Virginia regulators invite comments on EV pilot program proposed by electric cooperative

As noted in the order, Rappahannock Electric Cooperative (REC) on Jan. 2 filed an application for approval of an EV smart charging pilot program that REC anticipates would help it to manage its related capacity costs, load factor, and the upward pressure on residential rates that could occur when charging is done during on-peak hours

The Virginia State Corporation Commission, in a Jan. 24 order, said that by April 3, any interested person or entity wishing to participate as a respondent in a proceeding regarding a proposed electric vehicle (EV) pilot program may do so by filing a notice of participation.

As noted in the order, Rappahannock Electric Cooperative (REC) on Jan. 2 filed an application for approval of an EV smart charging pilot program that REC anticipates would help it to, for instance, manage its related capacity costs, load factor, and the upward pressure on residential rates that could occur when charging is done during on-peak hours.

The cooperative requests a voluntary, experimental, two-year EV pilot that initially is limited in scope to 200 residential customers the first year and up to 400 residential customers the second year. The commission added that REC plans to “introduce the EV pilot to its customers through its website, social media outlets, Cooperative Living Magazine, and other promotional methods.”

The commission said that as proposed, to be eligible to participate in the EV pilot, customers must be served on one of the cooperative’s residential rate schedules other than “Schedule R-TOU”; own an all-EV; and charge the EV at home using a specific type of Wi-Fi-enabled, Level 2 charger continuously connected to the internet to transmit data to the cooperative.

Per the cooperative, participation in the EV pilot would be voluntary, and there would be no fees to enroll or participate in the EV pilot. The commission added that participants could elect to withdraw from the EV pilot at any time without penalty.

Through its proposed EV pilot, REC states that it seeks to avoid what it perceives as two drawbacks to introducing a rate for a yet-to-exist load using separate metering and a new rate:

  • The additional cost incurred by the utility and participating customers for the separate metering
  • The risk that the presumed load profile is incorrect and thus the new rate is insufficient to recover costs, or is overly burdensome or punitive

The commission added that REC states that the EV pilot avoids those drawbacks because the EV pilot would allow it to measure EV charging by using the metrology built into certain EV chargers, bill all household consumption, therefore according to REC’s standard residential tariff as measured by the utility meter, and then apply a bill credit of 4 cents per kWh to the kilowatt-hours consumed during “Smart Hour” EV charging.

REC further states that customers who choose to charge an EV outside of “Smart Hours,” would continue to pay the standard rate with no risk of penalty, but would forfeit all bill credits for that cycle, the commission said.

REC represents in its application that the EV pilot would not harm non-participating customers because, for instance, the avoidance of increased capacity related costs resulting from charging during “Smart Hours” would offset the cost of bill credits REC plans to pay participants. The commission added that the cooperative states that its proposed bill credit amount is meant to remove capacity related wholesale costs from the standard ESS rates within the residential tariff. However, REC further represents in its application that the cooperative plans to analyze wholesale power costs annually to determine if the bill credit amount for the EV pilot is appropriate.

Among other things, the commission also said that REC proposes to provide staff with a report at the end of 12 months of operation of the EV pilot, to include certain metrics of the EV pilot for each month of the reporting period.

The commission noted that written comments on the matter may be filed with its clerk by April 3. Commission staff is to file a report containing its findings and recommendations by April 17, the commission said, adding that the cooperative may file with the clerk any rebuttal to the staff report by May 1.