Realizing the ambitious goals for Electric Vehicles in California requires effective education and outreach to increase consumer awareness and demand for Electric Vehicles. Education and outreach is particularly important in this market because lack of consumer experience with Electric Vehicles may repress demand. Education and outreach can inform consumers, maximize consumer satisfaction, facilitate installation of home charging equipment, and, in concert with time-of-use rates, further encourage off-peak charging of Electric Vehicles. For these reasons, the August 20, 2009 OIR requested parties to comment on what entities and programs could best facilitate convenient and timely installation of electric vehicle service equipment and educate Electric Vehicle owners about the economic and environmental benefits of off-peak charging.36
In response to this question, parties generally agreed that a collaborative approach on education and outreach between all those involved, including Electric Vehicle manufacturers, dealers, charging equipment manufacturers, installers, local inspectors, Electric Vehicle service providers, utilities, state agencies and local government, was needed. Education and outreach programs will be more effective if customers receive similar messages from multiple sources. Accordingly, we expect utilities to work collaboratively with all relevant stakeholders to deliver consistent messages to potential and existing Electric Vehicle users.
10.2. Utility's Role
Parties also agreed that of the many different entities involved in the Electric Vehicle industry, utilities could play a unique role in communicating information to potential and existing Electric Vehicle owners Some parties suggested that, because of the utilities' ongoing customer communications programs, utility participation could minimize the cost of Electric Vehicle education and outreach. (Environmental Coalition November 12, 2010 comments at 4; CFC November 12, 2010 comments at 11.)
In response, utilities agreed that they could play an important role in education and outreach, and they urged the Commission to permit proactive customer education on charging equipment options, load management, and Electric Vehicle rate options. (SCE October 5, 2009 comments at 56.) Utilities did not all endorse the Commission's adoption of specific guidelines to define the scope of the utility role. PG&E, for example, cautioned against limiting their role on education and outreach too early in the developing Electric Vehicle market. (PG&E November 12, 2010 comments at 5.) Instead, PG&E encouraged the Commission to address guidelines after further market development has taken place to avoid discouraging utility communication on Electric Vehicle issues. (PG&E December 3, 2010 comments at 5-6.) To a certain extent, SDG&E concurred. (SDG&E December 3, 2010 comments at 6.)
CFC acknowledged the utility's key role in conducting Electric Vehicle education and outreach but suggested that an independent entity free from potentially conflicting business interests, such as the Commission, would be more appropriate. (CFC November 12, 2010 comments at 11.) TURN expressed concern that utilities might spend excessively on the mass-marketing of the societal and environmental benefits of Electric Vehicles to the general public. (TURN December 3, 2010 comments at 4.)
Regarding the utilities' role in education and outreach, we agree with those parties that suggest that utilities have an important role to play in customer education and outreach. As the Electric Vehicle market develops, utilities in collaboration with other stakeholders will need to provide proactive and targeted customer education on certain charging equipment issues, including load management and Electric Vehicle rate options.
We direct the utilities to proactively collaborate with other stakeholders to develop an approach to customer outreach and education. Customers should be aware of the availability, cost, and environmental impacts of Electric Vehicles and available metering options, rate plans, and charging options before they make their service selections.
We also direct the utilities to pursue a targeted outreach policy, meaning we do not support mass marketing efforts but, to control costs, expect the utilities to target customers with an interest in Electric Vehicles.
We also find that now is the appropriate time to adopt guidelines to define the scope of the utilities' role in education and outreach as these guidelines are critical in initiating a collaborative process, overseeing ratepayer costs, and providing clarity concerning the roles of the various stakeholders and the utilities in the new Electric Vehicle market.
10.3. Neutrality & Integration with Utility's Primary Responsibilities
In furtherance of defining the scope of the utilities' role, the assigned ALJ issued a ruling seeking comments on proposed guidelines. (ALJ Ruling October 27, 2010 at 4-5.) Our adopted guidelines are set forth in Section 10.4. These guidelines are based on comments by parties in this proceeding, our obligations under § 740.2, and our prior experience with similar guidelines in the low emission vehicle context.
Based on parties' comments, broad consensus existed on the scope and tone of the utilities' role in education and outreach. Parties generally agreed that utilities should not express preferences for vendors, installation providers, Electric Vehicle service providers and vehicles or vehicle types. We agree. Regarding these and similar topics related to Electric Vehicles, utility communications must be neutral. Regarding safety, reliability, and off-peak charging, neutrality is not required.
Parties also generally agreed that utilities should undertake education and outreach as part of their broader responsibilities to ensure the Commission's goals of grid reliability, safety, load management, and greenhouse gas emission reduction and other AB 32-specific environmental goals.
NRDC suggested that the scope of communication should "direct utilities to play a role in ensuring that customers understand the environmental, energy efficient, financial, and system benefits of PEVs" because these issues are consistent with the "traditional responsibilities" of a utility. (NRDC
December 3, 2010 comments at 3-4.)
In contrast, the EVSP Coalition raised concerns that the utilities' education and outreach programs may result in an unfair competitive advantage over Electric Vehicle service providers. The EVSP Coalition recommended restricting any utility communication to utility-specific information. (EVSP Coalition December 3, 2010 comments at 5-6.) Similarly, as mentioned above, CFC raised concerns that utilities' work in this area may result in conflict of interests.
In comments on this topic, SCE clarified that the goal of Electric Vehicle-focused education and outreach was not to support utilities' preferences. (SCE reply comments December 3, 2010 at 6-8.) We agree with SCE's clarification on this matter. The utilities' role in Electric Vehicle education and outreach is part of their broader responsibilities but is not to express preferences.
Moreover, we find that the guidelines we adopt today are consistent with our obligations under § 740.2 and the earlier enacted legislation set forth in §§ 740.3 and 740.8.37 To promote the directives set forth in theses statutes, we adopt education and outreach guidelines that seek to engage utilities in reducing barriers to the widespread deployment of Electric Vehicles while at the same time directing utilities to conduct education and outreach efforts on the safety and reliability of the electric system and on cost reduction, including through environmental initiatives, such as equipment charging options, load management, and Electric Vehicle rate options. (Pub. Util. Code § 740.2.) These guidelines do not address other topics addressed by §§ 740.3 and 740.8, including costs for development of "equipment or infrastructure" and the extent of ratepayers' interest in such policies. (Pub. Util. Code §§ 740.3(c) and 740.8.)
The guidelines we adopt today are also generally consistent with prior Commission precedent in the area of low emission vehicles. In D.05-05-010,38 the Commission determined that it would support reasonable funding for the utilities' low emission vehicle customer education programs, provided that the customer education programs primarily furthered the goals of ratepayer safety and reliability of electric and natural gas systems, controlled ratepayer costs, and informed customers about related load impacts and methods for mitigating them in a manner that is responsive to their and the public's needs. (D.05-05-010 at 12, 14, and 16.) However, in D.05-05-010, education and outreach regarding related social and environmental matters were limited to those communications that were "incidental" to those communications primarily focused on safety, reliability and cost reductions. We find this limitation too restrictive today, given our efforts to promote policies in this decision to actively support reduction of greenhouse gas emissions through Electric Vehicle adoption and deployment.
10.4. Guiding Principles - Utility Education and Outreach
Based on the prior discussion, we adopt the following principles and requirements to guide utility education and outreach:
a. Each utility has an obligation to use funds to provide its customers with information regarding the choices available for metering arrangements, rates, demand response programs, Electric Vehicle service equipment, equipment installation, safety, reliability, and off-peak charging.
b. Each utility has an obligation to use funds for targeted Electric Vehicle education and outreach to educate customers about the environmental and societal benefits of Electric Vehicles consistent with the state's policy goals related to the reduction of greenhouse gas emissions set forth in AB 32.
c. Due to the potential for conflicts of interest, the types of information described in (a) and (b) must be communicated in a competitively neutral manner without value judgments or recommendations.
d. Regarding safety, reliability, and off-peak charging, utilities may present information and make value judgments and recommendations. The neutral communication requirement does not apply because safety and reliability are primary utility responsibilities, and information on safety, reliability, and off-peak charging is unlikely to raise conflicts of interest or anti-competitive behavior.
We direct Energy Division to monitor the utilities' use of education and outreach funds and to identify any examples of utility violations of the Electric Vehicle communication principles and requirements above. As time goes on, we may revisit the parameters of utility Electric Vehicle education programs in response to new market conditions and revise these guiding principles and requirements accordingly.
10.5. Costs of Utility Education and Outreach
Currently, the utilities' costs related to Electric Vehicles are supported by their low emission vehicle programs. While we acknowledge parties' comments about appropriate customer education funding levels, we will not address funding in this rulemaking. We agree with SCE that "[a]ttempting to set spending limits in the context of this rulemaking is inappropriate" and this request instead belongs in general rate cases, where low emission vehicle programs funding levels are currently set. (SCE December 3, 2010 comments at 8.) Likewise, utilities should implement the required education and outreach guidelines despite the unavailability of additional funding now. Consistent with the Commission's practice, the utilities should request approval for funding for ongoing or future education and outreach costs within their general rate cases or at another appropriate time. In such requests, costs of Electric Vehicle education and outreach must be separately identified from any future costs associated with a utility-Electric Vehicle notification process.
36 August 20, 2009 OIR at 27.
37 Pub. Util. Code § 740.8 provides, in full, as follows: As used in Section 740.3, "interests" of ratepayers, short- or long-term, mean direct benefits that are specific to ratepayers in the form of safer, more reliable, or less costly gas or electrical service, consistent with Section 451, and activities that benefit ratepayers and that promote energy efficiency, reduction of health and environmental impacts from air pollution, and greenhouse gas emissions related to electricity and natural gas production and use, and increased use of alternative fuels.
38 Opinion on Contents of Utility Low Emission Vehicle Program Application, Application 02-03-047 (SDG&E), Application 02-03-048 (SCE), and Application 02-03-049 (PG&E) effective May 10, 2005 (addressing Low Emission Vehicle programs and contents of future applications for seeking funding of such programs).