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USA: Modifications to Electric Rate Schedule E-9 for Residential Time-of-Use Service for Low Emission Vehicle Customers and Creation of New Schedule EV

Pacific Gas and Electric Company (“PG&E”) hereby supplements its Advice
Letter 3910-E dated September 26, 2011, to address, in part, issues and
concerns raised in response to that advice letter.

Purpose

On September 26, 2011, PG&E filed revisions to voluntary Electric Vehicle
Schedule E-9. The proposed changes were, in part, ordered by Decision 11-07-
029. In that decision, the Commission concluded PG&E’s existing voluntary rate
for electric vehicle customers, Schedule E-9, needed to be revised. As PG&E
noted in its Advice Letter, Schedule E-9 is both complex and outdated, and its
tiered structure does not reflect PG&E’s cost of service. In this supplemental
advice letter, PG&E responds to concerns raised by parties in response to
Advice Letter 3910-E by modifying its proposal for Schedule E-9 and by creating
a new Schedule EV.

Background

PG&E discussed the background associated with the changes to Schedule E-9 in
depth in Advice Letter 3910-E and does not repeat that background here. As of
November 4, 2011, PG&E received 75 protests to PG&E’s advice letter from
individuals or organizations. PG&E responded to protests on November 14,
2011. These protests had the following main themes:





Public policy objectives for EVs and EV charging rates;
The potential for adverse bill impacts under PG&E’s proposed rates;
Future rate choices that will be available for EV charging loads;
Specific rate design and cost allocation issues;
Other recommendations; and

Advice 3910-E-A

-2-

Procedural adequacy of notification to customers affected by the proposed
changes.

Specific rate design issues raised included the implementation of a monthly
customer charge, time-of-use (TOU) period definitions and revenue neutrality as
the basis for setting rates.

Rate Proposal

PG&E’s original proposal in Advice 3910-E addressed two key policy objectives:
(1) to correct the extremely low tiered rates on Schedule E-9; and (2) to offer
TOU rates without an inclining block tiered rate structure which creates a
disincentive for electric vehicle charging by driving total usage into higher tiers.
In this advice letter, PG&E supplements its original proposal to address issues
raised in protests while still meeting these key objectives. First, PG&E proposes
to grandfather existing customers on Schedule E-9 to provide two additional
years of this schedule. However, to ensure that Schedule E-9 is not continued
indefinitely at inappropriate rate levels, PG&E proposes to eliminate Schedule E-
9 on the later of the date of a decision in Phase 2 of the 2014 GRC or December
31, 2014. Second, PG&E will establish a new Schedule EV that meets the
second objective by establishing a voluntary rate for customers with electric
vehicles that is time differentiated and non- tiered.

Modified Schedule E-9

PG&E’s current Schedule E-9 has two options. The first option allows customers
to take whole house service, including EV charging, through one meter. This
“whole-house”, or single meter option, is called Option A of Schedule E-9. The
second option under Schedule E-9 is for charging-only service. Under this option,
service to the EV charger is separately metered. This is known as Option B of
Schedule E-9. Both options of Schedule E-9 will remain open to existing
customers, as well as any new qualifying customers, until the effective date of
the new Schedule EV that is proposed in this advice letter and described further
below. After Schedule EV becomes effective, no additional customers will be
allowed to take service under either option of Schedule E-9. The customers
taking service under Schedule E-9 prior to the effective date of Schedule EV will
be “grandfathered” under Schedule E-9, and will have the opportunity to
continue service on this schedule until the later of the date a decision is granted
in Phase 2 of PG&E’s 2014 GRC, or December 31, 2014. At that time, both
options of Schedule E-9 will be eliminated and the customers will be migrated to
an otherwise available rate schedule.

In this advice letter, PG&E requests only the changes to Schedule E-9 needed to
close the schedule to new customers and to indicate the timeframe when
Schedule E-9 will be eliminated as described above. No changes to the rate
levels in Schedule E-9 are being requested in this advice letter.

Advice 3910-E-A

-3-

New Schedule EV

For customers with electric vehicles that are not “grandfathered” under Schedule
E-9, or do not wish to continue service under Schedule E-9, PG&E proposes a
new, optional Schedule EV. The new Schedule EV is offered instead of
completely revising all rates for Schedule E-9 as PG&E originally proposed in
Advice 3910-E. As such, the new Schedule EV is a non-tiered TOU rate like
PG&E originally proposed for a revised Schedule E-9. Also, like Schedule E-9,
Schedule EV will have two options: Option A for whole house service and Option
B for charging-only service.

PG&E anticipates it will need up to six months to revise its billing systems so that
Schedule EV can be offered, at which time Schedule E-9 will be closed to new
customers as discussed above. In addition, customers must have an appropriate
meter to accommodate the new TOU periods under Schedule EV.

PG&E has revised its initial proposal for non-tiered TOU rates for electric vehicle
charging significantly to address concerns raised by the parties. First, both the A
and B options of Schedule EV will be designed on a revenue neutral basis. To
address concerns raised by the Division of Ratepayer Advocates (DRA), revenue
neutrality is determined for the class as a whole (rather than just single family
residences as PG&E had originally proposed), and does not include an
adjustment for EV usage (again, rather than PG&E’s original proposal to include
175 kWh for incremental EV usage).

Second, to address several parties concern with regard to the proposed
customer charge of $8.00 per month, Options A and B of Schedule EV do not
include a customer charge (although, like PG&E’s other residential rates that do
not include a customer charge, Option A does include a minimum charge). As
directed by the Commission, Option B includes a meter charge of $1.50 per
month which is expressed in the tariff as a daily charge. Since some of the
revenue that must be collected is allocated to a meter charge on Option B, the
energy rates on Option B are slightly lower than the corresponding energy rates
on Option A. The proposed rates for both Option A and Option B of Schedule EV
are shown in Table 1, below. In total, these changes make electric vehicle rates
more attractive than the rates originally filed in Advice 3910-E.
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1 comment to USA: Modifications to Electric Rate Schedule E-9 for Residential Time-of-Use Service for Low Emission Vehicle Customers and Creation of New Schedule EV

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