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A. 19-10-012 SBUA Opening Testimony

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A. 19-10-012 SBUA Opening Testimony BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U-902-E) to Extend and Modify Application 19-10-012 The Power Your Drive Pilot Approved (Issued October 28, 2019) By Decision 16-01-045. DIRECT TESTIMONY OF PAUL L. CHERNICK & JOHN WILSON ON BEHALF OF SMALL BUSINESS UTILITY ADVOCATES Jennifer L. Weberski Litigation Supervisor Small Business Utility Advocates 548 Market Street, Suite 11200 San Francisco, CA 94104 Telephone: (703) 489-2924 Email: [email protected] May 18, 2020 TABLE OF CONTENTS I. Identification & Qualifications ....................................................................... 1 II. Introduction .................................................................................................... 3 III. Budget Controls. ............................................................................................. 5 IV. Utility ownership of EVSE. .......................................................................... 12 V. Reporting Requirements, Including EM&V. ............................................... 19 VI. Outreach to Small Businesses. ..................................................................... 25 ATTACHMENTS Attachment - 1 Qualifications of Paul Chernick Attachment - 2 Qualifications of John D. Wilson Attachment - 3 California Energy Commission, Final 2019 Integrated Energy Policy Report, CEC-100- 2019-001-CMF (January 2020) Direct Testimony of Chernick and Wilson • Application 19-10-012 • May 18, 2020 Page i 1 I. Identification & Qualifications 2 Q: Mr. Chernick, please state your name, occupation, and business address. 3 A: My name is Paul L. Chernick. I am the president of Resource Insight, Inc., 5 4 Water St., Arlington, Massachusetts. 5 Q: Summarize your professional education and experience. 6 A: I received a Bachelor of Science degree from the Massachusetts Institute of 7 Technology in June 1974 from the Civil Engineering Department, and a 8 Master of Science degree from the Massachusetts Institute of Technology in 9 February 1978 in technology and policy. 10 I was a utility analyst for the Massachusetts Attorney General for more 11 than three years, and was involved in numerous aspects of utility rate design, 12 costing, load forecasting, and the evaluation of power supply options. Since 13 1981, I have been a consultant in utility regulation and planning, first as a 14 research associate at Analysis and Inference, after 1986 as president of PLC, 15 Inc., and in my current position at Resource Insight. In these capacities, I have 16 advised a variety of clients on utility matters. 17 My work has considered, among other things, the cost-effectiveness of 18 prospective new electric generation plants and transmission lines, conservation 19 program design, estimation of avoided costs, the valuation of environmental 20 externalities from energy production and use, allocation of costs of service 21 between rate classes and jurisdictions, design of retail and wholesale rates, and 22 performance-based ratemaking and cost recovery in restructured gas and 23 electric industries. My professional qualifications are further summarized in 24 Attachment-1. Direct Testimony of Chernick and Wilson • Application 19-10-012 • May 18, 2020 Page 1 1 Q: Have you testified previously in utility proceedings? 2 A: Yes. I have testified over three hundred and fifty times on utility issues before 3 various regulatory, legislative, and judicial bodies, including utility regulators 4 in thirty-seven states and six Canadian provinces, and three U.S. federal 5 agencies. This previous testimony has included planning and ratemaking for 6 distributed resources, distributed resource planning, the benefits of load 7 reduction on the distribution and transmission systems, utility planning, 8 marginal costs, and related issues. 9 I have filed testimony in five California PUC proceedings since June 10 2018. 11 Q: Mr. Wilson, please state your name, occupation, and business 12 address. 13 A: I am John D. Wilson. I am the research director of Resource Insight, Inc., 5 14 Water St., Arlington, Massachusetts. 15 Q: Summarize your professional education and experience. 16 A: I received a BA degree from Rice University in 1990, with majors in physics 17 and history, and an MPP degree from the Harvard Kennedy School of 18 Government with an emphasis in energy and environmental policy, and 19 economic and analytic methods. 20 I was deputy director of regulatory policy at the Southern Alliance for 21 Clean Energy for more than twelve years, where I was the senior staff member 22 responsible for SACE’s utility regulatory research and advocacy, as well as 23 energy resource analysis. I engaged with southeastern utilities through 24 regulatory proceedings, formal workgroups, informal consultations, and 25 research-driven advocacy. Direct Testimony of Chernick and Wilson • Application 19-10-012 • May 18, 2020 Page 2 1 My work has considered, among other things, the cost-effectiveness of 2 prospective new electric generation plants and transmission lines, retrospec- 3 tive review of generation-planning decisions, conservation program design, 4 ratemaking and cost recovery for utility efficiency programs, allocation of 5 costs of service between rate classes and jurisdictions, design of retail rates, 6 and performance-based ratemaking for electric utilities. 7 My professional qualifications are further summarized in Attachment-2. 8 Q: Have you testified previously in utility proceedings? 9 A: Yes. I have testified more than a dozen times before utility regulators in the 10 Southeast U.S. and Nova Scotia, and appeared numerous additional times 11 before various regulatory and legislative bodies. 12 II. Introduction 13 Q: On whose behalf are you testifying? 14 A: We are testifying on behalf of Small Business Utility Advocates. 15 Q: What is the scope of your testimony? 16 A: We review the application of San Diego Gas & Electric (SDG&E or the 17 Company) for the Power Your Drive Extension. 18 Q: What issues do you address? 19 A: We address three aspects of SDG&E’s proposed extension: 20 • Budget controls. 21 • Ensuring that utility-installed chargers advance California’s goal for 22 electric vehicles. 23 • Outreach to small business customers. Direct Testimony of Chernick and Wilson • Application 19-10-012 • May 18, 2020 Page 3 1 Our focus is primarily on workplace charging, although some of our comments 2 address multi-unit dwellings (MUDs) and disadvantaged communities 3 (DACs). 4 Q: What are your conclusions regarding the SDG&E application? 5 A: SDG&E’s Power Your Drive (PYD) extension addresses a well-established 6 market need to achieve California’s electric transportation goals. Overall, the 7 PYD pilot appears to have achieved significant learning with respect to site 8 host engagement and the construction process. 9 The overall objective of PYD and other transportation electrification 10 programs is to transform the transportation market by reducing the barriers to 11 EV ownership. As SDG&E states, the availability of chargers “will send a 12 signal to drivers that owning and operating an EV is within reach.”1 13 While SDG&E makes a strong case that it has succeeded in deploying 14 over 3,000 charging ports and implementing an innovative Vehicle Grid 15 Integrated rate (“VGI rate”), it is less certain whether the “signal to drivers” 16 has been successfully received. We believe that some modest adjustments to 17 SDG&E’s program could strengthen that signal, and better measure the 18 response. These improvements would expand the information that can be 19 learned from the pilot and better position SDG&E to develop a broader 20 transportation electrification program. 21 Q: What do you recommend? 22 A: In order to strengthen the “signal to drivers,” we recommend approaches that 23 would stretch the program budget further, by limiting the cost per port and 24 increasing customer cost participation. We also suggest that SDG&E strive 1 SDG&E, Application Ch. 1, p. BAS-5 at 16-17. Direct Testimony of Chernick and Wilson • Application 19-10-012 • May 18, 2020 Page 4 1 towards limiting the cost based on the number of drivers served who do not 2 have alternative regular access to charging facilities, as well as the number of 3 new EVs acquired due to the additional charging facilities. SDG&E does not 4 currently have the necessary data to associate drivers or EV purchases with 5 specific charging facilities; it is timely for SDG&E to prepare for those 6 analyses. 7 In order to better measure the effectiveness of the charging-access signal, 8 we recommend several steps: 9 • Consider expanding utility ownership of electric vehicle service 10 equipment (EVSE), rather than shifting to make-ready only at 11 workplaces. 12 • Enhance evaluation, measurement and verification (EM&V) with a third- 13 party report, similar to those conducted for energy efficiency programs. 14 • Increase the focus of the program (and EM&V) reporting requirements 15 on increasing EV adoption rates and supporting drivers “who otherwise 16 might not have access to regular charging facilities.”2 17 • Enhance the outreach strategy to address market barriers faced by small 18 businesses. 19 III. Budget Controls. 20 Q: What is SDG&E’s budget for the Power Your Drive (PYD) extension? 21 A: SDG&E proposes $58.4 million in total capital and O&M expenditures to 22 install approximately 2,000 ports at 200 sites.3 Because SDG&E is proposing 2 SDG&E, Application Ch. 1, p. BAS-10 at 1-2. 3 SDG&E,
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