5. Testimony of Other Parties

In its pre-settlement testimony, DRA presented the following general conclusions and recommendations in response to PG&E's RCES proposals:

a. PG&E's proposed new bill is larger and more expensive than necessary.

b. No more than $16.3 million should be allowed to fund the RCES effort, with further study culminating in an advice letter with a final proposed bill format.

c. PG&E's Information Technology (IT) cost estimates for individual work packages are high, and its requested 20 percent contingency funding is not justified.

d. The same assumptions underlying PG&E's 2011 GRC Phase 1 decision should apply to RCES cost recovery.

e. A one-way balancing account for RCES costs should be established.

f. RCES costs should be recovered via distribution rates so that all customers using PG&E's services pay a fair share.

TURN also presented pre-settlement testimony with the following recommendations:

a. PG&E should seek the continued and additional input of consumers and consumer representative groups on the appropriate content and formatting used in energy statements. PG&E should be required to demonstrate efforts in a collaborative process prior to acceptance of final designs.

b. PG&E should conduct a feasibility study to consider the use of rate comparison tools to inform customers of potential savings associated with alternative electric rate schedules.

c. RCES cost recovery for Dynamic Pricing including RTP, Peak Time Rebates and Critical Peak Pricing, should be limited to this proceeding.

d. PG&E should ensure greater integration between paper and electronic bills, provide an opt-out for customers seeking a simplified one-page bill, highlight the compounded savings resulting from reduced usage, and provide paper bills in all languages requested by customers.

e. Base labor escalation rates on IT Costs and Customer Outreach and Education Costs should be 2.5% instead of the 3.75% base rate presented in PG&E testimony. Cost savings are estimated at $403,000.

CforAT submitted testimony, arguing that PG&E was failing to adequately meet the needs of customers with disabilities regarding the amount of information provided in large font in both its proposed standard format and its proposed low vision version of the RCES. Deficiencies in the outreach strategies surrounding the RCES, if not corrected, will cause the low vision format of the RCES to be underutilized and will also prevent many customers with disabilities from receiving the full range of educational information that PG&E intends to send out during the transition to the new bill format. This may result in a lower level of understanding of the new bill among disabled customers as compared to the rest of PG&E's customer base.