RECEIVES 2013 HAY 24 P U^OI Mitchell Tannenbaum, Esq. Deputy General Counsel MAINE PU1LJIC UTIL. COMM. Maine Public Utilities Commission 18 State House Station Augusta, ME 04333-0018 Re: Electricity Maine - Request for Information Dear Mitch: On behalf of Electricity Maine, I am writing to respond to your letter of May 8, 2013 requesting information. I will respond toeach ofyour questions inturn. 1. Please describe the process by which Electricity Maine informs radio stations to change ordiscontinue a particular promotion. Electricity Maine's marketing department periodically, as messaging or promotions require sends e- mails to our radio station sales representatives that includes scripts, talking points, message changes or general information. In addition to this, we speak regularly (some times weekly) via phone with the sales representatives at particular radio stations. We also meet face to face periodically with station representatives and radio personalities, but not necessarily every time we change messaging. In most cases in which we are altering our advertising messages or content, we send the stations an email with the updated content and request that it be used until further notice. Please see our response to question number 2for examples. Occasionally our marketing department will call particular stations and asked that particular marketing messages be aired, but we do not keep records ofthose calls. Electricity Maine radio promotions take several forms. Occasionally Electricity Maine will produce its own ads of :30 or :60 seconds that it provides to radio stations to run. Electricity Maine has also provided scripts of :15, :30, or :60 seconds in length for the radio stations to produce with their own local talent. Athird category of radio spot are :05 "blinks", that are previously recorded and air as scheduled. More frequently Electricity Maine provides radio stations with talking points that are read live on the air, or recorded to sound live and played at other times of the day. These live or sound live" spots may then be put into the automated system as part ofthe mix ofcommercials. The stations typically keep alibrary of these recorded ads that their automated system draws from to air at various times. Electricity Maine currently runs promotions with approximately 11 radio stations each running approximately 150 ads ("mentions") in one ofthe above forms per month, for atotal ofapproximately 3,000 mentions per month. 2. Please provide copies of all communications/e-mails with radio stations that include ascript for promotions to air during the period of February 1, 2013 to March 31, 2013 or that involve achange or discontinuation ofaparticular promotion. Enclosed are copies ofwritten communications with radio stations from our marketing department on January 8, 2013, February 13, 2013 and March 8, 2013, April 5, April 8, April 23 2013 and May 8 ZOU. As noted above, our marketing staff is in regular verbal contact with radio station sales' representatives, but we do not keep written records ofthose phone or in-person communications. 3. Please confirm that it is Electricity Maine's position that its radio promotions .Ulmg^e/en0d February *•2013 to March 31,2013 (except for possible mistakes by the radio Sf,.0?? DOt Pr0Vide comParisons to standard offer prices in effect during the period March 2012-February 2013 and/or include a statement at the end of promotion that referred to standard offer rates in the CMP and BHE service territories in effect as ofMarch 1,2012. The written communications provided in response to question number two reflect the talking points or ad content Electricity Maine has requested that stations work from as either station recorded ads or as live spots or blinks. The talking points provided on January 8, 2013 and February 13, 2013 reference standard offer as indicated. The talking points provided on March 8, 2013 and thereafter do not reference standard offer or price comparisons to standard offer. Because the radio stations maintain a library of prerecorded ads and there is no record of which prerecorded ads were picked by the automation to run at any particular time, and because other radio station ads are live mentions of which no written record is kept (other than date or time), we cannot track what ads were aired when. We now understand that in recent months some radio station staff may haye aired out of date station-recorded ads or relied on out of date talking points in airing live spots As aresult, we have followed up with all ofour radio stations and asked that they destroy out of date recorded ads and use only current talking points in airing live spots. Aletter from the Portland Radio Group reflecting their acknowledgement ofthis problem is attached. Iheo?ifential md Sma11 commercial standard offer rate as of March 1, 2013 is 6.826 cents/kWh in the CMP service territory and 6.696 cents/kWh in the Bangor Hydro territory. Electricity Maine currently offers customers three price options: 1) an 18-month fixed rate of 7.58 cents/kWh 2) a12month fixed rate of 778 cents/kWh, and 3) a6-month fixed rate of 6.8 cents/kWh. Attached to this letter is atable that identifies the rates at which new customers were enrolled and current customers were renewed in February and March 2013. As reflected in the table, Electricty Maine has consistently attempted to offer aproduct at rates below the applicable standard offer price, although the term of the product has differed. The only time we were not able to achieve this was for new enrollments beginning March 20, 2013 in the Bangor Hydro territory, where we offer a9-month rate of 6.8 cents/kWh compared to the BHE Standard Offer rate of6.696 cents/kWh. h • t P'eaf ™nfu™ that it is Electricity Maine's position that its radio promotions FfrU3ry *' 2°13 t0 toMarch 31'2013 P°ssible by the radio station) did not include astatement the effect that(exceP* if yourforpower billstakes says standard offer you're paying too much. * Please see response toquestion 3 above. 5 Please provide audio fdes for all radio promotions that aired during the period February 1,2013 to March 31,2013 and dates for which the promotions aired. Please see my response to question 1above. Iam provided with this letter adisc with audio files for SlTadio Demote prepared by Electricity Maine and all recorded promotions prepared by radio "br^onTe Eng points provided by Electricity Maine. Because the radio stations do not ^SmZnis ofwhL particular prerecorded ads or live spots were aired, we cannot identify which ads were aired in the time period inquestion. 6 Did Electricity Maine change or discontinue any ofits promotions after receipt of the MPUC Staffs letter toElectricity Maine dated April 5, 2013? If so, please provide the reason(s) for the change/discontinuance. S S I.0thestations, as submitted with this letter, and in our oral communications with the stations. 7. Please provide the basis for the statement in Electricity Maine promotions that Electricity Maine customers will save nearly $7 million in 2013. This statement was an error that we are now addressing. The $7 million savings figure represents total c^d^^tom "savings from the initiation ofservice by Electricity Maine in 2011 through early 2013. It was incorrectly advertised as prospective savings in 2013. 8 Please indicate whether the supply contract of any Electricity Maine customers that initially enrS with aTerms of Service that contained the following statement "Upon —i^fserri^ wTre EZLJ&^T^^SEL renewal, a. ahigherprice than The cu^rr's prio'r price. If so, please indicate how such automatic renewals are consistent with the language in the applicable Terms ofService. Earlier vercions ofElectricity Maine's Terms ofService contained the " ^^ ^ cmteTers are directed to the website to review the current terms of service^ hi addition when ElccSSy Maine amends its Terms ofService, we pmvide all customers with advance nonce ofthe ra™f: rn th°Uf ? ^^ Wi" ^ a£fect to CUSt°mer's *« c™ contract If acustomer ease mwhich acustomer raises acomplaint or concern about automatic renewal wheto^ecaVedbv Electncity Mame product, to swith to Standard Offer service, or to switch to adiffirentTFP .liT^ cost to diecustom*. Each ofdie teeon-line complain* ™„££J££ **T ' during May1,2" '"""' "" SCriP* ** *° Pr0m0,i<,,,S "•at haVe aired - WCL^ *•» some radio stabon staffmay have aired out ofdate stata-iecoidedads ZeliedZ'ZS 2 Iappreciate die time and attention the Commission and its Staffinvests in supporting the development Verytruly yours, Sent: Tuesday, January 08, 2013 2:51 PM Subject: [BULK] Electricity Maine Update Importance: Low Good Afternoon, Attached are two items: doc with :30/:60 scripts and a separate sheet with updated talking points for endorsements. Endorsement talking points should focus on the top 4 items & Free Power Giveaways. Please send me produced :30's and :6CCs to review. Occasional air checks on testimonials would also be appreciated. Along those lines, we'll be providing you with an email address to send air checks and audio files to. For now they can come to me...but, well, I get so many and would like to give them a home to call their own. In the category of you'll be wicked thrilled to hear...We are working on refining our process for tracking calls and enrollments. This will be part of a larger ITupdate to our sites, using the promo codes will become easier and more intuitive for our users. For those of you we have web ads running with we'll be providing new creative (please send me any sizes you need). We will be creating unique url landing pages to direct your web traffic too. Where possible we'll customize the message based on the station folks listened to, this way-when they click"to enroll", hopefullyyour station will be top of mind and select the corresponding promo code. This is still a couple weeks out, new URL's will be provided with new web creative. We believe this will definitely help with tracking enrollments. Let me know if you have any questions-comments-concerns or just want to say "hi". Cheers, -Will Will Fessenden Director Media Strategy Fessenden From: Will Fessenden Sent: Wednesday, Februlry 13,2013 2:13 PM Subject: Electricity Maine Update Attachments: ME so way, ME 60 WW, E|2c!ricityMEjeblaIkingpoims docx Good Afternoon, Attached are updated talking points for endorsements-these mimic and reinlorce new TV which will begin in a week or so. These talking points are a hit tighter than you might be used to seeing bm want to keep focus on these prime areas. You will nmltey less about abput chulce and why we are the best choice including: The Power to Help and working with a Maine cumpany locused on community. Also attached is a :30 and a :60 voiced hy Kiley Bennetl. Please use the attached 130's anu :so's fora" traffic rhet are non-endorsement live spots. For traffic purposes you can use the attached lhmufll March 1. l'u send along new traffic and info early the week of 2/25". Let me know if you need anything else from me, happy to answer any questions vuu migln have. chat soon. ~wm wul Fessenden Director Media Strategy re 207 4405021 wlessendenQfilovldergowelLum ProviderPOWER must? Companies or Provider PDWEV iecirwuy Mame Yo recess 2574 Welectnciyinecom ENH Power ml nea lEGEZbfi m: m' enhpuwemw **Electricity Maine Radio ENDORCEMENT TALKING POINTS** Feb 14, 2013-TFN . Every day hundreds of Mainers switch to Electricity Maine. Some switch to save on the supply portion of their power bill, some switch to support aMaine-owned company that builds jobs here at home, while others switch to support Maine non-profits through the Power to Help Fund. • Mainer's have choices as to where to get their electricity. Electricity Maine is the largest provider in the state-nearly 200,000 have made the switch and they are proud so many people have placed their trust in electricity Maine. If you are among those who have made the switch-share your good fortune with family, friends and neighbors. . Switching is easy -Just grab your power bill, if on page 2it says "Standard Offer" you're paying too much. Visit electricity MEdot com, click Enroll Now. It takes just acouple minutes and you are on your way to supporting the Power to Help. • If you prefer to speak with acustomer service representative call 866-573-2674 (repeat phone as many times as necessary). Electricity Maine's talented, knowledgeable customer service team will can answer all your questions and help you enroll. • To learn more, visit electricity MEdot com, visit them on Facebook or go toyour favorite search engine and do a search for Electricity Maine. I($\i> CohJV EpctricltyMAINE The power to SAVE • Electricity Maine was the first, and now the largest, competitive supply provider in Maine, with nearly 200,00 customers • In 2013 customers will combine to save $6.8 million! • When you choose Electricity Maine as your electricity supplier, you're not only saving money, you're also building jobs right here in Maine, with a Maine owned company. • Each enrollment with Electricity Maine helps to support local non-profits, including the Good Shepard Food Bank, St. Mary's Health System and the Dempsey Center, plus many more. • It's easy to switch! Just grab your electric bill, go to www.electricityme.com, and click the "Enroll Now" button (takes less than 5 minutes!). Or call (866) 573-2674. FREE POWER Electricity Maine is giving away Free Power for YEAR to 100 lucky MAINE HOMES! 11 • That's right, you could be one of the lucky Mainers to win free power for a year from Electricity Maine • 25 winners will be chosen each quarter during the promotion • Electricity Maine will pay the power supply portion of the winner's electric bills every month for an entire year!!! AND Free Power for a Month! I • Once a month Electricity Maine will continue to provide FREE Power for a MONTH to ONE LUCKY Winner. • • All Maine residents are eligible to win Free Power for a Month. Check out our website to view winners since September 2011. How do you register to Win? • • Ifyou are ALREADY a customer of Electricity Maine, you are already included in the promotions Ifyou are NOT a customer, you can log on to electricityme.com to review the official rules and entry form • Iffor any reason you do not want to be part of these promotions, you can call Electricity Maine's customer service team and asked to be removed 1-866-573-2674. I(g l3 CO*. Why is Electricity Maine offering these promotions? • That's what makes Electricity Maine unique...they are focused on giving back! • As away to thank their 190,000 customers, and others supporting their efforts, they decided to create these promotions. STANDARD FACTS • If your CMP or Bangor Hydro Bill stills says "Standard Offer" you are paying too much for your power supply. • Electricity Maine's goal is to always be LOWER than the "Standard Offer" • Providing One Year Fixed Rates • Pay Less and Support Maine • Creating NEW Jobs for Maine People • Share the news and make the Switch • It's Quick, It's Easy. • Join the movement across Maine to save on your monthly power supply and support Maine's economy. • ENROLL TODAY!!! www.electricityme.com January 7, 2013-TFN Electricity Maine :30 MX: None (dry read) Nearly 2hundred thousand Mainers can't be wrong. Electricity Maine was the first and now the largest competitive electricity supply provider in Maine. In 2013 Electricity Maine customers will combine to save 6point 8million dollars. When you switch to Electricity Maine you put the power to help to work supporting Maine jobs, supporting Maine non-profit organizations and saving you and your family money. Enrolling is quick and easy -grab your utility bill and visit Electricity ME dot com. That's Electricity ME dot com. Will Fessenden Will ressenden Friday. March on, 2013 1:59 PM Gail Ruwe (Galiltuwealcumuluseomi; aiette, shire com); Peter Hoglund Steve Landly mike.sambionk@cumulus.com7 Merry St Pierre Kim Daellenbadi Morgan Wilkins com' subject.- Electricity Maine Radio Endorsements Attachments: endorcement'draflflocx Good Atternoon, Hope this note finds everyone doing well. Attached are the latest talking points (or jock endorsements. Please note we are shitting away from focusing on savings-instead talking about doing business with a Maine owned company, creating jabs here at home, supporting Maine nonprofits through the inev to Help Fund, while uttering a competitive rate on the supply portion of the bill, This is part one of the new "branding" of Electricity Maine (as opposed to direct response] as a Maine comvany, dedicated to Maine's long term economic health. Please use attached until further notice. If we haven't sponken and conlimted in Studio interviews with ownership, lets talk as I would like to get them in this month. Regavds and (hanksl Our media partners will continue to play a strong role in the next phase at EME's development. -will Will Fasunden Director Media Snategy i" 440-5022 wiessendeanrovl ergowgr com ProviderPQWER an; or Provider Power Marne 'nll Frec- isrss 57: 2574 ENH Power noeswsisar Lorri Electricity Maine-ENDORCEMENT TALKING POINTS March 8-TFN day hundreds of Mainers switch to Electricity Maine. With more than 200,000 thousand enrollments Electricity Maine is the state's largest and most trusted electricity supply company. *Mainers are enrolling with Electricity Maine for a host ofreasons-some switch to support a Maine owned and operated company-creating jobs here at home. Others make the switch to support Maine non-profits through the Power to Help Fund, others enrolled with Electricity Maine because they want a competitive rate ontheir electricity supply. have choices where to get their power. If you want a local company, building jobs here in Maine, supporting Maine communities, make the switch to electricity Maine. *The Electricity Maine Power to Help fund has given thousands of dollars to local non-profit organizations like the Dempsey Center, St. Mary's Regional Medical Center, and Good Shepherd Food Bank. When enrolling with Electricity Maine simply use the promo code ofthe organization of your choice and Electricity Maine will contribute $5.00 to that organization. That is what the Power to Help is all about. is easy-Just grab your power bill, visit electricity MEdot com, click "Enroll Now". It takes just a couple minutes. *lf you prefer to speak with acustomer service representative call 866-573-2674 (repeat as many times as necessary). Try to have your power bill available-either on line or by phone, enrolling is quick and easy. *To learn more, visit electricity MEdot com, facebook.com/electricityme or go toyour favorite search engine and do a search for Electricity Maine. Will Fessenden From: WM Fessenden Sent: Friday. April 05, 2013 9 08 AM To: Will Fessenden Subject: Updated Talking Points Attachments: docx Good Morning and Happy Friday Updated Talking jock Endorsement talking points for Maine are anachedv Focus continues to be that Maine is a Maine owned company, the PowerTo Help Fund being a key component of our Having received some feedback, as your (jocks) are Interested in greater detail, more specifics, about Powerto Help Partners, have included info on 3 upcoming Power To Help partner events. when talking about The Power To Help, jocks are encouraged to rotate mentions of the events Along with Power To Help info there IS also more familiar talking polnts/infn. Please review the attached, share with Onealr talent and as always thanks for your continued support. Don't hesitate to contact me with questions/concerns lor great praise)! Regards, ewm Will Fessenden Director Med'la Strategy ProviderPOWE Companies of Premier Power Electricity Mame Toll Flee com EN Power To!' Free 178667266 2941 enhgower com Electricity Maine-ENDORCEMENT talking points April 5-TFN *Every day hundreds ofMainers switch to Electricity Maine. With more than 200,000 thousand enrollments Electricity Maine is the state's largest and most trusted electricity supply company. *As a Maine Owned Company, one of the core principals-part of the mission of Electricity Maine is to give back to the communities and raise awareness ofsome ofthe great non-profit organizations in Maine. Through the Power to Help Fund, Electricity Maine supports organizations through direct donations as well as technical expertise and volunteers. Power to help organizations include: Examples ofPower toHelp partner organizations (please rotate mentions): • Androscoggin Home Care &Hospice-Electricity Maine is a primary sponsor ofthe Hospice House 5k and Remembrance Walk-in Farmington, South Paris and Auburn. Money raised from this event supports patient care at the Hospice House. • United Way of Androscoggin County Touch ATruck event on May 4th at Central Maine Community College. Kids and the young at heart are invited to attend the free event and get up close with dozens ofcool vehicles including fire trucks, tractor trailers, police cars and much more. • Museum L-A Bands on the Run Half Marathon and 5K-a unique event supporting Museum L-A, a 5k &Half marathon along roads and trails along the Androscoggin River and Lewiston/Auburn-along the route runners and walkers will be treated to the sweet sounds of local bands and musicians. For more information about the Power to Help Fund, partners and events-visit Electricity ME dot com, click the "Power to Help" button. *Mainer's have choices where to get their power. If you want a local company, building jobs here in Maine, supporting Maine communities, make the switch to electricity Maine. *The Electricity Maine Power to Help fund has given thousands of dollars to local non-profit organizations like the Dempsey Center, St. Mary's Regional Medical Center, and Good Shepherd Food Bank. When enrolling with Electricity Maine simply use the promo code ofthe organization ofyour choice and Electricity Maine will contribute $5.00 to that organization. That is what the Power to Help is all about. *Switching is easy-Just grab your power bill, visit electricity M Edot com, click "Enroll Now". It takes just a couple minutes. *lfyou prefer to speak with a customer service representative call 866-573-2674 (repeat as many times as necessary). Try to have your power bill available-either on line or by phone, enrolling is quick and easy. *To learn more, visit electricity M Edot com, facebook.com/electricityme or go to your favorite search engine and do a search for Electricity Maine. Fessenden -- Fm Fessenden Sent: Juesday, April 23, 2013 10:05 AM To: Fessenden Subject: Updated Maine :30 and talking polms Attachments: OUTBOUND OPACUSARCHIVE: VES Good finds you all dolng well Attached l5 an updated :30 ltortnose ofvcu :30'sl and endorsementlalkmg palnts. Snand polnts should be the only spots 2; messaging you use. . A lntroducing language about two contract options loutllned in yellow). The goal drive interest/(alls for these optlons and talk about the security of fixed rates (versus vanable rates offered by many of out tompetltorsl - Don't hesitate to promote the phone number as often as you are comfortable - Don't nesltate to encourage llsteners to use respectlve promo codes "Don't forget to mentlon you heard lt here. Please send me produced 30's to OK and the usual occaslunal alrchecks polnts can begln ASAP Let me know ltyou have any quesnons, Thank you. Regards, will Fessenden Dlrettor Medla Strategy erssenden@grovldergower.com ProviderPOWER Companles ol Plot/me: Power Maine Toll Free 143656732674 ENN Power TDIlFree memos--25" enhgowemom Electricity Maine-ENDORCEMENT TALKING POINTS April 22-TFN *Every day Mainers switch to Electricity Maine. With more than 200,000 thousand enrollments Electricity Maine is the state's largest and most trusted electricity supply company. *Now Electricity Maine has 12 and 18 month plans to meet the needs of you and your family. All rates are fixed that way you have the security of knowing your rates won't increase. That's right no variable rates, no guessing on your part. This is part of Electricity Maine's commitment to you. *Signing up for a 12 or 18 month fixed rate means Electricity Maine is able to give back to community and non-profit organizations through the Power to Help Fund- raising awareness of some of the great non-profit organizations in Maine. Through the Power to Help Fund, Electricity Maine supports organizations through direct donations as well as technical expertise and volunteers. Power to help organizations include: Examples of Power to Help partner organizations (please rotate mentions): • Androscoggin Home Care & Hospice-Electricity Maine is a primary sponsor of the Hospice House 5k and Remembrance Walk-in Farmington, South Paris and Auburn. Money raised from this event supports patient care at the Hospice House. • United Way of Androscoggin County Touch ATruck event on May 4th at Central Maine Community College. Kids and the young at heart are invited to attend the free event and get up close with dozens of cool vehicles including fire trucks, tractor trailers, police cars and much more. • Museum L-A Bands on the Run Half Marathon and 5K-a unique event supporting Museum L-A, a 5k & Half marathon along roads and trails along the Androscoggin River and Lewiston/Aubumalong the route runners and walkers will be treated to the sweet sounds of local bands and musicians. *Switching is easy-Just grab your power bill, visit electricity M E dot com, click "Enroll Now". It takes just a couple minutes. *lf you prefer to speak with a customer service representative call 866-573-2674 (repeat as many times as necessary). Try to have your power bill available-either on line or by phone, enrolling is quick and easy. *To learn more, visit electricity M Edot com, facebook.com/electricityme or go to your favorite search engine and do a search for Electricity Maine. FORGET TO SPIKE IN LANGUAGE SIMILAR TO: "WHEN YOU ENROLL-DON'T FORGET TO MENTION YOU HEARD IT HERE...." (ENCOURAGE USE OF YOUR STATION PROMO CODES April 22, 2013-TFN Electricity Maine :30 MX: None (dry read) Every day Mainers are making the switch - more than 2 hundred thousand have already enrolled, making Electricity Maine - a Maine owned company - the largest electricity supplier in the state. Now with 12 and 18 month options - you pick the plan that best suits you and your family. Best of all, Electricity Maine rates are fixed, protecting you from fluctuations in the market. None of the variable rates you get from other supply companies. No guessing on your part - just security. Learn more about Electricity Maine at electricity m e dot com or call 866-5732674. The number again: 866-573-2674. PORTLAND R A D I 0 C R 0 ' May 15, 2013 Mitchell Tannenbaum, Deputy General Counsel Maine Public Utilities Commission, 18 State House Station Augusta, Maine, 04333-0018 Dear Mr. Tannenbaum, Thestationso, Portandwo Ra* have been— «^££SwE2£k'" February and March reooi»odGroup instructions ^ " ' ^ per our agreement rS^rr^=-ZZS::an, — producedorperformed on behalf of Electricity Maine. Sincerely, CO Warren T. Maddock Portland Radio Group Sales Manager Portland Radio Group Sales Manager VVGAN VVPOR « WMGX • VVYNZ • WZAN • WBAE "420 Western Avenue • South Por'tland, Maine 04 I06 • !207 774-456 1 • FAX (207! 774-3788 RFSPONSE TO QUESTION 3. NFW ENROLLMENTS MONTH OF FEBRUARY 2013 NFW ENROLLMENTS MONTH OF MARCH TERM TERM RATE UTILITY CMP 0.06823 CMP BHE 0.06689 BHE RATE UTILITY CMP 0.06823 BHE 0.06689 (MONTHS) (MONTHS) RENEWALS MONTH OF RENEWALS MONTH OF MARCH 2013 FEBRUARY 2013 TERM TERM (MONTHS) RATE RATE UTILITY 0.06823 CMP 0.06823 CMP 0.06823 BHE 0.06823 BHE UTILITY (MONTHS) (03/20/2013 ~CURRENT) 2013(03/01/2013 - 3/19/2013) TERM UTILITY NFW ENROLLMENTS MONTH OF MARCH 2013 (MONTHS) RATE These Are Elctricity Maine's Current Terms and Rates. Please See Website For Details.