SDG&E Replies to Protest and Response of Advice Letter 4021-E

Issue 1: The program limits EVSE ownership for some target customers to site hosts and the utility, excluding third-party electric vehicle service providers ("EVSPs"), without justification.

• SDG&E agrees. Third-party ownership will be included as an option in the final approved PYD for Communities program design.

Issue 2: The proposed exclusion of CHAdeMO ports at direct current fast charger ("DCFC") stations will preclude utilization of these chargers by many of the electric vehicles ("EVs") currently on the road.

• SDG&E does not object to including CHAdeMO ports at DCFC stations.

Issue 3: SDG&E should include community-based organizations ("CBOs") in its outreach and demonstrate that it has used information gathered from CBOs to inform the development of its program design.

• SDG&E disagrees and objects to further CBO outreach and input used to design PYD for Communities as unnecessary.

Issue 4: SDG&E’s proposal should include specific level 2 charging port ("L2:) and DCFC goals that are informed by CBO information.

• SDG&E agrees in part. SDG&E agrees that “L2 ports should be located where longer dwell times are expected or required” and that dwell times should be considered when selecting chargers for sites.
• However, these decisions should be made on a per-site basis rather than at a programmatic design level.

Issue 5: SDG&E’s proposal should use port costs from Pacific Gas and Electric Company’s ("PG&E’s") EV Fast Charge DCFC and Southern California Edison Company’s ("SCE’s") Charge Ready 2 L2 programs.

• SDG&E disagrees. PG&E's program costs are outdated because they are based on a decision from four years ago and SCE's program is in the early stages of implementation and supports proportionally fewer DCFCs than PYD for Communities.
• The Commission should approve the proposed per-port average costs proposed by SDG&E, because these costs are based on observed, implementable, current costs.

Issue 6: SDG&E’s proposal should include lower cost subsidies for private parties and the public sector than that proposed in SDG&E’s current AL 4021-E.

• SDG&E disagrees. Reducing rebate levels will bias the program away from true underserved communities and make it less accessible, undermining the intent of Commission D. 21-05-028.

Issue 7: SDG&E’s proposal should conform to program duration guidelines specified in D. 21-07-028, and program completion for near-term should occur before the end of 2025.

• SDG&E disagrees. Mandating a shorter program timeline will likely require SDG&E to prioritize more sophisticated site hosts, undermining the accessibility of the program for underserved communities.

Issue 8: SDG&E’s proposal should be modified to provide greater detail on how its data collection and reporting will satisfy D.20-12-029.

• SDG&E agrees. SDG&E can include a final snapshot of how many sites choose to use custom pricing rather than passing through time-of-use rate signals in the PYD for Communities final report.

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