19. Evaluation of Outreach and Education Efforts

DRA notes that PG&E has received over $300 million in Customer Outreach and Education costs in the two AMI proceedings, the 2006-2007 GRC and demand response programs for budget years 2002-2008 and 2009-2011, over and above what it is seeking in this case. DRA recommends that, before the Commission authorizes any additional ratepayer funding for this PDP outreach, it establish performance measures. DRA indicates that PG&E's testimony as to how it intends to conduct effective outreach to small commercial and medium C&I customers, is so vague as to be virtually meaningless. DRA states that given the vagueness of PG&E's plans for small commercial customers, measuring the effectiveness of PG&E's Outreach and Education efforts is critical and that performance measures can be used to improve the efficiency and effectiveness of Outreach and Education activities and strategies to help achieve key objectives and ensure that ratepayer money is not wasted.

Therefore, DRA recommends that the Commission order PG&E to retain a reputable, independent impact assessment firm to measure and evaluate PG&E's Outreach efforts, and report on those efforts periodically to its proposed Outreach Advisory Panel and to the Commission. Further, DRA recommends that PG&E be directed to use unspent funds, previously authorized in the AMI case, to pay for the contract with impact assessment firm, and should include the Energy Division in the hiring process to ensure the independence of the evaluator.

At this time, DRA suggests the following goals for the independent impact evaluation firm:

· Representative surveys of a sample of customers who have been targeted by Outreach and Education efforts to measure the effectiveness of the outreach; and

· Assessment of progress towards goals of Outreach and Education activities, i.e., increased understanding of new rates, ability to make informed choices, ability to avoid rate shock.

Under DRA's proposals, the Commission and the Outreach Advisory Panel would receive survey results directly from the impact evaluation firm and provide guidance for changes to PG&E's Outreach and Education effort. DRA indicates that while ratepayer funds need to be spent on this effort, doing so will maximize the effectiveness of how the total budget for Outreach and Education is spent.

PG&E opposes DRA's independent evaluator recommendation. PG&E agrees that measuring and evaluating the awareness levels achieved by outreach are key to any effective marketing plan, especially one built on the principle of continuous improvement. PG&E also agrees that tracking studies and surveys are a critical component of outreach. Nor does PG&E oppose submitting to the Commission periodic reports on customer outreach. However, it appears to PG&E that DRA's recommendation is based largely on its lack of sufficient expertise to evaluate PG&E's outreach plan, not on any failing in the plan itself. PG&E states that is presumably why DRA's recommendation ignores PG&E's foundational research proposal and therefore represents an unnecessary and duplicative expense in the range of $120,000 to $150,000 annually.

PG&E states that it has already built measurement and evaluation into its outreach plans, specifically in the customer research component, and that research will be an important way for PG&E to measure the success of its customer outreach, and make modifications as needed.

Further, for reasons similar to that expressed with respect to funding in Section 11, PG&E asserts that it would not be appropriate, as DRA suggests, to fund an assessment firm from residential outreach dollars approved in the AMI case.

19.1. Discussion

We feel it is important that PG&E is able, in a transparent way, to demonstrate that it will evaluate its outreach and education efforts and, if necessary, that it will modify its efforts appropriately. We agree with DRA's assertion that PG&E has not provided sufficient details on how this would be done. To address this concern, we direct PG&E to issue a request for proposals (RFP) in 2011, in order to engage a third party to conduct an evaluation in 2012 of the effectiveness of customer education and outreach efforts of small and medium customers. PG&E should work with the Demand Response Evaluation and Measurement Committee (DREMC), which will have input into the project design and scope of work for the RFP. The DREMC will also take part in scoring proposals and reviewing the final report. We will additionally impose certain reporting requirements on PG&E to elicit information and to provide a means for parties to express concerns and a means to address any such concerns. PG&E shall:

· File a Tier 3 advice letter within 120 days of this final decision clearly identifying and describing the specific performance measurements, for each of its customer classes, which it will use to determine that its outreach and education campaign is successful. After reviewing any protests and comments, Energy Division will prepare a resolution adopting specific performance measurements;

· Prepare a monthly report to be provided to the Energy Division and posted on a public website. This monthly report should include a breakdown of cost categories and money spent on education and outreach as well as a narrative description that describes the costs. PG&E should work with the Energy Division to design an appropriate format for the reports. Reports should be filed until customer outreach and education activities approved in this decision and the 2011 GRC are completed;

· Provide a semi-annual written progress report to all parties on the service list, which includes foundational research conducted and findings, all outreach activities that have occurred, including number of customers that have received person to person contact, lessons learned from interactions, performance measurements that have or have not been met and if necessary modifications to outreach efforts going forward. The form and content of the report should be coordinated with the Energy Division and should be modified as necessary on an ongoing basis. The first of these reports should be completed and served on all parties no later than June 1, 2010, and reports should continue until six months after customer outreach and education activities approved in this decision and the 2011 GRC are completed;

· Hold quarterly progress report presentations. Two of the meetings shall be with Energy Division, DRA and the Business & Community Outreach group. Two of the meetings shall be in conjunction with the semi-annual written reports and open to all parties on the service list;

· Provide, to the Commission's Business & Community Outreach group, PG&E's schedule of outreach events, at which PG&E staff will be educating customers about PDP and TOU rates. (Events include workshops, industry meetings, and meetings with members of Chambers of Commerce, or other industry or customer segments that may not be represented by Chambers of Commerce, etc.) To the extent possible, PG&E should coordinate such events with the Business & Community Outreach group; and

· After each of the presentations to parties on the service list, provide an addendum to the semi-annual written report to parties on the service list. The addendum shall include a workshop report describing recommendations and issues raised during the presentation, and how PG&E will proceed as a result of the discussions and recommendations.

If the Commission finds, based on the information 1) in the monthly quarterly or semi-annual reports, 2) through the advice letter process, 3) through feedback from the Business & Community Outreach group, or 4) through the formal third party evaluation reviewed by the DREMC that PG&E's methods of education and outreach are failing to satisfactorily educate customers or reach specific market segments that are most at risk, it may be necessary for the Commission to order PG&E to redirect its customer outreach and education efforts and funding. PG&E remains subject to the education and outreach performance criteria established for PDP, and the effectiveness of the utility's education and outreach efforts approved here will be a factor in approving requests for additional funding for customer education and outreach for PDP in future proceedings.

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