6. Company Vehicles and Employee Uniforms

Edison requests that the Commission also carve out a limited exemption to Rule V.F.1 for the name or logo that appears on affiliate company vehicles and employee uniforms. Again, Edison argues that the principle purpose of using the name or logo in such instances is for identification, rather than to initiate a business transaction. Edison argues that this limited exemption will enhance customer information and might also further customer safety. Edison believes that if the Commission required a rule-compliant disclaimer on a company vehicle, the disclaimer would be of such size as to subject the disclaiming company to ridicule. Edison also believes it is important from a consumer protection perspective that employee uniforms clearly delineate who the employee works for.2

ORA and TURN state that there is tremendous value associated with the ability to place corporate identifiers on company vehicles and employee uniforms. ORA and TURN point out that the petition does not specify which company vehicles or employee uniforms should be exempt. ORA and TURN state that Edison makes no pledge not to co-advertise or co-brand with its affiliates in these two situations.

In its reply, Edison specified with more detail which company vehicles and employee uniforms should be exempt from Rule V.F.1.

We grant Edison, and all other utilities subject to the Affiliate Transaction Rules, a narrow exemption from Rule V.F.1 with respect to affiliate company vehicles and employee uniforms as more fully described below. As we did for building signage, we grant this exemption because of some limited specific practical problems posed by strict application of the Rule. We continue to recognize the importance of promoting the separation of the affiliate and utility in the minds of the consumer. Further, this exemption should not be abused by the affiliate in order to market its products or services. For example, such signs should not routinely include telephone numbers, promotional banners, or other product advertisements. In the event it is necessary to include an affiliate telephone number on a company vehicle (such as a security patrol car) to indicate where the consumer can call if there are any problems, it should connect to an affiliate's "trouble shooting" desk. It is a violation of Rule III.E and V. F. 4 for utility to co-advertise or co-brand with its affiliate.

Although the primary purpose of a name or logo on a vehicle or employee uniform is for identification, it may also have a secondary marketing purpose or effect. However, we grant this narrow exception to Rule V.F.1 because it is important that consumers be able to identify which company owns and is responsible for a vehicle, and, more importantly, to identify for whom a particular employee works, especially if the employee is making field calls (i.e., if the employee is a repair person). Important public safety concerns require such identification. Also, Edison recognizes that such employees are prohibited by state law as well as Commission rules, from claiming that they represent the utility. Therefore, we grant a limited exemption to Rule V.F.1 to Edison and other utilities subject to the Affiliate Transaction Rules, as conditioned above, for the following situations:

2 Edison states that if any other party to these proceedings is concerned that the requested exemption could be used or abused as an opportunity to turn the back of an employee's uniform into a billboard (with perhaps an "800" number), that party could request modification of the Rule back to its original form if such abuse occurs.

Previous PageTop Of PageNext PageGo To First Page