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2 On October 24, 2013, the governors of eight states signed a memorandum of understanding (MOU) committing to coordinated action to ensure the successful implementation of their state zero-emission vehicle (ZEV) programs. ZEVs include pure battery-electric vehicles, plug-in hybrid electric vehicles, and hydrogen fuel cell electric vehicles. Collectively, these states are committed to having at least 3.3 million ZEVs operating on their roadways by The MOU identifies joint cooperative actions the signatory states will undertake, and additional actions that individual jurisdictions are considering, to build a robust market for ZEVs. The MOU created a multi-state ZEV Program Implementation Task Force and called for the development of the Multi-State ZEV Action Plan. The Task Force, composed of state officials, serves as a forum for coordination and collaboration on the full range of program development, support, and implementation issues to promote effective and efficient implementation of ZEV regulatory initiatives. NESCAUM, a nonprofit association of state environmental agencies, serves as the facilitator and provides technical and policy assistance to the Task Force. The Multi-State ZEV Action Plan provides additional detail and specificity to the commitments in the MOU and is intended to assist in developing consistent and complementary measures within and across our states to foster efficient market development and maximize the ownership experience for consumers. This report was developed by the ZEV Task Force Regulatory Infrastructure Implementation Team. The Task Force would like to thank Elise Keddie, Zero Emission Vehicle Implementation Manager for the California Air Resources Board, and Adam Ruder, Clean Transportation Program Manager for the New York State Energy Research and Development Authority, for their leadership as co-chairs of the Team and Kathy Kinsey as lead NESCAUM staff.

3 This document makes recommendations for state public utility commission action to consider or address potential barriers to deployment of electric vehicle supply equipment and adoption of plug in electric vehicles consistent with the Multi-State ZEV Action Plan. In general, the mission of state public utility commissions (PUCs) is to ensure that public service companies operate in the interest of the public, specifically in ways that promote safe, adequate, reliable, and economic public utility services. In addition to regulating electric and natural gas utilities, PUCs may regulate water and water sewage companies, telecommunications, and services provided by passenger-for-hire transportation companies and other passenger carriers. Responsibility for the oversight of retail electricity services includes setting retail electricity rate structures, which in turn, involves determining the prudency of utility expenditures and the appropriate allocation of utility operating costs and capital investments to customer rates, as well as establishing a rate of return on utility equity and capital investments. Recommended PUC Regulatory Practices: The scope of a state PUC s regulatory authority will determine to what extent owners or operators of EVSE in that state fall under the jurisdiction of the PUC. State public utility laws often define a public utility supply company in broad terms, which can result in uncertainty about whether owners or operators of EVSE are subject to regulation as an electric company or as a supplier of retail electricity. Public service companies are subject to comprehensive regulation as utilities and face a high regulatory burden to enter the market. Compliance with the regulatory requirements applicable to retail electricity suppliers could be prohibitively expensive for EVSE providers and has been identified as a potentially significant barrier to expansion of charging infrastructure. EVSE owners and operators are themselves, utility customers and should be treated as such; including the owner, operator, or 1 State Statutes governing public service vary in the terms used for public service companies. Some statutes refer to utilities, some refer to electric corporations, etc. As used in this document, a public service company is meant to encompass that cross-jurisdictional variation. 1

4 person that charges at an EV charging station in the regulatory definition of retail electric customer is one way to clarify the regulatory status of EVSE providers. A growing number of states have exempted EVSE providers from regulation as public service companies, either through PUC proceedings or by enactment of legislation. They include California, 2 Oregon, 3 Colorado, 4 Florida, 5 Hawaii, 6 Illinois, 7 Maryland, 8 Massachusetts, 9 Minnesota, 10 Pennsylvania, 11 Utah, 12 Virginia, 13 Washington, 14 West Virginia, 15 New York 16 and the District of Columbia. 17 By clearly exempting EVSE providers from regulation as public service companies, state PUCs can eliminate regulatory uncertainty and remove regulatory barriers to the expansion of the infrastructure sector to facilitate accelerated deployment of charging stations. State PUCs may still want to monitor the development of this nascent service sector to identify any consumer or other issues that might interfere with smooth integration of EVSE and PEVs into the grid, and thus warrant regulatory action. Tracking new PEV purchases and EVSE installations helps utilities assess the adequacy of local distribution systems to manage increased load demand associated with PEVs. State PUCs should give consideration to adoption of regulatory changes or voluntary measures that would enable such notifications. Given the protected nature of personal information maintained by motor vehicle and other state agencies in many states, however, establishment of mandatory notification 2 and bill/asm/ab_ /ab_631_bill_ _chaptered.html Open&file=1258_enr.pdf A4C54EC02220}

5 procedures for new vehicle purchases may require a legislative amendment to the state s public information act. This was the case in Maryland where legislation was enacted requiring disclosure by the state motor vehicle administration of the addresses of the registered owners of new PEVs to public utilities solely for the purpose of planning for the availability and reliability of electricity service. 18 Similar legislation was enacted in California. 19 Utility notification might also be achieved through adoption of voluntary reporting measures. For example, where the installation of a charging station requires issuance of an electrical permit from local permitting authorities, as is typically the case, utility notification of EVSE applications by local permitting authorities could provide timely valuable grid planning information to utilities. Other reporting options include requiring utility notification as a grant condition in conjunction with EVSE or vehicle purchase incentive programs, identification of new charging station installations by utility ratepayers who elect EV TOU rates, or securing EV purchaser s consent to utility notification by dealerships at the time of purchase. TOU rates reflect the higher cost of providing electricity during periods of peak demand, and conversely, the lower cost of service during off-peak periods. Off-peak charging of PEVs not only saves EV owners money, but it also has the potential to largely mitigate the impact of PEVs on the grid by shifting load to off-peak hours. Moreover, all ratepayers benefit from EV rate structures that encourage off-peak charging because increased demand for electricity during peak hours drives up the cost of electric rates for everyone. Shifting load to off-peak hours can reduce the need for peak-demand related capital expenditures, and thus spreads capital costs more evenly across the grid. This may reduce peak charges for everyone. Four of the eight ZEV MOU states (CA, MD, MA, NY) have either implemented pilot voluntary residential TOU rate programs for EV drivers, or have opened proceedings to consider offering such rates. In a fifth MOU state, Oregon, the state PUC has ordered its utilities to offer TOU rate choices for EV charging to all of their customers. 20 Maryland s two largest utilities, Potomac Electric Power Company (PEPCO) and Baltimore Gas and Electric Company (BGE), have implemented separate residential

6 pilot EV charging TOU rate programs under the direction of the state s Public Service Commission. The PEPCO pilot program offers its customers three different options, two of which entail installation of a second meter dedicated to EV charging, along with a separate bill. Both pilot programs have been extended through the end of The rate structures and other program elements are described in a January 30, 2015 Public Service Commission report to the Governor and Legislature, which includes a preliminary assessment indicating that EV-owning customers of both utilities are shifting charging load to off peak price hours in response to the availability of TOU rates. The report, Electric Vehicle Pilot Program Report, Public Service Commission of Maryland, January 30, 2015, is attached to this document for reference as Appendix A. Other utilities also offer, or have offered, voluntary residential TOU rates for EV charging, including Consumers Energy Company in Michigan, 21 and Pacific Gas and Electric, 22 San Diego Gas and Electric, 23 and Southern California Edison. 24 For additional examples of voluntary residential TOU EV rates, see the April 2013 report prepared for the New York State Energy Research and Development Agency, Compilation of Utility Commission Initiatives Related to Plug-in Electric Vehicles and Electric Vehicle Supply Equipment, at pages In New York, Consolidated Edison Company of New York (Con Ed) has implemented a voluntary pilot incentive program to encourage off peak charging by EV owners. The pilot is testing the capacity of one particular type of Branch Circuit Energy Management Device (BCEMD) to: (1) measure how much electricity an EV uses independently from the whole house load; (2) monitor customer charging habits; and (3) provide some level of utility control of EV charging. The BCEMD technology collects energy consumption data in 5-minute intervals. Each participant has access to an on line portal to view in near real time how much electricity is used to charge the customer s EV and is provided with the ability to program the charging of the EV on line or using a smart phone. Although a full year of data for all pilot project participants is not yet available, preliminary analysis indicates that while the particular device used in the pilot is not recommended for large scale deployment or billing purposes due to a number of limitations, the BCEMD technology has proven to be valuable for monitoring charging habits, providing peak demand charging information to customers for use in deciding Commission-Initiatives-Plug-acc.pdf 4

7 whether to select TOU rates, eliminating the need for installation of a second revenue grade EV meter to separately measure EV load and providing Con Ed with limited ability to control EV charging. Analysis of charging data collected by the pilot indicates that the majority of customers not served by voluntary TOU rates charge their vehicles during peak hours, while those served by voluntary TOU rates charge almost entirely during non-peak hours. The pilot will continue into Con Ed will explore the potential benefits of an offpeak EV charging or utility-controlled incentive program using BCEMD technology. A March 2015 status report describing the pilot is attached for reference as Appendix B. A supplemental report is expected in November of Demand charges are fees imposed by utilities, typically on commercial ratepayers, for peak power use during a billing cycle, regardless of the amount of energy drawn at the power rate. Demand charges are calculated on the basis of the highest demand over a short period of time and can add significantly to the electric bill of an EVSE host, particularly when utilization is low, thus acting as a barrier to deployment of DC fast chargers, and even multiple Level 2 chargers at a single location. In order to encourage deployment of DC fast chargers by businesses in the early adopter phase, the Hawaii PUC has waived demand charges for DC fast chargers deployed by commercial customers of the Hawaii Electric Company that install a separate meter dedicated to EV charging. 26 In an open rulemaking proceeding to address multiple utility policy issues affecting alternative fueled vehicles (R ), the California PUC is considering development of a charging station demand charge policy. Possible alternatives to waiving demand charges for charging stations altogether include establishing a higher kwh usage trigger for application of demand charges, or a separately metered, but higher per-kwh, rate for EVSE that would at least partially compensate for the electric system costs that would otherwise recovered through demand charges. For example, the California PUC temporarily authorized transit fleets using DC fast charging to be eligible for TOU rates without demand charges. The demand charge exemption allows the fleet owner to scale the EVs in their fleet over a defined period of time without jeopardizing the economic case for

8 electrification, while maintaining a price signal consistent with utility operational costs. Upon adopting a larger fleet, the fleet would revert to an otherwise applicable rate with a demand charge, but the $/kw cost of the demand charge would be levelized over more energy consumption. In effect, this allows the owner to operate the fleet with a per-kwh rate that remains competitive with traditional fuels. 27 The structuring of demand charges to ensure that they do not become an impediment for EVSE hosts, or too costly for EVSE end users, will eliminate uncertainty among commercial customers that increased electricity usage from installation of one or more DC fast chargers (or possibly multiple Level 2 chargers) might trigger prohibitive demand charges. While exemption of EVSE providers from regulation as public service companies eliminates a significant potential barrier to the growth of public and private charging networks, PUCs are uniquely situated to provide the oversight of this developing service sector necessary to ensure grid reliability. The following oversight activities are ones that state PUCs may want to consider in the future as the EV market evolves and expands over time: To facilitate the smooth integration of EVSE into the electricity grid as the EV market expands, state PUCs may want to establish procedures to monitor the impact of PEVs on electricity demand and grid stability. PUCs may want to monitor the electric rates utilities charge EVSE providers to ensure that EVSE providers are not subject to discriminatory rates, particularly in segments of the market where end-use EV drivers face split-incentive or agency issues (e.g., multi-unit residential dwellings). In states where net metering from PEVs is permitted, PUCs may want to monitor compensation rates offered by the utilities to ensure that consumers are compensated for the electricity they sell back to the grid consistent with the state s net metering policy and 6

9 PUCs may want to explore regulatory approaches that will allow utilities to recover the costs of providing purchase incentives for PEVs and installation of home, workplace, or public charging stations. PUCs may want to consider whether, as providers of electricity as a fuel, utilities should be eligible for emission reduction credits in states that have adopted Low Carbon Fuel Standards, and whether the value received from such credits should be returned by the utilities to EV customers. PUCs may want to explore the use of Vehicle-Grid Integration 28 strategies for electricity storage, support of intermittent renewables, bundled demand response through managed EV charging and peak load shaving CPUCEnergyDivisionVehicleGridIntegrationZEVSummit.pdf and GridIntegrationRoadmap.pdf 7

10 Appendix A:

11 PUBLIC SERVICE COMMISSION OF MARYLAND ELECTRIC VEHICLE PILOT PROGRAM REPORT In compliance with Section of the Public Utilities Article, Annotated Code of Maryland 6 St. Paul Street Baltimore, MD Tel: (410) January 30, 2015

12 TABLE OF CONTENTS I. INTRODUCTION... 1 II. BGE ELECTRIC VEHICLE PILOT... 2 III. PEPCO ELECTRIC VEHICLE PILOT... 3 IV. DEVELOPMENT OF THE PILOT METRICS... 4 V. RESULTS OF THE PILOTS... 4 A. BGE Pilot Results... 5 B. Pepco Pilot Results... 5 VI. CONCLUSIONS... 6

13 I. INTRODUCTION This document constitutes the 2015 report of the Public Service Commission of Maryland ( Commission ) regarding the implementation of Maryland s pilot programs for recharging electric vehicles ( EVs ) during off-peak hours. This report is submitted pursuant to of the Public Utilities Article, Annotated Code of Maryland ( Pub. Utils. ), which requires that the Commission shall report to the Governor and to the General Assembly on the experience of the pilot program and the Commission s findings on or before February 1, With the passage of Senate Bill 179 ( SB 179 ), Maryland s General Assembly required the Commission to establish a pilot program for electric customers to recharge electric vehicles during off-peak hours 1 by June 30, The statute provides that an electric company may request to participate in the pilot program and directs the Commission to make every effort to include at least two electric companies in the pilot. 2 Under the statute, the pilot program is required to include incentives for customers to recharge EVs so as to increase the efficiency and reliability of the electric system and lower electricity use at times of high demand. Possible incentives include time-of-use electricity pricing, credits on distribution service, rebates on charging system costs, demand response programs, and other incentives approved by the Commission. 3 On August 12, 2013, the Commission issued Order No approving EV pilot programs for Baltimore Gas and Electric Company ( BGE ) and Potomac Electric Power Company ( Pepco ). 4 Both pilots have been extended by the Commission until December 31, Md. Laws, Ch. 403, codified at Pub. Utils (m). 2 Pub. Utils (m)(2). 3 Pub. Utils (m)(4). 4 Case No. 9261, In the Matter of the Investigation into the Regulatory Treatment of Providers of Electric Vehicle Charging Stations and Related Services. 5 Pepco and BGE s extensions were approved by Letter Orders dated October 8, 2014 and January 21, 2015 respectively. Pepco s filing was made with Mail Log Nos , and BGE s filing was made with Mail Log Nos and

14 II. BGE ELECTRIC VEHICLE PILOT BGE offers a single whole house time-of-use ( TOU ) plan for its EV owning customers. BGE s pilot is available only to those residential customers who receive Standard Offer Service ( SOS ), do not participate in net metering, and do not purchase renewable energy from a third party. Any qualifying EV owner can opt into the pilot and can leave the pilot for any reason without penalty. BGE s proposal was designed to be revenue neutral. Currently, BGE s generation and transmission charges for customers enrolling in the EV pilot are $ per kwh during the summer peak, and $ per kwh during the winter peak. The summer and winter off-peak rates are $ and $ per kwh respectively. 6 The summer rates are in effect from June through September, while winter rates are in effect from October through May. Summer peak rates are from 10 a.m. to 8 p.m., Monday through Friday. Winter peak rates are from 7 a.m. to 11 a.m. and 5 p.m. to 9 p.m., Monday through Friday. Off-peak rates are all other hours. For comparison, BGE s current generation and transmission charge for SOS customers is $ per kwh. 7 BGE s distribution rates are the same for all residential classes. Months in Effect Days in Effect Times in Effect Peak Rates (per kwh) Off-Peak Rates (per kwh) Table 1 Comparison of BGE's EV and SOS Rates Summer EV Rates June- September Monday- Friday 10 a.m.- 8 p.m. Winter EV Rates October-May SOS Oct. 1, 2014 May 31, 2015 SOS June 1, 2015 Sept. 30, 2015 Monday-Friday All All 7 a.m.-11 a.m. and 5 p.m.- 9 p.m. $ $ $ $ $ $ $ $ All All 6 The rates are defined in BGE s Retail Electric Service Tariff, page 77A. (Available at: iffs/rdr_1.pdf) 7 Ibid. 2

15 III. PEPCO ELECTRIC VEHICLE PILOT Pepco s EV pilot consists of three separate residential offerings. The first option requires Pepco to install a level II charging station, and the costs of the charging station are shared equally between the customer and Pepco. This option is available for up to 50 residential customers. The second option requires the customer to have an existing charging station and is available for up to 200 residential customers. Both sets of customers (hereafter referred to as PIV customers) have a second meter for their EV, receive a second bill for their EV, and may opt to receive 100% renewable energy for an additional $ per kwh. Pepco also offers a whole house TOU rate that is available for up to 1,000 residential customers. These customers receive the same rate for their house and EV and do not require a second meter. Currently, Pepco s generation and transmission charge for PIV customers is $ per kwh during the summer peak, and $ per kwh during the winter peak. 8 The summer and winter off-peak rates are $ and $ per kwh, respectively, for the two options in which the customer s EV charging is separately metered. 9 For customers with a whole house TOU rate, the on-peak rates are the same as the rates for PIV customers. However, the summer and winter off-peak rates are higher at $ and $ per kwh, respectively. 10 The summer rates are in effect from June through October, while winter rates are in effect from November through May. Peak rates are from noon to 8 p.m., Monday through Friday, while offpeak rate include all other hours. For comparison, Pepco s current generation charge for an SOS customer is $ per kwh. 11 Pepco s distribution and transmission rates are the same for all residential classes. 8 The rates are defined in Pepco s Rate Schedules for Electric Service in Maryland, pages 21 & 22. (Available at: 9 Ibid, at Ibid, at Ibid, at

16 Table 2 Comparison of Pepco's EV and SOS Rates Summer EV Rates Winter EV Rates SOS Months in Effect June-October November-May Oct. 1, 2014 May 31, 2015 Days in Effect Monday-Friday Monday-Friday All All SOS June 1, 2015 Sept. 30, 2015 Times in Effect 12 p.m.-8 p.m. 12 p.m.-8 p.m. All All Peak Rates (per kwh) $ $ $ $ Off-Peak Rates (Separate Meters, per $ $ $ $ kwh) Off-Peak Rates (Whole House TOU Rate, per kwh) $ $ $ $ IV. DEVELOPMENT OF THE PILOT METRICS In Order No , the Commission directed the EV Working Group 12 to convene to establish the metrics to be captured and reviewed through the duration of the BGE and Pepco pilots. The Working Group identified five key areas that could support the pilot objectives: 1) pricing; 2) demand response; 3) customer education and enrollment; 4) smart technology demonstration; and 5) baseline information and impact understanding. In February 2014, BGE and Pepco submitted detailed metrics they will be tracking throughout their respective pilots. On January 16, 2015, BGE submitted its preliminary findings from its complete 2014 metrics results. 13 In a January 16, to Staff, Pepco provided its summary metrics results. Pepco plans to file the finalized results for all metrics data through the end of 2014 by the end of January V. RESULTS OF THE PILOTS On January 16, 2015, both Pepco and BGE provided reports summarizing the results of the pilots. Although the Commission expected feedback regarding the pilots to use in evaluating 12 Parties in the Working Group include the following: BGE; Pepco Holdings, Inc.; Potomac Edison; Southern Maryland Electric Cooperative; the Office of the Maryland Governor; the Maryland Office of People s Counsel; the Maryland Energy Administration; the Maryland Department of the Environment; NRG Energy; Coulomb Technologies; ECOtality; E-Car Solutions, Inc.; EV Service Providers; and Commission Staff. 13 Commission Mail Log No

17 these programs, both BGE and Pepco reported that they are still reviewing and collecting data, so any conclusions drawn from the pilots are best considered preliminary. Moreover, due to the timing of customers enrollments and the number of enrollees thus far (29 for BGE and 55 for Pepco as of December 31, 2014), the pilots may lack sufficient data to draw robust conclusions regarding the charging behavior of EV owners in response to TOU rates. 14 Both BGE and Pepco requested and the Commission granted approval to extend pilots through the end of As more EV models are being introduced and more customers purchase EV s, there could be a larger pool of customers from which to draw pilot participants. Extending the pilots will allow the companies more time to acquire the data necessary to draw statistically significant conclusions from the respective pilots (currently the companies have gathered a full year of data for only three enrolled customers). A. BGE Pilot Results Of BGE s 29 participants, 17 enrolled in the second half of While there is not sufficient data to determine conclusively if there have been changes in participant behavior regarding charging patterns, BGE s preliminary analysis show the participants are shifting load off the peak price hours. BGE s metrics show an estimate of 695 EV owners that could participate in the pilot. Of those, 541 EV owners are not eligible to participate in the pilot; most commonly because the customer s electricity was served by a competitive electricity supplier. In addition, BGE has received 464 requests for information regarding the EV pilot rates. Assuming these inquiries are all coming from EV owners, this would represent over two-thirds of the estimated EV owners in BGE s territory, indicating that a significant number of EV owners may have at least preliminary interest in TOU rates. B. Pepco Pilot Results 14 As almost 60% of BGE s enrollees occurred in the second half of 2014, there is limited data with regards to how the rates affected behavior in the peak months. 5

18 Pepco received 117 customer applications resulting in 55 enrollees, with one on hold at the customer s request, six in the enrollment process, 22 customers deciding not to enroll, and 33 disqualified applications. Of those disqualified, the two most common reasons were coderelated 15 and customers participating in net-metering. 16 On July 30, 2014, the Commission accepted a request from Pepco to allow net-metering customers to participate in its EV pilot. 17 Of Pepco s 55 participants, 27 enrolled in the second half of Of those participants, 47 are enrolled in the PIV rate offering, and Pepco cost-shared the charging station installation of 30 of these. Pepco has spent an average of $2,154 per customer in cost-sharing, or $249,627 of its $1,092,500 total budget for the pilot. 18 Of the 47 PIV customers, 19 have elected to receive their electricity supply from renewable resources. The Nissan Leaf, Chevy Volt, and Tesla S models account for 45 of the 55 vehicles owned by customers enrolled in the pilot. Six other models account for the remaining ten vehicles. Pepco s metrics show it takes approximately two months to enroll a PIV customer, about half of which is for installation of the EV charging equipment. Conversely, customers electing the whole house TOU rates are on average enrolled in four days. The Pepco report states that all of these customers charge their EVs primarily in the offpeak hours. Since the eight customers with a whole house TOU rate don t have a separate meter for their EVs, Pepco has no way of confirming when these customers are charging their EVs. However, Pepco eventually will be able to determine whether these customers shift substantial load into the off-peak hours. VI. CONCLUSIONS BGE is currently performing customer surveys, and will begin receiving usage and customer feedback data available by the end of March Pepco is also continuing its analysis of the existing data to date. Moreover, as part of Pepco s proposal to extend the pilot for one 15 The wiring or electric panels in these residences were not in compliance with the National Electrical Code. 16 One customer was disqualified because they didn t own an EV. 17 Commission Letter Order dated July 20, 2014, Mail Log No Pepco s total budget attributed $610,000 to equipment, installation and inspection costs and $500,000 to administrative costs. 6

19 year, Pepco committed to submit a more robust report by December 31, This latter report will include additional information from the more extensive data set obtained through October 31, The forthcoming data provided by each utility will assist the Commission in presenting more robust conclusions once the pilots are completed. 19 BGE is also planning to submit an additional report by December 31, The reports will not include data for all of 2015, but instead are intended to provide the available data to the Commission in sufficient time to report to the General Assembly early in the 2016 legislative session. 7

20 Appendix B:

21 Consolidated Edison Company of New York, Inc. Electric Vehicle Pilot Report Case 13-E-0030 March 31, 2015

22 Consolidated Edison Company of New York, Inc. Electric Vehicle Pilot Report I. Introduction In the Joint Proposal adopted by the New York State Public Service Commission ( Commission ) in its February 21, 2014 Order Approving Electric, Gas and Steam Rate Plans In Accord with Joint Proposal ( Order ) in Case No. 13-E , Consolidated Edison Company of New York, Inc. ( Con Edison or the Company ) indicated that it is conducting a pilot focused on testing the ability of metering technology to separately meter electric vehicle ( EV ) load in single family residential premises and is evaluating participants responsiveness to peak demand information. As part of the Joint Proposal, the Company agreed to expand the pilot to up to 50 participants and to issue a report evaluating the accuracy and usefulness of the metering technology and make a proposal for next steps, as appropriate, by March 31, In accordance with that requirement, the Company hereby issues this Electric Vehicle Pilot Report ( Report ). II. Background Con Edison initiated an Electric Vehicle (EV) Pilot Program in June 2012 with eight pilot participants: six Con Edison customers (five in Westchester and one in Staten Island) and two Orange and Rockland Utilities, Inc. ( O&R ) customers. The objective of the pilot was to test a particular Branch Circuit Energy Management Device (BCEMD) to measure how much electricity an EV uses independently from the whole-house load, to monitor customer charging habits, and to provide some level of utility control of the EV. Although this pilot focused on one 1 Case No. 13-E-0030, Proceeding on Motion of the Commission as to the Rates, Charges, Rules and Regulations of Consolidated Edison Company of New York, Inc. for Electric Service ( Rate Case ). 1 3/31/2015

23 particular BCEMD, the Company continues to explore other technologies and devices that may be beneficial to EV and other customers. As mentioned above, the Joint Proposal adopted by the Order required that Con Edison attempt to expand its EV pilot program to up to 50 participants. As a result of that requirement, in July 2014, Con Edison began installing BCEMDs in homes of additional Con Edison EV customers. Currently, there are a total of 50 Con Ed customers participating in the EV Pilot: eight Brooklyn customers, one Bronx customer, seven Queens customers, five Staten Island customers and 29 Westchester County customers. These 50 customers own or lease a total of 54 EVs: 32 battery electric vehicles (19 Teslas, nine Leafs, two BMW i3s, one Honda Fit, one Mercedes Smart Car) and 22 plug-in hybrid electric vehicles (15 Volts, one BMWi8, two Ford Cmaxs, one Ford Fusion and three Priuses). Four Con Edison customers have two EVs. Of the 50 Con Edison customers, a total of sixteen customers either were already served on a voluntary time-of-use ( VTOU ) rate or signed up for a VTOU rate as a result of the pilot: 10 customers have signed up for the Service Class ( SC ) 1 Rate III with the one year price guarantee for EV owners, five customers are on the grandfathered SC1 Rate II, and one customer is on the SC2 Rate II. The remaining 34 are on the standard, residential flat rate (SC1 Rate I). A total of fifteen customers have solar arrays installed, of which 12 live in Westchester. For three of these solar customers, BCEMDs were installed to monitor their solar arrays, in addition to their EVs. 2 Currently, in order for Con Edison s EV customers to take advantage of VTOU rates, the customers have two options: (1) have their entire residence on a VTOU rate, or (2) establish a 2 There appears to be a high correlation between EV ownership and solar arrays, particularly in Westchester County. 41% of Westchester EV pilot participants have solar arrays. Almost all EV pilot participants that do not currently have solar, have expressed an interest in installing solar. 2 3/31/2015

24 separate account by installing a second meter dedicated to their EV. 3 BCEMD could theoretically allow customers to go onto a VTOU rate or participate in other incentive programs for their EV without having to incur the expense of installing a second meter to measure EV load separate from household load with the ongoing expense of an additional monthly Customer Charge. This pilot may provide valuable data and analysis as to whether such devices will achieve that goal. For each pilot participant, Con Edison installed a BCEMD which consisted of a combination of at least one device controller and an energy gateway. To measure and control the EV load, the device controller is installed on the same branch circuit as the EV charging station or outlet (110V or NEMA outlet) used for EV charging. EV energy consumption is collected in five minute intervals and this data is sent via Zigbee protocol to an energy gateway embedded in an approved revenue grade meter or in a standalone device ( standalone gateway ) which is plugged into an 110V outlet in the customer s home. For those customers with strong cellular service near the location of their meter, a meter retrofitted with the gateway replaced their existing Con Edison meter, allowing household energy consumption to also be collected in five-minute intervals. However, for those customers with poor cellular service at the location of their meter, a standalone gateway was provided and plugged into an outlet located in an area of the customer s residence with stronger cellular service. For these customers, household energy data is not being collected. All interval data is sent via wireless network to a data center managed by a third party contractor, who in turn transmits the data to Con Edison. Participants have access to an online portal to view in near real-time (15 minute delay) how much electricity is used in the customer s residence (if a gateway has been embedded in the meter) and to charge 3 Currently, a second account would be served under SC 2. The Company has filed (in Case 15-E-0050) a proposal for a standalone PEV charger rate based on SC 1 Rate III (Electric Rate Panel Initial Testimony, starting on page 55, line 20). 3 3/31/2015

25 the customer s EV, and is provided the ability to program the charging of the EV online or with a smartphone. Through the portal, Con Edison also has the ability to monitor and control each customer s EV load. As the pilot progresses to obtain a full year of data, the Company will gather and analyze data and continue to provide data and useful information to pilot participants. Although it is too soon to draw definitive conclusions from the pilot at this time, the Company provides the following as preliminary analysis of the pilot and the usefulness of the BCEMD or similar device. The Company will also continue to explore other technologies that would allow the EV load to be separately measured from the whole-house load. III. Usefulness of the BCEMD The primary functionality of this type of device is that it allows Con Edison to measure how much electricity an EV uses separately from the whole-house load, to monitor customer charging habits, and to provide some level of utility control of EV charging. There are however, several limitations of the BCEMD to measure EV charging described below. For instance, the BCEMD used in the pilot can be used to measure, monitor and control EV load for any Customer that has strong cellular service on a circuit up to 50 amps. For customers in multi-family dwellings where the garage and meter is below grade and there is no or limited cell service, the Company was unable to use the BCEMD technology. This is a significant limitation for Con Edison since most customers in New York City live in multifamily dwellings and many multi-family parking garages are below grade level with poor cellular service. Moreover, the BCEMD that was used in the pilot did not provide the Company with the ability to include customers with dual charger Teslas that would require a 100 amp circuit in the 3/31/2015 4

26 pilot, as this particular BCEMD has a technological limitation of 50 amps. Four potential EV volunteers were unable to participate for this reason. The Company will continue to explore BCEMD or other technologies that would have the capability of handling 100 amp circuits. Additionally, the BCEMD used in the pilot does not currently meet many of the minimum functional requirements typically expected of a revenue grade meter. 4 For all these reasons combined, large scale deployment would not be recommended or supported for this particular BCEMD and the Company continues to explore and evaluate other technologies. As discussed below, despite these limitations, the usefulness of the BCEMD or other similar technologies to both the Company and participants is easily demonstrated. 1. Ability to Measure EV Load and Provide Insights on Customer Behavior First, the BCEMD eliminates the need to install a second revenue grade meter in the customer s home to measure EV load separate from household load. In addition, the BCEMD monitors charging habits, and provides some level of utility control of the charging of the EV. The BCEMD also enables and facilitates a variety of indirect benefits to EV customers. For instance, because the EV is separately measured as compared to the whole-house load, the use of this particular BCEMD may enable Con Edison to provide each EV Pilot participant with reports summarizing their total household energy consumption and EV energy consumption into off peak, on peak and super peak periods. The Company can also provide participants with the incremental cost of EV charging under SC1 Rate I and a bill comparison demonstrating what the customer would pay on various VTOU rate alternatives: SC1 Rate III and SC2 Rate II (with a dedicated meter for their EV) with and without restricting their EV charging to off-peak hours. These manually generated reports may allow customers in this 50-person pilot to make an 4 The minimum functional requirements are set forth in Case 09-M-0074, the proceeding on AMI systems. 5 3/31/2015

27 informed decision as to whether to select a VTOU rate when considering their whole house and EV load profile. Con Edison plans to begin issuing these customer reports in June While the BCEMD provides the Company with preliminary insight into customer charging behavior by allowing the Company to measure EV load separately from household load, the small number of participants in this pilot makes it difficult to draw broad conclusions. Additionally, the amount of data available at this time only captures one summer month of last year; the Company expects to have more definitive analysis of customer charging behavior as a full year of data is gathered. With current data that is available, the average monthly EV usage ranges from a high of 781 kwh (Tesla with a 85 kwh battery size) to a low of 12.7 kwh (Prius with a 4.4 kwh battery size). 70% of the EV pilot participants have average monthly EV usage of greater than 200 kwh, and only five customers had average monthly EV usage over 500 kwh. To date, of the pilot participants who are not currently on a VTOU rate, 56% of the EV charging took place during peak hours 5 and 11% during super peak hours (M-F, 2 pm 6 pm) in September 2014 (a summer month), and 66% of the EV charging took place during peak hours during non-summer months (October 2014 January 2015). Based on the data obtained to date in this pilot, it appears that the majority of EV charging for customers not on a VTOU rate takes place during peak hours (8 am 12 am). Conversely, customers on a VTOU rate (SC1 Rate II and SC1 Rate III) charge their EV almost entirely during the off-peak times (12 am 8 am). Figure 1 illustrates the EV Load Profile for non-vtou customers for Summer and Non-Summer Months for which the Company has available data. Given this information, the Company is also in the early stages of analyzing VTOU rate scenarios for the pilot participants for which the Company has complete monthly whole-house 5 Off peak, on peak and super peak hours are defined as those time periods specified under SC1 Rate III. 6 3/31/2015

28 and EV five minute interval data since September. For these customers, Con Edison analyzed the data using one month of summer data (September 2014) and 4 months of non-summer data (October 2014 February 2015) to estimate the potential annual savings assuming these customers were full service customers on the SC1 Rate III, compared to the SC1 Rate 1. Over a half of these customers would have saved in electricity costs by switching to the SC1 TOU Rate III based on their actual energy use. The Company will continue to analyze this data as part of the pilot, and provide information to customers in the customer reports discussed above. Figure 1. EV Load Profile for Non-VTOU Customers Non VTOU Customers Off Peak On Peak Super Peak EV Load EV Load EV Load Summer (September 14) 33% 56% 11% Non-Summer Months 34% 66% NA (October 14 February 15) 2. Ability to Analyze Impact on Con Edison System The BCEMD allows the Company to review and analyze the impact of EV charging on customer peak demands and potential impact on the Con Edison electric system. For instance, in September 2014, for all pilot participants, EV charging contributed to the customer peak daily demand 69% of the time. 6 In January 2015, that number increased to 73% of the time. In September 2014, EV charging contributed more than 50% of the customer peak daily demand 6 Percentages were derived by identifying the existence of EV charging during the hour of customer peak daily demand in a given month for each customer. The number of such days were summed and divided by total number of days in the given month. 7 3/31/2015

29 44% of the time, and in January, EV-charging contributed more than 50% of the customer peak daily demand 54% of the time. Figure 2 illustrates EV contribution to peak demand for a single customer in Westchester County for the month of September /31/2015 8

30 Figure 2: Example of EV Contribution to Daily Peak Demand for a Single Customer in Westchester County (September 2014) 3/31/2015 9

31 3. Access to Energy Information One attractive feature of the pilot when recruiting the 50 participants was access to near real-time information on the amount of energy used in the home and to charge their EV. This access to energy information could provide participants with insight on which devices in their home are driving their energy consumption and the ability to better control their total energy usage and reduce their electric bills. Although the only device in the customer s home that is individually monitored is the EV, they are able to see in near real-time (15 minute delay) their house load increase and decrease as they turn on and off individual devices. When customers were provided with the ability to program and control the charging of their EV online or with a smartphone, most of the customers chose not to use the Con Edison provided portal or application to program or control the charging of their EV. Only three customers are currently taking advantage of this Con Edison-provided feature. Most customers program and control the charging of their EV directly from their vehicle or via a smartphone app provided by the vehicle manufacturer. 4. Ability to Enable Utility and Participant-Controlled Demand Response Events The BCEMD also provides the functionality to allow the Company or participants to control EV charging. Through the portal developed as part of the pilot, Con Edison is able to control the charging of all EV pilot participants and run demand response events. However, this control is limited to interrupting EV charging turning the vehicle off and then back on again. The utility portal provides summary graphs and data on all utility-controlled demand response events. A total of 27 utility-controlled events were conducted with the participation of 21 participants. Participants were asked to be present at the time of the test to confirm the 3/31/

32 interruption and resumption of the charging. On average each event lasted 2 minutes with an average of 4.4 kw of demand removed (ranged from 0.1 kw to 9.6 kw, total of kw). Response times may vary depending on several factors such as the vehicle type and on the strength of the cell service. On March 18, 2015, Con Edison conducted a participant-controlled test. With 36 hours advanced notice, an was sent to all 50 participants asking them to refrain from charging their EVs between the hours of 12 midnight to 1 am. The Company chose this time period because it represented the peak EV load for this group of EV customers. For the previous 30 weekdays, the total EV load peaked between 12 midnight and 1 am at 37.7 kw. This is similar to the start of the off-peak hours for the SC1 Rate III. During this test, the Company experienced near total cooperation; a total of less than 1 kwh was consumed by two participants during this event s time frame. Using the previous 30 weekdays as a baseline, participants were able to shed almost 37 kw from 12 midnight to 1 am. The Company observed moderate shifting of demand in the immediate subsequent hours, 27 kw at 3 am but this was still under the baseline daily peak at midnight. Furthermore, the Company observed that on the following day, EV peak demand was greater and charging occurred over a longer duration compared to the baseline. A greater number of participants charged the next day; indicating that participants may have forgone charging the day of the event and compensated by charging more the following day. Figure 3 compares baseline load to event day load and next day load. 3/31/

33 Figure 3. Customer-Controlled Event on March 18, /31/

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