18. Outreach Advisory Panel

DRA recognizes that PG&E's plan for Outreach and Education is subject to change because PG&E has not yet performed the foundational research necessary to determine how to best reach different customer segments effectively. However, as to Customer Outreach and Education to small commercial customers, DRA states that it does not seem that PG&E has any specific plan to most effectively use the ratepayer funding it seeks. For example, DRA suggests that PG&E could do more to make use of the Internet for communicating with small customers.

DRA states that the Commission should be concerned about the vagueness of PG&E's plans for Customer Outreach and Education to its small commercial customers noting that if PG&E's Customer Outreach and Education program for small commercial customers is inadequate, many of them will begin receiving bills that are higher and less predictable than before, and for reasons they do not fully understand. This, in turn, could undermine the success of the Commission's dynamic pricing initiative.

To assist PG&E in providing effective outreach to the small commercial business community, DRA recommends that the Commission direct PG&E to establish an Outreach Advisory Panel. The goal of the Outreach Advisory Panel would be to monitor and evaluate the effectiveness of PG&E's Outreach and Education programs on an ongoing basis. DRA states that it can include participants from consumer groups, Chambers of Commerce, Energy Division, local small business organizations, intervener groups representing small businesses, and nonprofit community-based organizations which represent small business customers.

Under DRA's proposal, the Outreach Advisory Panel would be provided the opportunity to make recommendations for improvements before PG&E launches its Outreach and Education efforts for small commercial customers and to recommend changes to the Outreach and Education effort on an ongoing basis; the costs for the Outreach Advisory Panel would be met from the unspent marketing and customer costs PG&E has received in the AMI proceedings; and the burden of using the Outreach and Education dollars in a manner which is most beneficial to the customer would be on PG&E.

PG&E opposes DRA's Advisory Panel recommendation. While PG&E agrees that soliciting input from a wide spectrum of sources can increase the relevance and effectiveness of outreach, and appreciates the particular outreach challenges presented by small business customers, PG&E asserts that its outreach plans already address those challenges. For example, incremental Dynamic Pricing Specialists added to meet the needs of defaulting large customers will be retained and new Specialists and Account Managers hired during the rollout of dynamic pricing to smaller customers. A total of 40 incremental Specialists and 21 incremental Account Managers will be available to assist smaller business customers, especially those who could be adversely impacted by PDP were they not to take action to change their energy usage. PG&E argues that by interacting with various types of small business customers, these representatives will be able to provide a valuable feedback on how the program can be made more relevant and effective as the outreach continues over a two-year period. Moreover, engaging with relevant groups is already part of PG&E's outreach planning. For example, PG&E's customer workshops will entail partnering with industry and community groups, and PG&E will be engaging with various groups through pilot studies and customer interviews that have already begun.

PG&E state that it is concerned that pre-approval of outreach and educational materials for small commercial customers by an Advisory Panel (Panel) would delay development of materials and increase the amount of time necessary to implement outreach campaigns. Also, it is unclear what such a specialized Panel would contribute and thus difficult to justify the time and money involved. Other concerns relate to unknown specifics of DRA's proposal including the number of Panel members, how they would be selected, exactly whom they would represent, how the Panel would be governed, exactly what it would review, how often it would meet, and what costs would be involved. Also, for reasons it already addressed with respect to incremental funding, PG&E states that it would not be appropriate, as DRA suggests, to fund such a Panel from residential outreach dollars approved in the AMI case.

PG&E notes that the main example of the specificity that DRA contends is lacking in PG&E's plan is with respect to use of the Internet. PG&E assumes that a high percentage of small and medium customers do have access to the Internet and states that one of the many things it already plans to do is DRA's suggestion that PG&E include in every mailing a request that the customer provide an e-mail address.

18.1. Discussion

PG&E's concern that pre-approval of outreach and educational materials might result in delay is valid. Also, there appear to be certain aspects of PG&E's planned efforts, such as customer workshops and partnering with industry and community groups, which would duplicate what an advisory panel might accomplish. For these reasons, we will not adopt DRA's Outreach Advisory Panel proposal. Instead, PG&E shall work with Energy Division and the Business & Community Outreach group and develop a written customer education and outreach plan. The utility shall post the plan to the service list within 60 days of the final decision. PG&E shall provide parties to the proceeding the opportunity to provide comments and feedback on the plan. PG&E must include the plan and may include revisions based on feedback from parties in the advice letter described in Section 19.1. The plan shall be submitted with the advice letter for informational purposes only and the utility may begin implementing the plan prior to a resolution on the advice letter. The plan shall include:

· Education goals the utility expects to have achieved with customers by the time they reach their default date;

· A list of monthly timelines for activities, the types of activities that will be conducted (i.e., mailings, emails, calls, workshops, meetings with business or agricultural leaders or organizations), as well as the geographic area, customer groups, and market segments that will be that will be targeted, including ethnic and traditionally "hard to reach" customers;

· The methods that will be used to directly educate the 10% of small and medium customers whose bills are likely to be increased by the largest percentage based on previous year's usage if they stay on the PDP rate;

· A description of how customers will be educated about the tools and programs available to enable them to reduce energy consumption when a peak event is called, including energy efficiency and distributed generation and storage (effort should be made to coordinate this approach with other integrated marketing approaches); and

· A summary of other outreach and education plans, models or strategies around the country that PG&E can incorporate into its proposal to increase the number of small and medium customers that experience person to person interactions.

The Director of the Energy Division may direct the utility to make additions to the plan if necessary.

In order to help facilitate input from the smaller customers, business groups, and community groups, we will require that PG&E work with the Commission's Business & Community Outreach group to determine how the group can assist PG&E in outreach efforts to small and medium customers. The Business & Community Outreach group can be a resource in raising PDP awareness and also ensuring the Commission policy is being implemented effectively. In order to best support the utilities' outreach efforts, the Business & Community Outreach group may request information such as results from PG&E's consumer research or information from customer databases (e.g., contact information for small and medium customers; meter status; planned outreach efforts and pilot programs; percent defaulting to PDP versus opting-out; and number and nature of complaints or inquiries about PDP and TOU rates). To the extent that the Business & Community Outreach group participates in this process, we expect that it will keep the Energy Division informed of its activities and evaluations of the ongoing process.

Also, we will require PG&E to hold quarterly meetings (see Section 19.1). These meetings will provide opportunities for parties and the public to provide ongoing input into PG&E's outreach plans.