Application No.: A.19-08-

Exhibit No.: SCE-03, Vol. 2 Witnesses: V. Hernandez

J. Lim D. Tasaka

(U 338-E)

2021 General Rate Case

Communications, Education & Outreach

Before the

Public Utilities Commission of the State of California

Rosemead, California August 30, 2019

SCE-03, Vol. 2: Communications, Education, and Outreach

Table Of Contents Section Page Witness

-i-

I.  INTRODUCTION .............................................................................................1 J. Lim 

A.  Content and Organization of Volume ....................................................1 

B.  Summary of O&M Request ...................................................................1 

II.  COMMUNICATIONS, EDUCATION AND OUTREACH .............................3 

A.  Overview of Communications, Education and Outreach ......................3 

1.  Customer Communications, Education and Outreach .....................................................................................3 

2.  Escalated Complaints and Outreach ..........................................3 V. Hernandez 

3.  External Communications ..........................................................4 D. Tasaka 

B.  Regulatory and Compliance Considerations ..........................................4 

1.  Safety, and Reliability – RAMP Compliance ............................4 

2.  Communications and Outreach Regarding Disconnections of Vulnerable Customers ..................................5 J. Lim 

3.  Multi-Channel Marketing Compliance Requirements .............................................................................6 

C.  Comparison of Authorized to Recorded 2018 Expenses for Communications, Education and Outreach............................................6 

D.  O&M Forecast .......................................................................................7 

1.  Customer Communications, Education and Outreach .....................................................................................8 

a)  Work Description and Need for Activities ....................8 

(1)  Education Centers and Events ...........................8 

(2)  Multi-Channel Campaigns ...............................12 

b)  Comparison of Authorized 2018 to Recorded ......................................................................17 

c)  Scope and Forecast Analysis .......................................18 

SCE-03, Vol. 2: Communications, Education, and Outreach

Table Of Contents (Continued) Section Page Witness

-ii-

(1)  Historical Variance Analysis ...........................19 

(2)  Forecast ............................................................20 

d)  Basis for O&M Cost Forecast ......................................26 

2.  Escalated Complaints and Outreach ........................................27 V. Hernandez 

a)  Work Description and Need for Activities ..................27 

b)  Comparison of Authorized 2018 to Recorded ......................................................................30 

c)  Scope and Forecast Analysis .......................................30 

(1)  Historical Variance Analysis ...........................31 

(2)  Forecast ............................................................32 

d)  Basis for O&M Cost Forecast ......................................34 

3.  External Communications ........................................................35 D. Tasaka 

a)  Work Description .........................................................35 

(1)  Public Education ..............................................35 

(2)  Key Initiatives/Media Relations ......................37 

(3)  Digital Communications ..................................37 

b)  Need for Activity .........................................................38 

c)  Comparison of Authorized 2018 to Recorded ......................................................................39 

d)  Scope and Forecast Analysis .......................................40 

(1)  Historical Variance Analysis ...........................41 

(2)  Forecast ............................................................42 

(3)  RAMP Integration ............................................43 

e)  Basis for O&M Cost Forecast ......................................44 

1

I. 1

INTRODUCTION 2

A. Content and Organization of Volume 3

This volume presents Southern California Edison’s (SCE) Test Year 2021 forecast of Operations 4

and Maintenance (O&M) expenses for activities that support the Communications, Education and 5

Outreach Business Planning Element (BPE). The funding request presented for the BPE will allow SCE 6

to continue its efforts to educate and bring awareness to both residential and business customers about 7

available clean energy and energy savings program opportunities, rate and account management options, 8

and SCE’s critical safety initiatives. This volume also presents the costs for SCE to continue providing 9

necessary service by responding to customer inquiries, resolving customer complaints, and improving 10

customers’ experiences with SCE’s programs and services. 11

This volume summarizes the scope of work, key drivers for the work, and regulatory mandates 12

that impact the level of O&M requested for the Communications, Education and Outreach BPE. The 13

volume also includes an analysis of O&M funding authorized in the 2018 General Rate Case (GRC) 14

compared to recorded amounts in 2018, the Base Year, and the 2021 Test Year O&M labor and non-15

labor forecast. SCE explains the reasons for any variances between the Base Year expenditures and Test 16

Year forecasts. The activities detailed in this volume are managed in SCE’s Business Customer 17

Division, Customer Programs and Services, Customer Service Operations Division, and Corporate 18

Communications organizations. 19

B. Summary of O&M Request 20

This volume presents SCE’s request for $21.810 million (constant 2018 dollars) in O&M 21

expense for the 2021 Test Year to effectively perform the functions and activities described in this 22

volume. The supporting testimony and workpapers for Communications, Education, and Outreach 23

capitalized software projects are discussed in SCE-06, Vol. 1, Part 2. Figure I-1 illustrates the 24

Communications, Education and Outreach share of SCE’s Customer Interactions Business Planning 25

Group (BPG) total O&M expenses, which is approximately 12 percent. 26

2

Figure I-1 Communications, Education and Outreach

O&M Expenses (In 2018 Constant $Millions)

Table I-1 below presents SCE’s Communications, Education and Outreach’s O&M expenses 1

recorded for 2014-2018 and the forecast for 2019-2021 by each of the categories of activities that are 2

described in this testimony. 3

Table I-1 Communications, Education and Outreach

Recorded 2014-2018 and Forecast 2019-2021 (Constant 2018 $000)

4

2014 2015 2016 2017 2018 2019 2020 2021

1 Customer Communications, Education and Outreach $6,470 $4,139 $2,241 $3,721 $3,761 $3,397 $4,507 $9,193

2 Escalated Complaints and Outreach $1,548 $1,134 $946 $883 $1,165 $1,068 $1,253 $1,303

3 External Communications $15,417 $17,387 $10,274 $10,850 $11,139 $11,045 $11,052 $11,313

4 Total $23,434 $22,660 $13,461 $15,453 $16,065 $15,510 $16,812 $21,810

Line No. Work Activity

Recorded Forecast

3

II. 1

COMMUNICATIONS, EDUCATION AND OUTREACH 2

A. Overview of Communications, Education and Outreach 3

This section provides an overview of the work activities discussed in this volume, as well as the 4

customer needs, compliance requirements and regulatory policies driving SCE’s O&M request for these 5

work activities. There are three main work activities explained in this volume: (1) Customer 6

Communications, Education and Outreach (CCE&O); (2) Escalated Complaints and Outreach; and (3) 7

External Communications. Each of these work activities plays a vital role for SCE to provide service to 8

its customers and to meet its compliance obligations. 9

1. Customer Communications, Education and Outreach 10

The CCE&O work activities are foundational to establishing on-going and relevant 11

communications with SCE’s customers about SCE services and programs to help customers meet their 12

energy management needs. These activities are led primarily by SCE’s Business Customer Division 13

(BCD) and Customer Programs and Services (CP&S) organizations. This work activity includes: (1) 14

education and awareness offerings delivered at the Energy Education Centers in Tulare and Irwindale1 15

for residential, commercial, industrial, agricultural, and government and institution customers with 16

information regarding energy management programs and technologies, renewable generation, codes & 17

standards, zero net energy (ZNE), environmental solutions, electric safety, and utility programs; and (2) 18

the planning, creation, and optimization of multi-channel communications campaigns, websites, emails, 19

and print materials to drive customer awareness and adoption of SCE rate and pricing options, as well as 20

other basic electric service offerings, through digital, and other channels. 21

2. Escalated Complaints and Outreach 22

The Escalated Complaints and Outreach work activity is carried out by SCE’s Consumer 23

Affairs organization, which receives and gathers feedback from SCE’s customers and answers customer 24

inquiries, resolves customer complaints, and improves customers’ experiences with SCE’s programs and 25

services. This organization handles escalated customer inquiries and complaints transferred from the 26

Commission’s Consumer Affairs Branch (CAB) and those received directly by SCE through various 27

channels. Consumer Affairs also monitors SCE’s social media channels to respond to customer inquiries 28

1 Historically, operational expenses for the Energy Education Centers have been jointly funded through Public

Goods Charges (PGC) and O&M funding. Only the O&M portion of the total operating costs for the Energy Education Centers is included in this GRC application.

4

or complaints that come through these channels. In performing its outreach function, this organization 1

also, among other things, advocates for SCE’s most vulnerable customers such as those enrolled in 2

SCE’s Medical Baseline and critical care programs, as well as elderly and disabled customers. 3

3. External Communications 4

The External Communications work activity is carried out primarily by SCE’s Corporate 5

Communications organization, which effectively and efficiently educates external audiences (including 6

both residential and non-residential customers) about a range of topics including safety, outages and 7

storms, and clean energy. The end-to-end process for executing these communications (including 8

planning, production, distribution and evaluation), and the labor and non-labor expenses for these 9

communication activities, is managed through public education, key initiatives and media relations, and 10

digital communications. The specific sub-activities and associated O&M request to support these sub-11

activities is detailed later in this Volume. 12

B. Regulatory and Compliance Considerations 13

1. Safety, and Reliability – RAMP Compliance 14

SCE’s Risk Assessment and Mitigation Phase (RAMP) filing includes requirements for 15

SCE to perform certain actions to reduce the risk of contact with energized equipment. The purpose of 16

the RAMP review by the Commission’s Safety and Enforcement Division (SED) is to assess whether a 17

utility has described and justified proposed safety mitigations.2 The RAMP report identified nine 18

primary risks to public safety, including wildfire, cyberattack, and contact with energized equipment. As 19

part of its RAMP compliance obligations, SCE’s External Communications engages in public outreach 20

communications that focus on informing the public about the appropriate and safe actions to take when 21

encountering a downed electrical wire. A more detailed description of the activities included in RAMP 22

can be found in the External Communications’ work description below (see Section II.D.3.). Table II-2 23

shows the External Communications’ RAMP report control of Public Outreach to address the risk 24

associated with the public coming into contact with energized electrical equipment. 25

2 See

https://www.cpuc.ca.gov/uploadedFiles/CPUC_Public_Website/Content/Safety/Risk_Assessment/SCE%20RAMP%20REVIEW%20-%2005-24-2019.pdf (as of July 25, 2019).

5

Table II-2 GRC Activities Included in SCE’s 2018 RAMP Filing3

2. Communications and Outreach Regarding Disconnections of Vulnerable Customers 1

The requested O&M for the Consumer Affairs organization, in performing its outreach 2

function, is driven in part by the Commission’s regulations and policies related to utility disconnection 3

and reconnection processes. The Commission’s Disconnection Order Instituting Rulemaking (OIR) 4

(R.18-07-005) proceeding is driven by legislation, Senate Bill (SB) 598,4 that requires the Commission 5

to develop new policies, rules, and regulations to reduce the rates of residential disconnections for non-6

payment. Specifically, in Decision (D.)18-12-013, the Commission directed the investor-owned utilities 7

to update their tariffs to classify senior citizens (65 years and older) as vulnerable customers.5 SCE’s 8

Consumer Affairs organization works with vulnerable customers to avoid credit-related disconnections 9

and will continue to coordinate with other organizations within SCE to conduct outreach activities to 10

vulnerable customers who are at risk of a service disconnection as the Disconnections OIR continues. 11

These activities are discussed below in Section II.D.2.a. 12

The Commission has recently adopted an emergency disaster relief and consumer 13

protections program designed to assist California utility customers who experience a housing or 14

financial crisis due to wildfires, so that they keep vital utility services and receive financial support in 15

the wake of a disaster. In D.19-07-015, issued in the Commission’s Emergency Disaster Relief 16

Rulemaking (R.18-03-011) proceeding, new policies were adopted that protect residential and small 17

business customers, by providing temporary billing, payment and service disconnections as a result of 18

3 RAMP ID Definitions: C = Control, M = Mitigation, and CM = Compliance.

4 See https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB598 (as of August 9, 2019).

5 Order Instituting Rulemaking to Consider New Approaches to Disconnection and Reconnections to Improve Energy Access and Contain Costs, D.18-12-013, December 13, 2018, Ordering Paragraph 1.

GRC Activity RAMP Control / Mitigation Name

RAMP ID Risk Addressed

External Communications Public Outreach C2 Contact with Energized

Equipment

6

wildfires or other disasters.6 SCE’s Consumer Affairs organization coordinates with local and state 1

authorities on the communications, public education, and deployment of specific disaster relief 2

protections for customers impacted by disasters. These activities are discussed below in Section II.D.2.a. 3

3. Multi-Channel Marketing Compliance Requirements 4

In Section 5.1.6 of SCE’s 2018 General Rate Case Decision (D.19-05-020),7 the 5

Commission requires that SCE demonstrate its level of outreach and effectiveness of multi-channel 6

marketing activities to minority customers. The details of SCE’s multi-channel marketing activities, and 7

compliance with D.19-05-020 are discussed below in Section II.D.1.a. (“Outreach and Communications 8

to Diverse Communities”). 9

C. Comparison of Authorized to Recorded 2018 Expenses for Communications, Education 10

and Outreach8 11

On May 24, 2019, the Commission issued D.19-05-020, which authorized SCE’s O&M Forecast 12

for the Test Year 2018 (“2018 GRC”). Figure II-2 below compares the requested and authorized O&M 13

expenses from SCE’s 2018 GRC with the recorded expenses for Communications, Education and 14

Outreach BPE in compliance with D.15-11-021. As shown in Figure II-2 below, SCE’s recorded 15

expenses in 2018 Communications, Education and Outreach were higher than authorized by $415,000. 16

This variance of approximately three percent is within normal operating expectations. 17

6 Decision Adopting an Emergency Disaster Relief Program for Electric, Natural Gas, Water and Sewer Utility

Customers, D.19-07-015, July 11, 2019.

7 See Decision on Test Year 2018 General Rate Case for Southern California Edison, D.19-05-020, issued May 24, 2019, p. 139 (“Future testimony however, should include further evidence demonstrating SCE’s commitment to minority outreach and measuring its effectiveness.”).

8 Refer to WP SCE-07, Vol. 01 – Authorized to recorded.

7

Figure II-2 Communications, Education and Outreach

Comparison of 2018 GRC Authorized versus Recorded (Constant 2018 $000)

D. O&M Forecast 1

This section presents a description of, and need for, the work activities covered in this Volume. 2

In this section, SCE also presents a comparison of 2018 authorized to recorded expenditures, scope and 3

forecast analysis, and the basis for the Test Year O&M cost forecast. Figure II-3 below presents the 4

Communications, Education and Outreach O&M expenses that were recorded for 2014-2018 and 5

forecast for 2019-2021. 6

8

Figure II-3 Communications, Education and Outreach

Recorded 2014-2018 and Forecast 2019-2021 (Constant 2019 $000)

1. Customer Communications, Education and Outreach 1

a) Work Description and Need for Activities 2

A description of, and need for, work in the CCE&O area is set forth in the 3

following sub-activities: (1) Education Centers and Events and (2) Multi-Channel Campaigns. 4

(1) Education Centers and Events 5

(a) Energy Education Centers 6

Currently, SCE operates two Energy Education Centers (EEC), one 7

in Irwindale and one in Tulare. The EEC in Irwindale (EEC-Irwindale) is a 51,000 square-foot complex 8

that includes a conference center that can accommodate over 100 customers and several meeting rooms 9

where educational workshops, seminars, and other events are conducted. The EEC in Tulare (EEC-10

Tulare) is a 32,000 square-foot complex located on ten acres and consists of six buildings, one of which 11

is constructed with energy-efficient materials and demonstrates energy-efficient construction 12

technologies and applications. Due to its close proximity to the largest agricultural counties in the state 13

(Kern, Tulare, and Fresno), EEC-Tulare employs expertise in agricultural energy efficiency applications 14

and demonstrates energy-efficient agricultural irrigation technologies. 15

9

In 2018, over 57,000 customers visited the EECs. Specifically, 1

EEC-Irwindale hosted approximately 45,000 visitors and EEC-Tulare hosted approximately 12,000 2

visitors who participated in technical seminars, technology demonstrations, and special events. In 2018, 3

the EECs conducted 16 customer classes funded through the O&M budget on such topics as electrical 4

safety, power quality, renewable energy, and demand response. In addition to the O&M funded classes, 5

both centers hosted over 1,600 O&M-funded customer events and meetings.9 6

Both EECs provide residential, commercial, industrial, government 7

and institutions, and agricultural customers with information regarding energy efficiency, demand 8

response, renewable generation, codes & standards, ZNE, environmental solutions, electric safety, 9

transportation electrification, and utility programs to help customers make informed decisions about 10

how to safely, effectively, and efficiently manage energy cost and energy use within their homes or 11

businesses. The EECs provide a venue for hosting educational activities in support of SCE’s Clean 12

Power and Electrification Pathway,10 training sessions via SCE’s Workforce Education and Training 13

(WE&T) program, various symposiums, as well as onsite displays, exhibits and demonstrations in two 14

strategically located centers within the service territory. These centers provide customers the ability to 15

view actual equipment in operation while receiving information, education, and hands-on product and 16

service demonstrations by unbiased technical specialists. This activity exposes many residential and 17

business customers to the latest energy saving technologies to which they would otherwise not have 18

access. The EECs also educate and inform customers about their options regarding installation of such 19

technologies, as well as SCE programs that may be available to help customers utilize these 20

technologies. As such, this activity is an important channel for customer education, and SCE will 21

continue to perform similar activities related to the EECs in the Test Year and beyond.11 22

9 Operational expenses for the EECs are jointly funded through Public Goods Charges (PGC) and O&M

funding. The PGC-funded portion of the EECs is not included in this GRC request. An additional 451 seminars and workshops funded through the PGC were presented in 2018 on energy efficiency topics, such as energy-efficient lighting, daylighting, food service, HVAC, and energy management.

10 The Clean Power and Electrification Pathway is a whitepaper, issued in November 2017, that presents SCE’s integrated blueprint for California to reduce greenhouse gas emissions and air pollutants. See https://www.edison.com/content/dam/eix/documents/our-perspective/g17-pathway-to-2030-white-paper.pdf (as of August 11, 2019).

11 To meet continued demand for these offerings, SCE makes incremental facility upgrades to ensure and maintain technological relevance in course offerings, displays, and facilities to keep pace with ongoing market and technology advancements. Facility upgrades and additions at the EECs requiring capital are included in SCE’s EEC capital forecast located in Exhibit SCE-06, Vol. 5.

10

(b) Business Outreach Events 1

To help meet the needs of its diverse business population, whether 2

a Fortune 500 business or a small family-owned business, SCE’s Business Customer Division (BCD) 3

hosts meetings and workshops aimed at educating customers. These meetings and workshops allow SCE 4

to engage in two-way dialog with customers to better understand their business needs and shape future 5

programs and services to align with their feedback. 6

In 2018, BCD hosted 25 events in 11 communities throughout 7

SCE’s service territory (Compton, Long Beach, South Gate, Garden Grove, Westminster, Santa Monica, 8

Ontario, Fullerton, Costa Mesa, Irwindale, and Tulare). These events consisted of the following: Power 9

Briefing seminars, advisory panels, executive customer briefings, signature events, industrial 10

conferences, and the World-Ag Expo. 11

A brief description of each of these types of events follows: 12

Power Briefing Seminars provide education and updates to 13

business customers on regulatory, legislative, rates, and utility 14

programs so they can better manage their energy costs and 15

operations. 16

Advisory Panels support senior business leaders in 17

manufacturing, chain accounts and agricultural segments to 18

share best practices in energy operations and management. 19

These panels also provide a forum for SCE to share and receive 20

feedback on current and future energy programs. 21

Executive Customer Briefings are two-way dialogue meetings 22

between SCE’s president and C-suite leaders from specific 23

customer groups, such as indoor horticulture-focused 24

companies, to gain an understanding of customer barriers 25

associated with adopting energy programs. 26

Signature Events are culturally-focused events recognizing and 27

celebrating businesses, community partnerships, and leaders 28

that honor the contributions ethnic business communities have 29

made toward a clean energy future while also providing SCE 30

11

an opportunity to learn how to continue to meet the needs of 1

these communities. 2

Industrial Conferences consists of hosting industrial 3

conferences, such as the Annual Water Conference, to provide 4

customers with industry expertise and perspective on a wide 5

range of topics, including current statewide and local issues, 6

the latest information on energy efficiency, demand response, 7

and distributed generation technologies and programs. 8

World Ag Expo (EEC-Tulare only) active participation by SCE 9

at the world’s largest outdoor agricultural exposition that 10

supports agricultural and pumping customers. During the 11

event, SCE hosts various education sessions and meetings for 12

customers on topics such as electrical safety, electrical 13

planning processes, demand response programs, self-14

generation technologies, water efficiency/pump efficiency, 15

managing energy costs, rate options/analysis and transportation 16

electrification. 17

In 2018, over 2,500 customers attended these business engagement 18

events and an additional 2,000 people visited SCE’s booth during the World-Ag Expo. These strategic 19

business engagement events are necessary to allow SCE to better understand customer energy needs, 20

issues, and program barriers, and to also engage early adopters as influencers to help drive change. 21

These proactive meetings and events, which are targeted at strategic industries and audiences, serve as a 22

conduit to educate and inform customers, and encourage clean energy choices now and into the future. 23

These events result in customers becoming program pilot participants, ambassadors for energy program 24

adoption in their industry or community, and co-developers of new innovative clean energy programs 25

and solutions, such as the Clean Energy Optimization Pilot.12 As such, business outreach events are an 26

12 The Clean Energy Optimization Pilot is a first-of-its-kind, performance-based, greenhouse gas (GHG)

reduction program. The four-year, $20-million pilot provides performance payments to customers who identify and reduce GHG emissions behind the meter. Compensation is based on actual metered results and is funded through SCE’s GHG cap-and-trade allowance revenue. Success is measured on GHG emissions avoided, rather than the standard method of measuring reduced energy use. This pilot was authorized by D.19-04-010, Decision Approving the Clean Energy Optimization Pilot and Adopting the Parties’ Joint Settlement Agreement, April 25, 2019.

12

important channel for business customer education and facilitates targeted two-way dialogue with SCE 1

customers who may not find other communication channels (e.g., Customer Contact Center) as 2

effective. 3

(2) Multi-Channel Campaigns 4

Multi-Channel Campaigns create awareness of, educate customers about, 5

and encourage adoption of SCE programs, rates, services, and self-service options using several 6

different communication and engagement channels and strategies. In 2018, SCE continued to conduct 7

multi-channel campaigns, and focused on outreach and communication to diverse communities, as 8

described more fully herein. Specifically, SCE conducts multi-channel campaigns that are mainly 9

focused on Program Marketing, Rate and Compliance Marketing, and Self-service Marketing. 10

(a) Description of Multi-Channel Campaigns 11

Program Marketing is focused on educating customers about the 12

various programs offered by SCE, utilizing market research and analytics to better understand customer 13

needs, matching customers with SCE programs and solutions, and reaching customers though the 14

appropriate combination of delivery channels. Rate and Compliance Marketing campaigns provide 15

customers with personalized rate information, including information on SCE.com, to explain rate 16

options, rate comparisons, the ability to proactively switch rate plans, as well as to highlight other 17

helpful programs and services that support customers during rate changes. Finally, Self-service 18

Marketing drives customer awareness and adoption of self-service capabilities, which include all 19

services that allow customers to conveniently access information and complete routine transactions 20

without the assistance of a live customer service representative. These self-service transactions include 21

turn on and transfer of service, outage updates, enrolling in programs, viewing usage information, and 22

applying for various programs. 23

All multi-channel marketing campaigns involve the planning, 24

creation, and optimization of communications, websites, emails, social media, and print materials to 25

drive customer awareness and adoption of SCE rates, programs and services. Each campaign utilizes 26

information developed by the Customer Experience Management13 work activity, including customer 27

research and analytics, to better understand customers’ needs, match customers with SCE programs and 28

solutions, and reach customers though the appropriate combination of delivery channels. SCE also 29

13 See SCE-03, Vol. 5 for more details regarding the Customer Experience Management work activity.

13

utilizes community grassroots organizations, events, and third parties to communicate with customers 1

about SCE’s service offerings. 2

With each marketing campaign, SCE takes every opportunity to 3

encourage customer adoption of related self-service capabilities. Self-service, in general, delivers the 4

highest levels of customer satisfaction (versus other interaction channels) at the lowest cost to serve 5

SCE’s customers.14 By shifting customer transaction volume to self-service digital channels, SCE can 6

reduce costs and provide a more satisfying experience to the customer when compared with a non-7

digital channel.15 In support of this effort, a comprehensive report issued by Accenture highlights 8

findings that customers who interact with their energy provider digitally tend to adopt other programs at 9

a higher rate than customers who do not. Digital interactions are also a less expensive channel to market 10

to customers, resulting in better value for each marketing dollar spent.16 11

(b) Examples of Multi-Channel Campaigns 12

In 2018, SCE conducted various multi-channel campaigns, and 13

similar campaigns will be ongoing through the Test Year. One example is a 2018 marketing campaign 14

that supported California Assembly Bill (AB) 793.17 This multi-channel campaign promoted incentives 15

both for purchasing and installing a device and for enrolling in SCE’s Smart Energy program, which 16

14 Bianchi, Raffaela; Gascal, Gergely; Svoboda, Daniel. “Overcoming Obstacles to Digital Customer Care.”

McKinsey, pp. 2-3, August 2015.

15 Francesco Banfi, Boris Gbahoue, Jeremy Schneider. “Higher Satisfaction at Lower Costs: Digitizing Customer Care.” McKinsey, p. 12, July 2015.

16 See https://www.accenture.com/_acnmedia/accenture/next-gen/insight-unlocking-value-of-digital-consumer/pdf/accenture-new-energy-consumer-final.pdf (as of July 29, 2019). Specifically, a survey contained in the report found the following attributes amongst digitally engaged customers: (1) Higher trust. Forty-one percent of digital consumers state that they trust their energy provider to help them optimize their energy consumption, versus thirty-one percent of non-digital, (2) Higher satisfaction. Sixty-nine percent of digital consumers indicate that they are satisfied with their energy provider—fourteen percentage points higher than those who do not use digital channels, (3) Higher likelihood to share personal information. Digital consumers are about 1.5 times more likely to share their personal or energy usage information than non-digital users, (4) Higher likelihood to participate. Eighty percent of digital consumers indicated they would participate in an energy management program, compared to fifty-nine percent of non-digital users, and (5) Higher likelihood to sign up for energy-related products and services. Seventy percent of digital consumers indicated they would sign up for automated home energy management devices, compared to just forty-eight percent of non-digital consumers.

17 Among other things, AB 793 requires each California utility to develop an outreach program to educate customers about the ability to ascertain real-time energy use data by employing energy management technologies. See Public Utilities Code Sections 717 and 1790.

14

helps customers better manage their energy usage.18 In addition to general outbound communications, 1

SCE employed a segmented approach to reach both residential and non-residential customers, as well as 2

focused efforts to educate income-qualified customers. For example, SCE conducted 388 in-store events 3

at retail locations including Lowes, Best Buy and The Home Depot. Of these, 254 (or 65%) were held at 4

stores located in disadvantaged communities (DACs). 5

As an additional example of this work activity, SCE provides 6

information to customers regarding important rate-related updates. In 2018, a multi-channel campaign 7

was developed and initiated to support the default of business and agricultural and pumping service 8

accounts on eligible rate options to Critical Peak Pricing (CPP), as well as the transition to new Time-9

Of-Use periods for Non-Residential customers effective March 1, 2019 as described in SCE-03, Vol. 10

5.19 The objective of this campaign was to create awareness and help SCE customers prepare for these 11

rate changes by providing information starting in October 2018 with direct mail letters and emails. In 12

January and February 2019, customers received another round of reminder letters and emails, followed 13

by after-care communications in June through September which included a final set of letters and 14

emails. 15

SCE also ran mass media advertising throughout this period to 16

increase awareness (Print, Radio, Digital Display, Search Engine Marketing, Social Media, and Outdoor 17

billboards), with Print and Radio ads also delivered in Spanish, Vietnamese, Chinese and Korean. The 18

mass media campaign delivered a total of over 225 million impressions across all media platforms. This 19

campaign provided awareness of key rate-related updates, as well as promoting helpful solutions such as 20

energy management tools (e.g., My Account, Rate Comparison Tool, Business Energy Advisor and 21

Budget Assistant) to track and manage electricity usage and costs toward bill mitigation. Other examples 22

of rate-related marketing campaigns developed and managed by this team include Residential Rate 23

Reform,20 as well as the marketing, education, and outreach planning for renewable energy rates in 24

18 SCE’s Smart Energy Program is an energy management program that provides up to $150 in rebates for

purchasing a smart thermostat and signing up for the program, as well as up to $40 in annual bill credits for ongoing program participation. See https://pages.email.sce.com/SCESmartBonus/ (as of July 31, 2019).

19 See SCE-03, Vol. 5 Section II.C.3.c.2 where SCE discusses activities associated with market education & awareness and one-time costs for CPP default and new TOU periods.

20 Activities regarding Residential Rate Reform included the development and launch of marketing to support a pilot that would default 400,000 residential customers to a time-of-use (TOU) rate in March 2018. The marketing efforts included creating customer notification campaigns and a mass media campaign increasing

15

disadvantaged communities (DACs), such as the DAC-Green and DAC-Community Solar Green Tariff 1

(CSGT) programs.21 2

(c) Need for Multi-Channel Campaigns 3

Multi-channel marketing is critical to ensure that customers are 4

educated about new and existing rate options, how specific rate plans, programs and services might 5

benefit them, and how their energy usage affects their energy costs and the environment. This activity 6

can help to deflect traffic from higher-cost channels (e.g., phone and manual application processing) by 7

allowing customers to leverage self-service channels to better understand and inquire about their rate 8

options, energy costs, and enroll in beneficial programs and services. This activity also helps meet 9

customers’ expectations about how to interact with SCE, which in turn can improve customer 10

satisfaction. 11

(d) Outreach and Communications to Diverse Communities 12

In D.19.05.030,22 the Commission directed SCE to provide 13

additional testimony demonstrating its commitment to minority outreach and measuring the 14

effectiveness of such outreach. SCE is committed to communicating with its diverse communities in a 15

manner that is both relevant to the customer and their individual needs, as well as in the customer’s 16

preferred language when possible. SCE’s customer base has the following demographic characteristics: 17

A 54% non-White majority (30% Hispanic, 11% Asian/Pacific 18

Islander, 3% African American, 10% Unknown, 46% 19

White/Other).23 20

general awareness of rate plan options among SCE’s diverse residential customers. SCE recorded eligible incremental costs in the Residential Rate Implementation Memorandum Account (RRIMA) consistent with the operation of that memorandum account as shown in SCE’s Commission-approved preliminary statement in its Tariff Book.

21 See Alternate Decision Adopting Alternatives to Promote Solar Distributed Generation in Disadvantaged Communities, D.18-06-027, June 21, 2018 (approving the DAC-Green Tariff and Community Solar Green Tariff programs, including appropriate cost recovery mechanisms).

22 See D.19-05-020, p. 139 (“Future testimony however, should include further evidence demonstrating SCE’s commitment to minority outreach and measuring its effectiveness.”).

23 This demographic data is taken from information compiled by Acxiom in 2019. SCE contracts with Acxiom, a third-party company that collects anonymized customer demographic data, through publicly available information, surveys, and other means, that may be used for targeted marketing.

16

Spanish, Chinese, Vietnamese, and Korean rank as the top 1

languages representing populations “Age 5+ Who Do Not 2

Speak English Very Well.”24 3

4 out of 10 households are likely struggling financially.25 4

As detailed above, SCE delivers multi-channel campaigns to 5

ensure that its diverse customer base is educated about new and existing rate options, beneficial 6

programs and services, as well as tools that help customers understand how their energy usage affects 7

their energy costs and the environment. In 2018, SCE conducted in-language multi-channel campaigns 8

that supported business and agricultural and pumping customers, as well as rebates available as part of 9

SCE’s Smart Energy Program. 10

To support business and agricultural and pumping customers, SCE 11

provided print and radio ads in Spanish, Vietnamese, Chinese and Korean. Total media impressions of 12

44 million were delivered through radio, of which 39% were in a language other than English. SCE also 13

delivered 29 million impressions from print ads in other languages.26 Additionally, SCE reached DACs 14

to promote SCE’s Smart Energy Program by conducting 254 in-store events at Lowes, Best Buy and 15

The Home Depot in DAC locations, representing a 65% DAC coverage ratio out of the total 388 in-store 16

events. 17

SCE remains committed to communicating with diverse 18

communities in 2021 and beyond, as SCE’s service area is home to some of the most diverse 19

populations in the nation. SCE’s marketing practice of audience segmentation takes into consideration 20

the optimal messages and delivery channels to reach SCE’s diverse populations. This practice includes 21

ensuring that messages resonate not only in-language but also from a cultural perspective, as well as 22

media analysis to include appropriate delivery channels (e.g. radio, print, digital, etc.). Partnerships with 23

community-based organizations (CBOs) will continue into future campaign planning and execution to 24

24 Refer to WP SCE-03 Vol. 2, p. 7 – Outreach and Communications to Diverse Communities for additional

details.

25 This demographic data is taken from information compiled by Acxiom in 2015. SCE contracts with Acxiom, a third-party company that collects anonymized customer demographic data, through publicly available information, surveys, and other means, that may be used for targeted marketing.

26 Specifically, of the 29 million impressions, 21 million were in Spanish, 4.5 million in Chinese, 3 million in Korean, and 780,000 in Vietnamese.

17

help reach SCE’s diverse customer base. Through this partnership, SCE provides CBOs with key 1

messaging that impacts their constituents and creates talking points to help drive key messages. 2

b) Comparison of Authorized 2018 to Recorded27 3

The previous section provided an overview of activities performed in the 2018 4

Base Year as part of SCE’s CCE&O efforts. This section presents a comparison of requested and 5

authorized O&M expenses from SCE’s 2018 GRC with the 2018 recorded expenses in the CCE&O 6

GRC Activity, in compliance with D.19-05-020. As shown in Figure II-5, SCE’s recorded expenses for 7

2018 in CCE&O were $203,000 less than the authorized amount, approximately a five percent variance. 8

This variance is within normal operating expectations. 9

27 Refer to WP SCE-07, Vol. 01 – Authorized to recorded.

18

Figure II-4 Customer Communications, Education and Outreach Comparison of 2018 GRC Authorized versus Recorded

(Constant 2018 $000)

c) Scope and Forecast Analysis 1

This section provides an historical variance analysis and an explanation for 2

material year-to-year variations in labor and non-labor O&M expenses for the CCE&O work activity 3

between 2014 and 2018. Then, SCE presents the forecasted O&M labor and non-labor expenses for 4

2019 through 2021, along with a discussion of the reasons for the requested increase in funding for the 5

Test Year 2021. Figure II-5 provides a summarized view of historical and forecasted labor and non-labor 6

O&M for CCE&O. 7

19

Figure II-5 Customer Communications, Education and Outreach

Recorded 2014-18 and Forecast 2019-202128 (Constant 2018 $000)

(1) Historical Variance Analysis 1

(a) Labor 2

Recorded labor declined from 2014 to 2016 by approximately 3

$1.376 million due to Operational Excellence initiatives that reduced the workforce. Between 2016 and 4

2017 recorded labor increased by $736,000 due to enhancement of communications and outreach to 5

business customers, as part of the effort to improve business customer satisfaction. SCE did not fill 6

vacant positions pending the final Commission decision in SCE’s 2018 GRC, which resulted in a 7

decrease of $576,000 between 2017 and 2018 recorded labor. 8

(b) Non-Labor 9

Recorded non-labor costs declined $2.853 million from 2014 to 10

2016 due to Operational Excellence initiatives, including the elimination of certain non-labor activities 11

28 Refer to WP SCE-03, Vol. 2, pp. 2-7, for recorded and forecast financial information.

2014 2015 2016 2017 2018 2019 2020 2021Labor $2,541 $2,229 $1,165 $1,901 $1,325 $1,637 $1,760 $1,760

Non-Labor $3,929 $1,909 $1,076 $1,820 $2,436 $1,760 $2,746 $7,433Other

Total Expenses $6,470 $4,139 $2,241 $3,721 $3,761 $3,397 $4,507 $9,193

Ratio of Labor to Total 39% 54% 52% 51% 35% 48% 39% 19%

Recorded Forecast

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

$9,000

$10,000

2014 2015 2016 2017 2018 2019 2020 2021

Labor Non-Labor Other

20

such as the annual Summer Readiness Campaign. An increase of $744,000 in 2017 was due to activities 1

related to enhancement of business customer communications and outreach, as part of the effort to 2

improve business customer satisfaction. In 2018, non-labor costs increased $616,000 due to increased 3

spending on self-service marketing campaigns. 4

(2) Forecast 5

Historically, operational expenses for the CCE&O work activity have been 6

jointly funded through both O&M and Public Goods Charges (PGC) funds. For the purpose of this GRC 7

application, only the O&M portion of the total operating costs for this work activity is included in the 8

forecasts. SCE’s forecast of Test Year O&M expenses for CCE&O reflects the specific adjustments for 9

labor and non-labor expenses described in detail below. 10

The 2018 Base Year activities for CCE&O are described above. For both 11

labor and non-labor expenses, SCE began with the Base Year, and then made certain Test Year 12

adjustments to the Base Year expenses, as discussed below, which are necessary to accurately reflect 13

SCE’s anticipated CCE&O activities in the Test Year. 14

(a) Labor 15

For the Test Year 2021, SCE forecasts labor expenses of $1.760 16

million, which is an increase of $435,000 over 2018 recorded. Subsection (c) below provides more detail 17

on this forecasted increase in O&M labor. 18

(b) Non-Labor 19

For the Test Year 2021, SCE forecasts non-labor expenses of 20

$7.433 million, which is an increase of $4.997 million over 2018 recorded. Subsection (c) below 21

provides more detail on this forecasted increase in O&M non-labor. 22

(c) Test Year Adjustments 23

SCE’s forecast of Test Year O&M expenses for CCE&O reflects 24

increases in labor and non-labor. These adjustments are described in detail and summarized in Table II-3 25

below. 26

21

Table II-3 2021 Test Year O&M Adjustments

(Constant 2018 $000)

(i) Analytics & Integrated Marketing 1

SCE proposes to implement the Analytics & Integrated 2

Marketing (AIM) initiative to build a new, advanced digital marketing analytics capability that will 3

provide data-driven, technology-enabled capabilities to deliver more relevant, actionable 4

communications to SCE customers and will improve outcomes in terms of affordability (lower cost-to-5

serve), customer satisfaction, and ultimately progress towards California’s GHG reduction goals.29 This 6

important initiative is the primary driver of the requested O&M increase for this BPE in the Test Year 7

and will provide a marketing technology foundation that will allow SCE to understand customer intent, 8

anticipate and monitor their responses to SCE’s marketing communications, and drive optimal customer 9

engagement through all communications and service channels in near-real time. The AIM data-enabled 10

approach will allow SCE to personalize its education and outreach efforts to more precisely drive 11

customers’ energy consumption behavior, product / service adoption, and shift their primary interactions 12

to lower-cost digital channels. 13

29 See https://www.climatechange.ca.gov/ (as of August 9, 2019).

22

SCE’s historically low expenditures, compared to other 1

electric utilities, on marketing communications and analytics30 has resulted in lagging digital customer 2

engagement when compared to industry peers for programs like paperless billing.31 The AIM program 3

will focus on improving customers’ digital engagement, including the adoption of paperless billing and 4

self-service options, which will result in lower operating costs, such as decreased postage, billing, and 5

other mailing costs as well as potentially fewer service contact center calls. Improved digital 6

engagement is expected to also lead to improved customer satisfaction32 – customers are one-third more 7

satisfied when using self-service channels than traditional interactions.33 Further, regular digital 8

communication will help ensure customer contact information remains accurate, and accurate contact 9

information is critical for Public Safety Power Shutoff (PSPS) events and other power outage 10

notifications in order to ensure customer safety. 11

The costs associated with the AIM marketing technology 12

foundation are comprised of specialized vendor-sourced capabilities to support and conduct enhanced 13

data and analytics and implement and operate marketing technology (MarTech) on behalf of SCE; 14

communication costs to update contact data and grow SCE's digital communications base with up-to-15

date information; and MarTech services fees and communications expenses associated with enabling 16

customer enrollment in paperless billing and self-service options.34 17

SCE anticipates that incremental MarTech services will be 18

needed to enable AIM including, but not limited to, a Customer Data Platform (CDP) solution, 19

personalization technologies, campaign management tools, and upgrades to SCE’s marketing 20

30 According to 2018 Kantar Media - Stradegy Online, SCE’s per customer communications expenditure was

nearly 67% lower than the average expenditure of nine large electric utility peers on customer communications.

31 Based on the 2019 J.D. Power Residential Electric Customer Satisfaction Syndicated Study and the 2018 J.D. Power Business Electric Customer Satisfaction Syndicated Study, 51% of SCE’s residential customers and 55% of its business customers stated they received electronic bills, compared to each of the survey's top performers, where 61% of residential customers and 64% of business customers stated they received electronic bills.

32 SCE’s Voice of the Customer data shows higher customer satisfaction when transacting through SCE.com or interactive voice response (IVR), compared to transacting with a live agent. Refer to WP SCE-03 Vol. 2, p. 8 – Voice of the Customer for additional details.

33 See https://www.mckinsey.com/business-functions/operations/our-insights/customers-lives-are-digital-but-is-your-customer-care-still-analog (as of July 25, 2019).

34 Refer to WP SCE-03 Vol. 2, p. 9 – AIM Costs for additional details.

23

automation solution to enable advanced campaign analytics. These technologies are generally procured 1

as cloud-based, Software-as-a-Service (SaaS) with one-time implementation costs and on-going annual 2

subscription fees. 3

Effective implementation and ongoing operation of an 4

advanced MarTech suite of SaaS tools requires specialized skill sets not currently found in SCE’s in-5

house labor pool. To ensure these technologies are implemented efficiently and operated effectively, 6

SCE will source this work through specialized marketing vendors, or agencies. The non-labor vendor 7

costs for implementing and operating the tools are typically based on a time-and-materials fee structure, 8

based on competitively bid Statements of Work in accordance with SCE’s standard Supply Management 9

policies and procedures. 10

The AIM marketing technology foundation will power an 11

integrated, year-round customer engagement campaign model which will enhance and expand upon 12

SCE’s base multi-channel campaigns. As compared to the current state of SCE’s multi-channel 13

campaigns, which often are structured to prioritize individual program goals, the AIM approach will 14

educate and engage customers in a more frequent ongoing and broader conversation about the 15

interconnected options and choices they have as modern energy consumers. This integrated, proactive 16

approach will simplify the messages customers receive through more targeted and timely interactions 17

which will minimize the potential for confusion and message fatigue. 18

AIM’s focus on conducting marketing/outreach and 19

providing service through lower cost channels is expected to help SCE realize average annual savings of 20

$1.250 million between 2021 and 2023.35 Additionally, as a result of the expected increase in paperless 21

billing adoption through AIM, average annual savings of $2.093 million are expected between 2021 and 22

2023.36 The paperless billing savings are derived from reductions in postage and billing operations 23

material costs. These expense savings forecasts are discussed in SCE-03, Vol. 1. To realize these cost 24

35 Refer to WP SCE-03 Vol. 2, p. 10 – AIM Savings from Lower-Cost Marketing Channels for additional

details.

36 Refer to WP SCE-03 Vol. 2, p. 11 – AIM Savings from Conversions to Paperless Billing for additional details.

24

savings, SCE forecasts that its AIM effort will require an additional $5.200 million37 in non-labor O&M 1

in the Test Year 2021 over Base Year recorded costs. 2

(ii) Education and Awareness for CPP Steady State and 3

Building Electrification 4

In March 2019, business service accounts under 200 kW 5

and agricultural and pumping service accounts over 200 kW (close to 280,000 service accounts) began 6

defaulting to Critical Peak Pricing (CPP).38 The CPP rate offers incentives during the summer months in 7

exchange for higher event prices during 12 “CPP event days” each year, typically called on the hottest 8

summer days. SCE engaged in education and awareness in preparation for this transition. 9

With approximately 280,000 service accounts defaulted to 10

CPP and an expected growth of approximately 10 percent annually through 2023, SCE requests 11

additional O&M funds in 2021 and beyond to provide CPP steady state communications. This will 12

provide ongoing education to inform CPP customers of upcoming events and offer tools and resources 13

to help customers manage their energy usage in response to the events and understand the resulting bill 14

impacts. These communications will also help customers better understand their rate options, including 15

bill protection for the first year of enrollment and the option to de-enroll from the CPP rate. Costs 16

include direct mail, email, and other digital communications to remind customers of upcoming summer 17

events and direct messaging to notify customers when an event begins and ends. 18

In addition to communications about pricing, SCE also 19

educates customers about clean energy programs and tools. For example, as SCE develops programs to 20

transform the market for end-use equipment in buildings39 to meet the State’s carbon reduction goals, 40 21

customers will need increased awareness of their options to shift from on-site combustion fuels to clean 22

37 Refer to WP SCE-03 Vol. 2, p. 9 – AIM Costs for additional details.

38 In D.16-03-030, the Commission required SCE to provide default CPP for customers with demands less than 200 kW and large agriculture and pumping customers with demands over 200 kW. SCE filed a Rate Design Window application, A. 16-09-003 proposing changes to the CPP default and on March 1, 2019, SCE implemented orders in D.18-07-006.

39 Refer to SCE-03, Vol. 5, Section II.C.3.a.2 for additional details regarding the Building Electrification (BE) program.

40 https://ww3.arb.ca.gov/html/fact_sheets/2030_renewables.pdf (as of August 16, 2019); see also SCE-1, Vol. 1, p. IV for SCE commitment to helping the state meet its environmental goals.

25

electricity. Current research41, suggests low awareness amongst customers and contractors/installers of 1

building space and water heating as a cost-effective component to help achieve California's GHG 2

emission reduction goals.42 In order to help transform this market, SCE requests additional O&M 3

expenses for mass media buys to begin the process of increasing awareness and educating customers 4

about new emerging technologies they can adopt to support California’s clean energy future. 5

SCE is requesting a $1.482 million increase to the Test 6

Year adjustment for CPP Steady State and Building Electrification education and awareness.43 7

(iii) Customer Communications, Education and Outreach 8

Previously Unfilled Positions 9

CCE&O had approximately four full-time-equivalent 10

vacancies44 in 2018 that will be filled for 2019 and are expected to continue through 2021 and beyond. 11

These positions were not filled pending a Final Decision in SCE’s 2018 GRC proceeding. 12

(d) Summary of Request 13

As shown below in Figure II-6, for the 2021 Test Year, SCE 14

forecasts $9.193 million in O&M expenses for CCE&O, an increase of $5.432 million, or 144 percent 15

compared to the 2018 Base Year O&M expenses of $3.761 million. 16

41 https://www.ethree.com/wp-

content/uploads/2019/04/E3_Residential_Building_Electrification_in_California_April_2019.pdf.

42 See California Energy Commission’s Deep Decarbonization in a High Renewables Future, p. 32, where data shows that the majority of residential space and water heating equipment sales are natural gas, liquid propane, and electric resistance units. https://www.ethree.com/wp-content/uploads/2018/06/Deep_Decarbonization_in_a_High_Renewables_Future_CEC-500-2018-012-1.pdf (as of August 1, 2019).

43 Refer to WP SCE-03 Vol. 2, p. 12 – Education and Awareness for Critical Peak Pricing (CPP) Steady State and Building Electrification for additional details.

44 Refer to WP SCE-03 Vol. 2, p. 13 – CCE&O Previously Unfilled Positions for additional details.

26

Figure II-6 Customer Communications, Education and Outreach

Comparison of 2018 Base Year to 2021 Test Year (Constant 2018 $000)

d) Basis for O&M Cost Forecast 1

The 2018 Base Year activities for Customer Communication, Education 2

and Outreach expenses are described in Section II.D.1.a of this Volume. The Last Recorded Year 3

accurately reflects the expense level associated with Base Year activity levels that are planned to 4

continue through the Test Year, plus the adjustments proposed above. For these reasons, the Last 5

Recorded Year is the appropriate basis for forecasting Test Year labor and non-labor expenses.45 6

45 The decision to use Last Recorded Year as the basis for the Test Year labor and non-labor O&M expense

forecast for Customer Communication, Education and Outreach is consistent with the direction provided in D.04-07-022 and D.89-12-057, wherein the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the Last Recorded Year is the appropriate basis for estimating Test Year expenses. Although there have been variations year-to-year, with an uptick the last two years as a result of costs stabilizing after Operational Excellence efforts, overall O&M expenses have generally trended downward over the period 2014-2018.

27

2. Escalated Complaints and Outreach 1

a) Work Description and Need for Activities 2

The Escalated Complaints and Outreach work activity is carried out by SCE’s 3

Consumer Affairs organization. The Consumer Affairs organization reviews, investigates and responds 4

to customer disputes that are received by SCE. While customer disputes are received from a variety of 5

sources, the typical disputes received and addressed by Consumer Affairs are those that come through 6

the Commission, SCE and Edison International, elected officials, social media channels (e.g., Facebook, 7

Twitter, Instagram), Better Business Bureau, and general correspondence addressed to the SCE’s 8

corporate office. Table II-4 below details the number of inquiries and complaints handled by Consumer 9

Affairs from 2014-2018, showing an increase of 20 percent from 2017 to 2018 alone, and an overall 4.5 10

times increase from 2014 to 2018. In resolving customer disputes, the Consumer Affairs organization 11

also adheres to SCE Rules and Tariffs, provides resolution to issues, and identifies opportunities to 12

mitigate future recurrence to improve customers’ experiences with SCE. This work activity enables SCE 13

to adequately address escalated customer complaints received annually, including those received by the 14

Commission, elected officials, and social media channels (e.g., Facebook, Twitter, Instagram). 15

Table II-4 Inquiries and Complaints Resolved by Consumer Affairs

NOTE: The large increase in social media inquiries between 2016 and 2017 was tied primarily to introduction of Facebook Messenger for businesses, and SCE’s discontinuation of the email option.

In addition to dispute resolution, SCE’s Consumer Affairs organization performs 16

the following activities. 17

Line No. Description 2014 2015 2016 2017 2018

1 Telephone Complaints 2,109 2,803 3,347 3,221 2,674

2 Informal Complaints 770 864 865 931 890

3 Written Complaints 356 373 707 731 593

4 Social Media

Inquiries/Complaints 6,783 14,301 18,334 33,350 41,812

5 Total Complaints and

Inquiries

10,018 18,341 23,253 38,233 45,969

28

Assistance for Vulnerable Customers. Consumer Affairs advocates for SCE’s 1

vulnerable customers, especially those with financial difficulties or medical conditions. For example, 2

SCE educates customers regarding its Medical Baseline program, which is available to SCE customers 3

that require electric-powered medical support equipment in their homes. Customers enrolled in Medical 4

Baseline are granted a greater allocation of the lowest-cost electricity (Baseline Allocation) each month, 5

which reduces their overall energy costs. In support of the Medical Baseline program, Consumer Affairs 6

works with community-based organizations (CBOs), government agencies, disability and senior 7

organizations, senior centers, and regional centers to educate customers and service providers about SCE 8

rates, programs, and services, as well as to help identify customers who might qualify for Medical 9

Baseline. As shown in Table II-5, enrollment in Medical Baseline has grown steadily from 2014 with 15 10

percent higher total participation in 2018 than in 2014. 11

Table II-5 Historical Medical Baseline Participants by Type

2014-2018

Medical Baseline Customer Assistance. SCE’s Consumer Affairs group oversees 12

additional activities for SCE’s Medical Baseline customers, particularly those identified as Critical 13

Care.46 For example, SCE consistently attempts to collect preferred alternate contact information for 14

each Medical Baseline customer through the customer’s Medical Baseline application, renewal 15

applications, community meetings and other interactions with its customers. In an annual letter sent to 16

all Medical Baseline customers, SCE further reminds such customers to update their contact information 17

and plan for emergencies, such as establishing a back-up plan, when electricity may not be available. 18

46 Critical Care Customers are defined as Medical Baseline Customers who cannot be without electrically-

operated medical equipment for more than two hours.

Line No.  Medical Baseline Enrollment Category  2014  2015  2016  2017  2018 

1  Critical Care  15,149  15,311  15,868  16,419  17,433 

2  Non‐Critical Care  67,800  70,653  72,727  74,512  77,760 

3  Total  82,949  85,964  88,595  90,931  95,193 

 

29

Outage Assistance. In addition, Consumer Affairs provides outage assistance 1

beyond that described above for Medical Baseline customers. For example, in situations when Critical 2

Care customers cannot be reached regarding an extended outage, Consumer Affairs will attempt 3

additional means, including sending a field representative to the customer’s residence to inform these 4

customers of the outage, which enables these customers to be better prepared.47 Consumer Affairs may 5

also distribute ice, water, flashlights, and safety information to customers who are without power. 6

Historically, these distribution events have occurred once or twice per year and are usually in a single 7

geographical location. However, in the current environment of increased fire risk and SCE’s enhanced 8

operational practices to include greater use of PSPS, Consumer Affairs resources may be engaged in 9

expanding assistance to the public through local assistance and community resource centers as needed. 10

Local Assistance centers operated by the county often remain active for weeks following an event which 11

allows SCE to dedicate employees full time to these locations in order to serve the needs of customers 12

impacted by events. 13

Assistance with Credit Disconnections. Consumer Affairs also helps customers 14

enrolled in SCE’s Critical Care program avoid credit-related disconnections. Specifically, SCE’s Credit 15

and Payment Services department provides advance notice to Consumer Affairs whenever SCE’s most 16

vulnerable, or Critical Care customer accounts are subject to disconnection. Consumer Affairs attempts 17

to reach these customers to alert them that they are at risk of disconnection, to make payment 18

arrangements, and, if applicable, to provide information regarding agencies that may be able to aid the 19

customer with bill payment. When Consumer Affairs is unable to contact customers through phone or 20

direct mail, the group may request that Wellness Checks be performed by local law enforcement or 21

Adult Protective Services. 22

Other Customer Assistance. SCE’s Consumer Affairs group also oversees the 23

Good Neighbor Program, which connects SCE customers and members of the community with 24

organizations whose mission is to provide them with social services. Additionally, in response to 25

disasters, SCE’s Consumer Affairs leads the support and staffing efforts at local assistance centers to 26

provide in-person support for customers impacted by the event. Finally, Consumer Affairs oversees the 27

deployment of Consumer Protections (R.18-03-011) for customers impacted by disasters declared by 28

Governor Proclamation. 29

47 Notifying Critical Care Customers of an extended outage is required by R.18-12-005 (SCE’s De-Energization

Rulemaking).

30

b) Comparison of Authorized 2018 to Recorded48 1

Figure II-7 below compares the requested and authorized O&M expenses from 2

SCE’s 2018 GRC with the 2018 recorded expenses in the Escalated Complaints and Outreach GRC 3

work activity, in compliance with D.19-05-020. As shown in Figure II-7, SCE’s recorded expenses for 4

2018 in Escalated Complaints and Outreach were more than the authorized amount by $0.019 million, 5

approximately a two percent variance. This variance is within normal operating expectations. 6

Figure II-7 Escalated Complaints and Outreach

Comparison of 2018 GRC Authorized versus Recorded (Constant 2018 $000)

c) Scope and Forecast Analysis 7

This section provides an historical variance analysis and an explanation for 8

material year-to-year variations in labor and non-labor O&M expenses for the Escalated Complaints and 9

Outreach work activity between 2014 and 2018. Then, SCE presents the forecasted O&M labor and non-10

48 Refer to WP SCE-07, Vol. 01 – Authorized to recorded.

31

labor expenses for 2019 through 2021, along with a discussion of the reasons for the requested increase 1

in funding for the Test Year 2021. Figure II-8 provides a summarized view of historical and forecasted 2

labor and non-labor O&M costs for Escalated Complaints and Outreach. 3

Figure II-8 Escalated Complaints and Outreach

Recorded 2014-2018 and Forecast 2019-202149 (Constant 2018 $000)

(1) Historical Variance Analysis 4

(a) Labor 5

Recorded labor declined from 2014 to 2017 by $628,000 due to 6

Operational Excellence initiatives that reduced the workforce. The increase of $259,000 in 2018 was due 7

to the need to handle steadily growing number of inquiries and complaints by implementing a rotational 8

program to bring SCE staff from other departments to support the Consumer Affairs team for a 12-week 9

period. The labor costs during this rotation were recorded to the Escalated Complaints and Outreach 10

work activity. Additionally, as a result of rapidly increasing number of customer inquiries through social 11

49 Refer to WP SCE-03, Vol. 2, pp. 15-19, for recorded and forecast financial information.

32

media channels, Consumer Affairs hired new staff members with the necessary social media skills to 1

keep pace with customers’ preferred channels for interacting with SCE. 2

(b) Non-Labor 3

Recorded non-labor declined from 2014 to 2016 by $41,000 due to 4

Operational Excellence initiatives that reduced the workforce. The increase of $27,000 from 2016 to 5

2018 was due to the need to support local assistance centers as required by D.18-03-011, including costs 6

associated with lodging, meals, mileage and other travel costs associated with deployment of staff to 7

various local assistance center locations. 8

(2) Forecast 9

The 2018 Base Year activities for Escalated Complaints and Outreach are 10

described above. For both labor and non-labor expenses, SCE began with the Base Year, and then made 11

certain Test Year adjustments to the Base Year expenses, as discussed below, which are necessary to 12

accurately reflect SCE’s anticipated Escalated Complaints and Outreach activities in the Test Year. 13

SCE’s forecast of Test Year O&M expenses of $1.303 million for Escalated Complaints and Outreach 14

reflects an overall increase of $138,000 over the Base Year. The Test Year adjustment is discussed 15

below. 16

(a) Labor 17

For Test Year 2021, SCE forecasts labor expenses of $1.268 18

million for this work activity, which represents an increase of $142,000 from 2018 recorded labor 19

expenses. This increase in labor represents two additional resources to manage increased social media 20

communications and coordination, as well as new, real-time customer communications and issue 21

resolution stemming from SCE’s Voice of the Customer initiatives.50 22

(b) Non-Labor 23

For the Test Year 2021, SCE forecasts non-labor expenses of 24

$35,000 for this work activity. This amount, which represents a decrease of $4,000 compared to 2018 25

recorded, is requested for employee training and travel expenses, customer collateral which explains 26

programs for critical care and medical baseline customers, and attendance/sponsorship of customer 27

outreach events. 28

50 Refer to SCE-03, Vol. 5, Section II.C.1 for details about Voice of the Customer initiatives.

33

(c) Test Year Adjustments 1

Table II-6 Escalated Complaints and Outreach 2021 Test Year O&M Adjustments

(Constant 2018 $000)

(i) Increased Consumer Affairs Support 2

The increased Consumer Affairs support will consist of one 3

advisor position which will oversee new program development and enhanced operational efficiencies in 4

the areas impacting SCE’s social media and voice of the customer programs for $94,000. The addition 5

of a customer service representative at $48,000 is necessary to support the continued increase in social 6

media communications and voice of the customer needs. These two added positions equal the 2021 Test 7

Year expense labor adjustment of $142,000. The non-labor expenses for the 2021 Test Year are 8

forecasted to be $4,000 less than the Base year, resulting in a total increase of $138,000 in Test Year 9

2021 for this work activity. 10

(d) Summary of Request 11

As shown below in Figure II-9, for the 2021 Test Year, SCE 12

forecasts $1.303 million in O&M expenses for Escalated Complaints and Outreach, an increase of 13

$138,000, or 12 percent compared to the 2018 Base Year O&M expenses of $1.165 million. The reasons 14

for this increase were discussed above. 15

34

Figure II-9 Escalated Complaints and Outreach

Comparison of 2018 Base Year to 2021 Test Year (Constant 2018 $000)

d) Basis for O&M Cost Forecast 1

The 2018 Base Year activities for Escalated Complaints and Outreach expenses 2

are described in Section II.D.2 of this Volume. The Last Recorded Year accurately reflects the expense 3

level associated with Base Year activity levels that are planned to continue through the Test Year, plus 4

the adjustments proposed above. For these reasons, the Last Recorded Year is the appropriate basis for 5

forecasting Test Year labor and non-labor expenses.51 6

51 The decision to use Last Recorded Year as the basis for the Test Year labor and non-labor O&M expense

forecast for Escalated Complaints and Outreach is consistent with the direction provided in D.04-07-022 and D.89-12-057, wherein the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the Last Recorded Year is the appropriate basis for estimating Test Year expenses. Although there have been variations year-to-year, with an uptick last year as a result of costs stabilizing after Operational Excellence efforts, overall O&M expenses have generally trended downward over the period 2014-2018.

35

3. External Communications 1

a) Work Description 2

This section provides a review of the activities required to effectively and 3

efficiently educate external audiences about a range of topics including, notably, safety, outages/storms 4

and clean energy initiatives to meet the state’s goals. The end-to-end process for executing these 5

communications includes planning, production, distribution and measurement. The work activity 6

categories discussed below include the following: (1) Public Education, (2) Key Initiatives/Media 7

Relations and (3) Digital Communications. 8

SCE’s service territory covers 50,000 square miles and includes five media 9

markets, one of which is the second largest in the United States.52 Corporate Communications, on behalf 10

of the company, communicates with external audiences through multiple channels, including 11

newspapers, television, radio, out-of-home channels such as billboards and bus shelters, and digital 12

media channels including the web and social media. Customers are increasingly using new technologies, 13

and they expect to receive real-time communications, especially during service interruption, through 14

their channel of choice. 15

To deliver important messages to customers and the general public, SCE must 16

communicate with an ethnically and linguistically diverse set of customers. Approximately 46 percent of 17

SCE’s residential customers speak a language other than English at home, with 44 percent of those 18

customers (20 percent of overall customers) speaking English less than “very well.”53 Corporate 19

Communications delivers many messages in multiple languages, including Spanish, Chinese, Korean 20

and Vietnamese, to achieve maximum customer and public awareness of key information. 21

To follow is a detailed look at the work activity categories that support 22

External Communications. 23

(1) Public Education 24

The first work activity category is Public Education. Examples of the work 25

that supports Public Education include mass media buys, translations, communications measurement 26

and video/graphics production. The primary driver of this work activity category is public safety 27

52 Top 100 Media Markets, News Generation, http://www.newsgeneration.com/broadcast-resources/top-100-

radio-markets/.

53 Determined by Nielsen and American Community Survey based on detailed analyses of 2010 census data.

36

advertising. The purpose of public safety advertising is to help the population of 15 million people54 in 1

SCE’s service territory stay safe around electricity, and specifically the electrical equipment that delivers 2

electricity. The highest priority subject is downed power lines, but other topics include tree trimming 3

and metallic balloons (which cause power outages when they contact power lines and were responsible 4

for over 1,000 outages in 2018). The functional work required to support public safety advertising 5

includes media planning and buying, campaign strategy, creative development, advertisement 6

production, translations and analytics/reporting. 7

In addition to safety ads, translations are required for other critical 8

customer-facing information distributed via SCE.com, news releases and stories online in Energized by 9

Edison. 10

Communications research and measurement (“Analytics”) and video and 11

graphics production (“Creative Services”) are resources that support virtually all External 12

Communications activities. Analytics include capturing, analyzing and reporting on structured and 13

unstructured data: (1) to ensure accountability with detailed reporting on past activities, and (2) to 14

inform efficient and effective decision-making on future communication activities. The Creative 15

Services resources form an in-house production team that generates digital and printed materials to 16

support everything from crisis and outage communications to safety to clean energy. 17

Public Education is one of the controls used to reduce the risk of contact 18

with energized equipment as identified in the RAMP report.55 The control includes two activities: (1) 19

Public Safety Outreach, and (2) At-Risk Worker Safety Outreach. Public Safety Outreach focuses on 20

informing the public on actions to take when encountering a downed electrical wire or overhead 21

equipment. Such efforts include billboards, television and radio announcements, digital and social 22

media, signage on SCE vehicles, community outreach and information distributed at community events. 23

At-Risk Worker Safety Outreach provides mailers, flyers and other outreach to third-party contractors, 24

54 The estimated population in SCE’s service territory is based on inputs from the 2010 census data, the average

number of residents per household, and the total number of customer accounts.

55 See https://www.cpuc.ca.gov/uploadedFiles/CPUC_Public_Website/Content/Safety/Risk_Assessment/SCE%20RAMP%20REVIEW%20-%2005-24-2019.pdf (as of July 25, 2019).

37

agricultural workers, first responders, and tree trimmers to inform them of the dangers of working 1

around energized equipment.56 2

(2) Key Initiatives/Media Relations 3

This work activity category is dedicated to effectively achieving much of 4

the earned media communications. The labor tied to this activity is split into two focus areas: (1) 5

reactive/near-term/unplanned communications on emergent issues such as storms, wildfires, outages and 6

any other ad hoc media inquiries; and (2) proactive/longer-term/planned communications on topics like 7

transportation electrification, achieving the state’s greenhouse as reduction goals and wildfire mitigation 8

efforts. 9

The resources assigned to this effort develop communications that are 10

delivered primarily through the media with the ultimate goal of having these communications delivered 11

to audiences including SCE customers and the general public who work and live in SCE’s service 12

territory. The outputs for this work activity include news releases, media statements, interviews and 13

briefings, fact sheets, and question-and-answer documents. The team performing this work activity 14

answers inquiries to SCE’s 24-hour media hotline and serves as public information officers during 15

emergencies. They also provide support for the company’s digital publishing channel, Energized by 16

Edison, whose purpose is to keep various audiences informed on issues that impact SCE’s customers. 17

(3) Digital Communications 18

The third work activity category is Digital Communications and its 19

operations are supported by the tools, software and labor required to create, curate, manage, publish and 20

measure the effectiveness of content delivered primarily to customers across various web and social 21

media properties. In 2018, this group was responsible for generating more than 150 million total digital 22

impressions via publishing around topics such as safety, outages, and crisis communications.57 23

In addition to publishing, a growing component of Digital 24

Communications continues to be Social Customer Service.58 Social Customer Service has seen 25

significant year-over-year growth – total responses grew by 517 percent from 6,783 in 2014 to 41,812 in 26

56 For the Public Outreach control, no comments were included in SED’s RAMP report dated May 24, 2019 or

intervenors’ comments submitted on SED’s report.

57 In 2018, SCE generated 122 million impressions via Facebook and Instagram and 33 million impressions on Twitter.

58 Social Customer Service is defined as all customer service activity that is transacted on social media channels, primarily Facebook and Twitter.

38

2018 – which has created a commensurate need for resourcing. The core social media team, which 1

staffed in Corporate Communications, is responsible for all of the non-labor expenses related to this 2

activity, as well as supplementing labor needs as needed in times of crisis. 3

The core social media team contributes to SCE’s social customer service 4

output in the following three ways: funding the Sprout Social community management tool that is used 5

to moderate all of SCE’s branded social media activity (including the software to support the chatbot); 6

designing and refining the chatbot;59 and supporting the Customer Service agents as needed during 7

crises when we have increased traffic and/or critical inquiries that extend beyond traditional work 8

schedules. 9

The major non-labor expense for Digital Communications is licenses for 10

software and tools including the previously mentioned Sprout Social and Percolate, the latter of which is 11

required to effectively manage content production and flow, and also enables measurement of 12

communications and resource allocations. 13

b) Need for Activity 14

Safety messaging is a top priority for all audiences, with messages being 15

delivered across most primary external channels, including advertising, web, social media, general and 16

ethnic media, as well as through public safety education programs for school children and at-risk 17

workers including construction workers, agricultural workers, tree trimmers and first responders. The 18

public safety advertising campaign is delivered to the public through mass media in multiple languages 19

and plays a critical role in educating the public about how to stay safe around electricity/power 20

equipment. The value and importance of this activity is underscored by research (see Figure II-10 21

below) which over many years has demonstrated a strong correlation between safety advertising spend 22

and customer awareness of actions they can take that can mitigate risk of injury or death. 23

59 A Chatbot is defined as an automated response agent that makes the initial contact with customers who make

inquiries over social media channels such as Facebook and Twitter. For basic inquiries, such as how to report an outage, it is designed to completely resolve the task. For more complex inquiries, it is designed to gather basic information to reduce the time required by customer agents to research and resolve the inquiry.

39

Figure II-10 Awareness vs. Media Spend

2016-2018, By Quarter

SOURCE: Awareness: CAT (Customer Awareness Tracking) 2016-18 Spend: tracked internally.

External Communications activities are also necessary to mitigate the risk of 1

customers not having access to critical and potentially life-saving information during major crises and 2

catastrophes, which are occurring more frequently for residents in the state of California. The personnel 3

responsible for performing this work activity are trained to be able to effectively deliver critical 4

information to customers – and various other stakeholders – during crises through their extensive and 5

ongoing training in the National Incident Management System (NIMS). 6

External communications activities are also needed to educate customers about 7

making cleaner energy choices to help meet the state’s commitment to a carbon-free future. 8

c) Comparison of Authorized 2018 to Recorded60 9

Figure II-11 below compares the requested and authorized O&M expenses from 10

SCE’s 2018 GRC with the recorded expense for External Communications in compliance with D.19-05-11

020. As shown in Figure II-11, SCE’s recorded expenses in 2018 External Communications were more 12

than authorized by $0.599 million, which equals approximately a five percent variance. This variance is 13

60 Refer to WP SCE-07, Vol. 01 – Authorized to recorded.

40

within normal operating expectations, and the increase was due to the production of new safety 1

advertising creative to refresh the old campaign that was last updated in 2015. 2

Figure II-11 External Communications

Comparison of 2018 GRC Authorized versus Recorded (Constant 2018 $000)

d) Scope and Forecast Analysis 3

This section provides an historical variance analysis and an explanation for 4

material year-to-year variations in labor and non-labor O&M expenses for the External Communications 5

work activity between 2014 and 2018. Then, SCE presents the forecast O&M labor and non-labor 6

expenses for 2019 through 2021, along with a discussion of the reasons for the requested increase in 7

funding for the Test Year 2021. Figure II-12 provides a summarized view of historical and forecasted 8

labor and non-labor O&M for External Communications. 9

$10,540 $10,540 $11,139

0

2,000

4,000

6,000

8,000

10,000

12,000

2018 Request 2018 Authorized External Communications 2018 Recorded

External Communications

$599

41

Figure II-12 External Communications

Recorded 2014-18 and Forecast 2019-202161 (Constant 2018 $000)

(1) Historical Variance Analysis 1

(a) Labor 2

From 2014 to 2018, recorded labor costs decreased by $1.36 3

million as a result of personnel reductions realized from a combination of the following: employee 4

attrition (positions not refilled), efficiencies gained from reorganization, and an Operational Excellence 5

initiative. The $0.949 million reduction that was realized in 2015 was the result of a decision not to 6

backfill positions that were either already vacant or became vacant during the year. The following year, 7

in 2016, Corporate Communications executed an Operational Excellence initiative that further 8

consolidated work activities and generated additional labor savings of $0.618 million. Corporate 9

Communications labor remained generally flat over the next two years. There was a slight increase in 10

2018 as the department was at the planned staffing level. 11

61 Refer to WP SCE-03, Vol. 2, pp. 21-25, for recorded and forecast financial information.

2014 2015 2016 2017 2018 2019 2020 2021Labor $4,074 $3,125 $2,507 $2,544 $2,714 $2,552 $2,453 $2,714

Non-Labor $11,343 $14,262 $7,767 $8,306 $8,425 $8,493 $8,599 $8,599Other

Total Expenses $15,417 $17,387 $10,274 $10,850 $11,139 $11,045 $11,052 $11,313

Ratio of Labor to Total 26% 18% 24% 23% 24% 23% 22% 24%

Recorded Forecast

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

$16,000

$18,000

$20,000

2014 2015 2016 2017 2018 2019 2020 2021

Labor Non-Labor Other

42

(b) Non-Labor 1

From 2014 to 2015, the $2.919 million increase in non-labor O&M 2

expenses was due to incremental production and media costs for new public safety advertisements. 3

Advertising undergoes a major creative refresh approximately every three years to avoid message 4

fatigue and decline in customer awareness. When a new advertisement campaign is produced, it is 5

standard practice to launch with a more concentrated media buy to introduce customers to the new 6

advertisements. From 2015 to 2016, the $6.495 million decrease in non-labor was due largely to an 7

Operational Excellence initiative resulting in a consolidation of work activities and research tools, 8

research tools, subscriptions, some media services, and renegotiated vendor contracts. Further cost 9

efficiencies were realized by shifting media from television to digital and reducing website translations. 10

In 2017, non-labor expenses increased to support compliance-related advertising and then remained 11

relatively flat into 2018. 12

(2) Forecast 13

(a) Labor 14

As shown in Figure II-12, labor expenses have been relatively flat 15

from 2016 through 2018 with minor increases of one percent in 2017 and seven percent in 2018. The 16

activity levels in the Base Year are planned to continue in the Test Year and therefore, the Last 17

Recorded Year forecast method is the most appropriate forecast method for the Test Year labor forecast 18

of $2.714 million.62 19

(b) Non-Labor 20

As shown in Figure II-12, non-labor expenses were relatively 21

stable in 2017 and 2018. The Last Recorded Year amount of $8.425 million is an appropriate basis to 22

start with for the Test Year forecast because it accurately reflects the expected base level of External 23

Communications activities for the Test Year. SCE then made one Test Year adjustment to the Last 24

Recorded Year non-labor expenses, which has been calculated relative to 2018 activity levels and 2018 25

62 The decision to use Last Recorded Year as the basis for the Test Year O&M labor forecast for External

Communications is consistent with the direction provided in D.04-07-022 and D.89-12-057, wherein the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the Last Recorded Year is the appropriate basis for estimating Test Year expenses.

43

recorded non-labor O&M expenses and is necessary for SCE to perform the anticipated External 1

Communications activities in the Test Year.63 2

For Test Year 2021, SCE forecasts non-labor expenses of $8.599 3

million which represents an increase of $174,000, or two percent, from 2018 recorded of $8.425 million. 4

The Test Year adjustment is for increases in software licensing, mailing costs for at-risk worker safety 5

messaging and license fees for access to firewalled news content and research.64 6

(3) RAMP Integration 7

Public Outreach is one of the controls used to reduce the risk of contact 8

with energized equipment as identified in the RAMP report. The control includes two activities: (1) 9

Public Safety Outreach, and (2) At-Risk Worker Safety Outreach. Public Safety Outreach focuses on 10

informing the public on actions to take when encountering a downed electrical wire or overhead 11

equipment. Such efforts include billboards, television and radio announcements, digital and social 12

media, signage on SCE vehicles, community outreach and information distributed at community events. 13

At-Risk Worker Safety Outreach provides mailers, flyers and other outreach to third-party contractors, 14

agricultural workers, first responders, and tree trimmers to inform them of the dangers of working 15

around energized equipment. 16

(a) Reconciliation Between RAMP and GRC for Public Outreach 17

Control 18

As shown in Table II-7 below, the increased annual forecast of 19

$1.005 million for 2019-2021 is due to two factors. The first factor is rising demand for advertisement 20

space due to a strong economy, increased ad spending for local and presidential election cycles, and the 21

growth in digital platforms. The second factor is the need to refresh advertisements more often to avoid 22

message fatigue and compete with other messages delivered through more channels and devices. This 23

results in higher creative and production costs on an annual basis. The increase is necessary to ensure 24

that SCE reaches everyone in the service territory with important public safety messages. 25

63 The decision to use Last Recorded Year as the basis for the Test Year O&M non-labor forecast for External

Communications is consistent with the direction provided in D.04-07-022 and D.89-12-057, wherein the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the Last Recorded Year is the appropriate basis for estimating Test Year expenses.

64 Refer to WP SCE-03 Vol. 2, p. 26 – External Communications for additional details.

44

Table II-7 External Communications – Controls

O&M Forecast: RAMP to GRC Variance (Nominal 2018 $000)

e) Basis for O&M Cost Forecast 1

The 2018 Base Year activities for External Communications expenses are 2

described in Section II.D.3 of this Volume. The Last Recorded Year accurately reflects the expense level 3

associated with Base Year activity levels that are planned to continue through the Test Year, plus the 4

adjustments proposed above. For these reasons, the Last Recorded Year is the appropriate basis for 5

forecasting Test Year labor and non-labor expenses.65 6

65 The decision to use Last Recorded Year as the basis for the Test Year labor and non-labor O&M expense

forecast for External Communications is consistent with the direction provided in D.04-07-022 and D.89-12-057, wherein the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the Last Recorded Year is the appropriate basis for estimating Test Year expenses. Although there have been variations year-to-year, with a slight uptick the last two years as a result of costs stabilizing after Operational Excellence efforts, overall O&M expenses have generally trended downward over the period 2014-2018.

RAMP Risk 

RAMP

 ID

RAMP Control 

Name

Filing 

Name 2019 2020 2021

RAMP 5,451$     5,451$     5,451$    

GRC 6,455$     6,455$     6,512$    

Variance 1,005$     1,005$     1,061$    

Contact with 

Energized 

Equipment

Public OutreachC2