Comment Log Display

To: whom it may concern:
Date: 8/18/09
From: Richard Lowenthal, CEO of Coulomb Technologies
Regarding: 30 day notice of metering language

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In section (c )(3) ( C ) 1 in the metering language, it says:


1. For residential charging stations, the total electricity
dispensed (in kWh) to all vehicles at each residence based
on direct metering, which distinguishes electricity delivered
for transportation use. Before January 1, 2015, “based on
direct metering” means either:

a. the use of direct metering (also called submetering) to
measure the electricity directly dispensed to all
vehicles at each residential charging station; or

b. for households and residences only where direct
metering has not been installed, the regulated party
may report the total electricity dispensed at each
residential charging station using another method that
the regulated party demonstrates to the Executive
Officer’s satisfaction is substantially similar to the use
of direct metering under section (c)(3)(C)1.a..



…. But we believe it should say:

1. For charging stations, the total electricity
dispensed (in kWh) to all vehicles based
on direct metering, which distinguishes electricity delivered
for transportation use. Before January 1, 2015, “based on
direct metering” means either:

a. the use of direct metering (also called submetering) to
measure the electricity directly dispensed to all
vehicles at each charging station; or

b. Where direct
metering has not been installed, the regulated party
may report the total electricity dispensed at each
charging station using another method that
the regulated party demonstrates to the Executive
Officer’s satisfaction is substantially similar to the use
of direct metering under section (c)(3)(C)1.a..b. Where direct
metering has not been installed, the regulated party
may report the total electricity dispensed at each
charging station using another method that
the regulated party demonstrates to the Executive
Officer’s satisfaction is substantially similar to the use
of direct metering under section (c)(3)(C)1.a..

Justification:
We see a lot of charging stations installed outside households and
residences, even when the station is for residential use.  For
example we have installed curbside charging for people who do not
have a home garage, but the stations are on meters shared for other
purposes.  In San Jose, we have stations on meters that are also
used for traffic signals.  In parking lots we are usually on a
circuit which is also used for lighting.  We also want to be sure
that in mixed use retail-housing parking lots, that these metering
provisions are effective.  In cities like San Francisco the
majority of vehicle charging for residents will not be in a home
garage and so this provision must apply outside the home garage. 
San Francisco residents mostly park on-street, with the next most
common place being in shared parking lots.   We shouldn’t leave
those residents out of this provision.   

Thank you for your consideration,
Richard Lowenthal