Interim Marketing and Outreach Plans

Given the general agreement on the need for interim CSI marketing and outreach activities, this decision directs the program administrators to submit proposed interim marketing and outreach plans by letter to the Director of the Energy Division, with a copy sent to all parties on the service list of this rulemaking. A more detailed description of the contents of the interim marketing and outreach plans and the approval process is set forth in Appendix A to this order.

We will not require the program administrators to file these proposals as formal Advice Letters, as initially proposed in the assigned Commissioner Ruling, because Advice Letters are filed only by utilities. SDREO is not a utility. Thus, we find it more appropriate for the three program administrators to submit their proposals via a business letter to the Director of the Energy Division, with a copy to the service list of this rulemaking. This will allow parties the opportunity to provide Energy Division with comments on the interim plans.

Based on additional comments by the parties, we provide several clarifications regarding the interim marketing and outreach plans and approval process.

First, the program administrators expressed concern that they would not be able to submit all marketing and collateral materials, such as brochures, fact sheets, and customer education kits, within 10 days of this order. PG&E suggests it needs time to conduct targeted market research. SCE requests the Commission provide guidelines for CSI messages. We agree that 10 days is a very short timeframe. Nevertheless, our intent is for the program administrators to implement basic marketing and outreach of general program information at this time. The Commission can provide more detailed guidance on CSI marketing messages, and allow a larger budget for detailed market research, after it has considered marketing issues with greater depth at a later point in this proceeding. Therefore, this decision clarifies that the program administrators should file a general marketing and outreach plan and budget within 20 days of this order, and that specific collateral materials do not need to be included with the plan. Instead, after each program administrator's plan is approved by Energy Division, the program administrator should submit collateral materials such as bill inserts as they are developed directly to the Energy Division for staff review and approval, in consultation with the assigned Commissioner. Energy Division will work informally with each program administrator to review and approve all collateral materials. We delegate to the Energy Division and assigned Commissioner to review final versions of all collateral materials before they are issued. The parties may provide input on the overall interim plans, but we limit review of all collateral materials to Energy Division and the assigned Commissioner for efficiency.

Second, SCE suggests it intends to market CSI jointly with its energy efficiency programs. ASPv objects to this idea and contends that CSI needs to be marketed independently, at least initially. In our view, it is reasonable to allow the CSI program administrators the flexibility to jointly market CSI with energy efficiency programs. By this decision, we will allow SCE and all program administrators to conduct interim CSI marketing and outreach jointly with energy efficiency as long as they create a method for tracking and allocating marketing costs between energy efficiency and CSI, and adhere to this tracking methodology. This tracking methodology should be included in each program administrators' interim marketing proposal. It is important for the Commission to separately account for all funds spent on CSI and energy efficiency activities.

Third, the ruling proposed two bill inserts in 2007 to promote CSI. PG&E suggests one insert in 2007, and a second in the first quarter of 2008. We agree with this suggestion and modify the interim plan accordingly. SDG&E contends the bill insert requirement is problematic because issues concerning access to utility billing envelopes, responsibility for the content of the insert, and costs of the insert and mailing have not been addressed. SDG&E states that its bill envelope space in 2007 "may be full" and an additional insert requirement could cause SDG&E to incur added postage. After the proposed decision was circulated, SDG&E provided further legal argument that its billing envelope is utility property and it cannot be compelled to use such property to further the interest of a third party, namely SDREO. To avoid delay of CSI interim marketing activities, at this time we will require only PG&E and SCE to use bill inserts for interim CSI marketing. SDREO should consider independent mailings or other marketing options, in lieu of a bill insert, and propose these other activities as part of its interim plan.

Fourth, SCE asks for an interim marketing budget of more than $500,000 in recognition of its higher overall administrative budget. We will not grant SCE's request to enlarge its interim marketing budget because we assume costs for basic marketing materials are likely to be similar across service territories and because the interim marketing activities we approve by this order are more limited than the PG&E and SCE proposals. As we have already stated, our intent is to allow each program administrator to perform preliminary marketing, focusing on basic program information and training for installers. We will grant SCE's request for a process to request additional interim marketing funds. Program administrators may ask Energy Division for approval to spend up to 20% more than $500,000 for interim marketing, or $100,000. SDG&E suggests separate invoicing of SDREO's interim marketing expenses with supporting documentation. SDREO responds that it is amenable to this approach. We approve SDG&E's recommendation for SDREO to separately invoice its marketing expenses.

Fifth, SDG&E is concerned that any installer training should include discussion of utility interconnection requirements. SDREO agrees that this topic is important. It states it will continue to invite SDG&E to make presentations on this topic at solar training sessions in its region. We agree this topic is important, and we encourage SDREO to continue to invite SDG&E's participation at training sessions. We agree with SDREO that both SDG&E and SDREO must have a consistent message with regard to utility interconnection, and continued cooperation and communication between the two entities is of paramount importance to the success of CSI.

SDG&E contends it will need reimbursement for costs it incurs to send interconnection personnel to SDREO's installer training. SDREO responds that if interconnection personnel at other utilities charge for their CSI-related training time, then the same standard should apply to SDREO. The Commission has previously rejected SDG&E's requests for the utility to receive additional funds to provide SDREO with interconnection and other utility expertise, noting that "[u]tility program administrators receive internal technical support; SDREO must receive similar treatment." (D.04-12-045, p. 20.) We uphold that conclusion here, and we further direct that SDG&E may charge SDREO only if utility interconnection personnel in other regions charge for their time.

Finally, SCE requests clarification of expense reporting requirements regarding interim marketing activities. We herein clarify that the program administrators should submit semi-annual expense reports regarding CSI administrative expenses incurred to date. These semi-annual reports should list interim marketing costs separately from other administrative expenses. The first report is due on July 15, 2007 to the Director of the Energy Division, and further reports are due every six months thereafter. In keeping with D.06-08-024, the program administrators may spend no more than 5% of budgeted CSI funds on administration, and by this order, an additional $500,000 for interim marketing, unless Energy Division approves additional marketing funds of no more than $100,000.