PG&E / CPUC - Non-Tiered Time Of Use Rates

[waitingforaleaf]

I've spent a decent amount of time editing a rate calculator (originally written by Martin Eberhard) for estimating your electricity rates. Since there's plenty of customization available, it is a great tool for seeing what your rates would be under E1, E6, E7, E9A, or E9B.

The original file that I received had errors with regards to calculations for the Utility User's Tax and E9B tier calculations. Based upon my calculations, I believe that I have fixed the utility user's tax calculation. For the E9B calculations, I believe that the modifications I've made will allow E9B to be accurate IF EV charging is calculated for ONLY off-peak hours. I screwed up the calculation for partial-peak and peak charging (but don't have the time or need to fix it), so the numbers get vastly inaccurate if charging occurs during those periods (keep this in mind if you put in >36000 miles per year into the calculator as this will "force" you to charge in partial peak and skew the results into inaccuracy).

I've also made a second worksheet that includes the proposed rate changes to E-9 from Advice 3910-E, so you can do side-by-side comparisons for how the proposed changes will affect your bill. I would have loved to integrate them into a single worksheet, but the modifications to the worksheet are beyond the amount of time I would want to spend in doing so.

In any case, if anyone is interested in these two documents, feel free to shoot me a PM with your e-mail address, since I haven't figured out how to attach those documents to a forum post. I can also forward my written letter of protest for people to peruse or use as a template should you wish to send a letter of your own.

 

[mxp]

< cut >
In any case, if anyone is interested in these two documents, feel free to shoot me a PM with your e-mail address, since I haven't figured out how to attach those documents to a forum post. I can also forward my written letter of protest for people to peruse or use as a template should you wish to send a letter of your own.

waitingforaleaf,

many thanks for helping out. Could you pls post the text/content of your letter so that others could simply "cut-n-paste" the verbiage from your template? I intend to leverage from your template. Thank you!!

Some further questions:
1. would a class action voice from a legal standpoint be of any effective, directed at PG&E even at this early stages of the process?

2. does anyone here have a contact in the US Dept of Energy: Energy Efficiency & Renewable Energy section who can help represent the peoples voice at the CPUC hearing?
http://www.afdc.energy.gov/afdc/laws/law/CA/6489" onclick="window.open(this.href);return false;


From our personal side: We did our research into utility rates, factored in "nissan-leaf-incentive-9.pdf", current and projected E9B rate increases (reasonable %'s) and personal funds to pay for E9B install before we even committed to buy the cars. We are a 2 leaf household.

How frustrating that this issue has come up! We wouldn't not have purchased the Leafs if we had known that PG&E was planning to do utility rate hikes in the 50%- 75% range to cash in on electric car user adoption.

http://www.nissanusa.com/ev/media/pdf/incentives/nissan-leaf-incentive-9.pdf" onclick="window.open(this.href);return false;
"nissan-leaf-incentive-9.pdf"
STATE OF CALIFORNIA
Pacific Gas & Electric Rate Reduction
Short Description: A discount rate is offered for electricity used to charge Electric Vehicles during off-peak
times.

Beneficiary: PG&E customer who charges an electric vehicle
Type of Incentive: Reduced rate for electricity used
Effective Dates: Current benefit, no sunset date
Value of Benefit: Reduced rate for electric used
Full Description: Pacific Gas & Electric (PG&E) offers a discounted rate for electricity used to charge battery electric
vehicles and plug in hybrid electric vehicles.
State Statutory References: Not Applicable

Other Link(s):
http://www.afdc.energy.gov/afdc/laws/law/CA/6489" onclick="window.open(this.href);return false; (AFDC Website)

 

[Deleted member 3645]

Hi Guys, I hope I am not bike-shedding here, but whatever happened to electric generation competition? Wasn't the whole deal with Enron in the 90's and California grid rate meltdown with the introduction of competitive generator utilities that you could sign up with, and still pay the standard transmission rates? Are there any competitive generators available in your area besides PG&E, and do they offer better (more green, windmill/hydro/solar) generation options , and better time-of-day rates? I am from Massachusetts, and you can select alternative generators as your service provider who do just that.

regards, Stefan

 

[edatoakrun]

Hi Guys, I hope I am not bike-shedding here, but whatever happened to electric generation competition? Wasn't the whole deal with Enron in the 90's and California grid rate meltdown with the introduction of competitive generator utilities that you could sign up with, and still pay the standard transmission rates? Are there any competitive generators available in your area besides PG&E, and do they offer better (more green, windmill/hydro/solar) generation options , and better time-of-day rates? I am from Massachusetts, and you can select alternative generators as your service provider who do just that.

regards, Stefan

Off topic, but I expect other non-California Resident readers are trying to figure out how why the region with the highest EV sales has some of the worst EV public policies. The short answer is, that after the Enron Debacle, “deregulation”, allowing consumer choice in their electricity supplier, has become a political non-issue in California.

California is served by a number of private and public electricity monopolies, and there is little prospect of change in the immediate future.

IMO, this will be a major obstacle to EV use in California. Not only because PG&E and the other utilities do not have competitive market incentives to serve home charging needs (as this rate proposal indicates) but because the rate and regulatory structure makes it very difficult to develop the public charge infrastructure on a profitable basis.

After the relatively few Taxpayer-funded DC stations are built in The Bay area and Southern California, what happens next?

 

[oakwcj]

I've just learned that Bob Levin from the Division of Ratepayer Advocates of the PUC has been assigned to PG&E's request to change the E-9 rate structure. His email address is [email protected]. I just sent him the following email, in which I took the liberty of inviting him to the BayLeafs meeting on Sunday:


As a Nissan LEAF owner on the E-9A rate, I'm dismayed by PG&E's apparent attempt to sabotage the TOU rate for electric vehicles by effectively eliminating any incentive to charge during off-peak hours and therefore any incentive to remain under the E-9 structure.

I've been on the E-9A rate for four months. For the last two months, my net electricity bills have been $80.10 and $89.52. Under the new proposal, the bills would have been $96.52 and $106.16, including the proposed $8 monthly "customer service charge" which PG&E makes only a half-hearted attempt to justify. I also calculated what my bills would have been under E-1. The results are $98.03 and $110.85. According to a discussion on the main LEAF owners forum, my situation is typical:

http://www.mynissanleaf.com/viewtopic.php?f=24&t=5794" onclick="window.open(this.href);return false;

If the PUC were to approve the new rate structure, we would have all the ingredients for a new documentary: "Who Killed the E-9 Rate?" The culprit would be pretty easy to determine.

In its advice letter to the PUC, PG&E acknowledges that bills would go up substantially for 3/4 of customers on E-9A and for all but one customer on the E-9B rate. Although PG&E undoubtedly has the data, it did not provide a comparison between E-9 bills under the proposed structure and E-1. The reason for this is quite clear. The data would show that the new rate proposal would eliminate incentives for off-peak charging. In fact, PG&E explicitly states that its "proposed changes to Schedule E-9 are designed to be revenue neutral for electric vehicle customers, relative to service under Schedule E-1 and subject to specific usage assumptions about the Schedule E-9 customers’ household and electric vehicle charging loads." Obviously, if the proposal is revenue neutral relative to the E-1 rate, it doesn't contain any incentives for off-peak charging. I could understand a proposal that was cost-neutral to PG&E, because its costs for providing electricity during off-peak periods are lower than during peak periods.

As I understood the PUC's directive to PG&E, it wanted the tiers eliminated for off-peak charging on E-9B and an exploration of removing the tiers for E-9A. A much better solution would be to eliminate the tiers on E-9A only for off-peak periods, while keeping the baseline and tiers for peak and partial-peak periods. The actual proposal combines absurdly high rates and the elimination of tiers for peak and partial-peak periods, with the predictable result of significant increases in electricity bills for most customers.

I know that this is very short notice, but the Bay Area LEAF owners group will be meeting at the Luscious Garage on Sunday at 11:30 and this item will be on the agenda. If you or someone else from DRA could attend, you would be able to hear first-hand from a lot of LEAF owners currently on the E-9A rate.

I hope these comments have been useful to you. I intend to send a similar protest letter to the PUC and PG&E. I'd appreciate any advice you might have about how to proceed.

 

[Nekota]

++1

I've just learned that Bob Levin from the Division of Ratepayer Advocates of the PUC has been assigned to PG&E's request to change the E-9 rate structure. His email address is [email protected]. I just sent him the following email, in which I took the liberty of inviting him to the BayLeafs meeting on Sunday:


As a Nissan LEAF owner on the E-9A rate, I'm dismayed by PG&E's apparent attempt to sabotage the TOU rate for electric vehicles by effectively eliminating any incentive to charge during off-peak hours and therefore any incentive to remain under the E-9 structure.

I've been on the E-9A rate for four months. For the last two months, my net electricity bills have been $80.10 and $89.52. Under the new proposal, the bills would have been $96.52 and $106.16, including the proposed $8 monthly "customer service charge" which PG&E makes only a half-hearted attempt to justify. I also calculated what my bills would have been under E-1. The results are $98.03 and $110.85. According to a discussion on the main LEAF owners forum, my situation is typical:

http://www.mynissanleaf.com/viewtopic.php?f=24&t=5794" onclick="window.open(this.href);return false;

If the PUC were to approve the new rate structure, we would have all the ingredients for a new documentary: "Who Killed the E-9 Rate?" The culprit would be pretty easy to determine.

In its advice letter to the PUC, PG&E acknowledges that bills would go up substantially for 3/4 of customers on E-9A and for all but one customer on the E-9B rate. Although PG&E undoubtedly has the data, it did not provide a comparison between E-9 bills under the proposed structure and E-1. The reason for this is quite clear. The data would show that the new rate proposal would eliminate incentives for off-peak charging. In fact, PG&E explicitly states that its "proposed changes to Schedule E-9 are designed to be revenue neutral for electric vehicle customers, relative to service under Schedule E-1 and subject to specific usage assumptions about the Schedule E-9 customers’ household and electric vehicle charging loads." Obviously, if the proposal is revenue neutral relative to the E-1 rate, it doesn't contain any incentives for off-peak charging. I could understand a proposal that was cost-neutral to PG&E, because its costs for providing electricity during off-peak periods are lower than during peak periods.

As I understood the PUC's directive to PG&E, it wanted the tiers eliminated for off-peak charging on E-9B and an exploration of removing the tiers for E-9A. A much better solution would be to eliminate the tiers on E-9A only for off-peak periods, while keeping the baseline and tiers for peak and partial-peak periods. The actual proposal combines absurdly high rates and the elimination of tiers for peak and partial-peak periods, with the predictable result of significant increases in electricity bills for most customers.

I know that this is very short notice, but the Bay Area LEAF owners group will be meeting at the Luscious Garage on Sunday at 11:30 and this item will be on the agenda. If you or someone else from DRA could attend, you would be able to hear first-hand from a lot of LEAF owners currently on the E-9A rate.

I hope these comments have been useful to you. I intend to send a similar protest letter to the PUC and PG&E. I'd appreciate any advice you might have about how to proceed.

 

[edatoakrun]

I had a long conversation with a PG&E EV program rep yesterday. No guarantee the following is accurate, but the relevant info:

All E9 ratepayers should receive written notification. Anyone received this yet?

CPUC approval of the rate change (if it happens) will probably take many months after the 11/1/11 date, and PG&E will take additional time to institute the changes. All E9 customers will be able to change to other rates, E1 or E6, before the new rate starts, with no one year minimum.

I urge all PG&E customers, and EV advocates, even those who are not personally affected, to consider how this rate proposal, will damage the EV market, and energy efficiency in general, and comment on this proposal.

By pricing a large proportion of EV owners out of the PG&E TOU energy market, before the cars are even available in large numbers, The CPUC would be undermining its own stated goals.

...The challenge of single meter Electric Vehicle rate design, as summarized by SCE, is to structure a simpler, cost-based, time-of-use rate that avoids the disincentives for Electric Vehicle use associated with tiered rates but still recovers, at a minimum, the incremental cost to serve Electric Vehicles....

http://docs.cpuc.ca.gov/published/Final_decision/139969-04.htm#P152_24975" onclick="window.open(this.href);return false;

This rate proposal disincentives both EV use, and off peak charging. The incremental kWh charge for EV usage, by switching from E1 to the "new and improved" E9, for a PG&E ratepayer with my level of home and EV annual electricity usage, would be about 23 cents per kWh, for 100% off peak charging!

Alternately, PG&E will sell the same ratepayer the same amount of electricity at E1 rates, even if they charge 100% on peak, for 12.3 cents per kWh.

I cannot comprehend how PG&E could have produced a rate proposal embodying stupidity on such a fundamental level.

 

[oakwcj]

I did get a response from Bob Levin of DRA [Division of Ratepayer Advocates]. Unsurprisingly, he will not be able to attend the BayLeafs meeting. He also stated that: "I would encourage you, and others on the LEAF owners forum, to protest.
It is quite likely that DRA will protest as well." This is significant, because DRA is an independent body inside the PUC, which can appear as a party in all PUC proceedings.

 

[hill]

Wow...the proposed change in rates really is utter crap. Unless, you are a consumer that regularly hits Tier 4 and 5 of your electricity rate, this proposed change will effectively cost you much more. Those who conserve on electricity usage are extremely short-changed by this proposal.

How well does the CPUC respond to letters challenging these proposals? I'm definitely sending one in today.

From personal experience filing a protest to CA's PUC I can tell you that you won't get much. If it's any consolation, the PUC DOES know how to placate utility customers pretty well. And if it's any consolation to SD utility folks, Edison's TOU system is a nightmare due to meters that NO one knows how to read ... except apparently the meter reader. What they do with that data sometimes works ... other times not so. With a meter that can have literally hundreds of programs - coupled with seasonal adjustments, and or time adjustments - and or solar/no solar added into the mix, we said said 'screw it'. We got our old fashion G.E. mechanical kWh meter back. Until the utility can tell us exactly what is / isn't being metered, they are NOT going to get to (negatively, to the tune of almost 200kWh's over 3 months) screw up any more of our solar surplus.

Right now the only thing that the utilities are working hard at is fighting tooth and nail with the PUC, to pay the smallest amount for PV surpluses. I can't WAIT to see how complex they make THOSE formulas. I better go buy another calculus/trigonometric function calculator to cross check the screw ups they'll work to their advantage with THOSE formulas. The utility companies ought to be working on getting the grid in decent shape, but that's just not happening.

I have seen consumer interest articles in the newspaper that get the utility's attention. The utility doesn't like having their pants down around their ankles in the media. Around individual customers though ... it doesn't seem to be a big deal. But if your complaint can make the business section of a big paper, well, that WILL actually get results. Other wise - good luck.
.

 

[matth]

Here's a letter that I've drafted to the PUC. Feel free to copy parts of it, but be sure to include your own experience and views. It's too late now for me to make if final, so if anyone has suggestions or catches any typos, please let me know so I can fix it!

CPUC Energy Division
Tariff Files, Room 4005
DMS Branch
505 Van Ness Avenue
San Francisco, California 94102

VIA ELECTRONIC MAIL AND USPS

re: Advice 3910-E
(Pacific Gas and Electric Company ID U 39 E)
Modifications to Electric Rate Schedule E-9 for Residential
Time-of-Use Service for Low Emission Vehicle Customers

Last week, shortly after receiving delivery of my Nissan Leaf, I switched my rate service from E-1 to E-9A. If the Commission approves PG&E's request as submitted, I will switch back to E-1. I believe the vast majority of those currently on E-9A will do the same.

1. PG&E's request, rather than carrying out the Commission's goals of increasing electric vehicle (EV) penetration, would have exactly the opposite outcome.

PG&E's own analysis (Advice Letter, page 5) shows that rates will increase for at least 75% of the relevant rate base. To the extent that electric rates have an effect on EV market penetration, it is simply inconceivable that increasing the amount that a customer would otherwise pay would increase market penetration. Indeed, there is every reason to expect the opposite result.

2. PG&E's request to eliminate tiered rates violates over thirty years of PUC policy.

California's public utilities have long had rate structures with tiers that provide less expensive electricity for lower usage and more expensive electricity for greater usage. This tiered rate structure has been one important part of the scheme that has made California one of the most energy efficient economies in the United States.

PG&E submitted its Advice Letter to comply with PUC Order D.11-07-029 (“Order”) requiring it to propose non-tiered rates for E-9B customers (Advice Letter, page 2). In the context of the history of tiered rate structures, this makes sense, since there is very little, to nothing, that an EV owner can do to improve the efficiency of an EV.

Moreover, shifting miles traveled from internal combustion engine vehicles to EVs is an important public policy goal. For that reason, with today's mix of vehicles, it's important that EVs drive as high a share all vehicle miles traveled (VMT) as possible. Therefore, encouraging conservation of electricity by reduced EV VMT does not make sense.

The PUC Order also required PG&E to provide a non-tiered option for those on E-9A. This would be a departure from the PUC's past practice, since E-9A also includes base household electricity use. However, PG&E has responded by proposing to make E-9A non-tiered for all. This clearly contravenes the Order, and would remove important conservation incentives for a highly motivated group of customers.

3. PG&E should be ordered to consider other options.
There may, indeed, be a need to modify the E-9 rates. Consideration should be given to a tiering scheme that makes allowance for average PEV use. Certain Electric Vehicle Service Equipment has the capability to communicate its electricity use; PG&E could provide an incentive, such as a higher baseline rate, for customers who agree to allow PG&E access to those data.

The best solution may be increased use of E-9B, as that rate schedule makes a clear distinction between PEV use and household use. However, in order to make that happen, significant barriers need to be removed. PG&E's own data bear that out: its analysis shows that only 35 customers are on E-9B, or less than 10% of the total on E-9. The main reasons, based on my experience and that of others I know, is cost and complexity. It can cost over $2,000 to install a second meter (considering hardware, labor, and permitting costs); this amount is unlikely to be amortized in reduced electric costs in the reasonable future. PG&E should be directed to investigate and implement simple, low cost measures (such as dual meters, and subtractive metering) that would reduce the cost and complexity of E9-B.

4. PG&E has already failed to meet its commitment for communication about the E-9 changes.

PG&E's application states that it “plans to communicate with its current E-9 customers and with customers who have pending E-9 applications to inform them of the revised TOU periods and revised rate design before these changes take effect” (Advice letter, page 5). I requested that I be switched to E-9 on or about September 28, 2011, a week after PG&E made its filing on this matter. I specifically asked if there were any anticipated changes to this rate schedule, and was told that there were none currently. If there exists a “specially trained PEV customer call center operations team” (Advice letter, page 6), that team has no meaning to a PG&E customer making a cold call to request PEV rate information.

5. PG&E's $8/month customer charge will drive more customers to E-1

PG&E states that the $8/month customer charge is based on its marginal customer costs that reflect customer-related costs which do not vary with usage for residential customers (Advice letter, page 3). It's not clear to me why E-9 customers should bear the marginal cost, rather than the average of such costs, nor why such costs are not simply built into rates, as they appear to be for other rates, such as E-1. This is another case of PG&E building disincentives into a rate that the PUC has specifically requested that PG&E design for incentives.


cc:

Brian K. Cherry, PG&E
Mark Toney, TURN

 

[csriram45]

I have been away from forum for a while and just came across this news in the bay leaf email thread. I definitely think this whole thing is just a scam so PGE can make more profit. I am a bit unclear if we are expected to send both electronically and via US Mail or electronically alone is sufficient? I also think we need to send 2 sets of letters correct?

 

[matth]

I am a bit unclear if we are expected to send both electronically and via US Mail or electronically alone is sufficient? I also think we need to send 2 sets of letters correct?

PG&E's notice says email and snail mail to the PUC, email copy to PG&E. I don't see anything about dupes of the snail mail. I don't know how PUC works, but most public agencies (including the one I work for) try to be a little understanding of members of the public who may not be familiar with the minutia of their procedures.

 

[EVDRIVER]

It is my understanding that those with huge $5K electric bills will pay far less and those with normal bills say $50-$200 could be paying double regardless of the plan you are on. This applies to all customers not just solar or EV.

 

[Spies]

Any more news on this rate change? With PG&E wanting the rate to go into effect November 1st that only leaves a little over 3 weeks to go. If the rate does go into effect at the very least PG&E will need to reprogram or change out my meter.

 

[edatoakrun]

Any more news on this rate change? With PG&E wanting the rate to go into effect November 1st that only leaves a little over 3 weeks to go. If the rate does go into effect at the very least PG&E will need to reprogram or change out my meter.

See what I posted on 10/1 RE timing of a rate change. I still haven't recieved written notice. Has anyone else? One more example of PG&E incompetance to mention in our letters.

I had a long conversation with a PG&E EV program rep yesterday. No guarantee the following is accurate, but the relevant info:

All E9 ratepayers should receive written notification. Anyone received this yet?

CPUC approval of the rate change (if it happens) will probably take many months after the 11/1/11 date, and PG&E will take additional time to institute the changes. All E9 customers will be able to change to other rates, E1 or E6, before the new rate starts, with no one year minimum.

I urge all PG&E customers, and EV advocates, even those who are not personally affected, to consider how this rate proposal, will damage the EV market, and energy efficiency in general, and comment on this proposal.

By pricing a large proportion of EV owners out of the PG&E TOU energy market, before the cars are even available in large numbers, The CPUC would be undermining its own stated goals...

 

[edatoakrun]

Planning on mailing the letter below shortly. Comments or suggestions?

CPUC Energy Division
Tariff Files, Room 4005
DMS Branch
505 Van Ness Avenue
San Francisco, California 94102
VIA ELECTRONIC MAIL AND USPS
Re: Advice 3910-E
(Pacific Gas and Electric Company ID U 39 E)
Modifications to Electric Rate Schedule E-9 for Residential
Time-of-Use Service for Low Emission Vehicle Customers

I am an electric vehicle driver protesting this proposal, which would not only double my own annual PG&E E9A electric bill, but would also undermine CPUC efforts, by destroying the incentives now available to many ratepayers, to use EVs and to shift electricity consumption to off-peak hours.

Regarding the rate proposal described in the letter, PG&E has failed to:

Give notice to PG&E ratepayers.

Accurately report the billing effects of this proposal, to both present and future EV owners.

Factually report the damage this rate proposal will do, to both the residential energy conservation and EV introduction efforts, initiated by the CPUC for the benefit of the State of California.

Before any rate increase representing fundamental changes in the residential rate structure is adopted, all PG&E ratepayers should be notified, and appropriate public comment should be allowed. In fact, PG&E has not even notified all current Electric vehicle owners, much less potential EV owners (every driver in the State) of this proposal. Even though I contacted PG&E directly, and was promised written notice regarding this proposal, I have not received any. From the letter referenced above, sent to the PUC but NOT to ratepayers, it appears PG&E is using a request by the CPUC to improve E9B rates, to effectively eliminate the price signals provided by the E9A rate design, for a large class of ratepayers.

I expect my currant E9A bill to double, under this proposal, because I have lowered my home energy use, and shifted much of it, as well as all my EV charging, to off-peak hours. Based on my electricity use since my TOU (“dumb”) meter was installed last month by PG&E, I estimate that my one year E9A electricity bill will be about $366. If this proposal is adopted, my E9 bill, for the same kWh use and TOU, would increase to approximately $744. I would have a great incentive to change to E1, the lowest rate option offered by PG&E, resulting in an annual bill of about $576, for the same TOU.

Of course, once I switched to E1, I would also have the option of Charging my EV during, and shifting my home electricity use to, peak usage hours, with no increase in my PG&E bill.

PG&E did not have the information I used when calculating the bills above, when creating this proposal, because my TOU meter has not yet been read by PG&E. In fact, PG&E has virtually no useful information on current and future EV owner’s TOU, because the very small sample cited in the letter is not representative, of current and future EV owners and ratepayers.
PG&E’s small sample is reflective only of electricity usage by a few hundred EV “early adopters”. It is disingenuous of PG&E to claim those statistics as representative of the much larger number of mass-market EVs, which have been available for less than a year, for which PG&E has not yet collected statistically useful information.

This rate proposal removes rate incentives for both EV use, and off peak charging, not only for me, but for large numbers of potential EV drivers. The incremental kWh charge for EV charging for a PG&E ratepayer, with my home and EV annual electricity usage, switching from E1 to the proposed E9, would be about 23 cents per kWh, for 100% off peak use.

If the CPUC accepts this proposal, it will discourage EV adoption, and the E9 rate option, by pricing the off-peak electricity used to charge EVs far higher than the PG&E marginal cost, as well as the E1 rate, for a large percentage of PG&E customers. How will the CPUC and PG&E make reasonable decisions regarding EV integration into the grid, if these EV owners are priced out of the E9 option, and therefore do not even notify PG&E that they drive an EV?

The current E1 tiered rate system encourages home energy efficiency, and the E9a rate also provides incentive for off-peak use. Any cost based TOU would likely raise rates for low use, low tier PG&E customers. But PG&E's E9 proposal would effectively remove the home conservation incentives of tiered rates only for EV owners, while leaving them for ratepayers driving non-EVs. In doing so, it would greatly harm the current efforts to integrate EVs into the California vehicle fleet, and the CPUC goals of promoting residential energy conservation, and of lowering the economic and environmental costs of electricity generation by decreasing the variation between peak and off peak use.

The CPUC should reject this proposal, and take appropriate action to institute a more rational and workable rate design process, to meet the needs of ratepayers, PG&E, and the Interests of all California residents.

 

[Nekota]

There is one error in the PG&E application in reference to the time of use hours. "Peak: 2:00 p.m. to 9:00 p.m. Monday through Sunday AND 3:00 p.m. to 7 p.m. Saturday, Sunday and holidays." I interpret this to mean Monday through Friday to match the rest of the TOU descriptions.

Second point is the calculated rates are simply the averages of T1, T2 and T3 rates from the E9a schedule which doesn't seem to reflect a study of rates but a 'quick' fix calculation.

Third point, the California ISO has a Demand Response initiative from the FERC where E9 rates compared to E1 fail to provide an incentive to the end user to enable participation in the ISO market.

These are the items I will be adding to the proposed letter. I am also looking for seasonal demand data from CAISO for the winter vs summer demand profiles showing the demand levels for Saturday and Sunday compared to the workweek. Why are the rates on the weekend increased so dramatically and winter rates so high compared to the former E9a winter schedule.

 

[matth]

Good letter. Thanks for doing it.

One suggestion--make your third bolded point #1. I think (though I don't know) that the PUC will care little about the other two.

Planning on mailing the letter below shortly. Comments or suggestions?

CPUC Energy Division
Tariff Files, Room 4005
DMS Branch
505 Van Ness Avenue
San Francisco, California 94102
VIA ELECTRONIC MAIL AND USPS
Re: Advice 3910-E
(Pacific Gas and Electric Company ID U 39 E)
Modifications to Electric Rate Schedule E-9 for Residential
Time-of-Use Service for Low Emission Vehicle Customers

I am an electric vehicle driver protesting this proposal, which would not only double my own annual PG&E E9A electric bill, but would also undermine CPUC efforts, by destroying the incentives now available to many ratepayers, to use EVs and to shift electricity consumption to off-peak hours.

Regarding the rate proposal described in the letter, PG&E has failed to:

Give notice to PG&E ratepayers.

Accurately report the billing effects of this proposal, to both present and future EV owners.

Factually report the damage this rate proposal will do, to both the residential energy conservation and EV introduction efforts, initiated by the CPUC for the benefit of the State of California.

Before any rate increase representing fundamental changes in the residential rate structure is adopted, all PG&E ratepayers should be notified, and appropriate public comment should be allowed. In fact, PG&E has not even notified all current Electric vehicle owners, much less potential EV owners (every driver in the State) of this proposal. Even though I contacted PG&E directly, and was promised written notice regarding this proposal, I have not received any. From the letter referenced above, sent to the PUC but NOT to ratepayers, it appears PG&E is using a request by the CPUC to improve E9B rates, to effectively eliminate the price signals provided by the E9A rate design, for a large class of ratepayers.

I expect my currant E9A bill to double, under this proposal, because I have lowered my home energy use, and shifted much of it, as well as all my EV charging, to off-peak hours. Based on my electricity use since my TOU (“dumb”) meter was installed last month by PG&E, I estimate that my one year E9A electricity bill will be about $366. If this proposal is adopted, my E9 bill, for the same kWh use and TOU, would increase to approximately $744. I would have a great incentive to change to E1, the lowest rate option offered by PG&E, resulting in an annual bill of about $576, for the same TOU.

Of course, once I switched to E1, I would also have the option of Charging my EV during, and shifting my home electricity use to, peak usage hours, with no increase in my PG&E bill.

PG&E did not have the information I used when calculating the bills above, when creating this proposal, because my TOU meter has not yet been read by PG&E. In fact, PG&E has virtually no useful information on current and future EV owner’s TOU, because the very small sample cited in the letter is not representative, of current and future EV owners and ratepayers.
PG&E’s small sample is reflective only of electricity usage by a few hundred EV “early adopters”. It is disingenuous of PG&E to claim those statistics as representative of the much larger number of mass-market EVs, which have been available for less than a year, for which PG&E has not yet collected statistically useful information.

This rate proposal removes rate incentives for both EV use, and off peak charging, not only for me, but for large numbers of potential EV drivers. The incremental kWh charge for EV charging for a PG&E ratepayer, with my home and EV annual electricity usage, switching from E1 to the proposed E9, would be about 23 cents per kWh, for 100% off peak use.

If the CPUC accepts this proposal, it will discourage EV adoption, and the E9 rate option, by pricing the off-peak electricity used to charge EVs far higher than the PG&E marginal cost, as well as the E1 rate, for a large percentage of PG&E customers. How will the CPUC and PG&E make reasonable decisions regarding EV integration into the grid, if these EV owners are priced out of the E9 option, and therefore do not even notify PG&E that they drive an EV?

The current E1 tiered rate system encourages home energy efficiency, and the E9a rate also provides incentive for off-peak use. Any cost based TOU would likely raise rates for low use, low tier PG&E customers. But PG&E's E9 proposal would effectively remove the home conservation incentives of tiered rates only for EV owners, while leaving them for ratepayers driving non-EVs. In doing so, it would greatly harm the current efforts to integrate EVs into the California vehicle fleet, and the CPUC goals of promoting residential energy conservation, and of lowering the economic and environmental costs of electricity generation by decreasing the variation between peak and off peak use.

The CPUC should reject this proposal, and take appropriate action to institute a more rational and workable rate design process, to meet the needs of ratepayers, PG&E, and the Interests of all California residents.

 

[Ready2plugin]

I was one of the first on E9a and I have yet been notified. How did you get the notice, phone, email, snail mail?

 

[edatoakrun]

I was one of the first on E9a and I have yet been notified. How did you get the notice, phone, email, snail mail?

No notice, even after I called PG&E, and was told "its in the mail".

Has ANYONE received notice?