Details for: 4480-E (Part 1 of 1).pdf

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

April 27, 2021
(U 338-E)

Southern California Edison Company’s Charge Ready 2
Low-Port Rebate program

In compliance with Decision (D.) 20-08-045, Ordering Paragraph (OP) 26, Southern
California Edison Company (SCE) hereby submits this Advice Letter (AL) to provide
information about SCE’s Charge Ready 2 Low-Port Rebate Program.
On September 2, 2020, the California Public Utilities Commission (Commission or
CPUC) issued D.20-08-045 (Decision), authorizing SCE’s Charge Ready 2 (CR2)
Infrastructure and Market Education programs. The Decision authorizes $436 million in
funding to support electric vehicle (EV) charging infrastructure, rebates, marketing,
education and outreach, and evaluation of the CR2 infrastructure and market education
In OP 26, the Commission directed SCE to work with its Transportation Electrification
(TE) Advisory Board to develop a “low port rebate” for sites installing four or fewer ports.
The Commission further directed SCE to reflect the rebate amounts authorized and the
resulting budget changes for the low port rebate in its Tier 2 Advice Letter requested in
OP 9 of the Decision. Because OP 9 of the Decision directs SCE to submit a Tier 1 AL
after two years of customer enrollment to address the site-host ownership option, SCE
is submitting this Advice Letter in advance of program implementation to reflect the
rebate amounts and budget changes for the Low-Port Rebate Program.
Pursuant to the Decision, the Low-Port Rebate Program will be available to commercial
customers, including workplaces, public venues, and multi-unit dwelling (MUD) sites

Decision, p. 2.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4480-E (U 338-E) -2- April 27, 2021 choosing to install four or fewer charging ports.2 The Low-Port Rebate Program will offset program participant costs associated with the purchase and installation of Level 1 (L1) or Level 2 (L2) electric vehicle service equipment (EVSE) on the customer-side of the meter. This rebate is intended to help offset charging equipment costs and any necessary infrastructure upgrades on the customer-side of the meter. If a utility-side distribution service upgrade is necessary at the participant’s site, neither the rebate nor other CR2 program funds will be applied to the utility-side infrastructure work. Rebate Amount: The Decision directs SCE to work with its TE Advisory Board to develop a low port rebate, up to $16,000 per port for sites installing four or fewer ports.3 SCE interprets this directive as establishing a $16,000 cap for the rebate, while allowing SCE to work with its TE Advisory Board to determine an appropriate rebate amount. Accordingly, SCE and its TE Advisory Board determined that a one-time Low-Port Rebate of up to $5,000 per port is appropriate to help offset the purchase and installation of EVSE and any customer-side of the meter infrastructure upgrade required to support the installation of approved L1 and/or L2 charging stations. The rebate payment will not exceed the program participant’s actual costs. As with other CR2 program options, SCE will evaluate charging station rebate levels annually with its TE Advisory Board to ensure the rebate amounts are appropriate. Approach: In determining the appropriate rebate level, SCE considered examples of other EV charging rebate options, including: • • San Joaquin Valley Air Pollution Control District’s Charge Up! Program - provides a rebate between $5,000 and $6,000 per unit for the purchase and installation of new L2 EV chargers.4 The Department of Water and Power’s Commercial EV Charging Station Rebate – provided a rebate up to $5,000 per qualifying L2 charging station located in a disadvantaged community and up to $4,000 everywhere else.5 SCE believes that providing a rebate for the EVSE and customer-side infrastructure is appropriate and anticipates that most customers who seek to install a smaller volume of 2 3 4 5 Decision, p. 150. Decision, pp. 70-71. See!_Guidelines.pdf See
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ADVICE 4480-E (U 338-E) -3- April 27, 2021 ports may not need utility-side infrastructure upgrades to accommodate the additional charging equipment load.6 Coordination with the TE Advisory Board: On September 25, 2020, SCE discussed its proposal for the Low-Port Rebate Program with its TE Advisory Board, referred to as the Program Advisory Council (PAC). SCE proposed a rebate of up to $5,000 per port to cover costs for the customer-side EV charging infrastructure and the EVSE. On January 27, 2021, SCE also sent an email to the PAC members requesting feedback on the CR2 rebate amounts, including the Low-Port Rebate Program amount. On February 2, 2021 SCE received an email response from The Utility Ratepayer Network (TURN) requesting that SCE waive the requirement for a separate meter for participants in the Low-Port Rebate Program and recommending that “the rebate start at the amount referenced in the Decision – up to $16,000/port (maximum including both infrastructure and charging station costs). This amount cannot be exceeded and the rebate should cover only actual costs incurred by the site host.”7 SCE assessed the potential for waiving the separate meter requirement and determined that it can support TURN’s request to waive the meter requirement because participants will be required to have their EVSE networked, and SCE will be provided with port level data that will be collected from the Electric Vehicle Service Provider. Furthermore, in SCE’s reply to TURN’s protest to Advice 4438-E,8 SCE agreed to modify its proposed Schedule CRP to clarify that separate metering is optional for the Low-Port Rebate Program.9 Additionally, as SCE explained in its reply to TURN’s protest to Advice 4438-E, SCE explored the potential for the rebate to cover both the customer-side and the utility-side infrastructure work. SCE found that including utility-side infrastructure costs (i.e., construction advances and deeded infrastructure) in the rebate calculation would deviate from current accounting practices and would put SCE at risk of non-compliance with fixed asset capitalization accounting rules 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). Applying a portion of the rebate to the utility-side infrastructure work would result in mixing cost recovery of a single asset in 6 7 8 9 TURN similarly concludes that “In some instances, these [low port] sites may be able to install fairly low-cost infrastructure by utilizing existing service drops and panels and locating charging load near existing transformers. (Prepared Testimony of Eric Borden, Addressing SCE’s Charge Ready 2 Electric Vehicle Infrastructure Proposal, p. 28). Email received from Eric Borden. Advice 4438-E, Southern California Edison Company’s Proposed Schedule CRP, Charge Ready Program, to Implement Charge Ready 2. Reply to The Utility Reform Network’s Protest to Southern California Edison Company’s Advice 4438-E submitted on April 7, 2021, at p. 3.
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ADVICE 4480-E (U 338-E) -4- April 27, 2021 the general rate case and a balancing account (i.e., Charge Ready Program Balancing Account) that would require complex manual accounting adjustments to unwind. Further, the Decision does not direct SCE to apply the Low Port Rebate to utility-side infrastructure work. SCE agrees that the rebate should cover only those costs for the customer-side infrastructure and EVSE that are incurred by the customer. Based on these considerations, the Low-Port Rebate Program will offset costs associated with the purchase and installation of the EVSE and any required customerside of the meter infrastructure upgrades. SCE discussed its final Low-Port Rebate Program recommendations with its TE Advisory Board on March 12, 2021. Specifically, SCE noted that the one-time rebate would provide up to $5,000 per port to help offset the EVSE and related installation costs on approved L1 and L2 EVSEs. SCE did not receive any feedback or comments. Authorized Budget: Costs for the Low-Port Rebate Program will be captured within the authorized budget for Make Ready Expansion Program, which supports the installation of L1 and L2 makeready EV charging infrastructure at multi-unit dwellings, workplaces, fleets and destination centers for a total budget of $333M. TIER DESIGNATION Pursuant to OP 26 of D.20-08-045 and General Order (GO) 96-B, Energy Industry Rule 5.2, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice letter will become effective on May 27, 2021, the 30th calendar day after the date submitted. NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to:
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ADVICE 4480-E (U 338-E) -5- April 27, 2021 CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: Tara S. Kaushik Managing Director, Regulatory Relations c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and A.18-06-015 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at
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ADVICE 4480-E (U 338-E) -6- April 27, 2021 For questions, please contact Melodee Black at (626) 302-4728 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:mb:cm
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 4480-E Subject of AL: Southern California Edison Company's Charge Ready 2 Low Port Rebate program Keywords (choose from CPUC listing): Rebates, Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 20-08-045 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: 5/27/21 No. of tariff sheets: -0- Estimated system annual revenue effect (%): Estimated system average rate effect (%): 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: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 1 Discuss in AL if more space is needed. 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: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: Name: Tara S. Kaushik c/o Karyn Gansecki Title: Managing Director, Regulatory Relations Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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