Distribution Infrastructure and Planning to Support EV Charging

AB 841 (Ting, 2020) and EV Infrastructure Rules

The CPUC issued two resolutions in Fall 2021—one approving new Electric Rules for the large IOUs (E-5167) and one for the small IOUs (E-5168). These Electric Rules, known as the EV Infrastructure Rules, serve as alternatives to Rule 16 for any customer installing separately metered or submetered EV charging. Through the EV Infrastructure Rules, ratepayers cover the costs of service line extensions and electrical distribution infrastructure associated with EV charging. These Rules are one component of the CPUC’s implementation of AB 841 (Ting, 2020).

The establishment of the EV Infrastructure Rules signals a major policy shift in transportation electrification at the CPUC, as the new approach incorporates utility-side transportation electrification investments into the IOUs’ general rate case proceedings rather than individual program applications. Additionally, for separately metered or submetered EV charging installed outside of IOU transportation electrification programs, these Rules allow customers to cover less of the associated utility-side costs.

The IOUs began offering service under the EV Infrastructure Rules in mid-2022, and will begin reporting data from implementation in their EV Cost and Load report submitted in 2023. The data collection template for the EV Infrastructure Rules can be accessed here.

Energization Timing

The resolutions approving the EV Infrastructure Rules also address the issue of energization timing, or the time between a customer submitting an application with their utility to energize chargers to when the chargers receive power. In response to a proposal from the IOUs, the CPUC issued Resolution E-5247 in December 2022, which establishes an interim 125-business day average service energization timeline for projects taking service under the EV Infrastructure Rules. This timeline excludes projects that must go through Rule 15 for distribution upgrades, projects above two megawatts, and projects that require upgrades to a substation. The resolution directs the IOUs to collect one year of EV Infrastructure Rule implementation data to inform an updated proposal for a permanent service energization timeline.

On September 29, 2023, Energy Division staff hosted a public workshop to discuss issues pertaining to the Electric Vehicle Charging Infrastructure Service Energization Process and the adopted 125-Business Day Service Energization Average Timing requirement adopted via Resolution E-5247. 

The workshop covered the following items:

1. Establish expectations for the timing needed to complete a service line energization request and define the scope of each step when talking about EV service energization efforts. 
2. Present data reflecting the IOUs efforts to meet the 125-business day service energization average timeline and discuss if this data aligns with EVSP experiences. 
3. Discuss the IOUs’ data collection efforts, what the data collection categories demonstrate and what information is not being reflected, and ways to ensure the EV Infrastructure Rule service energization data collection process is consistent and informs other energization efforts that are being pursued through Rules 15, 16, and interconnection efforts through Rule 21. 
4. Identify ongoing barriers within the IOUs’ direct control that are impacting the IOUs’ ability to complete a service energization request within the 125-business day average and propose solutions for the IOUs to implement to overcome these barriers. 
5. Discuss the barriers outside of the IOUs’ control (customer, EVSP, AHJ, etc.) that are delaying the total time needed to complete a service energization request, identify the entity(s) responsible for addressing these barriers and how to pursue solutions with them.
6. Discuss the potential alternatives for accelerating the service energization process. 
7. Start the process of considering how to adopt a service energization timing requirement for projects currently excluded from the 125-business day service energization timeline.

The CPUC determined the discussions held on the September 29, 2023 workshop overlapped with the IOU-led workshop directed in Ordering Paragraph 6 of Resolution E-5247 and considered that IOU participation in the Energy Division staff’s workshop achieved compliance of Ordering Paragraph 6 of Resolution E-5247.

A recording of the September 29, 2023 workshop can be viewed here.

A link to the presentations can be viewed here.

Planning to Support Charging Infrastructure Deployment

The CPUC and its staff currently engage in a number of transportation electrification planning efforts to ensure the IOUs and the grid are prepared for the massive influx of EVs over the next several years. Leveraging the existing interagency coordination and planning framework, staff at the CPUC, CAISO, CEC, and CARB are working closely to ensure that our processes are planning for the expected growth in EV adoption over the next decade. This work includes, but is not limited to:

• The recent adoption of the 2021 CEC’s Integrated Energy Policy Report (IEPR) demand forecast—the starting point for all generation and infrastructure planning within the CAISO footprint—which reflects higher transportation electrification adoption consistent with CARB’s Advanced Clean Cars II and proposed Advanced Clean Fleets regulations;
• CAISO is using the Integrated Resource Planning (IRP) proceeding’s 2021 Preferred System Plan, reflecting the CEC’s 2021 IEPR forecast, in its 2022-2023 transmission planning process (TPP base case);
• The proceeding to modernize the electric grid for a high distributed energy resources future, authorizes the IOUs to use a variation of the CEC’s 2021 IEPR forecast to better study the distribution impact of high transportation electrification in their respective 2023 Grid Needs Assessments; and
• The CPUC’s new proceeding to advance demand flexibility through electric rates, which considers developing dynamic rates available for EV charging that may facilitate broader EV load management and grid support.