R.______ALJ/RMD/sid DRAFT
ALJ/RMD/sid Date of Issuance 8/24/2009
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking on the Commission’s own motion to consider alternative-fueled vehicle tariffs, infrastructure and policies to support California’s greenhouse gas emissions reduction goals. / FILEDPUBLIC UTILITIES COMMISSION
AUGUST 20, 2009
SAN FRANCISCO, CALIFORNIA
RULEMAKING 09-08-009
ORDER INSTITUTING RULEMAKING
TO CONSIDER ALTERNATIVE-FUELED VEHICLE TARIFFS, INFRASTRUCTURE AND POLICIES TO SUPPORT CALIFORNIA’S GREENHOUSE GAS EMISSIONS REDUCTIONS GOALS
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R.______ALJ/RMD/sid DRAFT
TABLE OF CONTENTS
Title Page
ORDER INSTITUTING RULEMAKING TO CONSIDER ALTERNATIVE-FUELED VEHICLE TARIFFS, INFRASTRUCTURE AND
POLICIES TO SUPPORT CALIFORNIA’S GREENHOUSE
GAS EMISSIONS REDUCTIONS GOALS 2
1. Summary 2
2. Legal Background 4
3. Technical Background 7
3.1. Vehicle Connection to Electric Vehicle Supply
Equipment Options 8
3.2. Potential Near-Term Electrical Distribution System Impacts 12
4. Tariff-Related Background 14
5. Preliminary Scoping Memo 16
5.1. Questions 19
5.2. Proposed Schedule 28
6. Coordination with Other State Agencies and Local Agencies 29
7. Record 30
8. Respondents 30
9. Proceeding Category and Need for Hearing 30
10. Parties and Creation of the Official Service List 31
11. Service of Documents 33
12. Commission’s Public Advisor’s Office 34
13. Intervenor Compensation 34
14. Ex Parte Communications 35
ORDER.. ..35
ATTACHMENT A – Respondents and Load Serving Entities
ATTACHMENT B – California Energy Commission, California Independent System Operator, and California Air Resources Board Representatives for Service
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R.09-08-009 ALJ/RMD/sid
ORDER INSTITUTING RULEMAKING
TO CONSIDER ALTERNATIVE-FUELED VEHICLE TARIFFS, INFRASTRUCTURE AND POLICIES TO SUPPORT CALIFORNIA’S GREENHOUSE GAS EMISSIONS REDUCTIONS GOALS
1. Summary
The Commission recognizes that many automakers will be introducing to California roadways electric charged vehicles in the next one to five years. [1] As a result of this market development, we are initiating this rulemaking to consider the impacts electric vehicles may have on our State’s electric infrastructure and what actions this Commission should take. We must ensure that the charging of these vehicles does not have adverse impacts on our electric system in terms of reliability, while at the same time recognizing the benefits of these vehicles in achieving California’s climate change goals.
This rulemaking seeks to consider tariffs, infrastructure and policies needed for California investor-owned electric utilities to ready the electricity system in a consistent, near-term manner for the projected statewide market growth of light-duty passenger plug-in hybrid electric vehicles (PHEV) and battery electric vehicles (BEV) throughout California. Other electric vehicle classes may be considered pending stakeholder input during this proceeding. We may also consider issues associated with natural gas vehicle market growth and any needed regulatory changes.
Our immediate goal is to review any current electric vehicle tariff schedules and facilitate electric vehicle charging infrastructure in the near-term to support a successful transition of a portion of the gasoline-powered vehicle fleet in California to electric vehicles. We intend to develop consistent statewide policies and standards to guide and encourage development of electric vehicle metering, home electric vehicle charging infrastructure, commercial and public charging infrastructure, tariff schedules, and, if advisable, incentive programs. Our efforts will be undertaken consistent with Commission and State policy goals, including reducing greenhouse gas emissions pursuant to Assembly Bill (AB) 32,[2] reducing petroleum consumption, improving and optimizing electricity system asset utilization, expanding the use of renewable energy as a charging fuel for electric vehicles, and ensuring electric service reliability.
We intend to collaborate with other governmental entities with interests in this area and encourage their input and participation. We also intend to coordinate consideration of tariffs, infrastructure, and policy with issues considered in the ongoing Commission Smart Grid proceeding (Rulemaking (R.)08-12-009). In the Smart Grid proceeding, we are considering issues associated with communication between the vehicle and utility or electric vehicle service provider.[3] As an example of the level of coordination we envision, if the Smart Grid proceeding develops communication guidelines, we may apply them to electric vehicle charging infrastructure installation guidelines developed here.
2. Legal Background
The Commission exercises jurisdiction over the activities of public utilities, including those that are electrical corporations. Pub. Util. Code § 216 defines public utility as “. . . every … gas corporation, electrical corporation, telephone corporation, … where the service is performed for, or the commodity is delivered to, the public or any portion thereof.” Subsection (b) of this code section goes on to provide: “Whenever any common carrier, toll bridge corporation, pipeline corporation, gas corporation, electrical corporation, telephone corporation, telegraph corporation, water corporation, sewer system corporation, or heat corporation performs a service for, or delivers a commodity to, the public or any portion thereof for which any compensation or payment whatsoever is received, that common carrier, toll bridge corporation, pipeline corporation, gas corporation, electrical corporation, telephone corporation, telegraph corporation, water corporation, sewer system corporation, or heat corporation, is a public utility subject to the jurisdiction, control, and regulation of the commission and the provisions of this part.”
Furthermore, Pub. Util. Code § 218 defines an electrical corporation as ". . . every corporation or person owning, controlling, operating, or managing any electric plant for compensation within this state, except where electricity is generated on or distributed by the producer through private property solely for its own use or the use of its tenants and not for sale or transmission to others.”
In this rulemaking, we will address the scope and role of the Commission’s regulatory authority over electric vehicle service providers, including third-party resellers providing electricity to electric vehicles, including the question of whether the Commission has jurisdiction over such entities. If so, we will consider the appropriate level of regulatory oversight, including whether thirdparty resellers providing electricity to electric vehicles should be exempted from our regulation as an electric utility, via a statutory change if necessary.[4]
Additionally, the California Air Resources Board’s Low Carbon Fuel Standard,[5] Section 95484(a)(6), applies to regulated parties for electricity fuel. That section of the Low Carbon Fuel Standard identifies load serving entities, electric vehicle service providers, electric vehicle charging equipment owners, and electric vehicle owners as potential regulated parties for electricity fuel. The California Air Resources Board’s Resolution 09-31[6] adopting the Low Carbon Fuel Standard directs the “Executive Officer [of the Air Resources Board] to continue to work with the Commission, electric utilities, oil refiners, and other stakeholders to review the provisions applicable to electricity and propose amendments, if appropriate, to the regulation by December 2009.” In this rulemaking, we will consider possible recommendations to the California Air Resources Board regarding the Low Carbon Fuel Standard.
In this rulemaking, we may also explore how certain existing laws, codified in 2002 (commonly referred to as “AB 1X”), [7] can accommodate the expected increase in electrical usage when residential customers charge electric vehicles on their residential electric accounts. AB 1X requires utilities to provide residential customers with up to 130% of the baseline quantities of electricity in existence at the time AB 1X was enacted in 2002, at rates no greater than those in effect at the time of that enactment. Under the current rate structure, if the additional electricity use required for an electric vehicle were billed on the existing residential account, it would, in many cases, be at the highest residential rate, which could have the practical effect of discouraging residential hook-ups for electric vehicle recharging. A possible solution is the use of a separate electric vehicle tariff and/or the use of separate time-of-use (TOU) meters for vehicle charging. Some customers, particularly those who have residential photovoltaic installations, may want to recharge their vehicles on a net-metered basis and may not want a separate vehicle recharging account or separate meter. We intend to address these issues in this rulemaking.
3. Technical Background
The purpose of this section is to provide charging infrastructure, distribution system impact, and tariff–related information relevant to this proceeding. A number of technical issues are presented to provide background for purposes of answering charging option questions presented in section 5 and as a starting point for discussion among parties.
The technical information provided here is in addition to the information provided in the Commission’s Policy and Planning Division’s May 22, 2009 white paper.[8] This white paper outlines electric vehicle drive train options, battery capacity options, battery chemistry options, and related infrastructure support requirements that distinguish PHEVs from BEVs. It also includes a limited analysis of the impact of a given vehicle population scenario on total energy demand, peak load, and net greenhouse gas emissions. Stakeholders submitted comments to the Policy and Planning Division on this white paper, which served to further clarify the technical information in the white paper.[9]
3.1. Vehicle Connection to Electric Vehicle Supply Equipment Options
This rulemaking invites academic, utility industry, automotive industry, local governments, and consumer comment on PHEV and BEV charging preferences, in addition to inviting stakeholder comment on applicable charging infrastructure codes and standards. We briefly explain the technical aspects of charging electric vehicles to give context to the questions that later follow.
A factory-model PHEV or BEV houses a charger that converts alternating current (AC) from an electrical circuit into direct current (DC) and regulates the current voltage directed to the on-board battery for storage.[10]
The electric vehicle charge time and Electric Vehicle Service Equipment (EVSE)[11] sub-circuit size determine the amount of energy (kWh) drawn per charge. As the electric vehicle market matures, electric vehicles may demonstrate improved energy conversion efficiencies, depending on factors including vehicle weight, drive train options, and driving conditions. Like household electric appliances, higher efficiency electric vehicles will use less energy (kWh) to provide the same energy service.
The difference between the vehicle battery state of charge and battery capacity determines energy needed per charge.[12] To draw power from an electricity sub-circuit at the residence or a commercial or public charging facility, the electric vehicle can either (1) use a mobile cordset EVSE to connect to a dedicated wall plug and a 120 Volt (V) sub-circuit (1.4 kW, 15 Amps (A) or 20 A), or (2) connect to a cord attached to a permanently mounted EVSE premise unit connected to a 240V sub-circuit (typically, 3.3 kW - 6.6 kW, up to 19.2 kW, 80 A).[13] A DC charging option includes an additional charger in the EVSE that bypasses the vehicle charger for higher power distribution (for example, 120 kW, up to 800kW).[14]
A second electric meter or sub-meter needed to separate vehicle load from the normal residential load is external to the vehicle and to the EVSE premises unit. An external communication bridging device is one of several options that could transmit homeowner and/or utility program messages through the Advanced Meter Initiative (AMI) meter and a communication platform to the uniquely identified vehicle. This rulemaking may explore whether the interface between the utility and the electric vehicle should include communication signals that include (but are not limited to) utility time variant pricing signals, demand response signals, and voltage ramping and regulation signals.
A mix of charging level options at standardized charging facilities (standard 120V (Level 1), 240V (Level 2) and DC charging options) will likely be required to support a mass electric vehicle market.[15] Many electric vehicle drivers may prefer Level 2 off-peak charging in order to charge larger BEV batteries within a reasonable time and expedite smaller PHEV battery charging. However, Level 1 charging is as ubiquitous as a standard 120V outlet. Level 1 and Level 2 charging at residential EVSE facilitates off-peak charging when electricity demand, driving demand, and electricity cost of service are low. Night time vehicle charging is convenient for a homeowner and has the potential to integrate increased levels of intermittent off-peak wind energy, flatten the electricity system load curve, and realize generation, transmission, and distribution system efficiencies.
However, some drivers may prefer daytime opportunistic charging at a residential, commercial, or public charging facility. [16] Daytime charging may be necessary to make electricity refueling as convenient as gasoline refueling, and may be a requirement for a mass electric vehicle market. The potential adverse impact of daytime charging, however, is that if it occurs during peak load time (approximately noon to 7:00 p.m.), this could have a negative impact on the grid, causing more expensive and polluting peak generation units to operate.
This rulemaking will also explore centralized charging as a potential charging option to complement decentralized residential charging. DC charging may offer a charge rate adequate to enable a geographically centralized electricity refueling model similar to the gasoline filling station model for conventional vehicles. Replaceable battery swapping stations located in urban areas, exurban areas, and along highways are another means of making electricity refueling time and location similar to the gasoline filling station model.[17]
Another technical issue relates to the fact that charging facilities will be located in multiple utility service territories, which may require an entity/entities (e.g., electric utilities, electric vehicle service providers, and/or clearing houses) to establish an electric vehicle usage billing system. This rulemaking may look at issues relating to the necessity of such a system to accurately track electricity fuel consumption to apply utility tariffs and track net greenhouse gas emissions reductions. A billing system may be preferable to a uniform statewide electric vehicle tariff; stakeholders note that utility tariffs are unique because of service cost differences due to geographic and regulatory factors.[18]
We note that early PHEV consumer behavioral research indicates after-market converted-PHEV drivers prefer charging at multiple times and locations, including daytime charging.[19] Again, this rulemaking is an opportunity to invite charging behavior research findings to analyze infrastructure performance requirements. We also welcome electric vehicle user input via their representative associations.
3.2. Potential Near-Term Electrical Distribution System Impacts
This rulemaking is also an opportunity to examine system-dependent analyses of transformer stress due to localized electric vehicle load, and discuss whether cost increases due to such load should be incorporated into utility distribution maintenance budgets in general rate cases or other cost of service proceedings. It is also an opportunity to assess demand response load management programs, tariffs, and other technologies that may be of use to avoid acute distribution system impacts. In the long term, pending electric vehicle market commercialization, other system impact costs may include transmission line upgrades and total energy procurement attributable to electric vehicle usage.