Draft Resolution Would Advance Utility-Controlled EV Load Management While Deferring Bi-Directional Hardware Support

The CPUC issued Draft Resolution E-5452, which approves with modifications SCE's request to update its Low Carbon Fuel Standard Holdback Implementation Plan to add a new vehicle-grid integration program known as Orchestrated Charging and Advanced Resiliency for Distribution (ORCHARD).

TLDR: The main storyline is that California is treating EVs primarily as controllable load assets, not compensated grid-export resources. Market participants should plan around that sequencing. The earliest the CPUC will consider this item is March 19.

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ORCHARD would integrate a software layer into SCE’s Distributed Energy Resource management system to directly manage residential electric vehicle charging in order to:

• Reduce localized distribution peaks caused by Time-of-Use charging patterns;
• Defer transformer upgrades; and
• Lower system costs.

SCE targets enrollment of 25,000 customers on circuits with less than one megawatt of available capacity and at least 100 EVs. The program is limited to light-duty, residential drivers; the draft resolution declines intervenor requests to extend eligibility to medium- and heavy-duty vehicles.

The draft resolution authorizes $11,464,112 in LCFS holdback funds for the orchestrated load management component and approves a $75 sign-up incentive plus annually declining participation incentives starting at $50 and reaching $0 by the customer's fifth year of enrollment. The draft resolution requires SCE to file a supplemental Tier 2 advice letter detailing its budget and methodology for evaluating enrollment and incentive adjustments.

The draft resolution denies, without prejudice, SCE's proposed bi-directional charging equipment rebates, finding the justification insufficient. Specifically, SCE proposes no export compensation mechanism and instead relies on the pending Vehicle Grid Resource Proposal and a Dynamic Rate Pilot that, according to the Commission, lacks sufficient funds to cover the 8,700 targeted bi-directional participants.

The draft resolution also identifies ambiguity around required operational modes (Momentary Parallel vs. Isolated) and the associated interconnection requirements.

INSTANT ANALYSIS

This draft resolution approves utility-controlled managed charging while rejecting subsidized bidirectional hardware. ORCHARD’s orchestrated load management moves forward; Vehicle-to-Everything rebates do not. For now, the CPUC is backing distribution deferral through flexible load control, not export-based vehicle-to-grid economics without a defined compensation structure.

The Tier 2 advice letter requirement is substantive. SCE must provide detailed budget allocations, attrition and participation thresholds, incentive-adjustment methodology, and analysis of interaction with dynamic rates. That filing will shape whether ORCHARD remains a bounded pilot or becomes a scalable load-flexibility platform.

The draft resolution's treatment of the 20% resiliency expenditure requirement is also notable. SCE argued the threshold is "prohibitively difficult" to meet given the narrow definition of resiliency provided by the CPUC in 2020 decision (D.20-12-027). The draft resolution accepts that reasoning (in part because CARB recently added VGI to the pre-approved non-equity holdback project list). That interpretation could influence how PG&E and SDG&E frame their own holdback filings going forward.

WHO SHOULD CARE?

• Utilities' regulatory and grid-planning teams. This draft resolution affirms that managed charging qualifies for LCFS holdback support and can be framed as a distribution deferral tool. The draft resolution also suggests that Vehicle-to-Everything hardware incentives will face scrutiny absent a defined export compensation pathway.
• VGI aggregators and EV software platforms. The Commission is comfortable with utility-orchestrated load control at scale. Vendors positioned around one-way managed charging and Distributed Energy Resource Management System  integration have a clearer runway than those anchored in export monetization.
• Automotive OEMs and charging manufacturers. Bi-directional capability alone is not enough. Without rate design or compensation mechanisms, hardware-forward Vehicle-to-Grid strategies will struggle to secure ratepayer-backed incentives.
• Policy staff tracking legislation and load-shift goals. ORCHARD reinforces that load flexibility, not new infrastructure, is the near-term tool for meeting electrification-driven peak growth.
• Energy traders and Resource Adequacy modelers. If orchestrated charging scales, controllable EV load may increasingly factor into distribution planning and future flexible capacity assumptions.