Texas Advocacy for Electric Transportation and EVs

Questions for PUC Docket 49125 • Relating to Electric Vehicles


Review of Issues Relating to Electric Vehicles

Texas Electric Transportation Resources Alliance (TxETRA) Ideas

Statement of Principle

The PUC of Texas should review issues regarding the deployment of Electric Vehicle Charging Stations and their impact on the ERCOT grid and market. The PUC should design rules governing Charging Stations with overall goals of eliminating market barriers and facilitating the development of an expanded electric transportation network within the state, while ensuring service provision in areas beyond the reach of the competitive market.

Recommended Topics for PUC Review

I.  Overview of Electric Vehicle Market

A.  What is the current market for EVs in Texas?

· What types of and how many EVs are operating in Texas?

· Where are the EVs located?  


B.  Where is the industry going in the next 15 years?

· What are the projections for growth of EVs?  (Break out by light duty, medium duty, busses, and heavy-duty vehicles.)

· What are the current estimates for development of electric vehicle market and estimates for demand? 

· Are there anticipated load “hot spots” or “pockets”?

C.  What are the other drivers of the EV market?

· What is the impact of Federal policy?

· Are there current state policies or incentives that affect the EV market?

D.  What are the current efforts of regulated and non-regulated utilities and REPs in ERCOT and IOUs outside of ERCOT related to EVs and Charging Stations?

· How many charging stations are already available in Texas? Where are they? Who owns them?

· What are the projections for growth in the deployment of Charging Stations?

· What are the current distribution tariffs that are applicable to Charging Stations?

E.    What is the regulatory status of an entity providing retail charging services in competitive areas of the state?

· Does the entity providing the charging service have to be a retail electric provider if operating in the competitive areas of the state?

· Are there other regulatory classifications that apply to providing retail or wholesale charging services?

II.  Issues Related to Deployment of Charging Stations 

A.  Should the state develop policy governing the deployment and operation of Charging Stations?

· What regulatory barriers, if any, are there to the development of EV Charging Stations that are within the scope of the PUC’s jurisdiction to address?  

· Should there be public policy encouraging deployment of Charging Stations or will market forces be sufficient?

· If not, what policy should be implemented to provide incentive to deploy them in rural and other potentially underserved areas?

· Should utility tariffs be designed to provide incentives to deploy Charging Stations in certain areas of the state?  For example, different connection fees depending on impact to distribution grid or time of use distribution fees? 

B.  Where should Charging Stations be located?

· Should the state have a policy for placement of Charging Stations and if so, what should be the guiding principles?

· Should Charging Stations be located on all major roadways of Texas?

· Should Charging Stations be located in commercial centers and large multi-family area?

· What areas of Texas might be underserved? Are these areas primarily rural, or could certain urban and suburban areas also be underserved?

C.  Who can own and operate Charging Stations in competitive areas of the state?

· Is ownership of Charging Stations a competitive service?

· If so, should there be an alternative ownership structure or incentives for underserved areas? 

· Should utilities be allowed to provide Charging Stations in underserved areas?

· If a utility is allowed to own and operate a Charging Station, how should the costs associated with that be recovered? 

· To what extent may a utility cooperate with third parties to develop Charging Stations?

D.  How should Charging Stations be funded and compensated?

· Should Charging Stations be funded by the provider installing them?

· Should EV owners pay a fee, added to the cost of charge or other ways than for using the Charging Station, for expansion of the system into underserved areas?

· How will this vary by type of utility?  

E.  Should the state mandate standards for the operation of Charging Stations? If so, under what conditions 

· Should the state determine interoperability standards or standards for universal connections between the plug on the charger and the vehicle?

· Should reliability standards be developed?

· Should Charging Station meter accuracy be monitored and regulated?  If so, how and what regulatory agency should monitor this?

· Should certain price and other disclosures be required on each Charging Station? If so, what should those be? 

III.  Issues Related to ERCOT Grid, Market, and Long-Term Planning

A.  What is the impact on the Distribution Grid?

· What is the estimated amount of new load over what period of time?  Does this load vary based on types of EV, such as light duty, medium duty, or heavy duty?

· What are the different impacts of home charging versus commercial or fleet charging?

· How should utilities and regulators incorporate current and future demand from Charging Stations in their various planning processes?

· Should a preference be given for placing a Charging Station in a location where the distribution system is adequate?  For example, should there be different connection fees depending on the impact to the distribution grid?  Are there other incentives or disincentives that could be used?

· Should the PUC create policies to encourage off-peak charging (similar to time-of-use rates for the price of energy)?  Should time of use rates be adopted for distribution system rates applicable to Charging Stations?  What are the best practices from other states or nations?

· What are the impacts of Charging Stations on a utility’s distribution grid and how should it be incorporated into planning?

· Should distribution utilities be allowed to build infrastructure to support potential charging stations before the actual need is there?

· Should the Commission require more distribution system transparency to facilitate location of Charging Stations?

B.  What is the impact on the ERCOT Market?

· What impact will Charging Stations have on peak demand? 

· Are there impediments in the ERCOT market structure that would limit the ability of charging stations to participate in the wholesale market?

· Is there guidance that the Commission should provide ERCOT to enable the integration of EV charging stations into the wholesale market or to discourage adverse impacts to peak demand on the grid?

C.  What is the impact on long-term Planning in ERCOT or in non-ERCOT areas? 

· What is the impact on needed generation?

· Is there an impact on transmission planning?

· What, if any, consideration should be given to vehicle to grid technology capabilities?

IV.  Role of the PUC and Other State Agencies

A.  What is the role of the PUC?

· What is the role of the PUC in developing and regulating the policies and rules governing Charging Stations?

· Is offering EV charging service in competitive areas of the state an activity subject to PUC regulatory authority?

· Is the resale of electricity purchased at a charging station subject to Commission jurisdiction and regulation?

· Should the state mandate customer protection standards for the operation of Charging Stations?  Are there customer disclosures the Commission has jurisdiction to require? Are there consumer disclosures that should be adopted by other state agencies 

· What issues should the Commission address in the near term; what issues should the Commission not address until the market develops more fully; and what issues should the Commission not address until after action by the Legislature?

B.  What is the role of Other State Agencies?

· What is the role of other state agencies in developing and regulating the policies and rules governing Charging Stations?

· What is the role of other state agencies in expanding the adoption of EVs and the deployment of Charging Stations?

C.   What other issues should the Commission consider as part of this inquiry? 

V.  What potential legislative changes might be needed?

Potential Organization of Commission Workshops


·  First Workshop: Questions I and II

·  Second Workshop:  Questions III - V