Our analysis of forecasted ME&O Plan budget activities includes a comparison of SDG&E’s proposal with that of Greenberg, which includes various assumptions: A ‘big bang’ default of all eligible customers at the same time (January 2019); A reach of 85-90% and a frequency of 10+ touches over an average of four weeks; A cost of $13 per customer for direct marketing materials; A heavy emphasis on continuous mass media at the statewide and local levels. These assumptions, particularly the high reach and frequency numbers, are intended to make energy use a more salient topic to all Californians. In the Blueprint, the estimated cost for SDG&E alone, not including any contribution to a statewide campaign, comes to roughly $23.4 million. Budget Category 2017 2018 2019 Total Mass Media Blueprint for SDG&E $0 $2,405,203 $4,572,091 $6,977,294 SDG&E $365,000 $2,175,000 $2,375,000 $4,915,000 Direct Marketing Blueprint for SDG&E $1,600,000 $9,500,000 $4,700,000 $15,800,000 SDG&E $2,066,000 $3,562,000 $4,623,000 $10,251,000 Public Relations Blueprint for SDG&E $7,000 $14,400 $14,400 $35,800 SDG&E "Outreach" $300,000 $460,000 $816,000 $1,576,000 Research and Evaluation Blueprint for SDG&E $217,000 $201,750 $201,750 $620,500 SDG&E $325,000 $425,000 $450,000 $1,200,000
In addition to the above categories, SDG&E includes $600,000 over three years for outreach related to the High Usage Charge and $832,000 for changes to its marketing and outreach software for a total of $19.4 million. The main reductions compared to Greenberg’s assumptions are in the areas of mass media and direct marketing. However, SDG&E provides little detail as to how their budget differs from the recommendations made in the Blueprint, and we direct them to clarify these differences and provide justification in its March 30 Tier 2 AL. In addition, any proposed 2017 budget expenditures that have been recorded in the RRMA thus far are approved subject to GRC review. We also direct SDG&E to address and clarify any timeline adjustments to proposed expenditures since the filing of 2992-E and 2992-E-A in this new Tier 2 filing. We approve SDG&E’s proposed budget expenditures of $19.4 million for entry into the RRMA. SDG&E shall present in its March 30 AL a clarification of the differences between SDG&E’s proposed budget and the budget recommendations made in the Blueprint, with justification as applicable. In addition, we direct SDG&E to include any audit of the RRMA in the next applicable PRRR report. Budgets are Subject to Change SDG&E states that the ME&O Plan and its associated budget are subject to change based on based on new information derived from TOU pilots, additional customer research, implementation or operational requirements, and guidance from the Commission regarding statewide ME&O. The measurement and evaluation methodology and the test-and-learn approach described by SDG&E will also act as a guide to continuous adjustment to the plan based on results. Accordingly, we acknowledge that changes to SDG&E’s ME&O Plan and associated budget may be necessary. SDG&E is directed to report actual cost deviations from the budget (or subsequently updated budgets) that are greater than $250,000 at the line-item level as well as the reason for the deviation. In addition, SDG&E is directed to provide a comparison of budgeted and actual