Amended Testimony on Customer Contacts...21 testimony and workpapers for Customer Contacts capitalized software projects are discussed in SCE-06, 22 Vol. 1, Part 2. 1 Such outage communications

Application No.: A.19-08-013 Exhibit No.: SCE-03, Vol. 04A Witnesses: K. Garcia

V. Hernandez J. Lim

(U 338-E)

2021 General Rate Case

Amended Testimony on Customer Contacts

Before the

Public Utilities Commission of the State of California

Rosemead, California February 20, 2020

SCE-03, Vol. 04A: Amended Testimony on Customer Contacts

Table Of Contents Section Page Witness

-i-

I. INTRODUCTION .............................................................................................1 V. Hernandez

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

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

II. CUSTOMER CONTACTS ................................................................................3

A. Overview ................................................................................................3

1. Customer Contact Center ...........................................................3

2. Business Account Management .................................................4

3. Digital Operations and Management .........................................4

4. Regulatory Compliance Requirements ......................................5 K. Garcia

5. Regulatory Background/Policies Driving SCE’s Request .......................................................................................6

B. 2018 Decision ........................................................................................6 V. Hernandez

1. Comparison of Authorized 2018 to Recorded ...........................6

C. O&M Forecast .......................................................................................7

1. Customer Contact Center ...........................................................9

a) Work Description ...........................................................9

(1) Inbound Communications ................................10

(2) Outbound Communications .............................12

(3) Project Management ........................................13

b) Need for Activity .........................................................13

c) Comparison of Authorized 2018 to Recorded ......................................................................14

d) Scope and Forecast Analysis .......................................15

(1) Historical Variance Analysis ...........................16


Table Of Contents (Continued) Section Page Witness

-ii-

(2) Forecast ............................................................17

e) Basis for O&M Cost Forecast Method ........................20

2. Business Account Management ...............................................21 K. Garcia

a) Work Description .........................................................21

(1) Account Management Activities ......................22

(2) Technical Support Services ..............................26

(3) Outage Experience ...........................................28

(4) Other Support Services ....................................31





(2) Forecast ............................................................36

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

3. Digital Operations and Management .......................................45 J. Lim

a) Work Description .........................................................45

(1) Facilitating Increased Use of Digital Channels ...........................................................45

(2) Migration of SCE.com to a New Cloud-Based Platform ......................................46






Table Of Contents (Continued) Section Page Witness

-iii-

(2) Forecast ............................................................51

e) Basis for O&M Cost ....................................................54

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 Customer Contacts Business Planning 5

Element (BPE). The activities detailed in this volume are primarily managed in SCE’s Customer Service 6

(CS) organization. The funding request presented in this volume will allow SCE to continue its efforts to 7

(1) respond to both residential and non-residential (commercial, industrial, governmental, and 8

agricultural) customer requests for service; (2) respond to customer inquiries about their service 9

including billing and payment arrangements; (3) provide customers with information on rates, programs, 10

and services to help them manage their bill and energy consumption, and (4) provide timely and 11

accurate communications to SCE’s customers before, during, and after outages.1 This volume of 12

testimony summarizes the scope of work, key drivers for the work, and regulatory mandates that impact 13

the level of O&M for the Customer Contacts BPE. 14

The volume includes analysis of (1) O&M funding authorized in the 2018 General Rate Case 15

(GRC) compared to recorded amounts in 2018, and (2) the 2021 Test Year O&M labor and non-labor 16

forecast relative to historical spending. 17

B. Summary of O&M 18

This volume presents SCE’s request for $68.9 million (constant 2018 dollars) in O&M expenses 19

for the 2021 Test Year to effectively perform the functions described in this testimony. The supporting 20

testimony and workpapers for Customer Contacts capitalized software projects are discussed in SCE-06, 21

Vol. 1, Part 2. 22

1 Such outage communications include outages associated with SCE’s Public Safety Power Shutoff (PSPS)

protocol in support of SCE’s Wildfire Mitigation Plan. See D.19-05-038, http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M298/K487/298487636.PDF. The outage-related funding request in this volume does not include costs that are recorded to the memorandum account approved as part of SCE’s Wildfire Mitigation Plan.

2

Figure I-1 Customer Contacts

O&M Expenses (Constant 2018 $Millions)

Billing & Payments,$66, 35%

Communications, Education &

Outreach, $22, 12%Customer Care

Services, $30, 16%

Customer Contacts, $69, 37%

3

II. 1

CUSTOMER CONTACTS 2

A. Overview 3

Customer Contacts activities describe how SCE provides various channels for our customers to 4

interact with us. They are performed by SCE’s (1) Customer Contact Center (CCC), which focuses 5

primarily on residential customers but is also the initial point of contact for small to medium non-6

residential customers, (2) Business Customer Division (BCD), which handles interactions with large 7

non-residential customers and with more complex small to medium-sized non-residential customers 8

through its Business Account Management activities, and (3) Digital Operations and Management 9

group, which provides SCE.com and other digital channels (e.g., mobile phone, voice activated devices) 10

as tools for customers to make service requests and get information whenever it is most convenient for 11

them. These areas also drive toward continuous improvement within their operations by identifying and 12

implementing program, service, and process enhancements that will positively advance the customer 13

experience. An overview of each area is provided below. 14

1. Customer Contact Center 15

From 2014 to 2018, SCE’s CCC handled on average 16.6 million2 inbound calls 16

annually. The CCC is responsible for fulfilling customer requests for service, addressing credit and 17

billing inquiries, identifying and describing usage patterns to customers, providing technical support for 18

SCE.com, working with field organizations to resolve customer issues, and discussing energy solutions 19

and products with customers. The CCC also responds, 24 hours a day, seven days a week, to emergency 20

calls regarding outages, damaged equipment, and disconnection of service. To handle this wide range of 21

inbound calls, the CCC employs nearly 400 Energy Advisors (ENAs) who are specially training to 22

handle customer calls and inquiries. In addition, the CCC continues to use a contract call center provider 23

to handle certain call types, such as service establishment and transfer of service, credit arrangements, 24

outage calls, and, most recently, California Alternate Rates for Energy (CARE) inquiries and 25

transactions, and Community Choice Aggregation (CCA) calls.3 The contract call center provider also 26

2 See Table II-2, line 4.

3 SCE’s contract call center provides general information to customers about CCA service and CCA charges on the customer’s electricity bill, as well as refers customers to their CCA for specific questions and information.

4

handles after-hour calls, including after-hour emergency service calls, which are an essential component 1

of SCE’s business resiliency efforts. 2

2. Business Account Management 3

Business Account Management activities are performed within SCE’s BCD organization. 4

These activities are performed by teams of account managers and technical staff that serve 5

approximately 300,000 business customers (approximately 700,000 service accounts). These activities 6

support the delivery of approximately 52 billion kilowatt hour (kWh) sales, which represents more than 7

half of SCE’s annual revenue.4 8

The Business Account Management function encompasses a number of activities for 9

SCE’s business customers, which are described in more detail in section II.C.2 below. These activities 10

include providing recommendations on utility and energy-related matters that have financial or 11

operational impacts to SCE’s customers; providing basic customer care functions such as resolving 12

billing, metering, and credit/payment issues; coordination and support before, during, and after outage 13

events, including Public Safety Power Shutoff (PSPS); providing education regarding optional and 14

default rates; performing rate analysis and constructing rate and load aggregation models; engineering 15

and technical on-site visits and evaluations of customer equipment; and assisting customers in assessing 16

the feasibility of adopting emerging distributed energy resources and technologies. Business Account 17

Management also focuses on improving the outage customer experience by providing timely and 18

accurate communications to SCE’s business and residential customers before, during, and after de-19

energization events (outages), including outages associated with SCE’s PSPS process. 20

3. Digital Operations and Management 21

The Digital Operations and Management group within SCE’s Customer Programs & 22

Services organization primarily: (1) plans and manages the growth and evolution of SCE’s digital 23

presence and end-to-end customer experience to meet SCE’s online customers’ needs, (2) designs and 24

develops SCE’s digital channels (SCE.com, voice activated devices, and mobile) using customer 25

feedback and other inputs to develop new or enhance existing features and functions, including tools to 26

help customers make informed decisions, enroll in programs, conduct self-service transactions, and 27

access their energy usage information, and (3) provides daily content support for SCE.com digital 28

services. 29

4 Refer to WP SCE-03 Vol. 4A, p. 16 - Number of Accounts and Sales for additional details.

5

4. Regulatory Compliance Requirements 1

The primary responsibilities of SCE’s CCC are to fulfill customer requests for service 2

connection, address credit and billing inquiries, and conduct many of SCE’s credit, collections, and 3

billing activities. These activities are accomplished through SCE’s live agents (ENAs), contract call 4

center, or Interactive Voice Response (IVR) system in accordance with SCE’s Commission-approved 5

Rules and Tariff Schedules.5 Also, in compliance with D.18-12-013, SCE’s CCC ENAs apply new or 6

revised service disconnection rules related to certain credit activities, such as including hot/cold weather 7

disconnection moratoriums and qualifying customers for the medical baseline program. Finally, in 8

compliance with D.19-07-015, the CCC ENAs will apply various consumer protections as appropriate 9

when a state of emergency due to a natural disaster is declared in a designated area of SCE’s service 10

territory. 11

In D.19-05-020, issued in SCE’s 2018 GRC, the Commission adopted an agreement 12

between SCE and the Small Business Utility Advocates (SBUA) that commits SCE to deliver certain 13

customer care and customer contact services for its small business customers. The agreement with 14

SBUA adopted in D.19-05-020 sets forth specific deliverables, including: (1) providing assistance to 15

small business customers on SCE’s portfolio of services and program offerings, (2) enhancing call 16

center and account management representative training to facilitate these interactions, (3) expanding 17

online tools available and targeted to small business customers, and (4) implementing outreach and 18

education events. A detailed discussion of SCE’s compliance with these requirements is provided in 19

Exhibit SCE-03, Volume 5. Additionally, in D.19-05-020, the Commission directed that SCE meet and 20

confer with the California City County Street Light Association (CAL-SLA) and all interested officials 21

from affected jurisdictions to address each of the concerns raised in CAL-SLA’s testimony. SCE was 22

directed to provide a joint proposal either as part of this GRC application, or as a supplemental exhibit 23

as soon as possible in the 2021 GRC proceeding.6 SCE’s Business Account Management activity will 24

support SCE’s compliance with this requirement.7 25

5 See SCE’s Rules and tariffs at https://www.sce.com/regulatory/tariff-books/rules.

6 See D.19-05-020, p. 356.

7 See SCE-02, V.01, Pt.2 Section II.F, where SCE discusses compliance with these requirements.

6

5. Regulatory Background/Policies Driving SCE’s Request 1

In July 2018, the Commission issued R.18-07-050 to develop new policies and processes 2

to reduce the rates of residential disconnections for non-payment as directed by Senate Bill 598 enacted 3

by the Legislature in 2017. In that proceeding, the Commission issued D.18-12-013, which required 4

SCE’s ENAs to apply new or revised service disconnection rules (as discussed in the prior section). This 5

rulemaking is ongoing and SCE expects that additional revisions to existing service disconnection rules 6

and processes may be enacted that will result in new or revised requirements for SCE’s ENAs. 7

In addition, the outage communications activities carried out by BCD’s Outage Team are 8

driven largely by de-energization public notification requirements detailed in Resolution ESRB-8, 9

adopted by the Commission on July 12, 2018. This Resolution builds upon the communications, 10

mitigation, and reporting requirements in D.12-04-024, and requires electric utilities to make reasonable 11

and appropriate attempts to notify customers of a de-energization event prior to performing the de-12

energization. Resolution ESRB-8 also standardizes utility practices for public outreach, notification, and 13

reporting requirements both before and after a de-energization event. As de-energization events increase 14

due to (1) SCE’s grid strengthening and modernization efforts, and (2) other dangerous conditions such 15

as wildfires, the work activities pursuant to Resolution ESRB-8 will continue to support increased 16

coordination, communication, and public education regarding de-energization events in an effort to 17

increase public safety and minimize adverse impacts from de-energization. 18

B. 2018 Decision 19

1. Comparison of Authorized 2018 to Recorded8 20

Figure II-2 below compares the requested and authorized O&M expenses from SCE’s 21

2018 GRC with the recorded expenses for Customer Contacts in compliance with D.19-05-020. As 22

shown in Figure II-2, SCE’s recorded expenses in 2018 Customer Contacts were $3.339 million less 23

than authorized. As described in this volume, this variance was primarily the result of Business Account 24

Management process efficiencies and continued refinement of BCD’s account coverage model, as well 25

as reduced Customer Contact Center and Digital Operations and Management expenses that are within 26

normal operating parameters. 27

8 Refer to WP SCE-07, Vol. 01A2 – Authorized to recorded.

7

Figure II-2 Customer Contacts

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

C. O&M Forecast 1

Figure II-3 below shows the Customer Contacts O&M expenses recorded for 2014-2018 and 2

forecast for 2019-2021. Each Customer Contacts GRC Activity forecast is discussed in detail in the 3

following sections. 4

8

Figure II-3 Customer Contacts

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

Table II-1 below presents the Customer Contacts O&M expenses that were recorded for 2014-1

2018 and that are forecast for 2019-2021, divided between each of the work activities within this BPE. 2

9

Table II-1 Customer Contacts


1. Customer Contact Center 1

a) Work Description 2

The CCC receives inbound customer calls9 which are handled through SCE’s 3

nearly 400 ENAs,10 Interactive Voice Response (IVR) system, and contract call center. In addition to the 4

functions described in the section above,11 SCE’s CCC also responds to customer inquiries through 5

alternative channels such as web chat, mail correspondence, or Teletypewriter (TTY) channels. 6

Historical CCC activity levels for the period 2014 through 2018 are summarized in Table II-2 below. 7

9 Calls received through SCE’s toll-free numbers. In 2018, Live Agents and IVR handled over 16.6 million

inbound customer calls.

10 2018 monthly average CCC staffing was 391 ENAs.

11 Those functions are: fulfilling customer requests for service, addressing credit and billing inquiries, identifying and describing usage patterns to customers, providing technical support for SCE.com, working with field organizations to resolve customer issues, and discussing energy solutions and products with customers (e.g., Budget Assistant).

2014 2015 2016 2017 2018 2019 2020 2021

1 Customer Contact Center $52,360 $49,243 $44,634 $47,173 $45,394 $42,855 $44,161 $45,0622 Business Account Management $17,870 $19,152 $14,236 $12,067 $14,136 $13,705 $16,047 $19,6783 Digital Operations and Management $3,729 $3,164 $2,786 $4,118 $3,318 $2,774 $5,047 $4,183

4 Total Expenses $73,959 $71,559 $61,656 $63,358 $62,848 $59,334 $65,254 $68,923

Recorded Forecast

Work ActivityLine No.

10

Table II-2 CCC Functions and Activity Levels

2014-2018

(1) Inbound Communications 1

From 2014 to 2018, live-agent inbound call volume decreased by 23 2

percent,12 while IVR-completed call volume increased by 34 percent.13 This shift was primarily due to 3

the increase in customer use of the IVR self-service channel to complete billing and payment 4

transactions. 5

The CCC also serves customers who prefer interacting with SCE in 6

languages other than English or who require special communication needs. To serve these customers, 7

SCE employs a combination of specially-trained ENAs, vendor services, and TTY technology. 8

Specifically, the CCC handles inbound calls through in-house multilingual representatives in six 9

languages: Spanish, Cambodian, Chinese (Mandarin and Cantonese), Korean, and Vietnamese. For 10

customers who speak another language, the CCC uses a vendor translation service to support customer 11

inquiries in over 180 additional languages. SCE also serves customers with speech and hearing 12

disabilities through TTY 24 hours/day, 7 days week. Customers can contact these ENAs via a special 13

12 -23.0% = (6,096,820 - 7,916,466) / 7,916,466.

13 34.4% = (10,508,592 - 7,819,150) / 7,819,150.

11

toll-free number that is listed on the back of SCE’s bill and other customer communications. In 2018, 1

SCE handled 105 TTY system-assisted calls. 2

The CCC also provides service to customers who potentially qualify for 3

special rates and programs. For customers who may qualify, trained ENAs provide information and 4

answer questions about Medical Baseline, CARE, FERA, and large print bills. If customers qualify, the 5

ENAs will assist them in enrolling for these rates or programs. 6

In the Test Year, and consistent with prior years, the CCC will leverage its 7

IVR and automated call-routing technologies to deliver (or “route”) calls to its ENAs. The CCC will 8

also continue to enable self-service functionality through the IVR. Examples of IVR self-service 9

functionality include automated CARE enrollments and recertifications, payment processing, payment 10

arrangement set ups, and trouble order status reporting. With the self-service functionality provided by 11

IVR, SCE provides customers an effective option to handle their requests and get the information they 12

need with 24/7 availability.14 13

Average Handle Time (AHT) is the average amount of time spent by a 14

live agent to handle a customer call. The AHT for inbound calls grew 13 percent from 2014 to 2018, as 15

the simpler calls related to routine customer service transactions were handled by SCE’s IVR, self-16

service platforms, or contract call center.15 More complex customer calls related to electric service, and 17

new SCE programs and services, are handled by SCE’s ENAs.16 The more complex customer calls took 18

longer on average to complete which is reflected in the increased AHT from 2014 to 2018, as shown 19

below in Table II-3. 20

14 The number of Spanish IVR calls SCE successfully handled by year was—2014: 839,382 calls; 2015:

1,156,966 calls; 2016: 1,370,608 calls; 2017: 1,474,290 calls; and 2018: 1,476,379 calls.

15 Simpler call types include: turn-on service, turn-off service, payment processing, and service account information and changes.

16 For example, in 2018, the new programs and services handled by ENAs included TOU (Time Of Use), CPP (Critical Peak Pricing), CCA (Community Choice Aggregation), PEV (Plug-In Electric Vehicles) / EV (Electric Vehicles), SDP (Summer Discount Plan), CARE (California Alternate Rates for Energy), NEM (Net Energy Metering), QAB (Questions About the Bill), and WebChat support.

12

Table II-3 CCC Performance Metrics

2014-2018

In the Test Year, the CCC will continue to use automated call-routing 1

technologies so that customers with complex issues can be assisted by trained and knowledgeable 2

ENAs, who will be able to educate customers about their options and resolve complex issues that are not 3

suitable for self-service. During the 2021 GRC period, in addition to greater call complexity, the CCC 4

expects total call volume to increase because of new rates and rate changes, new regulatory mandates, 5

continued Community Choice Aggregation (CCA) activity, and potential call activity dependent on 6

PSPS events. 7

(2) Outbound Communications 8

In addition to handling inbound calls, SCE’s CCC also utilizes its IVR 9

system to place outbound calls. Customers can receive these outbound calls in English or Spanish. The 10

CCC made approximately 9.7 million17 outbound IVR call attempts in 2018 related to credit and 11

collections and outage notifications. Of these outbound call attempts, approximately 6.9 million 12

informed customers of potential service disconnections for nonpayment, available payment options, and 13

resources available for obtaining payment assistance. In addition, maintenance outage notification 14

outbound call attempts decreased from 3.6 million in 2014 to 2.5 million in 2018 primarily due to 15

variations in (a) the number of maintenance outages, (b) average number of affected customers per 16

outage, and (c) the number of attempts necessary before the customer answered. 17

17 9.7 million 2018 outbound calls = 6.9 million IVR credit calls + 2.5 million IVR maintenance outage calls +

0.3 million IVR outage calls.

13

(3) Project Management 1

Project managers and analysts support the CCC by implementing 2

customer contact and other CS operational projects, such as Speech Analytics, Interactive Voice 3

Response, programs mandated by regulatory decisions, and system/process improvements. The Project 4

Management group is essential to the CCC because they implement regulatory-directed programs which 5

affect CCC and other CS operations. The Project Management group also develops and prioritizes 6

business requirements for process improvements to support various Operational Excellence initiatives 7

and call center technology upgrades. Furthermore, SCE expects that the Project Management group will 8

continue to find and implement newly identified Operational Excellence initiatives that may offset 9

unexpected increases in call volumes related to emerging efforts, such as Transportation Electrification 10

and Building Electrification. 11

b) Need for Activity 12

Handling customer calls is an essential part of basic customer service, and allows 13

customers to make requests and inquiries (e.g., service establishment and transfer of service, payment 14

arrangements, billing inquiries, and credit extensions), report power outages, ask about energy solutions, 15

and inquire regarding new programs and services (e.g., dynamic pricing, time-of-use (TOU), net energy 16

metering, and plug-in electric vehicle rate options). ENAs also respond to 911 calls from local police 17

and fire agencies to handle urgent information needs and access to SCE personnel and resources in 18

emergency situations. With the increase in routine customer service transactions successfully handled 19

through the IVR, self-service platforms, and the contract call center from 2014 to 2018, the remaining 20

complex calls and interactions are handled by the ENAs. Specially-trained ENAs are needed to resolve 21

complex billing inquiries that require billing research, consumption and rate analysis, and customer 22

education. Without the CCC activity, SCE would not be able to effectively respond to customer 23

inquiries and needs. 24

The IVR and associated technologies are critical to effectively handle customer 25

requests and enable SCE to meet its Commission-adopted service-level goal18 of answering 75 percent 26

of calls within 50 seconds, 90 percent of the weeks in a calendar year, as shown in Table II-2, in a cost-27

efficient manner. The IVR handled over 10.5 million customer calls, or 63 percent19 of all the customer 28

18 See D.98-07-077, p. 13.

19 63 percent = 10,508,592 IVR call volume / 16,605,412 total call volume.

14

calls received, in 2018. Without the IVR and related technologies, SCE would not be able to cost-1

effectively respond to customer inquiries and support needs. 2

c) Comparison of Authorized 2018 to Recorded20 3

Figure II-4 compares the requested and authorized O&M expenses from SCE’s 4

2018 GRC with the 2018 recorded expenses in the CCC GRC Activity, in compliance with 5

D.19-05-020. As shown in Figure II-4, SCE’s recorded expenses for 2018 in CCC were less than the 6

authorized amount by $1.585 million, a variance of approximately three percent, which is within normal 7

operating parameters, and primarily due to increased cost efficiency and call deflection. 8


15

Figure II-4 Customer Contact Center


d) Scope and Forecast Analysis 1

This section describes the historical O&M expenses, the Test Year forecast 2

method, and the adjustments included in the Test Year O&M forecast for the CCC. The recorded 3

adjusted historical and forecast O&M expenses for CCC are shown in Figure II-5 and discussed below. 4

$49,800 $46,979

$45,394

0

10,000

20,000

30,000

40,000

50,000

60,000

2018 Request 2018 Authorized Customer Contact Center 2018 Recorded

Customer Contact Center

($1,585)

16



(1) Historical Variance Analysis 1

(a) Labor 2

Recorded labor decreased by $8.847 million or 23 percent from 3

2014 to 2016 due to Operational Excellence initiatives such as call deflection initiatives,22 workforce 4

optimization and reduction through natural attrition, and directing calls to the contract call center. These 5

Operational Excellence initiatives resulted in sustainable annual cost reductions of approximately $7-8 6

million. Furthermore, 2017 recorded costs reflect these sustainable annual cost reductions, and also 7

include additional staffing to improve customer service levels relative to 2016 service levels. In 2018, 8

SCE was able to reduce labor costs as a result of its continued efforts to improve cost efficiency, which 9

included certain call deflection initiatives. 10

21 Refer to WP SCE-03, Vol. 4A, pp. 2-6, for Customer Contact Center recorded and forecast financial

information.

22 Call deflection is defined as the reduction of customer live-agent calls by the provision of self-service options to obtain information or complete a transaction, such as utilizing the IVR system or SCE.com.

17

(b) Non-Labor 1

Recorded non-labor has generally increased from 2014 to 2018 as 2

more customer phone calls have been handled by the contract call center provider to handle routine 3

customer service transactions. 4

(2) Forecast 5

(a) Labor 6

As shown in Figure II-5, labor expenses have declined over the 7

historical period from $37.675 million in 2014 to $28.922 million in 2018. For labor expenses, the Last 8

Recorded Year represents an appropriate base for the Test Year forecast because it accurately reflects 9

the expected base level of CCC activities for the Test Year. As discussed in section II.C.1.d.2(c) below, 10

SCE then made certain Test Year adjustments to the Last Recorded Year labor expenses to accurately 11

reflect SCE’s anticipated CCC activities in the Test Year. As a result, the Last Recorded Year, combined 12

with the Test Year adjustments detailed below, is the appropriate method for forecasting CCC Test Year 13

labor expenses. For the Test Year 2021, SCE forecasts labor expenses of $28.942 million, which 14

represents an increase of $0.020 million from the Base Year 2018 recorded costs of $28.922 million. 15

(b) Non-Labor 16

As shown in Figure II-5, non-labor expenses generally increased 17

from 2014 to 2018 due to the movement of a greater volume of routine transactions to the contract call 18

center. The contract call center is expected to keep handling these types of routine transactions. Thus, 19

the Last Recorded Year is an appropriate basis to start with for the Test Year forecast because it 20

accurately reflects the expected base level of CCC activities for the Test Year. SCE then made certain 21

Test Year adjustments to the Last Recorded Year non-labor expenses, as discussed in section 22

II.C.1.d.2(c) below, which are necessary to accurately reflect SCE’s anticipated CCC activities in the 23

Test Year. As a result, the Last Recorded Year, combined with the Test Year adjustments detailed 24

below, is the appropriate method for forecasting CCC Test Year non-labor expenses. For the Test Year 25

2021, SCE forecasts non-labor expenses of $16.120 million, which represents a decrease of $0.352 26

million from Base Year 2018 recorded costs of $16.472 million. 27

(c) Test Year Adjustments 28

SCE’s forecast of Test Year O&M expenses for CCC reflects 29

decreased expenses compared to Base Year spending due to reduced expenses associated with 30

Operational Excellence initiatives and CS Re-Platform benefits, which are partially offset by increases 31

18

in forecast call volume from CCA-related calls and CS Re-Platform stabilization. These Test Year 1

adjustments are described in detail below and summarized in Table II-4. 2

Table II-4 CCC Test Year Adjustments

Forecast O&M Expenses (Constant 2018 $000)

(i) CCA Call Volume Growth 3

SCE expects CCA call activity to increase from 4

2018 to the GRC Test Year.23 In prior years, customers impacted by CCA formation in the CCA’s 5

service area frequently contacted SCE’s CCC with questions. Based on this past experience, SCE 6

expects ongoing and increased CCA activity to continue resulting in CCA-related customer questions 7

coming into the CCC that will drive up call volume in the Test Year. Also, due to the complexity of 8

these types of calls, SCE expects that the CCC ENAs will spend more time per call relative to average 9

handle times to answer questions about these programs (i.e., customer calls related to CCAs have longer 10

AHT than non-CCA calls). As such, SCE forecasts that the increase in CCA call activity will require 11

approximately fifteen additional FTEs in the Test Year at an estimated annual labor expense of 12

approximately $750,000.24 13

(ii) CCC Operational Improvement Initiatives 14

The CCC has identified three operational 15

improvement initiatives that will reduce its forecast costs in the Test Year. First, CCC forecasts a 16

reduction in staffing levels by approximately four to five ENAs based on a forecast 0.4 percent increase 17

in diversion to self-service. Second, by shifting three percent of calls to the contract call center, SCE is 18

23 See SCE-03, Vol. 5 Business Account Management Services for SCE’s expectation of CCA growth. SCE

expects the number of CCAs in its service territory to increase from 6 in 2018 to 26 in 2021.

24 Refer to WP SCE-03 Vol. 4A, pp. 7-8 – Calculation to Determine FTE Requirements from CCA Growth for additional details.

Line No. Description Labor Non Labor Total1 CCA Call Volume Growth $750 $0 $7502 CCC Operational Improvement Initiatives ($730) ($352) ($1,082)3 Total Test Year Adjustments $20 ($352) ($332)

19

forecasting an additional reduction in staff of 10 ENAs. Finally, SCE expects non-labor savings of 1

$352,000 in 2021 from a reduction of vendor costs to support staff augmentation. With these benefits, 2

SCE forecasts 2021 Test Year savings of $1.082 million.25 3

(d) Summary of Request 4

As shown below in Figure II-6, SCE forecasts $45.062 million in 5

total O&M expenses for the CCC, a decrease of $0.332 million, or 0.7 percent, compared to Base Year 6

O&M expenses of $45.394 million. 7

25 Refer to WP SCE-03 Vol. 4A, p. 9 – CCC Operational Improvements Initiative for additional details.

20


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

e) Basis for O&M Cost Forecast Method 1

The 2018 Base Year activities for Customer Contact Center are described above. 2

The Last Recorded Year accurately reflects the expense level associated with Base Year activity levels 3

that are planned to continue through the Test Year, plus the adjustments proposed. For these reasons, the 4

Last Recorded Year, plus adjustments, is the appropriate basis for forecasting Test Year non-labor 5

expenses.26 6

26 The decision to use Last Recorded Year as the basis for the Test Year O&M expense forecast for Customer

Contact Center 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, overall O&M expenses have generally trended downward over the period 2014-2018.

$45,394$750

($1,082)

$45,062

$0

$5,000

$10,000

$15,000

$20,000

$25,000

$30,000

$35,000

$40,000

$45,000

$50,000

2018Recorded

CCA Call VolumeGrowth

CCC OperationalImprovement

Initiatives

2021Forecast

21

2. Business Account Management 1


Business Account Management provides a variety of customer support services 3

ranging from basic customer care functions (e.g., resolving billing, metering, credit/payment issues) to 4

more comprehensive support (e.g., educating customers on complex bill components, utility tariffs, 5

resolution of repair and maintenance outages, interconnection and added facilities agreements, and 6

distribution service requests). Business Account Management is instrumental in engaging and educating 7

customers on business resiliency plans in support of the state’s mandate for wildfire mitigation 8

strategies27 and in supporting customer participation in SCE’s Transportation Electrification program to 9

reduce greenhouse gas emissions through the electrification of ports and transport vehicles, and through 10

the installation of charging stations.28 The services and information that Business Account Management 11

provides fall within four categories: (1) account management activities, (2) technical support services, 12

(3) outage experience, and (4) other supporting services. These categories are discussed below. 13

Business Account Management activities and personnel are generally categorized 14

into assigned and unassigned groupings.29 Assigned account managers manage a portfolio of 15

approximately 4,500 medium to large businesses, serving as the first point of contact and providing 16

customer care and consultation through face-to-face interactions and routine phone and email 17

communications. Unassigned account managers serve smaller business customers using direct customer 18

contact and strategic customer outreach. Outreach for unassigned business customers is generally 19

conducted by leveraging strategic relationships with ethnic and diverse business connections, organizing 20

and attending industry specific trade and business association events and conferences, community 21

forums, and other settings dedicated to small and medium businesses. 22

27 See California’s Utility Wildfire Mitigation Plan (SB 901): https://www.cpuc.ca.gov/SB901/. Educating

customers on business resiliency plans includes one-on-one or small group consultations with a focus on awareness and planning. Such discussions may focus on SCE’s long-term and short term plans, how SCE’s plans may impact customers, and understanding what critical needs the customer’s resiliency plans are addressing, if any. These discussions may also assist with ideas for customer plans for contingencies, such as back-up power systems or operational strategies.

28 See SCE-03, Volume 5 for more information.

29 Customers are divided between assigned and unassigned account managers based on customer size, involvement in SCE programs, complexity of rates and operations, specialized service arrangements involving customer substations, advanced metering or interconnection requirements, geographical location, and industry type.

22

Over the last five years, Business Account Management has completed the 1

implementation of a new Account Coverage Model by consolidating and optimizing its business account 2

management support services functions to better align with non-residential customers’ energy related 3

needs. Prior to this approach, Business Account Management assigned account managers to business 4

customers based primarily on customer size measured by their energy consumption. However, after 5

internal analysis, Business Account Management discovered that this approach could be improved upon, 6

since some larger customers did not necessarily require the same level of service from their account 7

manager. The adopted new approach allows SCE to offer the right types of programs and services at the 8

right time and through the right delivery methods, while leveraging technology to make business 9

account management more streamlined, efficient, and effective and still providing a high-quality 10

customer care experience. Under this customer engagement model, in operation today, account 11

management resources are assigned based on complexity of operations, service needs, energy use, and 12

other customer-specific factors such as involvement with national security or critical health and human 13

services. 14

(1) Account Management Activities 15

As described above, Business Account Management supports large, 16

medium, and small non-residential customers through education, consultation, and feasibility studies. 17

More specifically, account management activities include resolution of billing and metering inquiries, 18

credit resolution issues, power quality research, PSPS education and notification, outage education and 19

notification, distributed energy resource and transportation electrification consultation, energy efficiency 20

consultation, and demand response education and enrollment. 21

(a) Resolution of Billing and Metering Inquiries 22

The Business Account Management team assists non-residential 23

customers with questions related to billing and metering. These questions arise, in part, due to the 24

variety of complex metering, billing, rate options, and programs available to customers. Billing and 25

metering inquiries also include resolving issues related to energy charges, usage calculations, billing 26

factors/accuracy, and metering operations. Additionally, as behind-the-meter technologies continue to 27

advance and customers deploy multiple power generation and storage systems behind the meter, 28

Business Account Management works to ensure that customers have accurate metering and billing 29

arrangements in place. Due to the complexity of these inquiries and programs, account managers serve 30

23

as the main point of contact for education and complex issue resolution. Tariff interpretation is often 1

involved with resolving these issues. 2

(b) Rate Option Assistance 3

This activity consists of account managers explaining customized 4

rate analysis and tariff requirements, such as firm service levels and voltage levels to facilitate customer 5

decisions about energy usage patterns, available demand response programs, and optional rate choices, 6

which help lower energy costs. Nearly two-thirds of SCE’s electric rates apply to the business customers 7

served by Business Account Management.30 These customers have a wide range of rate and billing 8

options to meet their energy management needs based on operational practices. 9

For example, in March 2019, the majority of business customers 10

were subject to changing time-of-use (TOU) periods and most small to medium customers defaulted to 11

the Critical Peak Pricing (CPP) program.31 Consequently, these customers required education and 12

support on how the CPP rate worked to determine if CPP or another rate option best met their needs. 13

Personalized consultation by the Business Account Management team helps business customers make 14

informed decisions on the best rate for their business. 15

(c) Credit Issue Resolution 16

The Business Account Management team serves as the key contact 17

for educating non-residential customers on the rules regarding credit policies and the need to maintain 18

favorable credit with the utility, which may include negotiating deposits and financial security 19

arrangements with the financial decision makers at the business. SCE’s credit administrators and 20

financial analysts depend on Business Account Management to facilitate communications with customer 21

decision makers and to provide specific knowledge of the customer to help resolve credit issues and 22

ensure appropriate actions are taken by the customer. The Business Account Management team interacts 23

with customers’ senior financial officers to explain late payment charges, security deposits, and other 24

issues related to financial risk, and assist in the development of solutions to these situations. 25

30 Refer to WP SCE-03, Vol. 4A, pp. 17-18 – Residential and Non-Residential Tariffs for additional details

regarding residential and non-residential rates. SCE currently has approximately 110 residential rates and approximately 160 non-residential rates.

31 See SCE-03, Vol. 5 for more details on SCE’s CPP program.

24

(d) Distributed Energy Resource and Transportation Electrification 1

Consultation 2

As customer choice continues to evolve and clean energy and 3

renewable technologies advance, Business Account Management serves as an unbiased and strategic 4

consultant to business customers, partnering with them to make informed business decisions on the 5

numerous energy options available and assisting them through SCE’s various application processes such 6

as interconnection agreements. Account managers maintain up-to-date knowledge on emerging 7

technologies and discuss strategies and technologies with business customers regarding the installation 8

of distributed energy resources (DER) including self-generation technologies, use of smart inverters, 9

battery storage, microgrids, local capacity requirement programs, net energy metering options, and many 10

others. SCE’s Clean Energy Optimization Pilot is an example of how SCE is responding to industry and 11

customer goals to reduce greenhouse gas emissions by providing holistic, DER-focused solutions as 12

opposed to the traditional energy efficiency (EE) and other demand side management (DSM) 13

programs.32 14

In addition to helping customers make clean energy choices, 15

Business Account Management serves as the customers’ and third party DER technology firms’ main 16

point of contact for complex energy technology consultation at a business customer’s site. Business 17

Account Management coordinates and supports SCE resources and subject matter experts assisting 18

customers with implementation and interconnection of their distributed energy technology strategies. 19

This includes bringing the customers’ facility and operational experts together with SCE distributed 20

energy resource specialists, field engineers, interconnection specialists, and planning personnel to assist 21

customers in the assessment and implementation of large energy projects.33 22

Business Account Management also assists customers by 23

providing education and information about SCE’s Transportation Electrification (TE) programs, 24

available technologies, and benefits (environmental, societal, and business value). Account managers 25

not only help create a pipeline of customers who are ready to begin the application process, but also 26

32 The Clean Energy Optimization Pilot is a pilot program which will provide incentive payments directly for

GHG emission reductions, rather than for electricity savings or directly for equipment. See Application (A.) 18-05-015 Application of Southern California Edison Company for Approval of Its Clean Energy Optimization Pilot, and D.19-04-010, April 25, 2019, for more information.

33 See SCE-03, Vol. 5 for more details regarding Distributed Energy Resources.

25

support the customer throughout the program lifecycle. This includes coordination of site assessments 1

and feasibility discussions with subject matter experts for the planning and deployment of fleets (new 2

and conversions) and charging infrastructure (siting, sizing, evaluating the grid, etc.), evaluation of load 3

estimates and rate analyses to help customers understand the incremental energy cost of incorporating 4

TE into their business operations, identification of solar and energy storage opportunities, and 5

informing customers about SCE and third party financial incentives and grants available to support TE 6

adoption. Business Account Management also supports customers in reducing their carbon footprint, but 7

also helps customers comply with existing and planned greenhouse gas reduction regulations or their 8

own independent sustainability goals. 9

(e) Public Safety Power Shutoff and Outage Education and 10

Notification 11

Due to the growing threat of wildfires in California, account 12

managers have taken on a new role as the main point of contact for Public Safety Power Shutoff (PSPS) 13

education and notifications to customers. In this role, account managers are on call 24 hours per day, 7 14

days a week and provide real-time communications and outage information on a proactive and reactive 15

basis. Coordination of PSPS efforts is complex, and must take into account the customer’s operational 16

needs and purpose (e.g., health and human services), as well as the need for technical solutions and 17

support by the utility (e.g., backup generation). Coordination activities by account managers also 18

includes proactive/preventative communications and information sharing, such as in-person 19

presentations, educational workshops, and direct follow-up with customers located in high fire areas that 20

have the potential of being de-energized during a PSPS event. These new circumstances require SCE 21

account managers to discuss and support customers in the development and implementation of their 22

resiliency plans in coordination with SCE’s own resiliency plans to be prepared for potential critical 23

situations, such as PSPS activations. In particular, the account managers have a critical role in 24

communicating with and assisting cities, counties, water agencies, telecommunications, hospitals, and 25

critical care agencies with outage management plans in the event a PSPS is needed in areas where 26

wildfire risk is high. In addition, maintaining up-to-date contact information for these sensitive 27

customers in high fire areas is of utmost importance so they receive notifications in a timely manner and 28

are able to properly prepare their businesses. Account managers coordinate closely with BCD’s Outage 29

Team to receive timely information on outage events, and participate in training sessions that provide 30

26

the most up-to-date information on SCE’s customer-facing communication processes before, during, and 1

after an outage event. 2

(f) Power Quality Research 3

Business Account Management initiates and facilitates the 4

coordination of transmission and distribution system power quality analysis to be delivered to customers 5

and assists in the resolution of issues, regardless of whether the root cause is SCE’s or the customer’s 6

equipment. In some instances, unsafe situations at the customer site are uncovered, and account 7

managers provide information to facilitate safe operating conditions. Power quality information is 8

increasingly important to customer operations as modern, computerized controls and automation 9

technologies are implemented at customer facilities, which are more sensitive to power quality 10

fluctuation than older electro-mechanically controlled equipment. 11

(g) Demand Response Information 12

As outlined in the state’s Energy Action Plan II,34 adopted by the 13

California Public Utilities Commission (CPUC) and the California Energy Commission, energy 14

efficiency and demand response are the highest priority in the loading order to meet increased electrical 15

demands, ahead of traditional generation or supply resources. Business Account Management consults 16

with customers about enrollment in new and modified demand response programs such as the base-17

interruptible program (BIP), agricultural and pumping interruptible (AP-I), and Critical Peak Pricing 18

(CPP). Through on-site customer visits and telephone conversations, account managers evaluate and 19

educate customers on how these programs and technologies can become part of their operations and help 20

lower energy costs, as well as support the operation of the grid during peak periods. 21

(2) Technical Support Services 22

SCE’s Technical Support Services provide a specialized level of technical 23

expertise to support activities such as development of customized rate analysis information and data 24

solutions, engineering and design services, and formal education and training. 25

(a) Engineering and Design Services 26

The engineers and technical specialists within the Engineering and 27

Design Solutions team (E&DS) provide targeted technical consultation to SCE’s non-residential 28

34 See https://www.cpuc.ca.gov/eaps/.

27

customers through on-site visits and evaluations at customer facilities.35 Through these activities, 1

recommendations regarding energy and technology solutions, and assistance with energy and cost 2

calculations for customers considering equipment, building, process, and operational changes are 3

provided. This team provides assistance in more complex technical situations that exceed the account 4

manager’s level of technical knowledge and experience. 5

The engineers and technical specialists routinely provide energy 6

modeling and calculated energy savings estimates to help SCE’s non-residential customers make 7

decisions about equipment replacement, building and process optimization & electrification, distributed 8

energy resource integration, transportation electrification solutions, and various rate and demand 9

response program participation options. When providing this assistance, engineers and technical 10

specialists often use specialized portable equipment to obtain data (e.g., equipment and/or production 11

line level electricity use, fluid flow, system temperatures, etc.) necessary for providing a level of 12

accuracy, detail, and objectivity that customers are typically unable to provide for themselves when 13

evaluating energy decisions critical to achieving important financial, operational, and/or sustainability 14

goals. 15

(b) Rate Analysis Center of Excellence 16

The Rate Analysis Center of Excellence (COE) supports the 17

Business Account Management and Customer Programs and Services (CP&S) organizations by helping 18

educate and inform customers about beneficial rate options, performing rate analyses for non-residential 19

customers, and comparing multiple complex rate options for large groups of non-residential customers 20

impacted by changes in rates or demand response rate options. The Rate Analysis COE, comprised of 21

subject matter experts, constructs rate and load aggregation models to compare proposed rates to 22

existing rates and to compare bill impacts on individual service accounts or groups of service accounts 23

on multiple proposed rates in mass. Each rate analysis, independent of the size or complexity of the 24

effort, entails to some degree the acquisition and normalization of usage data and the calculation and 25

validation of the results. The Rate Plan Comparison Tool, implemented in 2019, is a customer-facing 26

tool that allows customers to view simple rate analyses, submit rate change requests, and opt-out of 27

default rates such as critical peak pricing, while allowing the Rate Analysis COE to focus on more 28

35 SCE performed approximately 594,787, and 842 technical consultations in 2016, 2017, and 2018,

respectively.

28

complex rate analyses not available in the tool. The Rate Analysis COE is also responsible for the on-1

going maintenance and enhancement of this new tool. This team of rate analysis experts also provides 2

support to Business Account Management’s Customer Choice Services36 team by completing Joint Rate 3

Comparisons for Community Choice Aggregators. 4

(c) Customer Relationship Management Operations 5

Customer Relationship Management (CRM) is an automated 6

system that manages customer-related information by providing consistent documentation, tracking, and 7

delivery of customer communications. This information management system enables BCD and other 8

SCE program managers to provide consistent documentation, tracking, and delivery of customer 9

communications. The CRM system establishes a platform for program managers, account managers, and 10

other Customer Service employees to manage workflow, fulfill work requests, and sort and categorize 11

customer contact attributes to expedite the delivery of outbound customer education and information 12

materials. CRM is the central repository for most program-related interactions, including TE, DER, Grid 13

Resiliency, and Customer Care interactions, customer names, addresses, and other information. This 14

information helps BCD comply with required customer notifications about rates and programs and 15

maintains records of which customers were notified. 16

(3) Outage Experience 17

BCD’s Outage Team consists of individuals with knowledge of SCE’s 18

transmission and distribution systems, grid operations, customer service programs, and technology 19

solutions processes. The team uses this cross-cutting knowledge to coordinate and implement education 20

and communication initiatives designed to improve customer experience and satisfaction, and to 21

increase public safety before, during, and after a de-energization event. BCD’s Outage Team leads all 22

communication aspects of the outage experience, such as sending out notifications to customers 23

impacted by outages, and addressing any questions or inquiries pertaining to a specific outage or PSPS 24

event. The Outage Team also provides around-the-clock outage information and support to SCE’s 25

business account managers and Business Resiliency teams,37 and SCE’s Local Public Affairs, within 26

36 See SCE-03, Vol. 5 for more information about activities performed by SCE’s Customer Choice Services

organization.

37 The Outage Team supports SCE’s Business Resiliency Team by coordinating all outage communications related to PSPS activities.

29

communities impacted by an outage event. The 2018 Base Year activities carried out by BCD’s Outage 1

Team are described below. 2

(a) Proactive Communications to Support Outages 3

The Outage Team coordinates and delivers Dear Neighbor letters38 4

which are delivered to customers via US mail, email, or targeted social media campaigns for PSPS 5

activities and for maintenance outages. These letters provide a detailed communication to customers 6

within a specific geographic area who may experience increased traffic, lane closures, large equipment, 7

noise, or multiple outages, and are one way that SCE’s Outage Team proactively communicates with 8

customers in an effort to improve customer experience and satisfaction, and to increase public safety 9

awareness before a de-energization event, in addition to standard outage notifications. In 2018, SCE sent 10

nearly 2.4 million Dear Neighbor communications, 2.2 million of which were sent to support PSPS 11

activities. 12

(b) Public Educational Workshops 13

The Outage Team hosts educational workshops to help 14

communicate the need and provide the public with a better understanding of the need, for de-15

energization events. These workshops, also known as “PowerTalks,” are offered to all customers, and 16

are delivered throughout SCE’s service territory. The topics discussed include an overview of SCE’s 17

strategy on improving reliability, the different types of outages, how outages are caused, outage self-18

service tools, and resources customers can use to stay prepared and informed. SCE’s PowerTalks also 19

educate customers on the wildfire risk in California and SCE’s plan to mitigate the risks associated with 20

wildfires, and they provide an overview of the PSPS communication and SCE’s power shutoff and 21

restoration processes. SCE hosts PowerTalks in existing SCE facilities, public buildings, hotels, and 22

community centers to enhance customer accessibility. Customers who cannot attend PowerTalk sessions 23

in-person can do so remotely through online video and teleconferencing services. In 2018, BCD hosted 24

159 PowerTalk sessions with over 3,000 attendees. SCE’s Outage Team expects to conduct more than 25

100 of these events on an annual basis. In addition to PowerTalks, the team also facilitates separate 26

community meetings at the request of customers to address customers’ needs or concerns. These are 27

typically held at college campuses, industry associations, local government agencies, and even large 28

business customers such as hospitals. 29

38 Refer to WP SCE-03 Vol. 4A, p. 19 – Sample of ‘Dear Neighbor’ letter for additional details.

30

(c) Outage Communication Projects 1

SCE works to continually improve customer experience and 2

satisfaction related to outages. For example, in 2018, BCD’s Outage Team developed and implemented 3

several technology projects to improve customer communications, experience, and satisfaction related to 4

outages. SCE’s Outage Progress Tracker was launched on SCE’s website in February 2018, and 5

provides an intuitive, interactive display of near-real-time outage information including estimated 6

restoration time, number of customers impacted, and tips to help customers stay safe during an outage. 7

In October 2018, SCE launched the Customer Crew Connect (C3), which is a new smartphone 8

application that enables SCE field crews to update real-time outage information across key data 9

platforms. The C3 smartphone application eliminates delays due to manual data entry processes and 10

allows for timely and accurate information updates to customers impacted by an outage. 11

(d) Support of Essential Use Services and Re-Certification 12

BCD’s Outage Team also reviews new service accounts to identify 13

customers that provide essential use services and coordinates the annual re-certification process to 14

confirm the continued eligibility of existing essential use customers. Essential use customers are those 15

non-residential customers that provide essential public health, safety, and security services. Sections of 16

distribution or sub-transmission lines serving essential use customers who either do not have adequate 17

back-up generation or are within a category that is exempt regardless of the status of back-up generation 18

(e.g., hospitals and nursing facilities) are exempt from rotating outages.39 19

The work activities performed by BCD’s Outage Team are 20

necessary to deliver timely and accurate communications before, during, and after de-energization 21

events. Residential customers expect to be kept informed of outage events so they may alter personal, 22

school, work, child, elder or animal care provider schedules to ensure pertinent needs are being met 23

during an outage event. Business customers also need awareness of outage events so they may change 24

production schedules, and plan for alternate measures such as a generator to continue operations, or 25

make alternate arrangements to provide essential services to critical care or other vulnerable customer 26

39 Refer to WP SCE-03 Vol. 4A, pp. 20-21 – Classification of Essential Use Customers for additional details

regarding classifications of Essential Use Customers which is also available on sce.com at https://www.sce.com/sites/default/files/custom-files/docs/PDF/Essential_Use_Customer_Classification_Priority_System_Rotating_Outages.pdf?MOD=AJPERES.

31

populations whose health and safety would be put at risk during an outage. BCD’s Outage Team 1

continues to deliver support by proactively communicating thousands of outage events and updates each 2

month. BCD’s Outage Team also provides outage training and education for customer facing employees 3

across SCE, including specialized training for BCD’s account management staff.40 Without these key 4

activities, SCE would not be able to effectively support customer communications before, during, and 5

after outage events, including outages associated with SCE’s PSPS process during dangerous conditions. 6

(4) Other Support Services 7

(a) Streetlighting Solutions 8

Business Account Management is responsible for street light 9

related policy development and for providing customer interface for issues relating to SCE and customer 10

owned street lights. In this role, Business Account Management coordinates street light functions 11

throughout SCE, including work with Transmission and Distribution (T&D), Finance, Regulatory 12

Affairs, and Treasurers organizations. Business Account Management’s Street Light team focuses on 13

key areas that impact street light customers and helps to bring forward key technology shifts in the 14

industry. Business Account Management fields ad hoc requests in support of account managers, T&D, 15

and Local Public Affairs team members to facilitate analysis and review of technical data, for solutions 16

and review policy issues, evaluate and propose technology enhancements, process service requests, and 17

develop and share street lighting information. To better respond to customer feedback, Business 18

Account Management is responsible for resolving customer inquiries for escalated street light issues. 19

Business Account Management Street Light Team manages street 20

light acquisition projects being completed under Section 851 applications or advice letters. The team 21

works with customers to fulfill acquisition agreements and transition Rate Schedule LS-1 street lights in 22

specific communities to customer ownership (Rate Schedule LS-2). SCE is no longer offering LS-1 23

street light acquisitions and is honoring and completing agreements for customers that met the 24

requirements and entered the SCE street light acquisition queue prior to August 15, 2015. 25


As described above, Business Account Management provides a number of critical 27

services in support of SCE’s business customers’ needs. In addition, the nature of this activity is 28

40 See “Public Safety Power Shutoff and Outage Education and Notification” above for descriptions of how

BCD account managers coordinate closely with the Outage Team on customer-facing education and awareness activities.

32

evolving and expanding to meet new customer needs arising as a result of external factors such as 1

increased focus on reducing greenhouse gas emissions, and the need for resiliency planning in the face 2

of wildfires and other natural disasters. Business Account Management offers customers information 3

and serves as a trusted advisor to assist customers in evaluating clean energy options and in developing 4

strong resiliency plans to limit business losses in the event of power outages as a result of natural 5

disasters such as wildfires. 6

The CPUC’s support for a move towards solicitations for energy procurement 7

activities, including Energy Efficiency solicitations, has resulted in the need for more Business Account 8

Management activities. For example, third parties (for local capacity requirement (LCR) and EE) drive 9

customer questions, which in turn requires validation and customer education. Regardless of how the 10

energy market operates, customers come to SCE to become better educated and objectively informed 11

about their options. 12

Further, Business Account Management facilitates wise energy-related decisions 13

and delivers cost effective and creative customer solutions while managing complex customer care 14

related issues. Business account managers engage, educate, and partner with customers to make sense of 15

the growing and changing portfolio of DERs from energy efficiency to distributed generation, 16

transportation electrification, and a variety of new rates (e.g., dynamic pricing, time-of-use) and energy 17

procurement choices. Business customers rely on account management teams to help navigate the 18

changing and complex energy environment in California. Business Account Management will support 19

customers as they plan for energy resiliency and drive focused outreach strategies and advisory services 20

to encourage customer participation in TE programs and pilots. 21

Without this activity, SCE would not be able to effectively support its non-22

residential customers with their routine customer care inquiries and on new and emerging topics and 23

issues such as greenhouse gas reductions, comprehensive resiliency planning, energy procurement 24

solicitations, DERs, and transportation electrification. 25



2018 GRC with the recorded expenses for the Business Account Management GRC Activity. As shown 28

in the Figure II-7 below, SCE’s recorded expenses for 2018 in Business Account Management were less 29


33

than the authorized amount by $1.555 million, a 10 percent variance. This variance is due to refinements 1

of the Account Coverage Model as further discussed below, and the fact that SCE did not conduct self-2

service promotion campaigns pending a final decision in SCE’s 2018 GRC proceeding. 3

34

Figure II-7 Business Account Management



$15,478 $15,691

$14,136

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

2018 Request 2018 Authorized Business AccountManagement

2018 Recorded

Business Account Management

($1,555)

35




(a) Labor 2

Recorded labor costs increased by $1.577 million between 2014 3

and 2015 primarily due to Business Account Management filling in key vacancies and due to increased 4

support of infrastructure and reliability efforts, as well as increased customer requests for information 5

regarding the impacts of regulatory, legislative, and tariff changes. Costs decreased by $4.647 million 6

between 2015 and 2016 as a result of BCD’s continuous improvement efforts to streamline, refine, and 7

improve BCD’s Account Coverage Model by implementing an inside account management model for 8

mid-market customers in which interactions changed from face-to-face engagements to phone and email 9

exchanges as a primary communication approach. The decrease from 2016 to 2017 is partially due to 10

Outage Management costs which were recorded in accordance with GAAP rules and FERC accounting 11

42 Refer to WP SCE-03, Vol. 4A, pp. 11-15, for Business Account Management recorded and forecast financial

information.

36

guidelines. This accounting treatment is expected to continue through the forecast period. In addition, 1

costs decreased due to the centralization of three planning staff from Business Account Management to 2

Customer Service. The $1.356 million increase in costs between 2017 and 2018 was due to the need for 3

increased customer care in support of transportation electrification, billing inquiries, distributed energy 4

resources, education and consultation associated with more complex rates, education on new self-service 5

tools on SCE.com, and outage support activities. 6

(b) Non-Labor 7

Recorded non-labor costs decreased $0.564 million between 2014 8

and 2016. This decrease is consistent with the associated decrease in labor over the same period, as 9

discussed above. The decrease from 2016 to 2017 is due to Outage Management costs which were 10

recorded in accordance with GAAP rules and FERC accounting guidelines. This accounting treatment is 11

expected to continue through the forecast period. The increase in recorded non-labor costs of $0.712 12

from 2017 to 2018 was driven largely by expanded delivery of Dear Neighbor letters from nearly 13

200,000 in 2017 to almost 2.4 million in 2018. Most of these letters (2.2 million) were sent to support 14

PSPS activities. 15

(2) Forecast 16

(a) Labor 17

The 2018 Base Year activities for Business Account Management 18

are described in Section II.C.2.a of this Volume. The Last Recorded Year is an appropriate basis to start 19

with for the Test Year forecast because it accurately reflects the expected base level of Business 20

Account Management activities for the Test Year. SCE then has made certain Test Year adjustments to 21

the Last Recorded Year labor expenses, as discussed in section (c) below, which are necessary to 22

accurately reflect SCE’s anticipated Business Account Management activities in the Test Year. As a 23

result, the Last Recorded Year, combined with the adjustments detailed below, is the appropriate method 24

for forecasting Test Year labor expenses. For the Test Year 2021, SCE forecasts labor expenses of 25

$17.283 million, which represents an increase of $5.161 million over Base Year 2018 recorded costs of 26

$12.122 million. 27

(b) Non-Labor 28

The Last Recorded Year is an appropriate basis to start with for the 29

Test Year forecast because it accurately reflects the expected base level of Business Account 30

Management activities for the Test Year. SCE then has made certain Test Year adjustments to the Last 31

37

Recorded Year non-labor expenses, as discussed in section (c) below, which are necessary to accurately 1

reflect SCE’s anticipated Business Account Management activities in the Test Year. For these reasons, 2

the Last Recorded Year, combined with the adjustments detailed below, is the appropriate basis for 3

forecasting Test Year non-labor expenses. For the Test Year 2021, SCE forecasts non-labor expenses of 4

$2.395 million for Business Account Management activities, which represents an increase of $0.382 5

million over Base Year 2018 recorded costs of $2.013 million. 6


SCE’s forecast of Test Year O&M expenses for Business Account 8

Management reflects an increase in labor and non-labor expenses of $5.161 million and $0.381 million, 9

respectively, driven primarily by the need for SCE to provide more holistic, Distributed Energy 10

Resources (DER)-focused program and technology solutions rather than the solutions historically 11

offered through SCE’s portfolio of Energy Efficiency and Demand Side Management programs. A 12

number of recently evolving macro factors that impact SCE’s role as an energy provider have also 13

caused a shift in the activities of the Business Account Management team. These adjustments are 14

described below and summarized in Table II-5 and in Figure II-9. 15

Table II-5 Business Account Management

2021 Test Year O&M Adjustments (Constant 2018 $000)

(i) Account Management and Related Support Activities 16

The costs for SCE’s account management and related 17

support functions are authorized by the Commission in SCE’s GRC, Energy Efficiency, and Demand 18

Response proceedings. Historically, approximately 60 percent of these costs have been authorized in the 19

GRC, with the remaining 40 percent authorized in SCE’s Energy Efficiency and Demand Response 20

proceedings. 21

Line No. Description Labor Non Labor Total

1Account Management and Related Support Activities

$5,110 $59 $5,169

2 Outage Communications $51 $322 $3733 Total Test Year Adjustments $5,161 $381 $5,542

38

In recent years, two drivers have shifted the focus of SCE’s 1

account management and related support functions. First, in D.18-05-014, the Commission directed the 2

investor-owned utilities to implement third-party solicitation processes for providing energy efficiency 3

(EE) resources. SCE is implementing these processes and expects to be substantially finished in 2021. 4

This has reduced the amount of time required for account managers to support SCE’s EE programs, 5

which SCE expects to continue into its 2021 GRC period. Second, SCE’s customers are requiring more 6

account manager resources and time to support emerging programs and technologies, such as 7

Transportation Electrification (TE), Grid Resiliency, and DERs, as well as increased customer care to 8

support these programs and technologies. In response to these drivers and to support customers’ 9

evolving needs, SCE has adapted its business account management model and related support functions 10

to spend the appropriate amount of time and resources on EE-related matters, TE, DERs, and grid 11

resiliency. Fundamentally, the business account management support of SCE’s EE programs is declining 12

and the support for TE, DERs, and grid resiliency is increasing. However, SCE forecasts that the overall 13

business account management headcount (for the combined EE and O&M-funded business account 14

management activities) will not change. As such, customer costs and rates will not be impacted by this 15

Test Year adjustment. Put another way, without the reduction in EE support, SCE would have had to add 16

costs and headcount to address these increasing and emerging demands. 17

To meet the evolving needs of customers as discussed 18

above, SCE included a Test Year adjustment of $5.169 million43 for business account management.44 19

This adjustment is necessary to accurately reflect the amount of account manager time and resources 20

needed in the Test Year to support the efforts below. 21

a. Transportation Electrification 22

The expansion of Transportation Electrification,45 23

particularly tied to the to the Charge Ready programs (i.e., Charge Ready Pilot & Bridge, Charge Ready 24

43 Refer to WP SCE-03, Vol 4A, pp. 22-23 – Account Management and Related Support Activities for

additional details.

44 SCE expects that in 2021 energy efficiency portfolio funding previously allocated to the Business Account Management activities will be reduced by $5.169 million. SCE will seek that reduction as part of the required energy efficiency Annual Budget Advice Letter (ABAL) process.

45 Refer to WP SCE-03, Vol. 4A, p. 24 – Transportation Electrification Program Expansion for additional details.

39

Transport, and Charge Ready 2),46 will require an increasing amount of account management support to 1

educate business customers about SCE’s Transportation Electrification programs in order to develop the 2

pipeline of customers who enter into the various application processes.47 In addition to SCE TE 3

programs, there will also be a significant number of third party funded EV charging ports for which the 4

Business Account Management team will provide customer information concerning various TE 5

technologies, review third party proposals, and conduct non-standard rate impact analyses. The team 6

also supports the customer interconnection process and assists with complex metering and billing issues. 7

As the number of EVs increase, the Business Account Management team will be required to meet 8

expanding customer needs in this area. SCE forecasts that customer support activities related to 9

Transportation Electrification programs and general education will triple in the Test Year relative to 10

current levels. As such, Transportation Electrification represents approximately $2.689 million of the 11

total $5.169 million Test Year adjustment for Account Management activities. 12

b. Grid Resiliency 13

Recent natural disasters, particularly wildfires, have 14

raised the level of urgency for both customers and SCE to develop and implement resiliency plans to 15

deal with emergency situations. As a result of SCE’s ongoing grid modernization efforts,48 the number 16

of maintenance outages is expected to increase.49 Account managers will be increasingly called upon to 17

educate customers around resiliency planning and provide information about technologies, such as 18

backup generation and/or battery storage, which can help businesses become more resilient in the face of 19

disasters. SCE’s own ongoing resiliency related activities50 will often be undertaken at the sub-20

transmission and sometimes at the circuit level which will impact customers receiving service through 21

those facilities. Account managers will also be called upon to provide notification and support to 22

customers to ensure their businesses are not negatively impacted as a result of SCE resiliency actions. 23

46 See SCE-03, Vol. 5 for more information about Transportation Electrification.

47 This work is not covered by the Transportation Electrification balancing accounts. See D.16-01-023: Decision Regarding Southern California Edison Company’s Application for Charge Ready and Market Education Programs; D.18-12-006: Decision Granting Petition For Modification.

48 See SCE-02, Vol. 4, Part I for more information regarding SCE’s grid modernization activities.

49 Refer to WP SCE-03 Vol. 4A, p. 25 – Maintenance Outage Forecast for additional details.

50 See SCE-04, Vol.1 (Business Continuation), Vol. 2 (Emergency Management), Vol. 3 (Cybersecurity), Vol. 4 (Physical Security), V. 5A (Wildfire Management) for more information regarding SCE’s grid resiliency activities.

40

Such account management activities are not charged against SCE’s Wildfire Management budget and 1

will need to be charged to O&M. In addition, SCE account managers are responsible for providing 2

customer support and coordination prior to, during, and after a maintenance outage event to safeguard 3

for safety and ensure non-residential customers are prepared, questions answered, and issues resolved 4

quickly to limit the impact to the customer and SCE crews. SCE forecasts that Grid Resiliency (support 5

of maintenance and repair outages) customer support activities will increase by approximately 35 6

percent relative to current levels. As such, increased Grid Resiliency activities represent approximately 7

$0.552 million of the total $5.169 million Test Year adjustment for Account Management activities. 8

c. Distributed Energy Resources 9

Increasing implementation of DERs by customers is 10

another area that will require more account management and technical support from SCE staff.51 11

Customers look to SCE account managers as trusted advisors and request assistance for solving business 12

issues associated with implementation of DER projects. The Business Account Management team 13

provides customer information related to various DER technologies, reviews third party proposals, and 14

conducts non-standard rate impact analyses. The team also supports the customer interconnection 15

process and assists with complex metering and billing issues. By helping customers in implementation 16

of increasing numbers of DERs, SCE account managers and support staff also contribute to meeting the 17

state’s ambitious 2030 Climate Commitment.52 As the number of DER installations increases, the 18

Business Account Management team will be required to meet expanding customer needs in this area. 19

SCE forecasts that DERs customer interactions will increase by 25 percent relative to current levels. As 20

such, increased DER activities represent approximately $0.074 million of the total $5.169 million Test 21

Year adjustment for Account Management activities. 22

d. Customer Care to Support Transportation 23

Electrification, Grid Resiliency, and DERs 24

Transportation Electrification, grid resiliency, and 25

DERs are emerging topics for business customers that directly and significantly impact SCE’s 26

traditional customer care activities. Account management’s customer care activities include working 27

51 Refer to WP SCE-03 Vol. 4A, p. 26 – SCE Distributed Energy Resources (DER) Forecast for Business

Customers for additional details on DER installations.

52 https://ww3.arb.ca.gov/html/fact_sheets/2030_renewables.pdf. See also SCE-01, Vol. 1, p. IV for SCE commitment to helping the state meet its environmental goals.

41

with customers on billing and metering inquiries, providing rate option assistance, resolving credit 1

issues, educating customers on demand response programs, coordinating power quality research, and 2

communicating about outages. As described below, Transportation Electrification, grid resiliency, and 3

DERs will make all these services more complicated and will require more time to provide these 4

services. 5

For example, helping customers make informed 6

energy usage decisions by conducting account energy usage reviews and by explaining tariff 7

requirements and other factors (e.g., firm service levels and voltage levels) will become more 8

complicated and will require more time to service the same customers. Account managers also facilitate 9

communications with customer decision makers and provide specific knowledge of the customer to help 10

make determinations on credit issues and the appropriate actions to be employed, as well as interacting 11

with customers’ senior financial officers to explain late payment charges, security deposits, and other 12

issues related to financial risk. Transportation Electrification, Grid Resiliency, and DERs will make 13

providing credit issue information more complicated. 14

In other examples, account managers often initiate 15

and help coordinate analysis of transmission and distribution system power quality delivered to the 16

customer, and can help solve problems discovered from that analysis, whether the problem lies with 17

SCE’s equipment or the customer’s equipment. Transportation Electrification, Grid Resiliency, and 18

DERs will add to the list of energy-related issues that account managers advise customers on, as well as 19

increase the coordination that account managers perform on SCE resources such as field engineering, 20

interconnection, and planning groups to assist customers in the assessment and implementation of larger 21

energy projects. Outage communications will also be significantly impacted by Transportation 22

Electrification, Grid Resiliency, and DERs. For example, coordinating maintenance and repair outage 23

information is critical so that customers can alter production or work schedules or send employees or 24

students home for the duration of the outage, as well as for providing more detailed information than 25

what is provided in the automated outage alerts so that customers can fully prepare for and understand 26

the impact of outages on their businesses. Transportation Electrification, Grid Resiliency, and DERs will 27

make outage communications more complex and time consuming for SCE’s account managers. 28

SCE forecasts that additional customer care 29

activities to support the increased complexity of traditional customer care in light of Transportation 30

Electrification, grid resiliency, and DERs, will increase by approximately 30 percent from its current 31

42

level. As such, increases in traditional customer care represent approximately $1.854 million of the total 1

$5.169 million Test Year adjustment for Account Management activities. 2

(ii) Increases in Outage Management Activities 3

Outage communications, education, and notifications are 4

expected to increase from 2018 to 2021, as outage events continue to increase due to SCE’s grid 5

strengthening and modernization efforts, and the potential for PSPS outages due to other dangerous 6

conditions such as wildfires. These efforts will increase public awareness of SCE’s outage management 7

activities, enhance public safety, minimize adverse impacts from outage events, and support SCE’s goals 8

for improving outage communications and customer satisfaction. 9

BCD’s Outage Team plans to provide a variety of outage 10

marketing and communications across all channels to interact with our customers, including (1) posting 11

accurate storm updates on the Outage Tracker, (2) providing customers with the ability to report outages 12

online using photo, GPS, and text, and (3) keeping customers informed of public safety events and 13

major construction projects in their area. The Outage Team will also collaborate with SCE’s 14

Transmission and Distribution organization to provide customers with personalized reliability reports, to 15

help customers understand their usage, history of outages, and self-service resources available to them. 16

In 2018, SCE delivered two million emails to enhance customer awareness and education on SCE’s 17

outage management activities. Given the expected increase in both maintenance and PSPS de-18

energization events, SCE expects to deliver 1.5 million additional emails in 2021, for an anticipated total 19

of approximately 3.5 million emails. Similarly, in 2018, SCE sent nearly 13.5 million outage 20

notifications through multiple channels (email, phone, SMS text, text telephone (TTY), and hard copy 21

letters) to both residential and business customers. In order to support the expected increase in both 22

maintenance and PSPS-related outage events, SCE expects to send approximately 800,000 additional 23

outage notifications in 2021, for an anticipated total of approximately 14.3 million. BCD’s Outage Team 24

also plans to continue public education and outreach activities by conducting approximately 100 25

PowerTalks throughout SCE’s service territory in 2021. 26

BCD’s Outage Team also plans to provide new training 27

programs for customer-facing employees that focus on the communication processes before, during, and 28

after an outage. These outage training sessions are expected to enhance these employees’ ability to 29

effectively respond to customer inquiries in the event of a maintenance or PSPS-related outage, and 30

connect those customers with the resources and information they need to respond to an outage event. 31

43

SCE expects to conduct multiple training sessions in 2021 with approximately 30 customer-facing 1

employees from across SCE in 2021. 2

Combined, the increases in proactive customer outage 3

communications and the expansion of enhanced outage training in education will require a Test Year 4

increase of approximately $373,00053 over the Base year 2018 recorded O&M costs. This represents 5

approximately $51,000 in labor expenses for the administration and coordination needed to deliver the 6

additional notifications and new training sessions forecasted for 2021, and $322,000 in non-labor 7

expenses directly associated with vendor costs for the production and delivery of the additional multi-8

channel notifications and communications described above. 9

(d) Summary of Request 10

As shown below in Figure II-9, SCE forecasts $19.678 million in 11

O&M expenses for Business Account Management, an increase of $5.542 million, or 39 percent, 12

compared to Base Year O&M expenses of $14.136 million. 13

53 Refer to WP SCE-03, Vol 4A, p. 27 – Incremental Labor and Non-Labor Requirements for additional details

about outage management activities.

44



e) Basis for O&M Cost Forecast Method 1

The 2018 Base Year activities for Business Account Management are described 2

above. The Last Recorded Year accurately reflects the expense level associated with Base Year activity 3

levels that are planned to continue through the Test Year, plus the adjustments proposed above. For 4

these reasons, the Last Recorded Year, plus adjustments, is the appropriate basis for forecasting Test 5

Year labor and non-labor expenses.54 6

54 The decision to use Last Recorded Year as the basis for the Test Year O&M expense forecast for Business

Account Management is appropriate because the O&M increase from 2017 to 2018 was the result of increased customer care in support of transportation electrification, billing inquiries, distributed energy resources, education and consultation associated with more complex rates, education on new self-service tools on SCE.com, and outage support activities. Such customer care is part of SCE’s normal on-going operations. As such, the 2018 recorded expenses appropriately represent the base year operations for Business Account Management.

$14,136

$5,169 $373 $19,678

$0

$5,000

$10,000

$15,000

$20,000

$25,000

2018Recorded

Account Managementand Related Support

Activities

OutageCommunications

2021Forecast

45

3. Digital Operations and Management 1


The Digital Operations and Management (DOM) group (1) plans and manages the 3

growth and evolution of SCE’s digital presence and end-to-end digital customer experience, (2) designs 4

and develops SCE’s digital channels (SCE.com, voice assisted devices, and mobile) using customer 5

feedback to create new or enhance existing features and functions including tools to help customers 6

make informed decisions, enroll in programs, conduct self-service transactions, and access their energy 7

usage information, and (3) provides daily content support of SCE.com digital services. 8

For capital projects, DOM activities are needed to provide digital strategy and 9

customer experience design services prior to a project becoming a capital project and assuming 10

responsibility for ongoing operational maintenance of that project once it is implemented and no longer 11

a capital project. SCE makes its digital tools and content accessible to all customers by adhering to Web 12

Content Accessibility Guidelines (WCAG) 2.0 AA-compliant.55 13

(1) Facilitating Increased Use of Digital Channels 14

The table below shows customer-adoption statistics for SCE’s digital 15

channels and self-service transactions from 2014 to 2018. 16

55 The Web Content Accessibility Guidelines (WCAG) are internationally recognized standards which provide

guidelines for improving web accessibility. The WCAGs have been developed by the World Wide Web Consortium (W3C) with the purpose of providing guidelines to make websites useful to all users. The principles of WCAG 2.0 are to provide websites that are perceivable, operable, understandable, and robust.

46

Table II-6 Digital Operations and Management

Key SCE Online Usage Trends in 2014-201856

As evidenced above, overall customer engagement with SCE’s digital 1

offerings has increased significantly in the past five years as a result of continuous investments in this 2

support channel. For example, from 2014 to 2018, the average year-over-year (YOY) growth in visits to 3

SCE.com was 14 percent. Outage center page views is another example of increased digital engagement 4

enabled by the DOM group. The average YOY 2014-2018 growth of 45 percent for outage center page 5

views (see Line No. 7 in Table II-6 above) has been enabled by sustained investment in improving self-6

service capabilities for outages and by frequent enhancements in digital outage functionality by the 7

DOM team. These enhancements, which included providing additional outage information on outage 8

maps, optimizing outage functionality for mobile devices, and improving outage reporting and lookup, 9

were introduced to customers at regular intervals by DOM. 10

(2) Migration of SCE.com to a New Cloud-Based Platform 11

DOM is also responsible for activities supporting the post-transition of 12

SCE.com to the cloud and for the ongoing management and oversight of the associated vendor 13

56 Data in Energy Usage visits (line 2) does not fully represent activity in 2016 and 2018, as SCE experienced

data glitches and technical issues that underrepresented online usage trends during those years.

47

contracts.57 This transition has laid the foundation to better serve SCE’s customers digitally by providing 1

a better performing platform which enables SCE to more efficiently build out features and functionality 2

that otherwise would have required significant time and financial investments. This transition included 3

two key components: 4

Rebuilding SCE.com on new technology that enabled a transition from 5

SCE’s data centers to the cloud; and 6

Transferring management and maintenance of SCE.com from the 7

previous managed services provider (MSP) model to a new, less 8

expensive MSP model which includes greater digital competency and 9

is dedicated to managing SCE’s digital technology assets. 10


Digital capabilities remain a foundation of SCE’s strategy for improving the 12

customer experience, and SCE needs to continue to expand its self-service approach and deliver 13

capabilities for SCE’s growing base of online customers who engage via digital channels. On SCE.com, 14

mobile traffic has increased by approximately 13 percent, from 37.9 percent of SCE’s total web traffic in 15

2015 to 50.9 percent by year-end in 2018. Additionally, the SCE mobile app has been downloaded over 16

450,000 times between 2014 and 2018. SCE forecasts that mobile traffic will increase to 58 percent of 17

total traffic by 2021. Due to this exponential growth, SCE has taken a “mobile first” approach to 18

planning and designing web services and transactions. This means customer-facing online products and 19

services will be redesigned or developed to facilitate mobile device use.58 With SCE.com also seeing 20

growth of over 21 million visits from 2014 to 2018, it is evident that customers are increasingly using 21

digital channels for interacting with SCE. As SCE’s online customers continue to increase in number 22

and as the breadth of digital device usage increases, SCE must continue to transform its digital channels 23

to accommodate the basic needs and expectations of SCE customers, particularly with respect to the 24

57 This work is performed by the Digital Managed Services group within DOM.

58 Reference to "mobile device" is not limited to smartphones and includes several other devices which are gaining market acceptance (e.g., voice assistants via smart speakers, smart watches, and smartphones).

48

fast-growing mobile device area.59 Our continued investment in digital channels will allow SCE to meet 1

several customer and organizational goals: 2

Strategic: Address increasing digital demand by becoming the preferred 3

channel of choice for many SCE customers. 4

Operational: Simplify use of technology, provide high availability, and 5

increase reliability and scalability. 6

Affordability: Reduce SCE.com total-cost-of-ownership by outsourcing to a 7

provider with digital core competency. 8

Without these activities, SCE will not be able to meet customers’ increasing 9

preference for digital interactions, and customers will likely have to resort to higher cost-to-serve 10

channels such as live agent. 11



2018 GRC with the 2018 recorded expenses in the Digital Operations and Management GRC Activity, 14

in compliance with D.19-05-020. As shown in Figure II-10, SCE’s recorded expenses for 2018 in 15

Digital Operations and Management were less than the authorized amount by $0.199 million, a 6 percent 16

variance. This variance is within normal operating expectations. 17

59 Voicebot.ai notes that smart speaker adoption curve has followed that of social media and has now exceeded

that of smartphone adoption. See https://voicebot.ai/2018/06/02/4reasons-cmo-care-about-voice/, Voicebot.ai, 2 June 2018.


49

Figure II-10 Digital Operations and Management


$3,499 $3,517

$3,318

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

2018 Request 2018 Authorized Digital Operations andManagement

2018 Recorded

Digital Operations and Management

($199)

50





(a) Labor 3

Recorded labor decreased by $293,000 between 2014 and 2016 4

due to optimization of staffing levels, including shifting of work to vendors. In 2017, labor increased by 5

$745,000 as labor costs that had previously been recorded to various other programs were recorded to 6

DOM to maintain and enhance multiple digital enhancements, such as SCE’s Outage Center and related 7

outage functionality on SCE.com. Also, support of SCE.com was increased in 2017 and slightly again in 8

2018 as a result of an increase in customer demand for self-service options to access information and 9

complete transactions 24 hours a day, seven days a week. 10

61 Refer to WP SCE-03, Vol. 4A, pp. 29-33, for Customer Contact Center recorded and forecast financial

information.

51

(b) Non-Labor 1

Recorded non-labor costs decreased by $651,000 between 2014 2

and 2016 as vendor costs related to SCE.com were more appropriately charged to the organization 3

requesting the work. Costs then increased by $587,000 in 2017 due to increased design work related to 4

moving SCE.com to a cloud platform. Costs subsequently decreased by $1.043 million in 2018 due to 5

the wind down of the SCE.com cloud migration design work and the temporary postponement of 6

SCE.com updates to allow for the new platform to stabilize and receive customer feedback. 7

(2) Forecast 8

(a) Labor 9

The Last Recorded Year is an appropriate basis for the Test Year 10

forecast as it reflects the most recent activities undertaken by DOM. For the Test Year 2021, SCE 11

forecasts O&M labor expenses of $1.580 million for Digital Operations and Management activities 12

which is approximately the same as its 2018 recorded O&M of $1.581 million. 13

(b) Non-Labor 14

The Last Recorded Year is an appropriate basis to start with for the 15

Test Year forecast as it reflects the most recent activities undertaken by DOM. SCE made one Test Year 16

adjustment to the Last Recorded Year non-labor expenses, as discussed in section (c) below. This 17

adjustment is necessary to accurately reflect SCE’s anticipated Digital Operations and Management 18

activities in the Test Year. As a result, the Last Recorded Year, combined with the adjustment detailed 19

below, is the appropriate method for forecasting Test Year non-labor expenses. For the Test Year 2021, 20

SCE forecasts non-labor O&M expenses of $2.603 million for Digital Operations and Management 21

activities, which represents an increase of approximately $865,000 over Base Year 2018 non-labor 22

recorded costs of $1.737 million. 23


SCE’s forecast of $4.183 million for Test Year O&M expenses for 25

DOM reflects an increase of $865,00062 in O&M non-labor expenses driven primarily by necessary 26

ongoing updates, enhancements, and stabilization of SCE.com and related support of evolving digital 27

channels to continue to optimize the digital customer experience. Some of these digital channel 28

62 Refer to WP SCE-03 Vol. 4A, p. 34 – Breakout of Incremental Non-Labor Costs for additional details on

Digital Operations and Management.

52

improvement activities were not conducted in 2018 pending a final decision in SCE’s 2018 GRC 1

proceeding. Those digital channel improvement activities will now be undertaken in 2020 and 2021 2

resulting in the Test Year adjustment shown in in Figure II-12 as “Improved Digital Services” and 3

further described in the section below. 4

Table II-7 Digital Operations and Management

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



53

(i) Improving Digital User Experience 1

The activities included within the DOM test year 2

adjustment are expected to improve the customer experience on SCE.com, while creating lower cost 3

paths for customers and visitors to access account and program information. These activities fall within 4

three buckets: (1) re-designing SCE.com; (2) completing the critical work around maintaining the 5

managed services contract for transfer of SCE.com to the cloud; and (3) optimizing digital channels. 6

a. Re-design SCE.com 7

This re-design serves the critical function of 8

providing needed information and offering a positive user experience. SCE.com has not undergone a 9

redesign in approximately eight years and is overdue for this process.63 10

b. SCE.com to Cloud Maintenance 11

During the Test Year, SCE will continue the critical 12

work around maintaining the managed services contract for maintaining SCE.com on the cloud. 13

c. Optimize Digital Channels 14

SCE is planning the following initiatives to 15

optimize digital channels to accommodate the expected growth and to implement SCE’s digital 16

roadmap. 17

i. Focus on the Basics 18

Elevate SCE’s foundational mobile elements 19

to meet customers’ expectations and standards set by other industries. This includes expansion and 20

optimization of SCE’s responsive website as well as the introduction of a native mobile application that 21

enables customers to complete core billing, payment, and outage transactions and receive push 22

notifications regarding their account(s). 23

ii. Expand SCE’s Digital Ecosystem 24

Develop additional digital channels that are 25

not yet widely available to customers. Such channels include voice assisted devices, expanded digital 26

payment operations, expanded text options, and chatbot. 27

63 Gartner recommends that websites should be redesigned every three years. See Greene, Nicole. "Website

Success: How to Evaluate and Deliver a Website Redesign Project.” Gartner, 31 May 2019.

54

iii. Create Personalized Experiences 1

Deliver an experience based on the unique 2

needs and preferences of our diverse customers. This is expected to include delivering real-time, 3

contextual advice to encourage behavior change and to drive deeper, more valuable, and more trusted 4

relationships with our customers, and to include custom push notifications/alerts to serve tailored 5

behavioral nudges to facilitate or signal behavior change that is in the best interest of the customer. 6

In order to implement these initiatives, 7

DOM will engage vendors who are digital industry experts. Forecast vendor costs are based on SCE’s 8

business judgment and historical expenditures with comparable vendors on similar sized projects. 9

e) Basis for O&M Cost 10

The 2018 Base Year activities for Digital Operations and Management are 11

described above. The Last Recorded Year accurately reflects the expense level associated with Base 12

Year activity levels that are planned to continue through the Test Year, plus the adjustments proposed 13

below. For these reasons, the Last Recorded Year is the appropriate basis for forecasting Test Year non-14

labor expenses.64 15

64 The decision to use Last Recorded Year as the basis for the Test Year O&M expense forecast for Digital

Operations and Management is consistent with the direction provided in D.04-07-022 and D.89-12-057, wherein the CPUC stated that if costs have been relatively stable for 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, overall Digital Operations and Management O&M expenses have been relatively stable over the period 2014-2018. As such, the 2018 recorded expenses appropriately represent the base year operations for Digital Operations Management.

Documents

Amended Testimony on Customer Contacts...21 testimony and workpapers for Customer Contacts capitalized software projects are discussed in SCE-06, 22 Vol. 1, Part 2. 1 Such outage communications