Dive Brief:

• Pepco's transportation electrification plan for the District of Columbia has broad support from environmental groups and the electric vehicle (EV) industry, but the city's ratepayer advocate says customers should not be paying for what the market can provide.
• Comments in the proceeding were due to the D.C. Public Service Commission (PSC) on Jan. 15, and the Office of the People's Counsel (OPC) for the District of Columbia told regulators that Pepco's proposal is "detrimental to the competitive EV market" envisioned in the legislation enabling the utility's proposal.
• Regulators will now review the comments and issue an order determining how the proceeding will move forward.

Dive Insight:

Pepco has cut the budget for its transportation electrification proposal in the District of Columbia, but the city's consumer advocate says even with the reductions it cannot support the plan.

"The application does not justify the Company’s request for over $10 million dollars in ratepayer contributions and no proposed Company investment," OPC told Utility Dive in an email. "We recognize the value of being flexible in an evolving and developing market. However, protecting ratepayer interest will remain a primary concern for the Office of the People’s Counsel."

The D.C. government has made growing electric vehicle adoption a priority for the city, as the transportation sector contributes more than 20% of the city's carbon emissions. While there are still just a relative few EVs on the roads in Washington — last year there were about 720 among the city's more-than 300,000 registered vehicles —​ Pepco believes the number could reach 40,000 by 2030.

That volume of plug-in vehicles, according to Pepco, will require a mix of public DC Fast Charging and Level 2 chargers spread across the city, along with equipment for home charging.

Pepco's proposal has support from the Natural Resources Defense Council, Plug in America and the Sierra Club.

In order to achieve the District's electric vehicle and decarbonization goals, the city "must expand transportation electrification infrastructure," Plug In America said in its comments filed with city regulators. "Delaying the application will only delay the cities [sic] response to needing electrification infrastructure."

While the Sierra Club has a "identified a couple discrete pieces that we believe could be strengthened," they are broadly supportive of the proposal, Joshua Berman, senior attorney to the nonprofit's environmental law program, told Utility Dive.

Addressing the issue of whether ratepayer funds should go towards electrification, Berman said the Sierra Club generally "has been supportive of ratepayer dollars going to well-crafted utility programs that will expand access to the benefits of electrified transportation ... and believe this can be done in a way that will foster rather than hinder the growth of the competitive market."

In its written comments, the group told regulators that to the extent Pepco will own public charging stations, "those rates must be carefully reviewed to avoid unintended impacts to EV drivers or to the development of the competitive market."

But in calling for regulators to reject the proposal, OPC argued the transportation electrification proposal will stifle competition, whether or not the rates are subject to scrutiny.

"Much of Pepco's overall program methodology — that is, providing and owning ratepayer funded EV charging infrastructure — is detrimental to the competitive EV market," OPC said in comments. "This intrusion into the private sector is unnecessary ... Allowing Pepco to subsidize its own charging stations with ratepayer funds would discourage cost-effective investment in charging stations by private entities who lack the benefit of ratepayer subsidies."

Still, the consumer advocate said that is not the primary objection to Pepco's proposal.

"Each of the offerings that Pepco proposes to implement are missing key details, including that Pepco did not provide any analysis justifying the ratepayer-funded installation of thousands of chargers in a jurisdiction that is less than 70 square miles, in which a significant amount of the population does not own a car, and where there is an existing extensive public transportation network," OPC told Utility Dive.

The group went on to say that Pepco "did not conduct any analysis on the load impacts of additional EVs on the District’s distribution system; increased load could require distributions upgrades and additional ratepayer funds."

As the deadline for comments passed, the PSC will now review the submissions and determine how to proceed.