Joint Utilities Reply to Protests of Advice Letters in Compliance with Resolutions E-5167 and E-5168

Below are the Joint EV Industry Parties' protests, and the Joint Utilities' responses:

1. The 160 average timeline target does not "accelerate" energization and should be re-evaluated.

• Response: The timeline is within the 90 to 160 day range required by Resolutions E-5167 and E-5168. The timeline must account for additional civil construction work.

2. Additional evaluation points should be established to continue to accelerate the average service energization timeline from the current average of 150 to 155 business days to 90 business days.

• Response: The Joint EV Industry Parties provide no evidence that a 90 day timeline is feasible. The IOUs will provide an initial evaluation within 18 months, and the IOU annual reports will provide information on the number of business days.

3. AHJ permit review periods should be incorporated into average timelines.

• Response: This would be unreasonable, and the utilities predict they will fail to comply with this timeline.

4. Energization timelines should be tracked and improved under both the EV Infrastructure Rules and under Rules 15 and 16.

• Response: The Resolutions specifically excluded Rule 15 for this timeline. The IOUs have already committed to identifying process improvements and efficiencies to improve timelines for all its customers.

‍