Details for: 4071-E (Part 1 of 1).pdf

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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

September 9, 2019
(U 338-E)

Information Only Advice Letter -Community Outreach and Public
Awareness Plan for Customer Protections

Pursuant to Ordering Paragraph (OP) 8 of Decision (D.) 19-07-015, Southern California
Edison Company (SCE) hereby submits its plan to raise awareness about the existence
of the emergency customer protections before, during, and after a disaster.
In November 2017 and January 2018, the Commission adopted Resolutions M-4833
and M-4835, which required utility companies to take reasonable and necessary steps
to assist Californians affected by devastating wildfires in Northern and Southern
California. The protections adopted in those Resolutions were designed to ensure that
Californians who experienced housing or financial crises due to disaster did not lose
access to vital utility services and applied only to the specific incidents identified in the
On April 2, 2018, the Commission issued Rulemaking (R.) 18-03-011 to consider
whether to adopt comprehensive post-disaster consumer protection measures for all
utilities under the Commission’s jurisdiction. The Rulemaking sought comments on
whether to adopt the emergency protections ordered in Resolutions M-4833 and M4835 for use by all utilities in the event of disaster in which the Governor issues a state
of emergency proclamation.
On August 20, 2018, the Commission adopted interim measures in Decision (D.)18-08004, which affirmed the provisions of Resolutions M-4833 and M-4835 as temporary
disaster relief protection measures that the utilities were mandated to implement if a
declared emergency occurs.


Resolution M-4833 at pp. 5-8; Resolution M-4835 at pp. 4-8.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4071-E (U 338-E) -2- September 9, 2019 On July 11, 2019, the Commission adopted D. 19-07-015 establishing a statewide approach to support customers with essential utility functions across a range of potential threats and emergencies. In addition to affirming the customer protections laid out in the Resolutions and D.18-08-004, D.19-07-015 (Decision) directs the utilities to 1) continue coordination with Community Choice Aggregators (CCAs); 2) utilize the same cost recovery mechanism; 3) continue coordination with local, state, and federal agencies; 4) establish a plan for public awareness of customer protections; and 5) take proper action post-disaster. In the Decision, the Commission directed the electric and natural gas utilities to set forth a plan for customer outreach of protections in English, Spanish, Chinese (including Cantonese, Mandarin, and other Chinese languages), Tagalog, Vietnamese, Korean, and Russian where those languages are prevalent within the utilities’ service territories.2 OUTREACH PLAN Objective The objective of the customer outreach plan is to raise awareness and inform customers about the existence of the emergency customer protections before, during, and after a disaster occurs. Strategy SCE’s strategy will include a combination of tactics designed to reach all customers and raise awareness about the consumer protections. Tactics will include on-bill messaging, direct mail when appropriate, email, CBO engagement, targeted social media and SCE’s dedicated web page on the website. SCE’s awareness campaign will reach customers through its general awareness before a disaster may occur and will be more targeted during and immediately following a natural disaster event as declaration for a city or county within its service territory. Implementation 1. Community Outreach SCE will take all available steps to raise awareness and engage affected customers on the consumer protections that are available and crucial during periods of recovery when a disaster occurs. To accomplish this, SCE will use various forums, tactics and channels to reach customers annually to inform them about these necessary protections, all which are outlined below. 2 See D.19-07-015, OP8, pp. 67-68.
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ADVICE 4071-E (U 338-E) -3- September 9, 2019 2. Webpages has dedicated webpages for disaster support and emergency preparation at the following addresses: and The image below shows a screenshot of 3. Outbound Emails SCE will review all active (i.e., “in-market”) and planned (i.e., “not-yet-launched”) email campaigns to determine potential for consumer protections/disaster support message integration. For customers who have opted in to receive promotional marketing communications electronically, SCE will engage its agency partners to also provide estimated cost for including dynamic message exclusively on any emails designated for deployment to those opted-in customers in the designated disaster affected zip codes. Based on the severity, scope and number customers affected by the declared disaster, SCE may also elect to send a transactional email which does not require opt-in. SCE will utilize in-house resources to deploy the transactional email at no cost.
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ADVICE 4071-E (U 338-E) -4- September 9, 2019 4. Media Relations Outreach SCE will use targeted communications to various news and online media outlets, write news releases and media advisories as needed. Additionally, SCE will utilize its Energized.edison external website (which features news and stories), write messages and talking points to targeted news outlets. SCE also will have spokespersons available to do interviews for broadcast and online outlets to share relevant messaging with customers and the public. 5. Social Media Posts SCE will use Social Media for both awareness of the consumer protections and to drive customers to sign up for emergency alerts before, during, and after a disaster. During an emergency, SCE will publish messages directing customers to SCE’s website page “” or to SCE’s dedicated representatives in its contact center for those affected by the disaster. After an emergency, SCE will direct customers to its website that will have information on how affected customers can get information on the consumer protections and manage their bills. 6. Outbound Dialing When disasters occur, SCE will utilize its Emergency Outage Notification System (EONS) to send alerts and notifications to customers who may have been affected by the disaster event. The system will send customized messaging regarding SCE’s availability to assist customers who have been affected and will drive customers to “”, SCE’s dedicated disaster support site, or to the contact centers dedicated team of representatives who are available to assist with providing the appropriate consumer protections. 7. Customer Contact Center SCE’s Customer Contact Center (CCC) is open from 6 a.m. – 9 p.m. Monday through Friday, and Saturdays from 8 a.m. to 5 p.m. Before a disaster, a customer can call the CCC to talk with an Energy Advisor about the consumer protections offered, should a disaster strike. During a disaster, the CCC will have a dedicated Customer Support Team to help customers affected by the disaster to let them know of the protections offered, and/or may have questions about their electric service. After a disaster, the CCC will track affected customers in a dedicated database that will track any customer protections activities applicable to the individual customers account. Additionally, this tracking database is used by other departments with an active role in handling activities on customer accounts such as billing and credit departments.
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ADVICE 4071-E (U 338-E) -5- September 9, 2019 8. Community Outreach and Local Assistance Centers SCE is committed to support its customers affected by disasters and provides staffing at the County/City operated Local Assistance Centers (LAC’s). Representatives who staff these events are specially trained on how to interact with customers during challenging times and are there to provide in-person support for their SCE account needs. Customers who visit these locations receive support from SCE in various ways, including ensuring that their account(s) are identified as being affected so the customer protections can be applied. Disaster support team representatives remain at the LAC(s) for the duration of the event. Important to note is that SCE makes the safety of its employees and the public a top priority. Should a disaster occur that would otherwise leave the environment unsafe for SCE resources SCE may enact other tactics to reach its customers until the environment is deemed safe for its employees. 9. Local Governments SCE will work with local governments and distribute the consumer protections to County Offices of Emergency Management (OEM) before, during, and after a declared emergency. Targeted Outreach to Highly Affected Customers In addition to the outreach above, SCE will provide targeted outreach to highly affected customers by: 1. Direct Mail Similar to the outbound emails, SCE will review all active (i.e., “in-market”) and planned (i.e., not-yet-launched”) direct-to-customer campaigns to determine the extent to which supporting marketing communications can be augmented to include messaging that directs customers to to receive information about the consumer protections afforded to them in the event of a declared disaster. Message augmentation may potentially include creation of a free-standing insert that would accompany a marketing campaign’s pre-printed customer letter or materials. The insert would only be included only in those letters where the customer’s service or mailing address is in a designated disaster affected zip code. The historical average cost per piece for a 3.75 x 8.5” free standing, bi-lingual insert is roughly $0.04. Actual cost will vary based on the final quantity of inserts printed. Alternatively, if print production has not yet occurred for a campaign’s customer letter or other materials, SCE can also ask its agency partners to evaluate the feasibility of and incremental cost for including dynamic messaging exclusively on those letters or
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ADVICE 4071-E (U 338-E) -6- September 9, 2019 materials designated for mailing to customers in the disaster affected zip codes. The cost to implement dynamic messaging cannot be projected at this time in absence of obtaining an actual quote from the marketing agency that considers among other things scope, lead time for programming the dynamic message, ease of implementation, and the quantity and format of the communications that will display the dynamic message. SCE will ensure that any free-standing inserts created, or dynamic messaging implemented in support notifying customers about consumer protections are provided in the same languages as the primary direct mail or email communications they should accompany. Depending on the actual marketing campaign, translations (as applicable to the campaign) will mirror those languages currently supported on the website: Spanish, Chinese, Vietnamese and Korean. 2. Bill Onsert Space permitting, SCE will include pre-disaster awareness messaging and the link to the webpage on all residential customer bills using “on-bill” (onsert) messaging. SCE anticipates this proactive, pre-disaster awareness messaging will be implemented on a quarterly basis, consistent with SCE’s current communication cadence for bill onsert messaging. If Legal Notices, or other mandatory customer notifications preclude quarterly implementation, SCE will pre-select two non-contiguous months during the year that consumer protections/disaster relief awareness messaging can be implemented consistently on an annual basis. SCE will utilize internal marketing resources to develop high-level messaging that could be utilized for the bill onsert regardless of the type of disaster declared. As such, no costs are anticipated to be incurred for bill onsert messaging. 3. Community Based Organization (CBO) Engagement SCE partners with a network of over 100 non-profit community and faith-based organizations across its vast service territory to assist customers in enrolling into income qualified programs such as CARE, EAF and ESA. In the event of declared disaster, SCE will immediately mobilize and work with organizations within the affected counties to disseminate disaster relief information to affected customers. SCE will also ensure that each organization is provided with a generous supply of printed inserts so they may easily share SCE’s webpage containing the consumer protections/disaster support information with their constituents who may be seeking assistance.
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ADVICE 4071-E (U 338-E) -7- September 9, 2019 MULTILANGUAGE SUPPORT SCE will provide the consumer protections information in accordance with the language requirements: English, Spanish, Chinese (including Cantonese, Mandarin, and other Chinese languages), Tagalog, and Vietnamese as well as languages are prevalent within SCE’s service territory. TARIFF CHANGES This advice letter will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule, or rule. TIER DESIGNATION Pursuant to OP 8 of D. 19-07-015, this advice letter is submitted with a Tier 1 designation. NOTICE In accordance with General Order (GO) 96-B, General Rule 6.2, this information-only advice letter is not subject to protest. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, R.18-03-011, R.10-02-005, A.14-11-007, R.13-11-005, A.17-01-013 et al, A.16-09-001, and R.15-05-006 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-4039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at For questions, please contact Nicole Holliman at (626) 302-4617 or by electronic email at Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:nh:jm
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 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: 1 Advice Letter (AL) #: 4071-E Subject of AL: Information Only Advice Letter -Community Outreach and Public Awareness Plan for Customer Protections (No protest period) 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 #: Decision 19-07-015 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: No. of tariff sheets: -0- Estimated system annual revenue effect (%): Estimated system average rate effect (%): 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: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 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: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: (415) 929-5515 Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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