Because transportation is the largest single source of greenhouse gas emissions in California, we support new innovative strategies to promote the seamless transition of the transportation sector to increased reliance on Electric Vehicles. In preparation for this transition, electric utilities and other parties identified a need for a process to alert utilities when customers purchase Electric Vehicles. The utilities explained that they need to know the location where the Electric Vehicle charging will likely occur in order to thoroughly prepare for Electric Vehicle charging in their service territories and avoid adverse impacts to the electric grid. The California Plug-In Electric Vehicle Collaborative identified a similar need.11
In some instances, an Electric Vehicle buyer might voluntarily inform the utility of the physical location of charging. Electric Vehicle buyers are motivated to contact utilities to, for example, obtain service under an Electric Vehicle electric rate schedule. Electric Vehicle buyers have little motivation, however, to contact a utility for the purpose of notifying utilities of the location of the Electric Vehicle charging. In addition, no formal standardized notification program exists so that a utility can identify all Electric Vehicles being introduced into their service territories.
Utilities pointed to a number of benefits of some type of notification process. Most critically, if a utility knows an Electric Vehicle customer plans to charge at home, then the utility can study the adequacy of the local distribution system in advance and upgrade the infrastructure if needed. Obtaining information concerning the identity of the Electric Vehicle customer has other benefits as well. If a utility can identify Electric Vehicle owners, then the utility can target consumer education and outreach to appropriately advise the Electric Vehicle owners of the benefits of time-of-use rates that reflect the cost of charging on-peak and on the economics of Electric Vehicle ownership and operation. In other words, with timely notification to the utility that an Electric Vehicle will be charging in its service territory, the utility can address potential reliability problems, keep infrastructure costs down, and assist, as appropriate, with ensuring that Electric Vehicle owners have positive experiences with Electric Vehicles and maximize the benefits of these vehicles.
Other parties also noted the importance of a utility notification process and explained ongoing efforts to establish such a process. For example, as of December 2010, GM implemented a voluntary utility notification system. GM also pointed out that any notification system must be flexible enough to allow for refinements during early Electric Vehicle commercialization and projected growth. SCE, PG&E, and SDG&E proposed a statewide notification process, referred to as a data clearinghouse, to help notify utilities of customer purchases of Electric Vehicles, thereby giving utilities more time to adjust their electrical systems to meet Electric Vehicle load growth. In connection with this proposal, SCE, PG&E, and SDG&E requested Commission approval of initial funding to support the evaluation of the data clearinghouse.
NRDC expressed support for a notification process. CFC requested Commission scrutiny of data-related privacy issues. DRA urged the Commission to reject funding on the basis that ratepayers should not bear the cost of the initial evaluation for the utilities' Electric Vehicle data collection.
The merits of a notification process and the utilities' request for cost recovery are addressed below
4.1. Assessment Report
We conclude that, given the importance we place on avoiding adverse impacts to the electric system, ensuring safety, and efficiently managing the grid, the proposals for a notification system could prove to be solution to the challenge of Electric Vehicle growth, provided privacy concerns are adequately addressed. We are encouraged that, while no formalized standardized information exchange program currently exists, utilities are presently exploring bilateral agreements with auto manufacturers, such as GM, to establish voluntary arrangements that would provide utilities with notice when customers in their service territories purchase Electric Vehicles. As GM explained, it currently employs an opt-out style questionnaire seeking permission to share address level data with utilities to ensure grid reliability. Since December 2010, it has shared hundreds of addresses with California investor-owned utilities and publicly-owned utilities. This system could, perhaps, be a model to build upon for an expanded notification system and we are encouraged by the progress of GM, the utilities, and others in this regard.
We want to ensure that stakeholders continue their progress in the development of a notification system. Accordingly, we direct SCE, PG&E, and SDG&E to collaborate with stakeholders, perhaps relying on existing forums established by the California Plug-In Electric Vehicle Collaborative, to further develop such a system. To enable the Commission to monitor progress in this area, we direct the utilities to prepare an assessment report that sets forth potential notification options, the merits and projected costs of these options, and implementation scenarios. The assessment report must also recommend a preferred option going forward and explain how other stakeholders, if any, will participate in the notification system. The options detailed in the report may require participation by the Department of Motor Vehicles (DMV) or other government agencies to identify and address any privacy concerns that may arise due to the sharing of relevant information. 12 Options may include, but are not limited to, reliance on statewide stand-alone organizations. Other potentially lower cost options could incorporate a Graphic Information System with a mapping function and other low cost automated approaches.
This assessment report must be filed by utilities as a compliance report in this proceeding. The timeline for filing this report is set forth below.
4.2. Privacy Concerns
Parties raised concerns about privacy implications associated with the creation of a notification system. Any data made available via a notification system must be consistent with all applicable privacy laws. Due to privacy and customer consent concerns, we do not necessarily envision this system to be employed as a marketing or promotional tool for Electric Vehicles. The goal of this notification system remains safe, reliable, and efficient management of Electric Vehicle integration into the electric grid. The assessment report to be filed in this proceeding must address how utilities will handle privacy concerns.
We deny the requests by SCE, PG&E and SDG&E to authorize additional funding through this decision to cover the costs of the development or implementation of a notification system. Our expectation is that utilities will not require incremental funding to develop and participate in a notification system. However, utilities are not precluded from seeking recovery of reasonable costs of any utility notification systems in future rate cases.
4.4. Timeline - Assessment Report
To ensure this notification system develops in a timely fashion, the utilities must jointly file the assessment report in this proceeding within 150 days of the effective date of this decision. During this 150 day period, utilities must seek the involvement of the Commission's Energy Division Staff and provide regular updates to Energy Division Staff on a schedule to be determined by Staff.
4.5. Future Goals
We agree with GM that a national notification system, rather than a California-specific data system combined with various regional data systems, may ultimately be preferable. In the absence of a national notification system, it will likely be more difficult for utilities to effectively adjust their electric systems to account for Electric Vehicle load growth. By establishing a path toward a California statewide notification system, we seek to support the development of a national notification system.
11 Strategic Plan at 47.
12 Proposed legislation, (Senate Bill (SB) 859 Padilla (2011-2012 Reg. Sess.), as introduced on February 18, 2011) would allow the Department of Motor Vehicles to release an Electric Vehicle owner's residential address to an investor-owned utility, publicly-owned utility, and their respective agents if that utility uses the information only for the purpose of tracking electric vehicle charging points.