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Interest Group Petitions Pa Commission for Policy Statement on EV Charging Infrastructure

An interest group claiming a broad and diverse membership has petitioned the Pennsylvania Public Utility Commission (“PaPUC”) to issue a policy statement on how to recover the costs of EV charging stations in utility rates.[1]  The interest group, ChargeEVC-PA, includes entities ranging from environmental groups including Sierra Club and Natural Resources Defense Council, to EV charging industry members, electric cooperatives, and utilities alike.  In the Petition, the Group argues that now is the time for the Commission to act to ensure that Pennsylvania has a coherent policy that promotes and supports the adoption of Electric Vehicles (“EV”) by implementing policies (primarily utility rate structures) that encourage deployment of EV charging stations, both public and private.  The Petition claims that there will be 18 million EVs on the road by 2030 and that auto manufacturers now produce more than 90 EV models, and those numbers are expected to grow dramatically in the coming years to bolster the urgency of its request.  The Petition also notes the recently enacted Infrastructure and Jobs Act — which includes $7.5 billion for EV charging infrastructure – positions Pennsylvania to receive at least $171 million to build out EV charging stations across the state’s high volume traffic corridors, as further impetus to promulgate a state-wide policy now.

The Petition notes that while some electric utilities have issued tariffs with EV charging Time-of-Use (“TOU”) rates, those rates apply to all energy consumed in a household and may not provide appropriate incentives for adoption.  The Petition also notes that not even these TOU tariffs address the delivery portion of the customer bill, that reflect the benefits to the distribution system of having large numbers of customers using energy off-peak, which helps to level off the demand curve.  The Petition points out that home EV chargers draw significant current (7.2 kW) and that without incentives to charge off-peak, use of these chargers could amplify existing peaks and put strain on the grid which would accelerate the need to shore-up the grid.

The Petition highlights a number of potential rate structures including TOU rates, Critical Peak pricing where a higher price is triggered by specific events, real time pricing, time-limited demand charges to incentivize build-out of commercial charging stations, and others.  The point is there is no one-size solution, and it may be wise to adopt more than one approach, depending on the specific goals.

The Petition also provides principles to consider when preparing a policy statement, including lowering electricity rates for all customers through more efficient use of existing assets, avoiding unnecessary grid upgrades, reducing emissions by aligning charging with renewable energy production, encouraging adopting of EVs by reducing charging costs, and, to create a viable business model for public charging infrastructure.

The Petition proposes the Commission issue a policy statement after seeking comment on the proposal, ultimately leading to a tailored, reasoned result for uniformity across the industry.  It is clear that if the Commonwealth is going to achieve the decarbonization necessity of electrifying its transportation system, EV adoption rates must increase dramatically.  As part of the process, it is necessary to implement policies that lead to abundant publicly available charging infrastructure as well as private EV charging at reasonable rates.  The Petition does not address the issue of who owns the charging infrastructure and that avoids one potential pitfall that could slow the process.  The point of the proposed policy statement is more focused on how the roll-out will impact the grid and seeking policies to incentivize buildout while reducing unneeded strain on the delivery system.  The ball is now in the Commission’s court, and it must decide what, if anything happens next.

#EVCharging #IIJA #PaPUC #decarbonization




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