The Public Service Commission of Wisconsin (PSCW) has released a summary memorandum of initial comments in its docket to investigate electric vehicle (EV) policy and regulation. Comments were submitted by 24 parties, six utilities, and 12 members of the public in response to 28 questions categorized under the eight investigation topics initially laid out by PSCW.
Under Customer Expectations, commenters named limited charging infrastructure as one of the most significant barriers to EV adoption. Commenters highlighted this concern in many other topic areas throughout the memo. Other concerns were high upfront costs, consumer awareness, and vehicle availability in Wisconsin. Commenters identified federal tax credits and fuel savings as some enablers of EV adoption.
Comments also addressed Consumer Expectations of Electric Utilities Regarding EVs, including information resources, cost savings, and clear metering of EV charging. The comments cited several utility pilot programs to encourage EV adoption. Under Policies and Standards of Electric Utilities Regarding EV Infrastructure, utilities further discussed their efforts to develop pilot EV charging infrastructure and tariff rate programs.
Under Ownership and Operation of EV Infrastructure, a majority of commenters suggested there should be no limitations to ownership. However, commenters were split on whether utilities or third parties should own infrastructure for public charging and on the relationship between pricing and ownership. The memo discusses several options for energy purchase agreements between utilities, third-party providers, and end-use consumers.
Commenters also addressed Financing and Cost Recovery of EV Capital Investments and Rate Design and Service Considerations of EV Tariffs. Commenters largely agreed that third-party owners of EV charging infrastructures should not be considered statutory public utilities. However, both commenters and PSCW suggested legislative or regulatory change might be necessary to exclude third-party charging infrastructure owners.
Under EV Impacts on Storage, Distribution, Transmission, and Generation Infrastructure, commenters described grid management benefits of EVs such as load shifting to decrease costs, greater support for demand response activities, increased reliability through managed charging, and utilization of grid assets. Utilities did have concerns about increased demand during peak times and rising transmission and distribution costs.
Under EV Impacts on Interstate Competition Given Differing State Regulation, commenters mentioned the positive impact expanded EV charging infrastructure would have on Wisconsin’s tourism economy.
Throughout the eight topic areas, commenters expressed concerns about the potential for EV-related utility rates to result in cross-subsidies for non-EV users by non-EV users. Other commenters viewed EV adoption and infrastructure as providing a general societal benefit and potential cost savings to the entire system.
In the memo’s conclusion, PSCW mentions its jurisdiction is unclear in some issue areas, such as charging station ownership, subsidizing equipment, and defining costs and benefits of EV adoption. PSCW sees its role as more clearly defined in addressing the effects of EVs on electric system operations, consumer education, cost recovery of utility investments, and rate design and pricing related to EVs.
PSCW is now requesting utilities, interested participants, and members of the public to review the memo and provide input on next steps in the PSCW investigation.
View comments and other PSCW documents here.