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1 BEFORE THE PUBLIC UTILITIES COMMISSION 2 OF THE STATE OF CALIFORNIA FILED 11/20/17 3 04:59 PM Application of San Diego Gas & Electric Application 17-01-020 Company (U 902E) for Approval of SB 350 (Filed January 20, 2017) Transportation Electrification Proposals. Application 17-01-021 And Related Matters. Application 17-01-022 4 5 OPENING BRIEF OF CALSTART ON THE STANDARD REVIEW 6 TRANSPORTATION ELECTRIFICATION PROPOSALS FROM SAN 7 DIEGO GAS & ELECTRIC, SOUTHERN CALIFORNIA EDISON, AND 8 PACIFIC GAS AND ELECTRIC 9 10 11 12 13 14 15 16 17 18 19 Ryan Schuchard 20 Policy Director 21 CALSTART 22 2600 Tenth Street, Suite 407 23 Berkeley, CA 94710 24 Tel: (626) 744-5606 25 November 17, 2017 E-mail: [email protected] 1 1 / 11 26 27 BEFORE THE PUBLIC UTILITIES COMMISSION 28 OF THE STATE OF CALIFORNIA 29 Application of San Diego Gas & Electric Application 17-01-020 Company (U 902E) for Approval of SB 350 (Filed January 20, 2017) Transportation Electrification Proposals. Application 17-01-021 And Related Matters. Application 17-01-022 30 31 OPENING BRIEF OF CALSTART ON THE STANDARD REVIEW 32 TRANSPORTATION ELECTRIFICATION PROPOSALS FROM SAN 33 DIEGO GAS & ELECTRIC, SOUTHERN CALIFORNIA EDISON, AND 34 PACIFIC GAS AND ELECTRIC 35 36 37 I. INTRODUCTION 38 In accordance with Rule 13.11 of the California Public Utilities Commission 39 (“Commission”) Rules of Practice and Procedure (“Rules”), and the April 13, 2017 “Scoping 40 Memo and Ruling of Assigned Commissioner and Administrative Law Judges,” CALSTART 41 submits this opening brief on the standard review proposals filed by the investor owned utilities 42 in A.17-01-020 et al. 43 CALSTART is a nonprofit organization that aims to accelerate the commercialization of 44 clean transportation technologies. CALSTART has over 175 organizational members including 45 vehicle and component manufacturers, transit agencies, goods movement operators, and other 46 commercial fleets. 47 Among CALSTART’s many activities, it leads the Electric Fleet Alliance (EFA), a 48 coalition of industry stakeholders who are seeking to deploy medium- and heavy- duty electric 49 vehicles. Members of the coalition include Anaheim Resort Transportation, Foothill Transit, the 2 2 / 11 50 San Diego Airport Parking Company, UPS, BYD, Efficient Drivetrains, Motiv Power Systems, 51 and Thor Trucks, in addition to Chanje, Clipper Creek, and Zenith Motors, three companies that 52 have joined since our filing on September 29. 53 In the following pages, we will refer to medium- and heavy- duty vehicles (MHDVs) and 54 medium- and heavy- duty electric vehicles (MHD EVs). This group is conventionally known as 55 Class 3-8 trucks, and includes on-road, off-road, people movement, goods movement, and 56 vocational work vehicles that have gross vehicle weight ratings (GVWR) of more than 10,000 57 lbs. 58 59 II. SCE AND PG&E MEDIUM AND HEAVY DUTY VEHICLE CHARGING 60 PROGRAMS 61 A. Introduction and SB 350 Transportation Electrification Policy, Goals and 62 Benefits 63 Testimony by CALSTART and other parties has established that significant large- 64 scale public investment in infrastructure and new rates that incentivize MHD EV growth in 65 California are needed now, without delay. 66 MHD EVs are currently on the road and available for purchase in California among 67 diverse classes and categories, as has been discussed in the proceeding and is further detailed in 68 the next section.1 A principal barrier to the widespread adoption of MHD EVs is their total cost 69 of ownership (TCO), which is comprised of the combination of vehicle, charging, and 70 operations-related costs. Currently, the TCO of MHDVs using diesel and natural gas tends to be 71 lower than for EVs on a per-mile basis, due in large part to fuel-related costs.2 72 Investor-owned utilities (IOUs), with authorization from the Commission, are in a 73 position to significantly resolve the high TCO of MHD EVs and hence promote their widespread 74 adoption by deploying publicly rate-based infrastructure and relatively beneficial rate packages 75 for vehicle charging. These types of investments and programs are needed for the success of, and 1 CALSTART (March 6, 2017). “Response of CALSTART in Support of the Application of Pacific Gas & Electric…” and CALSTART (March 6, 2017). “Response of CALSTART in Support of the Application of Southern California Edison…” 2 Ibid. 3 3 / 11 76 are supported by, public vehicle-based incentive funding programs, such as the Hybrid and Zero- 77 Emission Truck and Bus Voucher Incentive Project (HVIP), led by the California Air Resources 78 Board and administered by CALSTART. 79 The notion of “widespread adoption” of MHD EVs should be taken to mean that plug-in 80 electric drivetrains will be broadly available, sold, and deployed on the road in most or all sizes 81 and categories of MHDVs throughout the state, and that they are economically accessible to 82 public and private fleets, large and small. 83 The crucial widespread adoption of MHD EVs supports the core environmental benefits 84 of reducing greenhouse gas (GHG) emissions and petroleum use, and improving air quality.3 It 85 also serves to develop a new base of local manufacturing, jobs, and investments in California 86 that will strengthen the economy and reinforce the state’s position as a leader in clean 87 technology. This observation is made clear by the many California-based manufacturers and 88 suppliers who are members of CALSTART and the Electric Fleet Alliance, as well as who are 89 profiled in the next section. 90 91 B. Scope of Projects 92 It is evident that California’s MHD EV market is ready for PG&E and SCE’s 93 proposed infrastructure investments. Over the past few years, the battery technology industry 94 has made rapid advances that have given rise to market growth that was not widely predicted. 95 Class 8 transit has gone from being considered notable as a first point of entry for MHDV 96 technology to being a segment where electrification is gaining market share even faster than with 97 cars. As this has happened, the technologies and experiences associated with electric transit 98 buses have rapidly begun to be diffused into other MHDV categories. Just this week, Tesla 99 unveiled an all-electric Class 8 freight truck planned for production in 2019 that has 500 miles of 100 range and can climb major grades fully loaded at 60 mph (compared to 45-50 mph for more 101 conventional diesel trucks).4 3 CALSTART (August 1, 2017). “Opening Testimony of CALSTART on the Standard Review…” 4 See https://www.tesla.com/semi/ 4 4 / 11 102 In the cross-examination of PG&E’s David Sawaya by Clean Energy (September 25, 103 page 201, line 27 through page 204, line 16), Mr. Sawaya outlined examples of some such MHD 104 EVs that are available in California. A wider set of MHD EVs that are either currently available 105 in California or scheduled to be available by 2019 include the following: 106 Heavy Duty (GVWR 26,001+ lbs) 107 » Class 8 transit bus: BYD, Complete Coach Works, Gillig, GreenPower, New Flyer 108 Industries, Nova Bus, Proterra 109 » Class 8 refuse truck: BYD, Motiv Power Systems, Crane Carrier Company, Peterbilt 110 » Class 8 terminal truck: BYD, Hoist Liftruck, Kalmar, and Orange EV 111 » Class 7-8 school bus: Blue Bird, Lion, GreenPower, IC Bus, Thomas/Daimler, 112 » Class 7-8 drayage and local freight truck: BYD, Crane Carrier Company, Cummins, 113 Freightliner, Kenworth, Mack Trucks, Peterbilt, Tesla, and Thor 114 115 Medium Duty (GVWR 10,001-26,000 lbs) 116 » Class 5-6 work trucks and buses: Amp Workhorse, BYD, Morgan Olson, and Zenith 117 Motors 118 » Class 4 shuttle and school bus: Ameritrans Bus, Motiv Power Systems, Starcraft Bus, 119 Phoenix Motorcars, Trans Tech Bus 120 » Class 4 work truck and delivery van: BYD, California Truck Equipment Company, 121 Chanje, Ford, FUSO 122 » Class 3 cargo and shuttle van: Zenith Mentors 123 » Class 3 utility truck: Bollinger 124 125 Many of the companies listed above are supported by California-based electric 126 powertrain and components suppliers including BAE Systems, Efficient Drivetrains (supplying 127 Blue Bird, Morgan Olson and Thomas/Daimler), Motiv Power Systems (supplying Ameritrans 128 Bus, Crane Carrier Company, Ford, Morgan Olson, Starcraft Bus, and Trans Tech Bus) and 129 TransPower (supplying Peterbilt). 130 The above list represents a very meaningful share of all MHDV categories. Perhaps more 131 significant, conventional large truck manufacturers such as Daimler, Mack, and Peterbilt are 132 investing in electric drivetrain capability by piloting and working closely with advanced 5 5 / 11 133 technology partners including the ones above. We expect that as infrastructure and attractive 134 rates for MHD charging become available, these types of companies, which serve the majority of 135 the truck market, could potentially be in a position to diffuse EVs within their portfolios and 136 provide dealership and service programs that reach mass markets. 137 The aforementioned vehicles focus on class 3-8 trucks and buses, but it is also significant 138 that electrification is happening in surrounding vehicle categories as well. For example, electric 139 trucks are being introduced in the “heavier light duty” classes, such as all-electric pickups by 140 Workhorse and Lightning Electric. Also, CALSTART and its partners are now working to 141 deploy light electric aircraft (Pipistrel) for full service operation in California. 142 143 C. Implementation of Projects 144 145 1. Program Design 146 It is evident that the full size and duration of PG&E and SCE’s proposed 147 infrastructure investment programs are needed, and we recommend that they be fully 148 authorized.
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