waitingforaleaf
Well-known member
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.
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.
oakwcj said: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.
....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...
oakwcj said: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.
mxp said:oakwcj said: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.
mxp said:oakwcj said: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.
oakwcj said:< 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
Nekota said:mxp said:oakwcj said: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/COMMENT_RESOLUTION/171370.pdf" onclick="window.open(this.href);return false;
If you have solar panels, you may find that switching to E6 gives comparable savings to the old E9. If you don't have solar panels, spend the money on them, rather than giving it away to lawyers. I can almost guarantee that the long-term payout will be higher.mxp said:My apologies if I sound overboard with this: Is it worth the time and money to hire legal representation to fight for the implementation of indefinitely grandfathering in E-9 adopters?
It always irks me hearing the 30+kWh of energy tagged to gas. Factor in all the death & destruction (wars) related to its acquisition, cancers/respitory/health issues/death/retraning searching for new fields, drilling pumping refining pumping some more, shipping etc, and you end up with only 2/3 of that amount. Not so with electrons. sorry - off the soap box now.Spies said:I find the whole "buck a gallon" thing completely meaningless without context. To me its no different than saying the Chevy Volt gets 230 MPG.waitingforaleaf said:Likewise, the statement that it costs a "buck a gallon" to fill up the EV at off-peak hours disguises the fact that household electricity usage under the EV rate (during the peak and partial peak hours) is heavily increased for customers who normally do not exceed the first three tiers under E-9.
EPA's own formula of 33.7 kWh of energy per refined gallon of gas would mean under the new rates one would be paying the equivalent of $3.27 a gallon summer off peak . . . . . . . . . . . . . snip
Can you imagine what your rates would be if we actually paid enough so that the grid wasn't always in disrepair - to the point where summer days almost guarantee brown-outs? You don't see many people standing in line to pony up enough to fix things.mxp said:[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?
hill said:...
Can you imagine what your rates would be if we actually paid enough so that the grid wasn't always in disrepair - to the point where summer days almost guarantee brown-outs? You don't see many people standing in line to pony up enough to fix things.
.
oakwcj said: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.
planet4ever said:If you have solar panels, you may find that switching to E6 gives comparable savings to the old E9. If you don't have solar panels, spend the money on them, rather than giving it away to lawyers. I can almost guarantee that the long-term payout will be higher.mxp said:My apologies if I sound overboard with this: Is it worth the time and money to hire legal representation to fight for the implementation of indefinitely grandfathering in E-9 adopters?
Ray
You have that backwards. It is E-7 which is now closed to new customers, and E-6 that you can still switch to. Most people (at least those with sizable solar arrays) consider that E-7 was much better, because its peak hours were weekdays 12 noon to 6 PM, year round, while the E-6 peak hours are weekdays 1 PM to 7 PM, May through October only.mxp said:I spoke to a friend recently who told me that the E-6 is now replaced with E-7 which is not as good at the E6. He was on E-6 for many years and was grandfathered in indefinitely.
First let me emphasize that I am not a shill for PG&E, nor an apologist for their rates, nor do I have any business relationship with them apart from the services they provide to our home. I know their rates are high, significantly higher than SMUD or a number of other local providers in northern California.srl99 said:If you are a net generator, PG&E pays you 3c/kWH for your excess electricity - which they claim is their cost to acquire.
What is the basis for your assertion, srl99, that they really pay a small fraction of that amount?If the eligible customer-generator is a net generator, the net kWh generated shall be valued at the rate for the kWh up to the baseline quantity, with any excess kWh generated, valued at the rate for the appropriate tier level in which the equivalent kWh of usage would fall.
planet4ever said:My earlier statement is based on my nearly six years experience with E-6. I have solar panels on my roof, and use schedule E-6. Averaged over the year I am a net consumer of electricity, not a net generator. I typically see 4-6 months per year of net generation during peak periods, and I am credited for that generation at peak rates, always in excess of $0.25/kWh. I suppose it is possible that if I were a net generator on an annual basis they would have some fine-print rule that would reduce that to $0.03/kWh. If so, I have certainly not found it. Here is what I see in the PG&E NEMS tariff:
What is the basis for your assertion, srl99, that they really pay a small fraction of that amount?If the eligible customer-generator is a net generator, the net kWh generated shall be valued at the rate for the kWh up to the baseline quantity, with any excess kWh generated, valued at the rate for the appropriate tier level in which the equivalent kWh of usage would fall.
Note: I am assuming home-scale solar or wind generation, not exceeding 30kW. I believe most home installations are significantly below that, typically closer to 5kW. Are you perhaps talking about large commercial installations? I haven't looked at the rates for those.
Ray
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