## Facts

- The Connecticut Light and Power Company (CL&P) filed a request with the Connecticut Public Utilities Regulatory Authority (PURA) seeking approval of a pilot rate program for direct-current (DC) fast-charging stations for electric vehicles planned for deployment along Connecticut state highways.
- Under CL&P’s existing commercial rate design, a DC fast-charging station would be billed under a structure with two primary components:
  - a demand charge tied to the customer’s monthly peak demand (reflecting the utility’s obligation to maintain sufficient capacity), and
  - an energy charge based on actual kilowatt-hours (kWh) consumed.
- For DC fast-charging equipment, peak capability is high even when actual energy delivered is low, especially in the initial rollout period.
- CL&P projected that, during early deployment, the charging stations’ utilization would be only about 2% to 5%.
- CL&P explained that, at those utilization levels, the demand-charge component would dominate monthly bills and drive the effective energy price above $1 per kWh, making operation of the stations economically impracticable.
- To address this mismatch between how costs were billed and how energy would be used during the pilot period, CL&P proposed an electric-vehicle “rate rider” limited to participating DC fast-charging customers.
- Under the proposed rider, the demand-charge component otherwise applicable to those stations would be converted into an equivalent per‑kWh charge applied to all kWh consumed, so that the customer’s bill would more closely track actual charging activity rather than peak capacity.
- CL&P characterized the rider as a pilot mechanism intended to support early DC fast-charger deployment and to gather experience with usage and billing impacts for this new load type.

## Issues

1. Whether PURA should approve CL&P’s proposed electric‑vehicle rate rider pilot that converts demand charges into an equivalent per‑kWh charge for DC fast‑charging stations to address excessive effective rates during low initial utilization.

## Decision

- PURA approved CL&P’s proposed electric‑vehicle rate rider pilot program, permitting the demand-charge component for participating DC fast‑charging stations to be restructured into an equivalent per‑kWh charge.

## Legal Principles

- PURA may approve a pilot rate rider for a narrowly defined customer class when the existing tariff design would yield extreme effective prices that are not aligned with expected usage for an emerging technology.
- A demand-charge component may be recovered through an alternative volumetric (per‑kWh) mechanism on a limited, pilot basis when low utilization would otherwise cause demand charges to overwhelm bills and impede early deployment of DC fast-charging service.
- In evaluating a proposed pilot rider, PURA may consider whether the rider is limited in scope, addresses a demonstrated billing problem created by the interaction of high peak capability and low early usage, and supports state transportation and infrastructure objectives tied to highway fast-charging availability.

## Conclusion

PURA granted CL&P’s request for an EV rate rider pilot for DC fast-charging stations on state highways, allowing demand charges that would otherwise apply under the commercial tariff to be converted into an equivalent per‑kWh charge so that bills during the early, low‑utilization phase would better track actual energy use and avoid extreme effective per‑kWh costs.


Request of Connecticut Light & Power Co. v. Public Utilities Regulatory Authority, 2014 WL 2801554 (Conn. Pub. Utils. Reg. Auth. 2014)