Transportation Electrification Plan Urgency and Equity—Comments on Proceeding No. 20A-0204E By Dan Regelson

TEP Urgency and Equity—Comments on Proceeding No. 20A-0204E
By Dan Regelson of
Xcel’s Transportation Electrification Plan (TEP) is a necessary step towards achieving
Colorado’s target of 940,000 EVs on the road by 2030. However, Xcel must do more to switch
customers from their existing fossil fuel vehicles. Building chargers and reducing perceived
barriers to EV adoption is necessary but not sufficient. SB 19-077 requires utilities, the PUC,
and other stakeholders to do everything they can to dramatically increase the EV adoption rate.
The PUC must require Xcel to improve this plan so that it better reflects the urgency obvious in
the worsening climate crisis and to do so equitably, reaching all consumers and not just those
who can afford to own an electric car and charge it in their own home.
These comments are broken into two sections—urgency and equity—with a list of
recommendations in italics at the end of each section.
Section 1: Urgency
The majority of Xcel’s proposed Residential, Multi-Unit Dwelling (MUD), and Commercial
portfolios— 75% of the $100 million budget—is assigned to deploying chargers. But success in
transportation electrification isn’t about dollars spent or chargers installed or even the number of
EVs on the road. Driving miles replaced is what matters. And while massaging preconceptions
and commissioning studies will eventually lead to EV conversions, getting people to electrify
their transportation now will normalize electrified transportation and enable more effective word
of mouth marketing. So what can Xcel do to increase the urgency of customer transitions to
electrified transport?
Customers love saving money, making the financial benefits of EVs their most compelling story.
Existing electric rates offer some ongoing savings when compared to gas on a per-mile basis for
drivers of small vehicles. And smart EV charging should allow for rate designs that
simultaneously benefit EV customers, non-EV customers, and the utility by effectively shifting
demand to times of low net usage and/or high renewable generation. Indeed, Xcel offers two
charging optimization programs and their time of use rate as ways to do exactly this. However,
these programs offer only nominal dollar incentives and are at best poorly explained 1 in the TEP
documents2. Instead, charging incentives must represent aggressive potential for savings to 1)
get customers thinking seriously about purchasing EVs and 2) effect real and substantial
demand shifting.
1 Participation in the static optimization program gives a $50 annual rebate while the Charging Perks pilot
offers an annual incentive of $100 with a level 2 charger ($50 with level 1). The Charging Perks pilot is
capped at 600 customers.
2 The TEP documents and associated testimony say that the charging optimization plans will be detailed
in the 2021-2022 DSM plan, however pages 266-270 of said DSM plan fail to include specifics of the
customer experience under either the static optimization plan or the Charging Perks pilot.
Colorado PUC E-Filings System
To do this, Xcel needs to offer $0.00-rate power for charging EVs at times of high renewable
surplus. This isn’t as radical as it seems , as it’s offering maximal savings to 3 4 customers who are
paying for Xcel’s capital expenditures rather than benefiting someone else (as in dispatching
surplus through an EIM or RTO) or nobody (curtailment)5. In 2018, Xcel curtailed 3.5% of wind
generation6. The equivalent amount of energy wasted could have instead charged 92,000 cars
for the entire year7.
Compared to the fixed incentives Xcel is proposing, free charging on surplus will better allow
users to take control of their charging and optimally use renewables. Ever-increasing EV range
already allows average drivers to go a few days between charges. And ever-increasing
renewable generation will only increase the problem/opportunity of surplus.
Existing Xcel programs/pilots already offer a couple of different approaches for implementing
● The Charging Perks pilot8 included in this TEP might work well if the static TOU rate is
replaced with a truly dynamic Time of Renewable9 rate.
● Xcel’s Critical Peak Pricing10 program offers businesses the opportunity to lower their
bills 5-10% annually by reducing their usage during times of very high system-wide load.
Participants are notified of Critical Peak events one day in advance, and a similar
method could be used to notify EV owners of upcoming renewable generation peaks.
● Xcel’s EV Service pilot11 in Minnesota offers unlimited night and weekend charging for a
flat rate. Billing on time of day and week does account for peak load but does not
account for peak renewables. And, this disproportionally benefits high mileage drivers
3How much does this cost? Supposing 100,000 EVs charging entirely on surplus (TEP “Mid” estimate for
EVs in Xcel’s territory in 2023, 30 miles per vehicle per day, 3 miles per kWh), the equivalent wholesale
cost at $0.02/kWh (estimated from 2019 Xcel 10-K) is $7.3 million annually. At summer off-peak TOU
rates of $0.08 per kWh, it’s $29.2 million annually. However, the opportunity cost of curtailment and the
benefits of truly maximizing the benefits of renewables must also be considered.
4 There is precedent for selling EVs with free charging:
5 And curtailment costs all ratepayers by 1) needing to replace the lost electricity with more expensive,
presumably fossil, sources and 2) losing the wind production tax credit.
6 Page 26, Figure 2 of IEEE Power and Energy Magazine November/December 2019 shows Xcel
curtailing about 3.5% of wind generation:
7 Assuming 30 miles per vehicle per day, 3 miles per kWh, 35% average capacity factor for wind, and total
wind capacity of 3180 MW from 2019 Xcel 10-K.
8 Charging Perks Pilot:
9 Public Comments on Proceeding No. 19AL-0687E “TOR, Not TOU:”
10 Critical Peak Pricing:
11 EV Service Pilot Customer Service Agreement:
(when the much larger numbers of low mileage drivers actually have the greatest
flexibility in scheduling their charging, especially with the relatively large battery capacity
of modern EVs). Depending on the actual break-even point of the flat rate fee, however,
this does illustrate a refreshingly progressive line of thinking when it comes to offering
savings to customers.
For all of these programs, the details of how they actually work are not publicly available, and no
results have been published. Instead of sharing what they’ve already learned and showing a
good-faith effort to truly do what’s best for Colorado and its customers, Xcel is trying to justify
spending tens of millions of dollars on charging infrastructure with a cost-benefit analysis that
fails to clearly show how they’re going to actually maximize the benefits of said infrastructure.
Instead, the PUC should require Xcel to:

  1. Share publicly the methods and all results of its EV-related pilots in Colorado and
    elsewhere around the country12
  2. Demonstrate that their TEP will be sustainable (i.e. not immediately require new
    generation or grid improvements by taking advantage of flexible EV charging demand)
    and maximally beneficial in the future by sharing data on renewable generation curtailed
    or dispatched to another utility through an EIM, both historical and future13
  3. Add a mechanism to the TEP which makes EV charging cost $0.00/kWh at times of
    renewable surplus14
  4. Set Performance Incentive Mechanisms (PIMs) directly related to beneficial
    transportation electrification15: 1) the increase in the proportion of EVs in the Company’s
    service territory and 2) demonstrated efficacy of shifting charging demand to use
    renewable energy16
    12 CRS 40-5-107 § 2f. “When considering transportation electrification programs and determining cost
    recovery for investments and other expenditures related to programs proposed by an electric public utility
    under subsection (1) of this section, the commission shall consider whether the investments and other
    expenditures are: (f) Transparent, incorporating public reporting requirements to inform design and
    commission policy”
    13 SB 19-077 § 1g. “Widespread adoption of electric vehicles should improve an electric public utility’s
    electrical system efficiency and operational flexibility, including the ability of the electric public utility to
    integrate variable renewable energy generation resources and to make use of off-peak generation
    resources.“ and CRS 40-5-107 § 2a. “When considering transportation electrification programs … the
    commission shall consider whether the investments and other expenditures are: (a) Reasonably expected
    to improve the use of the electric grid, including improved integration of renewable energy
    14 SB 19-077 § 1e. “Widespread adoption of electric vehicles should provide consumers with fuel cost
    savings and electric utility customers with potential cost-saving benefits” and 1g. “Widespread adoption of
    electric vehicles should improve an electric public utility’s electrical system efficiency and operational
    flexibility, including the ability of the electric public utility to integrate variable renewable energy generation
    resources and to make use of off-peak generation resources.”
    15 The PIMs outlined in the Direct Testimony and Attachment of Kevin D. Schwain—reported customer
    experience and level of participation in managed charging programs—do not align with any of the
    programmatic goals expressed in SB 19-077 § 1
    16 CRS 40-5-107 § 1b. “an application must seek to minimize overall costs and maximize overall benefits”
    Section 2: Equity
    Xcel’s TEP acknowledges equity as a priority and allocates roughly 15% of the total budget
    across the five component portfolios for low income customers. This is a good start and is in line
    with other utility EV plans . However, the details of these plans do not illustrate 17 a strong
    commitment to equity. The TEP taken as a whole will serve to widen the opportunity gap
    between those who can already afford EVs that they can charge at home and everybody else.
    Of course, some key elements of transportation equity are outside the purview of an electric
    utility. For example, incentives helping overcome the higher purchase cost of EVs come from
    the state. In addition, Xcel isn’t responsible for the distribution of dwelling types in its territory.
    However, a utility TEP should be expected to serve equity in several ways18:
  5. Equity in presumed mode of travel i.e. serves customers whether or not they own a car
  6. Equity in ease of access
  7. Equity in the secondary benefits of transportation electrification: financial savings, jobs,
    better air quality, grid improvements, etc.
    And Xcel’s TEP falls short in all three of these.
    Xcel’s proposal to expand access to chargers projects 26,750 charging ports through its
    residential program19, 1,281 ports through its multi-unit dwelling (MUD) program20, and 2,965
    ports through its commercial program21. This does not represent per-capita equality in charging
    access for Colorado’s 25.4% of households in structures of 3 or more units22, and it’s even
    worse when considering the relative inconvenience of negotiating shared chargers as opposed
    to private home chargers. Yes, infrastructure for chargers in MUDs is typically more expensive
    than in single family homes. But when the goal is equity and the costs are spread out over
    Xcel’s entire customer base, MUDs require a larger investment.
    17 Ihle Direct Testimony, Table JWI-D-1
    18 CRS 40-5-107 § 2h. “Widespread adoption of electric vehicles requires that public utilities increase
    access to electricity as transportation fuel, including for low- and moderate-income and underserved
    19 TEP page 18, table 4
    20 TEP page 24, table 6
    21 TEP page 30, table 8
    22 Per US Census 2018 ACS 1 year estimate
    Xcel’s TEP does include utility-owned DC fast chargers (DCFCs), which will be placed in
    locations that improve access to lower income or rural communities:
    Wishart Direct Testimony page 17
    Wishart Direct Testimony page 18
    This is a positive step in reaching underserved groups. Since these are expected to lose money,
    the balancing of accessibility benefit vs. public cost is basically arbitrary. When considering the
    target communities for these chargers and the expected time investment to access them, the
    maximal transportation electrification benefit would come from fully subsidized—free for
    low-income customers—charging. Or, at a minimum, the same per-kWh rate as the cheapest
    commercial competitor with no peak pricing surcharges.
    However, the proposed pricing for these public chargers is relatively high:
    Wishart Direct Testimony page 14 with added equivalent cost of gas23
    23Assuming 3 miles per kWh electric and 30 miles per gallon gas
    Wishart Direct Testimony page 13-14
    Keep in mind that the public charging providers are able to benefit from TOU rates—as is
    Xcel—while an individual customer at a utility-owned DCFC is not. Also, citing range anxiety
    here assumes that customers in low-income and rural communities have access to, and indeed
    prefer to use, other chargers. Again, setting subsidized pricing on “not financially viable”
    chargers is fairly arbitrary, and Xcel seems to fall on the punitive side of that.
    Also, Xcel may have overlooked vehicle-side limitations on charging rate. Many older models24
    and even some newer models25 have maximum DC charging rates well below 2.5 kWh per
    minute (150 kW). As an example, the 2015 Nissan Leaf, which can reasonably be purchased
    pre-owned26, can only charge at 40 kW (0.67 kWh per minute). Using the same assumptions as
    in the modified table SWW-D-3 above, the driver of that 2015 Nissan Leaf would be paying the
    equivalent of $13.50 per gallon at Xcel’s standard rate. In the context of equity, this means that
    Xcel is proposing pricing that is relatively more expensive for those who cannot afford
    top-of-the-line electric cars.
    26 There were 13 Leafs available for under $10,000 within 50 miles of Denver as of 9/24/20:
    Then there’s the shockingly high CPP rate. Xcel attempts to minimize this concern:
    Wishart Direct Testimony page 16
    There are three problems with this argument. First, the assumption that a customer’s next
    charger might be within the example 30 mile range may not be valid for the low-income or rural
    communities these Xcel-owned chargers target.
    Second, $15 for those 30 miles is expensive! $15 could buy nearly 200 miles of gas27 instead.
    And, of course, it’s even worse for EVs that are slower to charge, like the previously cited 2015
    Nissan Leaf. A 10 kWh charge for that vehicle would take 15 minutes and cost $56.25.
    Yes, that’s exactly like paying $56.25/gallon for gas.
    27 Assuming 30 miles per gallon and $2.31/gallon of gas—Colorado’s average on 9/18/20 per AAA.
    Third, there’s the assertion that encountering CPP prices is “very unlikely” for drivers. This might
    be true if those 60 hours in a year were randomly distributed. Xcel’s own testimony refutes this:
    Wishart Direct Testimony Table SWW-D-4
    If one had wanted to charge on one’s way home in the afternoon any of the four days between
    6/26/18 and 6/29/18, one would have had a 100% chance of encountering elevated pricing.
    Suggesting that expensive rates at public chargers might be avoidable by charging at home or
    work highlights another layer of inequity in this TEP. Simply, customers primarily using shared
    chargers, whether through the commercial or MUD portfolios, will be subject 28 to the high costs
    of on-peak charging without having access to the savings of off-peak charging. This applies
    both to the rebates associated with the residential managed charging options and the flexibility
    to easily defer charging until off-peak rates take effect. Ways to improve equity would include 1)
    focusing on assigned parking MUD chargers and 2) rates based on gross usage (with discounts
    timed to renewables generation) without a TOU component.
    Finally, there’s the question of equity in the secondary benefits of transportation electrification.
    This is harder to judge based on the relatively high-level content of the TEP. The
    underwhelming approach to equity already discussed suggests that there’s some work to be
    done, but hopefully Xcel has designed its Advisory and Research, Innovation, and Partnerships
    portfolios in accordance with existing best practices for transportation equity.29,30
    With all that, the PUC should require Xcel to:
  8. Increase the overall investment in the MUD portfolio, especially for assigned parking
  9. Start over again on their Xcel-owned DCFC pricing, charging per kWh while charging
    and applying a separate fee for occupying an idle charger (after a reasonable grace
    period like 20 minutes post completion of charging)
  10. Make Xcel-owned DCFCs free to use for low-income and other underserved populations
  11. Prioritize Shared Mobility and Fleet Charging—both on Example Projects list in
    Research, Innovation, and Partnerships
  12. Define the process whereby the jobs that result from the TEP will be assigned on an
    equitable basis
    Dan Regelson is a policy analyst for . He’s a lifelong Coloradoan with an
    electrical engineering degree from the University of Colorado Boulder and ten years experience
    as an engineer in the optics manufacturing industry.
    28 Assigned parking chargers can benefit from managed parking. Shared parking may or may not
    depending on 1) number of EVs competing for charging ports and 2) unspecified “access policies and
    billing arrangements” (TEP page 21-22) as configured by the site host.
    29 Greenlining Institute Mobility Equity Framework:
    30 USDN Guidebook on Clean Energy Program Design:

Authorizes invest


Report late 2022

If favorable for CO 2023 – legislation enabling

Would then require a rulemaking at the PUC – begin late 2023

Best case late 2024

Glen –

Savings for income qualifying families

Email announcement –

Got shut down…

Coop process – highlight partners

Compliance came back and said select an installer, undermines SC

2025 – Communities