Comment Log Display

 
Recently the CPUC has approved 2 out of three plans submitted by
the large IOUs in CA to become involved in the build out of
electric vehicle charging infrastructure. Specifically the IOUs
will use rate based funds to perform what has become known as “make
readies” in the EV charging ecosystem. “Make readies” refer to
bringing electrical circuits to locations where EV drivers actually
might want to charge their vehicles. In a significant departure
from the long standing business model wherein a utility is
responsible for delivering electrical circuits to the perimeter of
a business location while the business owner is responsible for any
needed electrical infrastructure on campus, utilities will now
force rate payers to foot the bill for the required circuit right
up to the point of load. 
 
There are several aspects of this new model which are unusual,
unfair and anti-innovation. What is it about EV charging that is
different from any other business requirement for electricity? Why
should rate payers pay for the needed circuits for EV charging but
not for, say, washer driers in a Laundromat? Would the owner of the
Laundromat not be justified in suggesting that his business is just
as worthy of the utilities increased expenditure to run dedicated
240v circuits to each of his very necessary machines? Or perhaps
the owner of a factory should ask to have the rate payers foot the
bill for the circuits necessary to operate her machinery. There has
never been any precedence for such an action and for good reason.
It is not the job of the utility to ease the way for certain
businesses but not for others. Rather there should be an even
playing field for all businesses and those that have special
circuit requirements should find innovative business practices to
either reduce their costs or increase their revenues to cover those
costs. 
 
Municipalities, States and Depts. of Transportation have been no
more favored by the utilities or the CPUC in the past. The
utilities do not use ratepayers dollars to run circuits to stop
lights or street lamps or any other vital transportation or public
safety amenity and yet for some reason EV chargers have been
singled out for this treatment. Tax dollars have been rightly
channeled to the development of our vital infrastructure and the
processes ensuring that tax dollars are spent in the best interests
of the constituency are transparent, tried and tested.  
Surely there is very little difference between the CPUC allowing
utilities to force rate payers to pay for infrastructure which is
only used by a very small minority and the imposition of a tax on
those rate payers. They certainly have no choice in whether or not
they pay. 
 
The stark difference is, of course, that taxing authorities are
governed by elected officials who can be unelected if the
constituency does not agree with the spending of their tax dollars.
This is not the case for the CPUC or the Utility. Rate payers must
pay whether they agree or not. 
 
It is clear that the utilities are well motivated to push for this
new model. They make money when they spend the rate payers money on
infrastructure. Who can blame them for pushing for a decision to
allow them to spend more even on infrastructure which has never
previously been in their domain. What is less clear is why the CPUC
or anyone else in government would think this fair or a good idea.
If EV charging infrastructure is deemed vital enough to be worthy
of public expenditures (and I believe it is) then it should be tax
payers not rate payers who pay through the thoroughly vetted
process currently in place for all public infrastructure
expenditures.  
 
The EV charging industry is also well motivated to support this new
model. These new CPUC approved plans speak only to their erstwhile
failure to come up with innovative models to allow them to afford
the requisite infrastructure to make their businesses work. Forcing
rate payers to fill the gaps between their desire and need for
clean energy and sound business models which actually work is anti
free-enterprise and just the sort of unwarranted intervention into
the private sector that suppresses the very innovation which will
be so vital to the success of the EV charging industry. Why would
anyone invent a better mouse trap when the public is forced to pay
for the inferior model currently in use? 
 
Finally, forcing rate payers to upgrade electrical circuits to
support EV chargers will further increase the industry’s already
alarming reliance on the old Utility business model which relies on
centralized generation and a grid which is highly vulnerable to
failure. What will happen when 10,000 vehicles do not charge during
SDG&Es next 10 hour blackout? Instead of forcing utility rate
payers to subsidize this sort of infrastructure California's
government should be doing everything in its power to promote
innovative technologies and business models, especially those that
utilize clean, renewable, locally produced and stored energy which
does not contribute to green house gases and which is not
vulnerable to grid outages. Such solutions do exist and they do
work but CA will have to SMARTEN UP if it is to see them. From now
on, the first choice in EV charging electrical infrastructure
should be renewables, locally produced and stored and only in those
few occasions where these resources cannot be leveraged should the
grid be used as a backstop. In any event, rate payers should not be
forced to pay for the infrastructure. End users or tax payers
should – just like every other private or public use since the dawn
of electricity in the United States.