5. Electric Vehicle Rate Design Principles
Rate design is our primary means to influence the Electric Vehicle owners' charging behavior. Encouraging customers to charge their vehicles during off-peak periods is a central objective of Electric Vehicle rate design. Properly designed rates also align revenue collection with cost causation. Simply put, rate structures can convey the costs and environmental impacts of the supply and demand of electricity to consumers, providing incentives for individuals to make choices consistent with the collective good.
The benefits of off-peak Electric Vehicle charging are manifold and accrue to the Electric Vehicle owners and non-Electric Vehicle owners alike. Off-peak charging places less strain on the distribution system, avoiding adverse impacts to the electric grid and reducing the need for costly infrastructure upgrades. Concentrating Electric Vehicle charging in off-peak periods will also dampen increases in energy procurement costs resulting from the addition of this new load: not only is energy more expensive during peak periods, but significant levels of on-peak charging could actually increase incremental procurement costs by exerting upward pressure on peak-time wholesale energy prices. Spreading fixed capacity costs over a larger volume of energy sales has the beneficial effect of lowering the average cost of providing electricity service for all customers.
Off-peak charging also delivers greater environmental benefits since substituting electricity for petroleum-based transportation fuels yields greater reductions in emissions of CO2 and other pollutants during off-peak periods. This is because the marginal generating units available during off-peak hours tend to be cleaner and/or more efficient than peaker plants. Finally, night-time charging facilitates' integration of wind energy by using the storage capacity of the Electric Vehicles' batteries transform California's predominantly nocturnal wind power resources into transportation fuel for daytime driving. Currently much of the wind capacity in California generates electricity off-peak. In addition to being low emission, wind generation is not designed to ramp down to accommodate additional wind output. By creating a new use for off-peak generating resources, off-peak Electric Vehicle charging could help address challenges posed by wind generation.
Time-of-use rates provide a potent incentive to encourage off-peak charging. We find that time-of-use rates are appropriate for Electric Vehicles because the time-of-use aspect of the rate better reflects cost causation principles than a non-time-differentiated rate and encourages Electric Vehicle charging when the costs imposed on the system are lowest and environmental benefits are greatest. In today's decision we assess the adequacy of time-of-use rate structures in existing rates designed expressly for Electric Vehicles or for which Electric Vehicle owners and/or electric vehicle service providers may be eligible.
Although our goal is to maximize off-peak charging, we appreciate that, at times, Electric Vehicle owners will need to charge their vehicles during peak periods or may simply find it convenient to do so. To ensure broad consumer acceptance of Electric Vehicles, it is crucial to accommodate the Electric Vehicle owners' charging needs and preferences and to attract private capital to support development of the necessary charging infrastructure. We are aware that several companies are exploring a variety of business models for Electric Vehicle charging in California, and we wish to avoid placing unnecessary constraints on them. At same time, we recognize that, to the extent Electric Vehicle charging occurs on-peak, it will place new demands on the grid. Rates designed for Electric Vehicle charging should reflect these incremental costs.
Demand charges may be used along with or instead of time-of-use rates to reflect the capacity costs a given customer imposes on the system. A typical demand charge is a rate component enumerated in dollars per kilowatt that is multiplied by a customer's maximum kilowatt electricity usage during a billing period. Demand charges are a common component of the utilities' medium and large commercial and industrial rates. We consider here whether it is appropriate to incorporate demand charges into Electric Vehicle rate schedules for residential and small commercial customers.
We note that our consideration of rates for electric vehicle charging occurs against the backdrop of an ongoing, gradual transition to default dynamic pricing (including time-of-use rates) for all utility customers. The smart meters that utilities are currently installing throughout their service territories have the capability to support time-of-use pricing, as they can record and transmit energy usage data at intervals of an hour or less. To take full advantage of this infrastructure investment and to help achieve our goal of making energy demand more responsive to wholesale market conditions, the Commission in D.05-11-009 ordered each utility to include proposals for time-of-use tariffs for all customers, including residential and small and medium commercial and industrial customers, in its next comprehensive rate design proceeding. Large commercial and industrial customers are already subject to default time-of-use rates.
The Commission is transitioning small and medium commercial and industrial customers to time-of-use tariffs. We anticipate that these tariffs will be rolled out through 2013, when the last of the three investor-owned electric utilities, SDG&E, completes its rate design proceeding, A.10-07-009. We find, however, that the general application of time-of-use rates for Electric Vehicle charging should not be slowed by the gradual pace at which the broader shift to universal time-of-use rates is occurring. We note that the movement toward universal time-of-use pricing is consistent with our view that electric rates for Electric Vehicle charging should be strongly time differentiated.
Below we apply these rate design principles to Electric Vehicle rate options for the residential and non-residential sectors. We also consider the adequacy of existing rates and provide direction for future review of Electric Vehicle rates.
5.1. Electric Vehicle Residential Rates
The task of designing Electric Vehicle rates for residential customers is complicated by the prevalence of inclining block or tiered rates for this customer segment. Tiered rates increase as a customer's cumulative usage increases during a billing period and are intended to promote energy conservation. Electric Vehicle charging is incremental to existing household load, and, therefore, if included with other household load via a single meter, may push the customer into the highest rate tiers. Because tiered rates climb steeply in all three of the utilities' residential rate structures, the bill impact for the Electric Vehicle purchasers could be significant. Some parties have contended that exposing the Electric Vehicle owners to tiered rates will raise charging costs enough to discourage prospective Electric Vehicle purchasers. For Electric Vehicle owners, tiered residential rates may also discourage overnight charging of Electric Vehicles at home, perversely encouraging on-peak charging at the workplace or other non-residential settings. Such an outcome would frustrate California's goals of promoting rapid customer adoption of Electric Vehicles while minimizing incremental infrastructure costs and maximizing environmental benefits.
Measuring energy consumption for the Electric Vehicle charging on a separate meter makes it possible to apply different rate schedules for charging versus other household loads. Alternatively, the expense of installing an additional meter can be avoided if customers are offered a non-tiered, single meter Electric Vehicle rate. Currently, each utility offers at least two Electric Vehicle rate schedules to residential customers seeking to charge their Electric Vehicles.13 Residential customers of each utility may choose between Electric Vehicle rate schedules that require Electric Vehicle electricity usage to be measured with a separate meter or whole house time-of-use rates that combine Electric Vehicle usage with all other electric usage on a single residential meter. While meter and rate issues, at times, overlap, meter issues are specifically discussed in Section 6.
Table No. 1
As shown in Table 5.1, all existing residential Electric Vehicle rate schedules include time-of-use rates with relatively higher prices during daytime, peak periods and relatively lower prices during off-peak periods. Some residential Electric Vehicle rates are non-tiered while in other instances time-of-use price differentials are superimposed on the underlying tiered structure.
We agree with the majority of parties that, with limited exceptions, the existing residential Electric Vehicle rates are sufficient for the early market. Our concerns regarding specific single and separately metered rates are discussed in Sections 5.1.1 and 5.1.2, respectively.
We find that the Commission should revisit the suitability of the utilities' Electric Vehicle residential rate schedules in 2013-2014. By then the Commission will have a better understanding of customer charging behavior and more Electric Vehicle load profile data to inform future rate design. The load research studies that we direct the utilities to undertake in Section 9 will provide insight into utility costs associated with Electric Vehicle infrastructure and service. Studies being conducted by Coulomb and Ecotality will also help us understand installation costs associated with electric vehicle service equipment. In addition, restrictions placed on residential rates by AB 695 (Kehoe, Stats. 2009, c. 337) will have expired,14 giving us more latitude in authorizing potential rate options for Electric Vehicle residential customers. For these reasons, we will target early 2013 to revisit Electric Vehicle residential rates. More details on our intention to revisit Electric Vehicle rates in 2013 are set forth in Section 5.4.
In keeping with our preference for affording customer choice, we also conclude that residential customers should be able to choose which Electric Vehicle rate best suits their needs. Residential Electric Vehicle rates should be offered on an opt-in (i.e., voluntary) basis. Staying on their pre-existing, non-Electric Vehicle rate should also be a permissible option, although as discussed in Section 10, we urge the utilities to educate Electric Vehicle owners about the possible savings they may realize from switching to time-differentiated Electric Vehicle rates.
A residential single meter Electric Vehicle rate, while specifically designed for Electric Vehicle charging, is applied to a residence's entire electricity usage. Single meter rates are also sometimes referred to as whole-house rates. As shown in Table 1, above, SCE's and PG&E's single meter Electric Vehicle rates are tiered, while SDG&E's are not. All of the utilities' single meter rates are optional (opt-in), meaning a residential customer must make a proactive voluntary decision to go onto the Electric Vehicle rate.
The challenge of single meter Electric Vehicle rate design, as summarized by SCE, is to structure a simpler, cost-based, time-of-use rate that avoids the disincentives for Electric Vehicle use associated with tiered rates but still recovers, at a minimum, the incremental cost to serve Electric Vehicles. (SCE December 6, 2010 comments at 12.) SCE is currently exploring the feasibility of offering a single meter non-tiered time-of-use rate for residential Electric Vehicle customers.
NRDC and the EVSP Coalition note that 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. As a result, such rates subject Electric Vehicle load to what these parties describe as high vehicle mileage costs. While removing the tiers from the single meter rate would address this issue, NRDC also expressed concern that switching Electric Vehicle charging from a tiered single meter rate to a non-tiered single meter rate could eliminate the conservation signals provided by the tiers.
Because a single meter Electric Vehicle rate motivates a customer to better manage the peak impacts of the entire household's electricity usage, not just the energy used for Electric Vehicle charging, we will not prohibit single meter Electric Vehicle residential rates. We hope that when we revisit rates for Electric Vehicles in 2013, inexpensive submetering technology will be readily available, obviating the need for such rates. As this outcome is not certain, we encourage SCE to continue exploring the feasibility of a non-tiered single meter rate, and we direct PG&E to do likewise. The load research that SCE and PG&E conduct pursuant to our directives in Section 9 should be designed to support this undertaking.
With separate metering or submetering, it is possible to avoid the potential disincentives tiered rates may create to residential Electric Vehicle charging while transmitting a pure time-of-use price signal to encourage off-peak charging. We find that Electric Vehicle residential rates should be opt-in, non-tiered and time-of-use for separately metered customers. We agree with DRA that these rates should be strongly time-differentiated (including delivery rate components), and that "to the extent that existing Electric Vehicle rates do not conform to these attributes, they should be changed" in the near term. (DRA September 24, 2010 comments at 13.)
As shown in Table 1, above, SDG&E and SCE already offer separately metered Electric Vehicle rates that are opt-in, non-tiered, and time-of-use. In contrast, PG&E's E-9b rate is a separately metered, opt in, time-of-use rate, that is tiered.15 Therefore, we direct PG&E to file an advice letter to modify Electric Rates Tariff Schedule E-9b to eliminate the tiers. This advice letter shall be filed as a Tier 2 advice letter within 60 days of the effective date of today's decision.
Some stakeholders have suggested that demand charges should be included in Electric Vehicle residential rates as an additional incentive to off-peak charging and to recover costs of upgrades to the distribution system needed to accommodate Electric Vehicle charging. Accordingly, we asked parties whether demand charges should be added to Electric Vehicle residential rates.
Demand charges are not currently a component of residential rates. Instead, in the residential setting, capacity costs are recovered through volumetric charges. In the context of residential Electric Vehicle rates, a demand charge could be included as a rate component so that Electric Vehicle customers who place higher costs on the electric system by, for example, charging on-peak or at higher voltages, are assessed rates based on the maximum demand they impose on the distribution circuit.
Some parties, including SCE, DRA, NRDC and Green Power Institute, stated that residential demand charges may not be necessary since time-of-use rates can accomplish capacity cost recovery. SCE also noted that costs associated with a particular customer class could be more easily recovered through a simple customer charge. Nevertheless, some of these same parties acknowledged that demand charges are a more precise tool for recovering demand-related costs. In contrast, SDG&E stated that increasing the time-of-use differentials could lead to the potential under recovery of the costs to serve a growing Electric Vehicle customer group. SDG&E suggests this argues for the need to introduce fixed and demand charge components to the Electric Vehicle rate structure.
We are persuaded that adding demand charges to residential Electric Vehicle rates would be too great a change to residential rates at this time. Instead, we direct each utility to re-evaluate the feasibility and benefits of an Electric Vehicle residential demand charge in its next review of Electric Vehicle rates, described below in Section 5.4.
In the August 20, 2009 OIR, we asked parties whether special arrangements were necessary for a residential customer to pay for electricity when charging an Electric Vehicle in another utility's service territory. For example, should the utilities establish a single billing procedure to link all Electric Vehicle electric usage, regardless of the service territory within which the Electric Vehicle charging occurs, to a customer's home utility. In the Staff's Rates Issue Paper, this issue was referred to as inter-utility billing. (Rates Issue Paper at 38.)
SCE and SDG&E were opposed to implementing inter-utility billing. SCE stated that a special rate for inter-utility billing could cause some utilities to over-collect and others to under-collect because wholesale energy prices and costs to serve customers differ between service territories. (SCE September 24, 2010 comments at 16.) In contrast, Green Power Institute and NRDC stated that the Commission should not foreclose any options regarding inter-utility billing at this time.
We find that it is premature for the Commission to direct the utilities to implement inter-utility billing. We leave open the possibility that further development of this concept may be useful in the future.
During this proceeding, several parties highlighted situations in which electric vehicle service providers might operate in a residential location. For example, an electric vehicle service provider may provide all the equipment required to charge an Electric Vehicle at a home together with a charging service, in which the electric vehicle service provider separately charges customers for the electricity used to charge their vehicle. In this case the electric vehicle service provider, not the homeowner, would be the utility's customer. Parties asked that the Commission clarify what rates electric vehicle service providers are eligible for in such a situation.
SCE recommended that all electric vehicle service providers be placed on commercial rates, regardless of the location. Under SCE's recommendation, electric vehicle service providers would only be eligible for commercial Electric Vehicle rates, even if the electric vehicle service provider obtained service in a residential location. (SCE September 24, 2010 comments at 2.) Other parties suggested that existing residential rates are sufficient for electric vehicle service providers in the near term and that any additional rate restrictions on electric vehicle service providers will unduly limit market growth.
We find that in order to preserve equitable, cost of service treatment and maintain a level playing field between utilities and electric vehicle service providers, existing residential Electric Vehicle rates should apply to electric vehicle service providers operating in the residential setting. Electric vehicle service providers should only be eligible for residential rates designed to serve Electric Vehicle load and, therefore, would not be eligible for non-time-of-use general service rates in the residential context. We adopt this limitation to ensure that electric vehicle service providers have appropriate rate incentives in the provision of their services in the residential setting to encourage off-peak charging. This finding is also consistent with D.10-07-044.
5.2. Electric Vehicle Non-Residential Rates
We now address which electric rate schedules should apply to Electric Vehicles charging at a non-residential customer premises, such as workplaces or retail locations. Our analysis of this issue is structured around a number of policy objectives associated with Electric Vehicles charging in non-residential settings. A chart of the existing non-residential rates available to customers is attached at Appendix 1.
These policy objectives include the following: (1) ensure net cost recovery for Electric Vehicle load at non-residential locations, taking into consideration that these costs may change over time as the Electric Vehicle market develops and the charging behavior for a larger market of Electric Vehicle drivers emerges; (2) simplify rate attributes for early market Electric Vehicle charging facility hosts; (3) enable customer choice with respect to rate options and metering arrangements; and (4) provide a transparent, dynamic price signal to electric vehicle service providers that reflects the higher costs of service for Electric Vehicles charging during hours of peak demand and the lower costs of service for Electric Vehicles charging during hours of reduced demand.
Currently, when a non-residential customer installs an electric vehicle charging facility, the electricity consumed at the charging station is measured along with all other usage that is connected to the same meter and all the electricity usage at the meter is subject to the same rate schedule. (SCE November 12, 2010 comments at 19; SDG&E November 12, 2010 comments at 12; PG&E November 12, 2010 comments at 6.) In the non-residential setting, one utility, SCE, also offers two separately metered time-of-use non-residential charging facility rates, rate schedules TOU-EV-3 and TOU-EV-4.
Based on the objectives noted above and the comments by parties, we find that, in the near term, charging equipment located at a non-residential customer premises should take service under the non-residential tariffs for which that customer would otherwise qualify. The only exception to this is PG&E's Schedule A-1(A) and A-1(B). These rate schedules include a relatively high usage limit of 200 kW. In addition, neither rate schedule includes a demand charge and, while schedule A-1(B) includes time-of-use rates, the rate differential is minimal. As a result, these two rate schedules fail to achieve the policy objectives noted above, most notably, reflecting the higher costs of service for charging Electric Vehicles during hours of peak demand. Therefore, unless modified, PG&E's Schedule A-1(A) and A-1(B) will not be available to electric vehicle service providers.
We understand that different entities may own the charging equipment located on a non-residential customer's premises. (SCE December 3, 2010 comments at 5; SDG&E November 12, 2010 comments at 12.) In the event that the owner of the charging equipment is an electric vehicle service provider, we find that the utility should treat the electric vehicle service provider offering charging services no differently than other similarly situated non-residential customers. By way of clarification, however, we note that curbside charging facilities, i.e., charging facilities located at street curbs and in areas close to public street lamps, are not eligible for street lighting rates, per existing tariff terms of service.
NRDC recommends that the Commission require, as a precondition of service, that an electric vehicle service provider's customers be informed of the costs of the electricity portion of the services provided by an electric vehicle service provider. NRDC is concerned that unless Electric Vehicle owners know the cost of electricity when re-charging their vehicles at a location operated by an electric vehicle service provider, they will not respond to the price signals and thus will not face appropriate incentives to charge their vehicles off-peak. For the reasons set forth below, we decline to adopt NRDC's recommendation at this time.
As explained in D.10-07-044, "the rate that an electric vehicle charging provider pays to the utility will be a cost of doing business that the charging provider may pass on to its customers or absorb. The charging provider will have a strong incentive to operate its business in a manner that is compatible with the needs of the electric grid." (D.10-07-044 at 27.) We find this incentive is sufficient for Electric Vehicle load and other load and do not find it is necessary to explicitly require electricity costs be precisely passed through to the vehicle owner using the electric vehicle service provider's charging services.
Moreover, the time-of-use price embedded in existing non-residential rate schedules are designed to send an appropriate price signal to a customer for electric usage at the non-residential premises, including when charging an Electric Vehicle with a non-residential customer's charging equipment. As a result, on-peak charging, to the extent it occurs, will be priced to recover the underlying cost of providing service at peak times. Similarly, to the extent that demand charges apply, they also convey price signals regarding infrastructure costs, and ensure cost recovery from those responsible for creating those costs.
In addition, we seek to ensure that charging-related infrastructure costs are shared by bundled and unbundled electric customers. To achieve this goal, we continue to employ cost-of-service ratemaking in setting the rate components for all the utilities' distribution customers, including Electric Service Providers and Community Choice Aggregators. Rate design should reflect any additional distribution system costs that result from peak Electric Vehicle charging that impose demands on any distribution-constrained facilities (including, potentially, time-variant distribution charges). For example, it may also be appropriate to revise demand charges in the non-residential setting to more accurately reflect costs imposed on the electric system by Electric Vehicle load.
For all these reasons, we find that utilities should treat electric vehicle service providers who offer charging services to the public, subject to the specific exceptions identified herein, no differently than other non-residential customers, including charging facility hosts that offer Electric Vehicle charging services to private tenants or employees.
5.3. Rate for Non-Residential "Quick Charging"
The August 20, 2009 OIR noted that Electric Vehicle consumers can choose from several different voltage options for Electric Vehicle charging. The voltage options differ from each other with regard to the amount of power that the electric vehicle service equipment draws from the electric system, which, in turn, impacts the amount of time it takes to provide an Electric Vehicle battery with a full charge. The different voltage options include Level 1 charging, which occurs at 120 volts and relies on a standard 120 volt outlet, and Level 2 charging, which occurs at 240 volts and typically draws 7.2 to 9.6 kilowatts depending on the amperage. Level 2 could draw as much as 19 kilowatts but this scenario is not expected to be typical.16
Another Electric Vehicle charging voltage option is referred to as "quick charging." Quick charging facilities, also known as direct current charging facilities, are designed to charge an electric vehicle battery to 80 percent capacity in approximately 30 minutes by drawing as much as 20 to 200 kilowatts or even more, 50 to 250 kilowatts. As a result, quick charging facilities place a considerably higher kilowatt demand on the electric system than even the fastest Level 1 or Level 2 charging. It is expected that quick charging will most commonly be available at non-residential sites or electric vehicle service provider charging spots and will function similarly to a gasoline filling station.
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.
5.4. Future Review of Rates
Many parties supported addressing Electric Vehicle rate design issues in the next general rate case cycle for each utility. DRA stated, "the Commission should revisit Electric Vehicle rate design in 2013 to evaluate whether changes are needed to facilitate Electric Vehicle adoption and/or ensure that Electric Vehicle-related cost responsibilities are equitably assigned. The Commission should direct the utilities to reflect the guidance from a 2013 Electric Vehicle rate design proceeding in their next GRC phase 2 rate design proceeding(s)." (DRA November 12, 2010 comments at 5.) The EVSP Coalition stated that the Commission should revisit existing Electric Vehicle rates after it has obtained a sufficient understanding of consumer Electric Vehicle usage and charging by early adopters. Two studies that will yield instructive results are Ecotality's Electric Vehicle Project and Coulomb's ChargePoint America. (EVSP Coalition November 12, 2010 comments at 7-8.)
We agree that Electric Vehicle rate design should be revisited. We find 2013 - 2014 to be a reasonable time frame to review the utilities' Electric Vehicle rates. By 2013, additional information will exist about Electric Vehicle charging load profiles, the costs and benefits of Electric Vehicle charging, and consumer response to Electric Vehicle time-of-use price differentials. The Commission will also have more information on the extent to which all commercial customers must take service under time-of-use rates.17 The expiration of the restrictions placed on the permissible options for residential customers for mandatory time-variant rates by AB 695 will also start to expire in 2013 and, as a result, open up more rate design possibilities.
Based on the utilities' current general rate case schedules set forth in
D.89-01-040, as modified, PG&E will file phase 2 (rate design) of its 2014 General Rate Case in early 2013. SCE and SDG&E will be filing their 2015 General Rate Cases in early 2014. To put the review of Electric Vehicle rate design on approximately the same schedule for all three electric utilities, we direct PG&E to include Electric Vehicle rate design proposals in its 2014 General Rate Case and direct SCE and SDG&E to file Electric Vehicle rate proposals in Rate Design Window applications in 2013, as provided for and in accordance with the schedule in D.89-01-040. (D.89-01-040, 30 CPUC2d 576, 579.)
In these filings, each utility is directed to include analysis of Electric Vehicle charging load profiles, the costs and benefits of Electric Vehicle integration and charging, and consumer response to time-of-use price differentials.
13 SCE Electric Tariff Rate Schedule TOU-EV1 (2 meters) at: www.sce.com/NR/sc3/tm2/pdf/ce114-12.pdf; SCE Electric Tariff Rate Schedule
TOU-D-TEV (1 meter) at: www.sce.com/NR/sc3/tm2/pdf/CE324.pdf; PG&E Electric Tariff Rate Schedule E-9a (1 meter) at: www.pge.com/tariffs/tm2/pdf/ELEC_SCHEDS_E-9.pdf; PG&E Electric Tariff Rate Schedule E-9b (2 meters) at: www.pge.com/tariffs/tm2/pdf/ELEC_SCHEDS_E-9.pdf; SDG&E Electric Tariff Rate Schedule EV-TOU (2 meters) at: www.sdge.com/tm2/pdf/ELEC_ELEC-SCHEDS_EV-TOU.pdf; SDG&E Electric Tariff Rate Schedule EV-TOU2 (1 meter) at: www.sdge.com/tm2/pdf/ELEC_ELEC-SCHEDS_EV-TOU-2.pdf.
14 SB 695, effective October 11, 2009 as an urgency measure, amended, among other sections, § 80110 of the Water Code and § 745 of the Pub. Util. Code to permit the Commission to authorize limited rate increases on 130% of the then existing baseline quantities but prohibits the Commission from authorizing mandatory or default time-of-use with or without bill protection for residential customers prior to January 1, 2013. Legislative restrictions ease on mandatory time-of-use pricing staring January 1, 2013.
15 PG&E's E-9 rate was also a mandatory rate, not opt-in. However, in PG&E Advice Letter 3751-E, filed November 2, 2010, PG&E requested a modification of Electric Schedule E-9 to make the rate optional for customers. Advice Letter 3751-E was approved by the Commission effective December 2, 2010.
16 Additional information on Level 1 and Level 2 charging is found in the August 20, 2009 OIR at 10-11 and the Rates Staff Paper at 21.
17 Time-of-use rates are in most instances mandatory for commercial customers registering over 500 kW of monthly demand. Demand charges are typically associated with these time-of-use rates. For commercial customers registering monthly demand under 500 kW, time-of-use rates are currently optional.
