CPUC Offers Guidance For Near-Term Utility Transportation Electrification Investments

While assuring stakeholders that a decision on the full-scale Transportation Electrification Framework (TEF) will be forthcoming, the California Public Utilities Commission (CPUC) this week issued an interim Decision Setting Near-Term Priorities For Transportation Electrification Investments by the Electrical Corporations (Decision 21-07-028). The decision authorizes California investor-owned utilities to submit proposals for transportation electrification (TE) investments prior to approval of the TEF and submission of full-scale transmission electrification plans, in order to “avoid gaps in existing program offerings to support meeting state goals for electric vehicle charging facilities for the year 2025.”

TE investment proposals may be submitted as applications under the Commission’s current rules, but D.21-07-028 also authorized two more streamlined approaches in order to enable more expedited consideration of smaller scale programs and proposals for extension of existing TE programs.

Near-Term Priority Programs. Each IOU may propose up to $80 million in “near-term priority” TE programs through a streamlined advice letter filing process, as long as each program’s budget is capped at $20 million and fits within one of the CPUC’s five near-term investment priority categories:

• Resiliency;
• Charging access for customers without access to home charging;
• Investments to support medium and heavy-duty EV adoption;
• EV infrastructure in new building construction;
• Assistance for low-income residential panel upgrades to accommodate Level 2 charging.

The near-term investment proposals must meet other requirements aimed at reducing ratepayer costs, limiting utility ownership of customer-side EV charging infrastructure, and focusing on underserved communities. Interested parties will have an opportunity to comment on and recommend modification of the near-term investment proposals through the Tier 3 advice letter protest/response process. The CPUC’s Energy Division will issue a template to guide preparation of advice letter filings.

Program Extensions. Each IOU may submit expedited applications for CPUC approval of proposals for extension of one of the following existing TE infrastructure programs: PG&E’s EV Charge Network, SDG&E Power Your Drive, SCE Charge Ready and Charge Ready 2, PG&E EV Fast Charge, PG&E EV Fleet, PG&E Empower, SCE Charge Ready Transport, SDG&E Power Your Drive for Fleets, and the small and large IOUs’ Schools and Parks pilots. Extension requests should demonstrate that:

• There is outstanding demand to participate in the expiring or soon-to-expire program;
• The extension makes modifications to align with vehicle-grid integration load management guidance;
• The IOU clearly incorporates lessons learned from the existing program to maximize ratepayer benefits and reduce per port costs relative to the existing program;
• Any proposed per port costs remain below the average per port cost threshold the CPUC adopted in recent TE decisions, to the extent applicable;
• The extension aligns with equity and environmental justice requirements;
• The IOU provides a rationale for how the proposal will help California meet the state’s charging targets without burdening ratepayers;
• The IOU proposes to own no more than 50% of EV charging stations and customer-side infrastructure, and only in underserved communities;
• The proposal includes competitive options for customer/site host ownership of behind-the-meter infrastructure;
• The IOU provides data for evaluation of costs and other metrics.

The expedited applications for program extensions must be submitted in accordance with Rule 2.9 of the Commission’s Rules of Practice and Procedure, which provide for issuance of a proposed decision within 12 months.

Ellison Schneider Harris & Donlan attorneys are monitoring TE proceedings at the CPUC, California Energy Commission, Air Resources Board, and other public agencies and jurisdictions throughout California. Please contact us for more information.

Contact: Lynn Haug, Jed Gibson