GRC phase 2 or Rate Design Window and then filing this request with the FERC before applying this transmission rate design on a more permanent basis. Further, any introduction of timedependent transmission rates should not be limited to EV rates but should encompass non-residential transmission rates generally. In the event FERC does not approve the 70/30 proxy split proposed in Joint-12, SCE should implement its proposed commercial EV rates using the transmission cost allocation currently approved by FERC. ORA describes its position that the “the proposed billing provision with respect to [demand] charges is a significant improvement over SCE’s original proposal.” ORA argues that “SCE’s original proposal was to simply assess the demand charge based on the high non-coincident demand of the EV meter. However, this would have overestimated customers’ demands, because it ignores the fact that the highest demand the grid sees is the combined (i.e. concurrent) demand of the host site meter and the EV meter.” As modified by the Joint Stipulation, the new billing provision accounts for the coincidence of the EV meter’s and the main business meter’s combined maximum demands resulting in a rate design that significantly reduces the financial impacts from demand charges. Tesla is supportive of this modification but recommends clarification to confirm that this structure would only apply to a customer’s delivered load. Tesla suggests, for instance, “if a customer installs storage that reduces the EV peak, there should be no penalty. … Tesla encourages resolution on this question within the final approved program rate design.” The issue Tesla raises would occur if the customer’s storage system were behind the meter that measures the facility load, but not the EV load, thereby reducing the facility’s metered demand, and potentially increasing the incremental EV demand to
GRC phase 2 or Rate Design Window and then filing this request with the FERC before applying this transmission rate design on a more permanent basis. Further, any introduction of timedependent transmission rates should not be limited to EV rates but should encompass non-residential transmission rates generally. In the event FERC does not approve the 70/30 proxy split proposed in Joint-12, SCE should implement its proposed commercial EV rates using the transmission cost allocation currently approved by FERC. ORA describes its position that the “the proposed billing provision with respect to [demand] charges is a significant improvement over SCE’s original proposal.” ORA argues that “SCE’s original proposal was to simply assess the demand charge based on the high non-coincident demand of the EV meter. However, this would have overestimated customers’ demands, because it ignores the fact that the highest demand the grid sees is the combined (i.e. concurrent) demand of the host site meter and the EV meter.” As modified by the Joint Stipulation, the new billing provision accounts for the coincidence of the EV meter’s and the main business meter’s combined maximum demands resulting in a rate design that significantly reduces the financial impacts from demand charges. Tesla is supportive of this modification but recommends clarification to confirm that this structure would only apply to a customer’s delivered load. Tesla suggests, for instance, “if a customer installs storage that reduces the EV peak, there should be no penalty. … Tesla encourages resolution on this question within the final approved program rate design.” The issue Tesla raises would occur if the customer’s storage system were behind the meter that measures the facility load, but not the EV load, thereby reducing the facility’s metered demand, and potentially increasing the incremental EV demand to
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