We now turn to whether utilities should be permitted to own electric vehicle service equipment. We take into consideration our finding in D.95-11-035 that utilities could not recover costs related to electric vehicle service equipment from ratepayers. We also consider the benefits of utility ownership of electric vehicle service equipment. For example, NRDC and SDG&E suggested utility ownership of this equipment could provide safety advantages, reduce customer cost, and support utility notification of location where vehicles will be charged.
We do not find convincing evidence that utility ownership of electric vehicle service equipment will result in safety advantages over electric vehicle service equipment owned by customers or other entities. Municipal governments already have permitting requirements that review project installations for their safety merits. Additionally, national standards on electric vehicle service equipment couplers and other equipment features ensure manufacturers' adherence to safety standards.
We also find speculative the assertion that utility ownership of electric vehicle service equipment will reduce customer costs. Although the utilities could benefit from economies of scale by purchasing electric vehicle service equipment in large numbers, the utilities are not the only entities that could make large scale purchases. Furthermore, the potential costs savings of a "single buyer" approach would, in all likelihood, limit customer choice and, perhaps, even dampen the competition that may yield cost reducing innovation. As such, we do not find that the benefits of utility ownership of electric vehicle service equipment outweigh the potential for competitive limitations resulting from utility ownership. However, utilities may continue to own electric vehicle service equipment used to charge their own electric vehicle fleets or provide workplace charging for utility employees.
At the September 27, 2010 workshop, the utilities expressed a concern that prohibiting utility ownership of electric vehicle service equipment at this early stage of market development may result in underserved markets or market failure. Should utilities present evidence in an appropriate proceeding of underserved markets or market failure in areas where utility involvement is prohibited, we will revisit this prohibition. Should the Commission revisit this issue, we will revisit the concerns outlined above, among others, including the potential cost-subsidization implications of any utility proposal to own public electric vehicle service equipment.
To the extent that SDG&E is requesting funds to support its Public Access Charging Facilities in A.10-12-005, SDG&E's general rate case proceeding, SDG&E must provide convincing evidence that our prohibiting SDG&E ownership of electric vehicle service equipment at this early stage of Electric Vehicle market development would result in underserved markets or market failures in areas where non-utility entities fail to properly serve all markets.