Owner Operator Service Contract

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					LCFS Electricity Workgroup
   Wednesday, July 14, 2010

        LCFS Regulated Party
           for Electricity
• The electricity service provider unless one
  of the following exists:
  – Bundled service provider who provides
    access to vehicle charging under contract with
    vehicle owner/operator
  – Owner of charging equipment, provided a
    contract with service provider exists
  – Owner of home with charging equipment,
    provided contract with service provider exists
    Regulated Party Example
• A utility installs EV charging equipment at
  a residence.
• The utility is eligible to receive LCFS
  credits for the electricity supplied as a
  transportation fuel.

     Regulated Party Example
• Macy’s offers EV charging to customers
  through charging equipment they have
  installed in their parking lot.
• The local utility is eligible to receive LCFS
  credits for electricity fuel delivered
• Macy’s and the utility have agreed through
  a written contract that Macy’s will receive
  LCFS credits.
     Regulated Party Example
• A parking lot owner installs EV charging
  equipment in the lot for customers.
• The local utility is eligible to receive LCFS
  credits for electricity fuel delivered
• The parking lot owners and the utility have
  agreed through a written contract that the
  lot owner will receive LCFS credits.
    Regulated Party Example
• A third party offers EV charging, through a
  network of charging stations placed in
  public places, to customers who pay for
  ongoing access to the network. The
  network may include standard chargers,
  fast chargers, or battery swap stations.
• The third party providers are eligible to
  receive LCFS credits.

Reasons for Third Party Default
• Third party bundled service providers are
  eligible to receive credits by default.
• Bundled service providers install charging
  infrastructure and sell fuel.
• Similar to regulated party for CNG –
  parties who establish infrastructure may
  receive credits.
• Charging infrastructure necessary for the
  success of the LCFS.
• “(B) The electricity services supplier, where ”electricity
  services supplier” means any person or entity that
  provides bundled charging infrastructure and other
  electric transportation services and provides access
  to vehicle charging under contract with the vehicle
  owner or operator;”
• Should regulation language be revised to
  distinguish between one time
  infrastructure install vs. ongoing access to
• Suggested regulation language?
• “(D) The owner of a home with electric vehicle-charging equipment,
  provided there is a contract between the homeowner and
  provider of electricity services specifying that the homeowner
  may acquire credits.”

• Should regulation language be revised to
  clarify that the contract is between the
  utility and the homeowner rather than
  between a third party provider and the
• Suggested regulation language?
• Cogen electricity generation –company
  who generates electricity, supplies to grid,
  and provides vehicle charging wants to
  generate LCFS credits
  – Need link (contract) to vehicle charging
  – Would require regulation change
• Suggested regulation language?

   CPUC Alternative Fueled Vehicle Proceeding
        Senate Bill 626 (Kehoe, 2009)

• Requires the PUC to develop rules to overcome barriers
  to the widespread deployment and use of PHEVs and
  BEVs by July, 2011

   – (A) Electrical infrastructure impacts, the role and development of
     public charging infrastructure
   – (B) Impact on grid stability and integration of renewable energy
   – (C) Technological advances
   – (D) Code and Permit Requirements
   – (E) Impact of PEVs on AB 32 goal attainment, RPS, and what
     steps should be taken to address emissions shifting from
     transportation to electricity sector

   CPUC Alternative Fueled Vehicle Proceeding
              Rulemaking Status
• May 2009: Issued comprehensive staff white paper
   – Recommended new OIR to reduce barriers
• Fall 2009: Issued Order Instituting Rulemaking.
   – Comments from over 20 parties
• January 2010: Phase I Scoping Memo:
   – March 16 2010: Joint Agency Home Charging Workshop
• May 21: Commissioner Ryan Proposed Decision
   – Ownership or operation of facility that sells charging services as motor
     vehicle fuel does not make the person/corp. a public utility under PU
     Code S 216 / S 218
• June 24: SDG&E TOU EV rate pilot approved
• June 29: Revised PD of Comr Ryan
   – Reaffirms initial PD conclusion; identifies other sources of CPUC
     authority (i.e., PU Code S 740.2) to address PEV impacts on grid and
     PEV impacts on GHG/RPS attainment
• July 29: Next CPUC Business meeting

     CPUC Alternative Fueled Vehicle Proceeding
       June 29, 2010 - Revised PD on Phase I
•   Ownership or operation of a facility that sells charging services as motor vehicle fuel does not
    make the person/corporation a public utility - PU C. S 216 and S 218

•   PU Code S 740.2 grants the PUC authority to develop rules to avoid adverse grid impacts and to
    attain GHG and Renewable goals

•   Additional PUC Authority:
     –   Procurement authority (Inc. RPS, RA, EPS)
     –   Notification and Application requirements for new service
     –   Rule 3 – existing customer changes to electrical load notice
     –   Tariff terms of service
     –   Dist. Line upgrades (Rules 15 & 16)
     –   Interconnection Rules (21)

•   Electric vehicle charging service provider will generally be an end-use customer
     –   Net costs (Impacts and benefits) recovered via D,T (potentially G) cost component of tariff (PU Code S 454)
     –   Charges can include volumetric (kwh), demand (based on time), and fixed charges
     –   If IOU provides electric vehicle charging services, provision of such services will not affect the utility’s status

•   Policy Context: Widespread use of PEVs complements CA efforts to reduce GHG, integrate
    intermittent renewables, reduce petroleum consumption

•   SB 1435 (Padilla)

    CPUC Alternative Fueled Vehicle Proceeding
                     Phase II

•   Health and Safety (Bus. And Prof. Code)
•   Utility Role / Boundary
•   Metering arrangements
•   Net cost determination/allocation
•   Pricing signal principles
•   Tariff Rule modifications
•   Smart charging incentives
•   Intra-/inter-utility billing
•   Smart Grid OIR: Standards and Metrics
•   Post OIR – Utility Tariff Applications

     Metering Requirements/
Estimating LCFS Electricity Credits
• Direct metering required if installed
• Direct metering required in all cases
  January 1, 2015 and thereafter
• An estimation method may be used prior
  to 2015 ( if no meter installed) provided
  the method has been approved by ARB
• We encourage regulated parties to begin
  the process of method approval prior to
  November 2010.
   Nonroad Electricity Credits
• Examined expected nonroad population of
  electric vehicles
• Examined potential interaction of LCFS
  nonroad credits with other programs
• LCFS implementation issues have pushed
  nonroad credit work to a future date

          LCFS Credits and
         AB32 Cap and Trade
• LCFS credits may flow into a credit
  program that is designed to accept them.
• Tentatively the AB32 system will not
  accept LCFS credits.
• AB32 rulemaking still in progress.

             Next Steps
• Continue to monitor CPUC rulemaking
• Potential Board update in December 2010

        Contact Information
• Carolyn Lozo
  (916) 355-1860
• Renee Littaua, Manager, Fuels Section
  (916) 322-6019


Description: Owner Operator Service Contract document sample