California’s Submetering Decision: A Game-Changer for VGI Solutions

California’s Submetering Decision: A Game-Changer for VGI Solutions

By Zach Woogen

In a decision that sets a new model for unlocking managed charging and “Vehicle to Everything” (V2X) bidirectional charging, California regulators last week approved a submetering protocol that allows customers to take advantage of EV-specific rates without needing to install a separate utility meter.  

This innovative approach uses networked EV chargers to measure electricity consumption, which has broad, significant implications for managed charging and other VGI use cases. Additionally, the decision establishes critical next steps for unlocking the use of vehicle telematics for submetering. 

The Vehicle Grid Integration Council (VGIC) celebrates the decision and commends the California Public Utilities Commission for its leadership. This critical development positions California to see increased participation in EV charging rates and demand response programs that support the grid. The decision also alleviates a crucial barrier to V2X adoption, unlocking new value for drivers, fleet operators, and the grid. 

Boosting Participation in EV-Specific Rates and Demand Response Programs 

California utilities offer residential and commercial EV-specific rates with low off-peak charging costs that reduce EV fueling costs. To date, participation in this compelling cost-saving opportunity has been limited due to the requirement that customers must install a separate utility meter to measure EV charging, which adds costs, delays deployment, and may be unfeasible due to physical space constraints. The new submetering approach alleviates this barrier by allowing a low-cost alternative to installing a new utility meter. 

Alleviating Barriers to V2X Backup Power and Customer Bill Management 

V2X bidirectional charging systems can discharge from the EV battery to serve a customer’s onsite load, or export to the grid without compromising mobility needs. Without submetering, customers seeking to use V2X backup power systems (e.g., Ford Motor Company’s Intelligent Backup Power) must forego the opportunity to participate in effective EV-specific rates. Similarly, customers seeking to use V2X bidirectional charging systems to meet site load, for example, to manage demand chargers would be unable to do so if they wish to take service under a compelling, separately metered EV-specific rate.

The new submetering decision no longer puts dynamic EV-specific rates at odds with V2X bidirectional charging. Instead, it supports customers looking to leverage both strategies and, in turn, unlocks compelling value for customers and the grid at large. This is a game-changer for V2X bidirectional charging solutions that provide backup power during grid outages, reduce electricity bills by managing site load, strengthen grid reliability by exporting to the grid, and support the integration of renewable energy. 

Submetering in New York and VGIC Presenting at Upcoming Workshop 

Meanwhile, regulators in New York recently approved new managed charging programs for residential customers, and stakeholders will convene on August 18th to explore submetering and other technical considerations to promote VGI. VGIC will be a workshop presenter and share strategies to implement submetering and implications for V2X bidirectional charging. Following the workshop, utilities will soon file implementation plans for each managed charging program, which will represent a significant step forward for New York’s VGI market. 

Steppingstone to the Use of Vehicle Telematics for Submetering 

The California and New York orders represent strong foundations for facilitating the use of vehicle telematics to measure EV charging. Both states are poised to consider a process over the next 1 to 2 years to incorporate vehicle telematics into submetering approaches. Using vehicle telematics to submeter EV charging is done today in many utility programs to support customers who charge from a standard 120V wall outlet, or “Level 1” charger, those who do not have a networked Level 2 charger, and those who prefer to measure charging via the vehicle rather than a charger,  such as some commercial fleets. 


We are excited by the policy innovation discussions underway in California and New York, and we will continue to engage in advancing these scopes of work to help support the transition to a decarbonized transportation and electric sector.

The VGIC is committed to advancing the role of electric vehicles and smart EV charging and discharging through policy development, education, outreach, and research.

To learn more about VGIC and the role it plays in unlocking the value of EVs and smart EV charging as a strategic grid resource,