Forward Looking Plan
The EV charging incentive program that was approved by the Public Utilities Regulatory Authority (PURA) was a thoughtful and forward-looking approach to support EV adoption and the flexible evolution of the grid.
It is considered a best practice for programs that hope to incentivize investment, supply chains, encourage changes in consumer behavior to be of lengthy duration. This was approved as a 9-year program. (Similarly, the federal Inflation Reduction Act, which more directly leaned into industrial policy, was a 10-year program.) The EV charging program, begun in 2022, has commercial and residential components and was essentially 2 programs joined at the hip. The first part is support for acquiring and installing an EV charging equipment. The second part, mainly focused on residential, is known as managed charging, and provides a financial incentive to charge-up during off-peak hours. As electricity demand rises, this kind of “load-shifting” strategy adds flexibility and resiliency to the grid.
So much for best-laid plans because, well, politics. In what we thought was an ill-considered move (we wrote about why in detail here), the residential program took a substantial hit in January of this year following legislation passed last year cutting the program funding by about one-third. Eligibility for the residential single-family charging incentive became restricted to income limited households and households living in high-poverty census tracts. It is estimated that participation will be reduced by 97% with downstream effects on managed charging enrollment.
Revisions Being Contemplated for Small (SMUD) and Large Multi Unit Dwellings (LMUD)
In a currently ongoing proceeding, Eversource convened a working group (EV Club was an invitee) to assess the design of the remaining parts of the residential incentive, those that apply to multi-unit dwellings, which are subdivided into small (2-4 units) and large (5+ units). This process has nothing to do with the legislature. It is an opportunity to take a step back and review potential improvements to the MUD portion of the incentive. These have somewhat different rules and apply to a more complex landscape. Eversource is developing recommendations to be submitted to PURA in August. The proposed changes discussed below have been submitted to the group for a final round of comments and will accompany the submission. A docket will be created and at that point the public at large can comment. It is expected that a final decision will be made before the end of the year.
SMUD – 2-4 unit building
One wrinkle in the SMUD incentive is that there are two paths to access it: residential or commercial.
A resident of an individual unit can access it on their own (single port). Or it can be accessed by the owner of the building and built for a minimum of 2 ports. These are the requirements and our opinion if we have one.
- Residential incentive eligibility only for income-limited individuals or high poverty/low opportunity (HPLO) areas.
- EV Club take – This is the income restriction that was passed last year by the legislature. The EV Club feels that the plain language of the statute (see below) specifies single-family, so why should it apply to multi-family?
Statute excerpt below:
(b) On and after January 1, 2026, the authority shall limit the expenses
for electric vehicle charging stations, as defined in section 16-19f, as
amended by this act, and customer wiring upgrades of any light-duty
electric vehicle charging program established by the authority in a
proceeding to twenty million dollars per year and further limit any
expenses for electric vehicle charging stations and customer wiring
upgrades incentivized as part of any residential single-family customer
program to residents who make less than or equal to three hundred per
cent of the federal poverty level or reside in any concentrated poverty
census tract, as defined in section 32-7x.
- The incentive level is $1500 to cover the cost of the hardware and installation, the same as the single-family incentive.
- EV Club note – If trenching or other significant make-ready type of expense is needed, it will likely defeat the project.
- Participation in managed charging for a minimum of 24 months is required for anyone taking this incentive. That brings with it an extra incentive of up to $300 annually.
SMUD Commercial
- Minimum of 2 ports required.
- There is a proposed change that in addition to standard 240-volt chargers, the building has the option of installing smart receptacles. These are 240 volt NEMA outlets, which are less expensive than chargers. The amperage of these can vary and the program allows for that. From the perspective of the program, it doesn’t matter whether it is low power, such as 20 amps, or a higher power such as 40 amps. It requires the vehicle owner to use their own cord. Sometimes an adaptor will be required.
- EV Club take – This is a sensible option to manage costs, though we would have also included an option for level 1.
- It is permissible to install residential grade EV chargers.
- EV Club take – This also makes sense. The previous requirement for commercial grade chargers is overkill for a small building.
- Incentive level is set to $1500 per port.
- EV Club take – This feels restrictive to us, again in the context of any needed make-ready. Eversource claims to have data that indicates it will be sufficient. If enough units for the entire building is wired, the incentive could be up to $6000 which at least allows some room for make ready expenses.
- Parking – Proposed change to relax parking requirements, such that it is no longer required that there be a specific space assignment for each EV port and that a space is no longer prevented from being assigned to an individual tenant.
- EV Club take – useful added flexibility.
- Participation in managed charging is optional. There is a managed charging pilot for commercial incentives. There are some technical considerations that make it more of a challenge for a multi-unit building to participate.
- EV Club take – we support getting as many people into managed charging as possible, and if a space is assigned to an owner/renter, we would like to see managed charging required if technically feasible.
Large MUD 5+ Units – Commercial Incentive Only
- Commercial-grade equipment required.
- Eligibility expanded to include not only standalone EV chargers but also level 2 smart outlets or level 1 smart outlets.
- Standard charger minimum of 2 ports. Same for L2 smart outlets. Level 1 has a minimum of 5 ports.
- EV Club take – We welcome this flexibility. The inclusion of level 1 ports for a significant proportion of units could be a way to get many more people charging while using power efficiently, despite its slow speed. If L1 is used, we recommend making it 20 amps.
- Incentive is provided for either standard EV chargers OR L2 outlets OR L1 outlets.
- EV Club take – It appears to exclude a mix of charger modalities if you want the incentive. For example, in the case of a large building with deeded spaces for some residents, it seems sensible to us to permit a mix of shared and dedicated chargers, not necessarily of the same type.
- Incentive is capped at $1500 per unit with a $20,000 per site maximum (standard) or $40,000 max for underserved locations.
Going Forward
This is not final. Comments solicited for the proposal may or may not be incorporated into the August comments. There will then be an opportunity for the public to comment when PURA publishes them. When the docket is available for comment, we will let everyone know. Commenting on a PURA docket is a fairly unpleasant process due to the kludgy UI, but in our experience the comments are taken seriously.
Once everything is finalized, we will update our incentive page.