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9 Russell G. Worden Managing Director, State Regulatory Operations May 22, 2017 ADVICE 3605-E (U 338-E) PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION SUBJECT: Southern California Edison Company s Plan to Comply With Resolution E-4820 PURPOSE Pursuant to Resolution E-4820 (Resolution), issued April 6, 2017, Southern California Edison Company (SCE) submits this advice letter requesting approval from the California Public Utilities Commission (Commission) for SCE s plan to comply with the Resolution. BACKGROUND Governor Brown signed Assembly Bill (AB) 793, and enacted Public Utilities Code Section 717 into law on October 8, AB 793 required the Commission to oversee the development and implementation by the California investor-owned utilities (IOUs) 1 of a demand-side management program that will provide incentives to residential or small / medium business (SMB) customers who acquire energy management technology (EMT) for use in their homes or places of business. 2 The legislation defines energy management technology as a product, service, or software that allows a customer to better understand and manage electricity or gas use in the customer s home or place of business. 3 AB 793 also required the IOUs to develop a plan to educate customers about the program and provide annual program savings updates to the Commission. On June 10, 2016, Administrative Law Judges (ALJ) Hymes and Fitch issued Joint ALJ s Ruling Providing Guidance on Compliance with AB 793 Activities (Ruling). The 1 The IOUs are Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Southern California Gas Company (SCG), and SCE. 2 Public Utilities Code Chap. 4, Article 1, Id. P.O. Box Rush Street Rosemead, California (626) Fax (626)

10 ADVICE 3605-E (U 338-E) May 22, 2017 Ruling was intended to provide more comprehensive direction on the content expected for IOU proposals and process for the implementation of the Legislative mandates. 4 The Ruling also allowed the IOUs two options for filing their AB 793 proposals. An IOU seeking to use currently authorized funding to fulfill its AB 793 requirements could file its proposal via a Tier 2 advice letter. 5 An IOU seeking new funding was required to file its proposal as a new application. 6 SCE submitted advice letter, 3446-E, on August 1, However, following subsequent correspondence with the Commission Staff, SCE and the other IOUs were instructed to file supplemental advice letters that had removed the joint IOU marketing plan, which was to be filed as a standalone advice letter. 7 SCE filed its Supplemental advice letter, 3446-E-A, with the Joint IOU marketing plan removed, on August 9, Following subsequent correspondence with the Commission Staff, SCE and the other IOUs were instructed to file supplemental advice letters to correct deficiencies the Commission had identified pertaining to metrics, strategies, and specific activities. On September 27, 2016, SCE submitted advice letter 3446-E-B requesting the Commission s approval of its plan to comply with AB 793 and the Ruling. The Resolution, issued on April 6, 2017, stipulates that the IOUs should: 1. Consider or promote more offerings that empower consumers with their own usage data made available by automated metering infrastructure (AMI); 2. Collaborate with third parties to animate the market for data-driven technologies; 3. Include metered savings and pay-for-performance models; 4. Integrate AB 793 Energy Efficiency (EE) offerings into the EE Rolling Portfolio Cycle, and; 5. Integrate AB 793 Demand Response (DR) offerings into DR portfolio, where feasible. 8 The Resolution ordered the IOUs to demonstrate compliance with Commission-directed modifications. 9 Specifically, the Resolution ordered PG&E, SDG&E and SCE to offer residential customers rebates for devices that utilize AMI data through a Home Area Network (HAN) device or similar medium such as the internet or Green Button Connect. The Resolution ordered SCE to launch residential and SMB pay-for-performance programs by fourth quarter of SCE and SCG were also ordered to create EMT marketplaces that include AB 793 relevant technologies. The Resolution also ordered the IOUs to include with their advice letters updates to their marketing plans to incorporate new product offerings and timelines Ruling at p Id, at p Id. 7 The utilities filed the statewide marketing plan via a joint Tier 2 advice letter. 8 Resolution at pp Resolution at p Id, at p. 36.

11 ADVICE 3605-E (U 338-E) May 22, 2017 PROPOSAL SUMMARY SCE s marketing plan update is presented as Attachment 1 to this AL., Attachment 1 describes SCE s approach to marketing the new AB 793 offerings required by the Resolution and SCE s plan to market EMT to disadvantaged communities and communities with high rates of disconnection. SCE s plan for specific marketing to communities with high disconnection rates and disadvantaged communities describes types of outreach to maximize effectiveness, plans to partner with others stakeholder and community groups to gain synergies, and plans to provide in-language communication to extend marketing reach. In general, SCE s marketing plan is designed to build awareness in communities with high disconnection rates and disadvantaged communities, drive customers to the marketplace, and better engage customers on SCE s current and new EMT-related programs. Attachment 2 describes the changes to SCE s EMT programs needed to meet the new requirements established in Resolution E Specifically, this attachment describes SCE s proposed EMT programs to meet the new requirements established in the Resolution, including rebate programs, residential and SMB pay-for-performance proposals and the online energy marketplace. Attachment 2 also describes SCE s plan to develop an EMT marketplace that will present relevant technologies as ordered in Resolution E SCE s current EMT offerings are described in the Appendix to Attachment 2. As part of the changes to the residential rebate program, SCE plans to offer an EE rebate to customers acquiring a qualifying smart thermostat technology. The Smart thermostat devices that would qualify for an EE rebate are based on SCE s residential smart communicating thermostat workpaper (SCE 17HC054) which recently received interim approval on April 14, 2017 consistent with the Energy Efficiency Policy Manual. 11 The program design and all the calculations in this workpaper were subject to a rigorous evaluation by the California Technical Forum (CalTF) culminating on February 23, SCE recognizes that, consistent with the EE Policy Manual 12 and D , 13 the Commission staff may review SCE s residential smart communicating thermostat workpaper. SCE recommends that any adjustments to the workpaper be made ex-post as a result of future M&V studies, upon Commission Staff review and be applied on a prospective basis. This will allow SCE to move expeditiously to implement the EE smart thermostat rebate program while providing for workpaper refinements that may result from a future Commission Staff review. 11 Energy Efficiency Manual, Version 5, published July 2013, page Ibid. 13 See D pages

12 ADVICE 3605-E (U 338-E) May 22, 2017 ATTACHMENTS Attachment 1 Southern California Edison Company s Updates to Local Marketing, Education and Outreach Plan in Compliance with Resolution E Attachment 2 Southern California Edison Company s Updated Proposal for Energy Management Technology Programs and Energy Marketplace Complying with Resolution E TIER DESIGNATION Pursuant to the Resolution, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice filing will become effective on June 21, 2017, the 30 th calendar day after the date filed. NOTICE Anyone wishing to protest this advice filing may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice filing. Protests should be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California Facsimile: (415) EDTariffUnit@cpuc.ca.gov Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this Advice Letter shall be sent to either via or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Telephone: (626) Facsimile: (626) AdviceTariffManager@sce.com

13 ADVICE 3605-E (U 338-E) May 22, 2017 Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415) Karyn.Gansecki@sce.com There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B, R , and R service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) For changes to all other service lists, please contact the Commission s Process Office at (415) or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by filing and keeping the advice filing at SCE s corporate headquarters. To view other SCE advice letters filed with the Commission, log on to SCE s web site at For questions, please contact Frank Harris at (626) or by electronic mail at Frank.Harris@sce.com. Southern California Edison Company /s/ Russell G. Worden Russell G. Worden RGW:fh:cm Enclosures

14 CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/cpuc Utility No.: Southern California Edison Company (U 338-E) Utility type: Contact Person: Darrah Morgan ELC GAS Phone #: (626) PLC HEAT WATER Disposition Notice to: EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water (Date Filed/ Received Stamp by CPUC) Advice Letter (AL) #: 3605-E Tier Designation: 2 Subject of AL: Southern California Edison Company s Plan to Comply With Resolution E-4820 Keywords (choose from CPUC listing): Compliance AL filing type: Monthly Quarterly Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: Resolution E-4820 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information: Resolution Required? Yes No Requested effective date: 6/21/17 No. of tariff sheets: -0- Estimated system annual revenue effect: (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: None Service affected and changes proposed 1 : Pending advice letters that revise the same tariff sheets: None 1 Discuss in AL if more space is needed.

15 Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Telephone: (626) Facsimile: (626) Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415)

16 Attachment 1 Southern California Edison Company s Updates to Local Marketing, Education and Outreach Plan in Compliance with Resolution E-4820

17 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E Table of Contents I. Executive Summary... 3 II. Marketing Plan Update... 4 A. Marketing of New EMT Programs and Services Required by the Resolution Energy Technology Marketplace Rebate Program for Devices that Utilize AMI Data Pay-for-Performance Programs... 6 B. EMT Marketing to Targeted Customers Identifying Customers for Targeted AB 793 Marketing SCE s Approach for Marketing to Targeted Customers

18 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E I. Executive Summary This Southern California Edison Company (SCE) Update to Local Marketing, Education and Outreach Plan (Marketing Plan Update) supplements SCE s previously approved two-year plan to promote Energy Management Technologies (EMT) as defined by Assembly Bill (AB) AB 793 directs the California investor-owned utilities (IOUs) 2 to develop local marketing plans to inform residential and small or medium business (SMB) customers about incentive programs that promote EMT. SCE s plan targets specific customer segments most likely to adopt EMT offerings, using multiple media approaches to elicit customer responses. In addition, Resolution E-4820 (Resolution) requires the IOUs to update the plans to include new product offering and timelines, as well as specific strategies on how they plan to market EMTs to the communities with the highest disconnection rates in their service territories or in disadvantaged communities. 3 The Resolution also requires that marketing efforts in these areas utilize greater resources and a more targeted effort than general marketing efforts." As such, SCE s Marketing Plan Update incorporates the required elements as stated in the Resolution. The Marketing Plan Update addresses the marketing of EMTs to communities with the highest disconnection rates and disadvantaged communities. SCE has a multi-faceted approach, including grassroots outreach, working with community advisors, statewide agencies, multi-family property owners, and providing in-language communications. In addition, this Marketing Plan Update provides SCE s approach to marketing EMT programs and services related to SCE s Energy Management Center and new pay-for-performance 1 See Advice 3446-E-B, Supplemental Filing to Advice 3446-E-A, Southern California Edison Company s Plan to Comply with Assembly Bill 793, Filed by SCE on September 27, 2016, and approved on April 7, The California IOUs are: Pacific Gas and Electric Company, San Diego Gas & Electric Company, Southern California Gas Company, and SCE. 3 See Resolution E-4820, Request for Approval of Pacific Gas and Electric, San Diego Gas & Electric, Southern California Edison and Southern California Gas Assembly Bill 793 (AB 793) Advice Letters (ALs), Ordering Paragraph 2.a., April 6,

19 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E programs. This Marketing Plan Update is integrated with the May 22, 2017 statewide updates to local AB 793 marketing plan. 4 II. Marketing Plan Update The Resolution requires the IOUs to update their marketing plans to include new product offerings, and timelines directed in this Resolution. 5 The Resolution also requires the IOU, in their marketing plans, to include specific strategies on how they plan to market EMTs to the communities with the highest disconnection rates in their service territories or in disadvantaged communities. 6 Therefore, SCE s Marketing Plan Update includes two sections. The first section provides SCE s plan for marketing the new EMT programs and services required by OP 1 of the Resolution. The second section describes SCE s plan for specific marketing to communities with high disconnection rates and disadvantaged communities, including types of outreach to maximize effectiveness, partnering with others to gain synergies, and providing in-language communication to extend marketing reach. SCE s marketing plan aligns with the statewide AB 793 ME&O integrated marketing plan to build awareness in communities with high disconnection rates and disadvantaged communities, drive customers to the Marketplace, and better engage customers on SCE s current and new EMT-related programs. SCE will develop a comprehensive tactical plan, based on budget allocation, 90 days prior to program or product launch. A. Marketing of New EMT Programs and Services Required by the Resolution This section describes SCE s plans to market the new AB 793 offerings required in OP 1 of the Resolution. OP 1 requires SCE to offer three new types of programs and to make all of its AB 793 offerings 4 Southern California Gas Company will submit the Assembly Bill 793 Joint IOU Marketing Plan Pursuant to Resolution E-4820, by Tier 2 advice letter on behalf of the Utilities. 5 Resolution, p. 36 (Ordering Paragraph (OP) 2). 6 Resolution, p. 36 (OP 2a). 4

20 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E available in an online energy technology marketplace. 7 The three types of programs SCE must offer are: (1) rebates for devices that use automated metering infrastructure (AMI) data through a Home Area Network, the internet, or Green Button Connect; 8 (2) residential payfor-performance program; 9 and (3) small and medium business payfor-performance program. 10 In addition to marketing the programs, SCE plans to make customers aware of its Energy Technology Marketplace. 1. Energy Technology Marketplace SCE plans to market its new Energy Technology Marketplace through SCE.com, bill onserts, and through Targeted Customer marketing (described in Section B). During the time until SCE is able to launch its Energy Technology Marketplace, SCE will launch an informationonly online site designed to make customers aware of energy savings opportunities through EMTs (SCE s Energy Management Center). At this site, SCE will provide information on new EE technologies, including those that provide real-time energy usage data for residential and business customers. 2. Rebate Program for Devices that Utilize AMI Data Once SCE s proposed rebate program for devices utilizing AMI data is approved by the Commission, 11 SCE will develop an education and outreach plan that leverages existing, local marketing channels and integrates with statewide marketing activities. This will include a target media plan that may include SCE.com merchandising, targeted and direct mail, digital banner ads and search engine marketing, Interactive voice response (IVR) directives, bill onserts, retail in-store merchandising, radio, and out of home based on target demographics. The final selection of tactics will depend on budget availability. In addition, SCE plans to leverage its Targeted Customer marketing approach, described in Section B below, to provide additional marketing to DACs and communities with high rates of disconnection. 7 Resolution, pp (OP 1b). 8 Resolution, p. 34 (OP 1a). 9 Resolution, p. 35 (OP 1d). 10 Resolution, p. 35 (OP 1e). 11 SCE proposes its rebate program in Attachment 2 of this advice filing. 5

21 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E 3. Pay-for-Performance Programs As stated in Attachment 2 of this advice filing, SCE plans to actively target EMT providers through an open solicitation process and review proposals with a specific focus on innovative solutions incorporating EMTs. As such, SCE will continue to develop its marketing plans based on the program design and characteristics. Once it has selected one or more pay-for-performance EMT offerings, SCE will develop an education and outreach plan that leverages existing, local marketing channels and integrates with statewide marketing activities. This will include a target media plan that may include SCE.com merchandising, targeted and direct mail, digital banner ads and search engine marketing, IVR directives, bill onserts, retail in-store merchandising, radio, and out of home based on target demographics. The final selection of tactics will depend on budget availability. In addition, SCE plans to leverage its Targeted Customer marketing approach, described in Section B below, to provide additional marketing to DACs and communities with high rates of disconnection. B. EMT Marketing to Targeted Customers 1. Identifying Customers for Targeted AB 793 Marketing As noted above, the Resolution requires SCE to describe how it will market EMTs to two groups of Targeted Customers: disadvantaged communities (DACs) and communities with the highest rates of disconnections. a. Identifying Disadvantaged Communities For the purpose of marketing EMTs to DACs, SCE defines a DAC as a census tract in the top 25 percent of the California Communities Environmental Health Screening Tool (CalEnviroScreen) Tool. 12 b. Identifying Communities with High Disconnection Rates 12 California Communities Environmental Health Screening Tool (CalEnviroScreen), is a screening methodology that can be used to help identify California communities that are disproportionately burdened by multiple sources of pollution. 6

22 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E For the purpose of marketing EMTs to communities with high rates of disconnection, SCE plans to market to zip codes in the SCE service territory that are correlated with higher disconnection rates. 2. SCE s Approach for Marketing to Targeted Customers This section describes the strategies and tactics SCE will use to market EMTs to Targeted Customers. To the extent possible, SCE plans to utilize authorized funding to provide greater resources and more targeted ME&O to communities with the high disconnection rates and DACs relative to general marketing efforts. However, because of the Resolution s additional ME&O requirements, SCE may seek additional funding at a later date. a. Targeted Marketing Through Paid Media SCE plans to utilize funds previously authorized by the CPUC to provide EMT paid media marketing to Targeted Customers. As such, SCE plans to market to Targeted Customers through currently deployed methods of communication, such as social media and print collateral. In addition, SCE plans to segment and target SCE bills and add bill onserts, which will include information on EMTs and other energy management products and programs. To the extent that additional paid media is necessary, SCE may need to request appropriate funding authorization. b. Partnerships SCE will develop a tactical plan to work with multi-family property owners and managers to reach Targeted Customers who are renters and not home owners. This will include Streamlined Program Implementation, Technical Assistance, and Engaging Multifamily Housing Industry Organizations. Streamlined Program Implementation includes integrating Energy Savings Assistance (ESA) and energy efficiency (EE) multifamily direct install efforts enabling program efforts to reach both tenants and property owners/managers across all levels of multifamily buildings (i.e., low-income and market-rate). Technical Assistance includes support for Benchmarking through ENERGY STAR Portfolio Manager, energy assessments and consultation, program guidance and financing options. Engaging Multifamily Housing Industry organizations and 7

23 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E associations will build partnerships in support of this complex market, which can provide key inroads and resources to help serve this customer segment. SCE plans to leverage existing local targeted DACs marketing activity to educate and make customers aware of EMTs with programs including California Alternate Rates for Energy (CARE), Family Electric Rate Assistance (FERA), and ESA, as well as provide collateral materials for hand-out at special local events and workshops. SCE plans to leverage current through SCE and Southern California Gas Company promotion of Programmable Communicating Thermostats (PCTs). For PCTs, SCE plans to combine current PCT Smart Thermostat training visits with information about new energy management products, programs, software, services and tools. SCE also plans to conduct retail store EMT training visits in which the purpose and benefits are to reach Targeted Customers at the immediate point-of-purchase location where they can receive additional information and/or review EMT products for potential purchase in their homes. SCE plans to leverage current efforts with trusted community advisors (business, educational, advocacy, and service organizations) to provide information and resources to Targeted DACs in order to educate people on SCE s EMTs and how these tools can help them save energy and money. SCE will partner with these organizations to encourage adoption of EMTs in their communities. SCE can demonstrate new EMTs at community workshops or other local events. SCE plans to partner with statewide organizations to enhance current outreach to economically disadvantaged communities in order to influence behavior change to adopt EMTs. SCE s plans include working and partnering with multiple organizations, such as California League 8

24 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E of Cities, 13 National Council of La Raza, 14 and the California Black Chamber of Commerce. 15 SCE plans to align with the statewide ME&O marketing efforts to target the K-12 audience and including families to reach the youth population. Such efforts are expected to work with the following groups within SCE s service territory: County departments of education, school districts, charter school operators, and sustainability groups at UC/CSU and private universities and colleges. Through this effort, SCE expects to provide targeted materials and outreach opportunities that encourage families to engage in EMT and other energy management tools. c. Integration with Statewide ME&O SCE plans to integrate activities with statewide MEO marketing currently being developed and implemented by DDB Worldwide Communications Group (agency in record). SCE plans to partner and leverage work being done to address the EMT needs of targeted DACs. DDB's plans to communicate to economically disadvantaged and multicultural communities, environmental/energy advice organizations m, state-based businesses/orgs, and education community groups is in process. In working with these organizations, SCE plans to align efforts with the statewide plan for Act, Enroll, Invest strategy, as depicted below. 13 The League of California Cities is an association of California city officials who work together to enhance their knowledge and skills, exchange information, and combine resources so that they may influence policy decisions that affect cities. 14 The National Council of La Raza, through research, policy analysis, and state and national advocacy efforts, as well as in program work in communities nationwide, serves millions of Latinos in the areas of civic engagement, civil rights and immigration, education, workforce and the economy, health, and housing. 15 The California Black Chamber of Commerce is the largest African American nonprofit business organization representing hundreds of small and emerging businesses, affiliates and chambers of commerce throughout the state, and focuses on business growth and development, advocacy in supplier diversity issues and building communities within their region of operation. 9

25 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E Type of Participation Act Enroll Invest Description Taking a tangible action to become a better energy manager and embrace behaviors of energy stewardship. Leading Californians to connect, sign up or contact their Program Administrator (PA). Specific to lead generation, this helps define where within the campaign (specific tactics) the handoff to PAs will occur. Driving Californians to purchase or invest in energymanagement products or programs. Example Lowering a thermostat, turning off the lights, or heeding guidance from an EMT device. Signing up for the right rate, participating in a home energy audit (online or by a contractor), or enrolling in a program (e.g., Budget Assistant). Investing in a home upgrade; purchasing an energy efficient appliances, electronics, or lighting; or purchasing a programmable thermostat or enrolling in a demand response program such as Summer Discount Plan (SCE s A/C cycling program). As part of the statewide marketing effort, SCE plans to work with environmental/energy advocacy organization, state-based businesses and organization with small businesses that represent economically diverse and low- and moderate-income energy consumers, to provide 10

26 Attachment 1 SCE Updates to AB 793 Local ME&O Plan May 22, 2017 Advice No E targeted materials and outreach opportunities that encourage their members to engage in EMT and other energy management tools. 16 d. Enhancements to Existing Efforts To the extent that it can provide valuable insights, SCE plans to conduct additional qualitative research to enhance consumer engagement messaging and strategies for Targeted DACs. SCE also plans to research ways that increasing targeted messages in languages other than English would enhance the existing AB 793 efforts to reach disadvantaged communities. Such efforts may include (1) translation and production of the current English EMC landing page into Spanish and other languages, (2) digital advertising in Spanish, Traditional Chinese, Vietnamese and Korean, (3) marketing messages and merchandising on SCE.com, and (4) marketing and education videos in Spanish. SCE will investigate what can be done to enhance in-language within existing funding capability. 16 Such as Urban League, National Association for the Advancement of Colored People (NAACP), National Council of La Raza, Minority Chambers of Commerce and Business Organizations. 11

27 Attachment 2 Southern California Edison Company s Updated Proposal for Energy Management Technology Programs and Energy Marketplace Complying with Resolution E-4820

28 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, 2017 Table of Contents Executive Summary... 3 Proposed EMT Programs to Comply with Modifications in the Resolution. 3 A. Residential Rebate Program... 3 B. Pay-for-Performance Program... 6 C. Energy Technology Marketplace... 8 Appendix - SCE s Current EMT Offerings

29 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, 2017 Executive Summary This document describes Southern California Edison Company s (SCE) plan to offer energy management technology (EMT) incentives in compliance with Assembly Bill (AB) 793 and Commission Resolution E (Resolution). The Resolution requires SCE to include three new AB 793 offerings: (1) rebates for devices that use automated metering infrastructure (AMI) data through a Home Area Network, the internet, or Green Button Connect; (2) residential pay-for-performance program; and (3) small and medium business pay-for-performance program. 1 The Resolution also requires SCE to make all of its AB 793 offerings available in an online energy technology marketplace. 2 This update describes SCE s proposed new EMT offerings, and SCE s plan to develop an EMT marketplace, in compliance with the Resolution. SCE s current EMT offerings are described in the Appendix. Key to this proposal is SCE s plan to continue its coordination with third-party product and service providers. SCE successfully administers its Save Power Day program in cooperation with thirdparty hardware and energy management providers. SCE will also reach out to the third-party EMT market to develop residential and SMB pay-for-performance programs, allowing third parties to submit program offerings. Proposed EMT Programs to Comply with Modifications in the Resolution A. Residential Rebate Program Resolution Ordering Paragraph (OP) 1.a, directs the electric utilities to offer residential customers rebates for devices that utilize Advanced Meter Infrastructure (AMI) data through a Home Area Network (HAN) or other mediums, such as the internet or Green Button Connect Approach and Overview 1 Resolution, pp (OP 1). 2 Resolution, pp (OP 1b). 3 Resolution at p

30 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, 2017 SCE is proposing three rebate programs for residential EMT devices: HAN device rebate Smart Thermostat Demand Response (DR) rebate Smart Thermostat Energy Efficiency (EE) rebate SCE's device rebate programs will be open to all residential customers who purchase a qualifying device. Additionally, SCE residential device rebate programs are vendor-agnostic and any qualifying device will be eligible for the rebate: Home Are Network (HAN) device rebate - Any ZigBee Smart Energy 1.x certified device can qualify for the rebate. Smart Thermostat DR rebate- Any Smart (programmable and equipped with communications capability) Thermostat eligible to participate in SCE s Save Power Day program can qualify for the rebate. Smart Thermostat EE rebate - Any Smart Thermostat (programmable and equipped with communications capability) qualified based on the approved EE work paper can qualify for the rebate. 4 SCE's HAN device and Smart Thermostat DR rebate programs will utilize AMI data as a component of the program design. The Smart thermostat devices that would qualify for an EE rebate are based on SCE s residential smart communicating thermostat workpaper (SCE 17HC054) which recently received interim approval on April 14, 2017 consistent with the Energy Efficiency Policy Manual. 5 SCE recognizes that, consistent with the EE Policy Manual 6 and D , 7 the Commission staff may review SCE s residential smart communicating workpaper. SCE recommends that any adjustments to the workpaper be made ex-post as a result of 4 SCE s Smart Thermostat EE rebate is being offered based on assumption of approved work paper SCE17HC Energy Efficiency Manual, Version 5, published July 2013, page Ibid. 7 See D pages

31 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, 2017 future M&V studies, upon Commission Staff review and be applied on a prospective basis. This will allow SCE to move expeditiously to implement the EE smart thermostat rebate program while providing for workpaper refinements that may result from a future Commission Staff review. 2. Customer Eligibility SCE's device rebate programs are open to all residential customers who purchase a qualifying device. To receive the Smart Thermostat DR rebate, customers must also be eligible to participate in, and enroll in, SCE s Save Power Day (PTR-ET-DLC) program. 3. Incentives HAN devices will be eligible for a $25 rebate when paired to a customer's smart meter. Smart Thermostats qualified for the DR rebate will be eligible for a $75 rebate at the time the customer enrolls in the Save Power Day program. Smart Thermostats qualified for the EE rebate will be eligible for a $50 rebate at the time of purchase from SCE's marketplace. 4. Pay for Performance The device rebates described above are offered as a one-time bill credit independent of any pay-for-performance mechanism. If these devices qualify for an approved pay-for-performance program, they may be eligible to receive ongoing incentives based on energy saving performance. 5. Data Source AMI data will be utilized in SCE's device rebate programs by making real-time data available to customers (IHD devices) or using AMI data to calculate energy savings (i.e. Save Power Day program). 6. Stakeholder Feedback Prior to submitting its Smart Thermostat EE work paper (SCE17HC054), SCE engaged the California Technical Forum (Cal TF) to evaluate the program design and calculations. Following its evaluation, Cal TF recommended the work paper for approval. 5

32 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, Timing As depicted in Figure 1 below, SCE's residential device rebate programs are expected to launch Q4 of Figure 1: Residential Rebate Program Planned Timeline Activity Description Jun July Aug Sep Oct Nov Dec Identify Devices Eligible for Rebates Update Systems to Support Device Rebates Train Support Staff on AB 793 Rebate Program Vett with ED, CalTF, CAEECC and/or the ETCC for input Launch Program B. Pay-for-Performance Program OPs 1.d and 1.e direct the utilities to launch residential pay-forperformance programs by the fourth quarter of The Resolution directs the utilities to utilize EMT technology vendors and products, including EMT software-as-a-service. 1. Approach and Overview To this end, SCE intends to pursue a residential pay-forperformance program consistent with Commission guidance utilizing a solicitation process, such as SCE's Innovation Development for Energy Advancement (IDEA) site ( where third-party providers are able to submit their proposed technology solutions and program offerings. The strategy and approach for SCE s residential pay-forperformance program is the same as SCE s approach for its SMB pay-for-performance program. Although the planned development approaches are the same, SCE expects that the SMB program will be different from the residential program. For example, the solicitations may appeal to different vendors with different program 6

33 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, 2017 innovations that vary by customer type. Also, different incentives and incentive structures may be optimized for this customer group. SCE plans to actively target EMT providers through an open solicitation process and review proposals with a specific focus on innovative solutions incorporating EMTs. Additionally, Any Smart Thermostat qualified based on an approved EE work paper will qualify for the rebate. 8 As part of this review, SCE will assess program designs, such as pay-for-performance and meter-based measurement components. Examples of potential third-party program designs may include a vendor engagement strategy using EMTs to optimize heating, ventilation and air conditioning (HVAC) usage or a behavior-based software application to help customers reduce their energy consumption. Incentive structures for this program are expected to be dependent on third- party proposals and may include a hybrid approach with an upfront incentive to reduce the cost of the EMT for the customer, and an ex-post pay-for-performance incentive based on verified savings. Incentive structures may be oriented towards the customer or vendor, or a combination of both. 2. Solicitation SCE s solicitation approach is designed to be technology and vendor agnostic. The approach will seek proposals that conform to the HOPPs evaluation, measurement and verification (EM&V) requirements. Furthermore, SCE s solicitation approach enables and welcomes EMT vendors and products. The solicitation is expected to consider EMTs either as a standalone technology or as a part of a bundled measure approach. Either approach will need to consider the potential EM&V ramifications when submitting proposals to properly account for HOPPs requirements to ensure measurable savings. 3. Timing In compliance with the Resolution and as depicted in Figure 2 below, SCE will require the third parties to launch in Q SCE s Smart Thermostat EE rebate is being offered based on assumption of approved work paper SCE17HC054. 7

34 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, 2017 Figure 2: Pay-for-Performance Program Planned Timeline Activity Description Jun July Aug Sept Oct Nov Dec Engage EMT Vendors Develop & Issue Solicitation Evaluate Responses & Select Programs Vett with ED, CalTF, CAEECC and/or the ETCC for input Issue P.O. Launch Program C. Energy Technology Marketplace OP 1.b directs SCE to create an energy technology marketplace that includes AB 793-relevant technologies. SCE plans to market its new Energy Technology Marketplace through SCE.com, bill onserts, and through Targeted Customer marketing (described in Section B). During the time until SCE is able to launch its Energy Technology Marketplace, SCE will launch an information-only online site designed to make customers aware of energy savings opportunities through EMTs (SCE s Energy Management Center). At this site, SCE will provide information on new EE technologies, including those that provide real-time energy usage data for residential and business customers. 1. Approach and Overview In compliance with OP 1.b of the Resolution, SCE plans to launch an online marketplace solution to increase awareness of available EMTs. SCE s marketplace solution will provide customers with information about an array of DR- and EE-related EMTs, including information on product pricing, available rebates, energy savings estimates, customer reviews, and tips for navigating to other online tools such as Enhanced Energy Advisor Tool or other programs designed to help manage customer usage. This marketplace solution will also include available SCE rebates on DR and EE products and EMTs and will provide a platform to apply for such rebates. 8

35 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, 2017 EMTs on SCE s marketplace are expected to include, but are not limited to, smart thermostats, power strips, lighting control modules, HAN devices, smart home devices, and connected home appliances. 2. Solicitation SCE plans to use a solicitation process to allow third parties with the capability to launch a marketplace solution to submit proposals. SCE will review proposals and select a qualified vendor to administer SCE s AB 793 marketplace. 3. Timing In compliance with the Resolution and as depicted in Figure 3 below, SCE will require a third party to launch a marketplace in Q Figure 3: Energy Technology Marketplace Planned Timeline Activity Description Jun July Aug Sept Oct Nov Dec Develop & Issue Solicitation Evaluate Responses & Select Vendor Vett with ED, CalTF, CAEECC and/or the ETCC for input Issue P.O. Implement and Launch Marketplace 9 SCE recognizes that it will be challenging to launch a marketplace in Q4, 2017, but will include the timeline stipulated in the Resolution in the solicitation. 9

36 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, 2017 Appendix - SCE s Current EMT Offerings EMT Information Tools and Services 1. Hourly and More Granular Usage Data SCE currently leverages the Edison SmartConnect AMI network to provide next day access to hourly and 15 minute usage data for residential and small and medium business customers. This information is updated daily and can be accessed at the MyAccount web portal through hand held and other devices. This information can help to provide near-real time access to electricity usage information. Access to this information can help customers better understand when and how much electricity they consume. This information will also help customers who are transitioned to or adopt time-of-use (TOU) rate plans where on-peak energy usage is typically the most expensive. The hourly and more granular usage data can also be used by customers to better understand how much electricity various appliances consume, by using different appliances during different times of the day, and reviewing the usage data recorded by the meter during those specific hours. Although this information is not available in real-time through the web portal, it is available the next day. 2. Daily Bill Calculations SCE leverages the AMI network to perform daily bill calculations for both Residential and SMB customers. The calculation algorithms span multiple rate plans and leverage the daily collection of interval data. These calculations are performed for the sole purpose of providing customers with intra-bill cost information to empower customers to understand their current costs, as of the previous day, within the current billing period. As part of the daily bill calculation, SCE also provides a forecast of the month end bill. This capability was developed to provide customers with near real-time feedback correlating electricity usage and relevant price, and provide them with an opportunity to reduce their bill before it's too late. It also was intended to help translate and simplify the cost structure associated with both tiered pricing rate plan designs, and time of use (TOU) rate plan options. 10

37 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, Energy Cost Tracking Enabled Through Proactive Alerts SCE leveraged both the daily bill calculation and bill forecasting capabilities to develop a program for Residential customers that delivers a text message alert (also available via , and voice messaging) which contains information about their current usage, current bill amount, and projected month end bill based on their intra-bill cycle usage pattern. Enrolled customers will receive weekly performance notifications as to how they are progressing toward a selected monthly spending target. Once enrolled in Budget Assistant, SCE compares the customer s selected spending target against the calculated Bill Forecast for the current billing period and then sends the customer routine notifications indicating their performance to their selected spending target, along with dynamic and usage specific messaging elements. The notifications include specific cost and usage information relevant to their current rate plan. Participating customers can update their preferred spending target at any time. Customers also have the option to modify the number of notifications received to either weekly, or only when the energy cost projection indicates they will exceed their selected spending goal. In 2016, SCE had approximately 450,000 customers enrolled which resulted in 7,613 MWhs of energy savings. As of the end of April 2017, program enrollment has increased to nearly 600,000, representing a 33% increase in participating customers. 4. Time-of-Use Energy Cost Tracking for Small and Medium Commercial Customers SCE also developed a similar offering for SMB customers. The tool delivers personalized and relevant content that compares a customer s current and projected costs against a seasonal (winter/summer) budget goal. SMB customers are provided with additional usage details in the alert messages based upon their specific Time-Of-Use (TOU) rate plan. All SMB customers have been transitioned to TOU rate plans, and the Budget Assistant tool for these customers was modified to deliver even more meaningful information to help these customers better manage their usage and costs during certain time periods throughout the week. These details include usage information on their highest peak for their current billing period, current maximum demand and customized savings tips by both rate and season of the year. 11

38 Attachment 2 SCE Program and Marketplace Proposal Advice No E May 22, Demand Alerts High Demand Notifications for SMB Customers SCE enhanced the Budget Assistant bill tracking capabilities to include delivery of alerts when certain high demand (recorded kw) thresholds are breached. SMB customers who have exceeded the maximum demand allowed for a given rate plan, for any given billing period, are sent a separate demand alert to raise awareness and ensure they understand the consequences. If for a given rate plan a certain high demand is exceeded 3 times within the most recent 12 month window, they will be placed on an alternate rate plan which may have higher associated costs. Providing these customers with this additional information further builds on the value proposition of the Budget Assistant tool. 6. Residential Tier Alert Communicating current Energy Prices SCE leverages the daily bill and projected next bill forecast calculation functionality to provide customers with an intra-bill cycle visual depiction of their current usage, associated kwh pricing, and expected usage and pricing through the end of the current billing cycle. As the customer s usage increases over the typical 30 day billing period, pricing can change as they cross through the various tiers associated with the next defined block of allocated energy. This visual depiction can help the customer better understand the basic residential rate plan s structure, associated pricing, and provides accurate estimates of both their bill-to-date and the forecasted month-end bill. SCE refers to this tool as Tier Position and the information displayed on the MyAccount portal complements and matches the cost projections provided through the Budget Assistant tool. The Tier Alert content has recently been updated to reflect the new 2 tiered rate structure and High Usage Surcharge. The visual also provides the projected tier cross-over points, the volume of kwh associated with each tier, and current tier pricing through the end of the billing period. The dynamic visual is updated daily. Programs/Services that Support EMTs 1. In-Home-Display (IHD) Device Activation/Enablement The SCE AMI network includes Home Area Network (HAN) Functionality. Each AMI meter is equipped with the capability to communicate to devices in-and-around the home. The HAN feature 12