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Erik Jacobson
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

December 19, 2018

Advice 5447-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

Information-Only Advice Letter - Confirmation of FleetReady Electric
Vehicle Service Equipment (EVSE) Rebate, Infrastructure Incentive, and
Definition of Financially Fit Pursuant to Decision 18-05-040.

Pacific Gas and Electric Company (PG&E) submits this Tier 1 information only advice
letter at the request of Energy Division confirming PG&E’s implementation of the
FleetReady program’s EVSE rebate amount and structure, infrastructure incentive
amount and structure, and definition of financially fit as informed by Program Advisory
Council (PAC) feedback.1
On June 6, 2018, the CPUC issued Decision (D.) 18-05-040, effective May 31, 2018,
approving with modifications PG&E’s proposed Standard Review Projects—FleetReady
and Fast Charge—and program budgets. The CPUC authorized a total combined budget
of $269,067,449; $236,324,660 for the FleetReady program and $22,394,041 for the Fast
Charge program with an additional $10,348,748 for program evaluation. The authorized
budget expenditures and revenue requirements are tracked through the subaccount of
PG&E’s one-way Transportation Electrification Balancing Account (TEBA) as modified in
Advice Letter 5309-E pursuant to Ordering Paragraph 48 of D. 18-05-040.2


Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.1 and 6.2, this Tier 1 information
only Advice Letter does not request any relief or action by the Commission and is not subject to
protest or response.
2 D. 18-05-040, OP 48: “Within 15 days of the effective date of this decision, Pacific Gas and
Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company
must each submit a Tier 1 Advice Letter to modify existing one-way balancing accounts approved
in Decision 18-01-024, Ordering Paragraphs 30, 15, and 23 respectively.” Advice Letter 5309-E
was approved effective as of June 15, 2018.


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Advice 5447-E -2- December 19, 2018 Consultation with Program Advisory Council On September 20, 2018, at PG&E’s Q3 Clean Transportation PAC meeting, PG&E presented proposed approaches to the following FleetReady program design elements to gather input from stakeholders: • • • EVSE rebate amount and structure, Infrastructure incentive amount and structure, and Definition of financially fit On October 30, 2018, PG&E held a PAC meeting open to all PAC members to further specifically discuss the above-mentioned topics. This meeting was held to provide an opportunity to lead more in-depth discussion on these topics that affect EV stakeholders. PG&E presented more detailed analysis on each approach as discussed below. Participants attending the meeting were generally supportive of the approaches presented with some specific concerns raised, detailed below. PG&E also distributed a feedback request form to all PAC members on the distribution list after the meeting, providing a chance for those who were able to attend in person and for those who were not in attendance to provide additional feedback. PG&E received written comments related to the above topics from EVgo and the California Public Advocates Office. For all three items presented in this Tier 1 information-only advice letter, values and approaches are meant to be a starting point for FleetReady implementation. PG&E will monitor the program budget, the market prices of chargers, and the cost of customerowned make ready infrastructure costs as part of the program and consult with the PAC on an annual basis, or more frequently as needed. On October 24, 2018, the Energy Division staff requested that PG&E document its values and approaches on these topics with an advice letter. FleetReady EVSE Rebate Methodology and Amount As corrected in D.18-10-026 issued on October 17, 2018, Ordering Paragraph 35 directs PG&E to work with SCE to establish EVSE rebate amounts for school buses, transit buses, and sites in disadvantaged communities (DACs), not to exceed 50% of the cost of the EVSE and not to exceed the cost to the participant in the case additional funding sources are utilized.3 D. 18-10-026, OP 35: “Pacific Gas and Electric Company (PG&E) and Southern California Edison Company (SCE) must set rebate levels for transit and school bus electric vehicle supply equipment (EVSE) in consultation with its Program Advisory Councils (PACs). These rebates must not exceed 50 percent of the cost of the EVSE. These rebates must only be offered to participants: (1) who are located in disadvantaged communities (DACs); or (2) participating transit 3
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Advice 5447-E -3- December 19, 2018 Given anticipated variability of charger power levels that will be installed for electric vehicles participating in the FleetReady program, PG&E has developed a rebate structure tiered by the charger’s power level. PG&E will establish four EVSE tranches based on power output: • • • • Tranche 1: Up to 20 kW (i.e. level 2 charging), Tranche 2: 20kW to up to 50 kW, Tranche 3: 50 kW to up to 150Kw, and Tranche 4: 150 kW and above. PG&E’s initial proposal for the EVSE tranches, as presented to the PAC, did not feature a tranche corresponding to Level 2 charging (Tranche 1); this is being added based upon stakeholder feedback. In addition, stakeholders noted that 150 kW chargers are available and used for some fleet applications, and they are substantially more expensive than 50kW chargers. To address this comment, PG&E has elected for the above-mentioned tranches, which have been slightly modified from those presented to the PAC, and to allow for 150kW chargers (rather than 151 kW chargers) to be included in the highest tranche. To determine rebate amounts for EVSEs in each tranche, PG&E will use relevant available data to determine the median price of chargers within the respective tranche which will be defined as the base cost. This approach is consistent with the approach implemented to establish the base cost for rebates in PG&E’s EV Charge Network program and allows for a base cost that is representative of the range of pricing and technologies included in each tranche. PG&E will then take 50% of the base cost for each power level tranche and set this as the cap for the respective category. Eligible participants will receive a rebate for their charger at 50% of the cost paid, not to exceed the specified cap for the appropriate tranche.4 PG&E will determine amounts for the EVSE rebate in two phases. In the first phase, to accommodate customers who are actively soliciting currently available vehicle grant funding and have an immediate interest in participating in the FleetReady program, PG&E will set EVSE rebate amounts based upon data from SCE’s June 2018 DCFC Pilot Request for information (RFI), which was conducted in June 2018. Due to lack of data on level 2 charging from the RFI, during this phase, PG&E will treat or school bus site hosts. PG&E and SCE should work with their respective PAC to develop further requirements for participants located in DACs to be eligible for a partial EVSE rebate. PG&E and SCE must ensure the rebates do not exceed the cost the site host pays for the EVSE after accounting for any other funding sources used for EVSE procurement.” 4 Rebates are subject to funding availability. Program funds will be disbursed on a first-come, firstserved basis.
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Advice 5447-E -4- December 19, 2018 EVSEs in Tranche 1 in the same way as those in Tranche 2. PG&E believes that this approach still provides a fair rebate for Level 2 chargers, given that they will still only be eligible for a rebate of a maximum of 50% of the actual cost of EVSE, ensuring that the customer still funds at least 50% of the EVSE purchase with non-utility funds. SCE’s DCFC Pilot RFI was sent to 14 companies and gathered responses from 6 participants, most of which provided data for multiple charger levels. The RFI resulted in 6 responses regarding chargers up to 50 kW, 3 responses for chargers 51-150 kW and 3 responses for chargers over 150 kW. SCE provided PG&E with the median cost of chargers in each of these categories which are used by PG&E as the base cost for each Tranche. Table 1 below details the base cost and EVSE rebate amounts PG&E will implement at the outset of the FleetReady program. Table 1. PG&E FleetReady EVSE Rebate Levels Power output Tranche 1 & 2 Up to 50 kW Base cost1 $30,000 Tranche 3 50 kW to up to 150 kW $50,000 50% of the cost of EVSE, up to $25,000 Tranche 4 150 kW and above $84,000 50% of the cost of EVSE, up to $42,000 Note: Rebate for eligible customers 50% of the cost of EVSE, up to $15,000 (1) Defined as the median EVSE cost in each tranche from SCE’s DCFC Pilot RFI. For phase 2, PG&E will conduct a request for qualification (RFQ) to qualify EVSEs eligible for participation in the FleetReady program and collect information related to the cost of those EVSEs. This RFQ will be conducted in parallel to phase 1 and results are expected in Q12019. Using the RFQ results, PG&E will also establish separate rebate amounts for tranche 1 and tranche 2, if appropriate. Once that RFQ data is available, PG&E will update the EVSE rebate amounts using the methodology described above. Regarding the requirement in OP 35 to avoid over-compensating participants who are leveraging additional funding resources, PG&E is working in close coordination with state and local agencies that administer grants or incentives for medium- and heavy-duty electric vehicles, infrastructure and/or EVSEs. PG&E plans to maintain coordination with these agencies to ensure funding is stacked optimally. In addition, PG&E plans to collect data from participating customers related to external funding received for the project and will include language in the FleetReady customer participation contract which requires that the customer not accept incentive funding greater than the total cost of the project.
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Advice 5447-E -5- December 19, 2018 FleetReady Customer-Owned Infrastructure Incentive Methodology and Amount Pursuant to Ordering Paragraph 39, all FleetReady program participants have the option to own, operate, and maintain the infrastructure behind the meter.5 In cases where the customer selects this option to construct and own the make-ready infrastructure, the customer will be eligible for an infrastructure incentive for up to 80% of the customerowned make-ready infrastructure costs (“80% Incentive Cap) on a per vehicle basis6. Program participants electing to own and construct their own make-ready infrastructure must still meet all applicable program eligibility criteria. PG&E established the 80% Incentive Cap for all vehicle sectors, using budget assumptions established in Table 6 of D. 18-05-040. For all sectors, PG&E attributed 40% of the total cost per site to the behind-the-meter infrastructure work, which is the portion that will be customer-owned, and 60% of total infrastructure costs to-the-meter work (utility-owned). This is 60/40 split is consistent with the site estimates PG&E filed in its budget workpapers for the FleetReady program. Per OP 39, PG&E then took 80% of the behind-the-meter costs to establish the estimated incentive per site, which was converted to an incentive per vehicle based on the average number of vehicles anticipated to be adopted by each respective sector. To simplify program implementation and customer understanding of the program offerings, vehicle sectors with similar installation costs were grouped together. Using the above methodology, the 80% per vehicle incentive caps for the FleetReady program were determined and are provided in Table 2 below. Initially, PG&E had proposed providing class 8 vehicles with a lower incentive level than transit vehicles. At the PAC meeting, Tesla expressed a concern that installation costs for class 8 vehicles are expected to be high and should be appropriately reflected in the D. 18-05-040, OP 39: “If the customer chooses ownership, the customer must manage and pay for the installation of the customer-side infrastructure and use state licensed labor for which the utility will provide a rebate of up to 80 percent of the installation costs, treating these costs as an expense for ratemaking purposes, and the customer must commit to operate and maintain the facilities consistent with relevant national, state, and local electrical standards for their site. The customer must submit its site plans and estimated site construction costs to the utility and state its commitment to operate and maintain the facilities consistent with relevant national, state, and local electrical standards for their site. The utility shall provide a rebate to the customer for customer-side infrastructure the customer installs that is the lesser of: (a) 80 percent of customer’s actual installation costs or (b) 80 percent of the average utility direct cost for installing the customer-side make-ready infrastructure in the relevant sector.” 6 Disbursing incentives on a per vehicle basis encourages participants to optimize charging solutions and allow for a single charger to serve multiple vehicles. This approach also accounts for variations in site cost due to number of vehicles being deployed and supports the FleetReady program’s goal to install infrastructure to support at least 6,500 medium- and heavy-duty electric vehicles. 5
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Advice 5447-E -6- December 19, 2018 per vehicle maximum rebate allowed for the customer-owned infrastructure incentive. PG&E agrees with this feedback and estimated the same cost per site for transit buses and class 8 trucks in its testimony. As a result, PG&E will apply the same level of incentive to class 8 vehicles as transit buses. Table 2. PG&E FleetReady Behind-the-Meter Infrastructure Incentive Caps by Vehicle Sector Vehicle Sector 80% Incentive Cap1 TRU, TSE, airport GSE and forklifts $3,0002 Transit buses and Class 8 vehicles $9,0003 Other vehicles $4,0004 Notes: (1) Except in cases where individual site costs are unrealistic, infeasible, or unreasonable, to-the-meter construction costs will be covered by the FleetReady program and/or funding that would be normally covered by Rule 16 under GRC. (2) Limited to 50 vehicles per site to facilitate funding availability for program site goals; sites with more vehicles to be considered on an individual basis. (3) Limited to 25 vehicles per site to facilitate funding availability for program site goals; sites with more vehicles to be considered on an individual basis. (4) Limited to 25 vehicles per site to facilitate funding availability for program site goals; sites with more vehicles to be considered on an individual basis. FleetReady Definition of Financially Fit Per Ordering Paragraph 38, for purposes of the FleetReady program, PG&E has developed a definition for financially fit in coordination with the PAC.7 Program applicants will need to provide proof of purchase of a minimum of two vehicles to be deemed financially fit. PG&E’s intent is to establish a definition that checks for financial fitness without adding excessive administrative burden for the customer or PG&E in the process. Since applicants will need to purchase at least two vehicles to be eligible for program participation, this approach does not add additional work, but rather confirms eligibility while also defining financial fitness. This is a sufficient measure to check for financial fitness because the upfront cost of purchasing a medium- or heavy-duty electric vehicle is the greatest investment in the total cost of ownership for an electric vehicle and demonstrates that the customer can be expected to have sufficient financial capital to cover the ongoing operations and maintenance costs. In the case that a program participant wants to plan for future EV procurement, PG&E may install infrastructure to support participants’ vehicle procurement plans up to 5 years into the future. To be eligible, the participant must provide evidence of a long-term fleet D. 18-05-040, OP 38: “Pacific Gas and Electric Company and Southern California Edison Company must ensure participating customers in either the Fleet Ready or Medium- and HeavyDuty Vehicle Charging Infrastructure Programs be financially fit to participate.” 7
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Advice 5447-E -7- December 19, 2018 electrification plan (e.g. a regulatory compliance plan or a publicly available sustainability plan) and a schedule of anticipated load increase associated with planned vehicle procurement. If the participant does not deliver the anticipated load, PG&E reserves the right to implement deficiency billing to cover the cost of unused system enhancements attributable to the difference between projected and actual load. The 5-year start will initiate upon contract execution at which time the program participant must confirm the total number of vehicles they will be purchasing in the next 5 years and therefore the number of vehicles PG&E will install infrastructure to support. PG&E will review all requests to install infrastructure for future EV procurements on a case by case basis. Tier Designation Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.1, this advice letter is submitted with a Tier 1 information only designation. Effective Date This Tier 1 information-only advice submittal is effective upon date of filing, which is December 19, 2018. Notice In accordance with GO 96-B, General Rule 6.2, this information-only advice letter is not subject to protest. In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service list for A.17-01-020. Address changes to the General Order 96-B service list should be directed to PG&E at email address For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter submittals can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations cc: Service lists for A.17-01-020
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ADVICE LETTER S UM M A RY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39 E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Annie Ho Phone #: (415) 973-8794 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Advice Letter (AL) #: 5447-E Tier Designation: 1 Subject of AL: Information-Only Advice Letter - Confirmation of FleetReady Electric Vehicle Service Equipment (EVSE) Rebate, Infrastructure Incentive, and Definition of Financially Fit Pursuant to Decision 18-05-040. Keywords (choose from CPUC listing): Compliance, Balancing Account AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.15-05-040 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: Yes Yes No No 12/19/18 No. of tariff sheets: N/A Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed 1: N/A Pending advice letters that revise the same tariff sheets: N/A Discuss in AL if more space is needed. 1 Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. Braun Blaising Smith Wynne P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Casner, Steve Cenergy Power Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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