I've been curious about why PG&E has done so little to publicize these rates, and now I think I know why--PG&E is not happy with the rates and wants to raise them. Now they are taking advantage of a recommendation from the California Public Utilities Commission (CPUC) to eliminate tiers as an opportunity to raise the rates for all but the most high energy consuming EV owners. The CPUC is concerned that the tiers cause a disincentive to EV ownership, but PG&E's response is an even bigger disincentive.
Here is the letter I just sent to the CPUC on the subject. Note that protest letters need to be sent by October 17 if you are interested in chiming in:
October 11, 2011
CPUC Energy Division
Tariff Files, Room 4005
DMS Branch
505 Van Ness Avenue
San Francisco, California 94102
Re: Advice No. 3910-E (Subject: Modifications of Electric Rate Schedule E-9 for Residential Time-of-Use Service for Low Emission Vehicle Customers
Director, CPUC Energy Division, et al.
I wish to file a formal protest against the proposed rate changes to electric rate schedule E-9 as suggested by PG&E in Advice No. 3910-E in response to CPUC decision 11-07-029.
I agree strongly with the CPUC’s desire to promote electric vehicles (EVs) and to ensure that the rate structure provides incentives for electric vehicles and for charging in the off-peaks. It is clear that the intent of CPUC decision 11-07-029 is to seek off-peak charging and to lower costs for EVs in order to encourage their use. The decision states, “Electric Vehicles are uniquely positioned to contribute toward the policy goals set forth in AB 32 and ARB's 2008 Scoping Plan to encourage the electrification of the transportation sector as a means of reducing overall greenhouse gas emissions.” I also strongly concur with your statement, “Our goal is to create a future where residential Electric Vehicle charging will be the norm.”
I believe that CPUC decision 11-07-029 encourages “non-tiered” rates for EVs in order to promote EV ownership and to avoid excessive charges. This is a valid concern, especially in the case of EV owners who drive for more than 1200 miles per month on their batteries* or who have two or more electric vehicles. However, since the average number of miles driven per month in the U.S. is around 1,000 miles per vehicle, the current Tier structure accommodates the needs of most drivers.
Also, the elimination of tiers is contrary to the goal of energy conservation. Even though EVs are much more environmentally friendly than internal combustion engine vehicles, we should still encourage choices that conserve energy. And even if the EVs are powered by renewable energy, the issues of urban sprawl such as loss of wildlife and farmland, as well as problems of obesity associated with excessive reliance on automobiles, should be discouraged. The tiered rates promote such conservation and healthy choices.
I believe the emphasis of decision 11-07-029 is on bypassing disincentives for EV use. Unfortunately, PG&E’s proposal takes advantage of the CPUC recommendation to eliminate tiers, as an opportunity to address primarily the issue of cost. In the words of Advice No. 3910-E, “Schedule E-9 is both complex and outdated, and its tiered structure does not reflect PG&E’s cost of service.”
Now these may or may not be valid points, but they do not address the essence of the CPUC’s recommendation to encourage EVs. I do not believe that the CPUC intended to discourage EV use by raising rates. And it is doubtful that the complexity of tiers is a serious problem since utility bills are currently tiered. Also, both of these issues are already addressed in CPUC decision 11-07-029 which states, “We find that the Commission should revisit the suitability of the utilities' Electric Vehicle residential rate schedules in 2013-2014.”
PG&E admits that their proposed rates would result in increases for the vast majority of people currently using E-9A and E-9B rates. Such an action is not at all compatible with encouraging EV use.
The simplest course of action would be to deny PG&E’s request. You could also consider allowing an option for a single tier for both E-9A and E-9B. This would benefit those who put a lot of miles on their EV or who have more than one.
You could also apply the single tier, albeit with a lower rate, only to the E-9B schedule. And you could also reduce electricity prices for only off-peak hours above tier 2 for both E-9(A) and (B), which would “bypass disincentives” to EV use.
It is important to understand that the E-9A rate is especially desirable for those who have solar panels on their roof as well as an EV. A recent study of Nissan Leaf owners (cited in the Santa Monica Daily Press) found that 30% have solar panels, and this is something the CPUC should strongly encourage. Rooftop solar panels produce enough electricity to keep total household consumption (both residential and EV) in Tier I and Tier II levels. This was the calculation we made when we sized our solar photovoltaic (PV) system. Changing the rates now would more than double our PG&E electric bill. This is no way to support California in replacing fossil fuels with clean energy and electric vehicles.
Combining PV and EVs is beneficial on many levels. It reduces greenhouse gases and air pollution; it reduces summer peak hour electricity consumption; and, as you have pointed out in decision 11-07-029 “night-time charging facilitates' integration of wind energy by using the storage capacity of the Electric Vehicles' batteries to transform California's predominantly nocturnal wind power resources into transportation fuel for daytime driving.”
Therefore, it is especially important to leave the E-9(A) rate unchanged.** Note that this is consistent with decision 11-07-029, which states, “Pacific Gas and Electric Company shall file an advice letter to modify Electric Rates Tariff Schedule E-9(B) to eliminate the tiers but retain time-variant pricing.”
However, as explained previously, I believe that the E-9(B) rate proposed in Advice No. 3910-E is excessive and ill-advised. PG&E admits that their proposal would increase rates for 34 of the 35 people now using E-9(B)—97%! This contradicts their claim that “PG&E’s proposed changes to Schedule E-9 are designed to be revenue neutral for electric vehicle customers.”
Two additional problems with Advice No. 3910-E are its elimination of weekend off-peak periods and its addition of a winter peak period. These appear to have no justification other than a rate increase and should be rejected by the Commission. PG&E presents disingenuous arguments to support these changes: e.g. “allow customers to more easily remember and understand the daily rate structure”, as if people don’t know when it is a weekend, and “to allow customers greater flexibility for their weekend and holiday charging needs” as if eliminating off-peak periods on the weekend is some kind of improvement.
Thank you for your consideration of these points, and also for your efforts to support electric vehicles and clean energy,
Sincerely,
Jack Lucero Fleck
*Calculation: The current baseline for Tier I averages 271 kwh per month. At 3.3 miles per kwh (our Chevy Volt) this is enough energy to drive 894 miles. Tier II allows 30% more mileage at a still low rate, i.e. 1,162 miles per month. So anyone driving less than 1,200 miles per month is almost entirely in Tier I and Tier II.
**Note that the following statement from decision 11-07-029 is true for many E-9(A) homes without solar power, but it is not true for most E-9(B) drivers, i.e. those driving less than 1,200 miles per month on their batteries: “the existing single meter Electric Vehicle rates effectively place the customer into the upper tiers of the rate structure due to the increased electric usage resulting from the customer's Electric Vehicle load.” Therefore, I am arguing that the E-9(A) rates are ideal for homes with EV and PV, and the E-9(B) rates are best for those with EV only. For both of the E-9 rates, the tiered system works well for most drivers.
Cc: Facsimile: (415) 703-2200
E-mail: jnj@cpuc.ca.gov and mas@cpuc.ca.gov
Director, Energy Division, Room 4004, at the address shown above.
Brian K. Cherry
Vice President, Regulations and Rates
Pacific Gas and Electric Company
77 Beale Street, Mail Code B10C
P.O. Box 770000
San Francisco, California 94177
Facsimile: (415) 973-6520
E-mail: PGETariffs@pge.com
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