4. Rule V.F.1

Rule V.F.1 of the Affiliate Transaction Rules provides:

Corporate Identification and Advertising:

1. A utility shall not trade upon, promote, or advertise its affiliate's affiliation with the utility, nor allow the utility name or logo to be used by the affiliate or in any material circulated by the affiliate, unless it discloses in plain legible or audible language, on the first page or at the first point where the utility name or logo appears that:

a. the affiliate "is not the same company as [i.e., PG&E, Edison, the Gas Company, etc], the utility,";


b. the affiliate is not regulated by the California Public Utilities Commission; and


c. "you do not have to buy [the affiliate's] products in order to continue to receive quality regulated services from the utility."




The application of the name/logo disclaimer is limited to the use of the name or logo in California.

In D.98-11-027, slip op. at p. 14, we clarified the Rule V.F.1. does not apply in certain limited situations where our goals of protecting consumer interests and fostering competition would not be harmed. These limited situations involved certain communications between the affiliate and governmental bodies, annual reports to shareholders, and certain affiliate internal communications. We also clarified Rule V.F.1 so that in the case of electric service provider affiliates, the second line of the disclaimer may read as follows, "The California Public Utilities Commission does not regulate the terms of that affiliate's products and services." (Id. at p. 15.)

Edison requests the Commission clarify D.97-12-088 to state that the disclaimer requirement of Rule V.F.1 shall not apply to: (a) building signage; (b) company vehicles; (c) employee uniforms; and (d) installed equipment on customer premises. We address each of these requested exemptions in order below.