Advertising & Branding: Are Utilities Getting It Right?
outside to assure objectivity.
5. SKIMPING ON BUDGET.
If too small, join forces with other suppliers.
6. GIVING UP TOO SOON.
Advertising needs time to sink in.
Don't revamp the campaign each year.
7. WAITING TOO LONG.
Tap customer loyalty while it's still there.
8. BREAKING PROMISES.
Ensure back-office support for what you're trying to do.
9. REACTING TO CRITICISM.
Don't be too easily derailed.
10. FAILING TO EXCITE.
Good advertising evokes an emotional response.
Source: A. Christine Fillip, senior vice president, The Kamber Group, Washington, D.C.
A Role for Regulators?
STATE utility commissions can be seen working to preserve juris-
diction in two areas of utility marketing: (1) uniform standards for disclosure of information to customers (sometimes referred to as "consumer education"), (2) codes of conduct for marketers that operate as affiliates of regulated distribution utilities.
INFORMATION DISCLOSURE. In July, the Pennsylvania Public Utility Commission issued interim rules for disclosure of prices, charges, terms of service and information about energy use and efficiency. Bills must state separate amounts for generation, transmission, distribution and transition surcharges. Docket M-00960890, F. 0008, July 10, 1997, 180 PUR4th 61 (Pa.P.U.C.).
Can the PUC regulate ad campaigns? The July rules appear unclear. On one hand, they force suppliers to "make available" their materials and marketing plans for review upon request by the PUC. Yet in 1996, the PUC had repealed all of its prior restrictions on sales promotion practices for gas and electric utilities, saying they were "excessive and obsolete." See, Docket No. L-00950108, Oct. 3, 1996, 1996 WL 677538 (Pa.P.U.C.).
CODES OF CONDUCT. On Dec. 16, the California Public Utilities Commission issued rules barring Kirkwood Gas & Electric, Pacific Gas & Electric, PacifiCorp, San Diego Gas & Electric, Sierra Pacific Power, Southern California Edison, Southern California Gas, Southern California Water, Southwest Gas and Washington Water Power from advertising their relationship with their affiliate. The utilities are not allowed to use their name or logo in any material circulated by the affiliate in California unless the affiliate discloses "clearly audibly and/or legibly" up front that: (1) the affiliate is not the same company as the utility; (2) the affiliate is not regulated by the CPUC; and (3) the customer does not have to buy the affiliate's products to continue to receive quality regulated services from the utility.
In addition, utilities may not participate in joint marketing with its affiliate, nor provide advertising space in billing envelopes to them, unless it offers the same to competing energy service providers (R.97-04-011, filed April 9, 1997).
PG&E Energy Services Vice President and General Counsel Doug Oglesby said they are pleased with the logo decision. Overall, he said, the plan is "a victory for competition and customers who need as broad a range of choices as possible."
Commissioners Jessie J. Knight Jr. and Richard Bilas withdrew a stricter alternate proposal that had recommended not allowing a parent's "name, logo, service mark, trademark or trade name" to resemble its affiliate's, which disappointed The Utility Reform Network, one of the two original proponents of such a ban, says spokesman Paul Klein. While