future. As TURN notes, “[t]his reflects the industry trend and consumer preference of moving towards faster charging (along with improving battery technology) and the related ratepayer risk of stranded or underutilized assets.” TURN notes that VW’s investment in DCFC will be at power levels ranging from 150-350kW. Though more expensive on a per site basis today, establishing higher capacity infrastructure mitigates the inevitable future cost of upgrading supporting distribution infrastructure to higher power levels. TURN suggests PG&E should ensure all make-ready infrastructure installed through the Fast Charge program can support 120 kW or higher powered EVSE, citing a study of Tesla superchargers. As ChargePoint notes, 150 kW better aligns with current trends in DCFC design, so while we support TURN’s recommendation to install infrastructure capable of higher power levels, we recommend PG&E install make-ready infrastructure to support 150 kW or higher power level EVSE for sites that support corridor charging. Corridor charging, where customers stop to charge during a trip, is the most likely to use higher charging levels in the future, as minimizing charging time during a trip will be important to driver experience. Site hosts should not be required to install an EVSE of 150 kW or higher, but as ChargePoint notes, “there is no risk of ‘stranding’ make-ready infrastructure built to support higher power DCFC technologies, and there is value for ratepayers in considering emerging trends in EVs and EV charging technologies.” Even if the site host chooses a higher capacity EVSE, “[a] charger’s ability to deliver power exceeding the on-board capacity of the vehicle using the charger does not mean that the EV cannot use the charger.” PG&E states that a cost contingency of 25 percent is needed to account for unforeseen costs associated with the significant site variation that may arise in
Management Office, which will coordinate “execution among vendors and contractors hired for the program.” SCE will use a request for proposal process to select contractors. Similarly, “the customer would have to commit to the use of qualified and certified union labor for make-ready installation,” to be eligible for PG&E’s FleetReady infrastructure rebate for make-ready infrastructure on a customer’s existing service connection. It is clear that there will be ample opportunity for non-utility entities to participate in the market to install makeready infrastructure to support charging stations. Additionally, we direct the utilities to conduct a competitive process to identify electrical contractors that are qualified to perform make-ready installations. This will ensure the market continues to grow for all qualified installers. No party expresses concerns about the impact of these programs on the market for charging equipment. When qualifying charging equipment, SCE plans to rely on adopted efficiency and safety standards to define its requirements and accept a large number of vendors and charging equipment models, as SCE has done for its Charge Ready Pilot Program. Participating customers, not SCE, ultimately select the qualified charging equipment they need for their operations. SCE suggests, and we agree, that “[t]his approach allows customers to select equipment that works best for their charging needs, and encourages third-party market participants to provide a variety of established and innovative technologies to meet customer demand.” PG&E states its cost estimates are designed only to support the installation of the make-ready infrastructure, and that it “has not endeavored to estimate the cost of EV chargers and network operations equipment, which will be borne by customers and/or third parties.”
GRC phase 2 or Rate Design Window and then filing this request with the FERC before applying this transmission rate design on a more permanent basis. Further, any introduction of timedependent transmission rates should not be limited to EV rates but should encompass non-residential transmission rates generally. In the event FERC does not approve the 70/30 proxy split proposed in Joint-12, SCE should implement its proposed commercial EV rates using the transmission cost allocation currently approved by FERC. ORA describes its position that the “the proposed billing provision with respect to [demand] charges is a significant improvement over SCE’s original proposal.” ORA argues that “SCE’s original proposal was to simply assess the demand charge based on the high non-coincident demand of the EV meter. However, this would have overestimated customers’ demands, because it ignores the fact that the highest demand the grid sees is the combined (i.e. concurrent) demand of the host site meter and the EV meter.” As modified by the Joint Stipulation, the new billing provision accounts for the coincidence of the EV meter’s and the main business meter’s combined maximum demands resulting in a rate design that significantly reduces the financial impacts from demand charges. Tesla is supportive of this modification but recommends clarification to confirm that this structure would only apply to a customer’s delivered load. Tesla suggests, for instance, “if a customer installs storage that reduces the EV peak, there should be no penalty. … Tesla encourages resolution on this question within the final approved program rate design.” The issue Tesla raises would occur if the customer’s storage system were behind the meter that measures the facility load, but not the EV load, thereby reducing the facility’s metered demand, and potentially increasing the incremental EV demand to