NCSEA Files Initial Comments in EV Pilot Docket

Last Friday, the NCSEA regulatory team submitted Initial Comments on Duke Energy’s Application for Approval of Proposed Electric Transportation Pilot. Duke Energy originally filed their Application in late March, and the North Carolina Utilities Commission (NCUC) called on intervenors to submit comments by July 5.  

In their Application, Duke Energy proposed an Electric Transportation Pilot with a number of goals including but not limited to: 

• More comprehensively understand the behavior of electric vehicle (EV) charging and impacts to the grid when charging multiple types of EV’s; 
• Create a foundation of fast charging infrastructure across Duke’s service territories in North Carolina; 
• Support electrification projects that benefit all customers, including low- or moderate-income customers and non-EV owners; and
• Create a competitive market for EV charging services while ensuring customer choice. 

NCSEA wholly supports the deployment of EVs and EV charging infrastructure but believes that these investments must be made in a way that supports all market participants. Our Initial Comments reflect this enthusiasm as well as our concerns about the proposed Pilot as submitted. NCSEA believes that the NCUC should deny parts of Duke Energy’s Application and approve others subject to modifications, as well as open a stand-alone proceeding to examine its goals for EV charging infrastructure deployment. 

The main points of concern for NCSEA outlined in our filing center around Duke Energy’s request to make capital investments in EV charging infrastructure. Duke Energy failed to provide evidence to support their claims that the Pilot programs “would install a foundational level of DC fast charging (DCFC) stations in North Carolina” while “leaving ample room for third-party investment.” Our concerns include: 

• Duke Energy provided inconsistent information in discovery—telling NCSEA that 455 plugs are necessary to support 80,000 EVs and telling the Public Staff that 455 stations are necessary; 
• The assumptions Duke Energy made in calculating the percentage of drivers with access to home charging—changing the default of 80-100 percent of customers having home access to 20 percent of customers not having home access; 
• The speed that the market is changing—when Duke Energy filed their Application there were only 86 DCFC plugs available and as of July 2, there were 144; 
• Duke Energy did not include Tesla charging stations in its examination of the size of DCFC market—Tesla sold more EVs than all other EV manufacturers combined in 2018; and 
• After the Pilot, only one-third of the DCFC market would remain for third-party investment. 

In our Initial Comments, NCSEA also expressed concern over siting and how Duke Energy would (or would not) use its knowledge of the grid to site charging infrastructure and ensure that underserved communities have access to charging infrastructure. Duke Energy’s knowledge of the grid would give it an unfair advantage over other market participants who do not have access to that same information. This knowledge will allow Duke Energy to capitalize, and effectively monopolize, the market for charging infrastructure. NCSEA fears that Duke Energy could use this advantage to install charging infrastructure at the locations that do not require expensive upgrades and leave those that require expensive upgrades for potential third-party market participants.  

Rather than approve Duke Energy to invest capital in EV charging stations, as requested in their Application, NCSEA requests that the NCUC direct Duke Energy to create and file a make-ready program. Briefly, a make-ready program would provide electrical service to the point where a charging station could be installed, and would prevent Duke from maintaining an advantage over third-party market participants. 

Upon request from NCSEA for the scoring criteria for Duke Energy owned chargers, Duke Energy failed to provide enough evidence that their three metrics (seen in Attachment 8 of NCSEA’s filing) would ensure access to charging infrastructure for underserved communities. NCSEA recommends that the NCUC be required to work with stakeholders to develop a more comprehensive set of scoring criteria. 

Though NCSEA has concerns about the Pilot, outlined in part here and in our Comments in full, we would not be opposed to the rebates that Duke Energy proposed in their Application with a few modifications including: 

• Lowering the rebate in the Residential EV Charging Program from $1,000 to $500 to double participation and remain consistent with other rebates offered by Duke Energy; 
• Creating EV-specific rate tariffs in Duke Energy’s next general rate case; and 
• Creating scoring criteria—beyond first-come, first-served—for receiving a rebate under both the EV School Bus Charging Program and the EV Transit Bus Charging Station Program.  

NCSEA is eager to work with Duke Energy and other stakeholders to ensure that the approved EV Pilot is beneficial for all market participants. To that end, we request that the NCUC deny Duke Energy’s request to make capital investments in charging infrastructure; approve (with modifications) the rebates proposed in the Application; and open a generic docket on EV charging.  

The NCSEA regulatory team will continue monitoring this docket and keep our members informed of updates. For first access to updates, be sure to become an NCSEA Business Member.