D.C. PSC Rules Pepco Can't Sell Power Supplies To End-Use Customers Charging Electric Vehicles At Public Charging Stations
Sales From Charging Stations Must Be Done Via An Affiliate
PSC Rejects Most Elements of Pepco's Transportation Electrification Plan
Approves Whole House Residential "Discounted" SOS Rate
Finds No Issue With Pepco Offering Green Adder To Supply Rates
April 13, 2019 Email This Story Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • firstname.lastname@example.org
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The District of Columbia PSC issued an order on Pepco's proposed transportation electrification (TE) plan
The PSC ruled that Pepco can only sell electricity from a public electric vehicle charging station EVCS through an affiliate
In reaching this conclusion, that PSC said, "The essential question is whether Pepco is permitted or otherwise obligated to sell electricity under the various TE Program Offerings through SOS. The proposed sales encompass two distinct sales transactions, first is the sale of electricity supply from the wholesale market to the EVCS and second, from the EVCS to the EV. Pepco in its Application and comments is asking the Commission to find that both sales of electricity are within the scope of SOS under D.C. Code § 34-1509. In creating SOS, the DC Council deferred to the Commission to determine the terms and conditions for SOS service. Further, based on the purpose of SOS in providing a backstop in case of default by an electricity supplier, ensuring all electricity service is covered, and serving customers who do not select an electricity supplier, the Commission finds that Pepco’s development of wholesale SOS rates that are designed to serve transportation electrification customers is within the purpose for which SOS was established. Therefore, the Commission finds that, as to traditional SOS electricity supply rates, from the wholesale electricity market to the EVCS, for EV related service, there is no jurisdictional barrier to the Offerings’ use of SOS under the TE Program."
The PSC further said, "Considering the environmental synergies between EV ownership and use of renewable energy, the Commission likewise finds no issue with the optional Green Adder, which provides 100% renewable electricity for EV charging. The Commission notes that competitive issues would arise if customers were prevented from switching to an electricity supplier that offered electricity supply to EV charging customers, a position which Pepco agrees with. Further, Pepco’s EV tariff must clearly disaggregate SOS and distribution services so that non-SOS EV charging suppliers are afforded the same and equal access to Pepco’s distribution system."
The PSC further said, "Turning to the second sales transaction -- from Pepco-operated EVCS to the EV, the Commission does not believe that Pepco’s proposal to sell electricity from Pepco operated EVCS to a customer’s EV falls within the scope of its provision of SOS, since as discussed above such a sale is within the definition of an electricity supplier. Therefore, pursuant to D.C. Code § 34-1513 (a) Pepco can only engage in the business of an electricity supplier through an affiliate."
Given that the PSC concludes that sales from an EVCS to a customer’s EV falls within the definition of an electricity supplier, the PSC also ruled that, pending the completion of a rulemaking to amend the Commission’s Electricity Supplier Rules in Chapter 46 of Title 15 of the District of Columbia Municipal Regulations to eliminate any requirements on electric vehicle charging station owners and operators to obtain a license from the Commission as a supplier, the Commission’s licensing requirements under those rules are temporarily waived for electric vehicle charging station owners and operators who sell or distribute electricity
The PSC approved Pepco's proposal to offer a Residential Whole House Time-Of-Use Rate for electric vehicles. Specific rates will be addressed in a future filing.
Pepco had originally proposed to permit Standard Offer Service (SOS) residential customers with EVs to choose a "discounted" 'whole house' TOU rate, "that offers the customer easy entry into a new rate and facilitates transition to PIVs [plug-in vehicles]." Such TOU component of the 'whole house' rate would include a time-based SOS rate intended to encourage usage, including PIV charging, during off-peak hours. On-peak hours will be 12:00 pm to 8:00pm, Monday to Friday, excluding holidays. All other hours will be off-peak.
Pepco had also proposed that all SOS customers on one of the EV options (both whole house and EV meter-specific) shall have the option of receiving electricity consisting of 100% renewable energy (PIV-Green) in the form of an 'Adder' to the EV-specific rate. "The Adder will allow customers to have their energy supplied from 100% green energy and claim zero tailpipe emissions when charging an all-electric vehicle," Pepco said
The PSC's order does not specifically address this proposal other than stating, as noted above, the Commission said that it, "finds no issue with the optional Green Adder, which provides 100% renewable electricity for EV charging."
The PSC directed Pepco to provide 'make-ready' infrastructure for thirty-five (35) Public Neighborhood Smart Level II Public Chargers and up to twenty (20) DC Fast Chargers.
For such approved fifty-five (55) public charging stations, Pepco is directed to facilitate the deployment of make-ready infrastructure in coordination with and as requested by third-party EVCS owner/operators and site hosts. Pepco had originally sought to own the 55 public chargers
The Commission approved Pepco’s deployment of 'make-ready infrastructure' for up to ten (10) Smart Level II EV chargers and two (2) DC Fast Chargers accessible for taxis and rideshare services. The Commission approved Pepco’s deployment of 'make-ready infrastructure' for five (5) Smart Level II charging stations and one (1) DC Fast Charging station for bus depots and bus routes. Pepco is not authorized to own or contract for the operation of EVCSs under the rideshare and busing deployments
The PSC directed that a working group address various other facets of Pepco's proposal, including exploration and development offerings for a fixed price residential rebate, and multi-dwelling unit EVCS deployment
The PSC rejected the following proposals from Pepco:
• Offering 2: Installation credit for up to one hundred and fifty (150) residential customers with existing, installed Electric Vehicle Service Equipment (“EVSE”) to install FleetCarma data loggers and receive monthly bill credit thereafter for participation.
• Offering 3: Fifty percent discount on the cost of new Residential Smart Level II EVSE and installation for fifty (50) residential customers.
• Offering 6: Fifty percent discount on the cost of new Smart Level II EVSE for fifty (50) customer workplace locations.
• Offering 9: Installation of charging infrastructure at a minimum of two (2) locations to support the use of Electric Fleet/Light Duty Charging Infrastructure consisting of up to ten (10) Smart Level II EVSE and one (1) DC Fast Charger at each location.
• Offering 12: Establish a $1 million Innovation Fund, to be funded by the Modernizing the Energy Delivery System for Increase Sustainability (MEDSIS) subaccount, for innovation projects.
• Offering 13: Establish a $1.5 million Technology Demonstration program to be funded by the MEDSIS subaccount.