The CPUC and California DC fast chargers

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edatoakrun

Well-known member
Joined
Nov 11, 2010
Messages
5,222
Location
Shasta County, North California
Could we use a thread to discuss the implications of CPUC utility rate design and it's hindrance of DC public charging?

It looks like California electric utilities have a history (see below) of arguing for even higher charges for EV fast-charge locations.

IMO, it pretty much confirms that California power companies are run by idiots, who do not understand that the best interests of their shareholders will be served by encouraging more off-peak energy use (BEV night charging) by making occasional on the road DC charging available, to potential BEV buyers.

It seems that this CPUC policy will result in delays in private businesses establishing charge locations by (bizarrely) linking the cost per kWh to the total kWH demand of the metered entity. This will mean very high marginal kWh costs to many of the very businesses which are otherwise ideally situated to install DC chargers, roadside convenience stores, fast–food outlets, and even gas stations, that currently pay relatively low demand charges.

5.3. Rate for Non-Residential "Quick Charging"
...SCE and PG&E stated that quick charging facilities should be eligible for existing non-residential rate schedules. NRDC stated that such facilities will place a greater stress on the electrical grid and emphasized the importance of assuring that terms of service be imposed to prevent price signals from being masked. (NRDC September 24, 2010 comments at 17.) SDG&E stated that differing rates should apply to facilities, such as quick charge facilities, that place a higher kilowatt demand on the system and, specifically, that quick charging facilities should incorporate monthly fixed charges and both on-peak and non-coincident demand charges that appropriately reflect kilowatt demand. (SDG&E September 24, 2010 comments at 10.)

At this time, we do not see a reason to treat non-residential electric vehicle charging differently from other types of non-residential electricity usage. We find that, at this early market stage, any additional costs placed on the system are adequately reflected in existing rates applicable to non-residential customers. Therefore, no need exists to develop rates specifically for customers with quick charge facilities. Notably the tariffs now available in the commercial and industrial context are characterized by a number of design features and eligibility requirements that serve to ensure that electric vehicle service providers bear the costs appropriate to their impacts on the electric system. These include all or some combination of time-of-use rates, demand charges, and/or eligibility criteria that limit the capacity under a given tariff to a pre-defined maximum....

http://docs.cpuc.ca.gov/PUBLISHED/AGENDA_DECISION/138526.htm" onclick="window.open(this.href);return false;
 
Boo, hiss. So this time around it will be the electric companies that kill the electric car? How ironic... :lol:

Seriously though, it's beginning to sound like using a 30+kW natural gas generator onsite to power the quick charger would be a better option since it would be a one time fixed cost. Or is there a demand charge on natural gas too?

https://www.google.com/#hl=en&tbm=shop&q=30kw+natural+gas+generator" onclick="window.open(this.href);return false;
 
GeekEV said:
Boo, hiss. So this time around it will be the electric companies that kill the electric car? How ironic... :lol:

Seriously though, it's beginning to sound like using a 30+kW natural gas generator onsite to power the quick charger would be a better option since it would be a one time fixed cost. Or is there a demand charge on natural gas too?

https://www.google.com/#hl=en&tbm=shop&q=30kw+natural+gas+generator" onclick="window.open(this.href);return false;
From what Tony has been posting, a generator based QC would have to be mobile, and couldn't stay in one location indefinitely.
 
How many feet would it be required to move?

Or, Generator A -> B -> C -> A ?

Is it just the Generator that needs to move, or the power source,
or both that need to move?
 
davewill said:
GeekEV said:
Boo, hiss. So this time around it will be the electric companies that kill the electric car? How ironic... :lol:

Seriously though, it's beginning to sound like using a 30+kW natural gas generator onsite to power the quick charger would be a better option since it would be a one time fixed cost. Or is there a demand charge on natural gas too?

https://www.google.com/#hl=en&tbm=shop&q=30kw+natural+gas+generator" onclick="window.open(this.href);return false;
From what Tony has been posting, a generator based QC would have to be mobile, and couldn't stay in one location indefinitely.


Easy- http://www.mynissanleaf.com/viewtopic.php?f=37&t=7104" onclick="window.open(this.href);return false;
 
I don't see what the big deal is here. They clearly stated that quick charge stations appear to be billed appropriately under existing non-residential rate structures. You highlighted the wrong portions of the quote. Here is the important section:

At this time, we do not see a reason to treat non-residential electric vehicle charging differently from other types of non-residential electricity usage. We find that, at this early market stage, any additional costs placed on the system are adequately reflected in existing rates applicable to non-residential customers. Therefore, no need exists to develop rates specifically for customers with quick charge facilities.
 
But they're NOT billed appropriately. Until EV adoption gets to the point where the chargers would be in constant use the spikes in usage they generate could trigger demand charges that would easily swamp any benefit to the business installing. For small businesses anyway - larger ones probably ready pull enough electricity that these spikes would average out over time and not trigger the charges. That pretty much kills QC anywhere except at "the big boys" for now. And without enough QC being available, the popularity of EVs will likely be limited. It's not hard to see that the current pricing structure could have serious negative impact on EV adoption here in CA - the very state that has pushed them so hard. Left hand, meet the right hand. Talk to each other!
 
GeekEV said:
But they're NOT billed appropriately. Until EV adoption gets to the point where the chargers would be in constant use the spikes in usage they generate could trigger demand charges that would easily swamp any benefit to the business installing. For small businesses anyway - larger ones probably ready pull enough electricity that these spikes would average out over time and not trigger the charges. That pretty much kills QC anywhere except at "the big boys" for now. And without enough QC being available, the popularity of EVs will likely be limited. It's not hard to see that the current pricing structure could have serious negative impact on EV adoption here in CA - the very state that has pushed them so hard. Left hand, meet the right hand. Talk to each other!

Correct. It will be particularly difficult to to profitably install DC chargers where they are needed most, in areas outside of urban population centers, where both those businesses with large electricity demand, and BEVs, are low density.

What I don't understand, is that I would think that the CPUC should have foreseen the roadblock to DC charging that they were putting up.

Were there no BEV advocates, involved in the process?

What can be done now, to correct this error?
 
edatoakrun said:
GeekEV said:
But they're NOT billed appropriately. Until EV adoption gets to the point where the chargers would be in constant use the spikes in usage they generate could trigger demand charges that would easily swamp any benefit to the business installing. For small businesses anyway - larger ones probably ready pull enough electricity that these spikes would average out over time and not trigger the charges. That pretty much kills QC anywhere except at "the big boys" for now. And without enough QC being available, the popularity of EVs will likely be limited. It's not hard to see that the current pricing structure could have serious negative impact on EV adoption here in CA - the very state that has pushed them so hard. Left hand, meet the right hand. Talk to each other!

Correct. It will be particularly difficult to to profitably install DC chargers where they are needed most, in areas outside of urban population centers, where both those businesses with large electricity demand, and BEVs, are low density.

What I don't understand, is that I would think that the CPUC should have foreseen the roadblock to DC charging that they were putting up.

Were there no BEV advocates, involved in the process?

What can be done now, to correct this error?

There appears to be an opening for renewed advocacy on this issue, because the rulemaking in this case [09-08-009] remains open. You would need someone with standing to request a change in the rate structure, probably a customer wishing to install a QC station, together with a company like Ecotality or Coulomb, wanting to sell the equipment.

For a customer armed with the necessary data, it shouldn't be that difficult an argument to make, given the Legislature's mandate to encourage the development of EV infrastructure.

Here's the text of Public Utilities Code section 740.2:

740.2. The commission, in consultation with the Energy Commission,
State Air Resources Board, electrical corporations, and the motor
vehicle industry, shall evaluate policies to develop infrastructure
sufficient to overcome any barriers to the widespread deployment and
use of plug-in hybrid and electric vehicles. By July 1, 2011, the
commission shall adopt rules to address all of the following:
(a) The impacts upon electrical infrastructure, including
infrastructure upgrades necessary for widespread use of plug-in
hybrid and electric vehicles and the role and development of public
charging infrastructure.
(b) The impact of plug-in hybrid and electric vehicles on grid
stability and the integration of renewable energy resources.
(c) The technological advances that are needed to ensure the
widespread use of plug-in hybrid and electric vehicles and what role
the state should take to support the development of this technology.
(d) The existing code and permit requirements that will impact the
widespread use of plug-in hybrid and electric vehicles and any
recommended changes to existing legal impediments to the widespread
use of plug-in hybrid and electric vehicles.
(e) The role the state should take to ensure that technologies
employed in plug-in hybrid and electric vehicles work in a harmonious
manner and across service territories.
(f) The impact of widespread use of plug-in hybrid and electric
vehicles on achieving the state's goals pursuant to the California
Global Warming Solutions Act of 2006 and renewables portfolio
standard program and what steps should be taken to address possibly
shifting emissions reductions responsibilities from the
transportation sector to the electrical industry.
 
oakwcj...There appears to be an opening for renewed advocacy on this issue, because the rulemaking in this case [09-08-009] remains open. You would need someone with standing to request a change in the rate structure, probably a customer wishing to install a QC station, together with a company like Ecotality or Coulomb, wanting to sell the equipment.

For a customer armed with the necessary data, it shouldn't be that difficult an argument to make, given the Legislature's mandate to encourage the development of EV infrastructure....

Thanks again oakwcj, for the relevant CUP rules, laws, and procedures.

So, have none of the California DC projects, vendors, or business with charger locations, pursued this option yet?
 
GeekEV said:
Seriously though, it's beginning to sound like using a 30+kW natural gas generator onsite to power the quick charger would be a better option since it would be a one time fixed cost. Or is there a demand charge on natural gas too?

No fees that I'm aware of for NatGas. A typical 60KVA genset is just not going to work in California. Short term, under 60 days, sure. The "work arounds" that folks suggest are all tempting fate with a very high price for losing.


Capstone Turbine Corporation, 21211 Nordhoff Street, Chatsworth, CA 91311 U.S.A.

Question: How does the Capstone MicroTurbine aid in controlling energy costs?
Answer: The Capstone MicroTurbine allows a business to generate its own electricity onsite, supplementing the electric grid. During peak usage hours, this effectively reduces or eliminates grid-connected power consumption and demand charges from the local utility.


Our CARB unit achieves levels < 4ppm NOx. <<<<----ya, that one!! (CARB=California Air Resources Board)

The ideal application for the Capstone system is in facilities wired for three-phase power with peak electric loads operating between 25 and 750 kilowatts.

Designed to run for extended periods of time with minimal maintenance. An air filter change is recommended after the first 8,000 hours of operation, with routine maintenance typically following every 8,000 hours. Factory engine servicing is recommended after 40,000 hours of intermittent or continuous use.

Stand alone or black startup time takes approximately 120 seconds.

Can be configured to run on the following fuels: Low Pressure Natural Gas, High Pressure Natural Gas, Compressed Natural Gas, Diesel, Gaseous Propane, Kerosene, "Sour" Gas, Landfill Gas, and Digester Gas.

Produce both alternating current (AC) and direct current (DC) power. The AC output is 480V.

Presently manufactures a 30kw, 60kW, etc

Capstone offers microturbines for purchase, lease or rent.
 
The point is exactly that there is no commercial sense to installing a fast charger in a remote area - this is one of the prime reasons for my proposal to install them inside Camp Pendleton next to the State Park on this thread:
http://www.mynissanleaf.com/viewtopic.php?f=27&t=7213#p158325" onclick="window.open(this.href);return false;
 
edatoakrun said:
oakwcj...There appears to be an opening for renewed advocacy on this issue, because the rulemaking in this case [09-08-009] remains open. You would need someone with standing to request a change in the rate structure, probably a customer wishing to install a QC station, together with a company like Ecotality or Coulomb, wanting to sell the equipment.

For a customer armed with the necessary data, it shouldn't be that difficult an argument to make, given the Legislature's mandate to encourage the development of EV infrastructure....

I have no idea, but I tend to doubt it, since there have only been UL certified QC stations for a month or two. Oregon is so far ahead of California on this issue. They've gotten a $20 million grant from DOE to install QC stations and have a statewide plan for locating them in places that make sense. Ecotality is contractually obligated to install a significant number of QC stations in California, but we know how quickly they do things.
Thanks again oakwcj, for the relevant CUP rules, laws, and procedures.

So, have none of the California DC projects, vendors, or business with charger locations, pursued this option yet?
 
edatoakrun said:
IMO, it pretty much confirms that California power companies are run by idiots, who do not understand that the best interests of their shareholders will be served by encouraging more off-peak energy use (BEV night charging) by making occasional on the road DC charging available, to potential BEV buyers.
It's why California is in last place behind even - gasp - Texas - in QC deployment. Without a robust public charging infrastructure, including QC, I don't think numbers of EV's on the road will grow much beyond current levels. With widespread QC, Nissan will need the Smyrna plant's output to keep up with demand, and other car makers may decide to produce EV's in volume instead of currently planned "field trial" quantities. The key is that by having the possibility of peak QC, people will be willing to drive an EV even though almost all their charging will be done in super off-peak.

So we have a CPUC rule (demand charges) intended to level peak demand. It does prevent a hundred EV's from exerting a 50 MW peak load (bad), but by so doing prevents a hundred thousand EV's from exerting a 4000 MW off-peak load (good). And of course while CPUC waits on real world data before making any decision to change the rule, they prevent installation of QC stations thus insuring that there will be no real world data.

Thanks for the reference to the relevant CPUC ruling. I'm encouraged to see the date (August 2009). Since then three Gov. Brown appointees have joined two Gov. Schwarzenegger appointees. It seems likely that the new commissioners may be willing to reconsider. I think it would take an organization with the stature of Plugin America, AAA, or the Sierra Club to get the attention of the CPUC however.
 
walterbays said:
edatoakrun said:
IMO, it pretty much confirms that California power companies are run by idiots, who do not understand that the best interests of their shareholders will be served by encouraging more off-peak energy use (BEV night charging) by making occasional on the road DC charging available, to potential BEV buyers.
It's why California is in last place behind even - gasp - Texas - in QC deployment. Without a robust public charging infrastructure, including QC, I don't think numbers of EV's on the road will grow much beyond current levels. With widespread QC, Nissan will need the Smyrna plant's output to keep up with demand, and other car makers may decide to produce EV's in volume instead of currently planned "field trial" quantities. The key is that by having the possibility of peak QC, people will be willing to drive an EV even though almost all their charging will be done in super off-peak.

So we have a CPUC rule (demand charges) intended to level peak demand. It does prevent a hundred EV's from exerting a 50 MW peak load (bad), but by so doing prevents a hundred thousand EV's from exerting a 4000 MW off-peak load (good). And of course while CPUC waits on real world data before making any decision to change the rule, they prevent installation of QC stations thus insuring that there will be no real world data.

Thanks for the reference to the relevant CPUC ruling. I'm encouraged to see the date (August 2009). Since then three Gov. Brown appointees have joined two Gov. Schwarzenegger appointees. It seems likely that the new commissioners may be willing to reconsider. I think it would take an organization with the stature of Plugin America, AAA, or the Sierra Club to get the attention of the CPUC however.

Sorry to burst your bubble, but the Phase II decision is from July 2011. The Rulemaking was initiated in 2009, and remains open, but the most recent decision is less than six months old. It was, however, written by Commissioner Peevey, whose term expires next year, I believe.
 
edatoakrun said:
What I don't understand, is that I would think that the CPUC should have foreseen the roadblock to DC charging that they were putting up.
I would not attribute that level of foresight to the CPUC. The most specific they've gotten is to explicitly forego regulation of "electricity for resale" (e.g. exerting jurisdiction over Blink/Chargepoint rates and fees) where charging infrastructure is concerned. I doubt anyone thought ahead to specific charging technologies and the impacts of existing tariffs structures (demand charges) on those economics. A good avenue for future lobbying/activism at the CPUC.
 
walterbays said:
Without a robust public charging infrastructure, including QC, I don't think numbers of EV's on the road will grow much beyond current levels. With widespread QC, Nissan will need the Smyrna plant's output to keep up with demand, and other car makers may decide to produce EV's in volume instead of currently planned "field trial" quantities.
I realize mine is a minority opinion, at least among those active on this thread, but I see the equation quite differently. The blunt fact is that QC is far too slow and inconvenient for long distance travel, except for a very few wild-eyed freaks like us early adopters.

"So what?" you ask. Well, I believe the real inhibitor to widespread acceptance of EVs is the (often illogical) reaction by potential customers that they would never buy an EV because it wouldn't work for long trips. You can spread tens of thousands of QC units around the US, and it will not make a dent in that reaction. "I have to sit half an hour for every hour I drive? That's insane!" (And before you start claiming that is exaggerated, it doesn't matter whether it is really true. That is just what they will say, because others will have told them it is true, and it's not all that far from the truth.)

The only things that would convince the long-distance-foot-draggers would be 300 mile batteries or near-instantaneous recharging, such as battery swaps or 500 kW charge rates. Neither of those is going to happen here any time soon. But there is another way to exponential growth in EVs. You sell them as cost-saving short-distance second vehicles. Once people get their hands on them they will discover how much fun they are to drive, and that they use them far more than their "primary" vehicle. But we will keep that under our hat, and let new owners discover it for themselves. Meanwhile, there is a huge pool of two-car (or more) families that can be talked into an EV -- even if there are no QC stations anywhere.

Yes, the Smyrna plant is key. Right now constrained supply forces the LEAF to be a niche vehicle. But you don't need QC for demand to take off once the supply is there.

Ray
 
I'll add a few points here, based on my opinion that we need a QC infrastructure, not to encourage long distance trips or longer commutes, but to extend range for the type of normal trips that are a part of our lives, including the occasional jaunt to or from the LA region to San Diego, from inland to the beach, from the coast to the desert or the mountains.

Reading through the CPUC documents, as well as the responses to rate case arguments by utilities, it appears that the PUC has really worked to encourage EV charging, following very clear policies that they have received from the legislature and the executive branch.

Their logic is that electric vehicles will do the vast majority of their charging in super off-peak hours. This provides benefits to the state-wide grid by increasing demand when power is plentiful and cheap without requiring additional distribution investments or expensive generating capacity during peak hours.

That logic appears very sound, reflecting good public policy consistent with other goals.

L1 or L2 Charging at work or as part of other larger facilities is also something that is easily covered by the existing rate structures.

The one fly in the ointment is the Quick Charge station. Development of a model where EV users pull a significant portion of their juice rapidly during peak hours is the exact opposite of the case that has been made for electric vehicles. While Quick Charging may be a necessary component of implementing widespread adoption of EV's, it is an area where the PUC wants the consumer to feel the price signals of peak hour charging.

There is still a case for a successful deployment of QC within the existing rate structure, but it will reflect Time of Use billing similar to what I have at home, where my SCE peak summer hour usage or PV generation rate goes as high as 53 cents a kwh while my super off-peak rate to charge my car is as low as ten cents a kwh. So a vendor offering QC will charge different rates during different times and seasons, consistent with their billing structure.

I think there are probably some public policy initiatives that could assist the development of QC stations;

1.) Allowing QC and L2 vendors to actually bill by the KWH, which as I understand it, is inconsistent with current PUC policy, where utilities jealously guard their monopolies. This would allow for a combination of billing based on time and power that would be fair to everyone and encourage maximum utilization of infrastructure, particularly where the charging station operators are combining their operations with PV generation and fleet charging.

2.) Allow Net Metering customers to shift any unused KWH to EV charging station operators. One of the real beauties of EV adopters is that such a high percentage (40%) of us are generating our own power during peak hours, providing local resilience to the grid and truly moving towards California's goals of fossil-free, greenhouse gas-free, air-pollution free transportation.

3.) Use tax credits to encourage sponsorship of first generation charging stations, and particularly QC charging stations by corporations, non-profits and individuals, particularly by the utilities.

4.) Communicate with utilities to encourage them to support Quick Charging as a part of their marketing efforts. Utilities operate with silos within their organization, where the people in charge of rate-setting don't talk to the people who are doing public relations and marketing. What better place for marketing an electric utility than an EV Oasis?

5.) Failure of current vendors, particularly Ecotality. Pronounce the EV project a success, stop subsidizing the bloated operations of its vendors, and move on.
 
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