VARNUM. October 1, 2018

Transcription

1 0 North Washington Square Suite 0 Lansing, Michigan Telephone / - Fax / - Timothy J. Lundgren tjlundgren@varnumlaw.com October, 0 Ms. Kavita Kale Executive Secretary Michigan Public Service Commission 0 W. Saginaw Highway P.O. Box 0 Lansing, Michigan 0 Re: MPSC Case No. U-0 Dear Ms. Kale: Attached for electronic filing in the above-referenced matter, please find the Rebuttal Testimony of James Ellis on behalf of ChargePoint, Inc and Proof of Service. Thank you for your assistance in this matter. Sincerely yours, VARNUM TJL/kc Enclosures c. ALJ All parties of record. Timothy J. Lundgren Ann Arbor Detroit Grand Haven Grand Rapids Hastings Kalamazoo Lansing Novi

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION ***** In the matter of the application of ) CONSUMERS ENERGY COMPANY ) for authority to increase its rates for ) Case No. U-0 the generation and distribution of ) electricity and for other relief ) ) OF JAMES ELLIS ON BEHALF OF CHARGEPOINT, INC.

3 Q. Please state your name and business address. A. My name is James Ellis. My business address is E Hacienda Avenue, Campbell, CA 00. Q. By whom and in what capacity are you employed? A. I am employed by ChargePoint, Inc. ("ChargePoint"), and currently serve as Senior Director of Utility Solutions. 0 Q. Are you the same James Ellis who provided Direct Testimony in this proceeding? A. Yes, I am. Q. What is the purpose of your rebuttal testimony? A. The purpose of my rebuttal testimony is to address and provide recommendations on proposals made in the Direct Testimony of various parties related to the Company s PowerMIDrive program. Q. Is there general consensus amongst the parties about whether the Company s PowerMIDrive is in the public and ratepayers interests? A. Yes, with two exceptions. 0 Q. Please describe the positions of the parties. A. Witnesses Douglas Jester, Max Baumhefner, and Robert Ozar indicate general support for the Company s proposal and provide a range of comments and suggested program

4 amendments related to (i) scope and budget, (ii) pricing for EV charging services, (iii) cost recovery, and (iv) implementation. Witness Rábago exclusively addresses the issue of regulatory asset accounting and recommends that the Commission deny the Company s proposal to capitalize rebate expenses associated with its proposed EV program. Rábago Direct Testimony at. Witness Coppola recommends that the Commission reject the Company s PowerMIDrive proposal entirely. Coppola Direct Testimony at. 0 0 Q. How do the parties address the scope and budget of the Pilot? A. Witness Jester recommends that the Commission should not cap either the number of [Direct Current fast chargers, or DCFCs ] to be supported nor the total spending on this component of the program based on an infrastructure analysis included in Exhibit MEC-. Jester Direct Testimony at and. Witness Ozar indicates that Staff s recommendation is to approve the $,00,000 requested by the Company as well an additional $,00,000 dedicated toward new or modified service connections and associated equipment. Ozar Direct Testimony at and. Witness Baumhefner recommends that the Company retain the ability to increase [multi-unit dwelling or MUD ] rebate amounts during implementation to ensure adequate participation in the pilot and that the Company should request to deploy some Direct Current (DC) Fast Charging stations in urban environments. Baumhefner Direct Testimony at. Q. Do you concur with recommendations to expand the scope and budget of the Pilot?

5 A. Partly. In my direct testimony I recommended that rebates be calculated on a per-port basis and that the budget of the program be increased to future proof the Public Charging Component with the construction of additional make ready stub outs, provided that increased funding could be dedicated for this purpose. Ellis Direct Testimony at -. I would accordingly support Witness Ozar s recommendation to increase the budget of the Company s program by $,00,000 to defray the costs of make ready infrastructure, provided that additional funds would also lead to future proofing sites. 0 I agree with Witnesses Jester that access to DC fast charging at corridor locations is essential to supporting transportation electrification in Michigan. However, I do not agree that it is necessary, or in the public or ratepayers interest, to provide open-ended authorization for the Company to recover costs associated with supporting the deployment of an unspecified number of DC fast charging stations. This could jeopardize the extent to which costs to ratepayers are minimized and benefits maximized. 0 Mr. Jester s recommendations are largely based on a charging infrastructure analysis submitted in Exhibit MEC-. I have not undertaken a detailed review of this analysis, but I have observed that the analysis assumes baseline data for current EV charging infrastructure deployed in the Company s service territory on estimates from the Alternative Fuels Data Center. Exhibit MEC- at. Estimates on publicly available infrastructure do not typically include data on residential or workplace charging stations, which are often not listed in public databases.

6 I agree with Witness Baumhefner that increasing access to residential charging at MUD and urban hub locations is essential to supporting equitable access to transportation electrification in Michigan. However, it is unclear whether Witness Baumhefner is suggesting to uncap rebate levels with unspecified, zero-sum increases that reduce funding for other market segments included in the Pilot. In order to ensure a balanced and reasonable program, I recommend against uncapping rebate amounts in a manner that would reduce funding for other market segments. 0 0 Q: What is your perspective on Witness Baumhefner s conclusion that free EV charging can be problematic and inefficient? A: As I note in my Direct Testimony, maintaining the ability for site hosts to set pricing for EV charging and parking services ensures that drivers can be incentivized to return to the vehicle when it is fully charged, allowing other drivers to plug in. Ellis Direct Testimony at. Q: Do you agree with Witness Baumhefner s assertion that site host participants should simply pass through a time of use (TOU) rate directly to drivers? A: No, I do not agree with Mr. Baumhefner s assertion, which is based on the presumption that it is appropriate to peg the price of EV charging and parking services to the price of gasoline. As I noted in my Direct Testimony, it would not be appropriate to peg the price of EV charging services to the price of gasoline. Ellis Direct Testimony at. Mr. Baumhefner s assertion fails to consider the model for refueling an EV. As I explained in Direct Testimony, the model for refueling an EV is inherently different than

7 an internal combustion engine vehicle because EV charging is a combination of refueling and parking services. Ellis Direct Testimony at. For example, a static TOU rate sent directly to drivers would only be assessed while an EV is actively charging, and would therefore prevent site hosts the utility s customer of record that pays the electricity bill from incentivizing drivers to leave once charging is complete. Preventing site hosts from having the ability to incentivize turnover would restrict driver access to EV charging infrastructure in critical market segments, such as workplaces or MUD locations with shared parking facilities. 0 In addition, Mr. Baumhefner s analysis relies on statistically insignificant data, such as the average weekday in Southern California Edison s Charge Ready program at only three MUD locations. Baumhefner Direct Testimony at. The Commission would be better served by evaluating data from the Company s PowerMIDrive program following its implementation before considering whether to restrict site hosts from optimizing utilization of and access to EV charging infrastructure. 0 Finally, Mr. Baumhefner identifies the pricing policy of San Diego Gas & Electric s (SDG&E) Power Your Drive program as evidence that the Company s PowerMIDrive program should bypass site hosts and set a static TOU rate directly to drivers. Baumhefner Direct Testimony at. However, as Mr. Baumhefner notes, SDG&E s program, which ensures that site hosts have the ability to implement alternative end-use pricing to drivers, delivers 0 percent of kwh [ ] during off-peak and super-off-peak

8 hours. Id. The example of SDG&E s program should, in fact, be viewed as an argument for maintaining site host flexibility in determining pricing for EV charging services. For these reasons, I recommend that the Commission clarify that pricing policies in all Components of PowerMIDrive allow site hosts to set pricing for EV charging services as I proposed in my Direct Testimony. Ellis Direct Testimony at Q: Do the parties agree with Witness Rábago s recommendation that the Commission deny the Company s proposal to capitalize rebate expenses? A. No. As I observed in my Direct Testimony, the Company s proposed program design and cost recovery mechanism would be the best model to encourage customer investment in competitive charging technologies and expand these needed technologies throughout Michigan. Ellis Direct Testimony at. Witness Ozar concludes that deferring program cost recovery via regulatory asset accounting is reasonable due to the significant level of detail yet to be established in the Program design and the fact that actual expenditures will be highly dependent on participation rates. Ozar Direct Testimony at. Witness Baumhefner notes that regulatory asset accounting would align cost-recovery with the useful lives of the asset and the timeframe during which the benefits from widespread EV adoption becomes material, and goes on to recommend that the Commission implement performance-based incentives. Baumhefner Direct Testimony at. It would be in the public and ratepayers interest to, for the purposes of a limited pilot, evaluate the efficacy and efficiency of recovering program costs via regulatory asset

9 accounting. Should the Commission accept Witness Baumhefner s suggestion to explore performance-based incentives, I recommend that the Commission convene a stakeholder group to develop and evaluate reasonable and suitable performance-based metrics. Q: Would this be the only reason to convene a stakeholder group? A: No. A stakeholder group could also serve to support program implementation and ensure timely enrollment of participants. 0 Q. Do you agree with Witness Coppola s conclusion that the Commission reject the Company s PowerMIDrive proposal? A. No, I do not. Witness Coppola s conclusion is flawed and based on a fundamental misunderstanding of EV and EV charging technology, driver and site hosts needs, and how EV charging can support grid operations. 0 Mr. Coppola asserts that residential and Level charger rebates will not resolve range anxiety given that these chargers are slow chargers requiring battery charging time from -0 hours for a 0 mile drive. Coppola Direct Testimony at. The premise of this assertion is factually incorrect, as Level charging stations would take nowhere close to 0 hours to charge an EV with a 0-mile range. Data on the Alternative Fuels Data Center website indicates that Level charging stations typically attain 0 to 0 miles of range per hour of charging. Mr. Coppola also fails to recognize that EV charging accessed October, 0.

10 typically takes place when drivers arrive at longer-dwell-time destinations (e.g., home and work), thereby refueling the vehicle in time for the next trip. 0 Mr. Coppola asserts that the Company s cost-benefit analysis is flawed because EV owners will likely want to keep their car batteries fully charged at all times to be ready for unexpected trips during all times of the day, which means they will plug in the charger whenever they are home or near a charging station. Coppola Direct Testimony at. As I explain in my Direct Testimony, the load associated with EV charging is receptive to price signals and can be managed to support the creation of widespread grid benefits. Ellis Direct Testimony at. Load management capabilities in networked EV charging technology allow site hosts and utilities to optimize EV charging regardless of when and where drivers plug in, while still ensuring a positive driver experience. Q. Does this conclude your rebuttal testimony? A. Yes it does. 0_.docx

11 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION ***** In the matter of the application of ) CONSUMERS ENERGY COMPANY ) for authority to increase its rates for ) Case No. U-0 the generation and distribution of ) electricity and for other relief ) ) PROOF OF SERVICE STATE OF MICHIGAN ) ) ss. COUNTY OF INGHAM ) Kimberly J. Champagne, the undersigned, being first duly sworn, deposes and says that she is a Legal Secretary at Varnum LLP and that on the st day of October, 0, she served a copy of the Rebuttal Testimony of James Ellis on behalf of ChargePoint, Inc. and this Proof of Service upon those individuals listed on the attached Service List via at their last known addresses. Kimberly J. Champagne

12 SERVICE LIST MPSC CASE NO. U-0 Administrative Law Judge Hon. Sharon L. Feldman Administrative Law Judge Michigan Public Service Commission 0 W. Saginaw Hwy., rd Floor Lansing, MI feldmans@michigan.gov Counsel for the Michigan Public Service Commission Heather M.S. Durian Daniel Sonneveldt Michael J. Orris Monica M. Stephens Michigan Public Service Commission 0 W. Saginaw Hwy., rd Floor Lansing, MI durianh@michigan.gov sonneveldtd@michigan.gov orrism@michigan.gov stephensm@michigan.gov Counsel for Consumers Energy Company Bret A. Totoraitis Anne Uitvlugt Gary Gensch, Jr. Michael C. Rampe Theresa A.G. Staley Consumer Energy Company One Energy Plaza Jackson, MI 0 bret.totoraitis@cmsenergy.com Gary.genschjr@cmsenergy.com anne.uitvlugt@cmsenergy.com michael.rampe@cmsenergy.com Theresa.staley@cmsenergy.com mpsc.filings@cmsenergy.com Counsel for Attorney General Celeste R. Gill Assistant Attorney General G. Mennen Williams Bldg., th Floor W. Ottawa St. Lansing, MI 0 Gillc@michigan.gov ag-enra-spec-lit@michigan.gov Counsel for Michigan Cable Telecommunications Association Michael S. Ashton Anita G. Fox Fraser, Trebilcock, Davis & Dunlap, P.C. W. Allegan, Ste. 000 Lansing, MI mashton@fraserlawfirm.com afox@fraserlawfirm.com Counsel for Michigan Environmental Council, Sierra Club, Natural Resources Defense Council, City of Flint, & City of Grand Rapids Christopher M. Bzdok Tracy Jane Andrews Olson, Bzdok & Howard, P.C. 0 E. Front St. Traverse City, MI chris@envlaw.com tjandrews@envlaw.com karla@envlaw.com kimberly@envlaw.com breanna@envlaw.com Counsel for Environmental Law & Policy Center Margrethe Kearney Robert Kelter Environmental Law & Policy Center 00 Lake Drive SE Grand Rapids, MI 0 mkearney@elpc.org rkelter@elpc.org Counsel for Hemlock Semiconductor Corporation Jennifer Utter Heston Fraser Trebilcock Davis & Dunlap, P.C. W. Allegan, Ste. 000 Lansing, MI jheston@fraserlawfirm.com

13 Counsel for The Kroger Company Kurt J. Boehm Jody Kyler Cohn Michael L. Kurtz Boehm, Kurtz & Lowry East Seventh St., Ste. 0 Cincinnati, OH 0 KBoehm@BKLlawfirm.com JKylerCohn@BKLlawfirm.com mkurtz@bkllawfirm.com Kevin Higgins Energy Strategies, LLC South State Street, Suite 00 Salt Lake City, Utah khiggins@energystrat.com Counsel for Wal-Mart Stores East, LP & Sam's East, Inc. Melissa M. Horn Higgins, Cavanagh & Cooney, LLP 0 Dorrance Street, th Floor Providence, RI 00 mhorne@hcc-law.com Counsel for Residential Customer Group Don L. Keskey Brian W. Coyer Public Law Resource Center PLLC University Office Place Albert Avenue, Ste. East Lansing, MI donkeskey@publiclawresourcecenter.com bwcoyer@publiclawresourcecenter.com Counsel for Michigan State Utility Workers Council, Utility Workers Union Of America (UWUA), AFL-CIO John R. Canzano McKnight, Canzano, Smith, Radtke & Brault, P.C. N. Main St., Ste. 00 Royal Oak, MI 0 jcanzano@michworkerlaw.com Counsel for Midland Cogeneration Ventures, LP Richard J. Aaron Jason T. Hanselman John A. Janiszewski Dykema Gossett PLLC 0 Townsend St., Ste. 00 Lansing, Michigan raaron@dykema.com jhanselman@dykema.com jjaniszewski@dykema.com Charles E. Dunn Midland Cogeneration Venture LP 00 East Progress Place Midland, Michigan 0 cedunn@midcogen.com Counsel for Association of Businesses Advocating Tariff Equity Bryan A. Brandenburg Michael J. Pattwell Clark Hill PLC East César E. Chávez Avenue Lansing, MI 0 bbrandenburg@clarkhill.com mpattwell@clarkhill.com jmjohnson@clarkhill.com ldegnan@clarkhill.com Jeffry C. Pollock Billie S. LaConte Kitty A. Turner J. Pollock, Inc. Olive Blvd., Ste. St. Louis, MO jcp@jpollockinc.com bsl@jpollockinc.com kat@jpollockinc.com