Today, the NCSEA regulatory team submitted a Proposed Order in the docket for Duke Energy’s Application for Approval of Proposed Electric Transportation Pilot. As a reminder, Duke Energy originally filed their Application in March 2019, and NCSEA filed Initial Comments in July. You can read a summary of our Initial Comments on our blog.
While the full text of our Proposed Order can be found on the North Carolina Utilities Commission (NCUC) website, we have highlighted the key takeaways below. The recommendations made by NCSEA in the Proposed Order are largely reflective of those from our July Initial Comments.
In part, NCSEA recommends that:
The residential Electric Vehicle (EV) charging rebate proposal, the fleet EV charging rebate proposal, the EV school bus charging rebate proposal, and the EV transit bus charging proposal be approved with modifications. Overall, NCSEA finds the rebates proposed in the Application to provide sensible incentives for different rate classes. However, NCSEA does recommend adjustments to rebate amounts. With the residential EV rebates, NCSEA recommends increasing the number of rebate awards available and decreasing the monetary amount of rebates. For fleet EV rebates, NCSEA recommends that a stakeholder process be used to determine the number of rebates to be used for commercial and industrial fleet vehicles. For EV school and transit bus rebates, NCSEA does not support a first-come, first-served system and recommends that a stakeholder process be used to determine the best method rebate allocation.
The public charging programs proposed in the Application are rejected and Duke Energy Carolinas and Duke Energy Progress (collectively, “Duke”) should propose a make-ready program for public EV charging. Briefly, a make-ready program would provide electrical service to the point where a charging station could be installed. This would prevent Duke from maintaining an advantage over third-party market participants and would not cause as many costs to ratepayers.
Duke should propose EV-specific rates for residential and non-residential customers in their general rate cases. Duke’s Application does not propose to offer any EV-specific rate designs. These types of rates can encourage EV owners to charge their vehicles at times that are beneficial to the grid, which helps to mitigate increases in peak demand. As such, NCSEA recommends that EV-specific rates be proposed in their ongoing general rate cases.
Duke must coordinate a stakeholder process to develop metrics by which to measure their Pilot. Duke has not properly included objectives, metrics, goals, or other means of evaluating the success of their Application. In particular, NCSEA and other intervenors recommend that Duke be required to identify what success looks like to different groups, and how often those metrics and the underlying data should be compared.
NCSEA is wholly supportive of the deployment of EVs and EV charging infrastructure in North Carolina. However, we believe that these investments mustbe made in a way that supports all market participants, and we are eager to work with Duke and other stakeholders to ensure that this goal is met.
If you want to be among the first to hear updates from NCSEA regarding EVs and other clean energy technologies, consider becoming an NCSEA Member. NCSEA convenes our Business Members regularly in sector group meetings to dialogue on issues important to their sector, such as this Proposed Order. Our next Electric Vehicle Sector Group Meeting is Wednesday, March 3. Reach out to Matt Abele today to join NCSEA and be part of the conversation.