Paul Jensen of Green Ways 2Go, testified on November 3rd, 2022, to the North Dakota Public Service Commission, on the subject of Electric Vehicle Charging in connection with the National Electric Vehicle Infrastructure plan as promoted by ND DOT and its implications for the Electricity companies serving the state. The discussion was based on the HR 3684 Bill enacted into law in November of 2021.
Green Ways 2Go responded and trust that the PSC will consider these arguments when deciding how to proceed. Other submissions of value were those of ChargePoint as well as Xcel Energy, Mr. Brian Kopp of Dickinson, Larry Oswald of MDU,
The questions asked by the Commissioners to the public were and below you’ll find the answers of GW2G:
Q: Whether ownership of electric vehicle charging stations should be permitted by regulated utilities. If permitted, under what conditions?
A: Utilities should initially be involved in the granular day-to-day operations of EV charging stations and the electrical switchgear supplying the EV Charging equipment. However, as the market matures, private enterprises can take over this role. The main requirement to enable this is to make sure the EV charger sub-meters are utility grade and provide fair pricing to consumers.
Q: What should the Commission consider regarding unfair competition between third-party charging entities and regulated utilities?
A: The commission should be cautious with potential competition between Utilities, Cooperatives, and third-party charging resellers so it may create an even platform. Resellers should be able to bill their sales per kWh dispensed. Utilities have the potential to strangle the adoption of EV charging especially if various levels of responsible maintenance could create supply and availability issues. Home charging and commercial charging need each a different rule set which should be monitored by the PSC. Conflicts of interest must be prevented across electrical utilities and the oil and gas industry.
Q: Should the Commission consider special tariffs or rates for residential electric vehicle charging?
A: Electric Vehicle Supply Equipment with appropriate sub-meters to separate the EV load from the balance of a facility is favorable. Time-of-day rate programs can be beneficial if they specifically drive the behavior of EV recharging and can also support the Vehicle to Grid and X scenarios (V2G and V2X) However, it is important that price controls are maintained. Detrimental pricing policies, both with IPP Generators and Cooperatives, must be avoided to the benefit of the consumers. Expansions of EVSE equipment in households is not always managed best by traditional market forces. Utilities should be able to control a gradual integration of vehicle charging as and when the distribution lines can serve the new loads. On the other hand, upgrading distribution systems should not be unreasonably delayed if they are preventing quick adaption of Electric Vehicle charging.
Q: Whether the Commission should consider pilot programs in anticipation of the electrification of the transportation sector? If so, what pilot programs?
A: Yes, the Commission should consider pilot projects to evaluate the effect of vehicle charging in the state throughout its power lines and the distribution network. This can be done with an AI-Driven Distribution Load Profiling/Forecasting system analysis to Improve O&M, Seasonal & Event Preparedness for example.
- Trends in load growth (e.g., AC) and mix (i.e., EV), forecasts and capacity issues
- Scenario modeling for weather and other extreme events such as drought and wildfire.
- Potential impacts of distributed energy resources (DER)
- Improved distribution Capex planning
- Operational Systems optimization
- Piloting integration of solar, stationary storage (including CO2), EV charging, smart technologies, managed charging, V2X and V2G.
Q: What is the anticipated distribution system impact from residential and fleet charging?
A: For the near future it will be a gradual adaptation for North Dakota with a manageable impact, but it is important to carry out analysis as mentioned in the above suggestions. Substations and distribution transformers may need to be upgraded or older transformers and switchgear may need to be replaced. Fleet charging is typically located in already well-supplied regions and there are many methods available to do load sharing in a manner not disruptive to owners of grid and distribution operations. I recommend a study to be carried out soonest.