Rate Case: Advertising First, or Comprehension First?
Northgate Power has filed for a 9.4% residential rate increase; the public utility commission hearing is 14 weeks away. A grassroots group has collected 6,000 signatures and runs a Facebook page with 11,000 followers, mostly in the two lowest-income ZIP codes. Company research shows 61% of customers cannot accurately state what they currently pay per kilowatt-hour and 44% believe the utility's profits are 'excessive.' Communications has three staff, $120,000, and a CEO who wants to buy radio and billboard advertising for the first four weeks. The regulatory affairs lead wants no public messaging until the filing is complete. The increase is driven mainly by storm-hardening capital costs the commission has already accepted in principle.
1. Write one goal and three measurable objectives for the 14 weeks, and justify whether the CEO's four-week advertising buy is the right first move.
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Goal: sustain a level of informed public and commission support that lets the rate case be decided on its merits rather than on volume of opposition.
Objectives (measurable, time-bound, baseline-anchored):
- By week 6, raise the share of customers who can correctly name the main cost driver from a week-1 baseline (intercept survey, n≈400, ±5 points) to 40%.
- By week 10, reduce the share agreeing that profits are 'excessive' from 44% to 34% on the same instrument.
- By week 12, hold 8 meetings with community organizations and place 3 third-party letters or op-eds in the two low-income ZIP codes.
On the advertising: not wrong, but wrong first. Four weeks of radio and billboards before customers understand the cost driver buys reach without a credible message - awareness ahead of comprehension, which is the classic sequencing error in advocacy campaigns. Build comprehension through earned and owned channels first, test the explanatory message, then add paid in weeks 5–6. Also note the arithmetic: $120,000 cannot sustain broadcast reach for 14 weeks, so paid dollars should be concentrated where they change an opinion, not spread thin.
2. Resolve the standoff between the CEO and the regulatory affairs lead, naming the real constraints and the decision rule you would use.
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The dispute conflates two different risks. The regulatory risk is real: ex parte communication rules, filing confidentiality, and statements that could be read as prejudging the outcome or as misleading. But 'no messaging for 14 weeks' is not a legal requirement, and it hands the narrative to a group that is already framing the issue with 11,000 followers.
Separate the claim classes and let counsel rule on categories, not sentences:
- Communicable now: the filing itself, the cost drivers, hearing dates and process, how to participate.
- Counsel review required: characterizations of the outcome, predictions, anything touching settlement.
- Not yet available: customer-specific bill impacts before the commission's final numbers.
Decision rule: if counsel cannot cite a specific rule that prohibits a statement, the default is to communicate it. Ask counsel in week 1 to review a message matrix rather than every draft, and escalate the standoff to the general counsel with a written proposal. Record the hold, if one is imposed, as a joint decision with an end date - an open-ended silence becomes the communications plan by default.
3. Opposition concentrates in the two lowest-income ZIP codes, where a 9.4% increase hurts most. How do you adapt without it looking like you are buying off or targeting critics?
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Start from accuracy, not tactics: those customers face the largest real burden, so the content should change, not just the channel.
Do:
- Lead with concrete affordability items - budget billing, payment plans, low-income discount enrollment, arrearage forgiveness - and make enrollment the call to action, not 'support the rate case.'
- Have trusted local intermediaries deliver it: the community action agency, faith leaders, librarians. A utility spokesperson is the least credible voice on affordability.
- Hold listening sessions first and report back what you heard, including what you cannot fix.
- Fund the enrollment help regardless of the rate outcome, so it does not read as transactional.
Do not: use income data to micro-target reassurance messaging, run 'we care' advertising with no program behind it, or recruit customers to speak at the hearing in exchange for bill credits.
Test: if a resident read the plan in the local paper, would it look like help or like manipulation? The ethical line is whether the audience gets something real, not whether the message feels warmer.