Details for: SCE Reply to ChargePoint Protest to Advice 4322-E.pdf

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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

November 19, 2020

Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102


Reply of Southern California Edison Company to the Protest
of the ChargePoint, Inc. to SCE Advice 4322-E

Dear Energy Division Tariff Unit:
In accordance with Section 7.4.3 of General Order (GO) 96-B, Southern California
Edison Company (SCE) provides this reply to ChargePoint, Inc.’s (ChargePoint) protest
of SCE’s Advice 4322-E, submitted on November 12, 2020 (the Protest).


On September 2, 2020, the California Public Utilities Commission (Commission or
CPUC) issued D.20-08-045 (Decision), authorizing SCE’s Charge Ready 2
Infrastructure and Market Education programs. The Decision requires SCE to submit a
Tier 1 AL within 60 days of adoption of the Decision, outlining the RFQ processes for
electric vehicle service equipment under the site-host and utility-ownership models,
consistent with Section 4.5.12 of the Decision.1 Section 4.5.12 of the Decision further
directs SCE to include the technical, data collection, and warranty requirements for
participating Electric Vehicle Service Equipment (EVSE) vendors.2
On October 23, 2020, SCE submitted Advice 4322-E in compliance with the Decision.
On November 12, 2020, ChargePoint submitted the Protest. In the Protest,
ChargePoint seeks clarification that SCE’s streamlined process for pre-qualifying or

Section 4.5.12 includes a discussion of TOU Rates, Demand Response, and Technical
D.20-08-045, OP 19.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645 FAX (626) 302-6396


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Energy Division Tariff Unit Page 2 November 19, 2020 deeming qualified vendors and equipment already on SCE’s Approved Product List (APL) will apply to both Level 2 and Direct Current Fast Charge (DCFC) equipment.3 II. Response to the Protest In the Protest, ChargePoint states that SCE’s current APL only includes Level 2 charging stations and the APL should be expanded to include DCFC equipment as directed by D.19-11-017 and D.20-08-045.4 It is unclear to SCE why ChargePoint believes that SCE’s current APL does not include DCFC equipment. In Advice 4322-E, SCE provides a link to SCE’s current APL, which includes approved DCFC equipment.5 In addition, in the Protest, ChargePoint provides a different link to SCE’s current APL which also includes DCFC equipment.6 Nevertheless, SCE clarifies that SCE’s current APL includes DCFC equipment and intends to include additional DCFC equipment as it is approved. Lastly in the Protest, ChargePoint indicated that it has informally discussed this concern with SCE and has concluded that guidance from the Commission in the disposition of Advice 4322-E would be helpful.7 SCE does not believe a Commission disposition of Advice 4322-E is needed because SCE’s current APL includes DCFC equipment. As such, ChargePoint’s Protest is without merit and should be dismissed. III. Conclusion The Commission should approve Advice 4322-E as submitted. Sincerely, /s/ Gary Stern Gary A. Stern, Ph.D. cc: 3 4 5 6 7 Edward Randolph, Director, CPUC Energy Division Alexandra Leumer, ChargePoint Protest, p.1. Protest, p.2. Advice 4322-E, p..2. See footnote number 2. Protest, p.2. Protest, p.3.
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