Discussion
of Issues
Issue 1:
Should the Commission approve TECO’s proposed EV
charging pilot program?
Recommendation:
Yes. The Commission should approve TECO’s proposed
EV Pilot effective the date of the Commission’s vote. Capital expenditures
should be capped at $2 million for the life of the program, and operation and
maintenance (O&M) costs be limited to $100,000 annually for years two
through four of the Pilot. TECO should file annual reports, with the first
report due 12 months from the date the final order is issued approving the Pilot.
The annual reports should provide comprehensive data for each market segment,
including but not limited to the number of charging sessions, time of use,
charger utilization by geographic location, costs to EV drivers, installation
costs, load profiles, ongoing O&M expense, and Site Host or driver
feedback. Staff recommends that the Pilot commence the date of the commission’s
vote and terminate four years from the date the final order is issued approving
the Pilot, unless TECO files a petition to extend, modify, or permanently
implement the Pilot through a tariff revision. (Doehling, Mouring)
Staff Analysis:
Within TECO’s service territory, there are currently
340 non-utility owned Ports. Of these 340 Ports, 63 of them are Direct Current
Fast Charging (DCFC) Ports. Non-utility owned Ports take service from TECO at
the applicable retail rate. In addition to the non-utility owned Ports, TECO
currently owns and operates 45 Ports, one of which is a DCFC Port. These
TECO-owned Ports are not for public use and are unrelated to the proposed
Pilot.
Overview of Proposed Pilot
Under the proposed Pilot, TECO will purchase, install,
own, and maintain approximately 200 EV Ports within its service territory. Four
of the Ports will be DCFC and the rest of the Ports will be Level 2. A
limited number of Level 2 Ports will also be installed at each DCFC location to
provide redundancy.
As displayed in Table 1-1, two
hundred Level 2 Ports will be deployed at customer locations across five
different market segments: (1) workplaces, (2) public/retail, (3) multi-unit
dwellings, (4) income qualified,
and (5) government. TECO will partner with the Site Hosts to coordinate
installation, operation, and maintenance of the Ports. TECO asserted the four
DCFC Port locations will be carefully selected to help ensure 24/7
accessibility, proximity to local travel corridors frequently used by EV
drivers, and the opportunity to serve multiple market segments.
Table 1-1
Level 2 Ports by Market
Segment
|
Market Segment
|
Ports
|
|
Workplace
|
70
|
|
Public/Retail
|
70
|
|
Multi-unit Dwelling
|
20
|
|
Income Qualified
|
20
|
|
Government
|
20
|
In its petition, TECO stated it will bill the Site Host
for electricity consumed by the Ports at the appropriate tariff rate. Site
Hosts will then have the option of two different price structures for billing
EV drivers. The first option is providing no-cost access to the Ports. The
second option is a per kilowatt-hour (kWh) fee equal to TECO’s General Service
rate. For the second option, Site Hosts may include any network or transaction
fees, as well as any applicable taxes. Staff recommends that TECO require Site
Hosts to clearly identify all fees that will be incurred by EV drivers using
the Ports.
The proposed length of the Pilot is four years, commencing
after all Ports are installed. TECO stated it aspires to have all Ports
deployed by December 31, 2021. During the third year of the Pilot, TECO
committed that it will provide the Commission a final report of all data
collected and document the appropriateness to either extend the Pilot, make
charging a permanent tariff, or terminate the Pilot. However, staff recommends that the Pilot commence the date of the
commission’s vote and terminate four years from the date the final order is
issued approving the Pilot, unless TECO files a petition to extend, modify, or
permanently implement the Pilot through a tariff revision.
In the event the Pilot is terminated, Site Hosts will have
the opportunity to acquire all the Ports at their site for $1. All ongoing
costs for the Ports will then become the responsibility of the Site Host.
However, if the Site Host does not wish to acquire the Ports or for any other
reason no longer wishes to continue participating in the Pilot, TECO asserted
it would work with the Site Host, adjacent businesses, property managers, or
any other party in an effort to keep the Ports installed. If the Ports still
required removal, TECO stated it would work with the Site Host to return the
site to its original condition, at no cost to the Site Host.
Pilot Objectives
TECO lists five goals of the Pilot: (1) support utility
system planning, (2) ensure grid reliability, (3) develop TECO’s competencies
to serve the EV market, (4) meet customer needs in identified key markets, and (5)
inform/develop TECO’s long-term strategy. TECO also stated the Pilot supports
state and local initiatives to prepare for an electrified transportation sector,
and will provide TECO with a better understanding of EV interaction with the
local grid through the collection of Port and utility electric meter data.
TECO asserts that the Pilot will
achieve their proposed goal of supporting utility system planning by collecting
a variety of data points. The Utility claims these data points, along with any
additional data made available based on capabilities of the hardware and
software to be installed, will help it better understand impacts from EV
charging on the grid. TECO expects to evaluate these impacts at various levels,
including at the meter and transformer. TECO stated that modeling actual data
collected in a way that reflects increased utilization of charging
infrastructure due to widespread EV adoption, will allow the Utility to
understand any potential system planning impacts.
TECO expects that EVs will continue to increase in market
share for the foreseeable future. For this reason, TECO asserts that it is
crucial to understand what impacts at scale EVs will have on the local grid.
The compilation of the data expected to be collected through the Pilot will help
TECO in grid reliability planning and developing its long-term strategy.
TECO asserts the Pilot will develop its competencies to
serve the EV market in three ways. First, TECO’s competencies will be developed
through its direct involvement in the design, permitting, construction, and
maintenance of the Port. Second, the deployment costs, Port data collection, and
maintenance logs will provide information on unknown gaps where additional
focus is warranted. Last, a first-hand understanding of how EV drivers interact
with the local grid will assist with planning for maintaining grid reliability.
The Utility also expects the Pilot will serve to meet customer
needs in identified key markets. TECO anticipates that each market segment
identified within the Pilot will have unique challenges and opportunities in
how the EV market is served. The Utility believes that by deploying Ports
within each of the identified market segments, customers will be exposed to
opportunities for installing additional charging stations through visibility of
the Ports installed, word of mouth, or direct interaction with TECO
representatives regarding the Pilot.
As an alternative to the proposed Pilot, TECO considered
the use of pre-existing sources of data.
However, TECO believes the greatest benefit to the Utility, and ultimately the
customer, is to not only have first-hand knowledge of the complete installation
process but also have Utility specific data to support analysis and planning
for the local grid. Consequently, the Utility also stated it did not consider
contracting a third party to conduct a study for the purpose of achieving the
Pilot’s stated objectives.
Pilot Costs
The Utility will pay up to $5,000 per Level 2 Port towards
the cost of installation for workplaces, public/retail, and multi-unit
dwellings, and the full cost of installation for income qualified sites and
government locations. While TECO is only partially covering the installation
cost for workplaces, public/retail, and multi-unit dwellings, TECO will still
retain ownership of the Ports. Due to the limited number of DCFC Ports, along
with the expected variability of DCFC installation costs, TECO expects to cover
the full cost for DCFC locations.
The estimated capital cost for
the Pilot is $2 million. The total capital costs broken out by market segment
can be seen in Table 1-2, including program management and contingency costs. This
equates to an estimated total cost per port of $7,143 for workplace and
public/retail sites, $7,500 for multi-unit dwelling sites, $13,750 for each
income qualified site and government location, and $75,000 for each DCFC site.
For the sites where TECO is contributing a maximum of
$5,000, the estimated Utility contribution to installation costs are 70 percent
of the total costs. The remaining 30 percent of the total cost was budgeted for
program management and contingency costs. However, TECO was unable to provide
the estimated Utility contribution to installation costs for the income qualified,
government, or DCFC sites.
Assuming TECO budgeted 70 percent of the total cost for installation for these
sites as well, this equates to an estimated Utility installation cost per port
of $9,625 for both income qualified and government sites, and $52,500 for each
DCFC site. Since TECO is unable to provide a more accurate estimate of Utility
contribution for installation costs at this time, staff recommends that capital
expenditures be capped at $2 million for the life of the program.
Table 1-2
Estimated Pilot Costs
|
Market Segment
|
Ports
|
Total Cost
|
Total Pilot
Cost/Port
|
Estimated Utility
Installation Cost
|
Estimated Utility Installation
Cost/Port
|
|
Workplace
|
70
|
$500,000
|
$7,143
|
$350,000
|
$5,000
|
|
Public/Retail
|
70
|
$500,000
|
$7,143
|
$350,000
|
$5,000
|
|
Multi-unit Dwelling
|
20
|
$150,000
|
$7,500
|
$100,000
|
$5,000
|
|
Income Qualified
|
20
|
$275,000
|
$13,750
|
$192,500*
|
$9,625
|
|
Government
|
20
|
$275,000
|
$13,750
|
$192,500*
|
$9,625
|
|
DCFC**
|
4
|
$300,000
|
$75,000
|
$210,000*
|
$52,500
|
* Installation
costs are assumed to be 70 percent of the total costs.
** The cost per port for
DCFC sites includes the supplemental Level 2 Ports.
After year one of the Pilot, O&M costs are estimated
at $100,000 annually. TECO estimated O&M costs as 5 percent of the total
capital cost. Final costs will be determined through a combination of future
vendor request for proposals and required host site evaluations to determine
installation requirements. For this reason, staff recommends that O&M costs
be limited to $100,000 annually for years two through four of the Pilot.
Accounting Treatment
TECO has
requested that the capital investment, along with administration and operation
and maintenance costs associated with the Pilot, be recorded above-the-line,
and be approved for recovery through base rates. As stated above, if the
Commission terminates the Pilot, Site Hosts will be given the option to
purchase the Ports installed at their sites for a nominal fee of $1. Under this
scenario, the losses generated by selling the Ports below the unrecovered net
book value would also be recorded above-the-line in Account 421.2 Loss on
Disposition of Property. Under this scenario, any resulting net losses would be
recovered through base rates from the general body of customers. TECO has
stated that it believes this buyout option provides certainty and transparency
of future potential costs to prospective Site Hosts which it believes is
crucial to encourage participation in the EV Pilot. The Utility has also noted
that the proposed buyout option would help to avoid potential removal costs and
ensure that the Ports remain available to drivers in furtherance of Section
339.287, F.S. TECO has estimated total program costs, absent any offsetting incremental
revenue attributable to the Pilot or consideration of the recovery of any
potential losses from the sale of the Ports at the end of the program, would
equate to approximately $0.03 per 1,000 kWh residential bill.
Reporting Requirements
TECO stated it will provide annual reports until the
completion of the Pilot. Staff recommends that during the Pilot period, TECO
should file annual reports, with the first report due 12 months from the date the
final order is issued approving the Pilot. The annual reports should provide
comprehensive data for each market segment, including but not limited to the number
of charging sessions, time of use, charger utilization by geographic location,
costs to EV drivers, installation costs, load profiles, ongoing O&M expense,
and Site Host or driver feedback.
Conclusion
Based on the above, staff
recommends that the Commission approve TECO’s proposed EV Pilot effective the
date of the Commission vote. Capital expenditures should be capped at $2
million for the life of the program, and O&M costs be limited to $100,000
annually for years two through four of the Pilot. TECO should file annual
reports, with the first report due 12 months from the date the final order is
issued approving the Pilot. The annual reports should provide comprehensive
data for each market segment, including but not limited to the number of
charging sessions, time of use, charger utilization by geographic location,
costs to EV drivers, installation costs, load profiles, ongoing O&M
expense, and Site Host or driver feedback. Staff
recommends that the Pilot terminate four years from the date the final order is
issued approving the Pilot, unless TECO files a petition to extend, modify, or
permanently implement the Pilot through a tariff revision.
Issue 2:
Should this docket be closed?
Recommendation:
Yes. If no person whose substantial interests are
affected by the proposed agency action files a protest within 21 days of the
issuance of the order, this docket should be closed upon the issuance of a
consummating order. (Stiller)
Staff Analysis:
At the conclusion of the protest period, if no
protest is filed this docket should be closed upon the issuance of a
consummating order.
