special consideration for underserved areas. Our recommendations included adequate deployment goals for disadvantaged communities (DACs) and multi-unit dwellings (MUDs), participation payment waivers and rebates, and narrowing the eligible market segments due to insufficiently developed selection methodology. We also early and consistently urged for clarification on a proper definition of “disadvantaged communities”. The Decision includes a narrowed section of the proposed market segments, limiting deployment to workplaces and MUDs and excluding other proposed areas such as retail locations and government buildings. The special considerations regarding deployment requirements and payment provisions adopted for DACs and MUDs are in line with JMP recommendations. underserved segments that would adopt greater number of EVs, but for the availability of inexpensive EVSE.” – Decision Directing Pacific Gas and Electric Company to Establish an Electric Vehicle Infrastructure and Education Program, D.16-12-065, (12/21/2016) (“Decision”) at 34. “For example, JMP argues that the EV program in the PG&E territory should focus on the underserved customer segments of MUDs and disadvantaged communities.” – Decision at 35-36. “As demonstrated above, access to EVs by low-income minorities provides numerous benefits to individuals and the wider community. Given that many low-income residents likely reside in multi-unit dwellings (MuDs) with no access to charging infrastructure, these sites should be targeted for pilot phase deployment. Targeting MuDs also ensures that benefits and subsidies will accrue to the community and low-income minorities rather than retailers or workplaces that happen to be located in a DAC.” – Comments of TURN and the Joint Minority Parties on the Administrative Law Judge’s June 16, 2015 Ruling Requesting Comments (“TURN/JMP Phasing Comments”) at 14. “The Parties therefore recommend 100% rebates for charging stations in DACs, expensed by the utility and paid for with program funds.” – TURN/JMP Phasing Comments at 15. “Pacific Gas and Electric Company (PG&E) will provide a 100 percent rebate to the site host for the base costs of the Electric Vehicle Supply Equipment (EVSE) at Multiple Unit Dwelling sites that are Disadvantaged Communities where PG&E is installing and owning the make-ready infrastructure but does not own the EVSE.” – Decision at 85. “PG&E has proposed virtually no
See Also: JMP Opening Brief at 12-17. JMP Reply Brief at 3-9, 12-14. JMP Reply Comments on PD at 3-4 Rejection of Proposed Settlement The Joint Minority Parties (JMP) participated in settlement discussions and ultimately found the terms offered by PG&E and the settling parties to be insufficient, and not consistent with the law. JMP advocated for the rejection of the proposed settlement, arguing among other points for a limited utility ownership model, exclusion of DCFC stations, reductions in cost and size, focus on underserved market segments, and provisions for disadvantaged communities. The final Decision rejected the proposed settlement, and incorporated terms into the Final Program in line with JMP recommendations. Response of the Office of Ratepayer Advocates, the Utility Reform Network, Electric Vehicle Charging Association, TechNet, ChargePoint, Joint Minority Parties and Vote Solar to the Motion for Adoption of Settlement Agreement (4/1/2016) (“Joint Response to Settlement Motion”) at 10-11, 13-14. Comments of the Joint Minority Parties on the Proposed Settlement Agreement by Settling Parties, (4/12/2016) (“JMP Comments on Settlement”). Reply Comments of the Joint Minority Parties on the Proposed Settlement Agreement (4/18/2016) (“JMP Reply Comments on Settlement”) 3-5. Decision at 6, 7, 30-33. Verified Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to the proceeding? Yes Verified b. Were there other parties to the proceeding with positions similar to yours? Yes Verified c. If so, provide name of other parties: ORA, TURN, ChargePoint Verified d. Intervenor’s claim of non-duplication: ORA and TURN represent ratepayer interests generally, and as such, their positions aligned with those of JMP on certain issues. Throughout the proceeding, JMP made efforts to communicate and coordinate with other ratepayer advocates to avoid duplication, and jointly filed when it was appropriate. However, the other ratepayer advocates do not represent the same minority communities as JMP, and do not have the same direct grassroots involvement in Verified