LCFS Electricity Workgroup Meeting

1. LCFS Electricity Workgroup Meeting Wednesday, July 14, 2010

2. LCFS Regulated Partyfor Electricity • The electricity service provider unless one of the following exists: • Bundled service provider who provides access to vehicle charging under contract with vehicle owner/operator • Owner of charging equipment, provided a contract with service provider exists • Owner of home with charging equipment, provided contract with service provider exists

3. Regulated Party Example • A utility installs EV charging equipment at a residence. • The utility is eligible to receive LCFS credits for the electricity supplied as a transportation fuel.

4. Regulated Party Example • Macy’s offers EV charging to customers through charging equipment they have installed in their parking lot. • The local utility is eligible to receive LCFS credits for electricity fuel delivered unless… • Macy’s and the utility have agreed through a written contract that Macy’s will receive LCFS credits.

5. Regulated Party Example • A parking lot owner installs EV charging equipment in the lot for customers. • The local utility is eligible to receive LCFS credits for electricity fuel delivered unless… • The parking lot owners and the utility have agreed through a written contract that the lot owner will receive LCFS credits.

6. Regulated Party Example • A third party offers EV charging, through a network of charging stations placed in public places, to customers who pay for ongoing access to the network. The network may include standard chargers, fast chargers, or battery swap stations. • The third party providers are eligible to receive LCFS credits.

7. Reasons for Third Party Default • Third party bundled service providers are eligible to receive credits by default. • Bundled service providers install charging infrastructure and sell fuel. • Similar to regulated party for CNG – parties who establish infrastructure may receive credits. • Charging infrastructure necessary for the success of the LCFS.

8. Issues • “(B) The electricity services supplier, where ”electricity services supplier” means any person or entity that provides bundled charging infrastructure and other electric transportation services and provides access to vehicle charging under contract with the vehicle owner or operator;” • Should regulation language be revised to distinguish between one time infrastructure install vs. ongoing access to charging? • Suggested regulation language?

9. Issues • “(D) The owner of a home with electric vehicle-charging equipment, provided there is a contract between the homeowner and provider of electricity services specifying that the homeowner may acquire credits.” • Should regulation language be revised to clarify that the contract is between the utility and the homeowner rather than between a third party provider and the homeowner? • Suggested regulation language?

10. Issues • Cogen electricity generation –company who generates electricity, supplies to grid, and provides vehicle charging wants to generate LCFS credits • Need link (contract) to vehicle charging • Would require regulation change • Suggested regulation language?

11. CPUC Alternative Fueled Vehicle Proceeding Senate Bill 626 (Kehoe, 2009) • Requires the PUC to develop rules to overcome barriers to the widespread deployment and use of PHEVs and BEVs by July, 2011 • (A) Electrical infrastructure impacts, the role and development of public charging infrastructure • (B) Impact on grid stability and integration of renewable energy • (C) Technological advances • (D) Code and Permit Requirements • (E) Impact of PEVs on AB 32 goal attainment, RPS, and what steps should be taken to address emissions shifting from transportation to electricity sector

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

13. CPUC Alternative Fueled Vehicle ProceedingJune 29, 2010 - Revised PD on Phase I • Ownership or operation of a facility that sells charging services as motor vehicle fuel does not make the person/corporation a public utility - PU C. S 216 and S 218 • PU Code S 740.2 grants the PUC authority to develop rules to avoid adverse grid impacts and to attain GHG and Renewable goals • Additional PUC Authority: • Procurement authority (Inc. RPS, RA, EPS) • Notification and Application requirements for new service • Rule 3 – existing customer changes to electrical load notice • Tariff terms of service • Dist. Line upgrades (Rules 15 & 16) • Interconnection Rules (21) • Electric vehicle charging service provider will generally be an end-use customer • Net costs (Impacts and benefits) recovered via D,T (potentially G) cost component of tariff (PU Code S 454) • Charges can include volumetric (kwh), demand (based on time), and fixed charges • If IOU provides electric vehicle charging services, provision of such services will not affect the utility’s status • Policy Context: Widespread use of PEVs complements CA efforts to reduce GHG, integrate intermittent renewables, reduce petroleum consumption • SB 1435 (Padilla)

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

15. Metering Requirements/Estimating LCFS Electricity Credits • Direct metering required if installed • Direct metering required in all cases January 1, 2015 and thereafter • An estimation method may be used prior to 2015 ( if no meter installed) provided the method has been approved by ARB • We encourage regulated parties to begin the process of method approval prior to November 2010.

16. Nonroad Electricity Credits • Examined expected nonroad population of electric vehicles • Examined potential interaction of LCFS nonroad credits with other programs • LCFS implementation issues have pushed nonroad credit work to a future date

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

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

19. Contact Information • Carolyn Lozo clozo@arb.ca.gov (916) 355-1860 • Renee Littaua, Manager, Fuels Section rlittaua@arb.ca.gov (916) 322-6019