5. Co-Branding
In 2009, under the direction and guidance of the Commission staff, the utilities assessed the Statewide Marketing Education & Outreach (SW ME&O) program brand known as Flex Your Power (FYP). The assessment resulted in the creation of a new statewide "smart energy living" brand, called Engage 360, encompassing energy efficiency, demand response, and the flexibility to possibly include other demand side management options at a later date. D.09-09-047,
OP 34 (sixth bullet point), directed the utilities to "use the brand alone or in a co-branded capacity across all energy efficiency marketing efforts for all programs."
While Joint IOUs state that they fully support the use of the new Engage 360 brand, Joint IOUs seek to modify D.09-09-047 regarding co-branding in order to minimize confusion in the marketplace regarding whom a given communication is from. Joint IOUs argue that the decision requires an IOU to develop marketing collateral for any Energy Efficiency program with an IOU logo alongside the new statewide brand, but this requirement is not always appropriate.
There are several instances that Joint IOUs request modification of the
co-branding requirements:
· Joint IOUs seek flexibility to approve any co-branded material prior to its publication. For example, in any instance where an IOU does not approve the use of its logo in co-branded material, the statewide ME&O Program should use only the new ME&O brand.
· For all other statewide programs, Joint IOUs request the opportunity to approve the use of their brand in any co-branding material prior to its publication. In the event that an IOU does not approve, only the utility logo should be used.
· Joint IOUs propose several exceptions to the co-branding requirement where they propose only an IOU logo should be used:
· Any program not funded by energy efficiency funds;
· Campaigns and collateral that bundle energy efficiency and non- energy efficiency programs;
· Advertising solely funded by IOU shareholder funding and used at discretion of IOU; and
· Energy efficiency local and third-party program-specific marketing funded by energy efficiency funds.
Finally, in order to support the introduction and evolution of the new brand, Joint IOUs propose that co-branding of Engage 360 with IOU brands begin in conjunction with the launch of the mass media phase of the ME&O campaign and after awareness of the new Engage 360 brand is established. These co-branding efforts should begin at the determined threshold according to above guidelines and should preserve IOU ownership of the use of their respective corporate brands.
DRA/TURN urge the Commission to reject the request for "unfettered unilateral discretion" to determine when to use the Engage 360 brand. They argue that such discretion would be inconsistent with the Commission's intent that the new brand be used as directed by D.09-09-047 in OP 34. DRA/TURN contend that allowing the IOUs to decide when to use (or not to use) the brand would undermine the goal of providing clear, consistent information about energy efficiency and ways that Californians can reduce their energy use and greenhouse gas emissions.
At the October 22, 2010 PHC, Cope representing Joint Utilities stated that the IOUs did not seek the flexibility to unilaterally say when they would and would not use the Engage 360 brand, but instead to have some discretion as to when to use it on local programs. For example, Cope cited the current local governmental energy efficiency partnership pilot program with the City of
Palm Desert as a situation where there could be confusion between Engage 360 and a local brand. On all statewide programs, he stated that Engage 360 would be used. RT 288-290.
The intent of D.09-09-047 regarding co-branding is clear: the utilities are to "use the brand alone or in a co-branded capacity across all energy efficiency marketing efforts for all programs." The context of this requirement is stated as follows in D.09-09-047 at 236 (footnotes not in original):
We agree with the parties' comments to have the brand scope include all IDSM6 (including low-income) and renewable self generation options. However, we will use the market research studies to determine the most effective pragmatic approach to launch and evolve the scope of the brand beyond energy efficiency/conservation.
We direct the utilities, working under the direction of Energy Division, to complete the brand assessment studies and to implement the recommendations of that study in compliance with the direction provided herein and consistent with the Strategic Plan.7
The utilities state that they intend to use the Engage 360 brand on all statewide energy efficiency programs, as intended by D.09-09-047. There is no need to modify the decision on this point to allow utility pre-approval or veto. Joint Utilities provide little justification for exceptions to D.09-09-047 for other programs funded by energy efficiency funds, other than vague assertions of potential confusion. As there is no evidence of actual or likely confusion, we will not grant this request.
We will deny the Joint Utilities' Petition on this topic on all but one point. We will modify D.09-09-047 in one respect. There may be some IOU energy efficiency programs not funded by energy efficiency funds in 2010-2012 (although no specifics were given by Joint Utilities). In such cases, the requirements of D.09-09-047 are not binding. We will modify D.09-09-047 to make this clarification.
On a related issue regarding co-branding, the Joint Utilities claim it is essential to introduce co-branding in a phased approach that aligns with the marketing plan for the brand. The marketing plan was developed by DraftFCB, as shown in Attachment A to the Joint Utilities' November 15, 2010 filing (filed by SCE).
A key component of DraftFCB's strategic approach for brand implementation is to introduce this brand through a "grassroots movement," rather than initially launching it via a more traditional mass media campaign. In the initial phases of the groundswell movement that DraftFCB will build, Engage 360 will rely on Ambassadors and Leaders to personally carry its message. Later phases planned for the first quarter of 2012 will focus on transmitting the message through traditional mass media, after brand recognition and understanding of the brand have been established. As such, DraftFCB has recommended that co-branding with the IOUs be delayed until this time.
This request is reasonable and will be approved.
6 IDSM stands for integrated demand side management.
7 The completed brand assessment study can be found at: http://www.cpuc.ca.gov/NR/rdonlyres/93CB5008-7AED-4BB3-A940-138B84824FA9/0/SWMEO_Brand_Assessment_Report.pdf.
