Electric Vehicles (EVs):
SDG&E Infrastructure Program

 
Background

In November 2013, the CPUC opened a new Rulemaking to develop policies and guidance to support the Governor’s goals to build infrastructure to support the adoption of up to 1.5 million zero-emission vehicles in California by 2025. In December 2014, the CPUC issued a  Decision in stating that it would consider utility ownership on a case-by-case basis.   

SDG&E Program

On April 11, 2014, SDG&E filed an Application requesting CPUC approval to implement a program for installing Electric Vehicle charging stations. SDG&E referrs to its program as "Power Your Drive."  

SDG&E proposes the program would:  

  • Introduce hourly time-variant rates. 
  • Provide EV charging infrastructure. 
  • Provide a mechanism to determine customer benefits of efficient integration of EV charging loads with the California electric grid. 

SDG&E asserts its program design would:  

  • Target charging stations to multi-unit dwellings and the workplace. 
  • Install EV charging stations at 550 sites with 10 charging stations at each site, for a total of 5,500 charging stations. 
  • Cost $103 million on which SDG&E proposes to earn a profit, resulting in a total cost to customers of $195 million. 

SDG&E states benefits to customers include increasing Electric Vehicles:  

  • Cost-saving opportunity through the availability of alternative fuel choice. 
  • Driver “range confidence” that would leading to increased EV adoption. 
  • Demand for EV charging stations. 
  • Zero Emission Miles driven per EV.   

SDG&E expects to incent charging: 

  • During times of lower cost by providing a rate that reflects changes in energy prices throughout the day. 
  • By realizing changes in grid conditions at the circuit and system level. 

SDG&E proposed to own the charging infrastructure and stations on which they would earn a rate of return profit funded by its customers.   

 

SDG&E's Proposed Settlement Agreement

On June 3, 2015 a number of parties to the proceeding, including SDG&E and business and environmental groups filed a proposed Settlement Agreement with the CPUC proposing a program that would implement: 

  • A Vehicle-to-Grid Integration “Rate-to-Host” option that enables owners of multi-unit dwelling or worksites to select the price for EV charging.    
      
  • A Vehicle-to-Grid Integration Rate-to-Host requiring customers to manage their load using certain Guiding Principles including: 
    • Achieve installation of grid-integrated infrastructure to support 1.0 million zero emission vehicles by 2020. 
    • Accelerate the adoption of 1.5 million zero emission vehicles by 2025. 
    • Support clean air and climate change objectives. 
    • Provide net benefits to all ratepayers. 
    • Provide EV drivers with the opportunity to maximize fuel cost savings. 
    • Provide customer choice. 
    • Support investment in charging equipment and services by public, private and utility entities, avoiding anticompetitive impacts on the market.  
    • Incorporate learning and make adjustments to the pilot program as need. 
    • Provide data to inform state policy going forward. 
        
  • A Program Advisory Council composed of consumer, environmental, low-income, and industry representatives that would provide advice to SDG&E on program modifications. 
      
  • Program deployment in disadvantaged communities, allocating 10% of VGI Program electric vehicle infrastructure. 

On August 5, 2015 the CPUC issued a Ruling denying ORA’s request for hearings, however, it directed SDG&E to provide additional information related to the design and implementation of its updated pilot program in order to provide greater clarity on new program elements, including: 

  • Prequalification and Site Selection of Charging Station Vendors 
  • Installation, Operations, Maintenance, and Ownership of Charging Infrastructure 
  • Billing and Rates 
  • Program Advisory Council  
  • Monitoring and Evaluation of the Program 

 

CPUC Final Decision

On January 28, 2016, the CPUC issued its Decision approving SDG&E’s Settlement Agreement with the following modifications:   

  • Reduces the cost of the Electric Vehicle Charging Infrastructure Program from $103 million to $45 million. 
  • Limits the duration of the pilot from 4 years to 3 years. 

 

The CPUC issued a Ruling in September 2014 setting the scope and schedule of the proceeding.  

The CPUC held Evidentiary Hearings on SDG&E's original program Application April 27 - May 4, 2015.  
 

Program Advisory Councils (PAC)

SDG&E formed a Program Advisory Council to provide input into its pilot program activities: 

  • The PAC is comprices of Electric Vehicle Service Providers (EVSPs), ratepayer advocates, environmental groups, and automobile manufacturres. 
  • The PAC meets every 6 months. 

 

 

ORA Position

ORA supports the state’s goals to mitigate Greenhouse Gas emissions by increasing the adoption of Electric Vehicles. ORA supports EV strategies that will achieve this goal in the most effective and cost-efficient manner, to ensure accountability for customer funding. The CPUC should adopt a statewide Vehicle-to-Grid Integration pilot framework that is consistent across all utility service territories. ORA supports a phased approach to infrastructure deployment, similar to Edison’s proposed program in order to make program adjustments that will result in a successful program that optimizes ratepayers’ investment.    

Accordingly, ORA supports the CPUC's January 2016 Decision, which significantly reduces the cost and size of SDG&E's originally proposed EV charging station infrastructure program. The more reasonable size of this pilot will allow SDG&E to test its proposed strategy while supporting the state's goals and protecting ratepayer's investment.  

Proposed Settlement Agreement

ORA does not support the proposed Settlement Agreement because it does not demonstrate ratepayer benefits:   

  • Authorizes SDG&E to own EV charging stations, which will stifle competition in the EV charging market at ratepayers’ expense, and could impede meeting the governor's goal of increasing Electric Vehicles in California.    
      
  • Does not require SDG&D to provide the CPUC with information that would inform program improvements and effectiveness necessary to promote a robust and sustainable EV charging market, such as quarterly reporting.  

ORA requested that the CPUC hold hearings on the Settlement Agreement in order to provide clarity on new proposed program elements.  

  

See ORA's: 

July 3, 2015 Comments on the Settlement Agreement.  

  

SDG&E's Original Proposed Program

ORA recommends that the CPUC deny SDG&E’s Application because: 

  • The program size is too large for a pilot. 
  • The proposed pilot does not study customer behavior in response to price.  
  • The proposed pilot does not minimize financial risk to ratepayers.    
  • The proposed pilot does not study the correlation between the increase in EV service equipment with an increase in customer purchase and use of EVs. 

See ORA's: 

September 4, 2015 Brief. 

May 12, 2014 Protest to SDG&E’s Pilot Application.   

 

ORA's Pilot Proposal

On April 13, 2015, ORA filed a Motion recommending that the CPUC implement ORA’s Electric Vehicle Infrastructure Pilot (Cal EVIP) in order to expedite statewide EV charger deployment throughout California. ORA’s pilot proposal would allow the CPUC to move forward with foundational infrastructure planning while concurrently addressing fundamental policy issues in its EV Rulemaking proceeding. ORA’s Cal EVIP pilot would require the utilities to provide minimal ratepayer funding, but not own charging stations. The Cal EVIP pilot would:  

  • Provide EV charger rebates to test strategies and alleviate barriers for siting EV charging stations.  
      
  • Promote increased adoption of EVs and maximize Zero Emission Vehicle (ZEV) miles driven.   
      
  • Deploy EV charging stations consistently statewide for a period of 12-18 months.    
    • PG&E:  1700 Stations  
    • Edison: 1500 Stations  
    • SDG&E: 500 Stations  

To implement the statewide pilot, ORA recommended a stakeholder process to develop a consistent framework for the deployment of all utility Electric Vehicle infrastructure pilots. The CPUC should coordinate workshops and/or other collaborative efforts to develop pilot guidelines that include these key criteria:    

  • Assess EV market demand.  
  • Identify prime locations for EV infrastructure based on findings from prior pilot studies, demographics, economic data, and transportation assessments.  
  • Assess and alleviate EV adoption barriers by working with property owners and EV drivers.   
  • Define metrics and study methodologies to evaluate what strategies best promote EV adoption.  
  • Report findings to the CPUC in order to inform future deployment of EV infrastructure.  

The CPUC should broadly engage EV market stakeholders including regulatory agencies, electric vehicle service providers, utilities, automobile manufacturers, property managers, and other EV industry leaders.    

See ORA’s:  

March 16, 2015 Testimony in response to SDG&E’s in original April 2014 program Application (including ORA’s alternate pilot proposal in Chapter 6).  

April 13, 2015 Rebuttal Testimony, including ORA’s Cal EVIP Proposal for a statewide Charging Station pilot.  


 

CPUC Docket

See the Proceeding docket.