8. Marketing and Outreach Modifications40
In D.07-05-047, the Commission established interim guidance for CSI M&O activities. The CSI PAs have been conducting M&O activities on an interim basis in accordance with that decision while the Commission considered an appropriate long-term budget and approach for this element of the program.
To provide a strategic focus to M&O efforts, the CSI Staff Proposal recommended that the CSI general market administrative budget be spent on M&O activities that are designed to: (1) market the solar program and solar technology to consumers and end-users; (2) facilitate the development of a sustainable solar industry through the creation of tools, information, trainings, events that expand or support the solar industry; and (3) facilitate efforts to reduce installed cost of systems (e.g. reducing permitting fees, promoting group discounts, facilitating price competition, streamlining administrative costs, reducing administrative costs to contractors).
The Staff Proposal recommended that the PAs hire a marketing firm to handle statewide activities such as media buys, events and the overall brand. Staff also listed activities that the PAs should conduct as part of their M&O obligations, which would be approved annually via advice letter.
Comments were filed by Joint Solar Parties, CalSEIA and the CSI PAs. All groups expressed support for the goals of providing consumer information, facilitation of a sustainable solar industry, and strategies to reduce solar costs to end-users. The Go Solar California! brand continues to receive the support of all parties, and the parties' comments supported a targeted approach to ensure that the right information is provided to different groups of solar customers and professionals.
The CSI PAs did not support the staff recommendation to hire a marketing firm for a statewide M&O campaign. The PAs contend that each territory has unique needs, and the PAs are in the best position to tailor M&O to these needs. CalSEIA remarked that CSI-Thermal should be marketed alongside the general market program. In contrast, the CSI PAs rejected the staff proposal to file plans for the two programs simultaneously, arguing this would be problematic given the different needs of the programs. CCSE affirmed overall support for integrated marketing, when appropriate, with energy efficiency and demand response programs such as Energy Upgrade and Engage 360. The Joint Solar Parties suggested that activities should focus on developing various consumer and industry best practice guides and solar comparison tools.
The PAs commented on the Energy Division's M&O approval process, suggesting that it should not interfere with timely M&O implementation. They suggest a cost threshold that allows the PAs to spend below the threshold without Commission approval. PG&E disagreed with the advice letter process as the best way to approve plans, stating that potential protests would cause delays in the M&O planning process. The PAs all indicated that the proposed annual filing date of September 30th was inconvenient and that December or January would be a more appropriate time for them to file such plans.
Discussion. We will direct the PAs to continue to conduct the key M&O activities adopted in D.07-05-047, including but not limited the CSI electronic newsletter, monthly free classes for installers, use of the Go Solar California! brand and logo, and maintenance of CSI web site that link to the Go Solar California web site. We will leave to the discretion of the PAs and the Energy Division the many other recommended activities listed in the Staff Proposal, and encourage them to consider the merits of those activities when submitting plans to the Energy Division.
We direct the PAs to file annual M&O plans and budgets via advice letter by December 1st of each year, following the same general approval guidelines currently established by the Energy Division.41
40 See Staff Proposal Sections 5.2, 5.3, 5.5 and 5.6.
41 On April 5, 2011, the Energy Division approved the PAs' 2011 M&O plans, and issued "CSI Approval Procedure, and Energy Division Staff Guidelines, for CSI Marketing and Outreach Activities, Materials and Third-party Sponsorships-Version 1.0."
