Dayton Power & Light Files EV Plan with PUCO

On December 21, 2018, Dayton Power & Light (DP&L) filed a grid modernization plan with the Public Utilities Commission of Ohio (PUCO). The plan included a proposal to install 40-50 electric vehicle (EV) charging stations over a three-year period for a total capital investment of $5 million. DP&L proposed that they install, own, and operate the chargers. With this plan, DP&L becomes the second major Ohio operating utility to propose an EV charging investment plan to Ohio regulators.

These stations would be a mix of Level 2 and DC fast chargers. Kevin Hall, Director of Operations at DP&L, testified that DP&L anticipated the charging stations would be installed along major interstate corridors, as well as locations where it is convenient for customers to charge their EVs, such as retail stores, airport parking areas, and movie theaters. The proposal also includes time-of-use rates implemented through intelligent EV charging to incentivize charging during off-peak times. This will protect the grid and support lower electricity costs for all ratepayers by spreading out DP&L’s infrastructure costs over a larger base of electricity sold.

Clean Fuels Ohio applauds DP&L for taking significant steps forward, while noting specific elements that need to be clarified. “Well-designed utility EV programs include several components. DP&L’s plan includes some of these and could be modified to include others,” said Brendan Kelley, Director, Clean Fuels Ohio’s Drive Electric Ohio. “We look forward to supporting and working with DP&L and other stakeholders to further develop this plan.”

Clean Fuels Ohio analyzed the DP&L plan in the context of utility EV program design best practices:

  • Investments in Level 2 and DC fast charging equipment in three primary locations to support the adoption of light-duty EVs – multi-unit residential dwellings (MUD), workplaces (to support both employee vehicles and fleet vehicles), and highways, as well as charging infrastructure to support electrification of medium- and heavy-duty vehicles such as transit and school buses; DP&L’s proposal includes public and highway components, but not MUD or workplace; their stated goal for installing chargers is to address “range anxiety,” which is a reasonable justification for focusing resources toward public chargers, since those are the most visible, but lack of MUD and workplace charging are significant barriers to widespread and equitable EV adoption, and incentives for chargers in those types of sites will dramatically accelerate adoption.

  • Investments in “make-ready” infrastructure (i.e., the supportive wiring and panel upgrades for EV charging stations) and needed local distribution infrastructure; these are included in DP&L’s proposal for the chargers they propose to install, own, and operate.

  • Rate structures designed to direct flexible EV charging load into off-peak times; DP&L’s proposal includes time-of-use (TOU) rates.

  • Programs that allow the electric utility to directly control the times of vehicles charging, allowing for permission or possibility of override by the customer to direct as much charging as possible to off-peak times; DP&L’s proposal gives them control over the chargers they plan to install, but does not mention this for any other chargers in their service territory.

  • Rebates offered to qualified site hosts based on commitments to select and maintain appropriate equipment, with strong accountability measures to ensure rebate recipients operate stations responsibly for EV customers; DP&L’s proposal does not include this component;

  • Assurance of reasonable pricing by site hosts; DP&L’s proposal does not include this component;

  • Assurance that all stations utilize open, interoperable access and payments protocols for all customers; DP&L’s proposal does not include this component.

  • Allowance for some utility ownership of equipment in well-defined critical locations (particularly MUDs and highways); DP&L proposes to own and operate all the chargers mentioned in their plan; in the original EV plan submitted to PUCO by AEP Ohio, they proposed owning and operating all the chargers they would install; this was vigorously opposed by multiple interveners, as well as PUCO staff, and AEP Ohio ended up owning none of the chargers installed through their program; while early data from the AEP Ohio pilot indicates that some utility ownership might make sense (primarily corridor DC fast chargers), DP&L probably will not get to own and operate all; the PowerForward Roadmap states, “There may be justification for limited EDU participation in the development of EV charging infrastructure;” that does not seem to be compatible with DP&L’s proposal.

  • Utility policy that foregoes or limits demand charges for a reasonable period, particularly for DC fast charging stations; DP&L’s proposal does not include this component.

  • Funding for consumer education programs to increase awareness of availability of EVs and their benefits; DP&L’s proposal includes significant resources for customer education.

  • Open access to data collection to improve future EV programs; DP&L’s proposal states that it is expected to deliver open access to “grid data” for third parties and includes an “Analytics Center of Excellence” to “consolidate and analyze data from various devices and systems” for internal and customer use, but does not specifically mention collecting, analyzing, and sharing data collected on EVs and EV charging.

  • Robust and effective evaluation of EV programs; this may be included in DP&L’s plans for data analysis, but it is not specifically mentioned.

  • Dedicate resources to ensure access for low- and moderate-income customers to EV charging; DP&L’s proposal does not include this component.

Utility support for EV adoption is appropriate and positive because of the benefits that can accrue to the body of utility customers as a result of widespread transportation electrification. Electric utilities are particularly well-suited to address the infrastructure and market education challenges to EV adoption.

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