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

[waitingforaleaf]

Eight pages of obfuscation and PG&E still doesn't provide data comparing their proposal to E-1. The response simply speculates that EV owners who aren't on E-9 now might switch once the new rates take effect. The basic tone of the response is that EV owners are a bunch of spoiled, rich, coastal dwellers, and that no matter how high they jack up the rates, they will still be cheaper than gasoline.

Just looked over PG&E's reply to our protests and came to the same overall conclusion.

Apparently, PG&E considers 10 kwh to be equivalent to a gallon of gasoline ("4 cents per kWh, which provide the ability to charge at the equivalent of about 40 cents per gallon of gasoline"). Last I checked, the Leaf was supposed to be a 99 mpge car not a 45 mpge one (currently I average 4.5 mi/kwh). In any case, I certainly didn't appreciate the consistent use of that "miscalculation" as their standard for comparing charging costs to the cost of gasoline.

I also noticed that they continually argue that the off-peak charging rate is far below cost, but they never address the corresponding price increases that impact partial-peak and peak electricity rates. This is further exacerbated by their justification of peak rates throughout the year because of all the coastal customers they have that are purchasing electric vehicles.

In any case, I've run the math for my numbers comparing prices on E-9A (current), E-9A (proposed), and E-1 for the past two SUMMER months and averaged them:
E-9A (current) = $41
E-9A (proposed) = $77
E-1 = $49

Simulating this usage with the rate estimator, E-6 looks to be around $52.

If the proposed E-9A rate gets passed, you'll know which rate I'll be switching to... (as I'm sure PG&E has already assumed)

What's the latest update here wrt the rate hike? Did our protest emails got anywhere? Did the CPUC vote on a decision?

I haven't received any email nor mail from PGE yet.

Thanks.

The Advice Letter was suspended on October 7, 2011 based upon the need for staff review by the CPUC. The suspension end date is February 12, 2012, and the projected date of disposition date is June 2, 2012. So it's a matter of wait and see I suppose, unless anyone knows if you can actually reply to this "reply to protests."

 

[csriram45]

So how do we protest against the response that it does not meet the needs? There has got to be a way.

 

[mxp]

So how do we protest against the response that it does not meet the needs? There has got to be a way.

I am interested to fund a class action to prevent this from going any further. Clearly, PG&E is ignoring public opinion and is more interested in finding ways to get what they propose to implement.

We need proper due course to combat this or else, we're just raising our excellent arguments with no real ability to influence the CPUC or raise awareness with other government entities who could help us.

If somebody can help point in the right direction? I'll make the phone calls.

 

[mxp]

For those of you who are willing to email Brian K. Cherry directly to continue the protest, you could try this email address:

Brian K. Cherry ([email protected])

It worked for me, and it did not bounce back.

 

[oakwcj]

So how do we protest against the response that it does not meet the needs? There has got to be a way.

I am interested to fund a class action to prevent this from going any further. Clearly, PG&E is ignoring public opinion and is more interested in finding ways to get what they propose to implement.

We need proper due course to combat this or else, we're just raising our excellent arguments with no real ability to influence the CPUC or raise awareness with other government entities who could help us.

If somebody can help point in the right direction? I'll make the phone calls.

I know it's a fairly long thread, but it's not THAT lengthy, and this has already been discussed. I will try to find out if there is a procedural way to respond to PG&E's reply, but sending an email to Brian Cherry is not it. Any response would be filed with the CPUC Energy Division and served [copied] on PG&E.

 

[Spies]

Is PG&E's reply available online?

 

[edatoakrun]

I know it's a fairly long thread, but it's not THAT lengthy, and this has already been discussed. I will try to find out if there is a procedural way to respond to PG&E's reply, but sending an email to Brian Cherry is not it. Any response would be filed with the CPUC Energy Division and served [copied] on PG&E.

Please follow up with suggestions for further PUC contact.

As I read it, the PG&E response both ignored some of the points of my protest letter (page 6 of this thread) and also often misrepresented the facts of their proposal, as in implying that E6 rates would be lower than E1 for all EV owners, giving us an alternative TOU choice.

 

[waitingforaleaf]

Is PG&E's reply available online?

I just posted it on Filefactory. Just scroll down and click on the "Slow download"

edit: Filefactory link removed in favor of Nekota's link on google docs (https://docs.google.com/open?id=10HsBj37s7xL6VsRc9wQoUNYdTLxeKJs2mZwUuEspA6XQAyVs5IRJnkIURpOO)

 

[oakwcj]

I know it's a fairly long thread, but it's not THAT lengthy, and this has already been discussed. I will try to find out if there is a procedural way to respond to PG&E's reply, but sending an email to Brian Cherry is not it. Any response would be filed with the CPUC Energy Division and served [copied] on PG&E.

Please follow up with suggestions for further PUC contact.

As I read it, the PG&E response both ignored some of the points of my protest letter (page 6 of this thread) and also often misrepresented the facts of their proposal, as in implying that E6 rates would be lower than E1 for all EV owners, giving us an alternative TOU choice.

The procedures for Advice Letters are found in CPUC General Order 96-B. Unfortunately, section 7.4.3 provides:

7.4.3 Replies

The utility filing an advice letter shall reply to each protest and may reply to any response. Any such reply shall be filed with the reviewing Industry Division within five business days after the end of the protest period, and shall be served on the same day on each person who filed a protest or response to the advice letter. The protestant may not reply to the utility's reply.

The Commission's rules quite explicitly preclude replies to replies. I've still asked a DRA consultant whether such unauthorized replies would be considered or simply trashed. Here is a link to General Order 96-B:

http://docs.cpuc.ca.gov/published/REPORT/91328.htm#P151_8401

As I've said before, while I have no inside information, the Jerry Brown CPUC is an entirely different -- and better -- animal than the Arnold CPUC. I think the Commission will understand how laughable the PG&E response is. Nobody could believe that the E-6 rate makes sense for EV owners who don't have solar power. And it's entirely irrelevant that it will still be less expensive to power an EV than an ICE under the proposed rates. The real issue is whether the proposed rates would provide any meaningful incentive for charging during off-peak periods. PG&E dances around this question, and fails to provide any supporting data, because it knows that the answer is "no" in almost all cases.

Ordinarily, the Advice Letter process is handled at the Energy Division level, and never makes it to the Commission itself. In this case, because the proposal is so radical, and there has been so much opposition, it will probably be converted into a matter that is handled by a CPUC resolution, which means that it will be placed on the Commission's calendar and voted on in an open meeting. General Order 96-B also provides for a process for rehearing, which could potentially lead to a judicial proceeding before an ALJ and, at least theoretically, an appeal of an ultimate CPUC decision to the Court of Appeal. But that is way in the future. The main point is that we still have some bullets, even if we can't submit replies now. And it's quite possible that the CPUC staff will see this issue more from our perspective than PG&E's, because it has a strong policy encouraging the adoption of EVs and of using TOU rates.

 

[waitingforaleaf]

Mmm...quite unfortunate that we can't really reply back as there are a few counter-arguments brought up by PG&E that are inadequate or contain misrepresentation.

1. For people who use less electricity, E-1 will become the cheapest electric rate available (cheaper than E-6 and proposed E-9A)
2. 10 kwh is not equal to a gallon of gasoline (based on EPA fuel economy rating of 99 mpge and 34 kwh/100 miles, it would be 33.66 kwh)
3. Lack of justification (i.e. calculation) indicating that there is a true reason for an all-year round peak schedule, other than blaming it on a higher proportion of coastal customers.
4. Their comparison to rates provided by SDG&E and SCE focus only on the off-peak rate with no mention of the partial-peak and peak rates for which PG&E is significantly more expensive
5. Lack of an estimator provided by PG&E to compare the proposed E-9 rate with E-1 or E-6 (though I don't really need it as I'm already using my own estimator)

There are likely more points than these, but those stood out to me after a single reading of their response.

 

[DaveEV]

Apparently, PG&E considers 10 kwh to be equivalent to a gallon of gasoline ("4 cents per kWh, which provide the ability to charge at the equivalent of about 40 cents per gallon of gasoline"). Last I checked, the Leaf was supposed to be a 99 mpge car not a 45 mpge one (currently I average 4.5 mi/kwh). In any case, I certainly didn't appreciate the consistent use of that "miscalculation" as their standard for comparing charging costs to the cost of gasoline.

Best way to compare costs is fuel costs per mile. Using a Prius since that's the most likely alternative for LEAF owners, but this works out in our favor since we are comparing costs to the most efficient gas car in the market. My LEAF efficiency number is probably pretty generous - I'd expect the average driver to get closer to 3 mi / kWh especially if they do any freeway driving.

Prius at 50 mpg and $4/gallon gas is about 8c / mile.
LEAF at 3.75 mi/kWh and $0.30/kWh is about 8c / mile.

You can sure bet that if the utility raises rates to $0.08 / mile or $0.30 / kWh, interest in EVs will instantly drop off due to additional cost of an EV.

None of this takes into account that currently EVs do not pay any road tax - gasoline in CA is taxed $0.35 / gallon - plus the $0.18 / gallon for federal taxes - a total of $0.53 / gallon.

For a Prius, the road tax comes out to $0.01 / mile - it won't be long before the govt wants EV drivers to pay that lost revenue. For a LEAF, this would similar to a $0.04 / kWh tax on electricity.

Also note that comparing to a Prius

 

[waitingforaleaf]

Prius at 50 mpg and $4/gallon gas is about 8c / mile.
LEAF at 3.75 mi/kWh and $0.30/kWh is about 8c / mile.

You can sure bet that if the utility raises rates to $0.08 / mile or $0.30 / kWh, interest in EVs will instantly drop off due to additional cost of an EV.

This is the type of argument that PG&E will favor, because obviously at $0.11041 / kWH for off-peak charging during the summer ($0.11305 during the winter), it is cheaper to drive the Leaf than a Prius. However, the price to charge the Leaf during off-peak hours is not the only affected price by their proposed changes to E-9A. Their proposed price for partial-peak hours is $0.21431 for summer ($0.17365 for winter) and peak hours is $0.38451 for summer ($0.27932 for winter). While these prices may be palatable if comparing it solely to gasoline prices, they are significantly high for residential (domestic) electricity usage when compared to rates for E-1 users who can stay mostly within the first three tiers.

E-1 rates are currently $0.12233 for baseline, $0.13907 for tier 2 (101-130% of baseline), $0.30180 for tier 3 (130%-200% of baseline), $0.34180 for tier 4 and 5. Because of the price lock on the first two tiers, there is obviously an incentive for people to conserve and use less electricity. The same would be true under the current E-9A prices where the first two tiers are significantly cheaper. Removal of the tiered structure of E-9 simply raises prices for 3 out of 4 current E-9 customers. My guess would be that the lowest electricity consuming quartile of E-9 customers will see cheaper rates under E-1 than the proposed E-9A rate or E-6. Without hard numbers to support it, it is merely speculation but I'd be surprised if I'm very wrong as PG&E suggested that the lowest tier would see an approximately 80% increase in price when comparing E-9A current with E-9A proposed (a value I've largely verified for my electricity usage). The next two quartiles would need to run their numbers carefully, but nonetheless, they will see a price increase under E-9A (whether that increase is enough to switch over to another rate schedule should be calculated out).

Ultimately, the proposed change to E-9 really presents NO INCENTIVE for electric vehicle charging during off-peak hours that current E-9 customers do not already see. Rather, it presents itself as a price increase for 75% of E-9 customers and creates an incentive for the lowest electricity users to switch back to the more convenient non-TOU E-1 rate.

 

[oakwcj]

You might be interested in reading the July CPUC decision that ordered PG&E to eliminate tiers in the E-9B rate. In particular, you should scroll down and read Commissioner Florio's concurrence, in which he cites the importance of EVs in combating greenhouse gases. Mr. Florio was an attorney for the consumer group TURN before being appointed to the Commission by Governor Brown. I think you'll like his comments, particularly "My goal is that this Commission will be featured in a new documentary: "Who Saved the Electric Car?""

http://docs.cpuc.ca.gov/published/Final_decision/139969-13.htm

 

[oakwcj]

Here's the response I got from one of the analysts who filed a protest on behalf of the CPUC Division of Ratepayer Advocates:

"I cannot speak for the Energy Division, but I think it is likely that
they would consider responses from the public, especially from
individuals who have protested PG&E's advice letter.

In your letter, you should mention that you have sent a timely protest
and request the opportunity to respond to PG&E's reply. I suggest
addressing your letter to Edward Randolph (Director of the CPUC's Energy
Division) and Paul Phillips (Supervisor in charge of retail rate
design)."

If you're motivated to respond again to PG&E, it may be worth a shot. You should also copy Brian Cherry from PG&E.

 

[BlueSL]

10 kwh is not equal to a gallon of gasoline (based on EPA fuel economy rating of 99 mpge and 34 kwh/100 miles, it would be 33.66 kwh)

My Nissan Altima Hybrid -- a highly efficient car in the scheme of things when compared to the universe of cars for sale in the US -- averaged 34 mpg. I am getting 4 m/kWh average with my hilly highway-focused commute. That would translate to under 8.5kWh to the gallon.

The gallon of gas used to cost me $4.00. The 8.5kWhs costs me $2.89 (because I am all Tier 4 for car charging on E-1), which works out to 8.5 cents per mile. That is almost triple what Nissan claimed -- the infamous $.03 per mile. Surely, PG&E can get a little closer to Nissan's number!

Responding to another post, it is naive to call the Prius the gasoline pennies per mile benchmark just because many early adopters of the Leaf are likely moving on from a Prius. It's not about the small sliver of the population that is buying these cars now. It's about when your neighbor who drives a Malibu gets one. Their current price per mile for the Malibu owner is probably double that of a Prius.

 

[Nekota]

Is PG&E's reply available online?

https://docs.google.com/open?id=10HsBj37s7xL6VsRc9wQoUNYdTLxeKJs2mZwUuEspA6XQAyVs5IRJnkIURpOO" onclick="window.open(this.href);return false;

 

[hpage]

I read the the advice letter, many of the protests, and PG&E's response (recently posted, dated 11/14/2011). All that I can say is this:

Electrical rate should reflect cost of producing electricity.

1) Rate "tiers", ones not associated with actual cost, means someone is subsiding someone else. This is wrong.
2) Differing baselines for different geographical areas means someone is subsiding someone else. This is wrong.
3) Different rates for normal and "Code H - All-Electric Quantities" ("All-electric quantities are applicable to service to customers with permanently installed electric heating as the primary heat source.") means someone is subsiding someone else. This is wrong.

and (duck!)...

It's wrong if other ratepayers are subsidizing E-9 subscribers...

I am already getting several handouts -- from the feds (Blink, income tax credit) and CA (CVRP rebate, no payment of road taxes). No need of one from PG&E (if so).

That's it!

Howard

 

[davewill]

I read the the advice letter, many of the protests, and PG&E's response (recently posted, dated 11/14/2011). All that I can say is this:

Electrical rate should reflect cost of producing electricity.

1) Rate "tiers", ones not associated with actual cost, means someone is subsiding someone else. This is wrong.
...

Of course the rate tiers don't reflect cost. If that were the case, the rates would go down as usage went up. However, as we should all know, the "costs" that the utility pays are not the true costs to society and the environment. Therefore, it's been decided as a matter of public policy that residential users that use a lot of electricity should be penalized by paying more...the goal being to encourage conservation. I have to agree most heartily.

 

[astrorob]

According to PG&E, there are 324 people on E-9A and 35 on E-9B.

That tells you how pathetic a job the current rate structure is doing in getting people to switch to those rates. The people buying these cars now are on the bleeding edge. They actually understand all this stuff, and that is the best PG&E can do in terms of attracting new customers?

Well, of course, as a monopoly they never attract new customers; they already have (nearly) 100% of the customers in their service area. But on your "bleeding edge" and "understand" point, my (probably biased) opinion is that all LEAF owners who understand PUC-mandated rates in California should be working toward getting solar panels if that is feasible for their homes. Of course it isn't feasible in many situations, but where it is I am now convinced that PG&E's E6 rate will save money over E9 in a majority of cases. So, as oakwcj also suggested in response to your post, solar panels become an important factor in low acceptance of E9.

Ray

my personal situation is that due to the construction of my roof, solar would be a huge hassle and cost extra compared to a 'regular' installation.

i installed a ted5000 and simulated being on E9A during august, 2011, and found that my electric bills would be through the roof without significant behavior modification. with a family of 4 people it's just unrealistic to restrict all heavy usage to the off-peak hours.

in the end i'm still on E-1 and with the leaf, during the summer i was averaging about 27c/kwh which is in the neighborhood of 9c/mi. now that the winter has hit i'm sure my average cost is headed up.

i have not simulated E9B with a separate meter. the ~$2k upfront cost of installing a 2nd meter has kind of stopped me from thinking about it. but a rough calculation says that it would take about 5 years to pay for the 2nd meter, given that i'm using about 150kwh/month on the leaf.

anyway, just one data point. i do agree that if solar was feasible for me i'd probably already be on E6.

 

[DeaneG]

...i have not simulated E9B with a separate meter. the ~$2k upfront cost of installing a 2nd meter has kind of stopped me from thinking about it. but a rough calculation says that it would take about 5 years to pay for the 2nd meter...

And there is no guarantee that the E9B rate will be available through the five years it would take to pay off the second meter.