Reply comments regarding plug-in electric vehicles due by Aug. 11 in Rhode Island

Written reply comments in response to stakeholder comments on plug-in electric vehicles (PEVs) are due by Aug. 11, the Rhode Island Public Utilities Commission, Division of Public Utilities and Carriers, and Office of Energy Resources said on July 31.

Following a May 31 “Beneficial Electrification Technical Session,” that focused on PEVs, stakeholders were invited – in a notice of inquiry that was released on June 14 – to submit comments in response to the discussion and provide input on a series of questions regarding beneficial electrification, the commission said.

Nine entities provided written comments in response to that notice of inquiry, including ChargePoint, National Grid, Newport Solar, and the Sierra Club.

Over the next month, the “Power Sector Transformation” team will continue to develop a work product focused on important issues and recommendations for electric vehicles (EVs), the commission added. To support that work, as well as further workshops regarding EVs and heating later this summer, stakeholders are invited to submit written reply comments to the nine entities’ responses, the commission said. While replies to all topics addressed in the comments are welcome, the commission said that it has specific interest in further thoughts regarding the role of the utility in the adoption of EVs and the goals of an EV program.


In its comments, ChargePoint, which manufacturers EV charging equipment and services, said that it believes that there is a vital role for utilities in supporting increased EV adoption and that the right program design can encourage the installation of more charging stations around the state.

There are ratepayer and environmental benefits associated with increased EV adoption and managing the associated EV load on the grid, including downward pressure on rates from increased throughput associated with EV charging, balancing load with solar and other intermittent renewable energy on the grid, and cleaner air from fuel switching, especially in high traffic areas, ChargePoint said.

Additional ratepayer benefits could be realized with charging solutions that allow for load management and dynamic or time of use pricing mechanisms to drivers, given that EVs can be very flexible on when they need to charge, the company said. That necessitates that any utility program should require that associated charging stations participating in the program include demand response capabilities, two-way communications, and embedded energy metering, ChargePoint said.

Among other things, the company said that it encourages Rhode Island to expand on that topic and develop transparent criteria for evaluating and approving those programs to ensure that competition, innovation, and customer choice continues in the market, and that the programs are in the best interest of ratepayers.

In its comments, National Grid noted that it owns and operates 49 charging station locations – 102 ports – across Rhode Island, comprising about 60% of the 81 public charging stations installed to date in the state. The company said that it installed those stations using grant funds from the Rhode Island Office of Energy Resources, in partnership with a charging equipment vendor and network service provider, between 2011 and 2014.

In accordance with the company’s experience providing charging services to date, and in support of the state’s goals of growing EV adoption roughly 50-fold – from about 800 to 43,000 – by 2025, National Grid said that it suggests that its role in enabling EV adoption should include continuing to serve as operator of charging stations in public and private locations, through the installation, ownership, and maintenance of EV supply equipment (EVSE) and associated electrical equipment on the distribution system and behind customers’ meters.

National Grid said that key priorities for regulators and policymakers that apply broadly and in the specific context of beneficial electrification include building upon the existing regulatory framework in a manner that supports the utility’s core obligation to deliver safe and reliable energy, while also aligning utility financial interests with achievement of key policy outcomes, such as system efficiency, greenhouse gas reductions, or EV penetration, as well as customer interests.

Discussing the utility’s role in PEV adoption, Newport Solar, a Rhode Island-based solar company, said in its comments that it believes that it would be beneficial for the utility to replicate current models in energy efficiency and renewable energy program administration to encourage EV businesses and efficient markets.

Most market indications suggest that the barriers to EV adoption include price and incentives, range anxiety, and general education on EV financial value and usability, the company said.

There are opportunities for the utility to provide guidance and administrative support for EV adoption, including tracking deficiencies in product capability and providing information to manufacturers, distributors, and developers as a signal to development, the company said.

Under “[r]elevant circumstances in considering investments,” Newport Solar noted that most people in Rhode Island drive less than 100 miles per day, whereas most EVs have more than 100 miles of range per charge. Therefore, the company said, most of the miles driven in the state will be charged at residences.

“[C]onsideration of investments of both time and money on grid scale infrastructure should take second seat to investment in development and communication of incentive structures and PEV usability,” the company said.

In its comments, the Sierra Club said that there are several roles for utilities in accelerating EV deployment and managing EV load, including to help Rhode Island rapidly increase deployment of EVs through direct investments in EV charging infrastructure using either a make-ready model, direct utility ownership, or some combination of the two.

The Sierra Club said that utility investments should focus on sites that enable EV ownership and that are presently underserved by private sector investment, with optimal locations being those that can be consistently accessed by an individual driver and where the vehicle will be parked for long enough to gain usable range.

About Corina Rivera-Linares 3286 Articles
Corina Rivera-Linares was TransmissionHub’s chief editor until August 2021, as well as part of the team that established TransmissionHub in 2011. Before joining TransmissionHub, Corina covered renewable energy and environmental issues, as well as transmission, generation, regulation, legislation and ISO/RTO matters at SNL Financial from 2005 to 2011. She has also covered such topics as health, politics, and education for weekly newspapers and national magazines.