FC1130 - 2020 - M - 516, FC1155 - 2020 - E - 28 ~ pepco. RECEIVED 2020 JAN 29 4:09 PM An Exelon Company Dennis P. Jarnouneau Assistant General Counsel EP9628 701 Ninth Street NW Wash111gton DC 20068-000 I Office 202 872 3034 Fax 202.331 6767 pepco.corn djarnouneau@pepcohold1ngs com January 29, 2020 Ms. Brinda Westbrook-Sedgwick Commission Secretary Public Service Commission of the District of Columbia 1325 G Street N.W., Suite 800 Washington, DC 20005 Re: Formal Case Nos. 1130 and 1155 Dear Ms. Westbrook-Sedgwick: Enclosed please find the Transportation Electrification Working Group's report, prepared and submitted in accordance with Order Nos. 19898 and 19983 in the above referenced proceeding. Please feel free to contact me if you have any questions regarding this matter. Sincerely, D~ouneau Enclosures cc: All Parties of Record District of Columbia Transportation Electrification Working Group Background The temporary Transportation Electrification Working Group (the “TE Working Group”) was established by the Public Service Commission of the District of Columbia (the “Commission”) in Order Nos. 19898 and 19983 (collectively referred to as “Orders”) to further explore and develop the portfolio of program offerings (the “Offerings”) noted by the Commission for Pepco’s Transportation Electrification program approved in part by Order No. 19898 on April 12, 2019. In the Orders, the Commission directed Pepco to meet with Staff and other working group members to address members’ concerns regarding Offering 4 and Offering 5 and site selection for Offering 10 and report back to the Commission within 180 days. 1 Given the level of interest in other Offerings approved in Order No. 19898, the TE Working Group also discussed Offerings 7 and 8 in a collaborative setting. 2 The TE Working Group met on the following dates to review the relevant program topics: • • • • • September 16, 2019 – Offering 4, Residential Rebate Charging October 22, 2019 – Offerings 7 and 8, Public Make-Ready Charging and Meter and Data Collection November 13, 2019 – Offering 5, Multi-Dwelling Unit Charging and Meter and Data Collection continued December 9, 2019 – Offering 10, Taxi/Rideshare Make-Ready Charging and revisiting Offering 4, Residential Rebate Charging January 14, 2020 – Review Working Group Draft of Report Pepco, on behalf of the TE Working Group, herein submits as its deliverable, a Report summarizing findings and, where applicable, recommendations based on the topics raised by the members during the working group process. Minutes for each meeting are included in Appendices 1 - 4 of this Report. The TE Working Group was also advised by Commission Staff that interested persons will be permitted to provide additional comments on any program proposals or Offering modifications prior to final approval by the Commission. Introduction The topic of Electric Vehicle (“EV”) charging presents complex issues and opportunities, encompassing varying viewpoints on achieving the District’s clean energy goals. Where possible, the TE Working Group sought to reach a consensus on the Offering components discussed. For those topics in which a consensus See Order No. 19898 at P 73. Order No. 19898 also directed Pepco to discuss the “Maryland Approach” to submetering, or using embedded meters in charging stations. This directive was also discussed and is included in this report. 1 2 1 could not be reached, the varying viewpoints of members are presented within this report and attributed, as appropriate. In addition, Pepco has and will accept the feedback presented by working group members in the design, implementation, and refinement of the Company’s program. Because this is a five-year program, there will continue to be lessons learned as investments are made and as the EV market in the District of Columbia continues to evolve. As new technologies emerge, consumer preferences and behavior will become better established, allowing for best practices to be adopted for this program to shape the charging ecosystem. Also important, future electrification programs will be shaped by local government policies. The Offerings, which will be implemented by Pepco as part of this program, are a significant and necessary initial step to provide the infrastructure necessary to help fulfill the commitments set out in the Omnibus Act. Pepco’s approved program is only a small component of the broader effort needed to meet the District’s goals. The stakeholder process for the TE Working Group has demonstrated there are many ideas from many groups interested in helping to shape electric transportation infrastructure in the District. Offering 4 – Residential Rebates for Smart Level II Charging Under Offering 4, Pepco’s application proposed to provide $500 rebates for up to 500 Pepco customers in the District to install a smart Level II charger 3 at their premises. The rebates would be offered to the first 500 customers to apply for the program. As the majority of EV charging currently occurs at the driver’s home, Pepco noted in its application that, among other things, this Offering will help offset initial costs and incent EV adoption in the District. The Commission did not approve Offering 4 in Order No. 19898. Rather, the Commission stated that, “to gain greater clarity on the merits of the residential rebate program, and to ensure that any recommended rebate level aligns with the program specific benefits, the Commission refers Offering 4, a fixed price residential rebate,” to the working group for consideration. 4 In the working group, Pepco explained that smart chargers are needed for the utility to: (i) collect data on how the charger is being utilized, (ii) gauge trends in demand and (iii) assess the potential for managed charging programs, if such programs are later needed to lessen the load on transformers as EV adoption increases as expected. If approved, Pepco is committed to sharing non-confidential charging data in its quarterly reports to the Commission, which could be used to shape future programs and determine system needs. As noted in Order No. 19898, Pepco was authorized to offer a $300 rebate (to cover the incremental difference between a smart Level II charger and a non-networked charger) to support a comparable residential charging program in Maryland. 5 The smart Level II chargers approved by the Maryland Public Service Commission for use in Pepco’s Maryland program range in cost from approximately $600 to $1,000. As Pepco explained to the working group, similar offerings currently exist as a part of utility EV programs in other parts of the United States and a summary provided by Pepco noted that there are at Pepco considers smart chargers as those with communication and load management capability in addition to demand response capability. 4 Order No. 19898 at P 42. 5 Order No. 19898 at P 42. 3 2 least 22 existing residential rebate programs offering rebates ranging from $150 to $2,500 for both smart and non-networked chargers, with some programs including installation costs. These costs are within the range of Pepco’s proposal for $500 rebates. DOEE argued that managed charging and dynamic pricing could be pursued immediately and that other data sources be considered, including whole-house AMI or on-vehicle telemetrics. DOEE also asserted that any rebate design or use of ratepayer funds for residential EVSE should account for existing incentives available for residential EVSE, including the Alternative Fuel Infrastructure and Conversion Tax Credit. This tax credit provides a non-refundable tax credit of 50% of the allowable costs for the purchase and installation of a charging station at a private residence. The tax credit shall not exceed $1,000 per station at a private residence. The tax credit is available until the taxable year ending December 31, 2026. 6 The working group was not able to come to a consensus on the merits of a residential rebate charging program, such as Offering 4, nor components of the program (the number of participants or dollar amounts for rebates). Pepco requested member participants provide written feedback on key components for this Report. Comments received are included as Appendix 5. The written feedback, as well as additional commentary from other TE Working Group members, is summarized in the bullets below: Support for Offering 4 • • • • • Support for integrating higher levels of EVs and incentivizing EV drivers (ChargePoint) Support for Pepco’s Offering 4 under the conditions that rebate recipients agree to participate in future time-of-use (TOU) rate offerings and/or load management programs, that such offerings and programs be developed by Pepco by a specified date, and that Pepco be separately required to propose TOU or load management programs that utilize the communication software in vehicles themselves to avoid the need for smart meter installation. (Sierra Club) Support for targeting the higher cost associated with smart, networked chargers because they will unlock greater value for all ratepayers by providing better visibility and understanding of charging behavior and by enabling managed charging. (Greenlots) Residential charging rebates are a common and vital element of utility EV charging programs (ChargePoint) Support for quantity of 500 customers and a $500 rebate amount (ChargePoint) (Sierra Club) Opposition to Offering 4 • • Pepco has failed to clarify the merits of this offering. (DOEE) In addition, DOEE claims several deficiencies in Offering 4, including that learnings regarding charging behavior can be met without the offering, that Pepco did not present information on the benefits to the District customers or how the offering advances the District’s climate goals, or why subsidies for Smart Level II chargers are necessary. DOEE also states that the Offering raises equity concerns and that any such programs should prioritize mass transit over residential charging. (DOEE) Additional information on the Alternative Fuel Vehicle Infrastructure and Conversion Tax Credit available: https://otr.cfo.dc.gov/sites/default/files/dc/sites/otr/publication/attachments/AlternativeFuelVehicleInfrastructur eandConversionCreditsFAQs.pdf. 6 3 • • • The Offering is not in the public interest and does not provide the necessary benefit to support ratepayer funding. The chargers would be located on private property, but funded by ratepayers for private use strictly and adds an additional $250,000 of costs onto the backs of ratepayers. (OPC) EVADC opposes this Offering for the reasons stated by DOEE and also because, in its view, it perpetuates the false perception that a dedicated EVSE unit is necessary for owning an EV, in turn slowing EV adoption. (EVADC) General opposition to the Offering (AOBA agrees with DOEE and OPC also) Suggested Offering modifications/design considered by TE Working Group members Throughout the discussions of Offering 4, some members provided suggested modifications for consideration by the working group. They are as follows: • • • • • • • • If approved, the Offering should be a pilot with costs assigned directly to residential customers. (AOBA) If approved, customers should agree to provide data for a specific timeframe (i.e., actively participate) and customers must refund the rebate if the customer does not meet the active participation standards. (AOBA)(OPC) If approved, rebates should be limited to one per customer and issued on a first-come, first-served basis. (AOBA) Required customer participation in load management/Time of Use (TOU) rate program (see supplemental tactics). (Sierra Club) o The Commission should reevaluate program after one year to assess progress of load management programs and ongoing necessity of Level II rebates. (Sierra Club) Customers should have the ability to choose from a variety of hardware and networks. (ChargePoint) Pepco should lead a centralized RFQ or RFP process to ensure the technology meets Pepco’s needs; leverage industry competition to achieve the best value; and simplify the process for end users. (Greenlots) Encouragement for cybersecurity qualification to protect consumer data and Energy Star certification to encourage energy efficiency. (ChargePoint) Consider including installation costs with rebate (up to $500 total). (ChargePoint) Alternative (and supplemental) proposals for residential rebates for smart charging considered by TE Working Group members Several working group members did not fully support Offering 4, but suggested alternative pilots or program offerings that incentivize EV charging behavior that reduces adverse impact to the distribution system, including: • • Rate design and load management activities designed to encourage residential charging (OPC) Utilize dynamic pricing, including TOU rates to incentivize residential EV charging during off-peak periods. (DOEE) 4 Leverage the approved Whole House TOU rate (schedule RPIV) and/or future dynamic pricing rate designs to direct charging behavior. (DOEE) o Load management program should utilize communication capabilities. (Sierra Club) o Utilize on-vehicle telematics and metering to the extent possible. (DOEE) o Customer response to dynamic pricing and load management programs should be enhanced through the use of behavioral messaging and feedback mechanisms. (DOEE) Develop models of residential charging behavior through market research and non-intrusive EV load modeling. (DOEE) o • Pepco appreciates the perspectives of the members and has incorporated several recommendations into its final recommendation to the Commission. The Company continues to support a $500 rebate for up to 500 customers for Offering 4, with several modifications based on member feedback. For example, the Company agrees that load management and similar activities are critical to supporting increased vehicle electrification in the District, and Pepco would select EVSE for this program that are capable of providing future grid support. In addition, the Company sees merit in implementing this Offering as a pilot program to be reevaluated after a period post-commencement. Pepco also agrees the Offering could be modified to require residential customers to participate in the program for a set timeframe (ex: a minimum of one year) to retain their rebate. The TE Working Group recommends the Commission make a decision on this Offering based on the information presented in the proceeding and feedback from the TE Working Group. Offering 5 – Multi-Dwelling Unit Charging Offering 5, which the Commission directed the Working Group to evaluate, was discussed in the working group at the November 13, 2019 meeting. Under Offering 5, Pepco proposed to provide a 50% discount on up to 100 smart Level II chargers and a 100% discount on the cost of the chargers’ installation at condominiums, apartments, and other multi-dwelling units (MDUs). Pepco included this Offering in its application to incent and provide charging opportunities for residents in MDUs that lack the charging options available to residential customers with dedicated driveways and garages to install EVSE. Pepco would use the data collected from the smart chargers to analyze customer usage and patterns, refine marketing and outreach strategies, and assess impacts from EV charging on the distribution grid. The Commission, while noting the “clear value in an EV charging Offering focusing on MDUs,” did not approve Offering 5 in Order 19898. Instead, the Commission directed the working group to: 7 • • • • Collaborate on the development of a draft tariff Determine coordination and services provided by Pepco to MDU owners for the program Review selection criteria, identify beneficiaries, and determine the appropriate deployment numbers Determine the benefits and/or necessity of a 2nd meter for this program ( Please see Second meter utilization and submetering, below) The TE Working Group notes some members question the need for this offering and believe MDU owners should be responsible for the purchase and installation of EVSE in their buildings, and District goals emphasize reducing the number of light-duty vehicles in favor of other modes of transportation. These 7 Order No. 19898 at P 44. 5 members include AOBA and OPC. Members in favor of an MDU charging Offering as part of Pepco’s Transportation Electrification Program include Sierra Club, ChargePoint, ABB and Greenlots. EVADC believes residents of MDUs should be able to charge their EV by way of a submetered outlet to their existing Pepco account. Tariff Development As part of its application, Pepco proposed a new tariff – MDU-PIV – to apply to customers that participate in this Offering. While the working group considered whether a rate mechanism could support this Offering, neither the Company’s proposed MDU-PIV rate schedule nor the other rate mechanisms discussed were generally supported by the working group. As an alternative to MDU-PIV, Pepco presented a demand charge credit that would credit MDU charger owners the demand charge equivalent amount of 50% of a charger’s nameplate capacity. The group could not come to a consensus on whether demand charges are barriers to EV charger installations in MDUs. AOBA believes that demand charges may be a barrier to EV Charger installations, but stated that Pepco has not presented sufficient data to make that determination. ChargePoint encouraged reconsideration of this approach at periodic intervals throughout the program based on the participation rates and feedback. The working group also discussed the notion of a time-differentiated rate, and such a proposal was also met with greater interest by the group than the MDU-PIV tariff. Pepco described potential challenges to this concept for MDUs because schedules of MDU residents driving EVs may not necessarily coincide with typical hours for off-peak charging programs. It was suggested that establishing a shorter on-peak window could address Pepco’s concern. Similar to the demand charge credit, this option did not receive the group’s full support with some members expressing a preference for charging rates to be less complex in nature. While the TE Working Group could not come to a consensus on a tariff solution for MDUs, Pepco believes existing tariffs are sufficient for MDU charging. Alternatives Ratepayer Solutions to Smart Level II Charging for MDUs As opposed to deploying Level II chargers to support EV drivers in MDUs, the Electric Vehicle Association of Greater Washington, DC (EVADC) recommended deploying standard NEMA 5-20 or 14-50 outlets in parking spaces of the MDUs, as opposed to hardwired EVSEs with fixed J1772 connectors. These outlets would be sub-metered, and the parking spot reserved for an individual tenant. EVADC views this alternative as preferable, because EVs come with their own portable EVSEs, and by using their own portable EVSE, the driver has a direct relationship with Pepco. According to EVADC, this setup avoids unnecessary intermediaries between the driver and the grid, while also allowing the driver to purchase power at tariff-set rates from the same provider they chose for their home service. Under this scenario, tenants in MDUs should be able to access the same SOS tariff as home-owners with their own off-street parking. Further, EVADC posited the program dollars would be better used if the outlet solution were adopted since that option is much less expensive and could therefore be implemented on a wider scale. Additional comments from EVADC on this alternative are included in Appendix 6 of this Report. A general consensus was not met for this alternative. 6 • • • • • • • Some of the working group members supported the idea due to the anticipated lower costs and potential for supporting a higher number of customers. OPC states that as EV evolves, less costly solutions should be looked at and that this proposal should be contemplated as a more equitable solution for MDU and ratepayers. (OPC) Sierra Club supports pre-wiring of new and rehabilitated buildings to support EV charging and could potentially support to re-wire existing buildings to better support EV. For Offering 5, however, given its limited size, Sierra Club supports the offering as proposed so long as Pepco offers a time-differentiated (TOU) rate for these stations that takes advantage of the smart features of the installed Level 2 charging stations. (Sierra Club) Other members questioned this engineering practicality, potential safety hazards, increased maintenance requirements and that outlets are a short-term solution not well adapted to anticipated rates of EV adoption, concern was also expressed that this approach would significantly curtail the ability of Pepco to manage the impact of charging on the distribution system, which could be critical to mitigate system upgrades as EV adoption increases. (Greenlots) ABB commented this alternative would lead to a lesser experience for EV drivers and presented other potential challenges related to management and grid benefit described in further detail in Appendix 6. Pepco has presented no data on the safety of the proposals. (AOBA) ChargePoint expressed support for Pepco’s proposal of qualifying networked, Level 2 EVSE capable of utilizing embedded metering and controls to provide charging data and load management optionality for greater grid benefits. ChargePoint further notes the existing proposal does balance ratepayer costs and value through the use of participant cost share and caps, and is the recognized approach for nearly all similar utility programs throughout the U.S. DOEE encourages Pepco to explore incentives for Level 1 charging for MDUs, which may provide sufficient charging capability for many residential charging needs with a lower distribution system impact. Coordination and Services from Pepco to MDU Owner In its initial application, the Company did not specify a ceiling amount for the installation costs for Offering 5, however, if approved, Pepco noted its intent to model the Offering similar to the Company’s MDU program in Maryland, which has a ceiling of $7,500 for installation costs. While the TE Working Group agreed a ceiling should be established for installation costs, there was not general consensus on the dollar amount or methodology. ChargePoint agreed with proportionally limiting utility incentives but recommended a similar cap per station as well as a higher value cap per site to allow for greater participation and more equal treatment to much larger multifamily facilities serving many EV drivers compared to smaller properties. The TE Working Group collaborated on additional coordination items for Pepco and MDUs if the Offering were implemented. The Group’s recommendations are summarized as follows: • • • • Strong MDU/tenant education and outreach (outreach will likely bear additional costs) (DOEE) Cost-effective advertising/direct mailing campaign Website development to illustrate a calculator/estimate for program incentives (DOEE) Partnerships for outreach to include: 7 o AOBA, the PSC website, Clean Cities Coalition (DOEE) Selection criteria, identification of beneficiaries, deployment numbers The TE Working Group reviewed several categories to discuss criteria for an MDU charging program (as proposed in Pepco’s application for smart Level II chargers). The categories and observations are summarized as follows: • Deployment numbers – In general, the TE Working Group agreed that if Offering 5 advances in any form, Pepco’s proposal for deploying up to 100 EVSE could be supported. • Location/selection – Some members of the group saw merit in allowing more than one EVSE per MDU building, while OPC and AOBA believe EVSE should be allocated to only one per building. General consensus was to review/accept applications on a first come-first served basis although OPC stated that stations should only be installed where they will be utilized by EV drivers. Pepco’s application noted the Company would install chargers at MDUs with registered EV drivers, however the Company sees merit in providing EVSE to buildings in advance of an EV driver residing at the property to encourage EV adoption. ChargePoint also suggested reserving 10% 20% of the EVSE for low-to-moderate income locations. • Building/MDU criteria – these additional suggestions for consideration were provided during the working group: o Building age and readiness – generally newer buildings will be less expensive to install EVSE; absent an installation incentive cap price ceiling, installations should be limited to buildings which would not require costly upgrades to receive equipment. o Dedicated parking space – the building should have a dedicated space for EVs, any time of use restrictions should be determined by the MDU owner. (DOEE) o Number of residents – limiting the deployment goal based on the number of residents in an MDU can be hard to enforce and serve as a restriction for the program. o Number of buildings per MDU property to receive an EVSE – the group discussed limiting the number of chargers per owner in a single location, the experience from Greenlots has shown limiting the incentive to one charger per building could be unnecessarily restrictive and slow uptake, which is counter to the program’s goals. o ADA accessibility – EVSE placement should be in locations that are adjacent to designated ADA parking spaces to ensure access to charging for people with disabilities. (DOEE)  AOBA noted challenges with this suggestion as it could cause ADA spaces to be moved further away from building entrances. Pepco continues to support Offering 5 as the Offering brings electric vehicle charging opportunities to an underserved market – MDU residents. Pepco does not recommend a tariff solution applicable to MDUs at this point in time. None of the options discussed by the working group received consensus support. Instead, the Company recommends that any chargers installed as a part of this Offering continue to be served under their currently existing rate schedules until experience and best practices dictate that other tariff options may be more suitable. Pepco recommends the Commission make a decision on this Offering based on the in the information presented in the proceeding and feedback from the TE Working Group. 8 ChargePoint encouraged reconsideration of this approach at periodic intervals throughout the program based on participation rates and feedback. Second meter utilization and submetering In its initial application, Pepco’s Offering 5 called for the use of a second meter. Order No. 19898 required Pepco to confer with members on the approach in the Company’s Maryland service territory, where comparable programs are currently being implemented through the use of submetering. 8 It is Pepco’s belief that residential submetering is currently prohibited in the District and the TE Working Group requests guidance from the Commission on this topic. If the Commission determines that submetering is prohibited, AOBA urges the Commission to request that the restriction on submetering be eliminated. EVADC does not believe the Commission should proceed with the MDU offering until the permissibility of submetered outlets in MDUs has been addressed. Pepco noted in its MD 9261 EV pilot in 2014, there were challenges with obtaining charging data from the meter and that cellular costs often exceeded the cost of a second AMI meter installation. Additionally, the potential for billing errors can also be expensive. Technology has advanced since the pilot occurred and in the current, large-scale EV programs underway in Maryland (MD 9478), several of the MD utilities will be utilizing submetering to obtain data. Pepco commits to observing the submetering performance for the Maryland program and evaluating submetering options for programs in the District. The following table summarizes the items regarding Offering 5 in which the working group was able to reach consensus and where consensus was not met. Offering 5 – Multi-Dwelling Unit Charging Summary Items of Consensus by the Working Group Items of Non-Consensus by the Working Group • Should the Commission regulations • Use of Smart Level II EVSE or standard permit submetering of parking spaces in outlets(Level II) to support MDU charging MDU buildings, Pepco commits to evaluating this option and other relevant • Necessity (and design) of tariff and/or rate technologies for applicable programs solution associated with MDU charging within the District, eliminating the need for a second meter. Pepco commits to • Ceiling on the number of stations on an exploring additional technology. MDU building 8 • Schedule MDU-PIV as presented in Pepco’s Transportation Electrification Application is not supported by the Working Group. • The methodology in which a price ceiling should be established for installation costs (i.e. a flat dollar amount or creating a ceiling based on the number of stations in an MDU) • Should Offering 5 be approved by the PSC, incorporating Smart Level II chargers, up • Whether MDU residents should be afforded ratepayer protection for EV charging (EVADC proposal) Order No. 19898 at P 37. 9 to 100 EVSE is an appropriate deployment target. • Should Offering 5 be approved by the Commission, there should be a maximum incentive (ceiling) allowed for installation costs per Smart Level II chargers. Offerings 7 and 8 – Make-Ready for Public Charging Although Pepco was not directed by the Commission to discuss Offerings 7 and 8, numerous members expressed an interest in reviewing the public charging make-ready program. Under Offerings 7 and 8, Pepco was authorized to provide make-ready infrastructure to support the deployment of 35 Smart Level II chargers and 20 DC Fast Chargers (“DCFC”) for public use in the District. 9 Several working group members questioned how Pepco defined “make ready” infrastructure. Pepco noted that “make-ready” was defined in Order No. 19898 10 and that Pepco’s October 31, 2019 Implementation Plan proposed changes to its General Terms and Conditions consistent with the Commission’s definition. The Commission approved Pepco’s tariff changes at an open meeting on January 21, 2020. While the topic was discussed in the context of the public charging program, the “make-ready” concept is applicable to additional offerings including those related to Taxi/Rideshare (Offering 10) and Bus Charging (Offering 11). Order 19898’s description of “make-ready” work provided a graphic illustration of infrastructure that extends beyond typical utility work, which ends at the utility meter. 11 Pepco notes, that based on this illustration, the Company interprets make-ready as all work and infrastructure beyond the EV conduit and the meter through the EVSE. Upon completion of the make-ready work and installation of charging stations, Pepco will be responsible for the maintenance of its investments, while the EVSE owner and operator will be responsible for the maintenance of the actual charging equipment. DOEE raised the possibility that make-ready should exclude distribution upgrades, due in part to what it called a lack of transparency in how distribution upgrade costs are quantified and assigned – an issue being clarified through the RM9 Working Group. Pepco is unclear what transparency means in this context, but will follow the terms of its Commission-approved tariff. DOEE states that any rebate or use of ratepayer funds for public charging stations should account for existing incentives available for non-residential public charging, including the Alternative Fuel Infrastructure and Conversion Tax Credit. This tax credit provides a non-refundable credit of 50% of the allowable costs for the purchase and installation of a charging station on non-residential property designed for use by the public, with the tax credit not to exceed $10,000. The tax credit is available until the taxable year ending December 31, 2026. Order No. 19898 at P 49. See Order No. 19898 at P 32. 11 Id. 9 10 10 As required by Order No. 19898, Pepco will review requests for public charging make-ready in coordination with DDOT, which will adhere to the EV Public Infrastructure Expansion Amendment Act of 2018 in addition to the agency’s Curbside Charging Policy, which will be finalized through a rule-making process. Through the working group process, members were informed that the policy will include ensuring equitable access and distribution of EVSE within the District and encouraging turnover to foster efficiency in the use of each charger. Pepco intends to accept and review applications for the public charging make-ready program on a nondiscriminatory basis and in waves, where the applications will be prioritized on criteria established by both Pepco and DDOT. Pepco noted three primary criteria for evaluating each site: (i) load/feeder capacity, (ii) engineering requirements and (iii) total cost. Pepco notes the difficulty in establishing a cost ceiling for applicants, as the cost will depend on site-specific factors, but ideally sites will cost less than $75,000 for make-ready infrastructure. ChargePoint notes and Pepco acknowledges that costs can vary significantly for installing Smart Level II chargers compared to DCFC and each application must be evaluated on a case by case basis. Working group members offered additional criteria for consideration in prioritizing sites including: • • • • • • • • • • • • • • Prioritizing minimizing costs for drivers to access the site/charger (for example, sites with no parking fees) (DOEE)(EVADC) Prioritize sites that offer charging services at the lowest cost per kWh (EVADC) Ensuring long-term commitment from site hosts (DOEE) Proximity to Alternative Fuel Corridors (DOEE) Curbside charging stations should not be sited adjacent to existing or planned bike lanes or bus lanes (DOEE) Prioritize charging locations with sufficient existing distribution hosting distribution hosting capacity and minimal interconnection costs (DOEE) District-owned locations should be considered (DOEE) Public charging stations should be disbursed equitably, including charging stations in Ward 7 and 8 (DOEE) Expected utilization (DOEE) Willingness of third-parties to contribute to upgrade costs (DOEE) Ability to offer lessons learned (DOEE) Direct allocation of costs (AOBA) Ensure a broader pool of applicants and locations by not restricting public charging applications to only those locations under the jurisdiction of DDOT (e.g. a right-of-way, on the curbside, etc.) (ChargePoint) Recognizing caution in setting site cost caps and incorporate that installation costs between Level 2 and DCFC are significantly different and should be reflected in any budget target. (ChargePoint) Offering 10 – Taxi/Rideshare Charging Under the Clean Energy DC Omnibus Amendment Act of 2018, Transportation Network Companies (TNCs) are required to prepare electrification plans. Order No. 19898 approved Pepco to provide make-ready 11 work to support the deployment of 10 Level II chargers and 2 DCFCs dedicated to Taxi and Rideshare vehicles. 12 Order No. 19983 requires reviewing the site selection process with relevant members. 13 While the locations for chargers has not been determined, Department of For-Hire Vehicles (DFHV), Uber and Greenlots indicated a strong preference for modifying the program to increase or focus exclusively on DCFC, stating that Level II chargers typically do not make sense for the taxi or rideshare fleet. DFHV also expressed an interest in timing the site selection process for this offer with DOEE’s Electrification Roadmap to be finalized at the end of 2020. Determining the ideal dedicated sites for locating the 12 EVSE will involve continued collaboration with relevant members, including DFHV and TNCs operating in the District including, but not limited to, Uber Technologies, Inc. and Lyft, Inc. Uber notes the importance for equitable access for drivers to the EVSE when selecting the locations. Pepco recommended that any service, including chargers under installed under this Offering, continue to be served under an existing commercial tariff until experience and best practices dictate that other tariff options may be more suitable. No objections were presented by the TE Working Group for this recommendation. Pepco will update all members on the progress of this Offering, including any requested modifications, in the Company’s quarterly program reports. 12 13 Order No. 19898 at P 51. Order No. 19983 at P 22. 12 Appendix 1 ~ pepco. An Exelon Company Dennis P. Jamouneau Assistant General Counsel EP9628 701 Ninth Street NW Washington DC 20068-0001 Office 202 872 3034 Fax 202 331 6767 pepco com diamouneau@pepcohold1ngs com November 7, 2019 Ms. Brinda Westbrook-Sedgwick Commission Secretary Public Service Commission of the District of Columbia 1325 G Street, N.W. Suite 800 Washington, DC 20005 Re: Formal Case Nos. 1130 & 1155 Dear Ms. Westbrook-Sedgwick: Potomac Electric Power Company, along with its stakeholders, met on September 16, 2019 and October 22, 2019. Enclosed are the Minutes for the September 16, 2019 and October 22, 2019, Transportation Electrification Working Group Meeting, attendance sheet and power point presentation of issues discussed at the meeting. Please feel free to contact me if you have any questions regarding this matter. Sincerely, ~ Dennis P. Jamouneau Enclosures cc: All Parties of Record FC 1130 and 1155 Transportation Electrification Program Working Group Minutes for September 16, 2019 Meeting Meeting Commencement The TE Program Working Group meeting convened at 1:15 p.m. on September 16, 2019, at Pepco’s Edison Place office in Washington, DC. Attendees (See Attachment No. 1) Representatives were in attendance from the following organizations: Exelon/Pepco Holdings, Chargepoint, DC Public Service Commission Staff, DOEE, MJ Bradley and Associates, Greenlots, DC Board of Trade, DC Department of Transportation, EVADC, Sierra Club, DC Office of People’s Counsel, Tesla, DC DFHV Issues Discussed (See Attachment No. 2) • Introductions • FC 1155 order program approval review • Working group purpose and charter review – •  The final deliverable of this group is a report to the Commission by January 29. Where possible the group will make an effort to come to consensus on the issues discussed, where a consensus is not met, the report will present the varying viewpoints.  New members will be accepted throughout the duration of the temporary working group, however there will be a caveat that their comments were not shared during the monthly working group meetings; DOEE will seek participation from other district agencies they believe are necessary for the group.  Pepco is creating a shared drive to store documents that can be accessed by group members. Working group calendar review – Pepco will inform the group ASAP of the new dates in October and November  request to move November date due to NARUC conference;  request to move public neighborhood charging to October  The January date will be reserved for reviewing the draft report • Working group calendar review – Pepco will inform the group ASAP of the new date in November • EVSE Rebates discussion  The group separated into smaller teams to discuss issues and concerns regarding EVSE rebates in Pepco’s offer 4. See Attachment 3 for comments FC 1130 and 1155 Transportation Electrification Working Group Minutes for September 16, 2019 Meeting Offering 4 will be revisted in the group's December meeting Adjournment Meeting adjourned at 3:40 p.m. Agenda for Next Meeting By request, public charging will be on the October agenda. Pepco will coordinate with DDOT. Future Meeting Dates and Times October 22, 2019 1:00 p.m. Disclaimer – The information contained herein does not represent quoted statements by any person or group. Rather, the information presented is based on what is captured during the note taking process during the meetings. Page 2 of 2 FC 1130 and 1155 Transportation Electrification Program Working Group Meeting September 16, 2019 Offering 4: Residential Customer Rebates for Smart Level II EVSE TE Working Group members broke into four small groups to discuss Pepco’s Offering 4 using Pepco’s prepared questions as a framework for conversation. The discussion was extensive, and the minutes below provide a high-level summary of some of the comments that were made, but do not necessarily reflect the nuances of the individual comments and concerns raised the various parties that were present at the meeting. In addition, Offering 4 will be re-visited at the TE Working Group’s scheduled December meeting. 1. Do EVSE rebates directly or indirectly support the District’s goals for reduction in carbon emissions by 50% by 2032? G1. Ability to increase EV adoption, Shaping the charging for the time during the day, reducing GHG G2. Smart Level 2 EVSE provide the functionality to enable programs and pricing that can reduce carbon emissions. Connected Level 2 chargers are similar to AMI technology, which can be a tool to facilitate behavior change or technology adoption provided the programs and pricing are available and utilized, and appropriate functionality of the meters has been enabled. Rebate conversation needs to consider ecosystem of EV incentives, including the Alternative Fuel Vehicle Conversion and Infrastructure Tax Credit. G3. EV adoption can help reduce emissions. Current incentives available, access to data, how this will support Districts goals and timing of charging and other offerings. Goals for transport are twofold. Districts goals are reducing miles and electrifying cars. Potential to shape load. Overall, more data is required G4. Question as to whether rebates incentivize EV purchase. DOEE Input: The District’s climate goals are governed by the Clean Energy DC Plan and MoveDC, and the principles of Deep Decarbonization. The District Government has goals for GHG reduction in the transportation sector through mode-shifting away from private-use vehicles to other forms of transportation, maximizing reductions in vehicle miles traveled (VMT), as well as electrification of the remaining private vehicle fleets and decarbonization of the electricity supply. Incentivizing private EV purchases is not in and of itself furtherance of District Climate policy. DOEE is currently working on a Strategic Electrification Roadmap, in coordination with Pepco, to model the best phased approach for the installation of electric charging infrastructure from the grid perspective. Smart Level 2 chargers, if paired with appropriate programs or price signals (ex: demand response, time of use pricing, or real-time pricing) may enable GHG emissions reductions above and beyond Level 2 chargers that lack smart capabilities (non-connected). The deployment of Smart Level 2 chargers in single-family residential households without pricing, programs, or a plan to integrate the data into Pepco distribution planning, is unlikely to create GHG emissions reductions that would not exist with less expensive, non-connected Level 2 chargers. OPC noted that the question is phrased in a compound manner as it asks whether the rebates not electric vehicles support the District’s goals. To answer the question, it would first be necessary to determine if EVs support the District’s goals for reduction in carbon emissions. This requires a review of FC 1130 and 1155 the makeup of the greenhouse gas emissions emitted by the generation mix that serves the District versus the emissions from the number of cars that are displaced by EV cars. It then requires a study of what EVSE is needed to support those cars in the District, and whether residential rebates for EVSE would incentivize the purchase and use of an EV compared to the status quo scenario, and further if so, what level of rebate would be required to create such an incentive. OPC further noted that it is difficult to answer either this (or many of the other questions) as parties lack the baseline data needed to develop an adequate response. 2. Does EVSE equipment at individual residences provide benefits to the greater public? G1. Yes. Encourages charging during times of lower emissions and can provide health benefits to the public. Additional benefits exist from economic standpoint for utility operations. G2. Yes, potential for distribution system planning (DSP) and demand side management (DSM), but without seeing plans that will enable these benefits and how customers will adopt these programs, will not get us there to providing the benefits. We need more information, safety benefits etc. for justification. What are the main barriers to Smart Level II EVSE adoption? Cost issue? Or physical barriers? What is the specific goal of Offering 4 specific goal? G3. Yes. We don’t have enough information, how will it be managed, how will it interact with other technology etc., hard to answer without more baseline data including barriers to owning/installing an EVSE at a residence (ex: how many people drive, how many people own, how many people have space to install equipment, landlord issues) G4. Potential for Load Management through control data and demand response. DOEE Input: It is unclear from the offering what the benefits are intended to be and how those benefits would be distributed between rate classes, wards, and income levels. The deployment of Smart Level 2 chargers in single-family residential households without pricing, programs, or a plan to integrate the data into Pepco distribution planning, is unlikely to create system benefits that would not exist with less expensive, non-connected Level 2 chargers. OPC agreed with DOEE’s input and further submits that the utility yet to do an analysis of the need for chargers at individual residences in the District. Specifically, the utility has not evaluated how many people drive in the District, how many of that subset own or have control over their residence and also have the space to install a charger. Moreover, EVSE equipment has the potential to cause negative impacts to the greater public if not planned well. For example, if multiple individual chargers are placed on the same line that is already lacking in capacity, the additional capacity requirements could stress the line and created a need for further capital investment to alleviate the congestion. Rather than creating a benefit, these chargers will have imposed costs on the greater public. 3. What is the appropriate $ amount to offer District residents for EVSE rebates? G1. $500 proposed is within an appropriate range. It may not necessarily be enough. We must also consider the tax incentives currently offered. G2. Lack of cost benefit analysis, critical before discussing incentive levels. Certain customers cannot benefit from non-refundable this tax credits. Need to encourage deeper participation; overall felt the MD PSC’s argument that rebate should cover the incremental cost between connected and nonconnected EVSE ($300 rebate approved) to be compelling. Overall opportunities for deeper FC 1130 and 1155 participation and consider justification for different tiers of rebates. Additionally equity considerations exist, how can customers be incentivized who have lower spending ability? Should low income customers receive higher rebates to address first-cost barrier? G3. Offer must consider who benefits accrue to as well as equity considerations G4. Need to involve other technologies as well. Data on avoided costs would be helpful. In terms of transformer upgrades and other types of investments. Consider customers less likely to participate in this program. Show them that EVs are realistic to their households as well. DOEE Input: If Offering 4 is allowed to go forward, DOEE believes that the appropriate rebate value should reflect both the cost delta between non-connected Level 2 chargers and Smart Level 2 Chargers, as well as the existing Alternative Fuel Vehicle Conversion and Refueling Tax Credit. Some consideration may be made for low income customers that may not be able to take advantage of the non-refundable tax credit. OPC comment: Pepco must first demonstrate the need and benefit of offering an EVSE rebate before starting a discussion on the appropriate amount of the rebate. 4. What is the appropriate number of EVSE rebates to offer District residents? G1. 500 proposed is reasonable, the offer should be limited based on number of single family homes in the District. G2. More data was required at this time before suggesting an appropriate number G3. Not enough data at this time. G4. Suggestion to try concentrating on locales and numbers to collect data to avoid costs (ex: distribution system upgrades). DOEE is currently collaborating with Pepco for electrification and planning projects. DOEE Input: DOEE would require more information and data collection in order to make a determination on the appropriate number of recipients. OPC comment: Similar to the response above, Pepco must first demonstrate the need and benefit of offering an EVSE rebate before starting a discussion on the appropriate number of EVSE rebates to offer. Moreover, Pepco has not provided the stakeholders any analysis of the scope of the need in the District. 5. How can we ensure the costs for rebates are recovered equitably across District ratepayers? G1. It is worthwhile to consider allocating costs across all customers/rate classes G2. The group did not discuss, however there was discussion of cost of data from the utility or 3rd party G3. Very limited recovery from EV owners. Which classes does this impact and benefit. There are possibly better sources of funding than ratepayers. G4. Helpful to have better data for potential for recovering costs. DOEE Input: More data is required about who the beneficiaries of such a program would be. FC 1130 and 1155 OPC comment: OPC agrees with DOEE, and also Pepco has not yet demonstrated that costs of rebates should be recovered from ratepayers. 6. Should EVSE rebate incentives be targeted towards specific populations? If yes, how could rebates be adjusted? G1. Goal to be equitable for participants, suggesting different marketing dynamics; Education outreach, looking at to other partnerships to ensure affordable EVs, differentiating rebates. Consider income- based differentiation. G2. Same as G1. In addition to incentive levels, the education and outreach strategies are critical G3. Specific barriers facing different populations that are unique to the District. Do more evaluation of the populations before determining if there should be differentiation or a rebate at all. G4. Suggestion for geographic targeted. Ex: Where there are high concentration of EVs which may assist with load management DOEE Input: More information is required about what types of customers would be eligible and most likely to apply for this specific rebate. 7. How can rebates be targeted to benefit the operation of the distribution system? G1. Qualification levels to meet the needs of the utility; consider metering energy, smart communication, equip specs and tailor rebates based on distribution specifics. G2. Consider higher rebate levels for customers participating in demand response programs. Targeting customers that are participating in DSM. G3. It is not the rebates themselves that help, it’s the participation. DOEE roadmap with Pepco currently under evaluation looking at benefits to distribution systems. G4. See Q6. DOEE Input: DOEE is currently working on a Strategic Electrification Roadmap, in coordination with Pepco, to model the best phased approach for the installation of EV infrastructure and building electrification from the perspective of the distribution grid. EV charging structure, without any type of market signal to go along with it to incentivize charging behavior, is unlikely to benefit the operation of the distribution system. 8. Other Observations? ● ● ● ● A request was made by a working group member to discuss selection criteria to discuss public charging make ready (Offerings 7 and 8) earlier than the scheduled date to allow the program to move forward. Consider capabilities of onboard systems. Some items may be duplicative, can we get new insights? Where is vehicle charging, not just residence. Thoughts about wi-fi vs. cellular ability DOEE has concerns that the deployment of smart (connected) level II chargers will not create benefits without a plan from Pepco to utilize the metering, telemetry, and control FC 1130 and 1155 ● ● ● ● ● ● technologies. This could come in the form of price signals (e.g., TOU), programs (DR, behavioral), or third-party aggregation. DOEE drew an analogy between Smart Level 2 Chargers and Advanced Metering Infrastructure (AMI), by pointing out that AMI is an enabling device but does not produce energy savings or customer benefits on its own. Plans, what will data be used for. Tesla gave feedback regarding customer behavior. Consider FC 1143 elements. More about security of data, will District Government have access to it? Will it be following law and regulations? Technology is the right course to support, consider V2G technology. Pepco MD and Pepco DC are not analogous The framing of the today’s discussion jumped right into the “how” Pepco should implement Offering 4 without first addressing the threshold questions of “if” and “why” Pepco should implement Offering 4. The threshold questions must be answered prior to making recommendations on program design and implementation strategy. I pepco. An Exelon Company Transportation Electri■cation Program Working Group_ September 16, 2019 Attendees Name Af■liation 12' / from pan (0 3' 4567- z/m 3910. 11. 1213141516. , Bewa 1718. 19. 2021. 22. 232425. 26. 27. BUN D DC PSC J Transportation Electrification I pepcog Program Working Group September 16, 2019 Agenda 1 Introductions 2 TE Program Order Review 3 TE Working Group Purpose and Charter Review 4 TE Working Group Schedule and Topics 5 Review and Discussion of TE Program Rebate Offer 6 Roundtable 2 Introductions I pepcog 3 An Exelon Company Pepco DC EV Application – Order Summary Offering Program Components No. 1 Residential Whole House TOU 2 Residential Customers with existing EVSE and receiving FleetCarma units Size (Units) Size (Units) Unlimited 150 Unlimited - 3 Smart Level II EVSE for Residential customers (materials, installations and inspections) 50 - 4 Residential Customers Smart Level II EVSE rebates of $500 Maximum for 500 participants 500 (working group) 5 Smart Level II EVSE for Condominiums/Apartments (50% EVSE discount and 100% installation cost covered, not to exceed 100% of the total installation costs less any applicable rebates.) 100 (working group) 6 Smart Level II EVSE for Commercial customers (Workplace Charging) (50% EVSE discount and 100% installation cost covered, not to exceed 100% of the total installation costs less any applicable rebates.) 50 - 7 8 9 Public Neighborhood Smart Level II EVSE Public Neighborhood DC Fast Chargers Electric Fleet Light Duty Infrastructure 35 20 22 10 Electric Taxi / Rideshare Infrastructure 12 11 Electric Bus Infrastructure 5 bus depot chargers and 1 on-route charger to support use of electric buses 6 6 (make ready) 12 Innovation Fund (Car share, V2G Access Vans, etc.) TBD - 13 Technology Demonstration (Integration of microgrid technologies into community cluster of DCFCs) TBD - 4 35 (make ready) 20 (make ready) 10 L2 and 2 DCFC (make ready) TE Working Group Purpose and Charter Review I pepcoe An Exelon Com nan Working Group Schedule TE Working Group Schedule and Topics Tuesday, October 22 1-3:30 Multi-dwelling units Monday, November 18 1:00 – 3:30 Neighborhood charging Monday, December 9 1:00 – 3:30 Taxi/Rideshare Tuesday, January 14 1:00 to 3:30 (as needed) Review of outstanding items and working group document 6 EV Program - Considerations  MEDSIS (FC 1130) Vision: • Sustainable, reliable, secure, affordable, interactive and non-discriminatory  Drivers of plug-in electric vehicle drivers do more than 80% of their charging at home  Barriers to EV adoption  • Vehicle range • Perceived ability to charge • Vehicle purchase price/cost Utility incentives on residential smart L2 chargers to incentive market 7 Utility Rebates for Residential Chargers Sample Utility Azuzu Light & Water State California Rebate Amount $150 Georgia Power Georgia $250 Pepco Maryland $300 Alliant Energy Iowa, Wisconsin up to $500 PSEG New York $500 Puget Sound Washington $500 Island Energy California $750 (incl. installation and permitting)  Previous and current rebates for wifi and non-wifi capable equipment 8 EVSE Rebates Framework 1. Do EVSE rebates directly or indirectly support the District’s goals for reduction in carbon emissions by 50% by 2032? 2. Does EVSE equipment at individual residences provide benefits to the greater public? 3. What is the appropriate $ amount to offer District residents for EVSE rebates? 4. What is the appropriate number of EVSE rebates to offer District residents? 9 EVSE Rebates Framework 5. How can we ensure the costs for rebates are recovered equitably across District ratepayers? 6. Should EVSE rebate incentives be targeted towards specific populations? If yes, how could rebates be adjusted? 7. How can rebates be targeted to benefit the operation of the distribution system? 10 Roundtable i! pepcoy I Appendix 2 FCs 1130 and 1155 Transportation Electrification Program Working Group October 22, 2019 Meeting convened: 1:20pm Attendees: ABB, Apartment Office and Building Association (AOBA), ChargePoint, DC Attorney General’s Office, DC Department of Transportation (DDOT), DC Department for Hire, DC Office of People’s Counsel (OPC), DC PSC Staff, DC Department of Energy & Environment (DOEE), Electric Vehicle Association of Greater Washington DC (EVADC), EVgo, Exelon/Pepco Holdings LLC (PHI), Load Analytics, LVL2 Charging, MJ Bradley, Natural Resource Defense Council, Sierra Club Meeting Topic - Public Charging Program presented by Anthony Cassillo (DDOT), Jen Grisham (PHI), Jason Tucker (PHI) - Slide 6 - State of EV in the District  DDOT confirmed the 3 chargers (5 ports) presented are District owned and DDOT operated.  DC Gov noted fast chargers are available in CityCenterDC, Union Station (taxi-dedicated) and on Benning Road; EVgo noted that there is also DCFC in the parking garage of DC’s Hines Center (under expansion) and in an Electrify America station under final construction in the parking garage of the Walmart on Georgia Ave NW; participants were directed to PlugShare or to the AFDC map (https://afdc.energy.gov/stations/).  Questions for further investigation and review: • Looking at the EV Commuting Map, is there more data available or is this the most updated map? • Question: Is more recent data available regarding the number of EVs registered in the District? - Slide 7 - Rates and Enforcement  DDOT noted the customer must pay the charging rate along with the parking rate  Enforcement of parking or charging is difficult, especially enforcement of non-charging parking. - Slide 9 – Lessons Learned and Challenges  DDOT currently does not have a manager to monitor the performance of the chargers or if the chargers need repair.  District owns and does not have a good resource for repairing charging stations in-house. The repairs are outsourced to a 3rd party vendor if it cannot be done by in-house electricians.  Identified problems with some charging stations reliability or simply not working when the customer pulls up to charging station. Also, charging spaces may be occupied even if no charging is occurring.  Identified a need for proper signage and education to support the collection of meter revenue.  Owners may not know that they must also pay the meter along with the use of the charging station.  DDOT will not own EV charging stations moving forward, but rather accept application for permit by 3rd party charging vendor to install charging stations in public space and shift focus toward increasing the efficiency of existing stations. - - Slide 11 - EV Public Infrastructure Expansion Act/ Clean Energy DC Omnibus  A goal of the Clean Vehicle Transition Plan is to increase the number of registered vehicles 25% percent by 2030. Noted bulk of 412 registered EVs as of July 2018 is concentrated in Capitol Hill, CityCenter, Upper NW.  DDOT’s plan is to have at a minimum 15 L2 stations with at least 1 station in each ward per the requirements of the Electric Vehicle Public Infrastructure Expansion Amendment Act of 2018 Slide 12 - Curbside Charging Policy  DDOT is looking to increase chargers and infrastructure across the District to increase visibility and availability of EV chargers in public space to encourage people to switch to an EV.  Install an EV charger in each Ward and ensure equitable access.  Encourage turnover to foster efficiency in the use of each charger - Slide 13 - Curbside Charging Policy  DDOT is not going to permit application for EV chargers at Red-top meter spaces because those spaces are carefully placed and reserved for those with disabilities.  DDOT on RPP spaces – DDOT is not going to permit application for EV chargers at curbside space enrolled in the Residential Permit Parking (RPP) program because residents’ ownership of the residential curbside is different than their ownership of the curbside space that’s unregulated or regulated by meters. EVADC strongly opposes this decision by DDOT, and notes that DDOT made it unilaterally without consultation or discussion with Council. EVADC notes that streets with RPP generally have the least amount of off-street parking available, making curbside EVCS that much more essential. EVADC believes ANCs should have a role in determining how they want to incorporate EVCS on to RPP streets. - Slides 15 - 20 - Curbside Charging Policy: Next Steps  DDOT Finalizing Policy:  Plan to publish the proposed rulemaking before end of year (2019).  Comments will be accepted from the community and stakeholders.  DDOT is considering operational metrics but has not finalized at this time.  DDOT is considering the topic of bike lanes and siting EV chargers • Existing bike lanes will be protected, protections for future bike lanes may be added at a later time. • DDOT is observing City of Seattle on this topic  Standardized pricing is being considered  DDOT will review why existing chargers were removed from the ChargePoint map; ChargePoint declined to answer at the time of the meeting.  Question: Will the permit process go through the Public Space Committee? A: DDOT will field & review permits and committed to work with PEPCO on the permit application process. Plan to have the Public Space Director attend meeting with PEPCO to discuss how both agencies will field applications. - Slide 22 - Pepco Public Charging Summary  Pepco will provide the make-ready infrastructure for public chargers and will coordinate site selection with DDOT.  PSC Staff noted the Commission intends to schedule a hearing on the EVCS market in the District - Slide 23 - Make Ready Defined  Pepco interprets “make-ready” as construction work past EV conduit and the meter until the EV charger. The cost of “make-ready” work will be site-specific. Make ready infrastructure must have a concise definition. During discussion, District Government raised the possibility that the make-ready definition should exclude T&D upgrades.  The working group notes the role of the 3rd party and site must be determined.  ADA requirements must be complied with by the EVSE supplier  ChargePoint recommended limiting against the Right-of-Way  EVgo noted that DCFCs which are behind the meter at a large customer facility (such as Hines Center) as opposed to having their own service, may not qualify for “make ready” as usually defined.  The general criteria for Make-ready installations are Location, Load, need for potential upgrades based on load, avoidance of runaway costs.  Question: Does Make-ready include Switch-gear? A: Could include switch-gear in the program. Will discuss with DDOT due to cost becoming an issue.  Question: Who is responsible for the actual charging equipment? A: EVSC suppliers are responsible for the charging equipment. - Slide 24 - Application Process for Public Make-Ready and Siting  Application process will be similar to the General Service application found on Pepco’s website and modified specifically for this program.  EVgo noted that the general service application process is very slow and targeted towards new commercial construction at one facility. It could potentially be updated to provide faster (high level) response on multiple possible sites.  Application process will require site visits  Factors for timing of construction = Agreement on application and specifications for construction; Site conditions, Crew availability, and readiness of equipment. - Slide 26 - Potential Criteria for Approving Applications.  Other criteria for consideration: • Construction factors • DDOT has own requirements • Cost and Engineering requirements • Consider total driver cost to access site and charge; e.g. garage entrance fee + charging fee. • Use SOS as a cost anchor; the higher above SOS charging costs, the less the EVCS will be used. Ensure long-term commitment from site hosts who benefit from make-ready infrastructure. Some participants proposed that the cost of Standard Offer Service should be the anchor for charging service price. EVgo noted that this would not permit EVSPs to recover the cost of equipment, installation, payment processing, rent of the space, etc. • Priority for DCFC within 5 miles of an FHA-designed Alternative Fuel Corridors (currently I-95 and I295) • Public EVSE location is not within a road segmented identified as part of the Recommended Bicycle Network in the Multimodal Long-Range Transportation Plan (moveDC) or its successor. • Preference for projects that require typical interconnection facilities as compared to distribution system upgrades, raised idea of using a capacity map similar to solar PV. • An effort should be made to avoid sites requiring upgrades (including limiting definition of makeready infrastructure). • Consider city-owned/DCPS locations • Utilize available capacity data • Disbursement of chargers • • • • • - Operational metrics (reliability) Expected utilization metrics Uptime targets Willingness of 3rd parties to contribute for upgrade costs, if required Capturing of lessons learned  Question: Is there a “reasonable” cap for Make-ready? Could it exceed 150% for Make-ready infrastructure? A. PEPCO will review establishing boundaries around cost, and the working group will make recommendations in the final report. Factors for consideration include: • Evaluating data from other programs (ex. California) although data may be limited as programs are in early stages. • Other industry references can be used for a benchmark. • Review other references that have zero cap on infrastructure limitations. Most states are in the beginning stage, so this data may be unavailable. • Review any historical data on EV metrics • Consider AFDC data center criteria  Question: what is the definition of Public Charging? A. The working group will work on recommendations in the final report. Consider definition of public access as defined by the Alternative Fuel Data Center. Slide 27 Meter and Data Collection.  For current non-residential approved offerings in the District, 2nd meters are not required.  Will tie in with the existing meter, unless there is a need for metrology or TOU is introduced.  Alternative options can be reviewed for residential/commercial programs  November meeting will review the MDU offering in depth.  Pepco is willing to evaluate the cost/benefit results of utilizing other options. Next Meeting – November 13, 2019 @ 1 pm Topic – Multi-Dwelling Units FC 1130 and 1155 Attachment 1 Pepco DC Transportation Electri?cation Program Working Group October 22, 2019 Name Af?liation 1' (/Pma 86?? 01 PEG 2- AM (/1171 Aid 3- Aw ob 4/ '7 4- Ting/v16} ?gal/WM - 5. (?10;4a yd VS 6. Mr?m {Ammo Pr OAC 7- How? tar/V? 1:70 If]: 8- ,A?n rim #9 9. paln?m (glam/LU ?7 COOL) 10- WV 131 0015?: 11- Eggnu CAREU ABBA 12- MM Leave?l A2743 13. "Eb/91? 53??an 2.3/7.1 ?ant/tr 14. MmaA; no em 15- BOqem Futthara ch 16- 104211 9W Sim Cid/'0 17. ChmM-eS Bend?; lit/ADC 13- A 19. Clm?: ?1754([01' e?ao 20- Fm; (PO cam 21. Van HOW) M15914 22. 4%?va NIB i 74/ 23- (4- 159.1)? 24- (1m (903m (?>6ch 25' 19911411 QM 26- 53397 27- (if mnt?V/ 28. 5% Cum ?7057: 29. JANA. L44 papa) PQUU NOEL (1 FC 1130 and 1155 Attachment 1 Pepco DC Transportation Electri?cation Program Working Group October 22 2019 30. 31. H1) (3 mow. .0 (1103/! 32. WSW WK 91/ p?nf? 33. Phat/L MW 34. ?91/1 om. 35. Ohm/U. 36. Et/Go 37. Wt Mi too/UL Laid. 38. 39. 40. 41. 42. 43. 44. 45. 46. 47. 48. 49. 50. 51. 52. 53. 54. 55. 56. 57. 58. 59. 60. FC 1130 and 1155 Attachment 2 Transportation Electrification Program Working Group Public Charging Program October 22, 2019 1 FC 1130 and 1155 Attachment 2 Agenda  DDOT Public Charging Perspectives  Pepco Public Charging Make-Ready Program  Metering and Data Collection 2 FC 1130 and 1155 Attachment 2 Transportation Electrification: Electric Vehicle Charging Stations FC 1130 and 1155 Attachment 2 Repurposing Public Space How does DDOT repurpose this public right-of-way to accommodate EV charging infrastructure? 4 FC 1130 and 1155 Attachment 2 State of Electric Vehicles in the District FC 1130 and 1155 Attachment 2 State of Electric Vehicles in the District • 412 EVs registered to the District (July 2018) • 5 level 2 EV charging spaces • 14th St NW: 1 charger, 1 space • 2nd Pl SE: 2 chargers, 4 spaces 6 FC 1130 and 1155 Attachment 2 Rates and Enforcement • Charging Rates • $1/hour: 7AM - 8PM (prime time) • $.50/hour: 8PM - 7AM (overnight) • Parking Meter Rate • $2.30/hour: 7AM – 10PM • Maximum stay is 4 hours. • Violations • Parking an EV for more than 4 hours: $100 • No parking except for EVs while charging: $100 7 FC 1130 and 1155 Attachment 2 Lessons Learned FC 1130 and 1155 Attachment 2 Learned Lessons and Challenges • Maintenance and Age of Chargers • Parking-only sessions • Compliance with Parking Restrictions • Collection of Meter Revenue 9 FC 1130 and 1155 Attachment 2 Electric Vehicle Public Infrastructure Expansion Act Clean Energy DC Omnibus Amendment Act 10 FC 1130 and 1155 Attachment 2 Curbside Charging Policy Clean Energy DC Omnibus Amendment Act • Establish clean vehicle transition plan to promote the adoption of zero-emission vehicles Electric Vehicle Public Infrastructure Expansion Act of 2017 • Install EV charging stations across the District • DDOT shall publish on its website the locations of EV charging stations • Data Collection • Progress Report 11 FC 1130 and 1155 Attachment 2 Curbside Charging Policy • Goals • Expanding EV Infrastructure • Equity • Efficiency 12 FC 1130 and 1155 Attachment 2 Curbside Charging Policy • Citing Standards • Compliant with existing ADA guidelines and parking restrictions • 10+ feet from a fire hydrant • 25+ feet from intersection • Complaint with DC Design and Engineering manual • Curbside Space • Not permitted at blocks with rush-hour restrictions or emergency routes • Not be located at Red-top meters spaces • Not permitted at RPP spaces 13 FC 1130 and 1155 Attachment 2 Curbside Charging Policy: Next Steps FC 1130 and 1155 Attachment 2 Curbside Charging Policy: Next Steps • DDOT to finalize policy • Publish a notice of proposed rulemaking • Accept comments 15 FC 1130 and 1155 Attachment 2 Curbside Charging Policy: Next Steps DC Register: https://dcregs.dc.gov/Common/DCR/SearchIssues.aspx?AgencyID=1 16 FC 1130 and 1155 Attachment 2 Curbside Charging Policy: Next Steps District of Columbia Municipal Regulations and District of Columbia Register Office of the SecretaryI of the District of Columbia Office of Documents and Administrative Issuances DCR Issue: Vol.66 - No.42 Back To Main Menu DISTRICT CIF COLUMBIA REGISTER Vol.66 - No.42 October 11, 2019 ViewI the Issue 5 ?g COVER AND TABLE OF CONTENTS \l'iewiuiI File ACTIONS OF THE COUNCIL OF THE DISTRICT OF COLUMBIA D.C. 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Magi GOVERNMENT OF THE EDISTRICT OF COLUMBIA 17 DCMURIEL BOWSER, MAYOR FC 1130 and 1155 Attachment 2 Curbside Charging Policy: Next Steps ABOUT US CONTACT US HELP LOG IN DER Issue: Vol.66 - No.42 - ?ctober 11, 2019 Back To Main Menu Issue Date: October 11r 2019 Register Category: Proposed Rulemaking Showing 1 to 2 of 2 entries Show 50 7 entries Search: I Sedjon Notice ID Number Notice Register Issue Iii-31.01 Consumer and Regulatory Affairs, Department of - Notice of Proposed View Text min/2019 10/11f2019 Rulemaking - Civil Infractions Administrative Procedures Vol 66.342 NGDEEYZI 124.106 Documents and Administlative Issuances, Of?ce of - Errata Notice - View Text 101?11/2019 10/11f2019 Correction of Second Proposed Rulemaking published July Vol 66.342 26, 2019 - Part 2 Previous Next Of?ce of Documents and Administrative Issuances ABOUT US RESOURCES 4'41 4th Street, NW, Suite 5205 History of the Office of Documents DC Code Washington, DC 20001 What We Do Of?ce of the Attorney GenEIal PthEl (202) 723?5090 Hours of Operation Council of the District of Columbia Emzaglg Contact Information Federal Rules and Regulations Accessibility Privacy and Security Terms and Condilions About ilr?tq?? GOVERNMENT OF THE EDISTRICT OF COLUMBIA 18 DCMURIEL BOWSER, MAYOR FC 1130 and 1155 Attachment 2 Curbside Charging Policy: Next Steps Anthony Cassillo Policy Analyst Anthony.Cassillo@dc.gov 19 FC 1130 and 1155 Attachment 2 Curbside Charging Policy: Next Steps Contact re: Electric Vehicle Policy Anthony Cassillo- Policy Analyst (Anthony.Cassillo@dc.gov) 20 FC 1130 and 1155 Attachment 2 delivers district department of transportation FC 1130 and 1155 Attachment 2 Pepco Public Charging Summary (Offers 7 & 8) Category Ownership Quantity Ward Allocation Interoperability Other  PSC Decision  (Orders 19898 and 19983) Pepco will provide make‐ready EVSE infrastructure for  3rd party EVSE ownership and operation make‐ready for 35 Level II and 20 DCFC Pepco will not dedicate a percentage of EVSE  infrastructure to certain wards; a future Commission  hearing will review the EVCS market in District Pepco must provide make‐ready infrastructure to 3rd  parties on a nondiscriminatory basis Coordinate with DDOT on site selection and  construction (Pepco will comply with DDOT criteria) Focus is to implement PSC Decision and approved program elements as effectively, efficiently and equitably as possible, while ensuring sufficient learnings are captured and shared to inform potential future efforts 22 FC 1130 and 1155 Attachment 2 Make-Ready Defined ?Make-ready? Infrastructure Utility Utility meter, Charger Plug-in Electric Infrastructure panel and conduit Vehicle igm?e 1: Formal Case No. 1130, Vgo Reply Comments at 3. his graphic illustrates the concept of make-ready Source: I pepcm 23 An Exelon Company FC 1130 and 1155 Attachment 2 Application Process for Public Make-Ready and Siting  Pepco EVSmart program estimated launch Q1 2020  Website update with application for make-ready   Application will be a modified version of current new business application, specific for make ready infrastructure To promote fairness, applications will be accepted and reviewed in “waves”  Example – a 2 week window to submit applications for the program for the first round of review  Applications will be reviewed and approved on a transparent set of preestablished criteria determined by Pepco and DDOT, as informed by this TE Working Group.  Timing on construction for approved applications will depend on multiple factors and will be determined after engineering review 24 FC 1130 and 1155 Attachment 2 Pepco Proposed Requirements for Public Make-Ready   The interested party will complete an application per site (to be available on Pepco’s EVSmart webpage)  Site information  Service requirement (Load)  Charging equipment (number and level: 2 or DCFC)  Location of the charging equipment The applicant is responsible for the charging equipment (DCFC or L2 EVSE) and for completing all permits and inspections required to interconnect to Pepco facilities. 25 FC 1130 and 1155 Attachment 2 Potential Criteria and Considerations for Approving Applications  Criteria Examples  Cost  Engineering requirements   load  feeder capacity Other? 26 FC 1130 and 1155 Attachment 2 Metering and Data Collection (order 19898)  In its Application, Pepco states that second utility meters are needed for some residential situations (Offering 3 – 50% rebate on res charger and installation), MDU applications (Offering 5), and commercial situations (Offering 6 - workplace), while it is silent as to the need for metering where Pepco would own the charging stations (Offerings 7, 8, 9, 10, 11). ChargePoint, along with Tesla, indicate that Smart Level II chargers can contain embedded meters, which negates the need for a second utility meter. Additionally, in Maryland, Pepco and other utilities have sought permission for submetering of EVs utilizing the charging station’s internal meters. Pepco is directed to confer with stakeholders and report to the Commission on the feasibility of the Maryland Approach in the District.  Pepco has determined second meters are not required for its approved offerings at this time. 27 FC 1130 and 1155 Attachment 2 Roundtable pepco CERTIFICATE OF SERVICE I hereby certify that a copy of Potomac Electric Power Company's TE Working Group Meeting Minutes was served this November 7, 2019 on all parties in Formal Case No. 1130 and 1155 by electronic mail. Ms. Brinda Westbrook-Sedgwick Commission Secretary Public Service Commission of the District of Columbia 1325 G Street N.W. Suite 800 Washington, DC 20005 bwestbrook@psc.dc.gov Christopher Lipscombe, Esq. General Counsel Public Service Commission of the District of Columbia 1325 G Street N.W. Suite 800 Washington, DC 20005 clipscombe@psc.dc.gov Brian R. Caldwell Assistant Attorney General Public Advocacy Section Office of the Attorney General for D.C. 441 Fourth Street, N.W., Suite 600-S Washington, D.C. 20001 Brian.caldwell@dc.gov Meena Gowda Esq. Deputy General Counsel DC Water and Sewer Authority 5000 Overlook Avenue S.W. Washington, DC 20032 Meena.gowda@dcwater.com Sandra Mattavous-Frye, Esq. Office of People' s Counsel 1133 15th Street, N.W. Suite 500 Washington, DC 20005 smfrye@opc-dc.gov Kristi Singleton, Esq. Assistant General Counsel Real Property Division U.S. General Services Administration 1800 F Street, NW Room 2016 Washington, DC 20405 Kristi.singleton@.11.sa. gov Robert Cain, Esq. Washington Gas 1000 Maine Avenue, S.W., 6th Floor Washington, DC 20024 RCainl@washgas.com ~ouneau Appendix 3 ~ pepco. An Exelon Company Dennis P. Jamouneau Assistant General Counsel EP9628 701 Ninth Street NW Washington DC 20068-0001 Office 202 872 3034 Fax 202 331 6767 pepco com dJamouneau@pepcohold1ngs com November 26, 2019 Ms. Brinda Westbrook-Sedgwick Commission Secretary Public Service Commission of the District of Columbia 1325 G Street, N.W. Suite 800 Washington, DC 20005 Re: Formal Case Nos. 1130 & 1155 Dear Ms. Westbrook-Sedgwick: Potomac Electric Power Company, along with its stakeholders, met on November 13, 2019. Enclosed are the Minutes for the November 13, 2019, Transportation Electrification Working Group Meeting, attendance sheet and power point presentation of issues discussed at the meeting. Please feel free to contact me if you have any questions regarding this matter. Sincerely, ~ Dennis P. J amouneau Enclosures cc: All Parties of Record Transportation Electrification Program Working Group October 22 Meeting Update: DDOT is updating the figures presented from the October meeting with the following: As of November 10th, 2019, 1,665 electric vehicles are registered to the District. That number includes 1,420 registered to individuals and 245 registered to businesses. This amends previously provided data - the number of EVs registered to the District as of July 31, 2018, was 891. ************************************************************************************************** November 13, 2019 Meeting commenced: 1:15pm and convened at 4:30 pm Attendees: ABB, Apartment Office and Building Association (AOBA), ChargePoint, DC Attorney General’s Office, DC Dept of Transportation (DDOT), DC Department of For-Hire Vehicles, DC Office of People’s Counsel (OPC), DC PSC Staff, DC Dept of Energy & Environment (DOEE), Electric Vehicle Association of Greater Washington (EVADC), Exelon/Pepco Holdings LLC (PHI), Load Analytics, LVL2 Charging, MJ Bradley, Natural Resource Defense Council (NRDC), Sierra Club, Greenlots, Quanta Technology, Atlas Public Policy Presented by Jen Grisham (PHI) Peter Blazunas (PHI) and Robert Stewart (PHI) Meeting Topic – Multi-Unit Dwelling (MDU) Charging. Context: Offering 5, 50% off on charger / Installation up to $7,500 / Tariff “MDU-PIV” / review of obtaining data from 2nd meters and embedded meters Discussion started with the tariff portion of the offering, followed by the equipment-related portion of the offering. Key Takeaways: • • • • • The MDU tariff, as proposed in Pepco’s original filing, was generally not supported by the working group. The group came to a general consensus that there should be specific MDU charging tariff for the pilot program, with one abstention. Generally, the working group looks favorably on submetering, although submetering is not currently permitted in the District. Regarding application parameters, the group reached consensus on: - Location: Applications would be accepted on a first-come, first-served basis with a 10-20% reservation for low-to-moderate income customers (LMI) initially. - Caps for building owners: 1 (single or multiple port) installation per MDU owner. However, the type of equipment and deployment number were not decided mainly due to a disagreement on what type of equipment should be installed. Summary of positions: Offer Design • Pepco’s proposal calls for the installation of Level II charging equipment in mutli-dwelling units. Pepco’s position on the type of equipment to be employed is that the equipment should be smart EVSE that 1 • • allows Pepco to gather data, thus creating learnings that can be applied to the future to build programs (as opposed to just installing outlets). EVADC recommended deploying standard EVADC recommended deploying standard NEMA 5-20 or 14-50 outlets in parking spaces of the MDUs, as opposed to hardwired EVSEs with fixed J1772 connectors. These outlets would be sub-metered and the parking spot reserved for an individual tenant. This is preferable, because EVs come with their own portable EVSEs, and by using their own portable EVSE, the driver has a direct relationship with Pepco. This setup avoids unnecessary intermediaries between the driver and the grid (so no concern of prolonged broken EVSEs or exorbitant pricing), while also allowing the driver to purchase power at tariff-set rates from the same provider they chose for their home service. Tenants in MDUs should be able to access the same SOS tariff as home owners with their own off-street parking.. Further, EVADC commented the program dollars would be better used if the outlet solution were adopted since that option is much less expensive and could therefore be implemented on a wider scale. AOBA hypothesized that if “unmanaged” equipment (rather than managed EVSE chargers) were installed, the program could accommodate much more than 100 installations (Pepco does not have a comparable cost estimate for this solution). o This suggestion was met with mixed feedback. Some parties support the idea due to the anticipated lower costs and potential for supporting a higher number of customers while other parties questioned this engineering practicality, potential safety hazards and that outlets are a short-term solution not well adapted to anticipated rates of EV adoption.  ABB strongly discourages Level 1 chargers and believes that simple outlet charging will be insufficient and not a good driver experience, increase safety concerns in comparison to Level 2 chargers. Level 2 chargers provides EV drivers with state of charge information which provides a better EV driver experience.  ABB recommends that all chargers be networked/smart and managed. It would be difficult to track, repair, and maintain inoperable equipment if unmanaged. ABB also believes that it is better to have fewer and well-maintained chargers.  EVADC is of the opinion that current hard-wired, wall-mounted EVSEs are likely to become obsolete in the near to mid-term as Vehicle-to-Grid technology gets developed.  DOEE asked whether there was an installation ceiling. Pepco confirmed the intent for the program would be similar to its Maryland program to include a ceiling ($7,500). Regarding Offer 5, PSC Staff reminded the working group that the Commission has not decided on Offer 5. The Commission intends to make its final decision based in part on comments from the working group. Staff also noted should the offer move forward, revisions could be recommended based on the results of Pepco’s interim reporting. Tariff Design Options Discussed: Three potential options regarding MDU charging were discussed. 1. Pepco presented tariff MDU-PIV, which is a flat rate that necessitates a second meter to implement. 2. Pepco outlined a demand-charge credit that would credit MDU charger owners the demand-charge equivalent amount of 50% of a charger’s nameplate capacity. The demand-charge credit was presented as an alternative to the MDU-PIV tariff. 3. As originally outlined in Offering 5, the option of providing 50% off the cost of a charger in addition to covering installation costs up to $7,500 was discussed. • • Pepco reminded the working group that building a time-differentiated rate for MDU is challenging since the schedules of the individuals living in MDUs may be such that certain EV owners may not be able to shift EV charging to off-peak periods. On the question of whether an EV tariff is necessary, Greenlots believes that the question is more nuanced than that. Special EV tariffs can have real value when they are paired with managed charging. 2 • • • • • • • • ChargePoint commented that MDU-PIV rate with embedded metrology to avoid the 2nd meter would be a good solution. ChargePoint’s experience is that no building owner mentions demand charges as a barrier to EV adoption. Technology such as “Power Charging” can put a cap on kW used by chargers during specific periods of time. For example, a cap preventing the charger from going above 10 kW can be employed. Generally, there is no barrier to EV charger adoption. Quanta Technology commented the biggest barrier to EV charger installation is demand and efforts to remove this barrier will place us on the right track. AOBA adds generally that building owners do understand demand charges and take actions to attempt to lower them. Regarding charging rates, AOBA voiced a preference for them to be as simple as possible, avoiding more complex TOU rates. OPC does not support any demand charge credit as a way to subsidize the program, which was in response to Pepco’s example of the program being deployed in MD that has ratepayers subsidizing 50% of demand charges for 30 months. DOEE states that it supports dynamic pricing whether EVs are concerned or not and will continue to work with stakeholders under the Dynamic Pricing working group that will address these issues under the purview of the Commission. Regarding a potential MDU-PIV rate, DOEE believes we need to talk about the objective of the EV rate design. DOEE believes an optional, opt-in TOU rate seems appropriate, but that DOEE can’t say for sure unless the objectives of such a rate are well defined. Upon hearing that Pepco’s R-PIV rate was a whole house rate, DOEE asked if such a rate could be created for the common grounds of a building (such that charging would be covered). Sierra Club questioned whether demand charges are a significant barrier to deployment of EVSE at MDUs and the need for a demand charge holiday in this setting. Sierra Club supports a tariff that provides a time-of-use price signal to incentivize off-peak charging (regarding Pepco’s concern that some MDU residents may have non-traditional work schedules, Sierra Club notes that a short on-peak window can readily address this concern, and believes it is appropriate for any drive whose work schedule necessitates charging that truly coincides with system peak (e.g. between 5 and 8 pm) to pay more to do so, reflecting the greater cost that charging imposes on all customers. Metering • As part of a larger conversation on submetering, Staff reminded the group that residential submetering was prohibited in 1928. • Pepco noted in its MD 9261 EV pilot, there were challenges with obtaining data from the meter and that cellular costs often exceeded the cost of a 2nd AMI meter installation. Additionally, the potential for billing errors can also be expensive. Technology has advanced since the pilot and in the current, largescale EV programs underway in Maryland (MD 9478), several of the MD utilities will be utilizing submetering to obtain data. Pepco will observe the submetering performance for that program and evaluate options for a program in the District. • ChargePoint commented the goal is managing EV load to reduce strain on the grid, whether that is done best via technology embedded in the vehicle or otherwise is unknown. However, managed charging is key. General MDU Offering Policy • DOEE reiterated the District’s transportation policy and commitment to alternative transportation, such as bicycles, to accomplish the District’s goals. • AOBA generally reminded the group that comparisons between DC and Maryland for this topic are less applicable because public transportation in DC is used much more than in Maryland. • OPC generally does not support the deployment of chargers in locations where there are no EVs as it raises the potential for standard assets but recognizes that there is an equitable access issue that also exists. Buildings in which current EV owners are living should be prioritized and an effort should be 3 • • • made to place at least one charger in each ward if this offering is ultimately approved by the Commission. DOEE commented on the hope that managed charging will be among the suite of Pepco’s demand response offerings. Generally, AOBA commented that if building owners want EV chargers, the owner should be responsible for paying for them. AOBA believes building owners will need education regarding the effect that EV chargers would have on the building’s Energy Star score. Questions and commentary minutes: - - Slide 2 – Smart Level II for MDUs Summary (Offer 5)  Question: Registrants can only request for installation in the District? A: Yes.  Question: Will the criteria for MDU focus on 1 charger per customer or 1 charger that can handle multiple customers? A: For MDUs, the plan is for 1 charger to handle multiple users. This topic was discussed in further detail later in the meeting.  Question: Can a charger serve multiple buildings or one charger per MDU? A: 2nd meter for MDUs are recognized as a second individual meter (not sub metered).  Question: [2nd Meter Required] Does Pepco have the ability to submeter in the District? A: The DC Code states that you cannot submeter. A: Propose to have a 2nd meter attached to the existing meter for (1) data collection and (2) providing a quicker setup process for the customer.  Question: Is the $7,500 cap restricted to installation only? A: Yes.  Question: What are the requirements for RFP (ready for proposal) installations? A: Revenue Grid Metering Ability to handle the load Ability to collect data  Question: What is the rationale behind the $7,500 cap? A: The cap is reasonable based on the Company’s prior experience with the cost of charger installation. Slide 3 – Today’s Working Group Meeting Goals  Question: Which of the programs require a second meter and how is the KW carved out from the standard KW if only a single meter is utilized? Question is based on determining how load is credited per the EV program. A: The demand credit will only apply to chargers that are on the EV Plan. 4  Question: Would customers want this new plan or choose submetering instead? A: Some customers may prefer submetering due to the plan’s limitations (such as limiting 3 people per charger). Ideally apartments and condominiums will set up charging stations to attract residents.  Question: If an apartment building wants to install 6 charging stations, would it be difficult to place the stations in a lot without assigning it to an individual? The issue is that owners can install the stations without having the ability to control who parks in the selected areas.  Comment on installation: Some residents will use the installed chargers and others may simply plug into their home outlet. • Home outlet charging should not be considered a long-term solution as customers who use this approach will require additional charge time and will also increase safety hazards. o EVADC disputes this and claims a hardwired EVSE will typically deliver 240V, 32A, which is also available from the portable EVSE that comes standard with most new EVs plugging into any available NEMA 14-50 outlet (stove outlet). There is no evidence of any safety hazards. • Customers with short commutes and low vehicle use would determine the cost of having an installed charger vs plug-in wall outlet.  Question: Pepco – Is there also a need for a Tariff solution? If not, Pepco will focus solely on the equipment incentive portion of the offering.  Question: – How many Level 2 chargers were installed as a necessity for residents and is there any available data? A: No. Only the national data points are available. An option would be to survey residential customers after the initial pilot program for information and determine what worked best.  Question: What is the goal of the EV program? To meet existing demands or to help the District meet its related goals? A: Both Concerns: • Trying to get one rate schedule to solve multiple goals and not focusing on the outlook in 4-5 years. • There should be more data collection and testing instead of stating that customers can just plug-in anywhere (or submetering). • Submetering could improve over time and be used as a solution in the future. Are there Regulatory walls in place to suppress submetering? MDU Tariff/MDU-PIV applicability: • Pepco recognizes the charging stations are predominately located in the 8th Ward. • OPC is not in support of the tariff for MDU charging or any associated options, with the belief that the rebate should be enough. OPC’s pointed out that the District’s main goal is to decrease the number of vehicles on the road. At this juncture, OPC finds it difficult to have ratepayers pay for the installation of chargers at MDU sites where there are no EV owners and no public access. 5 • PSC Staff highlighted that residential submetering was prohibited in 1928. The ban was partially lifted in 2008 allowing submetering for non-residential customers. • Pepco’s take on MDU submetering is doing what is best for the customer, whether that means installing a second meter or using the existing metrology. o No language in the DC Code that restricts residential submetering. o AOBA mentions the need to add additional language to the existing law for condos and coops. o Cost of installing a second meter is estimated at $600 (includes the meter can, AMI meter, and other hardware). • Pepco posed the question as to whether a tariff is necessary or if the currently approved equipment incentive is enough on its own. o The group agreed with the equipment incentive. o Greenlots is not on-board with limiting the equipment incentive only to properties that already have EV owners. Many MDU residents want EVs but refrain from buying them because they lack a place to charge at home. Allowing MDUs to take advantage of the incentive, especially if no existing resident owns an EV, is a good way to increase EV adoption. Master Metered Units and Demand Charges • In regard to MDUs, most individual apartments have their own meter on the Residential rate schedule (which does not have a demand charge). The rate schedule for the remaining load for the building would only reflect that associated with EV charging and general areas.  Question: AOBA – Can Pepco determine the number of small-sized buildings and how small buildings are classified? Additionally, would second meter installation become a solution for this population? Managed Charging and Dynamic Pricing. (Utilities having the ability to manage the load from the charger). A Residential Dynamic Pricing Working Group to be convened by the PSC was proposed in the PSC Staff Proposed Opinion and Order in DC1130 (MEDSIS) to discuss dynamic pricing options for Pepco’s residential customers. Dynamic Pricing could create a price signal to encourage managed charging. OPC and DOEE supports dynamic pricing that is grounded in principles of effective grid utilization and management. OPC also noted that the MEDSIS working group requested its final working group report that the dynamic pricing working group be reconvened. • Greenlots believes that managed charging is the primary goal, stating the benefits of offering an incentive and the ability for utilities to share data. • Sierra Club identified managed charging as a critical long-term solution to EV load management as rates of EV penetration become more substantial • Can Pepco provide managed charging outside of an EV rate? • Greenlots asks if there is an option for Opt-In TOU rates for MDUs? A: The Commission has not approved any rates that apply solely to EV load. 6 Review of Deployment Numbers: • Criteria for consideration as an MDU is 3 or more dwelling units within the building. Estimated 240,000 per page 11 of the DC Policy Center Housing Report. • OPC commented that it is unsure if this Offering is needed as OPC supports AOBA’s rationale that due to the competitive market MDU owners meet the needs of their tenants. However, if the Commission approves this Offering OPC could possibly support up to 100 installations as mentioned in the Order should the offer move forward with Level 2 EVSE installations. • Conduit approach could extend to additional charging spots. • Goal is to make charging more readily available. • Define an “Electric Stub”. The stub is where the charger connects to the concrete infrastructure. • ChargePoint states that they would be able to service and support more than the initial 100 pilot spots with deploying the conduit only, saving revenue by not installing a box. • Group to further discuss workable solutions for the 100 pilot installs vs conduit only. • Question: Is the landlord (Owner) responsible for paying for the install? o A: As intended by Pepco’s application, the owner would be responsible for paying for installation costs in excess of $7,500. o A: Make-Ready goes beyond the meter (not Pepco’s normal course of business) Deployment Criteria Discussion: Location: • OPC’s position is for equitable access, installing charging stations where EVs are utilized. • If the Commission approves Offering 5, AOBA believes only 1 charger per building should be allowed and OPC agrees with this approach. • AOBA agrees with the 1st come 1st served proposed details for the 100 pilot customers. • Request flexibility with Wards that have registered EV customers and provide additional incentives to the other areas. • ChargePoint suggested reserving 10%-20% for LMI buildings/residents/locations noting successful programs utilizing this methodology. Age of Buildings: • Discuss and determine cost of new construction installation vs. existing buildings. o New construction will generally be cheaper in cost in comparison to older buildings. o Installation could be 20+% higher for existing buildings (cost could depend on structure). Dedicated Space: • Dedicated space for EVs must be owned by the landlord (Owner). • Time of use restrictions to be decided by the MDU owner. Number of Residents: • The group commented that limiting the deployment goal based on the number of residents can be hard to enforce but could serve as a restriction. • Pepco position is to keep the limitations to a minimum in order to get the program approved by the Commission. Number of Buildings: • Discussion included adding a limiter on how many chargers per owner in one location to prevent a single owner from cornering the market. 7 • • • Building readiness – installations should be limited to buildings that do not require costly upgrades to receive charging equipment. Greenlots expressed support for a balanced approach in capping the incentives. We do need some caps to prevent a small handful of buildings or real estate companies from using up all the incentives. On the other hand, if we want to encourage uptake of these incentives, a good way to accomplish that is to allow a real estate manager to use it at multiple properties. Limiting the incentive to 1 charger per building/property owner is unnecessarily restrictive and may slow uptake, which runs counter to the goal of this pilot. Question: What are the qualifications to determine the readiness of a building? o $7,500 cap per building (owner). o 1 rebate per owner, per year. o PSC – 1 rebate per owner in a 2yr window, then adjust the cap based on the usage and need. Accessibility: • DOEE suggested that, when placing the chargers, consideration be given to ADA accessible spaces and wall location. The group mentioned that this could entail unintended consequences, such as the ADA spaces being moved farther away from buildings in order to comply with the directive. Recommended Pepco/MDU Coordination Requirements: • Strong MDU/Tenant Education and Outreach (Pepco noted there are costs associated with this effort and its implementation plan filed on October 31 did not include costs related to this offering) • Initiate ad campaign/direct mailing (using the least expensive options available). • Partnering with AOBA. • Place on the Commission website. • Clean Cities Coalition – the CCC has been DOE’s champion regarding offering technical assistance and public education and outreach for EV adoption. • Customer outreach (detailing the benefits to landlords and ratepayers). • Place an estimate calculator on the website to show customers the program incentives. 8 FC 1130 and 1155 Attachment 1 Pepco DC Transportation Electri?cation Program Working Group November 13. 2019 519.9% Name Affiliation 1' DQx/tn p?pco 2- )oSi/l Cot/m (?nwe?/MM?b 3- 27AM 41.6 MAMA 6mm 9. Law 13 at? ,5 10. Josh BWU Chub 11. MAMAMWN Hamburg/x. 19c: 0% 12. 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Pm?hm; mo 24- 25' O?dj?larFC 1130 and 1155 Attachment 2 Transportation Electrification Program Working Group Multi-Dwelling Unit Charging November 13, 2019 1 Smart Level II for Multi-Dwelling Units Summary (Offer 5) Offer 5 Summary Participation Details • Pepco proposed to provide MDU • 100 customers; 1st owners/operators 50% off the cost come 1st serve of a Level 2 charger and 100% of basis the cost of installation FC 1130 and 1155 Attachment 2 PSC Decision (Orders 19898 and 19983) • Commission sees clear value in charging offerings focused on MDUs and spreading costs per charging station warranted • Noted stakeholder concerns on rate design and use of 2nd meter • Planned targeting included new and planned developments • 1 year requirement for participation • Customer would be account holder of premise with Pepco account contract • Required • Insufficient information to dedicated parking move forward with for PIV charging Offering 5 as filed infrastructure • At least 3 DC • TE Working Group to registered PIV discuss implementation owners residing details • 2nd meter required • Green rider option available 2 Today’s Working Group Meeting Goals  FC 1130 and 1155 Attachment 2 Determine necessity/development of new tariff for MDU charging  Review of MDU-PIV, R-PIV, and flat rate  Applicability of PIV-Green to MDU customers  Develop selection criteria, identify beneficiaries, determine appropriate deployment numbers  Determine coordination services provided by Pepco to MDU owners  Re-visit Maryland approach to metering; discuss potential implementation, challenges and alternatives utilizing 2nd meters  Impact on MDU-PIV rate offer  Impact on PIV-Green tariff  Availability of 2nd meters by non-(program) participating MDUs for EVSEs  Participation of 3rd party supplied customers 3 FC 1130 and 1155 Attachment 3 199 DEFINITIONS 199.1 When used in this title, the following terms and phrases shall have the meanings ascribed: Apartment - one (1) or more habitable rooms with kitchen and bathroom facilities exclusively for the use of and under the control of the occupants of those rooms. Apartment, bachelor - one (1) or more habitable rooms with bathroom facilities exclusively for the use of and under the control of the occupants of those rooms in a building containing three (3) or more apartments; provided, that in the building no kitchen facilities or privileges shall be available to or used by the occupants of the bachelor apartment. Apartment house - any building or part of a building in which there are three (3) or more apartments, or three (3) or more apartments and one (1) or more bachelor apartments, providing accommodation on a monthly or longer basis. (36 DCR 7627-7628) Building - a structure having a roof supported by columns or walls for the shelter, support, or enclosure of persons, animals, or chattel. When separated from the ground up or from the lowest floor up, each portion shall be deemed a separate building, except as provided elsewhere in this title. The existence of communication between separate portions of a structure below the main floor shall not be construed as making the structure one (1) building. Dwelling - a building designed or used for human habitation. When used without a qualifying term, it shall mean a one-family dwelling. Dwelling, multiple - a building containing three (3) or more dwelling units or rooming units, or any combination of these units totaling three (3) or more. Garage, mechanical parking - a building or other structure without repair or service facilities in which parking is accomplished entirely by means of elevators and in such a manner that there is no human occupancy other than by the elevator operators anywhere except on the main floor. Garage, parking - a building or other structure, or part of a building or structure, over nine hundred square feet (900 ft.2) in area, used for the parking of motor vehicles without repair or service facilities. The term parking garage may include a parking garage accessory to the principal use, but shall not include a mechanical parking garage. FC 1130 and 1155 Attachment 3 Garage, private - a building or other structure, or part of a building or structure, not exceeding nine hundred square feet (900 ft.2) in area, used for the parking of one (1) or more motor vehicles and having no repair or service facilities. Parking space - an off-street area accessible and of appropriate dimensions to be used exclusively for the temporary parking of a motor vehicle. (31 DCR 6585) Planned unit development - a plan for the development of residential, institutional, and commercial developments, industrial parks, urban renewal projects, or a combination of these, on land of a minimum area in one (1) or more districts irrespective of restrictions imposed by the general provisions of the Zoning Regulations, as more specifically set forth in chapter 24 of this title. (15 DCR 170) SOURCE §§ 1201 and 1202 of the Zoning Regulations, effective May 12, 1958; as amended by Final Rulemaking published at 39 DCR 1900, 1904 (March 20, 1992); as amended by Final Rulemaking published at 40 DCR 1951 (March 19, 1993); as amended by Final Rulemaking published at 40 DCR 3744 (June 11, 1993); as amended by Final Rulemaking published at 40 DCR 6364 (September 3, 1993); as amended by Final Rulemaking published at 45 DCR 1045, 1046 (February 27, 1998); as amended by Final Rulemaking published at 46 DCR 8284, 8286 (October 15, 1999); as amended by Final Rulemaking published at 47 DCR 9741-43 (December 8, 2000), incorporating by reference the text of Proposed Rulemaking published at 47 DCR 8335, 8336 (October 20, 2000); as amended by Final Rulemaking published at 48 DCR 9830, 9831-32 (October 26, 2001); as amended by Final Rulemaking published at 49 DCR 1655 (February 22, 2002); as amended by Final Rulemaking published at 50 DCR 8818 (October 17, 2003); as amended by Final Rulemaking published at 50 DCR 9387 (November 7, 2003); as amended by Final Rulemaking published at 50 DCR 10137 (November 28, 2003); as amended by Final Rulemaking published at 50 DCR 10822 (December 19, 2003); as amended by Final Rulemaking published at 51 DCR 3440 (April 2, 2004); as amended by Final Rulemaking published at 51 DCR 4778 (May 7, 2004); as amended by Final Rulemaking published at 52 DCR 6358 (July 8, 2005); as amended by Final Rulemaking published at 52 DCR 7259 (August 5, 2005); as amended by Final Rulemaking published at 52 DCR 9155 (October 14, 2005); as amended by Final Rulemaking published at 52 DCR 9713 (October 28, 2005); as amended by Final Rulemaking published at 53 DCR 2671 (April 7, 2006); as amended by Final Rulemaking published at 53 DCR 6363 (August 4, 2006); as amended by Final Rulemaking published at 53 DCR 9580 (December 1, 2006); as amended by Final Rulemaking published at 53 DCR 10085 (December 22, 2006); as amended by Final Rulemaking published at 54 DCR 3064 (April 6, 2007); as amended by Final Rulemaking published at 54 DCR 8943 (September 14, 2007); as amended by Final Rulemaking published at 54 DCR 8976 (September 14, 2007); as amended by Final Rulemaking published at 54 DCR 9393 (September 28, 2007);as amended by Final Rulemaking published at 55 DCR 34 (January 4, 2008); as amended by Final Rulemaking and Order No. 08-20 published at 56 DCR 2181 (March 13, 2009); as amended by Final Rulemaking and Order No. 08-16/08-16A at 56 DCR 3125 (April 24,2009); as amended by Final Rulemaking and Order No. 09-09 published at 56 DCR 8849 (November 13, 2009); as amended by Final Rulemaking and Order No. 09-16 published at 57 DCR 2961 (April 2, 2010); as amended by Final Rulemaking published at 59 DCR 4236, 4237 (May 4, 2012); as amended by Final Rulemaking published at 59 DCR 15096 (December 28, 2012); as amended by Final Rulemaking published at 60 DCR 8967 (June 14, 2013); as amended by Final Rulemaking and Order No. 13-06 published at 61 DCR 5981 (June 13, 2014); as amended by Final Rulemaking published at 62 DCR 8883 (June 26, 2015); as amended by Final Rulemaking published at 63 DCR 390 (January 8, 2016); as amended by Final Rulemaking published at 63 DCR 1632 (February 12, 2016). FC 1130 and 1155 Attachment 3 Electricity--P.S.C. of D.C. No. 1 Original Page No. R-X DC – MDU - PIV MULTI- DWELLING UNIT - PLUG-IN VEHICLE CHARGING SCHEDULE "MDU - PIV" AVAILABILITY This Schedule “MDU-PIV” is available for the duration of at least one year to all qualified customers, defined as the account holder of the premise with whom the Company has the account contract, who own or operate condominium/apartment complexes (“MDUs”) where dedicated parking can be made available for PIV charging infrastructure and where at least three District of Columbia-registered PIV owners reside. The customer agrees to allow the Company to maintain necessary equipment (if applicable) to monitor or manage the PIV load. CHARACTER OF SERVICE The service supplied under this schedule normally will be alternating current, sixty hertz, single phase, three wire, 120/240 volts, or three wire, 120/208 volts. MONTHLY RATE Kilowatt-hour Charge All kilowatt-hours Winter Summer $ 0.01576 per kwhr $ 0.01162 per kwhr Generation and Transmission Service Charges – Customers who do not receive service from an alternative Electric Supplier as defined in the Company’s General Terms and Conditions will receive Generation and Transmission Service from the Company under the provisions of Rider “SOS” – Standard Offer Service. Billing Credit - A monthly billing credit in the amount of $0.62 will be applied to the bill of each customer receiving a consolidated bill from an alternative supplier for services provided both by Pepco and by the alternative supplier. BILLING MONTHS Summer – Billing months of June through October. Winter – Billing months of November through May. METER READING Watt-hour meters will be read to the nearest multiple of the meter constant and bills rendered accordingly. GENERAL TERMS AND CONDITIONS This schedule is subject in all respects to the Company's "General Terms and Conditions for Furnishing Electric Service" and the Company's "Electric Service Rules and Regulations." Date of Issue: MONTH DAY, YEAR Date Effective: Usage on and after MONTH DAY, YEAR FC 1130 and 1155 Attachment 3 DC – MDU - PIV Electricity--P.S.C. of D.C. No. 1 Original Page No. R-X APPLICABLE RIDERS Standard Offer Service – Multi-Family Dwelling Unit – Plug-In Vehicle Charging Administrative Credit Delivery Tax Public Space Occupancy Surcharge Residential Aid Discount Optional Meter Equipment Related Services Net Energy Metering Rider Residential Aid Discount Surcharge Rider Sustainable Energy Trust Fund Energy Assistance Trust Fund Bill Stabilization Adjustment Residential Direct Load Control Rider Underground Project Charge Rider Community Net Metering Rider Customer Base Rate Credit Rider Underground Rider Excess Deferred Income Tax Credit Green-PIV (Optional) Date of Issue: MONTH DAY, YEAR Date Effective: Usage on and after MONTH DAY, YEAR FC 1130 and 1155 Attachment 3 GENERAL TERMS AND CONDITIONS FOR FURNISHING ELECTRIC SERVICE IN THE DISTRICT OF COLUMBIA FC 1130 and 1155 Attachment 3 10. SERVICE CONNECTIONS a. General The Company's practice shall be to provide service connection facilities which, in its judgment, will assure to the Applicant or Customer safe, adequate and reasonable electric service to meet their requirements commensurate with accepted industry standards and practices. A service connection will normally include those facilities installed by the Applicant or the Company on private property or within the vertical projection of the outermost structural component of the facility served, to the first terminal point for each service location at or in the building or facility to be served. This will also include facilities deemed necessary by the Company to interconnect existing or future Customers adjacent to the premises being served, as well as those facilities installed elsewhere and dedicated to connecting the Company's common distribution system to the point of termination of the Company’s service conductors. A normal service connection will be supplied in accordance with subsections a. through d. of this Section. The Company, upon request, to the extent reasonably practicable will supply a service connection in excess of or different from a normal installation consistent with the Company's practice set forth above ("Customer Plan"). Applicants shall furnish and install those items specified and shall contribute toward the Company's cost of furnishing and installing its facilities as specified in subsection e. of this Section. The Company will also install and own service connections referred to as “make ready infrastructure,” as defined and limited by the Public Service Commission in Order No. 19898 (paragraph 32 and 33), to support the installation and operation of electric vehicle charging in the District of Columbia. This “make ready” work consists of the service connection and supply infrastructure to support electric vehicle charging comprised of the electrical infrastructure from the distribution circuit to the stub of the Electric Vehicle Supply Equipment (EVSE). It can include equipment on the utility-side (e.g. transformer) and customer-side (e.g. electrical panel, conduit, wiring) of the meter. Notwithstanding any other provisions in Sections 10 or 11 of these General Terms and Conditions, the installation of “make ready infrastructure” as defined above will have no cost to the customer/ Applicant. All facilities installed by the Applicant which will be used to enclose, protect, support or provide termination for Company-owned facilities shall be approved by the Company. FC 1130 and 1155 Attachment 3 The usual practice is for the Company to provide a single service connection. However, where the electrical demands of the service are too extensive for a single service connection to be practical multiple service connections may be required. When multiple connections are deemed necessary by the Company, the Applicant will shift load wherever practicable from one service location to another to more advantageously balance the loads. Any relocation or alteration of Company-owned facilities may be made only with the approval of the Company and shall be at the expense of the party requesting the change or who is responsible therefore, if such change is occasioned by: 1. A request for relocation or alteration of such facilities, or 2. Structural changes on the premises served, or 3. Other private construction work being performed (or to be performed) which jeopardizes the safe and normal operation of existing electric facilities in the area. When service to a premises is discontinued, the Company will leave any or all of its service connection facilities in place, if permitted to do so, when in the opinion of the Company the facilities are reasonably protected and are likely to be used again at that location within a reasonable time. Company-owned service connection facilities will be removed (or, if underground, abandoned at the option of the Company) upon request of the Owner or other proper party. If the projected demand of the service connection requested by the Customer ("Customer Plan") is in excess of the projected demand of the Company Plan, in addition to paying a contribution in aid of construction for the local facilities, the Customer will be subject to the charges specified in Excess Facilities - Rider "EF". Under the terms of that Rider, a contract demand will be set equal to the difference between the projected kilowatt demand of the Customer Plan and the Company Plan. If the actual metered demand for that account reaches at least 90% of the Capacity of the Customer Plan for any twelve billing months within five years of the date that the facilities were installed, the Company will refund to the customer the contribution in aid of construction associated with those excess facilities and the amount collected through Rider "EF". A written contract with a minimum term of 5 years will be required for Customers taking service under Rider "EF". In the event that the Customer terminates service earlier than five years the Customer will be responsible for making the remainder of the payments in a lump sum. FC 1130 and 1155 Attachment 3 Attachment FC 1130 and 1155 Attachment 3 RESIDENTIAL SERVICE – PLUG-IN VEHICLE CHARGING SCHEDULE "R-PIV" AVAILABILITY Available to customers who own or lease a plug-in vehicle with an electric range of greater than 30 miles which requires electric service to provide periodic battery charging and who would otherwise be eligible to take electric service under Schedule “R.” The service supplied under this schedule is for both electric requirements for residential purposes as well as Plug-in Vehicle (“PIV”) battery charging purposes. All electricity provided under this schedule is delivered through the same meter. Net Energy Metering customers are eligible for this Schedule “R-PIV.” CHARACTER OF SERVICE The service supplied under this schedule normally will be alternating current, sixty hertz, single phase, three wire, 120/240 volts, or three wire, 120/208 volts. MONTHLY RATE Distribution Service Charge Customer Charge – Residential Kilowatt-hour Charge First 400 kilowatt-hours In excess of 400 kilowatt hours Summer Winter $15.09 per month $ 15.09 per month $ 0.00800 per kwhr $ 0.02283 per kwhr $ 0.00800 per kwhr $ 0.01594 per kwhr Generation and Transmission Service Charges – Customers will receive Generation and Transmission Service, including the Procurement Cost Adjustment, from the Company under the provisions of Rider “SOS” – Standard Offer Service at the following rates: Generation Service Charge All kilowatt-hours – On-Peak All kilowatt-hours – Off-Peak All kilowatt-hours – Admin Charge Transmission Service Charge Minimum Charge* In excess of 30 kilowatt-hours Summer Winter $ 0.09950 per kwhr $ 0.03034 per kwhr $ 0.00300 per kwhr $ 0.11199 per kwhr $ 0.03601 per kwhr $ 0.00300 per kwhr Summer Winter $ 0.12 per customer $ 0.00790 per kwhr $ 0.12 per customer $ 0.00790 per kwhr *The minimum charge includes the first 30 kWh or faction thereof of consumption. Procurement Cost Adjustment See https://www.pepco.com/MyAccount/MyBillUsage/Pages/DC/CurrentTariffsDC.aspx for the currently effective rate. BILLING MONTHS Summer – Billing months of June through October. Winter – Billing months of November through May. FC 1130 and 1155 Attachment 3 PEAK HOURS For Schedule “R-PIV,” On-Peak hours are considered to be 12:00 p.m. to 8:00 p.m., Monday through Friday, excluding holidays. METER READING Watt-hour meters will be read to the nearest multiple of the meter constant and bills rendered accordingly. GENERAL TERMS AND CONDITIONS This schedule is subject in all respects to the Company's "General Terms and Conditions for Furnishing Electric Service" and the Company's "Electric Service Rules and Regulations." APPLICABLE RIDERS Standard Offer Service – Residential – Plug-In Vehicle Charging Administrative Credit Delivery Tax Public Space Occupancy Surcharge Residential Aid Discount Optional Meter Equipment Related Services Net Energy Metering Rider Residential Aid Discount Surcharge Rider Sustainable Energy Trust Fund Energy Assistance Trust Fund Bill Stabilization Adjustment Residential Direct Load Control Rider Underground Project Charge Rider Community Net Metering Rider Customer Base Rate Credit Rider Underground Rider Excess Deferred Income Tax Credit Rider PIV-Green FC 1130 and 1155 Attachment 3 Attachment FC 1130 and 1155 Attachment 3 PLUG-IN VEHICLE – GREEN RIDER RIDER “PIV-GREEN” PLUG-IN VEHICLE – GREEN RIDER – “PIV-GREEN” This rider, which is only available to customers served under Schedule R-PIV provides 100% renewable energy on an opt-in basis to Schedule “R-PIV.” This rider is a dollar per kilowatt-hour rate and is applied to the Customer’s billed kilowatt-hours. This rider will be updated based on the most up-to-date market prices and the District of Columbia Renewable Portfolio Standards on or about February 1st and August 1st of each year. The current applicable Rider “PIV-Green” rate is equal to $0.04717 per kilowatt-hour. FC 1130 and 1155 Attachment 3 Pepca Demand Management Pilot for Plug-In Vehicle Charging in Maryland Final Report?Results, Insights, and Customer Metrics 2016 TECHNICAL UPDATE FC 1130 and 1155 Attachment 3 Section 8: Smart Level 2 EVSE with Embedded (ITron) Meter Comparison with AMI Meters For this Pilot Program, a level 2 smart EVSE was speci?ed. This EVSE had an embedded revenue grade meter from ITRON. These meters allowed Pepco to be able to communicate with the meters and, when appropriate, reduced their load during demand response events. AMI meters capture the load due to the EV and the line connecting the meter, Itron meters only measure the load due to the EV as they are embedded in the AMI meter. Therefore, the load difference between these two meters should largely consist of line losses. Detailed analysis was conducted to see how these two meters differed. A difference between 1 and 3 percent was expected due to the line losses mentioned above. A detailed analysis can be found in Appendix In summary, a comparison between the Itron and meter was made for 12 customers enrolled in the program, out of a total of 35 customers with the Itron meters. Unfortunately, due to communication issues, the Itron meters did not record many of the charging sessions. On average, the Itron meters did not log 70% of the charge events. An addition-.11 analysis was done to compare meter differences only when both meters concurrently logged a charge event. In this case, the agreement between meters was much better and there was on average only a 2% difference between the two readings for all data logged in 2015. The missed ltron charges are due to Wlli?l communication issues and glitches in the communication software. A new firmware is currently being tested that should fix these issues. Once these are fixed, the Itron meters should be able to log EV charges accurately. The smart level 2 EVSE with embedded IRON meter was within 2% of the second utility AMI meter reading. Due to data transmission paths (cellular and WI I71), the embedded meter data only reached the destination 30% of the time; therefore, the source data used for comparison was limited. FC 1130 and 1155 Attachment 3 RESIDENTIAL SERVICE SCHEDULE "R" AVAILABILITY Available for either Standard Offer Service when modified by Rider “SOS” or Distribution Service in the District of Columbia portion of the Company's service area for low voltage electric service where the use is primarily for residential purposes and for farm operations where the electricity for both farm and residential purposes is delivered through the same meter. Available only in individual residences and in individually metered dwelling units in multi-family buildings. Not available for residential premises in which five (5) or more rooms are for hire. Not available for seasonal loads metered separately from lighting and other usage in the same occupancy. Not available for temporary, auxiliary or emergency service. CHARACTER OF SERVICE The service supplied under this schedule normally will be alternating current, sixty hertz, single phase, three wire, 120/240 volts, or three wire, 120/208 volts. MONTHLY RATE Distribution Service Charge Customer Charge – Residential Kilowatt-hour Charge First 400 kilowatt-hours In excess of 400 kilowatt hours Summer Winter $15.09 per month $ 15.09 per month $ 0.00800 per kwhr $ 0.02283 per kwhr $ 0.00800 per kwhr $ 0.01594 per kwhr Generation and Transmission Service Charges – Customers who do not receive service from an alternative Electric Supplier as defined in the Company’s General Terms and Conditions will receive Generation and Transmission Service from the Company under the provisions of Rider “SOS” – Standard Offer Service. Billing Credit - A monthly billing credit in the amount of $0.62 will be applied to the bill of each customer receiving a consolidated bill from an alternative supplier for services provided both by Pepco and by the alternative supplier. BILLING MONTHS Summer – Billing months of June through October. Winter – Billing months of November through May. FC 1130 and 1155 Attachment 3 METER READING Watt-hour meters will be read to the nearest multiple of the meter constant and bills rendered accordingly. GENERAL TERMS AND CONDITIONS This schedule is subject in all respects to the Company's "General Terms and Conditions for Furnishing Electric Service" and the Company's "Electric Service Rules and Regulations." APPLICABLE RIDERS Standard Offer Service - Residential Administrative Credit Delivery Tax Public Space Occupancy Surcharge Residential Aid Discount Optional Meter Equipment Related Services Net Energy Metering Rider Residential Aid Discount Surcharge Rider Sustainable Energy Trust Fund Energy Assistance Trust Fund Bill Stabilization Adjustment Residential Direct Load Control Rider Underground Project Charge Rider Community Net Metering Rider Customer Base Rate Credit Rider Underground Rider Excess Deferred Income Tax Credit FC 1130 and 1155 Attachment 3 MASTER METERED APARTMENT SERVICE SCHEDULE "MMA" AVAILABILITY Available for either Standard Offer Service when modified by Rider “SOS” or Distribution Service in the District of Columbia portion of the Company's service area for low voltage electric service for multiple application to master-metered apartment buildings where the use is predominantly residential and not for retail business establishments. Not available for separately metered service billed on Schedule “GS ND” that did not qualify for multiple application of the residential rate as of December 31, 1982. Not available for seasonal loads metered separately from lighting and other usage in the same occupancy. Not available for temporary, auxiliary or emergency service. CHARACTER OF SERVICE The service supplied under this schedule normally will be alternating current, sixty hertz, single phase, three wire, 120/240 volts, or three wire, 120/208 volts. MONTHLY RATE Summer Distribution Service Charge Customer Charge $11.84 per month Kilowatt-hour Charge First 400 kilowatt-hours In excess of 400 kilowatt hours $ 0.00891 per kwhr $ 0.02542 per kwhr Winter $11.84 per month $ 0.00891 per kwhr $ 0.01774 per kwhr Generation and Transmission Service Charges – Customers who do not receive service from an alternative Electric Supplier as defined in the Company’s General Terms and Conditions will receive Generation and Transmission Service from the Company under the provisions of Rider “SOS” – Standard Offer Service. Billing Credit - A monthly billing credit in the amount of $0.62 will be applied to the bill of each customer receiving a consolidated bill from an alternative supplier for services provided both by Pepco and by the alternative supplier. BILLING MONTHS Summer – Billing months of June through October. Winter – Billing months of November through May. FC 1130 and 1155 Attachment 3 METER READING Watt-hour meters will be read to the nearest multiple of the meter constant and bills rendered accordingly. GENERAL TERMS AND CONDITIONS This schedule is subject in all respects to the Company's "General Terms and Conditions for Furnishing Electric Service" and the Company's "Electric Service Rules and Regulations." APPLICABLE RIDERS Standard Offer Service - Residential Administrative Credit Delivery Tax Public Space Occupancy Surcharge Optional Meter Equipment Related Services Net Energy Metering Rider Residential Aid Discount Surcharge Rider Sustainable Energy Trust Fund Energy Assistance Trust Fund Bill Stabilization Adjustment Residential Direct Load Control Rider Underground Project Charge Community Net Metering Rider Customer Base Rate Credit Rider Underground Rider Excess Deferred Income Tax Credit CERTIFICATE OF SERVICE I hereby certify that a copy of Potomac Electric Power Company's TE Working Group Meeting Minutes was served this November 26, 2019 on all parties in Formal Case No. 1130 and 1155 by electronic mail. Ms. Brinda Westbrook-Sedgwick Commission Secretary Public Service Commission of the District of Columbia 1325 G Street N.W. Suite 800 Washington, DC 20005 bwestbrook@psc.dc.gov Christopher Lipscombe, Esq. General Counsel Public Service Commission of the District of Columbia 1325 G Street N.W. Suite 800 Washington, DC 20005 clipscombe@psc.dc.gov Brian R. Caldwell Assistant Attorney General Public Advocacy Section Office of the Attorney General for D.C. 441 Fourth Street, N.W., Suite 600-S Washington, D.C. 20001 Brian.caldwell@dc.gov Meena Gowda, Esq. Deputy General Counsel DC Water and Sewer Authority 5000 Overlook Avenue, S.W. Washington, DC 20032 Meena.gowda@dcwater.com Sandra Mattavous-Frye, Esq. Office of People s Counsel 1133 15 1h Street, N.W. Suite 500 Washington, DC 20005 smfrye@opc-dc.gov Kristi Singleton, Esq. Assistant General Counsel Real Property Division U.S. General Services Administration 1800 F Street, NW Room 2016 Washington, DC 20405 Kristi.singleton@.!!sa. gov Robert Cain, Esq. Washington Gas 1000 Maine Avenue, S.W., 61h Floor Washington, DC 20024 RCain@washgas.com Appendix 4 !S pepco. An Exelon Company Dennis P. Jamouneau Office 202.872,3034 Assistant General Counsel Fax 202.331.6767 EP9628 djamouneau@pepcoholdings.com pepco.com 701 Ninth Street NW Washington, DC 20068-0001 December 20, 2019 Ms. Brinda Westbrook-Sedgwick Commission Secretary Public Service Commission of the District of Columbia 1325 G Street, N.W. Suite 800 Washington, DC 20005 Re: Formal Case Nos. 1130 & 1155 Dear Ms. Westbrook-Sedgwick: Potomac Electric Power Company, along with its stakeholders, met on December 9, 2019. Enclosed are the Minutes for the December 9, 2019, Transportation Electrification Working Group Meeting, attendance sheet and power point presentation of issues discussed at the meeting. Please feel free to contact me if you have any questions regarding this matter. Sincerely, Dennis R Jamouneau Enclosures cc: All Parties of Record Transportation Electrification Program Working Group December 09, 2019 Meeting commenced: 1:10pm Attendees: Apartment Office and Building Association (AOBA), DC Department of Transportation (DDOT), DC Office of People’s Counsel (OPC), DC Department of Energy & Environment (DOEE), DC PSC Staff, Department of ForHire Vehicles (DFHV), AECOM , Atlas Public Policy, Crown Castle, Greenlots, LVL2 Charging, Plug In America, Sierra Club, Siemens, Exelon/Pepco Holdings LLC (PHI) Presented by Michael Tietjen (DFHV), Jen Grisham (PHI) and Robert Stewart (PHI) Meeting Topic – Taxi/Rideshare and Residential Rebates. Context: Offering 10 / Installation ten Smart Level 2 EVSE and two DCFC dedicated to Rideshare/ Tariff Updates / Approved by Commission; Continued collaboration with DFHV and other participating entities. - Slide 2-3 – Offering 10 – Taxi/Rideshare Charging  Pepco began the meeting by describing our Taxi/Rideshare Charging Offering 10, which was approved by the Commission. Pepco noted that Uber and Lyft were unable to attend the meeting, but they are interested in participating in this program and collaborative meetings to determine optimal site selections. Staff indicated an interest in knowing potential sites for charger deployment for its report to the PSC. While high level discussions have occurred, today’s working group meeting was the first formal collaboration on this offer. DHFV indicated an interest in timing the site selection process with the DOEE Thermal Decarbonization Study to be finalized at the end of 2020. The relevant stakeholders will continue to collaborate on this offer and update the Commission periodically on progress through its required reporting.  - Pepco recommends that any service that includes the chargers installed under this program continue to be served under an existing commercial tariff until experience and best practices dictate that other tariff options may be more suitable. In October, Pepco submitted an update to its Terms & Conditions for Furnishing Electric Service in support of make-ready work. Slide 5 – Department For-Hire Vehicles  The Department For-Hire Vehicles (DFHV), an agency that provides regulation for taxis, limousines and Transportation Network Companies (TNC) that provide app-based rides, gave a presentation about taxis, with an emphasis on electric taxis. Approximately 125,000 trips by taxis are taken on a weekly basis with the peak time during lunch hours. Most trips are in the downtown corridor (primarily Massachusetts Ave., Louisiana Ave., Union Station and Dupont Circle) during the day from Monday through Friday. EV taxi trips average about 2.5 miles vs. 3 miles for non-EV taxis. Most EV taxi drivers report not having home charging stations and look to charge in the District or the corridors along their route to and from work. Roughly 40-45% of all taxi drivers commute from VA; DC makes up another 25%, and the remainder come from MD.  TNCs, collectively average 5-6 million rides annually. Under the CleanEnergy DC Omnibus Amendment Act of 2018, TCNs are required to prepare an electrification. EV taxis average 300400 rides per month.  The DC Govt. had initiatives to promote EV taxis in 2016, and at peak there were 130-140 EV taxis operating, but now there are only 50 EV taxis operating. There are currently about 150 combined plug-in hybrid and EV taxis. When surveyed, EV taxi drivers’ primary concerns were with the range and charging station accessibility. Other concerns identified by DFHV surround the garage charging stations, where the customer would have to pay the parking garage fee along with the fee to charge. There are 2 DCFC charging stations at Union Station and 1 on Benning Rd. exclusively used by EV taxis. By 2030, 50% of taxis and limousine service vehicles are required to be low or zero emission vehicles.  Less than a quarter of the taxi drivers operating in the District actually live in the District.  DFHV highly recommends that the type of charging (s stations included in the offering be changed to focus on DCFC instead of Level 2 chargers (DOEE notes). This change is desirable because it would more likely result in increased utilization by taxi drivers. PSC Staff noted such a request would be useful for reporting to the Commission. • • - [Greenlots] Was the intent of this offering to provide charging stations for taxis only or for everyone? o Pepco - Based on previous conversations, this is for taxis/rideshare only. [DC PSC] Are there any requirements or factors for siting fast chargers? o (DFHV) recommends that the chargers be sited in “clusters” (i.e., 2 sites of 6 chargers or 3 sites of 4 chargers). Additionally, DFHV recommends that chargers be sited in locations that are accessible by taxi drivers without paying additional parking fees (OPC notes). • How many rides do EV taxis make per day and how full are the vehicles? o DFHV – Per EV vehicle, trip counts range here from 300-400 trips per month for the busiest vehicles and some vehicles are utilized infrequently. o DFHV would need additional time to review its data to see if it can determine how “full” vehicles are, on average, during rides. • [DC PSC] Have you received any complaints from customers about not being able to locate charging stations? o DFHV - Yes. • [Greenlots] Any available data to show the increase in TNCs and decline in taxis? • [DC OPC] Raised an equity concern related t the idea that chargers subsidized by DC ratepayers would be used by a majority of drivers living in Virginia and Maryland. Slide 4 – Offering 4 – Rebates for Residential Level II EVSE (Rob Stewart)  Pepco discussed the proposed residential rebate for L2 chargers and the need for them to be smart chargers instead of “dumb” chargers. The cost of a Smart Charger in Pepco’s MD program ranges from $600- $1,000 from a utility sponsored provider whereas other chargers, which are not “smart,” can cost $300-$400 from Amazon and other retailers. Smart chargers are needed for the utility to collect data on how the charger is being utilized, gauge trends in demand, and for the possibility of managed charging (at a later date) if needed to lessen the load on the transformer. Data collected would be shared among the working group through annual reports. • [DOEE] What more can be done with the EV pilot program? The DOEE observed that the learning objectives from Offering 4 are limited to residential charging behavior in the absence of time varying rates of managed charging signals. DOEE noted that a more compelling learning objective might utilize an experimental design to compare charging behavior of residential customers under flat rates vs. the approved Whole Home EV TOU Rate (“R-PIV”) (OPC Notes). The DOEE recommends expanding the “learnings” objectives mentioned by Pepco by incorporating Time of Use (TOU) rates. Potentially, the 500 customers receiving rebates could be divided into two test cells. The first group would be placed on a R-PIV rate, and the second on a flat rate. o Yes, it can be done but would be determined in the future as data is collected. [DOEE] Will make available an electrification road map before the end of the year. [DOEE] Believes that Pepco has not adequately established that Offering 4 has merits and therefore DOEE cannot support Offering 4. Pepco has had two opportunities to establish the merits of Offering 4 – first through its initial TE Plan filing, and second through the TEWG process. The PSC in Order No. 19898 found that Pepco had not demonstrated that this Offering was in the public interest. Through the TEWG process, Pepco has again failed to present a robust or compelling case for the merits of Offering 4. Therefore, DOEE urges the PSC to reject this offering. Further discussion of program design or implementation strategy is rendered moot because the threshold issue of merit has not been met. • Does Pepco have the ability to collect hourly data? o If we know who our customers are, then we can collect data. However, it will be more difficult to collect because hourly data collected on AMI premise meters may not be granular enough to capture all charging data events. Pepco’s offering, with “smart” chargers, would allow us to collect data specific to the customer. o [DOEE] DOEE remains concerned about the potential impacts of EV charging on the distribution system and encourages Pepco to explore pilots and program offerings that incentivize EV charging behavior that reduces adverse impact to the distribution system. This could be accomplished through dynamic pricing, including time of use pricing (TOU), that creates price signals to encourage EV owners to charge during off-peak periods. It could also be accomplished through demand response (DR) programs, including managed charging that throttle EV charging when there are distribution constraints. Enabling technologies, which may include on-vehicle telematics or behavioral messaging, could further enhance the effectiveness and participation rates for dynamic pricing and DR programs. Pepco should leverage the approved Whole House Time-of-Use Rate (Schedule “R-PIV”) and/or future dynamic pricing rate designs to direct charging behavior. DOEE notes that the CleanEnergy DC Omnibus Amendment Act of 2018 allows Pepco to propose DR programs, and DOEE encourages Pepco to explore managed charging pilots as part of its portfolio of DR offerings. • Can Demand Response work for Level 2? o Pepco would prefer to see that chargers are turned down and not turned off During times of capacity needs. This would reduce the load of a Level2 charger to that of a level 1 charger. Customers should have the ability to opt out. • [DOEE] Can a District resident opt-in the program and apply for rebates/ incentives if the resident already has a charger installed? o Pepco responded that an agreement would be put in place similar to the one in Maryland to ensure participation so as to help achieve the goals of the program. o In the future, customers with eligible chargers could participate in other aspects of the program (to be determined in the future) but remain ineligible for the rebate. • [DC OPC] How are we ensuring that customers are receiving the rebate? Should there be a contract signed for new EV installation? o MD has a “Terms and Conditions” section in the Tariff that specifies that the customer will sign a contract. o Part of the contract will require utilization of the charger for a specified time period. • [DC OPC] If the offering is approved by the Commission, OPC would like to see that the chargers are spread out and not clustered in one ward. o Education and Outreach can be used to make sure customers in all wards are aware of this offering. Next Meeting – January 14, 2019 @ 1 pm Topic – Offering 4 – Stakeholder Feedback Provide written feedback on Offer 4 for final stakeholder report by 9 am Friday, December 13.  Suggested guidance  What is your organization’s current position on Offering 4?  What modifications would your organization suggest for Offering 4?  If Offering 4 were approved, what is the appropriate dollar amount?  If Offering 4 were approved, what is the appropriate number of rebates?  Describe any additional alternatives your organization has to promote residential charging to support the District’s clean energy goals.  What is your organization’s current position on Offering 4? [ChargePoint] ChargePoint supports offering 4 as originally proposed and continues to believe it is a vital element of any utility EV charging program [Sierra Club] Sierra Club is strongly supportive of utility efforts to manage EV load to maximize ratepayer benefits of the integration of higher levels of EVs. To this end, the Sierra Club supports incentives that will enable EV drivers who charge at home to receive and respond to time-of-use price signals and participate in utility load management and demand response programs. [DOEE] DOEE believes that Pepco has not adequately established that Offering 4 has merits and therefore DOEE cannot support Offering 4. Pepco has had two opportunities to establish the merits of Offering 4 – first through its initial TE Plan filing, and second through the TEWG process. The PSC in Order No. 19898 found that Pepco had not demonstrated that this Offering was in the public interest. Through the TEWG process, Pepco has again failed to present a robust or compelling case for the merits of Offering 4. Therefore, DOEE urges the PSC to reject this offering. Further discussion of program design or implementation strategy is rendered moot because the threshold issue of merit has not been met. [OPC] The Office of the People’s Counsel (“OPC”) stands by its previous stated opinion of opposition regarding Pepco’s proposed Transportation Electrification Offering 4 – Fixed Rebates for Residential Customers Installing Smart Level 2 Chargers (“Offering 4”) for inclusion in the final report to the of the Transportation Electrification Working Group (“TEWG”) to the Public Service Commission of the District of Columbia (“PSC”). OPC stands by its original position that Offering 4 lacks merits and should be rejected by the Commission as an unjust and unreasonable use of ratepayer funds.  What modifications would your organization suggest for Offering 4? [ChargePoint] ChargePoint concurs with the Company that a minimum eligibility for qualifying equipment should require “smart chargers” as they are needed for the Utility to collect data on how the charger is being utilized, gauge trends in demand, and for the possibility of managed charging (at a later date) if needed to lessen the load on the transformer. ChargePoint recommends following a similar approach as in the Maryland programs with the customer being able to choose from multiple qualifying residential L2 stations and charging networks. We also encourage strong cybersecurity qualification criteria to protect the participant and the utility (e.g. encryption, SOC 2 Type II reports, compliance with GDPR/CCPA, etc.) and Energy Star certification to encourage energy efficiency. [Sierra Club] To ensure that all ratepayers receive the maximum benefit of the program, we recommend several conditions on approval of the program and on participation in the program. First, recipients of the rebate should agree to participate in future time-of-use rates and/or load management programs that are enabled by the smart, networked chargers. Second, Pepco should be required, by a specific date, to propose load management programs for recipients of the rebates. These proposed programs should take the form of EV-only time-of-use rates and/or more active utility load management programs. Third, Pepco should be required, by a specific date, to develop load management programs that utilize the communications capabilities in an increasing number of plug-in electric vehicle models, which avoid the need for installing expensive smart, networked Level 2 chargers to achieve the same load management ends. Pepco should allow any EV owner whose vehicle or charger has the necessary communications capability to participate in these load management programs. [DOEE] DOEE encourages Pepco to explore pilots and program offerings that incentivize EV charging behavior that reduces adverse impact to the distribution system. This could be accomplished through dynamic pricing, including time of use pricing (TOU), that creates price signals to encourage EV owners to charge during off-peak periods. It could also be accomplished through demand response (DR) programs, including managed charging that throttle EV charging when there are distribution constraints. Enabling technologies, which may include on-vehicle telematics or behavioral messaging, could further enhance the effectiveness and participation rates for dynamic pricing and DR programs. Pepco should leverage the approved Whole House Time-of-Use Rate (Schedule “RPIV”) and/or future dynamic pricing rate designs to direct charging behavior. DOEE notes that the CleanEnergy DC Omnibus Amendment Act of 2018 allows Pepco to propose DR programs, and DOEE encourages Pepco to explore managed charging pilots as part of its portfolio of DR offerings.  If Offering 4 were approved, what is the appropriate dollar amount? [ChargePoint] ChargePoint supports the original proposal of $500 per qualifying device as this appears to be the average from other similar utility programs. To help ensure customer cost share and avoid unintended preference of certain models, the Company may wish to consider linking the rebate allowance to equal 50% of the combined installation and EVSE costs up to $500. [Sierra Club] As EV penetration in the District increases, it will be increasingly important that EV drivers charging at home are doing so in a manner that minimizes adverse impacts to the grid. Consequently, it will be increasingly imperative that all EV drivers engaging in home charging receive time-of-use price signals and/or participate in EV load management programs to reduce impacts. Determinations regarding the sizing of this offering should be made with an eye to this longer-term necessity. As an initial pilot, the Sierra Club supports Pepco's proposed sizing ($250,000, based on 500 rebates of $500). However, Sierra Club urges the Commission to conduct a reevaluation of the program after one year to assess Pepco's progress in moving forward with the load management strategies recommended in response to the prior question and the ongoing necessity and appropriateness of smart Level 2 rebates given the evolving capabilities of the EV fleet.  If Offering 4 were approved, what is the appropriate number of rebates? [ChargePoint] ChargePoint supports the original proposal of up to 500 customers. [Sierra Club] See response to prior question.  Describe any additional alternatives your organization has to promote residential charging to support the District’s clean energy goals. [ChargePoint] No Additional Comment. [Sierra Club] See prior responses. [DOEE] DOEE remains concerned about the potential impacts of EV charging on the distribution system and encourages Pepco to explore pilots and program offerings that incentivize EV charging behavior that reduces adverse impact to the distribution system. This could be accomplished through dynamic pricing, including time of use pricing (TOU), that creates price signals to encourage EV owners to charge during off-peak periods. It could also be accomplished through demand response (DR) programs, including managed charging that throttle EV charging when there are distribution constraints. Enabling technologies, which may include on-vehicle telematics or behavioral messaging, could further enhance the effectiveness and participation rates for dynamic pricing and DR programs. Pepco should leverage the approved Whole House Time-of-Use Rate (Schedule “RPIV”) and/or future dynamic pricing rate designs to direct charging behavior. DOEE notes that the CleanEnergy DC Omnibus Amendment Act of 2018 allows Pepco to propose DR programs, and DOEE encourages Pepco to explore managed charging pilots as part of its portfolio of DR offerings. Any proposed pilots or programs for residential EV charge management should leverage existing EVSE incentives, including the 50% tax credit. Pepco should be required to report data on charging behavior in response to dynamic pricing or DR and share the data through regular reports to relevant District government agencies. Pence District of Columbia Transportation Electri■ea■en Working Green Meeting Deeemher 9, 1019 Attendees Af■liation Transportation Electrification Program Working Group Taxi/Rideshare Charging And Residential Rebates December 9, 2019 1 Offering 10 – Taxi/Rideshare Charging  Pepco approved to deploy make-ready infrastructure to support the installation of ten (10) Smart Level 2 EVSE and two (2) Level II chargers dedicated to taxi/rideshare services.  Update to tariff/Terms & Conditions  Collaboration on site selection 3 Offering 10 – Taxi/Rideshare  Continued collaboration with Department for Hire and relevant stakeholders to determine siting locations and process for selecting/installing chargers  Considerations for siting:  Optimizing utilization  Number of chargers in locations  Cost  Proximity to Pepco facilities  Engineering requirements   Load, feeder capacity Pepco recommends entities participating in Offering 10 operate under their existing rate schedules 2 DRIVEN BY About The Department of For-Hire Vehicles Mission Strategic Objectives • The mission of the Department of For-Hire Vehicles (DFHV) is to protect the public interest by regulating the vehicle-for-hire industry to allow the citizens and visitors of the District of Columbia to have safe, affordable, and accessible transportation options. • Ensure passengers have safe and excellent riding experiences. • Ensure economic viability and expand economic opportunities for the vehicle-for-hire industry • Create and maintain a highly efficient, transparent, and responsive District government. 1 Key Activities 24/7 street enforcement Public complaints Lost and found Pilots and programs Technology Innovations Company registration and regulation • Driver registration (Taxi and Limo) • Vehicle Registration (Taxi and Limo) • • • • • • DFHV Taxi Overview (Average Trips and Vehicles Per Day) 35000 30000 28894 28177 26745 25230 25000 21189 20000 16510 15000 14401 10000 5000 2042 2822 3003 3055 2965 2982 Mon Tue Wed Thu Fri 2351 0 Sun Average of TripCount 1 Sat Average of UniqueVehCount DFHV Taxi Overview (Average Trips and Vehicles Per Hour/Weekdays) 2500 2042 2000 1873 2020 1902 1964 1824 1831 1658 1584 1477 1500 1277 1188 1198 1000 1247 1291 1316 1290 1253 1227 1037 1121 1073 1004 849 987 899 707 784 715 500 304 302 171 208 113 0 0 1 111 75 2 66 50 3 107 82 4 560 505 394 170 239 135 5 6 7 8 9 10 Average of TripCount 1 579 660 11 12 13 14 15 16 17 18 19 20 21 22 23 Average of UniqueVehCount DFHV Taxi Overview (Trips Mapped 12/1-12/r.?04. .. I . . TNC Overview (Trips per Month) TNC Monthly Trip Count 7,000,000 6,387,180 6,000,000 5,701,153 5,222,576 5,308,457 Jan Feb 5,785,771 5,495,767 5,457,185 Jun Jul 5,239,748 5,372,889 5,000,000 4,000,000 3,000,000 2,000,000 1,000,000 - 1 Mar Apr May Aug Sep DFHV TNC Overview (Trips and Vehicles Per Hour) 7000 6006 6000 Average Operator Count 6402 5491 5051 4886 5000 5864 5837 4350 4141 4257 4186 4347 5002 4596 4857 4473 4000 3495 3000 2374 2000 1707 959 1000 1232 581 356 610 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 8464 8678 23 24 Average of TripCount 12000 10405 10000 9264 9232 8000 7123 6571 9523 9031 7054 7127 7146 7182 7314 7922 7673 5948 6000 4000 3405 2618 2000 1442 1745 848 487 834 0 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 DFHV Current EV Taxi Fleet Active Registered EV Taxis 2016 Nissan leaf 77 2016 Kia Soul 7 2015 Nissan Leaf 6 2013 Nissan Leaf 2 2017 Chevy Bolt 2 2016 VW E-Golf 1 0 20 40 60 80 100 Active Registered Plug In Hybrids Toyota Prius (2013-2017) 32 Ford CMAX (2014-2017) 10 Ford Fusion Energi (2016-2018) 3 Kia Niro (2018) 2 0 5 10 15 20 25 30 35 DFHV History of DFHV EV Taxi Initiatives 2016 – DFHV makes first round of $10,000 purchase grants for Electric  Vehicles (13 Awards). 2016 – DFHV allows EVs as one of the acceptable criteria for getting a  new H Tag.  2017 – DFHV makes as second round of $5,000 purchase offset grants  (45 awards). 2017 – Installation of charging station at Union Station DFHV EV Taxi Driver Feedback What are the top challenges to driving an EV taxicab? I have to turn down long trips(such as to Dulles airport or other distant locations). 16 I have to re-charge frequently during the day. 14 There are not enough places to charge when I am working. 13 The cost of purchasing is too high. 11 Repairs are expensive. 5 It is difficult to maintain an EV and/or find repair services. 5 Other: Range, charging issues 3 Other: Does not like EV at all 2 There are not enough places to charge when I am working. 2 0 2 4 6 8 10 12 14 16 18 DFHV EV Taxi Driver Feedback What do you like most about driving an EV taxicab? I am helping to reduce greenhouse gas emissions and help the environment. 12 Quieter ride/reduced noise pollution. 9 Passengers enjoy riding in an EV. 5 Incentives were available to help with the purchase (tax credits, grants, etc) 4 Lower cost to operate. 2 EVs are safe. 1 0 2 4 6 8 10 12 14 DFHV EV Taxi Driver Feedback Reported Charging Location Union Station 11 Various charging stations near me (EVGo, ChargePoint) 5 Pentagon City 3 Takoma Park 2 Tysons Corner 1 Nissan Dealership 1 Dulles Town Center 1 0 2 4 6 8 10 12 DFHV EV Taxi Driver Charging Unique Drivers Sessions Average Session Length 10 Oh 32m Oh 30m Oh irn lclle Charging Eli-I: . a - Jul 1?.ng sea Oct new DEC EV Taxis Cluster Mostly in the Downtown Core J. 3 '5 . . r3.? .. . .5551"3'! I: . I Ir- ice-54.Cluster Mostly in the Downtown Core IS EV Tax Total Milage 433.5 575.0 783.1 394.6 539.4 579.5 284.0 954.1 449.0 411.9 528.9 720.5 941.2 713.1 770.0 666.0 899.5 787.7 779.7 1158.8 832.9 M165 K985 K965 M104 K918 M019 K921 N696 M064 M092 K950 M161 N841 M054 M022 K934 M050 K949 M119 K961 M053 1.32 610.2 2.13 486.4 2.68 K956 2.90 K957 570.0 199.5 537.1 268.4 K928 M042 400.0 K933 131.8 K963 1.56 203.0 230.2 M046 2.18 M100 270.2 M068 2.12 M138 181.7 M056 600.0 2.35 409.4 320.6 M088 2.33 2.30 2.26 299.9 191.6 M009 2.86 2.86 K946 174.9 M098 1200.0 M001 197.3 92.2 K966 M067 67.7 K953 95.0 28.1 M069 110.0 66.5 M038 1.45 M047 40.2 800.0 M127 7.3 K919 0.0 K991 EV Taxis Take Slightly Shorter Trips Than Gas Taxis Chart Title 1400.0 5.00 4.44 4.46 3.96 3.09 3.06 2.77 2.52 2.64 2.60 2.65 1.95 1.61 4.50 3.88 4.00 1000.0 3.47 3.23 2.95 2.07 1.95 3.50 2.96 2.73 2.55 2.67 1.82 2.80 3.06 2.27 3.00 2.25 2.17 2.14 2.50 2.20 2.00 1.49 1.50 1.30 1.00 200.0 0.50 0.00 Average mileage/vehicle DFHV Clean Energy Omnibus By 2030, 50% of public buses, passenger- and light-duty vehicles associated with privately-owned fleets with a capacity of 50 or more passengers or light-duty vehicles licensed to operate by the District of Columbia, commercial motor carriers, limousine-service vehicles, and taxis certified to operate by the District of Columbia shall be low-or-zeroemission vehicles. By 2040, 95% of public buses, passenger- and light-duty vehicles associated with privately-owned fleets with a capacity of 50 or more passengers or light-duty vehicles licensed to operate by the District of Columbia, commercial motor carriers, limousine-service vehicles, and taxis certified to operate by the District of Columbia shall be low-or-zeroemission vehicles. By 2035, 75% of public buses, passenger- and light-duty vehicles associated with privately-owned fleets with a capacity of 50 or more passengers or light-duty vehicles licensed to operate by the District of Columbia, commercial motor carriers, limousine-service vehicles, and taxis certified to operate by the District of Columbia shall be low-or-zeroemission vehicles. By 2045, 100% of public buses, passenger- and light-duty vehicles associated with privately-owned fleets with a capacity of 50 or more passengers or light-duty vehicles licensed to operate by the District of Columbia, commercial motor carriers, limousine-service vehicles, and taxis certified to operate by the District of Columbia shall be zero-emission vehicles. DFHV Considerations for PEPCO Working Group • DFHV highly recommends installation of fast charging stations • Drivers have told us they are looking opportunities to quickly charge up during the day.  • Use cases for level two chargers? • Optimal locations • Most EV activity is in downtown core, but it may be more difficult to find locations there. • Fees • Locations that driver can access without paying additional parking fees. DFHV DFHV DFHV.dc.gov GOVERNMENT OF THE DISTRICT OF COLUMBIA MURIEL BOWSER. MAYOR Offering 4 – Rebates for Residential Level II EVSE Background - Under Offering 4 in its Transportation Electrification Program Application, Pepco proposed providing up to 500 residential customers with plug-in vehicles a $500 rebate for the cost and installation of a Smart Level II charger, which offers remote management. The purpose of the offering was to help offset the upfront costs of charging equipment and incentivize plug-in vehicle adoption. Pepco would collect data obtained from the chargers to identify load impact caused by PIV use on local transformers as well as gain operational experience in communicating with smart chargers for future demand response events. 4 Offering 4 - Considerations  MEDSIS (FC 1130) Vision: • Sustainable, reliable, secure, affordable, interactive and non-discriminatory EVADC.com  Studies show drivers of plug-in electric vehicle drivers do more than 80% of their charging at home  Residential transformer loading is still a concern   Socio-economic conditions create the potential for local clustering Rebates provide:  Smart, controllable EVSE equipment for data collection and demand response evaluation  Valuable data on locational charging load and time of use help determine driver behaviors  Longer range vehicles require L2 charging in order to fully charge overnight  Utility rebates on residential smart L2 chargers will incentivize market 5 Offering 4 – Stakeholder Feedback  Provide written feedback on Offer 4 for final stakeholder report by 9 am Friday, December 13.  Suggested guidance  What is your organizations current position on Offering 4?  What modifications would your organization suggest for Offering 4?  If Offering 4 were approved, what is the appropriate dollar amount?  If Offering 4 were approved, what is the appropriate number of rebates?  Describe any additional alternatives your organization has to promote residential charging to support the District’s clean energy goals. 6 Utility Residential Charging Rebate Programs Active programs through December 2019 Utility Service Territory EVSE Equipment and Rebate  Type Max. Rebate  Amount Number of  rebates Entergy Arkansas, Louisiana, Mississippi and Texas Level 2 Charger $250 Unknown https://entergyetech.com/ Link Additional Requirements/Comment Alameda Municipal Power California Level 2 Charger and  installation $800 Unknown Qualifying level 2 (240‐volt) charging stations: Must be new, and not used, resold or rebuilt. Must be wall or pedestal‐mounted, and not portable. Must be certified by Underwriters Laboratories Inc. (UL  Listed); or ETL Listed https://alameda.dsmtracker.com/shop/residentia Must not be received from warranty insurance claims. l‐rebates/level‐2‐electric‐vehicle‐charger.html Eligible electrical upgrades: Must be permitted. Must be performed by an electrician with a valid C‐10  license. May include a new 240‐volt outlet, a new 240‐volt circuit,  and/or a new or upgraded panel Anaheim Public Utilities California Level 2 Charger, Installation  and Permit Fees $500 Unknown http://www.anaheim.net/593/Personal‐EV‐ Charger‐Rebate Azusa Power & Light California Level 2 Charger $150 Unknown https://www.ci.azusa.ca.us/1625/Plug‐In‐Electric‐ Rebate is applied as a credit to utility account. Vehicles Island Energy California Level 2 Charger, Installation  and Permit Fees $750 Unknown http://www.islandenergy.com/blog1/plug‐in‐ electric‐vehicle‐program‐info/ The qualifying Level 2 (240‐volt) EV chargers must comply  with SAE International J1772 standard (published on October 15,  2012) and must https://www.ladwp.com/cs/groups/ladwp/docu be: new and unused, and certified by a nationally  ments/pdf/mdaw/njyw/~edisp/opladwpccb6606 recognized testing 83.pdf laboratory (or NRTL), as recognized by the Occupational  Safety and Health Administration (e.g., Underwriters Laboratories) at  the time of purchase Los Angeles Department of  Water & Power  California Level 2 Charger $500 Unknown Pasadena Dept of Water  and Power California Level 2 Smart Charger and  Level 2 Non‐networked  $600 ‐ Smart L2 $200 ‐ non‐ Unknown Sacramento Municipal  Utility District California HCS‐40R Level 2 Charger utility provides  charger retail $665 Unknown Georgia Power Georgia Level 2 Charger on a  dedicated circuit $250 Unknown Alliant Energy Iowa and Wisconsin Level 2 Smart Charger and  Level 2 Non‐networked  chargers $500 ‐ Smart L2 $250 ‐ non‐ networked L2 Unknown *Offering has been approved and scheduled to launch 1 of 2 https://ww5.cityofpasadena.net/water‐and‐ power/residentialevrebate/ https://www.smud.org/en/Going‐Green/Electric‐ Vehicles/Residential/Level‐2‐Charger‐Info https://www.georgiapower.com/content/dam/ge Rebates available for installations completed between  orgia‐power/pdfs/residential‐pdfs/ev‐charging‐ January 1, 2019 and December 31, 2019. existing‐residential‐one‐pager.pdf https://www.alliantenergy.com/InnovativeEnergy Solutions/SmartEnergyProducts/ElectricVehicles/ EVHomeChargersandRebates Utility Residential Charging Rebate Programs Active programs through December 2019 Utility Service Territory EVSE Equipment and Rebate  Type EVSE Rebate  Amount Number of  rebates Naperville Electric Utility llinois Level 2 or Level 3 Charger $500 Unknown BGE Maryland Level 2 Smart Charger $300 1000 https://www.bge.com/SmartEnergy/InnovationT Customers agree to provide utility access to charging data echnology/Pages/EV‐FAQs.aspx Delmarva Maryland Level 2 Smart Charger $300 250 https://www.delmarva.com/SmartEnergy/Innova tionTechnology/Pages/ElectricVehicleProgramMD Customers agree to provide utility access to charging data .aspx Pepco Maryland Level 2 Smart Charger $300 750 https://www.pepco.com/SmartEnergy/Innovatio Customers agree to provide utility access to charging data nTechnology/Pages/FAQs.aspx Potomac Edison* Maryland Level 2 Smart Charger $300 1000 https://www.firstenergycorp.com/help/saving_e Customers agree to provide utility access to charging data nergy/electric‐vehicles/maryland‐ev.html Indiana Michigan Power Michigan Level 2 Smart Charger $2,500 250 Connexus Energy Co‐op Minnesota Level 2 Charger $500 Unknown Dakota Electric Co‐op Minnesota Level 1 or Level 2 Charger $500 Unknown https://www.dakotaelectric.com/wp‐ Applicants must be enrolled in off‐peak vehicle charging  content/uploads/2017/02/EVCharger_RebateFor program m.pdf Cape Hatteras  Electric Co‐op North Carolina   Level 2 Chargepoint EVSE $100 Unknown https://www.chec.coop/electricvehicles Randolph Electric North Carolina   Level 2 Smart Charger $500 25 Austin Energy Texas Level 2 Smart Charger and  Level 2 Non‐networked  chargers 50% off the  purchase and  installation; max  $1200 networked  $900 non‐ networked Burlington Electric Vermont Level 2 Smart Charger from  Chargepoint or Packetized  Energy $400 *Offering has been approved and scheduled to launch 2 of 2 Link Additional Requirements/Comment https://www.naperville.il.us/services/electric‐ utility/powering‐our‐community‐for‐the‐ future/electric‐vehicle‐charging‐systems/ https://www.indianamichiganpower.com/info/El Includes charger and installation ectricCars/MichiganIncentives.aspx Applicants must be enrolled in Time‐of‐Day or Off‐Peak rate  https://www.connexusenergy.com/save‐money‐ programs and‐energy/programs‐rebates/electric‐vehicles https://www.randolphemc.com/content/revup Customers agree to provide utility access to charging data Unknown Austin Energy may, at any time during your commitment  period, replace your charging station with an Austin Energy‐ owned charging station located in your home and on your  side of the meter. Austin Energy may install and operate Austin Energy owned  https://austinenergy.com/ae/green‐power/plug‐ data monitoring or charge management devices in your  in‐austin/home‐charging home and on your side of the meter. You agree to participate in Austin Energy surveys, interview,  and/or future charge management programs. Austin Energy  may use the participant’s charging station communication  signals to perform charge and load control functions,  including cycling charging Unknown https://www.burlingtonelectric.com/sites/default Requires enrollment in residential EV rate /files/inline‐files/EVSE‐EVRate‐form_0.pdf CERTIFICATE OF SERVICE I hereby certify that a copy of Potomac Electric Power Company's Minutes for the December 9, 2019, Transportation Electrification Working Group Meeting, attendance sheet and power point presentation of issues were served this December 20, 2019 on all parties in Formal Case No. 1130 and 1155 by electronic mail. Ms. Brinda Westbrook-Sedgwick Christopher Lipscombe, Esq. Commission Secretary General Counsel Public Service Commission Public Service Commission of the District of Columbia of the District of Columbia 1325 G Street N.W. Suite 800 1325 G Street N.W. Suite 800 Washington, DC 20005 bwestbrook@psc.dc.gov clipscombe@psc.dc.gov Brian R. Caldwell Assistant Attorney General Public Advocacy Section Office ofthe Attorney General for D.C. Washington, DC 20005 Meena Gowda, Esq. Deputy General Counsel DC Water and Sewer Authority 5000 Overlook Avenue, S.W. 441 Fourth Street, N.W., Suite 600-S Washington, DC 20032 Washington, D.C. 20001 Meena.gowda@dcwater.com Brian.caldwell@dc.gov Sandra Mattavous-Frye, Esq. Kristi Singleton, Esq. Office of People's Counsel Assistant General Counsel 1133 15"^ Street, N.W. Real Property Division Suite 500 U.S. General Services Administration Washington, DC 20005 1800 F Street, NW Room 2016 smfrye@opc-dc.gov Washington, DC 20405 Kristi.singleton@,asa.gov Robert Cain, Esq. Washington Gas 1000 Maine Avenue, S.W., 6"^ Floor Washington, DC 20024 RCain@.washgas.com Denhl P. Jamouneau Appendix 5 Transportation Electrification Program Working Group Requested Stakeholder Feedback on Offering 4 – Residential Rebates Topic – Offering 4 – Stakeholder Feedback  Suggested guidance  What is your organization’s current position on Offering 4?  What modifications would your organization suggest for Offering 4?  If Offering 4 were approved, what is the appropriate dollar amount?  If Offering 4 were approved, what is the appropriate number of rebates?  Describe any additional alternatives your organization has to promote residential charging to support the District’s clean energy goals. SIERRA CLUB  What is your organization’s current position on Offering 4? [Sierra Club] Sierra Club is strongly supportive of utility efforts to manage EV load to maximize ratepayer benefits of the integration of higher levels of EVs. To this end, the Sierra Club supports incentives that will enable EV drivers who charge at home to receive and respond to time-of-use price signals and participate in utility load management and demand response programs.  What modifications would your organization suggest for Offering 4? [Sierra Club] To ensure that all ratepayers receive the maximum benefit of the program, we recommend several conditions on approval of the program and on participation in the program. First, recipients of the rebate should agree to participate in future time-of-use rates and/or load management programs that are enabled by the smart, networked chargers. Second, Pepco should be required, by a specific date, to propose load management programs for recipients of the rebates. These proposed programs should take the form of EV-only time-of-use rates and/or more active utility load management programs. Third, Pepco should be required, by a specific date, to develop load management programs that utilize the communications capabilities in an increasing number of plug-in electric vehicle models, which avoid the need for installing expensive smart, networked Level 2 chargers to achieve the same load management ends. Pepco should allow any EV owner whose vehicle or charger has the necessary communications capability to participate in these load management programs.  If Offering 4 were approved, what is the appropriate dollar amount? [Sierra Club] As EV penetration in the District increases, it will be increasingly important that EV drivers charging at home are doing so in a manner that minimizes adverse impacts to the grid. Consequently, it will be increasingly imperative that all EV drivers engaging in home charging receive time-of-use price signals and/or participate in EV load management programs to reduce impacts. Determinations regarding the sizing of this offering should be made with an eye to this longer-term necessity. As an initial pilot, the Sierra Club supports Pepco's proposed sizing ($250,000, based on 500 rebates of $500). However, Sierra Club urges the Commission to conduct a reevaluation of the program after one year to assess Pepco's progress in moving forward with the load management strategies recommended in response to the prior question and the ongoing necessity and appropriateness of smart Level 2 rebates given the evolving capabilities of the EV fleet. Apartment & Office Building Association of Metropolitan Washington  What is your organization’s current position on Offering 4? [AOBA] AOBA does not support Offering 4. However, if the Commission approves Offering 4, AOBA submits it should be approved subject to two conditions: (i) the Offering is proposed as a pilot program and (ii) any and all costs and rebates are directly assigned to and recovered solely from residential ratepayers.  What modifications would your organization suggest for Offering 4? [AOBA] Further, if the Commission approves Offering 4 and consistent with a comment made by OPC, AOBA suggests that each selected residential customer formally agree to provide usage and other measurable data for specified time period (i.e., one or two years). AOBA further suggests that, if the residential customer does not or can not provide the agreed upon data, the customer must refund the rebate.  If Offering 4 were approved, what is the appropriate number of rebates? [AOBA] AOBA does not support the proposal to offer a $500 rebate to 500 residential customers. However, if the Commission approves a residential rebate, AOBA suggests that the rebates be limited to one per residential customer and offered on a first-come, first-served basis. ChargePoint  What is your organization’s current position on Offering 4? [ChargePoint] ChargePoint supports offering 4 as originally proposed and continues to believe it is a vital element of any utility EV charging program.  What modifications would your organization suggest for Offering 4? [ChargePoint] ChargePoint concurs with the Company that a minimum eligibility for qualifying equipment should require “smart chargers” as they are needed for the Utility to collect data on how the charger is being utilized, gauge trends in demand, and for the possibility of managed charging (at a later date) if needed to lessen the load on the transformer. ChargePoint recommends following a similar approach as in the Maryland programs with the customer being able to choose from multiple qualifying residential L2 stations and charging networks. We also encourage strong cybersecurity qualification criteria to protect the participant and the utility (e.g. encryption, SOC 2 Type II reports, compliance with GDPR/CCPA, etc.) and Energy Star certification to encourage energy efficiency  If Offering 4 were approved, what is the appropriate dollar amount? [ChargePoint] ChargePoint supports the original proposal of $500 per qualifying device as this appears to be the average from other similar utility programs. To help ensure customer cost share and avoid unintended preference of certain models, the Company may wish to consider linking the rebate allowance to equal 50% of the combined installation and EVSE costs up to $500.  If Offering 4 were approved, what is the appropriate number of rebates? [ChargePoint] ChargePoint supports the original proposal of up to 500 customers. . GOVERNMENT OF THE DISTRICT OF COLUMBIA Department of Energy and Environment DOEE Position on Pepco’s TE Offering 4 – Fixed Rebates for Residential Customers Installing Smart Level 2 Chargers Memo to the Transportation Electrification Working Group Introduction The District Department of Energy and Environment (“DOEE”) offers the following position regarding Pepco’s proposed Transportation Electrification Offering 4 – Fixed Rebates for Residential Customers Installing Smart Level 2 Chargers (“Offering 4”) for inclusion in the final report to the of the Transportation Electrification Working Group (“TEWG”) to the Public Service Commission of the District of Columbia (“PSC”). The TEWG has not arrived at a consensus regarding the merits of Offering 4, and instead will include individual member positions in the final report. DOEE, as filed under Formal Cases 1130 and 1155, does not believe that Offering 4, as filed in Pepco’s original Transportation Electrification Program Application (“TE Plan”), is justified on its merits. Additionally, DOEE believes that Pepco, through its participation in the TEWG, has failed to further elucidate the merits of Offering 4. Therefore, DOEE maintains its stated position that Offering 4 lacks merits and should be rejected by the PSC as an unjust and unreasonable use of ratepayer funds. Further discussion of program design for Offering 4, including rebate levels, is rendered moot because the threshold issue of merit has not been met. Background Pepco’s proposed Offering 4 would provide residential customers, with existing EVs and installed Smart Level 2 EVSE, a maximum rebate of $500, not to exceed 100% of the total EVSE installation costs, less any applicable rebates. Offering 4 would be available for up to 500 residential customers. In its application, Pepco justifies this rebate as necessary to offset the upfront costs of charging equipment and incentivize EV adoption.1 Further, Pepco will use data  Formal Case No. 1155, In the Matter of the Application of the Potomac Electric Power Company for Approval of its  Transportation Electrification Program (“Formal Case No. 1155”), Pepco Application for Approval of its  Transportation Electrification Program, ”), filed September 6, 2018 (“Pepco’s TE Program Application”), at page 30.  1 1200 First Street NE, 5th Floor, Washington, DC 20002 (202) 535-2600 doee.dc.gov collected from the Smart Level 2 EVSEs to “analyze customer usage and patterns, refine marketing and outreach strategies, and assess impacts on the grid.”2 In its initial comments in response to the Pepco’s TE Plan, DOEE explained that it prefers private investment rather than ratepayer investment in charging stations for District residents and questioned why additional financial incentives are required to support the deployment of EVSE for single family residential households. DOEE observed that District residents already have access to a 50% tax credit for EVSE for private use up to $1,000, or up to $10,000 for public use. DOEE recommended that Pepco identify opportunities to leverage existing incentives, including the tax credit, and provide additional analysis to justify the use of ratepayer funding.3 The PSC, through its Order No. 19898, found that Pepco’s TE Plan failed to explain why the rebate level was set at $500 and advised Pepco to target any rebates toward customer behavior that will benefit the operation of the distribution system.4 Further, the PSC Order referred Offering 4 to the TEWG to “gain greater clarity on the merits of a residential rebate program” and to “ensure that any recommended rebate level aligns with the program specific benefits.”5 Through Order No. 19898, the PSC made it clear that Pepco’s TE Plan, as filed, does not adequately establish the merits of Offering 4. The onus is on Pepco, as the applicant, to demonstrate through the TEWG the merits of Offering 4. Therefore, a clarification of the merits of Offering 4 is a threshold issue that must be resolved prior to any discussion of program design, including appropriate rebate levels. Discussion of TEWG Proceedings with Regard to Offering 4 The TEWG members discussed Offering 4 at the meeting on September 14, 2019, and again at the meeting on December 9, 2019. At the September 16 meeting, Pepco did not clarify the merits of its proposed Offering 4. Instead, Pepco reintroduced its Offering 4 and identified a sampling of other utilities that offer rebates for EVSE – although it was unclear whether those rebates were Ibid., at page 29. Formal Case No. 1130, In the Matter of the Investigation into Modernizing the Energy Delivery System for Increased Sustainability (“Formal Case No. 1130”), Comments by the Department of Energy and Environment on behalf of the District of Columbia Government, filed December 12, 2018 (“DOEE Initial Comments”), at page 7. 4 Public Service Commission of the District of Columbia, Formal Case No. 1155, Order No. 19898, rel. April 12, 2019 (“DC PSC Order No. 19898”), at Paragraph 42. 5 Ibid.  2 3 Page 2 of 5 for smart or non-smart Level 2 EVSE or what merits were identified to justify those other programs. Pepco did not lead a discussion of the threshold question of Offering 4’s merit, and instead asked TEWG members to break into small groups and discuss several questions regarding the benefits and design of Offering 4. This exercise exposed a lack of consensus among TEWG participants as to both the merits of Offering 4 and the appropriate program design (if offered). Offering 4 was again discussed at the December 9 TEWG meeting. At this meeting, Pepco identified additional utilities that offer rebates for Level 2 EVSE. Pepco also discussed its learning agenda for Offering 4. Pepco intends to use the data collected from the incentivized Smart Level 2 EVSE to better understand residential EV charging behavior in the absence of dynamic pricing or demand response programs. Pepco’s hypothesis, which they aim to validate through this Offering 4, is that EV owners will plug in their EVs as soon as they get home. DOEE does not believe that this learning agenda is compelling and that similar information can be garnered at a lower cost to ratepayers through market research and load modeling. Pepco did not present additional information on the benefits of this program to District residents, or how this Offering advances the District’s climate goals. Nor did Pepco present justification for why the market for Smart Level 2 chargers requires incentivization above and beyond the existing EVSE tax credit. DOEE’s Current Position on Offering 4 DOEE believes that Pepco has not adequately established that Offering 4 has merits and therefore DOEE cannot support Offering 4. Pepco has had two opportunities to establish the merits of Offering 4 – first through its initial TE Plan filing, and second through the TEWG process. The PSC in Order No. 19898 found that Pepco had not demonstrated that this Offering was in the public interest. Through the TEWG process, Pepco has again failed to present a robust or compelling case for the merits of Offering 4. Therefore, DOEE urges the PSC to reject this offering. Further discussion of program design or implementation strategy is rendered moot because the threshold issue of merit has not been met. Page 3 of 5 Alternatives to Promote Residential Charging to Support the District’s Clean Energy Goals DOEE remains concerned about the potential impacts of EV charging on the distribution system and encourages Pepco to explore pilots and program offerings that incentivize EV charging behavior that reduces adverse impact to the distribution system. This could be accomplished through dynamic pricing, including time of use pricing (TOU), that creates price signals to encourage EV owners to charge during off-peak periods. It could also be accomplished through demand response (DR) programs, including managed charging that throttle EV charging when there are distribution constraints. Enabling technologies, which may include on-vehicle telematics or behavioral messaging, could further enhance the effectiveness and participation rates for dynamic pricing and DR programs. Pepco should leverage the approved Whole House Time-of-Use Rate (Schedule “R-PIV”) and/or future dynamic pricing rate designs to direct charging behavior. DOEE notes that the CleanEnergy DC Omnibus Amendment Act of 2018 allows Pepco to propose DR programs, and DOEE encourages Pepco to explore managed charging pilots as part of its portfolio of DR offerings. Any proposed pilots or programs for residential EV charge management should leverage existing EVSE incentives, including the 50% tax credit. Pepco should be required to report data on charging behavior in response to dynamic pricing or DR and share the data through regular reports to relevant District government agencies. Page 4 of 5 Appendix: Excerpts from DOEE Filings and PSC Orders Relevant to Offering 4 DOEE Comments in FC1130, filed December 12, 2018:  DOEE generally supports the private investment of charging stations for District residents; however, DOEE questions why additional financial support is needed when existing infrastructure tax credits are already in place. DCG provides an income tax credit of 50% of the purchase and installation cost for an EVSE of 50% up to $1,000 for private use, or up to $10,000 for public use. DOEE recommends Pepco find ways to leverage existing incentives and to provide additional analysis to justify the use of ratepayer funding, if it is deemed that additional incentives are necessary to build out Residential Level 2 EVSE. DC PSC Order No. 19898, released April 12, 2019 (emphasis added) Under Offering 4, Pepco proposes to provide up to 500 residential customers a $500 rebate for the price and installation of a Smart Level II Charger. DOEE asserts that deployment of smart chargers can be left to the competitive market. It is not clear from Pepco’s filing why the rebate level was set at $500. While the switch to EVs aligns with the District’s environmental goals, Pepco should target rebates toward customer behavior that will benefit the operation of the distribution system. As part of its review, the Commission considered the recent Maryland Public Service Commission Order on EV programs.94 Specifically, the Maryland Commission set the rebate level to $300 for a smart charger, as there was testimony to suggest that this price was meant to capture the price difference between a non-smart charger and smart charger.95 Therefore, to gain greater clarity on the merits of a residential rebate program, and to ensure that any recommended rebate level aligns with the programs specific benefits, the Commission refers Offering 4, a fixed priced residential rebate, to the temporary TE Working Group for consideration. Pepco is directed to meet with Staff and other stakeholders in the TE Working Group to address stakeholders’ concerns within forty-five (45) days of the date of this Order and report back within 180 days of the date of this Order. Page 5 of 5 Office of the People’s Counsel Position on Pepco’s TE Offering 4 – Fixed Rebates for Residential Customers Installing Smart Level 2 Chargers The Office of the People’s Counsel (“OPC”) stands by its previous stated opinion of opposition regarding Pepco’s proposed Transportation Electrification Offering 4 – Fixed Rebates for Residential Customers Installing Smart Level 2 Chargers (“Offering 4”) for inclusion in the final report to the of the Transportation Electrification Working Group (“TEWG”) to the Public Service Commission of the District of Columbia (“PSC”). The TEWG has not arrived at a consensus regarding the merits of Offering 4. In OPC’s filed initial and reply comments in Formal Case 1130, OPC does not believe that Offering 4, as filed in Pepco’s Transportation Electrification Program Application (“TE Application”), is in the public’s interest nor provides the necessary ratepayer benefits to justify ratepayers funding said offering. OPC does not dispute that the District has an independent obligation to ensure infrastructure is present to support an all-electric future; however, this obligation must account for actual usage, system dynamics, be in the public interest and be just and reasonable. OPC has actively participated in the TEWG since its inception but does not believe that Pepco has provided any justification for Offering #4. In fact, OPC maintains that the same deficiencies that existed in Pepco’s TE filing still exist presently. As OPC stated previously in filed comments, there are certain Pepco EV activities that the Commission could designate as appropriate for ratepayers to participate in funding, which are “primary services” such as rate design and load management. Offering #4 is a rebate program exclusively designated for certain residential ratepayers and while laudable it provides no granular detail on load management, program benefits, nor system wide benefits as the Commission advised. OPC stands by its original position that Offering 4 lacks merits and should be rejected by the Commission as an unjust and unreasonable use of ratepayer funds. Appendix 6 Additional Comments - Ensuring Ratepayer protection for Residents of MDUs EVADC is deeply concerned that Offering 5 denies basic ratepayer protections for residents of MDUs. MDU residents should be able to charge their car by plugging into a submetered outlet tied to their existing Pepco account. A standard NEMA 5-20 outlet (on a 120V, 20A circuit, providing 1.92kW) is already standard for building exteriors and garages in the District. A typical EV can charge at a rate of 5-7 miles per hour from a 5-20 outlet, which is more than sufficient to recoup a resident’s daily commute. EV drivers welcome “Level 2” (240V, 40A or 32A circuit providing ~7kW) via NEMA 14-50 outlets, but recognize this places a far greater burden on the grid and the MDU’s existing amperage capacity. Because any given building’s electric panel will have a maximum amount of kW it can convey before requiring expensive upgrades, it is better to extend 1.92kW circuits with 5-20 outlets to more parking spaces as opposed to 7kW+ circuits hardwired into dedicated EVSEs for one or two parking spaces as Pepco’s Offering 5 currently proposes. There are a myriad of benefits to choosing submetered 5-20 outlets over hardwired, commercially networked EVSEs on 7kW+ circuits: • • • • • • • • • Expanding 5-20 outlets on 120V, 20A circuits is much less expensive than installing networked, hardwired EVSEs on 7kW+ circuits; For every-one parking space that would be served by a 7kW+ EVSE, four could be served by 1.92kW 5-20 outlets; MDU residents benefit from ratepayer protection and are not forced to enter into a commercial relationship with a networked EVSE operator; MDU residents have access to Standard Offer Service rates; MDU residents can use their own portable EVSE that came with their EV, and are not stranded if the third-party operator’s EVSE breaks down; MDU residents can power their EV with the same competitive power supplier they currently choose for their home service; By favoring 5-20 outlets over dedicated EVSEs with J1772 connectors, MDU residents have the flexibility to consider alternative electric personal mobility solutions, such as electric bikes and mopeds; Avoids complexity of residents sharing limited high-powered stations; MDU residents with EVs are not forced to give up privacy and data pursuant to private EVSE operators’ terms of use. ************************************************************************************* ABB commented that Level 1 charging poses a number of challenges as EVs reach a larger scale. Driver Experience - While Level 1 solutions might satisfy early adopters, it is far less appealing to mass consumers who want a simple, safe, and reliable charging experience—they don’t want to have to think about charging. Level 2 chargers are capable of being networked, which means they can be monitored for up time and reliability, they can provide live feedback to consumers via web-apps about their state of charge, and they can be upgraded and integrated into new programs and business models. With Smart Level 2, drivers can check on the charging status from their apartments (or anywhere with connectivity); this is not possible with unmanaged Level 1. 1 Further, as the capacity and range of car batteries continue to rise, Level 1 chargers will fall short of consumers charging expectations. For example, the total time to complete a full charge using Level 1 on a 60-kWh battery could take more than 40 hours. Level 2 charging provides confidence to ordinary consumers that the technology is working and is safe. Unmanaged Level 1 limits various business models for apartment owners and renters in the District. It excludes the option for 3rd party management, which may provide professional, seamless charging experience for an MDU’s residents and less complexity for their managers. These models can also be revenue- positive. The cost for “make – ready” such as a panel, circuits, conduit and copper – can be similar for Level 1 and Level 2, which limits cost savings for Level 1 in construction. In addition, utilities are routinely requiring smart Level 2 for demand response using Open Charge Point Protocol and open Automated Demand Response protocols, which are not possible with unmanaged Level 1 plugs. Networked chargers provide ratepayer benefits that Level 1 chargers cannot; for example, networked chargers provide utilities and commissions with visibility into the grid impacts, if any, of EV loads, enabling creation of EV specific rates, expanded customer offerings and choices, and more accurate distribution grid capacity planning. Avoiding costly system upgrades is only possible using smart Level 2 with energy management/ power sharing capabilities. 2 CERTIFICATE OF SERVICE I hereby certify that a copy of DC Transportation Electrification Working Group Report were served this January 29, 2020 on all parties in Formal Case No. 1130 and 1155 by electronic mail. Ms. Brinda Westbrook-Sedgwick Commission Secretary Public Service Commission of the District of Columbia 1325 G Street N.W. Suite 800 Washington, DC 20005 bwestbrook@psc.dc.gov Christopher Lipscombe, Esq. General Counsel Public Service Commission of the District of Columbia 1325 G Street N.W. Suite 800 Washington, DC 20005 clipscombe@psc.dc.gov Brian R. Caldwell Assistant Attorney General Public Advocacy Section Office of the Attorney General for D.C. 441 Fourth Street, N.W., Suite 600-S Washington, D.C. 20001 Brian.caldwell@dc.gov Meena Gowda, Esq. Deputy General Counsel DC Water and Sewer Authority 5000 Overlook Avenue S.W. Washington, DC 20032 Meena.gowda@dcwater.com Sandra Mattavous-Frye, Esq. Office of People ' s Counsel 1133 15th Street, N.W. Suite 500 Washington, DC 20005 smfrye@opc-dc.gov Kristi Singleton, Esq. Assistant General Counsel Real Prope1iy Division U.S. General Services Administration 1800 F Street, NW Room 2016 Washington, DC 20405 Kristi.sim!Ieton(@,gsa. gov Robert Cain, Esq. Washington Gas 1000 Maine Avenue, S.W., 6th Floor Washington, DC 20024 RCain@washgas.com D~mouneau