IX. Marketing Content

1. Parties' Positions

CCSF is concerned about PG&E's marketing plan and the qualifications of its marketing expert, seeks more Commission and/or EAG involvement in marketing the CPT, and asks that marketing materials be printed using recycled products. CCSF asks that the Commission make a fully detailed marketing plan a requirement for approval of the application.

PG&E intends to develop a very detailed marketing plan after Commission approval of the CPT and prior to launching the marketing campaign. PG&E has no objection to an ordering paragraph that provides a means for Commission staff to review the detailed marketing plan before the program is rolled out to customers. That marketing plan will also be shared with the EAG for its advice and input. PG&E requests that the review be coordinated in a manner that permits keeping the program on track for launch within the first quarter of 2007, and that approval of the application not be held up for this purpose.³⁶

2. Discussion

We are satisfied with PG&E's commitment to develop a detailed marketing plan, share it with the Commission staff and members of the EAG before the program gets underway, and take input from staff and the EAG on positive changes to the plan. The Commission is most interested that the marketing plan communicate the problem of global warming to customers in a fact-based way, and educate customers on how to reduce global warming. To the extent that GHG reductions are to be realized through long-term projects, PG&E should also disclose in its marketing materials that the time-frame of reductions does not match that of the emissions to be offset.

We also agree with CCSF that PG&E should to the maximum extent possible use recycled materials in its marketing campaign.

³⁶ PG&E reply brief at 28.