Save the Sound and the EV Club of CT respectfully submit the following written comments as part of the Annual Review of the Electric Vehicle Charging Program

Save the Sound and the EV Club of CT respectfully submit the following written comments as part of the Annual Review of the Electric Vehicle Charging Program – Year 2 in response to the Notice of Request for Written Comments issued by the Public Utilities Regulatory Authority (the Authority) on August 5, 2022. 

1. Provide comments on the EDCs’ proposed Level 2 EVSE Lease Program at MUDs, filed as Motion Nos. 3 and 4 in this proceeding, including but not limited to, each Companies’ established program parameters, pricing methodologies and proposed charges, and pricing for underserved customers. 

The United Illuminating Company (UI) proposes to establish a 5-year minimum leasing period, with an option to renew for a second 5-year term. At the end of a second consecutive lease term, ownership of the EVSE will revert to the customer. The schedule of monthly charges for various EVSE configurations is identical for baseline and underserved customers. Eversource has also proposed a lease program consisting of two consecutive 5-year leasing periods, with ownership reverting to the customer at the end of a second 5-yer lease. Unlike UI, Eversource proposes a lower monthly leasing rate for “underserved” customers installing EVSE located greater than 50 feet but less than 75 feet from electric service and for installations with four charging ports. 

 We recommend that the Authority investigate the opportunities available to United Illuminating to also offer a discounted rate for EVSE installations in underserved communities, as this serves one of the four main objectives of the EV Charging Program. Specifically, the Authority has stated that among the goals of the EV Charging Program is to “achieve an equitable transition to wide-scale EV deployment across all communities in Connecticut.”1 Providing additional support to encourage the deployment of EVSE at MUDs in underserved 

2. Provide comments on Eversource’s and UI’s Motion Nos. 8 and 9 in this proceeding, which include the following program proposals pursuant to Order No. 12 of the Final Decision: a. Proposed solution for offering an EV-only tariff within the Residential MUD Level 2 Charging Program that adopts a model similar to San Diego Gas & Electric’s “Power Your Drive” program; 

As noted by both Eversource and United Illuminating, the original design of the SDG&E “Power Your Drive” program relied on a complex rate mechanism tied to day-ahead hourly energy prices that did not provide substantial benefit over a less complex EV TOU rate structure to encourage off-peak vehicle charging. After an evaluation of the program, the California PUC made the following modifications to the PYD EV charging program: 

 EVSE only owned by the utility if the MUD is in an underserved community. 

 Site hosts pass the underlying time-variant price signals to customers, with the option to offer customized pricing.

  “Rate-to-Host” EVSE owners offering customized pricing to drivers were ordered to work with the utility to ensure desired charging behaviors and to reduce adverse impacts to the grid.

It is unclear what a “customized pricing” option would look like in Connecticut and what ultimate price drivers might be charged for a session. If the goal is to ensure that vehicles are charging during off-peak periods, allowing a custom pricing arrangement (without parameters or guardrails) could easily frustrate this purpose. Generally, the simpler the program is for customers to understand and access, the more successful it is likely to be. Under a MUD managed charging program there would also seem to be some need for caution in permitting MUD site hosts to set pricing for EV charging. This discretion could both negate other price signals encouraging off-peak charging or seek to charge unreasonably high rates to MUD residents as a “captive” market for the on-site EVSE, negating the benefit of convenient “at-home” access to charging.

While site-hosts should be compensated for the costs of installing and maintaining EVSE (to the extent not covered by program incentives), the Authority should consider if the pricing for the charging itself should be the mechanism to recover that. Perhaps MUD residents who wish to access the EVSE could pay a small monthly or annual fee to access that particular amenity, with the charging itself being a straight pass-through cost based on the utility-set TOU rate. Equity concerns should also be considered with respect to the management of EVSE at MUDs in underserved communities. b. Proposed key program parameters and a suggested timeline for implementation of a managed charging program at participating MUDs; and Given the above considerations, and potential variety in approaches even under the MUD managed charging proposal set forth by the CT EDCs, it would seem that the suggestion of beginning with a managed charging pilot program to field test site host capabilities and tenant charging behavior is sound. We would suggest, however, that such a pilot be implemented as soon as possible in order to be able to apply lessons learned in a timely and effective manner. Specifically, and in contrast to the recommendation by the EDCs, we would urge that the pilot program be implemented prior to the second half of 2023.

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