Details for: SCE Reply to TURN Protest to Advice 4438-E.pdf

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

April 7, 2021
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Reply to The Utility Reform Network’s Protest to Southern
California Edison Company’s Advice 4438-E

Dear Energy Division Tariff Unit:
In accordance with Section 7.4.3 of General Order (GO) 96-B, Southern California
Edison Company (SCE) hereby replies to the protest of The Utility Reform Network
(TURN) to SCE’s Advice 4438-E, Southern California Edison Company’s Proposed
Schedule CRP, Charge Ready Program, to Implement Charge Ready 2 (Advice Letter).
On March 11, 2021, SCE submitted the Advice Letter with the proposed Schedule CRP
tariff that sets forth the requirements, terms, and conditions for customers to participate
and/or receive rebates in SCE’s Charge Ready 2 programs (collectively, the CR2
Program). As summarized in the Advice Letter, SCE will offer the following programs as
part of CR2 Program: (1) Make-Ready Expansion Program, (2) Own and Operate
Program, (3) New Construction Rebate Program, and (4) Low-Port Rebate Program.
The specific requirements for customers to qualify for each of the programs are
provided in detail in Special Condition 2.a through 2.d of Schedule CRP. All other terms
and conditions are provided throughout the proposed tariff included as Attachment A to
the Advice Letter.
On March 30, 2021, TURN protested the Advice Letter. TURN asserts that the
implementation terms that SCE proposed for the Low-Port Rebate Program are
inconsistent with California Public Utilities Commission (Commission or CPUC) Decision
20-08-045, Decision Authorizing Southern California Edison Company’s Charge Ready
2 Infrastructure and Market Education Programs (Decision). Specifically, TURN
recommends to:
1. Include the utility-side infrastructure costs under the Low-Port Rebate Program;
2. Clarify that separate metering requirement is optional for the Low-Port Rebate
Program; and
3. Specify the maximum amount or calculation methodology for the Low-Port
Rebate Program.
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 April 7, 2021 DISCUSSION I. Utility-Side Infrastructure Costs Should not be Included Under the Low-Port Rebate Program In its protest, TURN asserts that the Low-Port Rebate Program does not comport with the Commission’s directive in the Decision. Specifically, TURN claims that while the Decision does not explicitly lay out all the terms of the Low-Port Rebate Program, the Commission’s intention is to adopt TURN’s proposal as discussed in its testimony.1 TURN also claims that its low-port rebate proposal is intended to cover both the makeready infrastructure and EVSE costs up to $16,000 per port.2 SCE disagrees with TURN’s assertion that the utility-side infrastructure should be included in the Low-Port Rebate Program, as TURN’s own testimony fails to make clear that the Low-Port Rebate Program should apply to both the utility-side and customerside infrastructure. Specifically, the Decision points to TURN’s testimony, which indicates that “for sites, that can utilize on-site infrastructure (e.g., existing panel, service drop or onsite transformers) the $16,000 rebate will cover a large portion of these costs.”3 TURN’s reference to the existing “on-site” infrastructure appears to imply that customers participating in the Low-Port Rebate Program may not need any new installation or upgrade to the utility-side infrastructure, a position SCE does not dispute. The Decision also references TURN’s explanation that the $16,000 rebate may be needed to cover “a large portion” of the customer-side infrastructure costs.4 While the Decision is clear that the rebate should cover customer-side infrastructure costs, it does not specify that utility-side infrastructure costs are required to be covered by the rebate. Further, SCE believes there is no adverse effect on the customer if the rebate is allocated solely to the customer-side infrastructure. SCE agrees with TURN’s implication that existing utility-side infrastructure can be leveraged and that most customers who seek to install three or fewer ports under the Low-Port Rebate Program may not need utility-side infrastructure upgrades to accommodate the EV load. Furthermore, SCE anticipates that customers who seek to install four ports will likely choose to participate in the Make Ready Expansion Program where the costs of the utility-side and customer-side infrastructures are paid for by SCE. Although SCE did consider including both the customer-side and utility-side infrastructure within its Low-Port Rebate proposal, in response to feedback on its Low Port Rebate proposal from TURN and the Energy Division, SCE found that including utility-side infrastructure costs (construction advances and deeded infrastructure) in the rebate calculation under the Low-Port Rebate Program is not only impractical but also would put SCE at risk of non-compliance with fixed asset capitalization accounting rules 1 2 3 4 TURN Protest, at p. 2. Id. Decision, at p. 63. Id.
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Energy Division Tariff Unit Page 3 April 7, 2021 and practices. In particular, the portion of the rebate assignable to the utility-side infrastructure would be considered a cost incurred by the utility to acquire the asset and would have to be capitalized according to FERC Electric Plant Instructions part (b)(1), mixing cost recovery of a single asset in the general rate case and balancing account (i.e., Charge Ready Program Balancing Account). In addition, manual adjustments to the asset basis would need to be made for balancing account recovery, including complex depreciation, cost of removal, and deferred tax calculations to ensure compliance with Generally Accepted Accounting Principles and Federal Energy Regulatory Commission Code of Federal Regulation Electric Plant Instructions. For the reasons explained above, TURN’s recommendation to include utility-side infrastructure cost as part of the Low-Port Rebate Program should be rejected. II. The Separate Metering Requirement is Optional for the Low-Port Rebate TURN states that the requirement for an SCE-approved meter dedicated to registering electric vehicle supply equipment (EVSE) load should be waived for the Low-Port Rebate Program and that it should be optional.5 SCE’s intention is to not require the customer to install a separate meter to measure the EVSE load for data usage purposes under the Low-Port Rebate Program. It is simply an option should the customer choose to install a separate meter. As such, SCE agrees to modify Special Condition 7 of Schedule CRP to clarify that separate metering is optional for Low-Port Rebate. III. Specify the Maximum Rebate Amount Allowed Under the Low-Port Rebate Program TURN states that the Advice Letter does not include the proposed rebate amount or calculation methodology for the Low-Port Rebate Program and that these items should be specified.6 As SCE advised TURN during a teleconference meeting on March 29, 2021, SCE intends to submit an advice letter in April 2021 with additional implementation details regarding the Low-Port Rebate Program including the rebate amount and calculation methodology for the rebate. SCE is still in the process of finalizing the details of the Low-Port Rebate Program and the advice letter that SCE intends to submit would be the appropriate filing to provide the additional implementation information that TURN seeks. SCE notes that the purpose of the Advice Letter and the proposed tariff, Schedule CRP, is to establish the requirements, terms, and conditions for customers to participate in the CR2 Program. Similar to the tariffs developed for SCE’s Charge Ready offerings, such as Schedule CRPP, Charge Ready Pilot Program, and Schedule CRT, Charge Ready Transport, the rebate amounts are not specified. By not specifying the rebate amounts 5 6 TURN Protest, at p. 3. Id.
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Energy Division Tariff Unit Page 4 April 7, 2021 in any of the tariffs related to Charge Ready programs, SCE is able to modify the rebate levels after consulting with its Program Advisory Council (PAC), without having to modify the tariffs whenever a change to the rebate level is deemed necessary, as authorized in the Decision and other decisions related to Charge Ready programs. Rebate modifications are often necessary to align with developments in charging station cost, design, and market demand. These changes are reviewed with the PAC annually, as mandated in the program Decisions. CONCLUSION SCE appreciates the opportunity to provide this reply to TURN’s protest and requests that the Commission approve Advice 4438-E as submitted, with the modification regarding metering for Low-Port Rebate Program that SCE intends to submit in a supplement to this advice letter. Sincerely, /s/ Gary A. Stern Gary A, Stern, Ph.D. GAS:sl:cm cc: Edward Randolph, Director, CPUC Energy Division Audrey Newman, CPUC Energy Division Elise Torres, Attorney for TURN Service List for A.18-06-015
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