Details for: 4431-E (Part 1 of 1).pdf

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

February 26, 2021
(U 338-E)

Southern California Edison Company’s Charge Ready 2 Plan
to Cobrand with Community Choice Aggregators and
Implementation Plan to Allow City of Lancaster to Own &
Operate Electric Vehicle Service Equipment on Behalf of Their

In compliance with Decision (D.) 20-08-045, Ordering Paragraph (OP) 33, Southern
California Edison Company (SCE) hereby submits this Advice Letter (AL) to provide
SCE’s plan to incorporate cobranding and competitively neutral marketing, and to
provide SCE and the City of Lancaster’s (Lancaster) implementation plan for allowing
Lancaster to own charging stations on behalf of its customers.
On August 27, 2020, the California Public Utilities Commission (Commission or CPUC)
issued D.20-08-045 (Decision), which was adopted on September 2, 2020, authorizing
SCE’s Charge Ready 2 (CR2) Infrastructure and Market Education programs. The
approved funding includes support for EV charging infrastructure, rebates, marketing,
education and outreach, and an evaluation of CR2 programs.
OP 33 requires that “[w]ithin 180 days of the date of adoption of the decision, Southern
California Edison Company (SCE) shall file a Tier 2 Advice Letter with the
Commission’s Energy Division, that at a minimum addresses: (1) SCE’s plan to
incorporate cobranding and competitively neutral marketing; and (2) SCE and
Lancaster’s implementation plan to allow Lancaster to own charging stations on behalf
of its customers, at no additional subsidy level to the program.”1


Decision, OP 33, p. 152.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4431-E (U 338-E) -2- February 26, 2021 DISCUSSION In compliance with OP 33, SCE submits this AL to provide (1) SCE’s plans for cobranding and conducting competitively neutral marketing specific to SCE’s Charge Ready 2 program, and (2) SCE’s joint implementation plan with Lancaster to allow the city to own charging stations on behalf of its customers, at no additional subsidy level to the program. 1. SCE’s Plan for Co-Branded and Competitively Neutral Marketing This plan serves as a basic framework for SCE and any Community Choice Aggregators (CCA(s)) within the shared territory that desire to collaborate on cobranded and competitively neutral marketing, education, and outreach to promote SCE’s CR2 program. Developed in consultation with Lancaster, this framework establishes (1) guiding principles, the critical foundation of our interrelationship, designed to provide structure and understanding of expected behavior and decision making, and (2) an activation planning process along with points of integration. a) Guiding Principles Utilizing the following guiding principles, SCE and the CCA(s) will develop and deploy co-branded and competitively neutral marketing for CR2 with clarity and understanding, and in a manner that enhances efficiency: • CUSTOMER FOCUS: The co-branded CR2 marketing, education, and outreach developed by SCE and the CCA(s) serve the best interests of the customer. • MUTUAL RESPECT: The relationship between SCE and the CCA(s) is characterized by mutual trust, respect, and commitment. • NEUTRALITY: CR2 marketing, education, and outreach will be competitively neutral and not advantage or favor one entity over another. • CONTINUOUS IMPROVEMENT: SCE and the CCA(s) will share feedback with the goal of continuously improving the relationship and the CR2 marketing outcomes. • PARTNERSHIP: Principles and processes for the relationship are established with the input and agreement of both SCE and the CCA(s), especially for decision-making and conflict resolution. • COST EFFECTIVENESS: As stewards of customer funds, cost efficiency is a priority and an important consideration throughout the production process; creative and copy approvals should be limited to factual accuracy rather than stylistic components such as imagery and tone due to the subjective nature of marketing communications and the need to balance and maintain version control and cost efficiency given the volume of CCAs
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ADVICE 4431-E (U 338-E) -3- February 26, 2021 within SCE’s territory. • TRANSPARENCY: SCE and the CCA(s) make clear and open communication an ongoing priority by striving to understand each other’s needs and self-interests. b) Activation Planning Process & Critical Points of Integration The activation planning process is based on a standard campaign development structure to identify critical points for successful integration from planning through production and delivery. This approach will help optimize the partnership and ensure that both SCE and the CCA(s) have opportunity to protect their brands and secure competitively neutral communications. SCE will proactively engage with the CCA(s) who have expressed an interest in cobranding with SCE on the CR2 marketing, education, and outreach materials. As detailed in Graphic 1, below, SCE will collaborate with the CCA(s) throughout the planning process on critical points of integration, which include: 1. Logo and Legal Requirements Phase: SCE will consult with the CCA(s) about logo usage guidelines and legal requirements. Key Milestone: SCE and CCA(s) participate in an informal sync-up in late Q1. 2. Planning Phase: SCE outlines its CR2 marketing plans for the year with overview of business marketing & communication tactics and goals. Key Milestone: Late Q1 or early Q2, SCE shares its plans with CCA(s) with the objective to identify opportunities for integration and co-branding. 3. Focused Creative Brief Phase: SCE initiates development of the tactical elements of the campaign by completing the creative brief which outlines the objective, target audience and consumer insights, the desired response and main message to consumer market to respond positively. Key Milestone: SCE shares the brief with CCA(s) to gauge interest in integration or co-branding. 4. Concept Development Phase: SCE and its agency develop layout and copy of the creative asset(s). Key Milestone: SCE presents to the CCA(s) the preferred concept and copy and solicits their input, comments and / or approvals. 5. Production Phase: SCE and its agency release artwork for creative production / printing. Key Milestone: SCE collaborates with CCA(s) for delivery of creative assets, samples, etc. Post-production, SCE and the CCAs will reconvene formally or informally to assess what worked, determine what could be improved, and identify best practices in the spirit of continuous improvement and to streamline and enhance future collaborations.
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ADVICE 4431-E (U 338-E) -4- February 26, 2021 Graphic 1: Campaign Development Approach 2. SCE’s and Lancaster’s implementation plan to allow Lancaster to own charging stations on behalf of its customers, at no additional subsidy level to the program. SCE and Lancaster have developed an approach that will facilitate Lancaster’s ability to own and operate EVSEs on behalf of their interested business customers through participation in the CR2 Make-Ready Expansion Program or Low Port Rebate. Lancaster is pursuing the opportunity to expedite the expansion of EV infrastructure by working directly with local businesses to assist with installing EV charging equipment. More than 30 businesses have expressed interest in partnering with Lancaster and allowing them to host charging stations at their business site. This approach, which will not result in any additional subsidy levels to the program, is further described below. a) • Participation in the Charge Ready 2 Make-Ready Expansion Program Lancaster will be able to participate in the CR2 Make-Ready Expansion Program on behalf of interested and qualifying non-residential customers located in the city.
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ADVICE 4431-E (U 338-E) -5- February 26, 2021 • Lancaster will complete the application to participate in the program and act as the customer participant (also sometimes referred to as “site-host”) for a participating site. SCE requested and received a single point of contact (SPOC) for Lancaster relating to site specific enrollment and program participation related activities. Lancaster has initially designated the Innovation and Economic Development Manager will fulfill that role. • SCE will evaluate the application through the routine screening process. If the site is approved for participation in the program, Lancaster will be presented with a program participation agreement for signature. After signing, Lancaster will initiate the EVSE acquisition/installation process. Lancaster will also determine, manage, and administer any additional agreements that may be developed and executed between Lancaster and the end-use site customer. SCE will not be party to any city administered program agreements. • SCE will coordinate all site and construction related activity directly with Lancaster. Lancaster has initially designated its Capital Construction Manager and Projects Coordinator as SPOCs for the program. Lancaster will coordinate any related activities directly with the site customer/owner. • All other program processes would remain the same, with Lancaster serving as the program participant/site-host for a given site as it relates to ALL project phases before, during and following EVSE installation. • Lancaster will be responsible for applying for any related rebates and providing the necessary documentation as required by the program for SCE to process rebate payments. • Lancaster will be the customer of record for the EVSE meter located at the site, meaning that Lancaster will be designated as the Service Account holder and be responsible for all related Service Account billing and payments. • Lancaster will be responsible for operating and maintaining the EVSE for the full 10-year duration, along with complying with other program related requirements as will be outlined in the program tariff, the program participation agreement, and other program guidelines. b) Low Port Rebate • Lancaster will be able to participate in the low port rebate on behalf of interested non-residential customers located in the city. • Lancaster will be responsible for applying for the Low Port Rebate, and for providing the necessary documentation as required for SCE to process any rebate payments.
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ADVICE 4431-E (U 338-E) • -6- February 26, 2021 Lancaster will be responsible for ensuring the operation and maintenance of the EVSE for a full 10-year duration, along with complying with other requirements as outlined in the program tariff and other related program guidelines. TIER DESIGNATION Pursuant to Ordering Paragraph 33 of (D.) 20-08-045 this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice letter will become effective, March 28,2021, the 30th calendar day after the date of submittal. NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail:
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ADVICE 4431-E (U 338-E) -7- February 26, 2021 Tara S. Kaushik Managing Director, Regulatory Relations c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. 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, A.18-06-015, and A.18-07-020 et al 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 Melodee Black at (626) 302-4728 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:mb: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: Advice Letter (AL) #: Subject of AL: 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 #: 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: Title: Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: 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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