R.12-06-013 – Residential Rate reform
R.13-12-011 – Water Energy Nexus proceeding
A.15-05-002 S-MAP Phase 2
A.15-09-010 – SDG&E Wildfire litigation
A.15-09-013 – SDG&E Gas Pipeline proceeding
R.16-02-007 – SB 350 rulemaking getting g to 50% RPS by 2030-40% GHG by 2030
A.16-03-004 - NDCTP (SONG Decommissioning)
I.16-10-015/016-Risk Assessment and Mitigation Phase 17-01-019- IOUs' DR Program Applications
R.16-12-001- Rule 18
A.17-01-012- Waiver of Certain Affiliate Transaction Rules for Interaction with Unregulated Subsidiary
A.17-01-020- Transportation Electrification
I.17-02-002-Aliso Canyon Natural Gas Storage Facility Located in LA.
A.17-02-008- Authority to Implement Economic Development Rates
A.17-03-019- Waiver of Certain Affiliate Transaction Rules for Interactions with Unregulated Subsidiary
A.17-04-027- Authority to Implement the Customer Information System Replacement Program
A.17-06-026 Review, Revise and Consider Alternatives to Power Char Indifference Adjustments (PCIA)
A.17-09-005- Implement Rate Relief and Increase Spend in Support of the San Diego Unified Port District’s Energy Management Plan
A.17-10-007-SDG&E 2019 Test Year General Rate Case
SDG&E Electric Vehicle Charging Stations Pilot Test
Summary of UCAN’s Objections
- All three major ratepayer protection groups oppose the proposed settlement. UCAN (Utility Consumers Action Network); TURN (The Utility Reform Network); ORA (Office of Ratepayer Advocacy)
- Too Big: SDG&E claims their 5,500 charging stations at 550 sites will make up only 20% of the eventual market for such services in 2025. UCAN is skeptical of this projection. If SDG&E’s chargers were all built today, they would represent 88% of today’s market.
UCAN recommended the CPUC adopt significant changes to SDG&E’s proposal, first that SDG&E’s proposal be reduced by more than 70% (from 550 sites to no more than 150 sites)
UCAN pointed out that SDG&E’s proposal for 10 stations per site was too rigid to accommodate the variety of locations and local EV populations that might support each site.
- Too Long: The pilot is proposed to last until 2037, that’s 22 years. Pilots do not normally last 22 years.
- Too Expensive: The current settlement proposal is a giveaway to SDG&E shareholders. Under CPUC rules, an IOU (Investor Owned Utility) gets to add all approved investments into their rate base, which means they can raise rates to ensure payback as they increase capital investments. So not only are they guaranteed to break even on the initial investment: they get a rate of return on that investment while the majority of ratepayers – who do not and will not own EVs – get to pay for this additional return to investors. Effectively, rates will increase by millions of dollars a year for these charging stations, and you will pay for this pilot through higher rates even if you don’t own an EV.
- SDG&E ownership of the Electric Vehicle Service Equipment (EVSE) is not necessary to test rate structure. Utility ownership of charging equipment has still not been adequately justified in the proposed settlement or the response to comments. SDG&E claims that they need to own the equipment to make sure it is useful for the life of the equipment. But SDG&E could take care of this “used and useful” problem by requiring locations they select for charging equipment to keep the equipment in Good Working Order.
- SDG&E wants to treat electric and gas ratepayers like tax payers and then impose a $100 million dollar tax increase. SDG&E has submitted testimony that suggests that, much like how taxes pay for state policy goals, the Public Utilities Commission can allow a rate increase to help meet the Governor’s policy goals for increased electric vehicle ownership. UCAN pointed out that ratepayers for essential services like electricity are not taxpayers and should not be treated as such.
- Misleading numbers from SDG&E. As UCAN’s expert points out, SDG&E has grossly miscalculated the cost effectiveness of this program by tossing into the calculations all the anticipated costs and revenues associated with expected organic growth in the EV market, i.e., all the growth that will happen with EVs regardless of whether this program is approved.
- Anti-competitive. SDG&E’s pilot may result in an anti-competitive environment for the private market place.
- Outrageous incremental cost per EV placed in service. SDG&E estimates that 3,300 additional EVs will be purchased in SDG&E territory due to greater access to SDG&E’s charging stations. UCAN did the math: SDG&E is asking for almost $103 Million for this “pilot” that will result, according to SDG&E’s own estimate, in an additional 3,300 EVs purchased in SDG&E territory. $103 million divided by 3,300 vehicles yields a cost to the ratepayers of $32,212 for each additional electric vehicle purchased.
- Equipment Obsolescence. Rapidly developing markets, like EV charging stations, undergo technological change rapidly, so it may be that the charging stations installed in this program will be obsolete before they are paid off. If approved, ratepayers will, of course, foot the bill for any obsolete equipment SDG&E purchases.
In addition to the objections noted above, UCAN has provided several other legal, factual and technical reasons why the CPUC should significantly scale back SDG&E’s proposal. Click here to learn more.
What is the California Public Utilities Commission?
The California Public Utilities Commission or CPUC is a state regulatory body tasked with regulating and monitoring investor owned (for profit) utilities in the state of California. Some of these include providers of electricity, water, and some telecommunications services, such as land line telephone services. The CPUC is made up of five Commissioners who are appointed by the Governor to staggered six year terms.
Why does the CPUC regulate investor owned (for profit) utilities?
In California our utility companies operate as monopolies which are regulated by the state legislature through the CPUC. The CPUC protects the public by making sure that Californians receive safe, affordable and reliable utility service. To accomplish this goal the CPUC sets the rates the utilities can charge for their services and policies which govern their operations. Since the investor owned utilities are monopolies, the CPUC is tasked with making sure that the public receives safe, reliable and affordable service while allowing the utilities to make a reasonable profit.
What is UCAN’s role with the CPUC?
UCAN is a nonprofit organization which represents the interests of utility consumers in proceedings before the CPUC. On energy matters, UCAN closely follows proposals and requests from SDG&E. UCAN also participates in a number of wide reaching rulemakings at the CPUC which sets utility policy and often have a statewide impact.
UCAN, as an advocate on behalf of the public interest, believes:
- Every household and business has a right to expect safe, affordable and reliable energy.
- Limited-income households, in particular, should not have to choose between energy and other necessities of life.
- Utility companies’ shareholders – not the public – should bear the costs of negligence and mismanagement.
- Utility companies should only be permitted to pass through to the public those expenses that are necessary, reasonable and prudent.
Advocating for these energy rights is a core mission at UCAN. We represent San Diego energy ratepayers by participating in legislative and regulatory proceedings, as well as by helping individual ratepayers in matters involving their utility service.
Electric Service Areas in California