Details for: PGE AL 5450-E.pdf

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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 21, 2018

Advice 5450-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

Confirmation of Fast Charge Program Electric Vehicle Service
Equipment (EVSE) Rebate and Definition of Disadvantaged
Community (DAC) Adjacent Pursuant to Decision 18-05-040.

Pacific Gas and Electric Company (PG&E) submits this advice letter at the request of the
Energy Division confirming the EVSE rebate amount and eligibility and definition of DAC
adjacent pertaining to the Fast Charge program as informed by Program Advisory Council
(PAC) feedback.
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 will be tracked through the dedicated
subaccount of PG&E’s one-way Transportation Electrification Balancing Account (TEBA)
as modified in Advice Letter 5309-E pursuant to Ordering Paragraph (OP) 48 of D. 1805-040.1

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 Californ ia 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 5450-E -2- December 21, 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 Fast Charge program design elements to gather input from stakeholders: • • EVSE rebate amount Definition of adjacent disadvantaged community (“DAC adjacent”) On October 30, 2018, PG&E held a PAC meeting open to all PAC members to discuss the above-mentioned topics. This meeting was held to provide an opportunity to lead a more in-depth discussion on these topics that affect industry stakeholders. PG&E presented detailed analysis defining DAC adjacent and provided an opportunity to discuss the EVSE rebate amount. Participants attending the meeting were generally supportive of the approaches presented, asked clarifying questions, and were understanding of the complexity of establishing such a definition in a diverse territory. PG&E also distributed a feedback 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 Fast Charge program from EVgo and the City of San Jose. In addition, following the PAC meeting, PG&E discussed these issues with The Utility Reform Network (TURN) and Greenling Institute. For both items presented in this advice letter, the approaches and values are meant to be a starting point for Fast Charge implementation. PG&E will monitor the program budget and the market prices of chargers as part of the program and evaluate 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. Fast Charge EVSE Rebate Ordering Paragraph 25 of D. 18-05-040 authorizes PG&E to issue rebates for EV charging station hardware for Fast Charge sites located in DACs up to a maximum of $25,000 per charger. PG&E will implement this approach for rebate eligibility and issuance for the Fast Charge program. Sites located in DACs will be eligible for a rebate of up to $25,000 per charger not to exceed the full cost of the charger hardware and installation. In accordance with D. 18-05-040, this rebate amount will not be available to sites in DAC adjacent areas, as defined in the next section, even if the sites support DAC
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Advice 5450-E -3- December 21, 2018 residents and businesses and even though PG&E believes this restriction may conflict with the Commission’s overall intent.2 Fast Charge Definition of Disadvantaged Community Adjacent The Commission finalized language in D. 18-05-040 pertaining to the Fast Charge program stating, “25 percent of the site hosts should be located in or adjacent to DACs”. “Adjacent” has not previously been used or defined in the context of qualifying DACs. PG&E considered several options to define DAC adjacent and consulted with the PAC as well as state agencies and organizations with expertise on this topic including the California Air Resources Board. PG&E considered the following three approaches to define DAC-adjacent: 1) 2) 3) Adjacent census tracts: includes all census tracts bordering a DAC census tract 5-mile buffer: Adds a five-mile buffer around all DAC census tracts Hybrid approach: Census tracts bordering existing DAC census tracts, capped at a 5-mile buffer. In addition, based upon feedback from parties, PG&E considered the use of the San Francisco Bay Area’s Metropolitan Transportation Commission’s (MTC) Communities of Concern map3 and the AB 1550 low-income communities maps 4 as a means of supporting a DAC-adjacent definition. When evaluating these options, PG&E found it difficult to apply a single definition across the geographic and population density diversity of PG&E’s service area. The “adjacent census tracts” approach expanded eligible geographic area immensely in more rural areas. On the other hand, in urban areas, where population is dense and census tracts are correspondingly small, the “5-mile buffer” approach extends across multiple non-DAC census tracts and can lead to an entire urban area – both affluent and not – being defined as DAC adjacent. Neither the MTC Communities of Concern map nor the AB 1550 lowincome communities maps were referenced in D. 18-05-040 in relation to DAC adjacent, and both posed challenges for implementation. In the case of the MTC map, it only covers the Bay Area and therefore makes border areas challenging to define. The AB1550 low income map poses the same challenge as the “adjacent census tract” approach; it expands eligible areas too broadly, especially in more rural areas. Greenlining Institute and the Utility Reform Network suggested defining DAC adjacent as the AB 1550 lowincome communities that are within 1/2 mile of a qualifying DAC census tract. PG&E feels, In response to this apparent prohibition in D.18-05-040, it is within the Commission’s discretion to clarify its intent in D.18-05-040 or modify D.18-05-040 to delete this prohibition and permit sites in adjacent DAC areas that support DAC residents and businesses. 3 4 2
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Advice 5450-E -4- December 21, 2018 however, that this definition is too limiting, as Fast Charge sites in any area adjacent to a DAC census tract will improve access to EV charging for DAC residents. To address the diversity of the geographic areas that PG&E serves, PG&E has decided to implement the “hybrid approach”. As initially proposed, this “hybrid approach” defined DAC adjacent as census tracts bordering existing DAC census tracts, capped at a 5-mile buffer. Based on feedback from the PAC and other stakeholders, PG&E has decided to modify its proposal to lower the cap to a half-mile buffer which is a more appropriate distance for residents of DACs to travel to access DCFC stations. Accordingly, PG&E will define DAC adjacent as census tracts bordering existing DAC census tracts, capped at a half-mile buffer. Census tracts that fit completely within the half-mile buffer will be considered DAC adjacent, and census tracts that extend beyond the half-mile buffer will be capped at a ½ mile to be included in the DAC adjacent definition. PG&E believes this approach maintains the intent of the decision to increase access of DAC residents to EV charging. By counting DAC adjacent sites towards the program target of installing 25% of sites in DACs, PG&E will make a concerted effort to site chargers in DAC and DAC adjacent communities, thereby increasing access to DCFC stations and bringing benefits of siting chargers in these communities such as increased business at charger sites. Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than January 10, 2019, which is 20 days after the date of this submittal. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission:
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Advice 5450-E -5- December 21, 2018 Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date PG&E requests that this Tier 1 advice submittal become effective upon date of filing, which is December 21, 2018. Notice 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 list 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) #: 5450-E Tier Designation: 1 Subject of AL: Confirmation of Fast Charge Program Electric Vehicle Service Equipment (EVSE) Rebate and Definition of Disadvantaged Community (DAC) Adjacent 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.18-05-040 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 12/21/18 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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