair Redwood Coast Energy Authority 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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