6. General Terms of the RCES Settlement
The RCES settlement resolves all outstanding disputes among the active parties, and provides that PG&E will submit the final versions of its RCES for Commission approval by advice letter. The Settling Parties agree on the following goals for RCES to (a) meet all legislative and regulatory requirements, (b) make the customer bill clear and easy to understand, with improved accessibility, and (c) provide customers with information that allows them to make informed energy decisions. Settling Parties agree on the following points:
1. PG&E's current Energy Statement satisfies most, but not all, statutory and regulatory requirements. The Energy Statement should be revised to comply with all statutory and regulatory requirements and to make it easier for customers to understand.
2. The amount of approved costs for the RCES project will affect the types and extent of changes that can be made to the Energy Statement, as well as the types and level of supporting activity associated with rolling out the revised Energy Statement to customers.
3. RCES project costs should be kept at a reasonable level, with recovery limited only to actually incurred costs up to the amount authorized by the Commission.
6.1. Scope of RCES Design Changes
PG&E's pre-settlement proposal for the scope of RCES bill redesign changes were described in its testimony.4 Examples of what PG&E proposed to be covered in the redesign included additional in-language bill versions, the daily usage bar chart (see figure 3-1 in PG&E-17), changes to show Direct Access/Community Choice Aggregation customers the rate components they pay to PG&E, inclusion of beginning and end of period meter reads, and implementation of a one-page bill. Settling Parties acknowledge that limiting RCES cost recovery to $19.012 million will mean fewer changes to the customer energy statement than were described in PG&E's pre-settlement testimony.
Settling Parties agree that PG&E will implement the following specific changes to its Customer Energy Statement to meet legislative requirements:
1. A graphic representation of cost-per-tier for gas and electric.
2. A clear definition of baseline.
3. Presentation of the TTY number5 as prominently as the main customer service number, and presentation of key information in large print.
D.07-07-047, Ordering Paragraph 10, provides that PG&E is to file an advice letter for approval of all changes to its bills that go beyond changes that would be considered cosmetic or superficial. Under the terms of the settlement, PG&E agrees to submit the final version of its RCES by advice letter. The advice letter is to include demographics of PG&E's service territory and how they respond to languages used in PG&E bills and inserts. The advice letter is to reference PG&E's commitment (a) to implement website accessibility for disabled customers consistent with the 2011 GRC Phase 1 settlement between Disability Rights Advocates and PG&E and (b) to comply with Priorities 1 and 2 of Version 2.0 of the Web Content Accessibility Guidelines.
Settling Parties agree that additional research is needed regarding customer preferences for various proposed revisions in the elements of the customer energy statement. PG&E held a workshop with interested parties to share results of its research on customer preferences and to receive additional input. In Settlement meetings and the research workshop, PG&E shared its plan for accomplishing redesign of the customer energy statement, including plans to use large 14-point sans serif font for the following items on the standard bill:
PG&E website URL
Customer account number
Amount owed by customer
Bill due date
Customer service phone numbers
(including English, with notation indicating that relay calls are
accepted, and a TDD/TTY phone number for accessing specialized
equipment for the hearing impaired.)
PG&E will use the large font also for the customer name and address unless the targeted low-vision focus group and quantitative research provides feedback indicating that a font size smaller than 14 point is more appropriate for this information. PG&E and CforAT agree to work together to ensure that feedback on the need for large print customer name and address is elicited appropriately at the targeted low-vision focus group.
In addition to its existing optional Braille bill, PG&E agrees to make available a new, optional "low-vision" bill that will not exceed two sheets of paper (four sides). The low-vision bill will include in large print, in addition to the large print information from the standard bill, all "Account Summary" information, all important phone numbers, a customer service email address (info@pge.com), the first two paragraphs of information under the heading "Rules and Rates," and additional detail regarding customer energy charges. The specific detailed information to be included will be based on the feedback received from the targeted low-vision focus group.
PG&E and CforAT agree to continue to discuss options for providing audio format bill information to customers. Costs associated with providing audio format bill information to customers are outside Phase 3 of this 2011 GRC.
6.2. Customer Outreach
As described in PG&E's pre-settlement testimony, PG&E proposed various forms of customer outreach to build awareness of the RCES revisions and to help customers read the new energy statement. Under the terms of the proposed settlement, PG&E agrees to conduct targeted outreach to hard-to-reach groups, specifically seniors, the disabled community, and certain language minorities. Outreach to disabled communities shall include, in large print, PG&E's customer service telephone number including TTY. The targeted outreach will include information on the availability of alternative formats for the energy statement. The channels for such outreach may include: bill inserts, PG&E's website, outreach through Community Based Organizations, targeted advertising in mass media publications or social media targeted at these hard-to-reach populations. Outreach will not involve individualized direct mailings.
PG&E agrees to continue to send general messages on the bill to members of customer classes or general customer groups, like California Alternative Rates for Energy in the future. PG&E agrees to investigate the potential to send targeted, customer specific messages to customers who, based on their recorded usage patterns, potentially could benefit from changing to another rate schedule for which they may be eligible. This effort will be entirely separate from RCES, may occur through a separate communication channel than the customer's bill, and its costs are not subject to the limitation on future cost recovery requests in Section G of the RCES settlement.
6.3. RCES Cost Recovery
PG&E originally proposed cost recovery of $34.7 million to accomplish its RCES implementation. DRA proposed limiting recovery to only $16 million, noting that PG&E's requested amount is more than three times more than the costs of bill redesign that were previously approved for the other two major California electric utilities combined. TURN and CforAT did not propose specific RCES cost recovery amounts.
Settling Parties agree that $19.012 million is a reasonable amount for the recovery of implementation of the RCES project. TURN agrees, in consideration for a maximum settlement amount of $19.012 million, not to pursue cost escalation issues in this proceeding.
The Settlement does not allocate specific amounts to any specific task, but the $19.012 million will cover customer outreach costs for RCES in standard formats (including specific communication for Spanish and Chinese language audiences) and accessible formats when feasible (e.g., as set forth in Section E), customer billing, revenue and credit, and inquiry costs. The following specific IT functionality is also included:
1. Basic format setup for new bill
· Includes transitional bills
· Payment stub
2. Core account information
· Account summary
· Charges and discounts
· Amounts past due versus currently due
· Charges by tier and peak period
· Start and end meter reads
· Currently mandated rate components
· Third party billing information (e.g. DA, CCA)
3. New notices format
4. Graphical/visual presentment
· Tiers visualization
· Additional graphic elements as indicated by
project research, if funding is available5. Format, Print, and Display all rates currently available to customers
6. Online presentment for new bill
7. Limited format changes/calculations for multi-premise
and streetlight bills8. Messaging areas
9. Large font version
10. English, Spanish and Chinese
As acknowledged by Settling Parties, approval of up to $19.012 million for implementation of the RCES project may mean fewer other changes to the energy statement than described in parties' pre-settlement testimony. The $19.012 million will also fund less activity than described in testimony associated with supporting roll-out of the revised energy statement as customers start to receive the new format with additional information. Settling Parties believe, however, that significant changes to the customer energy statement can still be achieved for $19.012 million.
If PG&E were to determine that an Oracle Customer Care and Billing (CC&B) new version6 will become available soon, so as to make bill reformatting much more efficient and cost effective, or if PG&E were to prefer to await the Commission's guidance for dynamic pricing implementation to better develop the new bill format, DRA would not object to PG&E's delaying this project. Specifically, if PG&E were to decide to wait and implement RCES after issuance of a new version of the Oracle CC&B that can perform the bill extraction and other work needed for the revised bill format before implementing RCES, settling parties agree that the IT costs for bill extraction and related IT work for RCES should be subtracted from the Settlement Amount. The requests for the new CC&B version and related IT work may be requested in a future GRC 1 proceeding.
The Settling Parties agree that a one-way balancing account for RCES costs should be used to record actual RCES costs, with recovery in rates limited only to actual RCES costs not to exceed the limit of $19.012 million. If actual expenditures for RCES were to exceed the limit authorized, the excess expenditures could not be recovered in rates. RCES costs would go into rates through PG&E's Annual True-Up filings on an actual cost basis each year until the test year of the next General Rate Case after the 2014 GRC.
Capital costs for the RCES project would be placed in rate base beginning in the test year of the next Phase 1 GRC case after the 2014 GRC. Settling Parties agree that the $19.012 million Settlement Amount is solely for implementation of the Revised Customer Energy Statement. On-going operating costs such as paper for hard-copy bills, annual translation costs, and other operational costs are not part of the Settlement and will be treated as normal operating costs in the 2014 GRC.
Settling Parties agree that the same assumptions underlying the 2011 GRC Phase 1 settlement will be used to convert actually-incurred costs within the authorized amount to revenue requirements for this Settlement. A detailed description of the one-way balancing account is provided in Attachment A to the Settlement.
6.4. Bill Redesign Costs in PG&E's 2014 GRC Cycle
PG&E agrees not to seek additional funding for bill redesign projects like RCES in the 2014 GRC cycle unless:
a) mandated by the Commission or the Legislature;
b) the cost for redesigning the bill is more than $10 million; and
c) it is truly incremental to this RCES (A.10-03-014).
This limitation includes any specific rate or bill changes ordered by the Commission as of October 31, 2011. The limitation on requests in future cases does not apply to future proposals involving (1) a new rate schedules or programs not covered by this Settlement, or (2) modifying, adding or deleting information for changes to rates or programs approved in a future RDW, GRC Phase 2, or other rate design cases, or (3) modifying, adding or deleting bill messages where costs are routinely addressed in a future GRC proceeding.
In the future, PG&E agrees not to request IT costs in future PG&E GRC Phase 2 proceedings or future RDW proceedings, unless the Commission directs that such proceedings are a proper venue for cost recovery. This limitation does not apply to the currently pending 2010 RDW proceeding, A.10-02-028, or the default residential rate program application, A.10-08-005.
4 See Exhibit PG&E-17 (April 15, 2011), chapters 1 through 8.
5 The TTY is an abbreviation referring to a teletypewriter, an electronic device for text communication via a telephone line, typically used when one or more of the parties has hearing or speech difficulties.
6 CC&B is PG&E's current customer information system which supports the establishment and management of customer accounts, billing, and collections.
