6. Electric Vehicle Metering
We now identify the metering arrangements available to Electric Vehicle customers, adopt policy guidelines to assist us in evaluating the merits of various Electric Vehicle metering arrangements in the residential and nonresidential setting, and review the interplay between Electric Vehicle meters and customer-side photovoltaic (PV) generation. Lastly, we address one of the more controversial issues in this proceeding, utility ownership of electric vehicle service equipment.
6.1. Metering Options
The Utility Role Staff Paper explored available and future metering options for Electric Vehicles and identified three categories of metering arrangements for Electric Vehicles:
(1) Single metering - Single metering arrangements which measure and bill Electric Vehicle load as part of the total customer load using the pre-existing meter.
(2) Separate metering - Separate metering arrangements requiring an additional meter dedicated to measuring Electric Vehicle load. This arrangement measures Electric Vehicle load as if the load were a separate service account, and enables the Electric Vehicle load to be billed separately from other non-Electric Vehicle load served on the premises.
(3) Submetering - Submetering arrangements in which a submeter measures Electric Vehicle charging apart from the primary meter. This is similar to separate metering in that it uses a dedicated meter for the Electric Vehicle load. However, the submeter is typically located on the customer's side of the primary meter, making it possible to bill Electric Vehicle load and the remaining household load on different rate schedules. At the present time, submetering is not an available option. In order to facilitate timely development of cost-effective submetering equipment, we direct the utilities to collaborate with other stakeholders to craft a submetering protocol in Section 6.7.
6.2. Metering Policy Goals
The record in this proceeding supports the Commission's consideration of the following specific policy goals for Electric Vehicle metering: (1) customer choice, (2) adequate data and technological functionality, (3) innovation and accommodating technological advances, (4) common technology standards, and (5) minimizing costs. Notably, these goals are generally consistent with the broader goals of the California Plug-In Electric Vehicle Collaborative's strategic plan.
Parties overwhelmingly favor customer choice as the primary policy goal in utility metering. We agree and adopt a metering policy that promotes customer choice and does not foreclose options for customers as the Electric Vehicle market develops. This flexibility will best support customer investment in metering technological and infrastructure. Our policy will both allow customers to identify options that best serve their needs, ensure consumer experiences with Electric Vehicles are positive, and help support the on-going development of metering technology and services to improve Electric Vehicle charging.
Within the Electric Vehicle metering context, we find that achieving adequate technology functionality is important to ensure that meters meets specific minimum standards to ensure the smooth integration of Electric Vehicle charging into the electric grid. More advanced metering functions, such as demand response, can be achieved through a variety of existing technologies but these functions go beyond what is, at a minimum, needed today. As such, we will not require meters to incorporate these more advanced functions now. We note, however, that numerous components of the Electric Vehicle charging process - including the vehicle, the electric vehicle service equipment, and Home Area Networks18 (HAN) - may in the near future be able to perform additional and more advanced communication and measurement functions consistent with the utilities' obligation to ensure that meters are Advanced Metering Infrastructure (AMI) and HAN enabled. (See, e.g., Smart Grid Rulemaking, R.08-12-009.)
We encourage innovation in metering functionality with flexibility to take advantage of emerging Electric Vehicle technologies. Accommodating future data needs and yet-to-be-developed technologies could present opportunities to reduce costs and improve the ability of Electric Vehicle meters to advance environmental and social goals, such as climate change. However, some specific future data needs, such as potential tracking of road taxes and California Air Resources Board's Low Carbon Fuel Standard19 credits, have yet to be clearly defined. Therefore, we cannot assume that a specific grade of meter, such as a meter that produces data accurate and detailed enough to be used for billing purposes (referred to as a "revenue-grade" meter), will be required for these purposes. Nevertheless, overall, we seek to encourage innovation in metering functionality. As data is collected and metering functionality improves, the Commission will continue to collaborate with the California Air Resources Board on topics that overlap with greenhouse gas emission reduction and electric vehicles, including the Low Carbon Fuel Standard, to ensure that ratepayer benefit is maximized through the electric vehicle market.
The Commission noted the importance of interoperability standards for the Electric Vehicle market in the January 12, 2010 Assigned Commissioner's Scoping Memo. Additionally, in the Smart Grid Rulemaking, R.08-12-009, Commission initiated a review of standardization issues generally. In short, we recognize the vital importance of national standardization in keeping equipment costs down.20 (D.10-06-047 at Conclusion of Law 5.) R.08-12-009 will continue to serve as the forum for the Commission's consideration for national interoperability of Electric Vehicles and the charging equipment with other parts of the electric system.
6.3. Metering Options - Residential Locations
In evaluating whether utilities should continue to make available all existing metering options to Electric Vehicle customers, we are guided by the above policy goals.
The Utility Role Staff Paper suggested that, in the short-term, utilities encourage residential customers to use single metering (whole-house metering), i.e., no separate Electric Vehicle meter or submeter. Staff's recommendation was based on its conclusion that Electric Vehicle-specific metering functionality requirements were still forming so until all Electric Vehicle metering and data requirements are better understood, utilities should encourage customers to use a single meter arrangement for Electric Vehicles to avoid potential stranded costs. (Utility Role Staff Paper at 36.) Staff also expressed concern that separate Electric Vehicle meters installed in the near-term might become redundant and unnecessary as relatively inexpensive and fully functional submetering technology becomes available.
During workshops and in comments, parties generally recommended that the various metering arrangements be made available to all customers. (PG&E September 20, 2010 comments at 1-2.) Some parties disagreed with the Staff recommendation that single metering be encouraged by utilities in the
short-term. These parties contend that a policy that promotes single metering will place utilities in a more advantageous position versus electric vehicle service providers because Electric Vehicle customers will become accustomed to interacting with the utility on Electric Vehicle meter topics and customers will need to incur additional costs to move to a different arrangement, which might include a submeter or separate meter. (WSPA September 20, 2010 comments at 3.)
We find that the utilities should continue to make available all existing metering options to customers. Our finding emphasizes the importance of preserving customer choice in metering arrangements at this early stage of Electric Vehicle market development as a means of promoting customer satisfaction, encouraging technological advancement, and creating a level playing field for electric vehicle service providers. For these reasons, we conclude that, despite the benefits of single metering in terms of keeping initial equipment costs low, we will not direct the utilities to encourage single metering options as the preferred approach in the near-term. To facilitate additional metering options, we seek to actively promote development of submetering options and establish a process to create an Electric Vehicle submeter protocol in Section 6.7.
6.4. Metering Options - Multi-Dwelling Units and
Non-Residential Locations
In the multi-dwelling unit (MDU) setting and non-residential locations, in contrast to the residential setting, the Electric Vehicle owner may not be the utility's electric customer. SCE and Coulomb described examples in the MDU setting, such as apartment complexes, and in the non-residential setting, such as office buildings, in which multiple Electric Vehicle owners use the same charging equipment. These parties raised questions about appropriate metering arrangements and the potential advantages of submetering is such settings. We find that submetering at MDUs and workplaces requires additional evaluation to determine what protocols and policies, if any, are needed to support these options, and we direct that MDU and non-residential metering issues be included among the submetering issues addressed in the Electric Vehicle submeter protocol process, which we discuss in Section 6.7.
6.5. Metering and Photovoltaics
We recognize that some Electric Vehicle owners will also have PV panels installed on their premises. We asked parties to consider whether this situation raised metering issues that require our specific consideration. In response, parties indicated that any of the three metering options could be utilized by PV customers who also own Electric Vehicles. (Utility Role Staff Paper at 20.) We find that PV customers should be provided with the ability to choose from a range of metering options to accommodate their data requirements. Because any of the existing metering categories can meet PV data requirements, we decline to adopt any further requirements on the integration of Electric Vehicles and PV metering at this time.
6.6. Ownership of Meters
Within the evolving Electric Vehicle market, the Utility Role Staff Paper identified two key customer-utility boundary issues related to metering: ownership of the electric vehicle service equipment and ownership of an Electric Vehicle submeter. The customer-utility boundary, which determines ownership, has generally been defined in the single-meter ssetting. The meter that is used to measure a customer's billable usage and the equipment on the utility's side of the meter is owned by the utility, while equipment located on the customer's side of the meter is owned by the customer.21 (Utility Role Staff Paper at 27-28.)
Our analysis is guided by two prior Commission decisions adopted in 1993 and 1995. In D.93-07-054, the Commission provided policy guidance for low and zero emission vehicles and identified four criteria for determining whether utility investments in low emission vehicle refueling infrastructure are consistent with the interest of ratepayers. These criteria included the following: 1) whether the investments contribute to reliable and efficient utility service; 2) whether the investments provide safe service; 3) whether the investments provide environmentally and socially responsible utility service; and 4) whether the investments maintain reasonable rates.
(D.93-07-054 at 19-24.)
In D.95-11-035, the Commission relied on the criteria adopted earlier in D.93-07-054 to deny requests by utilities for Commission approval of additional ratepayer funding to support the deployment of low emission vehicle equipment, including electric vehicle service equipment. In denying the utilities' request for funding, the Commission found that because low emission vehicles - as opposed to utility infrastructure to support these vehicles - are not a monopoly, utility participation in the low emission vehicle market should not be as a protected monopolist. The Commission also found no clear ratepayer benefit stemming from a utility's ownership of electric vehicle service equipment. In short, the Commission found that utility shareholders should bear the costs of any electric vehicle service equipment and no reason existed for a utility to be the sole provider of the electric vehicle metering and recharging equipment. (D.95-11-035 at 15-19.) The Commission also prohibited regulated utilities from using ratepayer funds for charging infrastructure investments. (D.95-11-035 at 35.)
In this proceeding, Staff suggested that customer ownership of meters would allow customers to respond to technology changes and to directly incur the costs and, likewise, receive the benefits of adopting innovations in metering. Staff suggested that the effect of competition for meters could produce cost savings for customers. Staff also pointed to several disadvantages to customer-owned meters, including the potential for lack of standardization of metering functionality, the need to have a governmental agency verify meter performance, and elimination of the opportunities to reduce costs through utility economies of scale. Staff concluded that utilities should own the meters in the case of single or separate metering, but that the customer should be given the option to own the meter in the case of Electric Vehicle submetering. (Utility Role Staff Paper at 37.)
With the guidance provided by D.93-07-054 and D.95-11-035, together with the information provided by the Utility Role Staff Paper, we evaluate the ownership issues of Electric Vehicle meters and electric vehicle service equipment by turning to the previously identified metering policy goals: fostering customer choice, achieving specified minimum data and technological functionality, allowing for future technological advances, recognizing common technology standards, encouraging innovation, and minimizing cost. Our analysis follows.
In the case of single and separate Electric Vehicle metering, we continue to designate the meter as generally on the utility side of the customer-utility boundary. Changes to the ownership of single and separate meters used for Electric Vehicles would represent a change in general metering policies. Based on parties' comments, we do not find sufficient justification to adopt this approach for single or separate Electric Vehicle meters at this time. In the longer term, however, technological and communication advances may support customer-owned meters used for separate Electric Vehicle metering that is more consistent with our policy goals. Thus, we remain open to re-evaluating customer ownership of separate meters should the appropriate technology develop to reduce costs associated with customer-owned separate meters.
In the case of ownership of Electric Vehicle submeters, we find that
customer-ownership of submeters is consistent with all of our above-noted Electric Vehicle metering goals, especially those policy goals related to customer choice, supporting technological innovation and minimizing cost. For example, we anticipate that customer ownership of submeters will allow customers to take advantage of new metering technologies to support new billing methods. Therefore, we find that Electric Vehicle submeters should be treated consistent with the treatment of any other equipment located on the customer side of the meter.22
The primary meter, as opposed to the Electric Vehicle submeter, will remain under the ownership of the utility. A submeter would measure Electric Vehicle load and be used by the utility in its billing calculations. This arrangement will provide utilities with control over the total billing level and limit opportunities for fraud or meter tampering. Most likely, incidences of fraud would be limited to tampering with the submeter's calculation of the Electric Vehicle subload, which does not impact the utility calculation of the total load at the primary meter.
While some parties, including SMUD, PG&E, and SCE, identified several potential benefits of utility ownership, such as increased access and oversight of submeters, efficiency, and permitting access to the submeter market, we find that such benefits do not outweigh the above-noted benefits of customer ownership of submeters.
6.7. Electric Vehicle Submeter Protocol
As part of this proceeding, we asked parties whether an Electric Vehicle submeter protocol is needed to determine rules for customer-owned Electric Vehicle submeters and, if so, to identify stakeholders to be involved in the development of such a protocol, the issues to be addressed, and whether we might learn from our experiences in other Commission proceedings, such as the Direct Access metering protocol adopted in D.98-12-080.
Parties generally agreed that a need exists for an Electric Vehicle submeter protocol to determine rules for customer-owned meters. Parties suggested that some of the goals in establishing an Electric Vehicle submeter protocol should be to establish minimum functionality and communication requirements for any submeter used to measure Electric Vehicle load. Such a requirement would enable manufacturers and customers to be sure that the meters, whether purchased separately or included in the vehicle or as electric vehicle service equipment, are compatible with the utility billing and communication system. In addition, NRDC and PG&E stated that the process to develop an Electric Vehicle submeter protocol should include a range of stakeholders, including electric vehicle service providers, utilities, and government agencies. Parties also suggested that the California Department of Food and Agriculture will play a key role in any submeter process as the regulator of non-utility measurement devices used in commercial transactions.
We agree that a process is needed to develop an Electric Vehicle submetering protocol. We also agree with NRDC that the Electric Vehicle submeter protocol should create a framework that can incorporate emerging metering technologies and encourage innovation. The submetering category as defined here remains broad, and any Electric Vehicle submeter protocol should support the use of submeters in various physical locations, such as standalone customer-owned submeters, or in electric vehicle service equipment or a vehicle. We also agree that the California Department of Food and Agriculture will play a key role in regulating non-utility measurement devices so its participation in the Electric Vehicle submeter protocol process is crucial.
In this process, stakeholders should also examine mobile detachable meters23 as described in SDG&E's September 20, 2010 comments. The California Air Resources Board expressed a concern that on-board vehicle metering will be expensive, but others, including GM, found this conclusion premature. GM further suggested that on-board vehicle metering "could provide the most cost effective, communications capable, regulatory compliant and utility/customer friendly solution for measuring and recording" Electric Vehicle electricity consumption. (GM December 1, 2010 comments at 2.)
For this and other reasons, we are interested in the creation of an Electric Vehicle submetering protocol that does not prejudge the merits or functionality of future technology developments.
We agree with PG&E that a central purpose of the Electric Vehicle submeter protocol is to certify the accuracy of the devices used for utility billing of vehicle electricity consumption. The protocol need not address HAN devices unrelated to utility billing. While submeters may be HAN-enabled, establishing an Electric Vehicle submeter protocol that applies to HAN-enabled Electric Vehicle submeters does not affect the utility's separate and distinct role in authenticating or certifying the accuracy of other HAN devices.
In response to Coulomb's request that we consider a "lightweight" certification process for submeters, we defer to the California Department of Food and Agriculture. The comments submitted by California Department of Food and Agriculture recognized that the regulation of customer-owned meters generally falls under its purview. For this and other reasons, we strongly support the California Department of Food and Agriculture's participation in the Electric Vehicle submeter protocol process.
Finally, parties suggested that a protocol be developed quickly. We agree and direct the utilities to cooperate with stakeholders to form a working group to develop an Electric Vehicle submeter protocol that could be adopted by the Commission as revisions to PG&E and SCE Tariff Electric Rule 18 and SDG&E Tariff Electric Rule 19.
The utilities are to include in the working group, at a minimum, Commission Staff, California Department of Food and Agriculture, automakers, and electric vehicle service providers. The utilities shall hold at least one publicly noticed workshop and shall issue a public report following the workshop. The report shall be filed in this proceeding within 15 days of the workshop. The filing of the report will be a compliance filing in this proceeding.
On or before July 31, 2012, the utilities are directed to jointly file a Tier 2 advice letter proposing a submetering protocol. The filed protocol must achieve, at a minimum, the following: (1) support the use of submeters located in electric vehicle service equiment or on a vehicle, including mobile detachable meters, as described in SDG&E's comments on the Utility Role Staff Paper; (2) determine the technical performance requirements for any submeters; (3) identify the minimum communication functionality and standards; (4) describe how submeter data management will support and protect the security and privacy of Electric Vehicle user data collected by utilities and third party entities; (5) provide a methodology for settling disputes; (6) identify and adhere to all existing and applicable national standards for measurement and communication functions; and (7) develop rules for incorporating subtractive billing into submetering tariffs.24
We also recognize that the submeter protocol will likely rely on technology standards related to smart grid communications, including HAN communication standards, that have not been finalized. The submeter protocol process involves a diverse set of stakeholders and will likely raise new issues that would benefit from stakeholder input. To facilitate the development of a comprehensive protocol, the utilities must jointly submit to the Commission, on or before October 31, 2011, a report that will allow the joint implementation of comprehensive protocol by July 31, 2012. The report will detail how the protocol will be informed by relevant ongoing standard development processes and include the specific issues that the protocol will address.
6.8. Separate Meter Costs
Addressing cost allocation and recovery for utility-owned separate Electric Vehicle meters is important because a separate meter is presently the only viable option to physically segregate Electric Vehicle usage from household usage. Additionally, a separate meter is currently needed for certain Electric Vehicle time-of-use rates. At present, no uniform utility treatment of separate meter costs exists. PG&E assesses a "per meter charge"25 to establish a service point for a second meter. In addition, PG&E's existing optional Schedule E-9b for Electric Vehicle customers includes a monthly recurring meter charge of $0.21881, unless a customer has a Smart Meter. SCE also includes a customer charge to recover the cost of services for a utility-owned separate meter.26 In contrast, SDG&E does not have a separate meter charge for customers with separate Electric Vehicle meters, but recovers the cost of these meters through general distribution charges borne by all SDG&E ratepayers.27 During this proceeding, parties questioned whether the costs of separate utility owned meters to be used for Electric Vehicle charging should be borne by all ratepayers or the Electric Vehicle customer. We address this question below.
DRA and TURN noted that the basic provision of utility service to a standard single residential account does not include a second meter. (DRA December 3, 2010 comments at 3; TURN December 3, 2010 comments at 1.) As a result, the standard allowance for residential account service installations, borne by all ratepayers, does not typically include the cost of a second meter to segregate a particular customer load.28 PG&E pointed out, however, that a second meter may be part of the costs subject to allowances under Tariff Rules 15 and 16 and proposes to include the cost of the separate meter in the rate-based standard installation allowance pursuant to these Rules.
We find PG&E's approach to be inconsistent with current practice regarding allowances for typical residential accounts. While this decision adopts a narrow modification to the costs addressed in Rules 15 and 16, this decision does not intend those changes to modify the existing cost allocation associated with separate Electric Vehicle meters. The intent of the narrow tariff modification is to facilitate the transition to an Electric Vehicle market by allocating certain upgrade costs to the general body of ratepayers. These costs should be those strictly limited to those on the utility side of the meter and that are necessary to establish a basic Electric Vehicle charging capability. This narrow modification to Tariff Rules 15 and 16 is discussed further in Section 8.
We further find that placing the costs of existing separate Electric Vehicle meters on the general body of ratepayers may result in an unfair advantage for utilities relative to the non-utility electric vehicle service providers. In making this finding, we agree with the competitiveness concerns raised by the EVSP Coalition and Green Power Institute. We also rely on Pub. Util. Code § 740.3(c), which establishes that the Commission's policies shall "... ensure that utilities do not unfairly compete with nonutility enterprises."
NRDC supported spreading the costs of separate Electric Vehicle meters over the larger body of ratepayers because a customer's choice to avoid the increased meter costs associated with a separate Electric Vehicle meter at the point of purchase of an Electric Vehicle might create greater overall system costs in the long term. NRDC suggests that, in the absence of a separate Electric Vehicle meter, customers may be less likely to charge their Electric Vehicle off-peak. However, because SCE, PG&E, and SDG&E customers do not pay a substantial one-time charge for a separate meter, we find NRDC's concern unlikely to arise.
Other parties suggested that initial capital outlays for separate Electric Vehicle meters could be mitigated by on-bill financing.29 However, on-bill financing is typically for customer-owned, non-residential facilities. Program eligibility restrictions may complicate this as a near-term option for residential customers. (SDG&E December 3, 2010 comments at 3.) For these reasons, on-bill financing is not a viable option for utility owned residential separate meters at this time.
Accordingly, we agree that if the individual utility customer chooses a separate metering option to obtain a particular Electric Vehicle rate, the customer (rather than all ratepayers) should bear the cost of the separate meter. We further support the use of monthly recurring charges to spread separate meter costs over time. In this manner, costs will not unduly discourage separate metering, and potential on-bill financing program restrictions are avoided. Lastly, we confirm that the utility retains ownership of the separate meter.
18 Home Area Network devices enable communication between various devices and the customer's electric meter.
19 More information about the California Air Resources Board's Low Carbon Fuel Standards are available at www.arb.ca.gov. The Low Carbon Fuel Standards are defined in Title 17 of the California Code of Regulations §§ 95480 et seq. and, generally, its purpose is to implement a low carbon fuel standard which will reduce greenhouse gas emissions by reducing the full fuel-cycle, carbon intensity of the transportation fuel pool used in California.
20 The National Institute of Standards and Technology and the Federal Energy Regulatory Commission are charged by the U.S. Congress to coordinate development and adoption of interoperability standards.
21 The Utility Role Staff Paper identifies several exceptions to this general rule. For example, a Direct Access customer or the Direct Access customer's Energy Service Provider can own the meter used for billing.
22 Parties and Staff identified two potential submetering options: electric vehicle service equipment-embedded meters and on-board vehicle metering. It is not clear how these options could be facilitated under a system in which utilities own the submeter.
23 Mobile detachable meters include technology for a meter that can be physically separated from the Electric Vehicle but also travel with the vehicle.
24 Subtractive billing refers to the process through which a utility can bill Electric Vehicle usage separately from other usage. All usage is first measured through the primary meter, while the Electric Vehicle usage is also measured by a dedicated submeter. The Electric Vehicle usage can be subtracted from the usage measured by the primary meter to bill the house consumption and the Electric Vehicle consumption separately. This subtractive billing is accomplished by back office billing software that links the meter data from the two meters and separately calculates the charges. (Utility Role Staff Paper at 18.)
25 Approved and implemented under PG&E Advice Letter 2552-G/2517-E. (PG&E January 7, 2011 Response to Energy Division Data Request.) PG&E points out that this charge is intended to off-set the administrative, back-office costs associated with establishing the service point and that this charge is unrelated to both the capital cost of the meter itself and the ongoing expense of maintaining a second meter.
26 SCE states that its separately metered TOU-EV-3 and TOU-EV-4 commercial Electric Vehicle rates have the same customer charges, including separate meter charges, as GS-1 and GS-2 customers, respectively. However, regarding the separately metered residential SCE TOU-EV-1 rate, this separate meter charge was set equal to zero as part of the 2009 general rate case phase 2 settlement. For SCE's residential customers, the uncollected metering cost is now collected via an adder to the volumetric rate. (SCE January 7, 2011 Response to Energy Division Data Request.)
27 SDG&E states it removed the separate meter charge pursuant to a revenue allocation agreement in the AMI settlement, D.07-04-043. (SDG&E November 12, 2010 comments at 3.)
28 The Rates Staff Paper described the standard allowance, per Tariff Rule 15, as "a prepayment of future rate base expenditures to be paid over time by all ratepayers" provided to the customer "for the cost of upgrades for new load. The allowance for residential load is a fixed amount. The allowance for non-residential load is based on forecast consumption."
29 On-bill financing refers to a loan program providing zero percent (0%) interest financing to qualified customers towards the purchase and installation of new energy efficient measures or equipment at the customer's premises.
