PPA Submits Comments To PUC Law Bureau On EV Rate Design


On November 13th, the Pennsylvania Petroleum Association submitted the following letter to the PUC Law Bureau regarding the Revised Policy Statement Order on Electric Utility Rate Design for Electric Vehicle Charging. This action was in response to the following motion made at the October 19th PUC Meeting by the Chairman Stephen DeFrank.

The PPA previously engaged in the Electric Vehicle Rate Design Working Group which was established by order of the PUC (more details can be found here). The purpose of which was for stakeholder feedback on how the regulatory body should design rate structures in the emerging electric vehicle market. The PPA’s goal in the process was to represent the interests of member companies who are (or at some point would be) interested in entering the EV Charging retail space. The primary comments presented by our group included:

  1. Opposition to electric utilities being able subsidize the buildout of the EV charging networks utilizing general rate payer assessments.
  2. Opposition to public utilities of owning or operating their own retail charging stations.
  3. Support of the creation of rate structure that would provide convenience stores and other retailers a level playing field in the entry to the EV charging business.

Below is the motion made by Chairman DeFrank. The PPA will continue to stay engaged in this process through the Law Bureau, the Governor’s Budget Office, and the public comment period.

Before the Pennsylvania Public Utility Commission (Commission) for consideration is the Order and Proposed Policy Statement encouraging all electric distribution companies (EDCs) to implement rates specifically designed for electric vehicle (EV) charging customers. The instant Order comes pursuant to the Commission’s action taken at Docket P-2022-3030743 approving ChargeEVC-PA’s petition to initiate a proceeding intended to result in the issuance of a policy statement on electric utility rate design for EV charging in the Commonwealth.

The utility landscape is evolving rapidly, none more rapidly than the electric industry. Increased penetration of distributed energy resources and EVs presents both a challenge and an opportunity for regulators and utilities. From a challenge perspective, absent appropriate policies, the increased adoption of these technologies will likely work to decrease utilities’ distribution system network capacity utilization – or the ratio of average demand to peak demand. This places significant headwinds on distribution rates. Further, this adoption could potentially strain electric generation prices and wholesale generation resource adequacy if EV charging load is added to hours of already existing peak demand.

However, EDCs have an opportunity to utilize the portfolio of new technologies such as, but not limited to, advanced metering, advanced grid monitoring, energy efficiency, demand response, and smart thermostats to better accommodate the evolving demand profiles created by this new energy landscape.

I submit that the purpose and scope of this Policy Statement should be to encourage EDCs to develop EV-charging distribution rates with cost-of-service principles that incentivize increased network capacity utilization of the distribution system. Further, I believe the Policy Statement should encourage default service providers (DSPs), presently a role occupied by EDCs, to develop EV-charging generation rates which, at a minimum, properly reflect the cost of generation services during times of system stress. This may include, but is not limited to, use of on and off-peak periods which appropriately incentivize the movement of charging consumption to off-peak periods or periods of less system stress.

I acknowledge that there are no single “turnkey” designs for EV-charging distribution or default service generation rates that achieve these principles. EDCs and DSPs are situated differently, with varying demographics, grid characteristics, and demand profiles. EDCs and DSPs may consider tools such as time-of-use, real-time pricing, demand charges, rebates, automatic control devices, and others to properly effectuate the public interest in line with the Commission’s proposed Policy Statement herein.

Further, I support development of distribution and default service generation EV rates that avoid unreasonable cross-subsidization between customers. As such, the proposed scope of the Policy Statement should also address fairness and equity principles that EDCs consider in developing EV charging rates for distribution and default service generation. Such principles include, but may not be limited to, impacts on low-income customers or disadvantaged communities.

THEREFORE, I MOVE THAT:

  1. The Law Bureau prepare a revised Proposed Policy Statement Order and revised Annex consistent with this motion.
  2. The Law Bureau shall submit the revised Proposed Policy Statement Order and revised Annex to the Governor’s Budget Office for review of fiscal impact.
  3. Upon receipt of a fiscal note from the Governor’s Budget Office the Secretary shall certify the revised Proposed Policy Statement Order and revised Annex and the Law Bureau shall deposit them with the Legislative Reference Bureau for publication in the Pennsylvania Bulletin.
  4. Interested parties shall have 30 days from the date of publication of the revised Proposed Policy Statement Order and revised Annex in the Pennsylvania Bulletin to file comments with the Secretary. 5. Interested parties shall have 60 days from the date of publication of the revised Proposed Policy Statement Order and revised Annex in the Pennsylvania Bulletin to file reply comments with the Secretary.
  5. A copy of the revised Proposed Policy Statement Order and revised Annex be filed at Docket No. P-2022-3030743 and be served upon all jurisdictional electric distribution companies, the Office of Consumer Advocate, the Office of Small Business Advocate, the Bureau of Investigation and Enforcement, the Department of Environmental Protection and all parties who filed comments at Docket No. P-2022-3030743

The PPA would like to thank the National Association of Truck Stop Operators (NATSO) and Charge Ahead Partnership for their continued support during this process.