December 14, 2022 — Report

Authors: Nancy Ryan, Partner, eMobility Advisors; Alissa Burger, Regional Policy Director, CALSTART; Jenifer Bosco & John Howat National Consumer Law Center; Miles Muller, Natural Resources Defense Council

The report, Best Practices for Sustainable Commercial EV Rates and PURPA 111(d) Implementation, summarizes commercial EV rate design solutions put forth so far by utilities across the country and distills a set of core principles for future rate reform efforts required by amendments to PURPA 111(d) under the infrastructure Investment and Jobs Act. The report discusses how regulators and utilities can look to rates recently adopted in several states as helpful models for designing long-term, sustainable solutions for improving the economics of commercial EV charging, without subsidizing EV charging or shifting costs to other customers.

Traditional commercial and industrial rates—designed for large buildings and industrial operations rather than electric buses, trucks, and public fast charging stations—can present a barrier to commercial EV adoption by erasing fuel cost savings relative to gasoline or diesel. Fortunately, some utilities have already recognized the imperative of commercial EV rate reform and that an electric transit bus that charges overnight isn’t the same thing as a factory that’s running around the clock. The amendments to PURPA 111(d) now require regulators and nonregulated utilities that haven’t already followed suit to consider new rates to support transportation electrification. The report provides a roadmap for regulators and utilities looking to develop new commercial EV rates consistent with the PURPA 111(d) amendments.