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CenterPoint Energy Houston Electric (TDU) Says Texas PUC Should Consider, "Direct Utility Investment In Public EV Charging Stations"
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In comments in response to questions in a Texas PUC project concerning electric vehicles, CenterPoint Energy Houston Electric, LLC (CEHE) said that the PUC should, "consider encouraging direct utility investment
in public EV charging stations in areas where competitive market forces may not reach."
CEHE said in its comments that, "In light of the uncertainty regarding the pace and impacts of future EV development, the
Company recommends that the Commission allow utilities to begin implementing pilot programs
now not only to identify and remove potential impediments to increased competitive market
investments in the commercial EV charging stations that might be needed when EV penetration
ramps up, but also to better anticipate the utility infrastructure impacts of having
potentially ubiquitous private and commercial charging stations within their respective service
territories."
CEHE said in its comments that, "In addition to promoting awareness
and education, the Commission should also consider encouraging direct utility investment
in public EV charging stations in areas where competitive market forces may not reach but where
it may nonetheless be in the public interest for EV charging stations to exist, such as along
hurricane evacuation routes and in economically depressed communities."
The REP Coalition filed comments stating that, "We urge the Commission to approach the issues
regarding deployment of EVs in ERCOT from the perspective that, where possible, cost-effective
competitive market solutions should be relied upon to resolve issues regarding deployment of EVs
in Texas."
"Market participants in the retail, generation, or competitive energy services sectors are
likely to be the appropriate sectors for integrating widespread adoption of EVs in ERCOT, rather
than subsidized through a utility-owned and -operated asset that is included in rate base paid for
by REPs (and ultimately the REPs' end use retail customers). In ERCOT, transmission and
distribution utilities ('TDUs') will have a very important role to play in building and operating
the backbone infrastructure that will support the integration of EV loads into the grid. But any
TDU participation in or subsidization of customer-facing competitive energy services such as
public EV charging would result in unintended adverse consequences for the competitive markets
in ERCOT," the REP Coalition said
The REP Coalition said that the deployment of EVs in ERCOT raises three
important policy considerations that the Commission should evaluate in deciding whether and how
to adopt rules to accommodate widespread deployment of EVs: (1) the cost of commercial
charging and associated utility tariff implications (e.g., demand charges and customer class
creation or assignment); (2) retail structural determinations such as where the meter ends and the
retail relationship begins; and (3) customer protection and disclosure requirements.
Tesla, Inc. filed comments asking the PUC to determine that EV charging service providers are not retail electric providers nor public utilities
Tesla said that, "One area that the Commission should evaluate further and that can help facilitate a more
seamless charging experience for commercial EV stations is determining that third-party owners
of EV charging infrastructure are not public utilities or retail energy providers and should not be
regulated as such. Tesla believes that the fairest way to bill customers for charging services is on
a $/kWh basis because the driver is paying for the energy they receive. The predominant
alternative approach to billing for charging services is on a $/minute basis. The pitfall of the
$/minute approach is that two drivers that are parked for the same duration will be billed the
same amount, yet they can receive two completely different quantities of kWh in that time
because the rate of charge is dependent on a variety of factors. These factors include the
vehicle's charging capabilities, state of charge, battery temperature, and others. However, given
the regulatory uncertainty as to whether non-utility charging operators are authorized to bill
drivers on a $/kWh, drivers tend to be billed on a $/minute basis in Texas."
"Tesla therefore recommends that the Commission further evaluate and seek additional
written comments on this topic in this docket, with the goal of issuing guidance about the
Commission's treatment of third-party charging operators in its recommendations and findings to
the Legislature for consideration," Tesla said
Project 49125
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Tesla Says PUC Should Determine Operators Of Commercial EV Charging Stations Are Not Retail Energy Providers
February 4, 2020
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Copyright 2010-20 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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