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
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.
Brian K. Cherry, PG&E
Mark Toney, TURN
Delivery estimate 8/2011
Actual delivery 9/17/11