CPUC Decision on “Limited Load Profiles” Offers Important Solution for Faster EV Charger Rollout in California

The California Public Utilities Commission (CPUC) created a new pathway for electric vehicle (EV) chargers and other load projects to avoid long delays to connect to the electric grid. The new “limited load profile” option allows projects to take advantage of existing grid capacity while they await grid upgrades. The ruling was significantly shaped by recommendations from the Interstate Renewable Energy Council (IREC), an independent nonprofit that has led efforts to enable more flexible connection options for both load and generation. 

“This is an important step forward. Projects will no longer need to remain offline while grid upgrades are completed—they can now make productive use of existing capacity,” said Sky Stanfield, regulatory counsel for IREC and partner at Shute, Mihaly, & Weinberger LLP.

A limited load profile is a schedule of how much power the system can draw from the grid at different times of the day or year, based upon when capacity is available. The decision establishes the use of limited load profiles as a temporary, “bridging solution” that projects may utilize to get connected and start operating while waiting for the utility to complete grid upgrades. Historically, if the electric grid required upgrades to safely and reliably supply the maximum amount of power a project required, projects could not connect until the utility completed those upgrades—the construction of which can take years. The use of limited load profiles, a type of “flexible service connection,” changes this scenario. 

Using load control methods, which limit how much power a system pulls from the grid, a project developer can ensure that their system will not exceed the power supply currently available at its location. Limited load profiles will not be available at every site and may not work for customers with limited charging flexibility, but they could provide a way for some customers to get online months or even years earlier than they would have otherwise. While some utilities have offered this option through pilot programs or at their discretion, this ruling is the first instance that IREC has seen of state utility regulators requiring utilities to offer limited load profiles to customers seeking to energize load projects. 

Initially, the ruling applies only to two of the state’s three leading investor-owned utilities, Pacific Gas & Electric (PG&E) and Southern California Edison (SCE), and builds upon pilot programs for limited load profiles that each of those utilities had been running. It does not currently apply to San Diego Gas & Electric (SDG&E) or Pacificorp, though regulators included a provision allowing parties to petition to expand the policy to those utilities in the future.  

The ruling specifies multiple allowable options for load control. The preferred option is the use of a power control system (PCS) certified to UL Standard 3141 for import limiting. While the order also allows customers to use load control methods other than a certified PCS, in those cases, the load profile will be much more limited, as it is required to stay within the capacity rating of the grid equipment.

The ruling also increases information access for developers by requiring the utilities to provide a “preliminary capacity assessment” within 30 days. This assessment is critical for customers to be able to evaluate whether there is power at the site prior to making significant investments in the full site procurement and application process.  

While the ruling is a positive step toward faster rollout of EV charging infrastructure in California that IREC applauds, there are areas where further clarification would be beneficial. 

First, regarding the “emergency rating,” IREC has some concerns about how this will impact the usability of the program. Utilities’ emergency equipment ratings are not public information, making it hard to determine if limited load profiles based on them will actually deliver meaningful amounts of capacity to projects in the way that the program is intended to. This is significant because certified PCSs may be cost-prohibitive for EV charging developers, particularly if their use is intended to be temporary. IREC recommends that the Commission further develop the record and resolve the open questions regarding capacity ratings, to determine how usable this option will be for customers without certified PCS.

Second, the ruling includes a “safe harbor” clause, which states that controlled load (i.e., load that does not increase the maximum power being pulled from the utility’s electric distribution grid) is not to be counted against grid equipment ratings. IREC has some concerns about potential grid safety and reliability implications of this approach. Ideally, the rulemaking process would have included details on the nature of these safe harbor requirements and an opportunity for parties to submit comments so that implications could be considered in the design of the limited load profile offering. 

“Today’s ruling is a significant milestone for the rapid development of electric transportation charging infrastructure,” said IREC Chief Regulatory Engineer Brian Lydic. "With it, California continues to lead the way in pioneering new approaches to flexibly integrate distributed generation and load into the grid in ways that support broader climate and clean energy goals.”

IREC commends the CPUC for its approach in this ruling and looks forward to continuing to engage in related regulatory processes to refine how this policy will work in practice. 

IREC | irecusa.org