LIMS-314-5918 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Approval of 2013-2014 Statewide Marketing, Education and Outreach Program and Budget (U39M). Application 12-08-007 (Filed August 3, 2012) And Related Matters. Application 12-08-008 Application 12-08-009 Application 12-08-010 SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) FLEX ALERT TRANSFER PROPOSAL JANET S. COMBS LARRY R. COPE ANDREA TOZER Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6713 Facsimile: (626) 302-7740 E-mail: [email protected]Dated: April 1, 2014
Transcript
LIMS-314-5918
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Application of Pacific Gas and Electric Company for Approval of 2013-2014 Statewide Marketing, Education and Outreach Program and Budget (U39M).
SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) FLEX ALERT
TRANSFER PROPOSAL
In compliance with Ordering Paragraph 16 of Decision 13-04-021, Southern California
Edison Company hereby submits the Flex Alert Transfer Proposal, attached hereto, on behalf of
itself, Pacific Gas and Electric Company, San Diego Gas & Electric Company, and California
Independent System Operator.
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Respectfully submitted, JANET S. COMBS LARRY R. COPE ANDREA TOZER
/s/ Andrea L. Tozer By: Andrea L. Tozer
Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6713 Facsimile: (626) 302-7740 E-mail: [email protected]
April 1, 2014
Attachment
Flex Alert Transfer Proposal
Flex Alert Transfer Proposal
Flex Alert Transfer Proposal
Table of Contents
A. EXECUTIVE SUMMARY ............................................................................................. 1 B. BACKGROUND ........................................................................................................ 2 C. SUMMARY OF PARTIES’ POSITIONS ON FLEX ALERT PROGRAM .................................. 3
1. SDG&E Highlights the Need for an EM&V Study ............................................................................... 3 2. SDG&E Proposed Transferring the Flex Alert Program to CAISO ................................................... 3
D. FLEX ALERT RESEARCH FINDINGS ........................................................................... 4 1. 2006-2007 Flex Your Power NOW! Evaluation Report ...................................................................... 4 2. 2008 Flex Alert Campaign Evaluation Report ..................................................................................... 4 3. Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and
SDG&E’s Peak Time Rebate Programs .............................................................................................. 5 4. 2013 Impact Evaluation of California’s Flex Alert Demand Response Program ............................ 5 5. 2013 Process Evaluation of the 2013 Statewide Flex Alert Program .............................................. 6 6. February 6, 2014 Flex Alert Event Media Report ................................................................................ 8 7. Overall Flex Alert Research Studies Conclusions .............................................................................. 9
E. FLEX ALERT PROGRAM COST/BENEFIT OVERVIEW ................................................. 10 F. FLEX ALERT PROGRAM TRANSFER PROPOSAL AND RECOMMENDATIONS ................. 10
1. CAISO Is Willing To Administer the Flex Alert Program .................................................................. 10 2. Utilities’ Recommendations .................................................................................................................. 11 3. Utilities Will Continue Local Demand Response Notifications ........................................................ 13
G. EXPLORATION OF ALTERNATIVE ENTITIES ............................................................... 13 H. FLEX ALERT BRAND ............................................................................................. 14 I. CONCLUSION ........................................................................................................ 15 APPENDIX A ............................................................................................................. 16
1. What Is A Flex Alert? ............................................................................................................................. 16
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A. Executive Summary
In Decision (D.)13-04-021, the Commission directed Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), San Diego Gas & Electric Company (SDG&E), and Southern California Gas Company (collectively, the Utilities), and California Independent System Operator (CAISO) to work together to develop a proposal for the transfer of the administration and funding of the Flex Alert program to CAISO or another entity, effective in 2015.
Through discussions and analysis in the development of this proposal, the Utilities agree that discontinuation of Utility funding of Flex Alert is appropriate at this time. The Utilities also agree that CAISO can continue to operate the Flex Alert program as follows:
The Commission should discontinue Utility funding for paid media for the
Flex Alert program;
CAISO should request that Walter McGuire & Company transfer the Flex Alert trademark and the Flex Alert Network to CAISO;
CAISO should request that Walter McGuire & Company transfer the FlexAlert.org URL and redirect traffic to CAISO’s website;
CAISO should include dedicated Flex Alert web content as part of the CAISO website;
CAISO should continue its unpaid Flex Alert activities, such as CAISO news bulletins, notifications to subscribers, and social media messaging;
The Utilities can include Flex Alert messaging as part of their local general awareness outreach through marketing, education, and outreach (ME&O) activities; and
Statewide ME&O should support generating awareness of Flex Alert. If the above recommendations are implemented this year, Utility funding and
administration of the Flex Alert program will not be necessary in 2015. CAISO has expressed its willingness to continue conducting the Flex Alert
program functions it currently executes and undertake additional responsibilities specifically for their balancing area only. However, CAISO is concerned over the lack of a funding mechanism proposal to cover administrative costs associated with undertaking these additional responsibilities, which would include the transfer of the Flex Alert trademark, managing the Flex Alert Network, and coordination of websites maintaining Flex Alert content.
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The Utilities recommend that CAISO continue the Flex Alert program and undertake the additional responsibilities outlined above. This will require CAISO to find a funding solution for the administrative costs associated with these activities.
B. Background
On May 10, 2012, the Commission adopted Decision (D.) 12-05-015, which provided guidance on the 2013-2014 energy efficiency portfolios and 2012 marketing, education, and outreach activities. Ordering Paragraph 117 of D.12-05-015 required the Utilities to file applications for statewide ME&O activities for demand-side management (DSM) programs.
On August 3, 2012, the Utilities filed their applications seeking approval of
statewide ME&O activities for demand-side management programs in 2013-2014. On November 8, 2012, Administrative Law Judge (ALJ) Fitch consolidated the Utilities’ applications into a single proceeding (A.12-08-007 et al).
On January 18, 2013, Assigned Commissioner Ferron and ALJ Roscow issued a
ruling dividing A.12-08-007 et al into two phases. Phase 1 would address budgets for the Flex Alert program for 2013-2014; and Phase 2 would address all other aspects of the statewide ME&O plans for 2013-2014. On April 26, 2013, the Commission issued D.13-04-021 establishing the Utilities’ annual budgets for the Flex Alert program for 2013-2014. D.13-04-021 contained the following ordering paragraphs:
Ordering Paragraph (OP) 17 of D.13-04-021 required that the Utilities and
CAISO file and serve in A.12-08-007 et al., by May 17, 2013, a jointly prepared report which details how the Utilities and ISO coordinate messaging during Flex Alert events today, and how they will optimize these efforts beginning summer 2013. This report was filed and served on May 17, 2013.1
OP 14 of D.13-04-021 required that SCE take the lead in initiating and
coordinating an Evaluation, Measurement and Verification (EM&V) study of Flex Alert, measuring 2013 ex post load impacts. SCE was required to file and serve the proposal in this proceeding no later than January 31, 2014. A portion of the 2012-2014 EM&V budgets authorized in Decision 12-04-045 was allocated to fund this study. On January 28, 2014, SCE requested an extension of time to comply with OP 14, and filed and served the study on February 28, 2014.2
OP 16 of D.13-04-021 required that the Utilities, CAISO, and other interested parties to work together to develop a proposal for the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity, effective in 2015. In compliance OP 16, this Proposal filed and served on March 31, 2014.
C. Summary of Parties’ Positions on Flex Alert Program
1. SDG&E Highlights the Need for an EM&V Study
In SDG&E Application (A.) 12-12-016 “Appendix X – SDG&E Response to Energy Division Guidance for Post Summer 2012 DR Evaluation and 2013/2014 Summer Planning,” SDG&E highlighted the need for a comprehensive EM&V study of the Flex Alert program to determine the level of customer understanding of the differences between Flex Alert and local demand response programs, and an evaluation of the load impacts of the program. This proposal was widely supported by the Utilities. In D.13-04-021, the Commission approved the load impact study (OP 14) and stated “it is reasonable that, given the continued reliance upon Flex Alerts for urgent conservation and load reduction, the actual success of the program should be analyzed in order to support future decisions on whether to increase funding and expand the program.”3
2. SDG&E Proposed Transferring the Flex Alert Program to CAISO
SDG&E agreed with SCE’s proposal4 to transfer the administration and funding responsibilities of Flex Alert to CAISO in 2015. Since CAISO is the only entity that can issue a Flex Alert, and the main purpose for issuing a Flex Alert is for statewide grid reliability5, funding for this type of program should be borne by all ratepayers in the state, rather than solely Utility ratepayers. Since CAISO has load management control over investor-owned and several municipal electric utilities, CAISO may be better suited in securing funding from a broader base of ratepayers benefitting from the program.
CAISO supported the general notion of exploring different funding and
administration options for the Flex Alert program but argued that the EM&V study should inform the proposal. CAISO also recommended exploring transferring responsibilities to another entity (such as the California Energy Commission), to address concerns about the viability of available funding mechanisms.6
In D.13-04-021, the Commission found merit in the transfer proposal and stated
that “it is logical that the entity controlling the program, ISO, also be responsible for administering and securing funding for the program, and that the funding is provided by all customers who benefit from the conservation and load reduction due to Flex Alerts, 3 D.13-04-021, p. 21. 4 A.12-08-008, p. 25, lines 5-7. 5 Flex Alerts can be called separately for Northern and Southern California. 6 CAISO’s Comments on Proposed Decision Phase 1, p.3.
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not just the ratepayers of the investor-owned utilities.”7 The Commission directed SCE to work with PG&E, SDG&E, CAISO, and other interested parties to develop a transfer proposal.8
D. Flex Alert Research Findings
Several Flex Alert research studies covering process and load impact analyses have been conducted in recent program cycles.9 These studies are summarized below and used to inform the Utilities’ joint recommendation.
1. 2006-2007 Flex Your Power NOW! Evaluation Report
Description: Research objectives for this evaluation report were to document the program goals and the implementation strategy for reaching them, assess customer awareness of and response to the program, assess effectiveness of program administration, assess whether the program caused a reduction in peak load, and provide guidance on whether the program should be continued in the future.
Summary: Most people understand the requested conservation actions, and end up conserving electricity, but confuse the need for conservation actions on particular days, not just particular times of day.10 Inconsistent and frequently changing program names and logos contribute to the confusion and weaken the message.11 Customers see the state and utilities as the appropriate leaders of this effort and news anchors as the most compelling source of information if an event is called.12 The load impact analysis was inconclusive and Flex Alert’s contribution to the estimated 200-1100 MW system response on Flex Alert days was unclear.13
2. 2008 Flex Alert Campaign Evaluation Report
Description: This report evaluated whether recommendations from the 2006-2007 Flex Your Power NOW! Evaluation Report were implemented, evaluated the effectiveness of the campaign in increasing customer awareness, assessed what conservation actions were taken and when, and determined key barriers to program participation.
Summary: Messaging consistency notably improved since it was first tested in the 2006-2007 Flex Your Power NOW! Evaluation Report. Overall, 67% of respondents recalled some sort of energy conservation message or the Flex Alert (unaided and
7 D.13-04-021, p.22. 8 D.13-04-021, OP 16. 9 Studies are available at www.calmac.org. 10 2006-2007 Flex Your Power NOW! Evaluation Report, p.4. 11 2006-2007 Flex Your Power NOW! Evaluation Report, p.3. 12 2006-2007 Flex Your Power NOW! Evaluation Report, p.6 and p.53. 13 2006-2007 Flex Your Power NOW! Evaluation Report, p.5.
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aided recall combined) and had a good recall of the requested conservation actions.14 However, very few respondents understood that conservation was especially needed on particular days.15 Significant media coverage of Flex Alerts occurred in the beginning of an event, but if an event lasted more than two days, media coverage declined considerably.16 Paid advertising communicated essential details about Flex Alerts more clearly than news media coverage.17 The load impact estimate for the 2008 Flex Alert campaign was approximately 222 to 282 MW based on self-reported air conditioner and lighting behaviors. These impacts are not verified as they were based on self-reporting, without an analysis of actual energy usage.18 Furthermore, this study revisited assumptions made in the 2006-2007 load impact estimate by using more detail on timing of actions, set-points, and building characteristics, resulting in a revision downwards from 93-495 MW to 45-75 MW.19
3. Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and SDG&E’s Peak Time Rebate Programs
Description: This study evaluated 2012 load impacts of SCE’s and SDG&E’s peak time rebate (PTR) programs and the effect of the two Flex Alert events called in 2012. SDG&E called seven PTR events in 2012, two of which occurred on the two Flex Alert days of August 10 and August 14. SCE called six PTR events, one of which was on the same day as the August 10 Flex Alert day. SDG&E included both notified and non-notified residential and small business customers, while SCE only included notified residential customers in the study.
Summary: SCE concluded that PTR customers who received event notifications did not respond to the Flex Alerts because the majority of the values shown are negative, indicating usage increases on Flex Alert days.20 SDG&E concluded that “there is no evidence that SDG&E’s residential or small commercial customers responded any differently on the two joint PTR and Flex Alert days than they did on the other PTR event days.”21
4. 2013 Impact Evaluation of California’s Flex Alert Demand Response Program
Description: The primary objectives of this study were to evaluate the ex-post load impacts of the Flex Alert program in 2013 and to develop Flex Alert program load impact estimates for the residential sector, using PG&E dynamic load profile data, and for all sectors combined using PG&E system load data.
Summary:22 In 2013, there were three Flex Alert event days (April 16, July 1,
and July 2), all of which were localized within PG&E’s service territory. The study found that no statistically significant load reductions could be attributed to the occurrence of Flex Alert event days. Both of the July Flex Alert event days coincided with event days for nearly every PG&E demand response program, which limited the ability to isolate any load reductions due to Flex Alert from the load reductions caused by the demand response programs.
The April 16 Flex Alert event was unusual due to the cause (vandalism severely damaged transformers at a substation in the San Jose area rather than a weather-related event), the event was called at approximately midnight instead of the typical daytime period, and the event also activated a wide variety of PG&E’s demand response programs. The April Flex Alert day applied to areas outside of PG&E’s service territory, but data is only available for PG&E’s entire service area rather than the specific area affected.
5. 2013 Process Evaluation of the 2013 Statewide Flex Alert Program23
Description: The process evaluation study assessed overall understanding and awareness of Flex Alert, interviewed the implementer and stakeholder representatives, investigated media coverage, conducted comparative research, and surveyed the Flex Alert Network organization. Customer surveys (web and phone based) were completed from mid-November 2013 through mid-January 2014.
Summary: There are relatively high levels of familiarity with the term “Flex Alert” and understanding of the requested conservation actions.24 However, there is likely still confusion between Flex Alert messaging and utility-based demand response notifications.25
Paid advertising ran from June 10 through September 29, 2013, and focused
primarily on the Southern California region. Television advertisements aired exclusively
22 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.1. 23 At the time of this filing of the Flex Alert Transfer Proposal, the 2013 Flex Alert Process Evaluation study has not been finalized and, therefore, should be considered preliminary in its findings. The study is currently in review by the Demand Response Measurement and Evaluation Committee (DRMEC) which includes members from SCE, SDG&E, PG&E, Energy Division and the CEC. Please use the following instructions to access the draft reports on the website:
− Go to www.sce.com/applications; − Under “CPUC Open Proceedings,” type A.12-08-007 into the search box; − Click “GO;” − From the Search Results screen, click the icon in the “Attachment” column that corresponds to
the document you want to view; − The document is presented in a PDF format (.pdf) and can be viewed online, printed, or saved to
your hard drive. 24 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.V. 25 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.V.
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in Southern California as did all advertising in languages other than English. The Northern region’s broadcast media tactics only included spot and traffic radio. Between April 16 and September 24, 2013, there were 297 news items which mentioned Flex Alerts.26 A large majority of Flex Alert earned media coverage (85%) appeared in Northern California, where all of the 2013 Flex Alert events took place.27
Flex Alert events on April 16, 2013 and February 7, 2014 occurred during mild
weather with origins unrelated to extreme heat. The two events called in anticipation of extreme heat (July 1 and 2, 2013) focused on constraints in Northern California. The variability in each of these events could therefore reduce the effectiveness of pre-planned marketing campaigns. In other words, a canned message to reduce energy usage from 1 pm to 6 pm is not effective when the event is called during other hours. During 2013, earned media provided responsive and credible coverage of Flex Alerts. Pre-scheduling media purchasing reflects a level of predictability that may not reflect grid conditions.28
Over the summer, the Flex Alert program’s paid media generated a much larger
number of impressions than the program gained from earned media (see Table 1). However, during the days surrounding events, earned media generated far more impressions than paid broadcast media. During the July event period, earned media provided nearly eight times as many impressions as paid media in Northern California, where the Flex Alert took place.29
Table 1: Impressions30 per Day from Earned Media and Paid Media
OUTREACH
TYPE
2013 DEMAND
RESPONSE SEASON (JUN 10-SEP 22)
APRIL 2013 EVENT PERIOD
(APR 16-APR 17)
JULY 2013 EVENT PERIOD (JUN 30-JUL 3)
FEBRUARY 2014
EVENT PERIOD (FEB 6-FEB 7)
NORTHERN CALIFORNIA
Paid Media 1,465,529 - 832,593 -
Earned Media 269,938 1,525,768 6,772,823 5,482,235
SOUTHERN CALIFORNIA
Paid Media 5,947,297 - 4,195,933 -
Earned Media 21,150 217,345 358,081 4,041,004
In general, the most frequently reported source of Flex Alert awareness was
television.31 Interviews with media professionals confirmed that the reporters and editors responsible for covering Flex Alerts view the events as newsworthy, primarily
26 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.76. 27 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.78. 28 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV. 29 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV. 30 Impressions are defined as views 31 Process Evaluation of the 2013 Statewide Flex Alert Program, p.32.
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due to the implied potential for energy shortages to result in power outages.32 The statewide program stakeholders noted that Flex Alerts garner significant media attention. However, staff and stakeholders had differing levels of certainty around the value of the paid media campaign – while some were convinced it was necessary to keep the public aware of the brand and informed about what to do during an event, others believe the earned media might be sufficient.33
The report also notes that the differing levels of investment in Flex Alert
contribute to a lack of clarity regarding program leadership and the perception that Flex Alert may be redundant to the Utilities’ local demand response programs.34
6. February 6, 2014 Flex Alert Event Media Report
On February 6, 2014, CAISO called a statewide Flex Alert event due to several gas-fired power plants that were curtailed because of natural gas shortages. An analysis of Flex Alert media coverage in Southern, Central, and Northern California media markets conducted by SCE shortly thereafter showed that 79 media outlets that carried the story on either February 6 or February 7, provided approximately nine million impressions. This report confirms findings from previous studies that earned media during events effectively generates impressions. More importantly, there was no paid advertising in market at the time of the February 6 event and was a good outcome because the Flex Alert hours were not consistent with what would have been in market. Details of the analysis:
Southern California:
Thirteen digital media outlets carried the story and three websites each ran two
stories
Five local TV stations ran the story a total of 21 times and counted for the majority of impressions
Three local radio stations ran the story a total of 29 times
Northern and Central California: 32 Process Evaluation of the 2013 Statewide Flex Alert Program, p.III. 33 Process Evaluation of the 2013 Statewide Flex Alert Program, p.VI. 34 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV.
Media # Media Outlets # Stories # Impression
Newspaper ‐ ‐ ‐
Digital 13 16 126,815
TV 5 21 4,143,750
Radio 3 29 702,100
Total 21 66 4,972,665
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Twenty four digital media outlets carried the story
Twenty six local TV stations ran the story a total of 79 times
Eight newspapers printed the story a total of 8 times
For TV and radio, the average quarter hour audience numbers for the time period when the spot ran were used to calculate the number of impressions. For digital, the average monthly visitors, divided by 30 days and then multiplied by 25% to account for the fact that not all visitors would have seen the story, was used as the calculation. The analysis did not identify any newspapers that carried the story in their print editions for the Southern California media market.
7. Overall Flex Alert Research Studies Conclusions
Research studies have shown that there are relatively high levels of familiarity with the term Flex Alert and understanding of the requested conservation actions. However, there is still confusion between Flex Alert messaging and utility-based demand response notifications.
News anchors are seen as the most compelling source of information if an event
is called but paid advertising communicated essential details about the Flex Alert program more clearly than news media coverage. However, earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. During the July 2013 event period, earned media provided nearly eight times as many impressions as paid media in Northern California, where the Flex Alert took place. The effectiveness of earned media was confirmed by the media coverage of the February 6, 2014 Flex Alert event, which resulted in approximately five million impressions even without any paid advertising in market at the time of this particular event.
Over the last several months, the use of Flex Alerts has been unpredictable
which reduces the effectiveness of pre-planned marketing campaigns. There were two Flex Alert events that occurred during mild weather with origins unrelated to extreme heat (April 16, 2013 and February 6, 2014) and two additional events (July 1 and 2, 2013) occurring in anticipation of extreme heat focused on constraints in Northern California.
Media # Media Outlets # Stories # Impression
Newspaper 8 8 1,778,503
Digital 24 24 254,597
TV 26 79 1,777,682
Radio ‐ ‐ ‐
Total 58 111 3,810,782
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Several studies attempted to measure Flex Alert load impacts, but all have been inconclusive in their findings. SCE’s and SDG&E’s joint 2012 load impact study35 concluded that load increased on Flex Alert days and that there is no evidence that SDG&E’s customers responded any differently on the two joint Peak-Time-Rebate (PTR) and Flex Alert days than they did on the other PTR-only event days.
E. Flex Alert Program Cost/Benefit Overview
The table below outlines the total annual authorized budget, paid media expenditures, fixed administrative costs, agency costs, the number of Flex Alert events, and load impact (if available) per program year since 2006. The Flex Alert program budget from 2006 to 2013 totals $62 million, with 35 events called during this time frame and no conclusive load impacts.
F. Flex Alert Program Transfer Proposal and Recommendations
1. CAISO Is Willing To Administer the Flex Alert Program
CAISO has the ability to evaluate and balance resources within its authority area and can initiate a Flex Alert specifically for that area. CAISO has generation load
35 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and PG&E’s Peak Time Rebate Programs. 36 Authorized Budgets 2006-2008: D.06-03-024, OP 1. Authorized Budgets 2009-2011: D.09-08-027, OP 17. Authorized Budget 2012: D.12-04-045, OP 19. Authorized Budgets 2013-2014: D.13-04-021, OP 1, OP 2, OP 3. 37 Source: http://www.caiso.com/Documents/Alert_WarningandEmergenciesRecord.pdf. 38 2006-2007 load impact results revised results shown in table as identified in the 2008 Flex Alert Campaign Evaluation Report. 2008 results based on self-reported air-conditioner and lighting behaviors, not verified. 2013 impact study found no statistically significant load reductions attributable to Flex Alert event days. 39 PG&E statewide lead for the Flex Alert program in 2006-2010.
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balancing control over both investor-owned and several municipal electric utilities for the CAISO balancing area, and the Utilities in that area have limited control over the program. However, the CAISO balancing area does not cover all of California. Substantial portions are controlled by other load serving entities and the intent for a statewide program would not be satisfied by a CAISO-only program. Other balancing areas in California have similar authority for their respective areas, but they do not currently participate in the Flex Alert program (although they may benefit from spillover Flex Alert messaging).
CAISO has expressed its willingness to continue conducting the Flex Alert
program functions it currently executes. It has also expressed a willingness to undertake additional responsibilities associated with the Flex Alert program providing that its administration of any Flex Alert functions would only be applicable to CAISO’s balancing area.
However, CAISO has expressed concern over the lack of a funding mechanism
proposal for CAISO to cover administrative costs associated with undertaking additional responsibilities that would be transferred to CAISO, including the transfer of the Flex Alert trademark, managing the Flex Alert Network, and additional coordination of websites maintaining the Flex Alert content.
2. Utilities’ Recommendations
The Utilities make the following recommendations:
The Commission should discontinue and eliminate Utility funding for paid media for the Flex Alert program. Research shows that unpaid media has effectively generated consumer engagement through public service announcements or news media reports.40 Unpaid media is seen as the most compelling and reliable source of information when a Flex Alert event is called. The value of paid media has been disputed by several stakeholders and has not provided quantifiable load impacts. Eliminating the paid statewide campaign is a reasonable approach.
CAISO should request that Walter McGuire & Company transfer the Flex Alert trademark and the Flex Alert Network to CAISO. CAISO should manage the Flex Alert Network, which supports the overall communication strategy, as almost all organizations that participated in the Flex Alert Email Survey41 reported that an event causes them to take action.
40 2013 Process Evaluation of the 2013 Statewide Flex Alert Program. February 6, 2014 Flex Alert Media Report. 41 2013 Process Evaluation of the 2013 Statewide Flex Alert Program.
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CAISO should request that Walter McGuire & Company transfer the FlexAlert.org URL, redirect traffic to CAISO’s website and discontinue the current Flex Alert website.
CAISO should include dedicated Flex Alert web content as part of the CAISO website www.caiso.com.
CAISO should continue its unpaid Flex Alert activities, such as CAISO notifications to subscribers via the CAISO website or its smart phone application, Twitter, Google+ and Facebook social media as described in the “Flex Alert Messaging Coordination and Optimization Report for Summer 2013.” In addition, CAISO should coordinate with state agencies to include the Flex Alert logo on government websites. The Flex Alert logo should be switched from green to red during a Flex Alert event.
With paid media for statewide Flex Alert activities discontinued, the Utilities can integrate Flex Alert messaging into their local ME&O activities to maintain awareness of the program and support CAISO’s unpaid activities. Examples include SCE’s Summer Readiness residential brochure which includes an explanation of the difference between Save Power Day and Flex Alert, and SCE’s Summer Readiness non-residential flyer with energy saving tips and Flex Alert educational messaging. This integration, along with awareness efforts by the Statewide ME&O campaign, helps eliminate the need for ratepayer funding and creates an effective alternative to continue providing awareness of Flex Alert.
Statewide ME&O should support generating awareness of Flex Alert. The goal of the Statewide Marketing, Education and Outreach Campaign (Energy Upgrade California), managed by the California Center for Sustainable Energy (CCSE) for the 2014-2015 program cycle, is that “Californians understand the value of energy efficiency, demand response, and distributed generation which leads to demand for products, services and rates for their homes and businesses.” Since generating awareness and understanding of demand response is part of the scope for this campaign, tactics such as paid media, earned/social media, website content, CBO outreach/education, and event outreach include general education about demand response and Flex Alerts. CCSE has also expressed its support for promoting Flex Alert event days in the “hero box” on the statewide Energy Upgrade California website and via social media channels.
Implementation of these recommendations would streamline Flex Alert
responsibilities and activities to the appropriate organization. The Utilities believe that these recommendations can be implemented before the end of 2014 so that program changes can be executed in 2015.
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3. Utilities Will Continue Local Demand Response Notifications
The Utilities will continue with local demand response program notifications to engage participation and achieve load reductions. In addition, given sufficient advance notice, the Utilities could dispatch certain programs and change website content when a Flex Alert is issued.
G. Exploration of Alternative Entities
The Utilities considered the California Energy Commission (CEC) as an alternative entity to administer and fund the Flex Alert program in preparing this transfer proposal. However, after a preliminary review, the Utilities concluded that a transfer to the CEC would require an unknown and potentially complex funding structure that may take a lengthy time to construct, adding an additional entity that would need to coordinate with CAISO (the only entity that can initiate a Flex Alert in its balancing area), and determining whether CEC is willing or able to take over the responsibilities for this statewide program. Because CAISO expressed support for accepting administration of the Flex Alert program and it was the only party who recommended exploring additional entities, the Utilities did not engage in discussions with the CEC.
A second alternative entity considered was the California Utilities Emergency
Association (CUEA). CUEA serves as a point-of-contact for critical infrastructure utilities and the California Office of Emergency Services (Cal OES) and other Governmental Agencies before, during and after an event to:42
Facilitate communications and cooperation between member utilities and
public agencies; and with non-member utilities (where resources and priorities allow);
Provide emergency response support wherever practical for electric, petroleum pipeline, telecommunications, gas, water and wastewater utilities and;
Support utility emergency planning, mitigation, training, exercises and education.
CUEA was recently brought to the Utilities’ attention as an option for taking on
the statewide responsibility for the Flex Alert program and was approached in the final stage of preparing this transfer proposal. Due to the limited opportunity for CUEA to provide input, the Utilities have not received its feedback.
42 Source: www.cueainc.com.
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H. Flex Alert Brand
The Flex Alert brand is owned by Walter McGuire & Company, Inc. (McGuire) as of November 9, 2010.43 Continuing with this brand name requires approval from McGuire as neither CAISO nor the Commission owns the trademark.
Research indicates44 that inconsistent and infrequently changing program names
and logos are confusing and weaken the message. The Utilities recommended that CAISO explore obtaining the required approvals to continue with the Flex Alert brand.
SCE facilitated a meeting on March 17, 2014, between CAISO and McGuire in
which the following topics were covered regarding the Flex Alert brand:
1. Use of the brand/ownership: McGuire confirmed that there are currently no costs for CAISO or IOUs to
use the brand, which will be confirmed in writing. Transferring the ownership of the brand to another entity is also an option that could be explored.
2. Administration: McGuire stated that trademark protection activities should continue in
order to ensure that the brand is not misused or forfeited. McGuire, as the current owner of the brand, has traditionally provided this service as a part of implementing the Flex Alert campaign. Costs for continuing this service would need to be determined if the campaign, or any part of it, is transferred to another entity.
3. Website: McGuire has developed and maintained the current program website,
www.flexalert.org. The annual costs varied depending on the type of activities that were required.
CAISO and McGuire agreed that a contract would be required if this activity is to continue in its current form in 2015.
4. Flex Alert Network: McGuire maintains a database which is updated annually by contacting
each member by phone to ensure accuracy of contact information. Network members are alerted through e-blasts distributed by McGuire.
Transferring the e-blast responsibilities to another entity, such as the CAISO, would require a review of the agreements McGuire holds with the Network members to determine if this would be allowed.
43 United States Patent and Trademark Office: Registration Number 3872849. 44 2006-2007 Flex Your Power NOW! Evaluation Report.
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I. Conclusion
The Utilities recommend that the Commission eliminate Utility funding for paid media for the Flex Alert program and that CAISO continue its unpaid Flex Alert activities as described in the “Flex Alert Messaging Coordination and Optimization Report for Summer 2013.” In addition, the Utilities recommend that CAISO obtain ownership of the Flex Alert brand and the FlexAlert.org URL.
The Utilities can integrate Flex Alert messaging as part of their local ME&O
activities with statewide ME&O supporting generating awareness of Flex Alert. CAISO has expressed its willingness to continue conducting the Flex Alert
program functions it currently executes and undertake additional responsibilities for its balancing area only. However, CAISO is concerned over the lack of a funding mechanism proposal to cover administrative costs associated with undertaking these additional responsibilities, which would include the transfer of the Flex Alert trademark, managing the Flex Alert Network, and coordination of websites maintaining the Flex Alert content.
Implementation of the recommendations proposed by the Utilities would
streamline Flex Alert responsibilities and activities to the appropriate organization. The Utilities believe that these recommendations can be implemented before the end of 2014 so that program changes can be executed in 2015.
The Utilities support CAISO continuing the Flex Alert program and undertaking
the additional responsibilities outlined above. This will require CAISO to find a funding solution for the administrative costs associated with these activities.
16
APPENDIX A
1. What Is A Flex Alert?
The “Flex Alert Messaging Coordination and Optimization Report for Summer 2013,” filed by the Utilities on May 17, 2013, describes Flex Alert as follows:
“A Flex Alert is an urgent call to Californians to immediately conserve electricity and shift demand to off-peak hours (after 6 p.m.). The Flex Alert campaign is an educational and emergency alert program that informs consumers about how and when to conserve electricity. The public awareness campaign is critical to achieving conservation during heat waves and other challenging grid conditions such as wildfires or when major power plant or power lines are unavailable. Flex Alerts also inform the public about the potential for service interruptions, giving customers the opportunity to conserve electricity to help prevent blackouts from occurring. The ISO typically issues a Flex Alert when there is potential for an electrical emergency (due to decreased operating reserves) or a transmission emergency (due to power line limitations).
CERTIFICATE OF SERVICE
I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) FLEX ALERT TRANSFER PROPOSAL on all parties identified on the attached service list A.12-08-007 et al. Service was effected by one or more means indicated below:
☒ Transmitting the copies via e-mail to all parties who have provided an e-
mail address.
☒ Placing the copies in sealed envelopes and causing such envelopes to be
delivered by hand or by overnight courier to the offices of the Commissioner(s) or other addressee(s).
ALJ Roscow CPUC 505 Van Ness Ave. San Francisco, CA 94102
☐ Placing copies in properly addressed sealed envelopes and depositing such
copies in the United States mail with first-class postage prepaid to all parties for those listed on the attached non-email list.
☐ Directing Prographics to place the copies in properly addressed sealed envelopes and to deposit such envelopes in the United States mail with first-class postage prepaid to all parties.
Executed April 1, 2014, at Rosemead, California.
/S/ Melissa Hernandez Melissa Hernandez Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770
PROCEEDING: A1208007 - PG&E - FOR APPROVAL FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: MARCH 26, 2014
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STEVEN D. PATRICK CHAIRMAN / PRESIDENT ATTORNEY LAT. BUS. CHAMBER OF GREATER L.A. SAN DIEGO GAS AND ELECTRIC COMPANY 634 S. SPRING STREET, STE 600 555 WEST FIFTH STREET, SUITE 1400 LOS ANGELES, CA 90014 LOS ANGELES, CA 90013-1011 FOR: LATINO BUSINESS CHAMBER OF GREATER FOR: SAN DIEGO GAS & ELECTRIC (SDG&E) LOS ANGELES AND SOUTHERN CALIFORNIA GAS (SOCALGAS) HOWARD CHOY ANDREA L. TOZER G.M., OFFICE OF SUSTAINABILITY ATTORNEY COUNTY OF LOS ANGELES SOUTHERN CALIFORNIA EDISON COMPANY 1100 NORTH EASTERN AVENUE 2244 WALNUT GROVE AVENUE LOS ANGELES, CA 90063-3200 ROSEMEAD, CA 91770 FOR: THE SOUTHERN CALIFORNIA REGIONAL FOR: SOUTHERN CALIFORNIA EDISON COMPANY ENERGY NETWORK SACHU CONSTANTINE FAITH BAUTISTA DIRECTOR OF POLICY PRESIDENT & CEO CALIF. CENTER FOR SUSTAINABLE ENERGY NATIONAL ASIAN AMERICAN COALITION 8690 BALBOA AVE., STE. 100 15 SOUTHGATE AVE., STE. 200 SAN DIEGO, CA 92123 DALY CITY, CA 94015 FOR: CALIFORNIA CENTER FOR SUSTAINABLE FOR: NATIONAL ASIAN AMERICAN COALITION ENERGY BILL NUSBAUM SHIRLEY A. WOO MANAGING ATTY ATTORNEY AT LAW THE UTILITY REFORM NETWORK PACIFIC GAS AND ELECTRIC COMPANY
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785 MARKET ST., STE. 1400 PO BOX 7442, MC B30A SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94120-7442 FOR: THE UTILITY REFORM NETWORK FOR: PACIFIC GAS & ELECTRIC COMPANY GERALD LAHR LEN CANTY ASSOCIATION OF BAY AREA GOVERNMENTS CHAIRMAN 101 8TH ST. BLACK ECONOMIC COUNCIL OAKLAND, CA 94607 484 LAKE PARK AVE., SUITE 338 FOR: THE SAN FRANCISCO BAY AREA OAKLAND, CA 94610 REGIONAL ENERGY NETWORK (BAYREN) FOR: BLACK ECONOMIC COUNCIL MELISSA KASNITZ NOEMI GALLARDO ATTORNEY LEGAL FELLOW CENTER FOR ACCESSIBLE TECHNOLOGY THE GREENLINING INSTITUTE 3075 ADELINE STREET, STE. 220 1918 UNIVERSITY AVE., 2ND FLOOR BERKELEY, CA 94703 BERKELEY, CA 94704 FOR: CENTER FOR ACCESSIBLE TECHNOLOGY FOR: THE GREENLINING INSTITUTE COLIN CLARK JUDITH B. SANDERS PROGRAM DEVELOPMENT MGR. SR. COUNSEL ECOLOGY ACTION OF SANTA CRUZ, INC. CALIF. INDEPENDENT SYSTEM OPERATOR CORP 877 CEDAR STREET, STE. 240 250 OUTCROPPING WAY SANTA CRUZ, CA 95060 FOLSOM, CA 95630 FOR: ECOLOGY ACTION OF SANTA CRUZ, INC. FOR: CALIFORNIA INDEPENDENT SYSTEMS OPERATOR (CAISO) MARCO LIZARRAGA LA COOPERATIVA CAMPESINA DE CALIFORNIA 1107 9TH STREET, STE. 420 SACRAMENTO, CA 95814 FOR: LA COOPERATIVA CAMPESINA DE CALIFORNIA
CASE COORDINATION CHARLIE BUCK PACIFIC GAS AND ELECTRIC COMPANY CALIF. CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 HUGH YAO JESSICA COHEN SOUTHERN CALIFORNIA GAS COMPANY MANAGEMENT FOLLOW/PROGRAM MANAGER EMAIL ONLY L.A.COUNTY OFFICE OF SUSTAINABILITY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 JODY S. LONDON LARA ETTENSON JODY LONDON CONSULTING NATURAL RESOURCES DEFENSE COUNCIL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: LOCAL GOVERNMENT SUSTAINABLE ENERGY COALITION
LAURA BRENNER KIMES MIKE CADE LAURA BRENNER KIMES, LLC ALCANTAR & KAHL, LLP EMAIL ONLY EMAIL ONLY EMAIL ONLY, IL 00000 EMAIL ONLY, OR 00000 SEPHRA A. NINOW, J.D. SHALINI SWAROOP REGULATORY AFFAIRS MGR. REGULATORY COUNSEL CALIFORNIA CENTER FOR SUSTAINABLE ENERGY MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 STEPHANIE CHEN MRW & ASSOCIATES, LLC SR. LEGAL COUNSEL EMAIL ONLY THE GREENLINING INSTITUTE EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 SIOBHAN FOLEY ANDREW STEINBERG CALIFORNIA CENTER FOR SUSTAINABLE ENERGY REGULATORY POLICY & REPORTING MGR. EMAIL ONLY SOUTHERN CALIFORNIA GAS COMPANY EMAIL ONLY, CA 00000-0000 555 W. FIFTH STREET, GT19A7 LOS ANGELES, CA 90013 DEANNE NG JEFF SALAZAR SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, GT14D6 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013 STEVE HRUBY CASE ADMINISTRATION SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 555 W. FIFTH ST., GT14D6 LAW DEPT. LOS ANGELES, CA 90013 2244 WALNUT GROVE AVE., RM 370 ROSEMEAD, CA 91770 DAVID LEBLOND DAVID P. LOWREY SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY POLICY & AFFAIRS 2244 WALNUT GROVE AVE. SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA 91770 1515 WALNUT GROVE AVE. ROSEMEAD, CA 91770 LARRY R. COPE DONALD C. LIDDELL ATTORNEY ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVE. / PO BOX 800 2928 2ND AVENUE ROSEMEAD, CA 91770 SAN DIEGO, CA 92103 ANNLYN M. FAUSTINO CENTRAL FILES REGULATORY CASE ANALYST & SUPPORT SDG&E/SOCALGAS SDG&E/SCGC 8330 CENTURY PARK COURT, CP31-E 8330 CENTURY PARK COURT, CP31E SAN DIEGO, CA 92123 SAN DIEGO, CA 92123
JOY C. YAMAGATA ATHENA BESA REGULATORY MANAGER CUSTOMER PROGAMS & POLICY MANAGER SAN DIEGO GAS & ELECTRIC / SOCALGAS SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP 32 D 8335 CENTURY PARK COURT, CP12H SAN DIEGO, CA 92123-1530 SAN DIEGO, CA 92123-1569 PAUL KERKORIAN AARON J. LEWIS ATTORNEY AT LAW NATIONAL ASIAN AMERICAN COALITION 6475 N PALM AVE., STE. 105 15 SOUTHGATE AVE., STE. 200 FRESNO, CA 93704 DALY CITY, CA 94015 ROBERT GNAIZDA RORY COX OF COUNSEL CALIF PUBLIC UTILITIES COMMISSION 15 SOUTHGATE AVE., STE. 200 DEMAND SIDE ANALYSIS BRANCH DALY CITY, CA 94015 AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 MARCEL HAWIGER JOSEPHINE WU THE UTILITY REFORM NETWORK PACIFIC GAS & ELECTRIC COMPANY 785 MARKET ST., STE. 1400 77 BEALE STREET, ROOM 975 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94105 MARDI WALTON SHADA DADRAS SR. REGULATORY ANALYST PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B9A 77 BEALE STREET, MC B10B, RM 1003 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 HILLARY CORRIGAN STEVE R. HAERTLE CALIFORNIA ENERGY MARKETS CASE MANAGER - ENERGY PROCEEDINGS 425 DIVISADERO ST. STE 303 PACIFIC GAS & ELECTRIC COMPANY SAN FRANCISCO, CA 94117-2242 PO BOX 7442, MC-B9A SAN FRANCISCO, CA 94120 MIKHAIL HARAMATI RYAN BRISCOE YOUNG ASSOCIATE THE GREENLINING INSTITUTE OPINION DYNAMICS CORPORATION 1918 UNIVERSITY AVENUE, 2ND FLOOR 1999 HARRISON ST., STE. 1420 BERKELEY, CA 94704 OAKLAND, CA 94612 GREGORY VAN PELT STEPHANIE MCCORKLE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CALIFORNIA ISO 250 OUTCROPPING WAY 250 OUTCROPPING WAY FOLSOM, CA 95630 FOLSOM, CA 95630-8773 ROBERT CASTANEDA LA COOPERATIVA CAMPESINA DE CALIFORNIA 1107 9TH ST., STE. 420 SACRAMENTO, CA 95814
MICHAEL COLVIN ANDREW KOTCH ADVISOR - ENERGY CALIF PUBLIC UTILITIES COMMISSION CPUC EXECUTIVE DIVISION EMAIL ONLY ROOM 5301 EMAIL ONLY, CA 00000 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 JACLYN MARKS STEPHEN C. ROSCOW CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DEMAND SIDE ANALYSIS BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES AREA 4-A ROOM 5010 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214
