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

Wed May 23, 2012 10:16 am

Just bumping this thread up, since the protest deadline is May 29 (less than a week away). Curious to see how others are handling this newest proposal.
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EricBayArea
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Re: PG&E / CPUC - Non-Tiered Time Of Use Rates

Thu May 24, 2012 10:49 am

Personally my wife and I don't use very much electricity and our bills are pretty low. I would categorize us as "light" users. Therefore on this type of plan we would probably be paying more (since we typically stay in tier 1 or 2 for all windows - off-peak, part-peak, peak).

I don't really like that PG&E is removing the incentive for us and others to use less electricity.
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EricBayArea
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Re: PG&E / CPUC - Non-Tiered Time Of Use Rates

Tue Jun 05, 2012 4:17 pm

I wrote PG&E and CPUC and voiced my concern with their proposed plan. Today I was CC'ed on a letter response from PG&E to the CPUC addressing mine and other's concerns. I tried to format the reply correctly below. Sorry if its a little off:

Re: Reply to Protests of Pacific Gas and Electric Company’s Advice
3910-E-A (Modifications to Electric Rate Schedule E-9 for Residential Time-of-Use Service for Low Emission Vehicle Customers and Creation of New Schedule EV) Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (“PG&E”) hereby files its reply to protests received as of May 30, 2012 to PG&E’s Advice Letter 3910-E-A. On May 9, 2012, PG&E filed Advice Letter 3910-E-A requesting approval from the California Public Utilities Commission (“Commission”) of modifications to Electric Rate Schedule E-9, which is an experimental tariff providing residential time-ofuse (“TOU”) service for qualifying low emission vehicle customers that was first implemented in 1996. In addition, Advice Letter 3910-E-A requested approval of draft tariffs of Schedule EV, a new voluntary rate for customers with electric vehicles (“EVs”). PG&E received eight protests to this advice letter, described in more detail below, and respectfully replies to these parties’ protests.

Description of Protests

Issues raised by protests to Advice Letter 3910-E-A can be summarized
as follows:
- The proposed EV rates do not promote EVs or off-peak charging;
- The proposed EV rates do not provide conservation incentives, and
should be tiered;
- Low-use customers do not have a viable TOU alternative;
- The proposed EV off-peak rates are too high and do not reflect cost of
service;
- The proposed EV rates should not include an on-peak period during the
winter or on weekends;
- The proposed EV rates should be set at marginal cost rather than on a full
cost, revenue neutral basis;
- Participation on the proposed EV rates should not be limited to 30,000
customers; and
- Schedule E-9B should be grandfathered indefinitely.

Most of these concerns were raised in the context of earlier protests and
addressed in PG&E’s reply to protests of Advice 3910-E. PG&E has referred to
its earlier reply where appropriate in its responses to protests of Advice 3910-E-A
provided below.

Reply to Protests

At the outset, several parties expressed concerns that the proposed Schedule EV rates would not be the lowest cost rate for them. PG&E recognizes that the proposed Schedule EV rates will not be the best rate choice for all of its EV charging customers, considering the diversity of residential customers that own EVs. It is extremely unlikely that one single rate could provide the lowest cost alternative for all customers who own EVs. As indicated in protests, customers who own EVs can range from very low use customers with solar installations to higher use customers that are penalized by tiered rate charges resulting from incremental EV charging. That is why Schedule E-9 and its replacement, Schedule EV, are voluntary rates. In fact, customers with EV charging will have three primary rate alternatives from which to choose. Schedule E-1 and Schedule E-6 both continue to be available to customers with EV charging served as part of their whole-house service. Schedule E-1 is a non-TOU, tiered rate. Schedule E-6 is a tiered TOU rate. These options are complemented by the proposed Schedule EV, which is a non-tiered TOU rate that includes both whole-house (single meter) and charging-only (separate meter) options. By providing this array of rate options, customers may choose the rate best suited to their situation.

In addition, PG&E offers the following reply to parties’ protests:
The proposed EV rates do not promote EVs or off-peak charging. The Schedule EV rates are designed to promote off-peak charging by providing significantly lower rates during the off-peak time period. PG&E’s off-peak rate of less than 10 cents per kWh on Schedule EV provides a gasoline equivalent charge of roughly $1.00 per gallon which
PG&E believes is a significant incentive for EVs compared to the current
cost of gasoline. Schedule EV also provides TOU energy rates that have an on-peak to off-peak ratio of more than 3 to 1 in the summer and well over 2 to 1 in the winter providing a clear incentive to charge during the off-peak period.
The proposed EV rates do not provide conservation incentives, and should be tiered. As noted above, and in reply to protests to the original advice letter, customers with EVs may still choose Schedules E-1 and E-6 which both provide conservation signals through tiered rates for wholehouse service. While E-6 may not provide the level of bill savings as Schedule E-9, its rates are much better aligned with PG&E’s cost of service.
Low use customers do not have a viable TOU alternative. As noted above, and in reply to protests to the original advice letter, PG&E does offer a TOU rate option for EV customers. TOU Schedule E-6 will continue to remain available for whole-house service customers. In addition, customers who have elected the EV charging-only option may continue to choose from Schedule E-1 or TOU Schedule E-6 for their regular house service.
The proposed EV off-peak rates are too high and do not reflect cost of service. The off-peak rate for Schedule EV is cost based. As noted in one protest, and as indicated in PG&E’s previous reply to protests, nonbypassable charges (NBCs), which must be paid by all customers, account for about half of the off-peak rate proposed by PG&E. As noted in Sheet 2 of the pro forma tariffs for Schedule EV, NBCs that must be paid by all customers include: (1) Nuclear Decommissioning; (2) Public Purpose Programs; (3) Competition Transition Charges; (4) Energy Cost Recovery Amount; (5) DWR Bond Charge; and (6) New System Generation Charges. NBCs represent charges that are paid by all customers ranging from costs associated with low-income ratepayer
assistance and energy-efficiency programs to generation-related charges. In addition to NBCs, transmission and distribution charges (costs associated with the transportation of electricity) are also included in Schedule EV off-peak rate. The Schedule EV off-peak rate can also be compared with similar tariffs to determine if it has been reasonably established. For example, the Schedule EV off-peak rate is much lower than the off-peak rate of similar non-residential rates (e.g., Schedule A-6), and is set about the same level as the off-peak tier 1 rate for Schedule E-6. In addition, the off-peak rate for Schedule EV is at about the same level as SCE’s off-peak tier 1 standard EV charging rate, and less than the SDG&E’s standard off-peak EV charging rate. Thus, Schedule EV’s offpeak rate is comparable to other rate options and is fully cost based.
The proposed EV rates should not include an on-peak period during winter or on weekends. PG&E commented extensively on this item in its earlier reply to protests, and does not repeat that detailed response here. However, PG&E notes that its choice of TOU periods factored in the impact on local distribution circuits of increased EV adoption. This included the impact of both clustering of EVs on local distribution circuits and distribution circuits that peak in the winter.
The proposed EV rate should be set at marginal cost rather than on a full-cost, revenue-neutral basis. Nowhere in D.11-07-029 does the Commission state that EV rates should be set at marginal cost levels. Moreover, as PG&E noted in its previous reply to protests, the Commission has previously ruled NBCs cannot be discounted.
Participation on the proposed EV rates should not be limited to 30,000 customers. PG&E has offered Schedule EV as an experimental rate option with a participation limit because the Commission intends to revisit rates for EV charging in the 2014 GRC. PG&E believes that the participation limitation can be reviewed at that time. In addition, given the current level of EV adoption (approximately 3,000 through March 2012), PG&E’s high estimate of EV adoption through 2014 is roughly 20,000 EVs. Therefore PG&E believes that a 30,000 cap on participation should be sufficient to accommodate EVs through this time period.
Schedule E-9B should be grandfathered indefinitely. The Commission has clearly indicated in D.11-07-029 that EV rates for the charging-only option should be revised to eliminate tiers. PG&E’s proposal in Advice 3910-EA is consistent with that decision because it phases these rates out by first closing the schedule to new customers and then eliminating Schedule E-9 by the later of the date a decision is granted in Phase 2 of PG&E’s 2014 GRC or December 31, 2014.
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oakwcj
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Re: PG&E / CPUC - Non-Tiered Time Of Use Rates

Tue Jul 24, 2012 2:45 pm

The CPUC Energy Division has issued a proposed decision approving PG&E's modified rate proposal, which grandfathers in customers already on the E-9 rate until at least the end of 2014. The proposed decision really doesn't say much, but it's being sent to everyone on the service list for comment. Since there were only 8 protests filed to the revised proposal, this is a done deal. The whole subject will be revisited by the CPUC in 2013 and 2014 as part of its next general rate review.
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edatoakrun
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Re: PG&E / CPUC - Non-Tiered Time Of Use Rates

Tue Jul 24, 2012 3:01 pm

oakwcj wrote:The CPUC Energy Division has issued a proposed decision approving PG&E's modified rate proposal, which grandfathers in customers already on the E-9 rate until at least the end of 2014. The proposed decision really doesn't say much, but it's being sent to everyone on the service list for comment. Since there were only 8 protests filed to the revised proposal, this is a done deal. The whole subject will be revisited by the CPUC in 2013 and 2014 as part of its next general rate review.


From the decision:

....Moreover, this rate may encourage electric vehicle adoption for high use customers, with
off-peak prices of less than $0.10/kWh compared with the substantially more expensive upper tier rates on Schedules E-1 and E-9...


And the Tesla owners did rejoice!

I wonder how many mcmansion owners will buy an EV, since it's now the sole way to "opt out" of the E-1 and E-6 tiered rates?
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Re: PG&E / CPUC - Non-Tiered Time Of Use Rates

Fri Aug 03, 2012 9:25 pm

oakwcj wrote:The CPUC Energy Division has issued a proposed decision approving PG&E's modified rate proposal, which grandfathers in customers already on the E-9 rate until at least the end of 2014. The proposed decision really doesn't say much, but it's being sent to everyone on the service list for comment. Since there were only 8 protests filed to the revised proposal, this is a done deal. The whole subject will be revisited by the CPUC in 2013 and 2014 as part of its next general rate review.


I did not receive any form of notification of this final decision. Can you point me to the URL link please?

Thanks.

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

Fri Aug 03, 2012 9:47 pm

mxp wrote:
oakwcj wrote:The CPUC Energy Division has issued a proposed decision approving PG&E's modified rate proposal, which grandfathers in customers already on the E-9 rate until at least the end of 2014. The proposed decision really doesn't say much, but it's being sent to everyone on the service list for comment. Since there were only 8 protests filed to the revised proposal, this is a done deal. The whole subject will be revisited by the CPUC in 2013 and 2014 as part of its next general rate review.


I did not receive any form of notification of this final decision. Can you point me to the URL link please?

Thanks.


The proposed decision was attached to an email sent to everyone on the CPUC service list. I don't have a URL. Here's the meat of the cover letter and the proposed resolution:

July 24, 2012 ID # 11492
Draft Resolution E-4508
August 23, 2012 Commission Meeting

TO: PARTIES TO DRAFT RESOLUTION E-4508
Service List R.09-08-009

Enclosed is Draft Resolution E-4508 of the Energy Division addressing Pacific Gas and Electric Company’s Advice Letter 3910-E-A. The Draft Resolution will be on the agenda at the August 23, 2012 Commission meeting. The Commission may then vote on the Draft Resolution or it may postpone a vote until later.

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

I.D.# 11492
ENERGY DIVISION RESOLUTION E-4508
August 23, 2012

RESOLUTION

Resolution E-4508. Pacific Gas and Electric Company (PG&E) Advice Letter 3910-E and Advice Letter 3910-E-A.

PROPOSED OUTCOME: This Resolution approves PG&E’s request to create a new electric vehicle rate schedule EV that eliminates the tiers but retains time variant pricing and to grandfather existing customers on E-9 electric vehicle rates until a decision in Phase 2 of PG&E’s 2014 General Rate Case or until December 31, 2014, whichever is later.
ESTIMATED COST: The proposed changes are revenue neutral on a class average basis.
By Advice Letter 3910-E, filed on September 26, 2011, and Advice Letter 3910-E-A, filed on May 9, 2012.
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Nekota
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Re: PG&E / CPUC - Non-Tiered Time Of Use Rates

Fri Aug 03, 2012 10:26 pm

mxp wrote:
oakwcj wrote:The CPUC Energy Division has issued a proposed decision approving PG&E's modified rate proposal, which grandfathers in customers already on the E-9 rate until at least the end of 2014. The proposed decision really doesn't say much, but it's being sent to everyone on the service list for comment. Since there were only 8 protests filed to the revised proposal, this is a done deal. The whole subject will be revisited by the CPUC in 2013 and 2014 as part of its next general rate review.


I did not receive any form of notification of this final decision. Can you point me to the URL link please?

Thanks.



http://docs.cpuc.ca.gov/word_pdf/COMMEN ... 171370.pdf
Res 20Apr2010 / Ordered 27Sep2010 / Delivered 12May2011

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

Fri Aug 03, 2012 10:48 pm

The August GGEVA meeting will be held this Sunday, August 5, 2012. This meeting will be a joint meeting with BayLEAFs, the Bay Area LEAF owners group. The BayLEAF meeting will begin at 9:00 AM.

A presentation on PG&E's rates for EVs by Genevieve Dufau-McCarthy of PG&E is scheduled for 10:00 AM.


The GGEVA portion of the meeting will begin at 11:00 AM with a presentation by Alan Soule describing a trip from the Bay Area to Chicago and back via historic Route 66 in hisTesla Roadster. The final presentation, given by Dan Myggen of Tesla Motors, will describe the Tesla Model S Sedan. A Model S will be on display.

The meeting will be held at 475 9th Street in San Francisco.

The meeting is free and open to the public. Any one interested in EVs is welcome to attend. Please invite others to attend this important meeting.

See http://www.ggeva.org for more details.
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Re: PG&E / CPUC - Non-Tiered Time Of Use Rates

Mon Aug 06, 2012 9:59 am

oakwcj wrote:
< cut >
The proposed decision was attached to an email sent to everyone on the CPUC service list. I don't have a URL. Here's the meat of the cover letter and the proposed resolution:

July 24, 2012 ID # 11492
Draft Resolution E-4508
August 23, 2012 Commission Meeting

TO: PARTIES TO DRAFT RESOLUTION E-4508
Service List R.09-08-009


Thank you to oakwcj and Nekota for providing links.

It's been a while since I last checked this. I did receive an email today from another protester requesting the CPUC DELAY their decision supposedly to be published on August 13. He expressed an alternative to ask CPUC to wait for a rate calculator.

I suppose is this too little to late now?

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