13. Marketing, Education, and Outreach

California has one statewide education and awareness program focused on demand response, which is called Flex Alert or the Statewide Demand Response Awareness Campaign (formerly referred to as Flex Your Power Now). Through the use of mass media such as TV commercials, radio advertisements, billboards, newspapers, and other communication avenues, Flex Alert is intended to educate the general public about the need to reduce electricity during times of peak electricity demand.

PG&E proposes to continue its Flex Alert program in 2009-2011, and requests a total of $6,405,000 for this campaign. SCE forecasts expenditures under this program of $4,947,991for 2009-2011, and SDG&E requests a total of $1,250,000 for its Flex Alert campaign. 

TURN asserts that it is irrational to spend money educating customers and conducting marketing for programs when those programs may change dramatically once demand response can be bid into the CAISO's new markets as Proxy Demand Resource or Participating Load. TURN recommends the utilities focus on the transition into the CAISO's new markets instead of on marketing existing demand response activities.¹¹⁰

SF Power objects to several elements of PG&E's marketing, education, and outreach funding requests. SF Power suggests that "funding associated with demand-response marketing, education, and outreach should be limited to supporting broadcast alerts during specific periods in which electricity demand is straining the grid."¹¹¹ SF Power also recommends that the utilities should pay financial incentives to nonprofits and other third parties to enroll participants in demand response programs. The Commission has endorsed outreach by community based organizations (CBOs) in other areas of demand side management (notably, in outreach for Low Income Energy Efficiency activities, and in workforce training for general energy efficiency), but has not yet adopted a policy on the use of CBO outreach for demand response. We decline to adopt this SF Power recommendation; as PG&E notes, there is insufficient information in the record of this proceeding to support this request. We are open to examining party proposals for expanding CBO and non-profit outreach for demand response in a future proceeding, consistent with our existing policy for energy efficiency activities. 

It is reasonable to continue the Flex Alert Campaign in its current form at the requested funding levels pending final recommendations of the California Energy Efficiency Strategic Plan on coordination of statewide marketing, education, and outreach efforts. The Strategic Plan required a brand assessment of the closely related, Flex Your Power brand, with pending recommendations that may have an impact on the Flex Alert brand. Therefore it may be appropriate to reevaluate the structure and funding of this program before the end of the 2009-2011 period. We adopt the following budgets for the Flex Alert Program:

	2009-2011 Requested Budget	2009-2011 Authorized Budget
PG&E Flex Alert	$6,405,000	$6,405,000
SDG&E Flex Alert	$1,253,886	$1,253,886
SCE Flex Alert	$4,947,991	$4,947,991

In some cases, the utilities have also requested funding for marketing and outreach as part of the budget of specific programs. In many cases, we authorize some marketing funds as part of program specific budgets in order to maintain enrollment during 2009-2011, but we expect the utilities to move towards more coordinated marketing, education, and outreach, and reduce or eliminate such program-specific budget requests for the 2012-2014 period.

In addition to the statewide Flex Alert Campaign, the utilities request funding for several utility-specific marketing programs, including PG&E's DR Core Marketing and Outreach program, and SCE's Circuit Savers, Agriculture and Water Outreach, Federal Power Reserve Partnership, Energy Leaders Partnership, Income Qualified Customers Outreach Pilot and Integrated Demand-Side Management Marketing. SDG&E proposes a Customer Outreach, Education, and Awareness program, and a Demand Response Emerging Technologies program. PG&E requests $10,707,000 for its specialized marketing programs, SDG&E requests $6,943,857, and SCE requests $14,329,454 for these programs.¹¹² TURN objects to the utilities' specialized marketing budgets, arguing that much of the funding requested by PG&E will provide a "slush fund" for activities that do little more than generate public relations benefits for the utilities.¹¹³ TURN reiterates its objection to these programs in its comments on the proposed decision, suggesting that based on historical recorded spending and other factors, funding for the SCE Federal Reserves Partnership should be reduced from $1.65 million to $81,000, and the budget for SCE's Energy Leadership Program budget should be reduced from $2.605 million to $692,000.¹¹⁴

These programs should be reviewed in the context of the utilities' energy efficiency application proceedings, in order to facilitate coordination among demand-side management activities. However, despite the increase in budget requests from historical spending levels, the increased budget requests for specialized marketing and education activities appear to be consistent with the expected general expansion of price responsive demand response and dynamic pricing activities. We approve the utilities' requested funding for these programs. We direct the utilities to coordinate these specialized marketing, education, and outreach activities with similar activities conducted with funding from energy efficiency and other demand-side management programs.   In addition, when marketing, education, and outreach funding for demand response programs are being decided, we encourage outreach to underserved communities via non-profit organizations and community-based organizations. We approve the requested budgets, as follows:

	2009-2011 Requested Budget	2009-2011 Authorized Budget
PG&E Core Marketing and Outreach	$10,707,000	$10,707,000
SD&E Customer Education, Awareness, and Outreach	$6,943,854	$6,943,854
SCE Specialized Marketing Programs	$9,381,464	$9,381,464

The activities and budgets for specialized marketing approved here may be reviewed and revised, if appropriate, in A.08-07-021, et al.

¹¹⁰ TURN Opening Brief, p. 10.

¹¹¹ SF Power Opening Brief, pp. 2-3.

¹¹² SCE Exhibit 1, pp. 66-84.

¹¹³ TURN Opening Brief, p. 2.

¹¹⁴ Opening Comments of the Utility Reform Network on the Proposed Decision of ALJ Hecht, p. 10.