Note Regarding References to ORA: Until September 2018, Public Advocates Office was previously known as ORA - Office of Ratepayer Advocates. 


Electric Vehicles: 
PG&E’s Infrastructure Pilot Program


On February 9, 2015, PG&E filed an Application requesting CPUC approval to implement a pilot program to deploy electric infrastructure for Electric Vehicle charging stations in its service territory, over a five-year period.    

PG&E proposes to deploy, own, and maintain Charging Stations at approximately 2,600 locations comprised of:   

  • ~25,000 Level 2 Electric Vehicle charging stations  
  • 100 Direct Current Fast Chargers  

PG&E claims its program will remove key barriers that will accelerate Electric Vehicle (EV) adoption by increasing: 

  • The availability of EV charging infrastructure to reduce barriers to entry into the EV market.     
  • Overall customer education and awareness of the benefits of EVs and fueling from the electric grid.     
  • Delivery of time-variant pricing to promote integration of renewable energy to the grid.      
  • Access to EV charging in disadvantaged communities.     


CPUC Sets Pilot Phase

On June 16, 2015 the CPUC issued a Ruling requesting comments on whether PG&E’s proposed Electric Vehicle program should be phased to allow a smaller initial deployment and what benefits this would offer.   

On September 4, 2015, the CPUC issued a Ruling directing PG&E to submit a supplemental proposal that will create an initial Phase 1 of EV charging station deployment, with the following criteria:   

  • Limited to a maximum of 2,510 charging stations (essentially, piloting 10% of PG&E’s originally proposed total). 
  • The stations are to be deployed over no more than 24 months.   

PG&E Supplemental Testimony

In response to the CPUC's September, 2015 PG&E filed Supplemental Testimony on October 12 that included two proposals:
  • The Compliant Proposal: Adheres to CPUC direction to deploy 10% of the original number of charging stations in PG&E’s application (2,510 charging stations) and collect data for an additional 12-month period at a cost of $87 million.   

  • Enhanced Program: PG&E's alternate, and preferred, proposal to deploy 7,530 charging stations during a 36-month period and permit data collection for an additional 12 month period at a cost of $187 million.  


Proposed PG&E Settlement

On March 21, 2016, PG&E and certain stakeholders filed a proposed Settlement agreement with the CPUC, proposing to own and install 7,500 Electric Vehicle charging ports over a period of 3 years for a cost of $160 million. PG&E refers to its program as "Charge Smart and Save." The proposed plan would target multi-unit dwellings and workplaces. The proposed settlement agreement would:  

  • Install 100 DC fast charger ports.  
  • Use third parties to market the program and sign up potential EV Site Hosts.  
  • Create a Program Advisory Council, comprised of non-market participants, to provide input on PG&E’s procurement of EV charging equipment and services.  
  • Require EV drivers to pay CPUC-approved Time-of-Use rates. 
  • Require the site host to make a participation payment based on the percentage of the EV charger cost, except for disadvantaged communities, government agencies, non-profits, and DC Fast Charger sites.

The Public Advocates Office (the Office) is not a party to this Proposed Settlement.


CPUC Proceeding Status

On March 29, 2016, the CPUC issued a Ruling revising the proceeding schedule and directing settling parties to responds to the Ruling's questions by April 12, 2016.

The Evidentiary Hearing took place at the CPUC April 25 - 28, 2016.

A CPUC Decision is expected by the end of 2016.



The Office's Position

The Office supports California’s goals to mitigate Greenhouse Gas emissions by increasing the adoption of Electric Vehicles. EV strategies should achieve this goal in the most effective and cost-efficient manner, to ensure accountability for customer funding. The CPUC should consolidate PG&E’s EV program application with the CPUC’s proceeding to develop Guidelines for Charging Stations, Grid Integration, and Rates in order to maintain consistency across each utility service territory.   


The Office Recommendations

The Office supports PG&E’s Compliant Proposal, which comports with the CPUC’s September 2015 Ruling directing the utilities to create a reasonable pilot charging station program of approximately 2,500 charging stations with up to 5,000 charging ports. The pilot should cost no more than $87 million. A small pilot will allow PG&E to test its plan to ensure it is sustainable, before spending significant ratepayer dollars in rolling-out a full charging station deployment.


The Office supports a competitive market for charging stations which will promote innovation and lower costs for customers. Accordingly, the Office does not support PG&E ownership of charging stations.

Additionally, the Office recommends that the CPUC should adopt PG&E’s Compliant Proposal with modifications in order to make improvements, including:  

  • Focus on the underserved customer segments of multi-unit dwellings and disadvantaged communities.  
  • If the CPUC finds utility ownership of charging stations necessary, then PG&E should own the charging stations only in the underserved markets of multi-unit dwellings and low-income communities, in order to ensure deployment in these markets. 
    • A "make-ready" model could be owned by the utility, a solution in which the utility owns the infrastructure up to, but excluding, the actual charging station.  
  • Similar to the pilot programs of Edison and SDG&E, PG&E’s pilot program should be overseen by a Program Advisory Council to promote a variety of stakeholder input.  


Accordingly, the Office does not support PG&E’s Enhanced Proposal, known as "Charge Smart and Save Program," as reflected in the Proposed Settlement, which would install up to 7,500 charging stations.
The Office supports coordination of deployment with the CPUC’s Distributed Resources Plan.

See the Office’s full analysis and recommendations:

June 17, 2016 Opening Brief 

July 8, 2016 Reply Brief   

The Office's Analysis and Testimony

The Office performed an in-depth review of PG&E’s Supplemental Application and found that the CPUC should approve a pilot program more in line with its June 2015 Ruling. The Office recommends that PG&E should not own the Electric Vehicle charging stations and that:  

  • Ratepayers should fund only the distribution infrastructure required to connect no more than 2,500 charging stations, which will allow for collection of pilot data, while minimizing the risk of stranded assets and costs.      
  • PG&E should implement its pilot in phases, which demonstrate success before proceeding to the next phase:
    • Require PG&E to install at least 1,500 Electric Vehicle charging stations (but no more than 2,000) within 18 months – or the CPUC should revisit assumptions if PG&E does not meet this goal.    
    • If PG&E meets the charging station installation goal, the CPUC should require 18 months of data collection and analysis to ensure the pilot is working or make adjustments as needed in order to maximize the program’s potential of meeting the state’s climate change goals.  

If the CPUC permits utility ownership of charging stations, PG&E should use shareholder funds to own no more than 20% of charging stations to minimize anti-competitive impacts. The CPUC should:  

  • Clearly define PG&E’s and electric vehicle service providers’ roles in the siting of charging stations, as well as marketing & education.
  • Require load management plans, metrics, and quarterly reports to manage, measure, and report the program’s performance.
  • Establish mechanisms to ensure accountability for program budgets and a reasonableness review.    

See the Office's November 30, 2015 Testimony on PG&E Supplemental Application.  


See the Office's July 3, 2015 Comments on the CPUC's Phasing Ruling.   

See the Office's March 13, 2015 Protest to PG&E's Application.  



Proceeding Status 

See the Proceeding docket.    



Other Resources

The Office's Electric Vehicle Portal Webpage  

The Office's CalEVIP Pilot Framework Proposal   

CPUC Electric Vehicle Proceedings Webpage