S Application for an Order Finding the D
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APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF ENTERGY ) ARKANSAS, INC.’S APPLICATION FOR ) AN ORDER FINDING THE DEPLOYMENT ) DOCKET NO. 16-060-U OF ADVANCED METERING ) INFRASTRUCTURE TO BE IN THE ) PUBLIC INTEREST AND EXEMPTION ) FROM CERTAIN APPLICABLE RULES JOINT MOTION TO APPROVE ADVANCED METERING INFRASTRUCTURE CUSTOMER EDUCATION PLAN FOR ENTERGY ARKANSAS, INC. Come now Entergy Arkansas, Inc. (“EAI” or the “Company”); the General Staff (“Staff”) of the Arkansas Public Service Commission (“APSC” or the “Commission”); and the Consumer Utilities Rate Advocacy Division of the Attorney General’s Office (“AG”) (hereinafter collectively, the “Settling Parties”), and for their Joint Motion (“Joint Motion”) to Approve the Advanced Metering Infrastructure Customer Education Plan for Entergy Arkansas, Inc. (“Customer Education Plan”) state as follows: 1. On August 11, 2017, the Settling Parties filed a Joint Motion to Approve Settlement Agreement (the “Agreement”) to inform the Commission that they had reached agreement on all issues in Docket No. 16-060-U. The Agreement set forth various commitments made by the Company pursuant to which Staff and the AG support that EAI’s deployment of Advanced Metering Infrastructure (“AMI”) is in the public interest. 2. On October 30, 2017, the Commission issued Order No. 8 finding that the Agreement and EAI’s deployment of AMI are in the public interest. The 1 APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 Commission noted the various commitments of the Settling Parties to work cooperatively toward the completion of their collaborative work.1 In working toward the goals set forth in the Agreement, and consistent with the Joint Motion to Approve Select Pre-Deployment Customer Education Materials approved by the Commission in Order No. 10 on August 20, 2018, the Settling Parties submit this Joint Motion seeking approval of the comprehensive Customer Education Plan. 3. Section 2(C) of the Agreement regarding the Customer Education Plan provides that the Settling Parties will work cooperatively to further develop a comprehensive Customer Education Plan, based on the proposed Customer Education Plan in EAI Direct Exhibit ODW-1. The Customer Education Plan development will include metrics to evaluate the effectiveness of the Customer Education Plan and customers’ response to AMI in accordance with Section 2(L)(iv) herein. EAI will work with the Settling Parties to further refine the proposed Customer Education Plan and submit an updated plan for review by the other Settling Parties. As set forth in the Direct Testimony of Oscar D. Washington including EAI Direct Exhibit ODW-1, EAI proposes development of a multi-phased comprehensive education plan. The Customer Education Plan will: 1. Specifically describe the specific activities and interactions with the utility that will be enabled by the implementation of the AMI meters. 2. Describe the efforts the Company will take to educate its customers 1 Order No. 8 at 110-111 2 APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 about the options they will have to obtain additional information and acquire additional services that are enabled by the deployment of AMI meters. 4. The work on the plan has been substantial. Over the past year, the Settling Parties have worked collaboratively to develop a robust plan to educate customers on the Company’s upcoming deployment of AMI such that customers may take advantage of the benefits provided by AMI. 5. The Customer Education Plan incorporates the Select Pre- Deployment Customer Education Materials approved by this Commission in Order No. 10. However, within the FAQs, EAI has now incorporated questions related to its privacy policy. 6. The Customer Education Plan generally explains the Company’s approach to reaching its diverse customer base including low income customers, non-computer users, and non-English speaking customers. Additionally, the plan lays out the Company’s approach to phased messaging for customers. The Company will educate customers in the following four phases: (1) pre- deployment; (2) meter deployment and individual activation of online energy management information and tools (3) energy management information and tools available to all customers; and (4) ongoing engagement. 7. As more fully set forth in the Customer Education Plan, the first phase, pre-deployment, will focus on the materials already approved by the Commission in Order No. 10, which explain to customers generally what to expect with the AMI deployment as well as respond to anticipated frequently asked questions. The next two phases focus on what customers should expect when their meter is replaced, and the features and benefits of the web portal. 3 APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 The fourth phase is focused on ongoing education of energy management tools and how to use the web portal. Throughout the phases, the Company will be evaluating customer reaction and adjusting our approach as needed. 8. The Company will communicate with and educate customers in a variety of ways including through the web portal, bill inserts, direct mail, door hangers, email, employee education, installer cards, letters, media relations, paid media, predictive dialing, social media, stakeholder and community outreach, text messaging, and videos. The Customer Education Plan describes how each of these methods of communication will be utilized in educating customers. The Customer Education Plan also includes a high level budget, and as a highly sensitive protected attachment, a detailed budget. 9. Based on the foregoing and by this Joint Motion, the Settling Parties are seeking the Commission’s approval of the comprehensive Customer Education Plan, which they respectfully submit was developed consistent with their obligations under the Agreement. 4 APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 WHEREFORE, the Settling Parties respectfully request that the Commission find the attached Customer Education Plan to be in the public interest and consistent with the Settling Parties’ obligations under the Agreement and grant all other necessary and proper relief. Respectfully submitted, ENTERGY ARKANSAS, INC. By: /s/ Kimberly K. Bennett Kimberly K. Bennett ABN: 95185 Assistant General Counsel Matthew R. Suffern ABN: 201002 Assistant General Counsel Jana K. Law ABN: 2011142 Senior Counsel Entergy Services, Inc. P. O. Box 551 Little Rock, Arkansas 72203 Telephone: (501) 377-5715 ATTORNEYS FOR ENTERGY ARKANSAS, INC. GENERAL STAFF OF THE ARKANSAS PUBLIC SERVICE COMMISSION By: _/s/ Bridgette M. Frazier Bridgette M. Frazier ABN: 99-036 Staff Attorney 1000 Center Street P.O. Box 400 Little Rock, Arkansas 72203 (501) 682-5816 5 APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 LESLIE RUTLEDGE ATTORNEY GENERAL By: _ /s/ M. Shawn McMurray Shawn McMurray ABN: 92250 Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-1053 Sarah P. Tacker ABN: 2002189 Sr. Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 6 APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 CERTIFICATE OF SERVICE I, Kimberly K. Bennett, do hereby certify that a copy of the foregoing has been served upon all parties of record by forwarding the same by electronic mail and/or first class mail, postage prepaid, this 28th day of September, 2018. /s/ Kimberly K. Bennett Kimberly K. Bennett 7 APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF ENTERGY ) ARKANSAS, INC.’S APPLICATION FOR ) AN ORDER FINDING THE DEPLOYMENT ) OF ADVANCED METERING ) DOCKET NO. 16-060-U INFRASTRUCTURE TO BE IN THE ) PUBLIC INTEREST AND EXEMPTION ) FROM CERTAIN APPLICABLE RULES JOINT MOTION EXHIBIT 1 AMI COMPREHENSIVE CUSTOMER EDUCATION PLAN 8 Entergy Arkansas, Inc. Joint Motion Exhibit 1 Docket No. 16-060-U APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 Page 1 of 82 Advanced Metering Infrastructure (AMI) Customer Education Plan for Entergy Arkansas, Inc. 9 1 Entergy Arkansas, Inc. Joint Motion Exhibit 1 Docket No. 16-060-U APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc. 110 Page 2 of 82 TABLE OF CONTENTS INTRODUCTION Primary Goal 4 Objectives 4 Purpose and Content 4 Commitment to Customers 5 Plan Components 5 STRATEGY & APPROACH Best Practices & Lessons Learned 6 Flexibility 7 Audiences 7 Multi-Channel 14 Phased Implementation 14 IMPLEMENTATION PLAN Tactics by Phase 16 Milestones & Key Messaging 17 PHASED MESSAGING Phase I 19 Phase II 22 Phase III 25 Phase IV 28 TIMING Program Timeline 29 120-day Timeline 31 Customer Education Timeline 32 RESEARCH & METRICS Performed Research: Insights 34 Customer Research Applications 38 Understanding Customers: The Role of Qualitative Market Research 38 Measuring Success: Introduction to Tracking Surveys 38 Segmentation 39 Proposed Research Plan 40 Metrics 41 ESCALATION PLAN 43 BUDGET 47 APPENDIX Appendix A: Utility Interviews 48 Appendix B: Sample Materials 52 Appendix C: Stakeholder and Community Outreach, Media 67 Appendix D: Attached Timelines 80 10 2 Entergy Arkansas, Inc. Joint Motion Exhibit 1 Docket No. 16-060-U APSC FILED Time: 9/28/2018 3:53:22 PM: Recvd 9/28/2018 3:52:47 PM: Docket 16-060-U-Doc.