SB 127 – Permits Direct Sales of EVs

SB 127, the bill permitting EV-exclusive manufacturers that do not have an existing dealer network to sell directly to open stores and service centers in CT is scheduled for a public hearing on Friday, Feb. 19th, beginning at 10 AM. We encourage everyone to submit written or oral testimony. Instructions and link to register below.

*TRANSPORTATION COMMITTEE

FRIDAY, FEBRUARY 19, 2021

The Transportation Committee will hold a public hearing on Friday February 19, 2021 at 10:00 A.M. via Zoom.  The public hearing will be recorded and can be viewed via YouTube Live.  In addition, the public hearing may be recorded and broadcast live on CT-N.com.  People who wish to testify via Zoom must register using the On-line Testimony Registration Form or copy this link into your browser https://zoom.us/webinar/register/WN_2SAYBsW_SQyu5CD7jU3VGA.  Registration will close on Thursday February 18, 2021 at 3:00 P.M.  Speaker order of approved registrants will be posted on the Transportation Committee website.  If you do not have internet access, you may provide testimony via telephone.  To register to testify by phone, call the Phone Registrant Line at (860) 240-0590 to leave your contact information.  Please email written testimony in PDF format to tratestimony@cga.ct.gov.  Testimony should clearly state testifier name and related bill information.  The Committee requests that testimony be limited to matters related to the items on the Agenda.  The first hour of the hearing is reserved for Elected and Public Officials.  Speakers will be limited to three minutes of testimony.  The Committee encourages witnesses to submit a written statement and to condense oral testimony to a summary of that statement.  All public hearing testimony, written and spoken, is public information. As such, it will be made available on the CGA website and indexed by internet search engines.

SB 718 – A Moratorium on New Fossil-Fuel Power Plants

SB 718 – This bill imposes a moratorium on building new fossil-fuel power plants. The immediate threat is the proposed Killingly natural gas power plant, which has already been issued some of the required permits by DEEP. We ask everyone to call as described below.

The Energy & Technology Committee has not raised SB 718, Senator Cohen’s bill to establish a moratorium on new fossil fuel plants. We need to show strong support for this by calling the Energy & Technology Committee TODAY (Thursday, February 11) and urging they raise this bill. The last day the Committee can raise this bill is Tuesday Feb 16, and tomorrow and Monday are state holidays, so today is the day to put on the pressure.

Here’s what to do:

Call (860) 240‑0430 – Very likely you will leave a message.

“My name is (YOUR NAME), I am calling from (YOUR TOWN), I am calling to urge that the Energy & Technology Committee raise Senate Bill 718 as a Committee Bill. We are facing a climate emergency, yet fossil fuel power plants are still being proposed and approved here in Connecticut. This bill would establish a moratorium on fossil fuel power plants, and it is crucial that the Committee discuss this important topic. Thank you.”

Direct Sales of Electric Vehicles (EVs) Should Be Permitted in CT

Post by Barry Kresch

Governor Lamont has signed onto the Transportation Climate Initiative (TCI), a regional cap and invest plan. At the same time, the state is falling behind the goals set forth in the Multi-State Zero Emission Vehicle Action Plan. The time has come to permit direct sales of EVs in CT.

Consumers deserve to come first and should be able to freely choose EVs that fit their lifestyles, needs, and budgets to accelerate the adoption of electric vehicles and more rapidly transition to a zero-carbon economy.

Outdated dealer franchise laws have been used as protectionism to prevent Tesla and other new EV manufacturers from opening stores in CT.

The EV Club is behind a new act, The EV Freedom Bill, that has been submitted to the legislature. It proposes that manufacturers that produce exclusively electric vehicles and have no existing franchised dealer network be permitted to sell their vehicles directly to the consumer. The definition of “sell” is inclusive. It encompasses sales, leasing, delivery, and service. It is important to specify these components. For example, even though Tesla has gained the right to lease (and conduct test drives) at its Milford service center, customers still have to go to New York to pick up their vehicles. (Even residents of the eastern part of the state must go to NY – they are not permitted to avail themselves of Tesla facilities in RI or MA.) The proposed bill also allows for new “ownership” models, such as subscription. The world is changing.

The bill obligates manufacturers to meet existing consumer protection laws (i.e. lemon laws) or regulations and to have an adequate plan to service their vehicles within the state.

Multi-State ZEV Action Plan

The state of CT is a signatory to the Multi-State ZEV Action Plan. This plan commits to getting 150,000 EVs on the road by 2025 and 500,000, about 20% of the fleet, by 2030. There were 12,624 as of July 1, 2020. That means we would need a compounded annual growth rate (CAGR) of 47.29% to hit the 2030 number, which translates to the state being in a pretty big hole. The chart below tracks needed CAGR for each data point I have since 2017. In this case, a rising line is a bad thing. (An updated number for January 1 is due to be reported soon.)

The ZEV Action Plan sets a goal but has no enforcement mechanism. It consequently relies on legislators, regulators, and citizens to make good decisions in order to get us there. The EV Freedom Bill is something that can have real near-term impact. Unlike other measures, such as purchase incentives, this will not cost the state any money. To the contrary, opening the state to innovative EV business models will increase buyer choice while positively contributing to public health, the achievement of our stated ZEV and emission-reduction goals, while generating revenue.

Opposition From Entrenched Interests

The roadblock to direct sales has been the dealership franchise laws. These laws, dating to the 1930’s, were passed at the time to protect independent business people who were opening dealerships to retail and service the products of an affiliated manufacturer. That was the manufacturers’ preferred method of expansion. But independent businesses, having gone to the trouble of establishing a market locally, sought to protect themselves from the possibility that an affiliated manufacturer would open up across the street and put them out of business. At the risk of repetition, the point was dealers seeking protection from their own affiliated manufacturers. These laws have now been re-purposed to prevent a manufacturer that doesn’t have a dealer network from opening stores. (It is due to these laws being so old that Tesla is now able to lease from its New Milford facility. Leasing didn’t exist at the time the laws were written and, therefore, wasn’t specifically prohibited.)

The auto dealership and manufacturer associations have effectively mobilized to block direct sales when it has come before the legislature in the past. They’re effective lobbyists. We would like to see them devote this level of effort to selling EVs.

Existing Auto Companies/Dealerships Not Selling EVs

It pains me to type that headline and I hope it changes at some point. This club supports all EVs, but we also have to recognize reality, and consider that this industry needs to evolve or adapt its model.

Tesla and other EV companies don’t want dealerships. Their position is that this model doesn’t work for them and they have a point! Legacy manufacturers have been slow to pivot to EVs and dealers have been even slower to sell them. This has been reported on extensively, by the NY Times, by the Sierra Club (74% of dealers nationally were not selling EVs in 2019), and others, including the EV Club of CT.

In the most recent EV Club analysis of DMV data, we saw that from July 2019 to July 2020, there was a net increase of 1827 EVs in the Department of Motor Vehicles’ registration file. 1361 of these were Tesla, a whopping 74%.

Club analysis of CHEAPR data similarly shows that less than 40% of the dealerships in the state have disbursed at least 10 rebates over the course of 5 plus years.

Aside from direct sales, other models are bubbling to the surface. One striking example is in Germany where Volkswagen has given up on its dealers to sell EVs. The company has gotten some good reviews for its ID.3 model (not available in the US) and has a larger, forthcoming ID.4 for which it is taking reservations. Sales of these vehicles in Germany are handled through VW Corporate. The dealers act as agents, providing test drives and delivering vehicles, for which they receive a fee. Importantly, the dealers do not take title to the cars, which changes the sales dynamic completely. This means that VW is taking on a major risk in terms of carrying costs, but nonetheless, feels it is worth it. UPDATE – Apparently, it is worth it. FeedSpot reports that with a successful introduction of the ID.3 in September, “Volkswagen passenger cars managed to leap to the number one spot in all-electric vehicles over the full-year 2020 with a share of 23.8% in Germany…”

It’s Not Only About Tesla

There are numerous EV startups poised to enter the market, and several that are taking reservations, such as Rivian and Lucid, have announced they plan to sell directly to consumers.

Even though the word “Tesla” was not included in previous versions of “direct sales” bills, those bills were written in such a way that they were only applicable to Tesla. The EV Freedom Bill applies to all EV manufacturers without a dealer network.

It Is About the Consumer

A study by Cox found that just one in three consumers were “very satisfied” with the dealership experience.

The Federal Trade Commission has blogged about this subject. Two sentences: “Dealers contend that it is important for regulators to prevent abuses of local dealers. This rationale appears unsupported…” “Such change can sometimes be difficult for established competitors that are used to operating in a particular way, but consumers can benefit from change that also challenges longstanding competitors.”

It Is About Connecticut

CT is the only state in the region that does not permit direct sales. Keeping out companies that manufacture environmentally friendly products sends exactly the wrong message to the kinds of innovative companies we seek to attract to the state to grow the economy. It undercuts what the state is communicating with the TCI, offshore wind, and the ZEV MOU.

Tesla and these new companies want to sell EVs in CT. Let’s let them. Let’s encourage them. Let’s buy them!

Note:

The bill now has a number: SB 127.

Please join us and reach out to your state legislators telling them you support this bill.  We need to lower our carbon footprint now. This really is a power of the people moment. If they hear from you, they will take notice.

An easy option is to use the Engage page that Tesla has set up. Non-Tesla owners can use it, though you will need to set up an account. It has a form letter, which can be customized. It will know who your legislators are.

You are also welcome to write your own thoughts. This is an online page that enables you to find out who your legislators are.

48% Month Over Month Drop in October Rebates

Newly released data, updated with transactions through October 31, show a decline from September to October from 97 to 59 rebates. (The September number was restated and is slightly higher than the initial reporting.) The expenditure for consumer rebates for the 10 months of the year to date is $587,000. The annual budget (including admin and dealer incentives) is $3 million. (The consolation is that the unspent funds will be rolled over into 2021.) There have been 62% fewer rebates issued year over year, Jan. through Oct. (546 vs 1435).

The Tesla Model 3 (15 rebates) and the Toyota Prius Prime (13) were the only vehicles in double digits for the month.

2020 has been a lost year in many ways that are more important than CHEAPR. But in our EV world, this incentive program has been in need of revamping and it hasn’t happened. We will discuss our take on why in a moment.

In another 6 -8 weeks or, we expect we’ll have the data to see if this was a lost year for EVs in general in CT.

We have blogged in the past about how we feel that CHEAPR has been a meaningful program, having given out over 6,000 rebates since inception. But rebate numbers, which had been steadily building, have reversed course since the changes in October 2019 that lowered the incentive levels and the MSRP cap, which was then further exacerbated by the recession.

Revisions to the program that were promised for 2020 are still pending. The most recent board meeting was on October 9th. There is no meeting posted on its website as of this writing. The CHEAPR board apparently remains divided as we await a vote on revised parameters. (This is our reading of the situation. The EV Club is not represented on the board, something we have requested.)

The legislation passed in May 2019 authorized a used EV incentive. A revised program plan was submitted to the board in July that included an income-limited used EV incentive and an income-limited supplemental incentive for new EVs. There has also been discussion of a time-limited “stimulus” incentive adder.

From our perspective, the impasse stems from whether to restore the base incentive and MSRP cap to the levels of before Oct 2019. (The used and supplemental incentives haven’t been areas of controversy.) DEEP is concerned that doing that and adding the new incentives risks depleting funds that could result in a temporary interruption in the program. They rely on modeling from their program consultant to assess this. (Though there was another round of modeling requested in October that has not been publicly disclosed to this point).

There was a second reason articulated by DEEP, which is that for the more expensive vehicles, consumers will buy them anyway, rebate or no. We don’t see it that way but won’t get further into that here.

Time to Restore the Prior Incentive Levels

The EV Club, along with the broader CT EV Coalition, believes there is a strong case for restoring the pre-October 2019 incentive levels and MSRP cap, along with introducing the used and supplemental incentives.

• The program is clearly failing this year.
• As of the most recently published EV registration data by the DMV in July, the state is losing ground relative to the commitments made in the Multi-state Zero Emission Vehicle Action Plan.
• There will be $4.9 million in available funds in 2021 due to this year’s underspending and some unused bridge funds from 2019, a 63% increase relative to budget.
• The recessionary economy is likely to persist for another 6 months. Let’s hope it is only that long. (It also makes for a difficult environment in which to model.)
• Due to the income-limitation aspect of the used and supplemental incentives, software development is required for implementation. They are thus unlikely to be ready for launch on January 1.
• The take rate for the used EV incentive is likely to be low in the short-term.
  • The incentive is income-limited.
  • The dealership representation on the board stated that the current market for used EVs is small. Our analysis of DMV registration files is consistent with this perspective.
  • As noted, the start date is unknown at this time.
  • There is still a shortage of charging infrastructure in the urban communities that this is intended to most benefit. This applies to the supplemental incentive as well. Over time, this will improve, but it will still be an issue in 2021.
• For BEVs, which, as noted in DEEP’s EV Roadmap, have a greater impact in lowering greenhouse gas emissions, there just aren’t a lot of them available under the current $42,000 cap. As EV introductions move more toward larger battery packs, EUVs, crossovers, and other popular (and larger) form-factors, this is likely to be even more the case.
• Even at the old (higher) levels, the CT plan is less generous than what is offered in other, nearby states.
• Finally, the EV Coalition intends to lobby for a larger share of the clean-air fee to be devoted to CHEAPR. If successful, the budget issue will be ameliorated. If not, there will be plenty of runway to make adjustments, not to mention empirical data as a basis on which to do so.

Few CHEAPR Rebates Given in August

Another tepid, desultory, underwhelming (I’m running out of adjectives – feel free to help in the comments) month for the CHEAPR program with only 40 rebates given out and a total dollar amount of $28,000. This is the second-lowest month of the year and continues the dispiriting (another adjective!) trend we have seen since November 2019. One interesting item: there were 9 rebates for the new Toyota RAV4 Prime plug-in hybrid. Between the RAV4 Prime and the Prius Prime, Toyota vehicles dominated the rebate activity. The reporting has been that the plug-in RAV4 Prime is a severely supply-constrained vehicle at present and there was some doubt that any would make it out of California, but apparently, they have.

Note: CHEAPR often restates the prior month when issuing new data. In this case, July has increased from 57 to 62 rebates and it is incorporated into the title graph.

Decision Time

The next CHEAPR meeting is scheduled for October 9 at 11:00 AM.

The Center for Sustainable Energy (CSE) presented a set of proposals for program revisions in July. The agenda includes a vote on the new program. The meeting is scheduled for only one hour, so we don’t expect much discussion. We do not know if this will be an up or down vote on the package or if the items will be considered individually. We know that despite 3 meetings and public comments, there isn’t a consensus on all the items.

This is what we know to the best of our information.

The package that will likely be presented to the board in October will have no differences relative to what was proposed in July.

• No e-bike incentive or even a pilot test. Ix-nay on this from the DEEP attorneys.
• A used-EV income-limited (lower/middle income, or LMI) incentive (non-controversial).
• A supplemental LMI EV incentive (non-controversial).
• No changes to base incentive levels or to the MSRP cap.
• No changes to the much higher fuel-cell vehicle incentive, which stands at $5000 with an MSRP cap of $60,000.

UPDATES as of 10/25/20

Modeling scenarios include:

• Maintaining the current (since 10/19) MSRP cap of $42K or raising it to $50K.
• Base BEV incentives of $2500 or $1500.
• A possible temporary “stimulus” additional sample of $1750 for BEVs and FCEVs, and $500 for PHEVs.
• $500 increase to $2500 for the LMI incentive.
• Possible inclusion of scenarios with base-level incentives less than $1500.

Incentive Levels and MSRP Cap

Much commentary, from board members, public attendees, and public comments, was in favor of raising the base incentives and the MSRP cap to at least where they were before DEEP lowered them in October 2019. These currently stand well below comparable incentive programs in nearby states. The CSE was tasked with modeling scenarios and they forecasted that there was a possibility that demand would exceed available funds, thus risking disruption. This blog doesn’t buy that line of argument for several reasons.

• A pandemic and recession of unknown duration make for a difficult environment in which to model. There is a lot of guesswork here, exacerbated by the fact that there are no empirical data on the take-rates for the new LMI incentives. A disruption would likely only occur if the economy roars back and the participation rates are at the high end of estimates.
• The dealership contingent spoke out for a higher MSRP cap. They argued that leases have grown in popularity to about half of all new car sales, and people can manage a lease payment on a vehicle they can’t afford to buy. Also, we are soon to see a wave of crossover and SUV EV launches, and these popular form factors are more expensive than sedans.
• Based on our analysis, and comments from the dealers, there isn’t much of a used EV market at this time. The incentive will help, but it will take some time for auction bids to be influenced such that inventory can build. Also, used Teslas are probably too expensive for an LMI limited buyer (and we don’t know how the rules will work for them – they may not qualify – something we will seek to find out).
• At the July meeting, when CSE proposed this incentive regime, they advised that the LMI system development would cause it not to be available until Q1 2021. We don’t know if they have been able to work on it during this period when the program isn’t finalized, but there could potentially be a delay.
• There is more money available – DEEP has indicated that the unspent funds from 2020 (they have only given out $398,000 in consumer rebates), as well as unspent bridge financing from 2019, will be rolled over into 2021. This will yield approximately $4.9 million in available funds (compared to the $3 million budget).
• The CHEAPR mission seems to be increasingly skewed towards the equity part of the mission. This blog supports the LMI incentives (and e-bikes, for that matter), but also sees the mission as just getting more EVs on the road. The program has fallen seriously short of that in the past year.

For these reasons, we think the best course is to raise the incentives and collect data. There will be plenty of time to course-correct if necessary. CHEAPR has an important role to play in moving people to drive electric. This is attested to by consumers, dealers, and our data. Let’s allow it to fulfill its potential.

Closing Pet Peeve

The $5000 fuel-cell rebate has never been given out in the 5+ years of the program’s existence, and there is no sign it will be anytime soon. You can’t buy one of these vehicles at present, and there is only 1 public hydrogen refueling station in the state. And yet, DEEP continues to use this as its headline incentive. It is misleading. It can be seen in the first sentence of the first paragraph on the CHEAPR home page. It was spoken out loud by Tracy Babbidge during the Sustainable Fairfield Webinar on September 28th. It was said by Victoria Hackett when she spoke at the Tesla leasing kickoff in February. Those are the occasions we are aware of but this is clearly not inadvertent. They are not helping themselves.

Editors Note: The October 9th meeting did not yield a resolution. A letter from the EV Coalition was debated that proposed a different structure. No vote was taken.

Meeting Details

We encourage members of the public to listen in! This is the Zoom info:

Webinar Information:

Join Zoom Meeting

https://ctdeep.zoom.us/j/99938032925

Meeting ID: 999 3803 2925

One tap mobile

+16468769923,,99938032925# US (New York)

Meeting ID: 999 3803 2925

Find your local number: https://ctdeep.zoom.us/u/adlDH6PJuC

An E-bike Pilot

Among the suggestions offered by members of the new CHEAPR board has been a pilot project for e-bike rebates.[1] This is most strongly advocated by those who are focused on lower-income households, which are often clustered in the state’s largest cities.

E-bikes are an emission-free mode of transportation and could provide another transportation modality option for people who can’t afford a car. Or it could be a cost-effective replacement for a second car.

E-bike Proposal Receives Divided Reception

An e-bike incentive has received a divided reception. If I were to characterize the opinions expressed during the public meetings and in the public comments submitted to DEEP, there seems to be support for an e-bike incentive, but with many opposed to its inclusion in CHEAPR.

The opposition to e-bikes being part of CHEAPR comes from two places. First, DEEP’s reading of the statutory language concludes that CHEAPR can only be used for vehicles and that e-bikes cannot be considered vehicles, or more specifically, ‘battery electric vehicles’ based on the language. That interpretation has been disputed,[2] but from DEEP’s perspective, this seems to be an end to the discussion.

The second reason is that a group that supports an e-bike purchase incentive feels that it should be done outside of CHEAPR with a separate pot of money to avoid being dilutive to getting EVs on the road.

The EV Club supports e-bike rebates. It would be preferable to have a new funding stream for them. Several people have pointed out that CHEAPR, which is funded by clean-air fees[3],  receives less than half of those fees, with the rest going to the general fund. We would like to see more of those funds diverted to supporting clean transportation, which could be where to source e-bike funding.

Proposal for E-bike Pilot

There is also the situation we are faced with this year. It is almost certain that CHEAPR will not spend its budget. The amount of money spent on rebates and dealership incentives in the first half of the year is only equal to about 22% of the $3 million budget on an annualized basis. No matter what changes are made to the program, it will be next to impossible to use these funds. The under-spending is due to the changes made to the program in October 2019 and exacerbated by the recession.

So, here’s our proposal. Create a carve-out and conduct an e-bike pilot in 2020 and into 2021. Allocate some reasonable budget, say in the range of $150,000 – $250,000, that would be a cap. We think this should be an LMI[4]-limited proposal, as the intent is not to subsidize e-bike purchase among affluent folks whose main interest is recreation. There would then be the opportunity to collect data. We could find out who is buying them, what they are being used for, and how effective the incentive is for motivating purchase and reducing emissions.

Rethinking the Cityscape

The broader context is that during our pandemic-induced lockdown, the clean-air benefits of having fewer cars on the road became palpable. That, coupled with fears about virus transmission while using mass transit, inspired many cities to think about what a more people-friendly, less polluted urban landscape/streetscape might look like. Cities and town centers have been closing streets to vehicular traffic and adding protected bike and pedestrian lanes. Parallel parking spaces have been converted to outdoor dining areas. Some of this is temporary and responsive because everything happened so fast. But it could be permanent, and we would all be better off for it.

The City of Hartford has a city-wide bicycle network plan approved, a Complete Streets ordinance, and a goal to reach 10% bicycle mode share by 2035 (in the Plan of Conservation and Development). Plans like this have not only environmental and lifestyle benefits, but they would reduce overall crash fatalities, especially for people walking and biking.

E-bike incentives are an idea worth exploring[5] and we have an opportunity to learn something about how such a program would work with funds that would otherwise remain unspent.

[1] Index of e-bike rebate support letters

[2] People for Bikes, 8/12/2020 – CT CHEAPR public comment and e-bicycle as vehicle legal analysis

[3] Total proceeds from the motor vehicle greenhouse gas reduction fee were estimated to be $8 million per year based on these two Office of Legislative Research reports, here and here.  Only $3 million per year from that fee revenue was dedicated to the CT CHEAPR EV incentives.

[4] Low to Moderate Income Household

[5] How E-Bike Incentive Programs are Used to Expand the Market, 2019

37 CHEAPR rebates in June

This tepid number was only slightly higher than the 27 in May, closing the quarter with a soft 81 rebates total and 275 for the first half of the year. This 275 compares to 818 during the first half of 2019.

Partly, this was due to the recession, but a lot of it has to do with the changes made to the program in October 2019, when the price cap for vehicle eligibility was lowered from $50K to $42K. You can see in the graph that the numbers immediately tanked in November and have stayed low.

CSE Proposal for CHEAPR Program Revisions

The CHEAPR board met on July 17th to entertain proposed program changes submitted by their consultant, the Center for Sustainable Energy (CSE). These proposed changes were a decidedly mixed bag. DEEP is accepting public comments until August 12th. Email comments to the at deep.mobilesources@ct.gov

These are our positions:

Open for Business – Tesla leasing in Milford

Tesla held its official kickoff of leasing vehicles directly to customers from its service center in Milford, CT.

The festivities opened with Mayor Ben Blake of Milford touting that the town has more EV charging stations than any town in CT and is the supercharger capitol of the state.

Bruce Becker, president of the EV Club of CT, moderated the event, noting that Tesla accounts for the majority of the increase in EV registrations year over year.

There were also speakers from CT DEEP, The Sierra Club, and the CT League of Conservation Voters.

Prospective leasing customers are permitted to take a test drive.

It is technically called a demonstration drive, and the wording in the liability release is a little different reflecting the fact that it is in the service of a prospective lease, but it’s a test drive.

The first step to direct sales?

Tesla is still not permitted to sell directly to consumers, unlike in our neighboring states of New York, Massachusetts, Rhode Island, and, for that matter, the majority of the country. What prevents Tesla from doing so are the so-named dealer franchise laws that were written decades ago to protect the dealerships from their own affiliated manufacturers. Those old laws did not address leasing which didn’t exist. Nonetheless, Tesla was careful, making sure they were legally buttoned up before taking this step. To be sure, this is only a first step, a foot in the door toward changing the law to permit direct sales. With other EV companies preparing to sell directly to consumers, if we in CT want to make a significant impact on emissions reduction, if consumers are to be given choice, it is only a matter of time.

Further coverage can be found in this article in the New Haven Business Journal.

Changes to CHEAPR = large decline in rebates

Club-member, Barry Kresch, penned an Op-Ed that was published in the Hartford Business Journal that discusses the early data regarding the impact of the way DEEP changed the parameters of the CT CHEAPR EV incentive program, and why rebates declined 71%. (This blog has also posted a couple of earlier entries about it here and here.) The incentive was lowered to a maximum of $1500 for a BEV and $500 for a PHEV, and eligibility restricted only to vehicles with an MSRP of no more than $42,000. The lower MSRP cap caused rebates for the Tesla Model 3 to practically disappear, but the effect goes deeper (pun intended).

The word count is constrained for these Op-Eds and the format does not permit graphical exhibits, so this post will be used to expand on a few points. First, these are the graphics from the CHEAPR stats page reflecting the pre and post periods relative to the date of the incentive changes (the incentive change was 10/15). The date range appears in the upper right portion of the image.

While most of the decline was Model 3 related, other vehicles were also affected. We note the steep falloff in the Chevy Bolt. The premium version of the 2020 Bolt begins at $41,985. Bolt rebates declined from 27 to 4. The BMW i3 no longer appears, and it had 2 rebates in the “pre” period. The Nissan Leaf declined from 16 to 4, and it is possible to exceed $42,000 with a Leaf Plus.

If the lowering of the price cap was intended to avoid subsidizing more affluent buyers, this is belied by the fact that the cap on fuel cell vehicles was raised to $60,000.

Massachusetts Incentive Program

As a point of comparison, the Massachusetts incentive program (back online after a brief hiatus) has incentives that are more generous than CHEAPR before the changes. The max incentive for a BEV is 67% higher at $2500. The PHEV rebate is triple CT at $1500 but the vehicle must have an electric range minimum of 25 miles to be eligible, which we think is a sensible requirement. Importantly, there is a price cap and it is $50,000, the same as CT before October 15th.

Current Incentive Structure Penalizes BEVs

We would like to underscore an important point. Batteries are the most expensive part of an EV and the lowering of the price cap, based on the above data, clearly tilts the incentives toward PHEVs, which have increased from 15% to 64% of the rebates. This works against maximizing the reduction of greenhouse gas emissions.

Do Incentives Work?

We have been asked this question. Perhaps what is still the best (and most extreme) example occurred in Georgia. At one time, GA had the fourth-highest number of EVs on the road of any state in the country, circa 2015. And it was due to one of the most generous incentives of any state: a $5000 state tax credit for the purchase or lease of a new EV. Not only was the incentive repealed in its entirety, but a $200 road-use tax was imposed on EVs. The result? Between June and August of 2015, EV sales plunged 89%. The road-use tax exceeds the amount of money paid in gas taxes by a typical ICE driver. And, of course, there are too few EV drivers to compensate for the decreasing ability of gas taxes to fund needed road improvements. It was clearly punitive toward EVs. It worked, but it also underscores the value of incentives. (Source: WSB-TV) The EV road use fee is reported to be the brainchild of the American Legislative Exchange Council (ALEC), the organization of conservative state legislators that writes draft legislation and often supports fossil-fuel interests. See this article in Consumer Reports.

Budget

With respect to DEEP managing its budget, there is one new item on the horizon, namely an incentive for used EVs. This was authorized by the legislature in the same bill that provided the new funding stream for CHEAPR. There has been no announcement from DEEP regarding when this may be implemented, how much the incentives would be, or whether there is any means-testing involved. This could conceivably be what caused DEEP to be concerned about their budget. Given that they were on track to be within their allotment, we think a data-gathering phase before implementing changes would have made for better-informed decisions.

This is the text of a letter that was sent to DEEP in response to the issuance of their EV Roadmap, which was published last month.

November 12, 2019

Commissioner Katie Dykes

Deputy Commissioner Vickie Hackett

CT Department of Energy and Environmental Protection 79 Elm St.

Hartford, CT 0610 DEEP.EnergyBureau@ct.gov

Dear Commissioner Dykes and Deputy Commissioner Hackett:

Thank you for the opportunity to provide comments in response to DEEP’s October 11, 2019 Notice and Opportunity to Comment on its draft Electric Vehicle Roadmap for Connecticut (draft Roadmap). The Connecticut Electric Vehicle Coalition (the EV Coalition or EVC) is a diverse group of clean energy advocates and businesses, organized labor, and environmental justice groups that support policies that will put more electric vehicles (EVs) on the road in Connecticut to achieve significant economic, public health, and climate benefits for our state.

The Connecticut EV coalition strongly supports the state creating a more strategic and ambitious strategy on zero emission vehicle (ZEV) deployment, one of several key strategies that will help the state tackle climate change, improve the public health and air quality, as well as create economic development opportunities for the state.

The EV Coalition appreciates the significant work that went into developing the draft Roadmap and looks forward to working with the Department to finalize a product that will serve as a useful guide for stakeholders and the State in equitably achieving transportation sector emissions reductions consistent with Global Warming Solutions Act (GWSA) goals.

The transportation sector is the largest source of greenhouse gas emissions in the State and responsible for the majority of smog-forming nitrogen oxide emissions. Connecticut will not achieve its GWSA commitments or achieve health-protective ambient air quality standards without significant electrification of transportation and reductions in vehicle miles traveled. To be effective, we believe that the Roadmap must strike the right balance between providing sufficient direction and avoiding over-prescription. The Roadmap should provide clear guidance to relevant market actors about expected roles and responsibilities and clarify both prioritization and timing for the recommendations in the document. At the same time, the Roadmap should eschew prescribing specific technologies, particularly given that technologies in the transportation sector are rapidly evolving and detailed specifications may become less appropriate over the duration of the Roadmap’s planning horizon.

With regard to prioritization, the Roadmap should clearly identify what needs to happen and when in order to ensure the state is on track to meet climate goals. The final Roadmap should include timeframes for its recommendations and identify high priority actions. As discussed further below, those high priority actions should include establishing aggressive public fleet electrification goals, including goals for transit fleets; conducting outreach to environmental justice communities to better understand local transportation and design electrified transportation solutions appropriate to each community; creation of a low-income EV rebate that is available for purchase of both new and used vehicles to help get more low-income residents into EVs; requiring the state’s utilities to develop electric rates that mitigate the impact that current demand charges have on deployment of fast-charging stations; recommending the adoption of EV-ready building codes so that all new construction is pre-wired for Level 2 EV charging; and recommending the elimination of the prohibition on direct sales of EVs in Connecticut, along with additional incentives for existing dealers to increase sales of EVs.

In prior comments, the EV Coalition urged DEEP to support its Roadmap with analysis of public charging infrastructure needs.1 We appreciate DEEP using the EVI Pro-Lite tool for this purpose in the draft Roadmap.2 DEEP should clarify, however, why the infrastructure need figures identified in the Roadmap using the EVI Pro-Lite tool differ from those provided in the final Governor’s Council on Climate Change recommendations,3 and include figures regarding the charging infrastructure needs for supporting 500,000 ZEVs in Connecticut in 2030. In addition, we urge DEEP to conduct sensitivities around key parameters (e.g., ratios of plug-in hybrid electric vehicles to battery electric vehicles, distributions of battery ranges across the vehicle fleet, and availability of home charging) to better understand ranges of public and workplace Level 2 (L2) and DC Fast Charging (DCFC) plug needs for 2030.

Recommendations regarding Equity:

The draft Roadmap minimally addresses equity and environmental justice issues. We commend the acknowledgement to prioritize these communities, but believe the final Roadmap needs to go further. Connecticut’s current transportation sector favors the single-occupancy vehicle and trucks. Low-income and minority communities are often among the worst affected by air pollution caused by these vehicles, affecting their respiratory and cardiovascular systems, and the environments in which they live. Any further action to electrify the state’s transportation sector needs to address outstanding equity issues. While the policies noted below are addressed within our comments on the relevant sections of the draft Roadmap, we present them below for emphasis.

Connecticut should provide incentives for the purchase of older model EV’s in order to expand the option of an EV purchase to low and moderate-income households. Currently, our EV rebates only apply to the sale or lease of a new EV, this should be altered to include a low- income rebate applicable to both new and used EVs so lower-income households can take advantage of the program.

In addition, a minimum percentage of the benefits of electrified transportation programs should be established for environmental justice communities and state-identified Economic Opportunity Zones. In addition to the types of community-specific programs intended to identify electrified solutions to the specific transportation needs of these communities (discussed below), it may be appropriate to carve out a percentage of EV charging stations to be sited in environmental justice communities particularly in areas where residents shop, work, and attend school and church.

Since public transportation is more widely used in low-income and minority communities the Roadmap should also prioritize the need for more electric buses and school buses. Electric buses do double-duty – they reduce emissions and take cars off the road, lessening Connecticut’s road congestion problems.

With the proper mix of EV charging stations, EV rebates, and electric buses, we can ensure that the Roadmap properly acknowledges our most overburdened and underserved communities.

Recommendations regarding Public and Private Fleets:

 While public fleets comprise only a small fraction of total vehicles in Connecticut, they are ideally designed for the state to truly “lead by example.” Studies show that increasing consumer awareness and familiarity with electric vehicles is important in influencing consumer purchasing decisions. Public fleets are one of the areas where Connecticut has the greatest direct control over the rate of vehicle electrification and creates opportunities to (1) increase direct EV driving experience with state employees and (2) increase the public visibility of EVs on our roads.

The current recommendation regarding the state fleet in the draft Roadmap—that the state “should consider setting targets for annual EV procurement for the state fleet, beginning with the goal of 5 percent of state vehicle in the first year”—is too weak: The state must set aggressive targets for electrifying public fleet vehicles.

Section 93 of Public Act 19-117,4 establishes several targets for EV deployment within the state fleet, which should inform the recommendation in the EV Roadmap.

• PA 19-117 requires, beginning January 1, 2030, that at least 50 percent of cars and light-duty trucks, and 30 percent of buses, purchased or leased for the state fleet to be “zero-emission.”
  • In light of the state’s express policy of reducing GHG emissions and need to reduce other air pollutants, we urge the state to go beyond the minimums established by the legislature and adopt a policy of procuring 100 percent zero-emission vehicles where such vehicles meet the performance needs for which they will be used, leading to stronger public fleet commitments: with a goal of ensuring that at least 50 percent of the cars and light-duty trucks and 30 percent of transit buses in the State’s fleet are zero-emission by 2030.
• PA 19-117 expands the Department of Administrative Services (DAS) commissioner’s annual legislative reporting requirements to include a procurement plan that aligns with these state fleet requirements and a feasibility assessment for the state’s purchase or lease of zero-emission medium and heavy-duty trucks; and
  • In alignment with the policy recommendation above, the feasibility analysis should be limited to the ability of commercially-available zero-emission vehicles to meet the performance needs required by the state. Any cost-benefit analysis should include estimated fueling and maintenance costs over the full useful life of the vehicle.
• PA 19-117 requires the DAS commissioner to study the feasibility of creating a competitive bid process for procurement of zero-emission vehicles and buses, and authorizes the commissioner to proceed if it would achieve cost savings.
  • The final EV Roadmap should encourage DAS to explore this option, as well as the possibility of joint procurement opportunities with municipalities and other

Regarding DEEP’s recommendation to update and publish guidelines for the installation of EVSE at state-owned facilities and public and private EV charging stations, DEEP has the authority to do this, and we encourage the agency to move forward with this activity. Using its ability to “lead by example,” state-owned and operated facilities should adopt minimum percentage charging requirements for parking areas, and such requirements should be included within all state-funded school construction projects. DEEP promoted similar recommendations to be included within the state building code for new residential and commercial construction, and these recommendations should establish the floor for state-owned and operated buildings.

Connecticut should support and incentivize electrification of private fleets by: (1) working with private actors and utilities to provide advisory services to fleet owners considering electrification; (2) developing rebates or incentives to support associated charging infrastructure needs; and (3) requiring utilities to develop rate designs that mitigate the impact of demand charges.

Recommendations regarding EVs beyond LDVs:

We strongly support incentives to electrify MDV and HDV. Connecticut should look to New York’s truck voucher incentive program5 to identify ways to incentivize purchases of cleaner, electric MDV and HDV.

While we encourage including fleet conversion to EVs as part of the electric utilities’ distribution system planning, DEEP should recognize that private fleet charging depots will likely need to be sited on-premises, so it may not be possible to target underutilized electric distribution circuits for fleet charging depots.

Accordingly, we should not let load decisions be the sole determinant in driving our EV infrastructure decisions. While it is clear that there are potential benefits from using EVs as a source of load smoothing and energy storage, the EV Roadmap should prioritize infrastructure investment where such investments will meet EV demand and benefit local communities. The goal should be to develop a comprehensive plan for building out our charging infrastructure in a manner that maximizes the combined, total benefits of increased EV deployment.

As noted in the GC3’s December 2018 Report, some of the largest GHG reductions from the transportation sector are likely to be achieved by increased investment in EV buses6, and these investments will likely be in our largest cities and most heavily-trafficked transportation corridors. While these are likely not areas with excess distribution capacity, nevertheless this is one critical area where investment must be made. The electric distribution companies (EDCs) should provide location-specific maps where excess distribution capacity exists so they may be evaluated against other criterial that would support investment in EV charging infrastructure.

Additionally, EV time-of-use rates can be an effective mechanism for shifting vehicle charging to off-peak times when the distribution system may be otherwise underutilized.

With respect to the pending California Advance Clean Trucks rule, we encourage Connecticut to continue to develop policies that leverage California’s authority to enact stringent motor vehicle emissions standards and polices beyond the floor established by the federal government. We should not pause our efforts pending the outcome of the current federal lawsuit, but rather position ourselves to act quickly when the court rules in favor of California and Section 177 states, including Connecticut.

Recommendations regarding Expanding EV Charging Infrastructure:

1. Building codes and permitting requirement recommendations

To encourage widespread adoption of EVs to meet Connecticut’s GHG reduction goals, policies must support the necessary infrastructure build-out to encourage consumer confidence with respect to “range anxiety” and support public education regarding EV technology. One critical component is expanding EV charging infrastructure, particularly in settings that vehicle purchasers cannot directly control (e.g., charging in public and semi-public/workplace settings, charging at multi-unit dwellings). It is also critical that new construction be capable of supporting EV charging infrastructure so that charging stations can be cost-effectively added as the need for them grows.

There is widespread consensus that the best time to prepare a location for the future installation of EV charging infrastructure is during the initial construction, rather than post-construction retrofitting. A recent analysis by Energy Solutions for the California Electric Transportation Coalition (CalETC) found that installing EV ready parking spaces during a building retrofit can save four to six times the cost of a standalone installation.7

The EV Coalition strongly supports the adoption of EV-ready building codes. DEEP must be an active participant in the adoption of updated building codes to ensure the necessary accessibility to EV charging as market penetration of EVs increases. To that end, DEEP should support adoption of EV-ready legislation through provision of templates for use in municipal building codes and zoning ordinances. The State has been presented with the opportunity to support EV-ready construction and has so far failed to act. The Code Adoption subcommittee of the State Codes and Standards Committee recently declined to adopt “EV ready” standards for new residential and commercial construction, citing increased cost and the relatively low number of EVs currently registered in Connecticut. This narrow view fails to adequately take into account the cost of building retrofits to accommodate charging infrastructure, as well as the clear market and industry signals regarding the future trajectory of EV adoption nationwide. The State must take this opportunity to support EV-ready infrastructure and enable Connecticut to lead the way toward an emissions-free transportation sector.

Additionally, local zoning requirements must not act as a barrier to deploying EV infrastructure in residential or commercial structures. Rather, requirements should encourage expansion of EV-ready infrastructure. Parking requirements must take into account the need to support a minimum level of EV charging spaces, as appropriate for the particular building structure. At a minimum DEEP should support building codes that mandate 10 percent of spaces be pre-wired for EV charging. Relating to ADA requirements, the Codes committee need not establish new ADA-compliant requirements; rather, the committee needs only to clarify how EV charging stations should comply with existing ADA requirements.

We support DEEP’s recommendation to consolidate permitting for Level 2 EVSE and DCFC installations. Such permitting would be better streamlined if: (1) applications could be submitted electronically and (2) a schedule of permit prices were published.

1. Siting recommendations

While grid impacts should be minimized if and when possible, that should not be the sole determining factor in site selection. Rather, demand and transportation needs should be allowed to shape charging infrastructure location.

1. Public charging infrastructure ownership recommendations

The EV Coalition supports DEEP’s recommendation that EDCs be permitted to rate-base make-ready investments in EV supply equipment in appropriate contexts. Utilities are uniquely positioned to encourage development of public EV charging infrastructure. DEEP should advocate in the PURA docket a clear expectation that utilities will submit proposals to support deployment of public EV charging stations.

As discussed further in other sections of these comments, carve-outs to ensure a percentage of EV charging stations are located in low-income and underserved communities are well-intentioned, but may not be the best way to support the transportation needs of these communities. The objective should be to improve access to clean, electrified transportation options that also improve public health, rather than proportional deployment of EV charging stations. Investments in low-income and underserved communities must be tailored to their specific transportation needs. For example, investments in electrified car or ride-sharing services or electrified transit buses may be more beneficial than charging infrastructure for certain communities. Community-specific assessments are necessary to determine the transportation needs of different communities.

Recommendations regarding Consumer Charging Experience, Interoperability, Pricing Transparency, and Future Proofing:

Fostering a positive consumer charging experience is critical to the successful transition to EVs in Connecticut. The challenge in addressing consumer experience through recommendations in the Roadmap is that, because technology is evolving so rapidly in this space, there are risks about being too prescriptive about specific technologies. As noted throughout these comments, the Roadmap should avoid dictating specific technological requirements.

For example, with regard to the proposed requirement that new electrical infrastructure installed at publicly funded DCFC stations be capable of supporting 150 kW charging stations or greater, we appreciate the intent of ensuring future-proofing of investments. However, the Roadmap should be crystal clear that this requirement pertains to the EVSE and not to the chargers themselves. In other words, the “make ready” infrastructure should be future-proofed to support the eventual installation of at least 150kW, but it does not make sense at this time to require actual installation of 150 kW chargers at every DCFC location. With regard to forms of payment, rather than prescribing specific requirements, it is preferable to defer to the existing statutory requirements on this issue found in C.G.S. § 16-19ggg.

With regard to signage and other standardization of charging experience, regional cooperation in this area is important as the region is relatively small with a large amount of cross-border traffic. Driver confusion regarding the availability of charging stations in neighboring states will negatively impact public perception and consumer adoption of EVs.

Finally, we support the draft Roadmap’s recommendation to establish a fine for ICE-ing and authorize state and municipal police and parking enforcement authorities to ticket vehicles in

violation of the law. This is low-hanging fruit and should be adopted. EV charging stations need to be available for EV drivers when needed.

Recommendations regarding Residential and Workplace Charging:

We support adoption of a right-to-charge law prohibiting Multi-Unit Dwellings (MUDs) and condominium associations from restricting lessees or condo owners with designated parking spaces from installing EV charging equipment and associated metering. Relevant stakeholders (e.g., condo owners) should be involved in the legislative process. In other jurisdictions this has led to common-sense approaches that were widely supported.

We further support DEEP’s efforts to ensure that the PURA docket evaluates and addresses approaches to manage EV load, which can take the form of rate design and/or managed charging or demand response programs. Technology needs to be able to support load management.

DEEP should adopt policies to encourage workplace charging in a manner that is technology-neutral and future-proofs these investments. For example, new infrastructure should be able to support L2 charging. The installation cost for L2 wiring is similar to the installation cost of L1 wiring. Thus, there is little value add to wiring only to support L1 charging.

Recommendations regarding Rate Design:

Rate design can be an effective tool for helping to manage EV load, and will be increasingly important as the number of EVs charging in Connecticut continues to increase. We agree with DEEP that if EV-only rates are going to be implemented, it is critical that they not require an additional revenue-grade meter, the cost of which is likely to cancel out the potential savings that an EV owner could accrue through off-peak charging. There are multiple alternatives to second meters to measure the EV component of household load. It can be measured using the embedded metering in smart, networked L2 chargers and advanced household meters that can parse load and identify the EV-specific component. We anticipate that EV load will soon be able to be measured through the communications capabilities of the vehicles themselves. The EV Roadmap should endorse the development of rate designs, including EV-only rate designs, that will help manage EV load. But in light of the rapid technological advances occurring, it is important that the Roadmap not be overly prescriptive about technologies through which EV-only rates can be implemented. The Roadmap should call for the utilities to be taking a proactive role and taking responsibility for managing EV load.

In addition to being a tool for managing EV load, rate design can be critical to removing barriers to deployment of DCFC stations. Demand charges are a major barrier to deployment of public (non-fleet) DCFC. As analyzed by RMI in the context of EVgo’s charging station fleet in California,8 particularly at low levels of utilization, demand charges can swamp volumetric charges under traditional commercial demand rates, thereby undercutting the business case for private installation of DCFC. Demand charges can also pose a barrier to fleet charging, including for depot charging of transit buses. Developing rate designs that address this barrier is critical to enabling deployment of electric transit buses in the state.

The concept of Eversource’s Rate Rider (which shifts the demand charge into the volumetric charge)9, is well-intentioned, but the current language of the Rate Rider is vague and confusing. There are good examples around the country of modifications to traditional demand charges that send appropriate price signals to station owners such as the recently-approved PG&E throughput-based subscription fee approach.10 Ultimately, we recognize that there is no one-size-fits-all approach to designing alternatives to traditional, demand-based rate structures. Each utility will need to design a rate that works best for its service territory. Regardless of the manner by which utilities address this challenge, their respective solutions should (1) be equitable and available to all DCFC, both existing and new, and (2) address the challenge through a predictable, transparent, and sustainable rate design, rather than a short-term incentive.

Recommendations regarding Innovation:

We appreciate the enthusiasm in the draft Roadmap for vehicle to grid (V2G) technology.

In the long term, when EVs are widespread, it will be valuable to be able to harness the stored energy in the batteries of parked vehicles. However, we do not believe that V2G should be identified as a high priority in the final Roadmap. Rather, it is critical in the near term to develop strategies for effective unidirectional smart charging (V1G) management of new EV load.

Recommendations regarding Leveraging Incentives to Promote Equitable, Affordable EV Adoption—CHEAPR Program:

The CHEAPR program has the potential to greatly boost EV adoption. Indeed, studies and modeling show that rebates that reduce the up-front purchase price of vehicles are a strong driver of EV adoption.11 Based on modeling that Synapse Energy Economics conducted for the Sierra Club in New York, it may be valuable to increase the sizing of the CHEAPR rebate for battery electric vehicles.12 Ultimately, the incentives should be sized such that the CHEAPR incentive, in addition to other federal and state incentives, is projected to put Connecticut on track to meet its transportation sector GHG commitments.

Additionally, the CHEAPR program will need to be scaled up to achieve 500,000 ZEVs on Connecticut roads by 2030 in order for the state to meet its climate goals.13 To that end, CHEAPR will need a large and sustainable source of funding. DEEP should explore the possibility of utilizing the Transportation and Climate Initiative (TCI) as a funding source for the CHEAPR program.

DEEP should also evaluate the merits of a low-income adder to the rebate in conjunction with other potential strategies to promote access to EVs for low-income and underserved communities, and extending the low-income rebate to the purchase of used vehicles. One alternative that warrants further consideration is a “cash for clunkers” program similar to what California and British Columbia have developed.

Finally, the EV Roadmap should recommend elimination of the current prohibition on direct sales of EVs, which is stifling sales of EVs in the state. The models that comprise the majority of national EV sales are not being sold in Connecticut. At the same time, the Roadmap should recommend additional incentives for existing auto dealers to increase their sales of EVs. More outreach to dealers regarding the existing CHEAPR dealer incentive is needed, given low levels of awareness by dealers, and additional incentives should be explored, such as: state reimbursement of the percentage of dealership local property tax equal to the percentage of EVs sold by the dealer each year, to a cap of 50%; state waiver of state income tax on all staff salaries based on percentage of EVs sold, to a cap of 50%; reimbursement of 100% of EV charging infrastructure and charging electricity costs at all CT dealer locations; free training for all CT dealers in EV sales using the PlugStarDealer.com program or a similar program; and/or higher CHEAPR rebates for all dealer cars used as service loaners and company cars.

Recommendations regarding Education and Outreach:

We support a coordinated approach to education and outreach among state actors and support a role for utilities and OEMs.

Connecticut should continue to support and participate in the regional Drive Change Drive Electric (DCDE) campaign and the Destination Electric Program to build upon and increase consumer awareness in the state and the region. We support the partnership framework among automobile manufacturers and state governments of the DCDE Campaign. While the campaign provides good web-based resources for learning about electric vehicles, there may be additional opportunities for proactive outreach and promotion. Such opportunities include cross-linking with other relevant state (such as DMV) and municipal (particularly for the Destination Electric program) websites.

We agree that OEMs should (and must) be active participants in advertising and marketing EVs in Connecticut, leveraging their years of experience in promoting conventional vehicles. Among the roles OEMs can play:

• Creation of informational and marketing materials for dealerships. While we assume that OEMs currently do this to some extent, we recommend an expansion of these efforts targeted to EV
• Providing additional dealer incentive for EV
• Providing supplemental consumer rebates for EV Purchases. For example, Nissan has partnered with the CT Green Bank to provide an additional manufacturer incentive of between $2,500 and $5,000 for the purchase of a Nissan Leaf.
• Providing well-promoted community “Ride and Drive” events, in partnership with the state, municipalities, and local businesses.

As noted above, we strongly support the recommendation to conduct focused outreach in underserved communities to inform the development of integrated approaches for deploying electrified transportation services strategically and addressing barriers to EV ownership by low- income households. We emphasize that the deployment of electrified transportation services should be informed by community priorities with respect to the type of services desired, whether that is increased access to light-duty EVs to replace older, unreliable personal transportation or the deployment of more electric buses and other clean transit options, with increased convenience and affordability.

Recommendations regarding Funding Mechanisms to Support Sustainable Incentive and EV Infrastructure Programs—VW EVSE:

VW EVSE expenditures should be coordinated with the utility programs that arise from the PURA ZEV docket.14 DEEP should focus on ensuring that key market segments, such as MUD L2, public transit corridor DCFC, and in-town DCFC, are being addressed.

A portion of the VW funding should be earmarked to support access to electrified transportation for communities that bear an outsize share of transportation emissions. DEEP should conduct outreach into these communities to better understand transportation needs and use VW EVSE funds to support charging infrastructure for transportation programs that will meet these needs (for example, communities that could be better served by car or rideshare programs). This is preferable to simply deploying a percentage of stations in overburdened communities.

Respectfully submitted,

The Connecticut Electric Vehicle Coalition

• Acadia Center*
• Connecticut Fund for the Environment*†
• Connecticut Green Buildings Council
• Connecticut Nurses Association
• Connecticut Roundtable on Climate and Jobs*
• Connecticut Citizen Action Group
• ConnPIRG
• Conservation Law Foundation
• ChargePoint*
• Chispa-CT*
• Clean Water Action*
• CT League of Conservation Voters
• CT 350
• Drive Electric Cars New England
• Eastern CT Green Action
• Electric Vehicle Club of Connecticut*
• Energy Solutions, LLC
• Environment Connecticut*
• Greater New Haven Clean Cities Coalition,
• Hamden Land Conservation Trust
• Hartford Climate Stewardship Council
• International Brotherhood of Electrical Workers*
• Interreligious Eco-Justice Network
• New Haven Climate Movement
• Northeast Clean Energy Council
• People’s Action for Clean Energy
• Proton OnSite
• Plug In America*
• RENEW Northeast
• Sierra Club*†
• Solar Connecticut,
• Tesla,
• Union of Concerned Scientists

* Connecticut EV Coalition Steering Committee Membership

Footnotes:

1 CT EV Coalition Feb. 21, 2019 Cmts at 2.

2 Draft Roadmap at 20.

3 Governor’s Council on Climate Change, Building a Low Carbon Future for Connecticut 29-30 (December 18, 2018).

4 An Act Concerning the State Budget for the Biennium Ending June 20, 2021, and Making Appropriations Therefor, and Provisions Related to Revenue and Other Items to Implement the State Budget.

5 See NYSERDA, New York Truck Voucher Incentive Program, available at https://www.nyserda.ny.gov/All- Programs/Programs/Truck-Voucher-Program.

6 See Governor’s Council on Climate Change, Building a Low Carbon Future for Connecticut (December 18, 2018).

7 Energy Solutions, Plug-In Electric Vehicle Infrastructure Cost Analysis Report for CALGreen Nonresidential Update (September 16, 2019), available at: https://caletc.com/energy-solutions-report-finds-that-increasing-the- number-of-electric-vehicle-capable-parking-spaces-at-new-buildings-and-adding-ev-capable-parking-spaces-to- existing-buildings-when-undergoing-certain/.

8 Rocky Mountain Inst., EVgo Fleet and Tariff Analysis Phase 1: California (Apr. 2017).

9 Available at https://www.eversource.com/content/docs/default-source/rates-tariffs/ev-rate- rider.pdf?sfvrsn=e44ca62_0.

10 See PG&E, PG&E Proposes to Establish New Commercial Electric Vehicle Rate Class (Nov. 5, 2018), available at       https://www.pge.com/en/about/newsroom/newsdetails/index.page?title=20181105_pge_proposes_to_establish_new

_commercial_electric_vehicle_rate_class; PG&E, PG&E’s Commercial Electric Vehicle Rate (Nov. 20, 2018), available at https://caltransit.org/cta/assets/File/Webinar%20Elements/WEBINAR-PGE%20Rate%20Design%2011- 20-18.pdf.

11 Studies have found a significant increase in EV sales with the implementation of rebates among low- and moderate-income households. Scott Hardman, The Effectiveness of Financial Purchase Incentives for Battery Electric V9ehicles, 80 Renewable and Sustainable Energy Reviews 1110 (2017), https://phev.ucdavis.edu/wp- content/uploads/2017/09/purchase-incentives-literature-review.pdf.

12 Synapse Energy Economics, Inc., Transforming Transportation in New York: Roadmaps to a Transportation Climate Target for 2035 (September 2019).

13 See Governor’s Council on Climate Change, Building a Low Carbon Future for Connecticut 28 (December 18, 2018).

14 PURA Docket No. 17-12-03RE04.

† To whom correspondence should be directed. Josh Berman, Sierra Club. Email Josh.Berman@sierraclub.org or phone (202) 650-6062. Charles Rothenberger, Connecticut Fund for the Environment. Email crothenberger@ctenvironment.org or phone (203) 787-0646, x122.

This is the official proclamation from the office of the Governor declaring the week of September 14-22 to be Drive Electric Week and highlighting the benefits that moving to EVs will have on emission reduction and public health.

The EV Coalition of CT has issued its own press release that highlights some specific actions occurring to support the effort to lower transportation emission levels and provide info on other local NDEW events.

Connecticut Electric Vehicle Coalition applauds Governor Lamont for proclaiming September 2019 as Electric Vehicle Month

Hartford, Conn. – The Connecticut Electric Vehicle Coalition is thrilled that Governor Ned Lamont, an electric vehicle (EV) owner himself, has recognized the significant environmental and economic benefits of EVs, as well as the necessity of widespread adoption, by proclaiming September 2019 as Electric Vehicle Month and September 14-22 as Drive Electric Week in Connecticut.

“While Washington, D.C., chips away at clean air and climate policies, Connecticut will do the necessary work to address climate change. That is why I have proclaimed September 2019 as Electric Vehicle Month in Connecticut,” Governor Ned Lamont said. “We must rapidly reduce our greenhouse gas emissions to meet Global Warming Solutions Act mandates—and with transportation as the largest source of greenhouse gas pollution, it’s the perfect place to start. Nearly 40% of our pollution comes from transportation, especially with so many of our roadways congested, leading to cars idling, and it contributes to health complications across the state and environmental injustices in our cities. By building public awareness of EV benefits, growing Connecticut’s network of charging stations, and generating our electricity with clean renewable sources, we can breathe easier knowing we are doing everything to combat our climate crisis.”

The Global Warming Solutions Act mandates Connecticut reduce carbon emissions 45 percent by 2030. To meet that goal, the Connecticut Department of Energy and Environmental Protection (DEEP) projects that 500,000 passenger cars will need to be electric by 2030, and the Governor’s Council on Climate Change calls for electrification of 30 percent of the statewide fleet of buses and commercial trucks by 2030. Attaining these targets will require rapid growth over the next decade—Connecticut will need about 40% average annual fleet growth to achieve the 500,000 electric vehicle goal.

During the spring 2019 legislative session, policymakers stepped up to the plate and funded $3 million per year for the state’s EV rebate program (CHEAPR), and also directed the state to purchase a minimum level of EVs for the state fleet. Governor Lamont’s first Executive Order, issued on April 24, 2019, includes the state fleet as one of seven areas targeted for emission reductions.

The Public Utility Regulatory Authority (PURA) began work on grid-side system enhancements to integrate heavy-duty electric vehicle fleets earlier in the year, the state’s Codes and Standards Committee is evaluating adoption of an “EV-ready” construction standard for new residential and commercial buildings, and DEEP is developing an EV Roadmap to identify policies, programs, and strategies that the State of Connecticut should pursue to optimize deployment of electric vehicles and associated infrastructure. The Roadmap is expected out this month.

Additional utility revenue from EV charging can support operation and maintenance of the existing electric distribution infrastructure, thus reducing the need for future electricity rate increases. EV growth also provides economic benefits, shifting electric grid revenue back to our region that would otherwise go towards dirty fossil fuels purchased elsewhere. It creates local jobs for skilled workers in infrastructure installation and maintenance, stimulating local economies and generating tax revenue for the state. In addition to these consumer and economic benefits, electric vehicle expansion leads to energy independence, as Connecticut EV drivers are unaffected by fluctuating gas prices and spend less money on imported petroleum products. It is estimated that by 2050, if EV targets are met, Connecticut ratepayers will save $500 million on their electric bills and $1.9 billion in vehicle operating costs.

###

The Connecticut Electric Vehicle Coalition is a diverse group of clean energy advocates and businesses, community justice organizations, labor unions, and local businesses that work together to advance policies that will build out electric vehicle infrastructure and put more electric vehicles on the road in Connecticut. The combination of these two goals will achieve significant economic, health, and climate benefits for the State.

What the Connecticut Electric Vehicle Coalition members are saying:

“With a huge proportion of dirty carbon emissions coming from the transportation sector, we must accelerate the expansion of electric vehicles in Connecticut in order to keep our climate commitments,” says Charles Rothenberger, Climate and Energy Attorney for Connecticut Fund for the Environment/Save the Sound. “Electrifying our transportation sector will boost the green economy, save consumers money, keep Connecticut healthy, and reduce our dependence on filthy fossil fuels. Fortunately, Governor Lamont and the legislature jumped behind the wheel this past session showing true initiative to electrify transportation in Connecticut. The next step to speed up EV adoption is for the state to complete and implement the Electric Vehicle Roadmap.”

“The growth of EV adoption in Connecticut demonstrates that the electric mobility revolution is underway,” says Kevin Miller, Director of Public Policy for ChargePoint. “ChargePoint applauds the Lamont Administration and legislature for prioritizing support for transportation electrification, which will help meet statewide energy and environmental goals and ensure that the State has the world-class EV charging network it deserves. We look forward to working with PURA, DEEP, DAS, and other stakeholders to make it easier for Connecticut drivers and riders to go electric.”

Members of the Connecticut Electric Vehicle Coalition 

• Acadia Center*
• ChargePoint
• Connecticut Fund for the Environment*
• Connecticut Nurses Association
• Connecticut Roundtable on Climate & Jobs*
• Connecticut Citizen Action Group
• ConnPIRG
• Conservation Law Foundation
• Chispa-CT*
• Clean Water Action*
• CT League of Conservation Voters
• 350 CT
• Drive Electric Cars New England
• Eastern CT Green Action
• Electric Vehicle Club of Connecticut*
• Energy Solutions, LLC
• Environment Connecticut*
• Greater New Haven Clean Cities Coalition, Inc.
• Hamden Land Conservation Trust
• Hartford Climate Stewardship Council
• International Brotherhood of Electrical Workers*
• Interreligious Eco-Justice Network
• New Haven Climate Movement
• Northeast Clean Energy Council
• People’s Action for Clean Energy
• Proton OnSite
• Plug In America*
• RENEW Northeast
• Sierra Club*
• Solar Connecticut, Inc.
• Tesla, Inc.
• Union of Concerned Scientists

* Connecticut EV Coalition Steering Committee Membership

DRIVE ELECTRIC WEEK EVENTS

Fairfield

Day:      Saturday, September 14, 2019

Time:    10am-2pm

Location: Fairfield

Fairfield Train Overflow Lot (across from Sportsplex)

140 Mill Plain Road

Fairfield, CT 06824

Glastonbury

Day:      Saturday, September 14, 2019

Time:    10:00 AM -2:00 PM

Location:  First Church of Christ

2183 Main Street

Glastonbury, CT 06073

Hamden

Day:      Saturday, September 14, 2019

Time:    11:00 am to 3:00 p.m.

Location: Miller Public Library

2901 Dixwell Ave

Hamden, CT 06518

Madison

Day:      Sunday, September 22, 2019

Time:    1 PM – 4 PM

Location:   Madison Senior Center

29 Bradley Road

Madison, CT 06443

Middletown

Day:      Saturday, September 21, 2019

Time:    2:00 PM – 5:00 PM

Location:  Harbor Park

100 Harbor Park Road

Middletown, CT 06457

New Britain

Day:      Sunday, September 22, 2019

Time:    12:00 – 4:00

Location:   Central Conn. State University

1615 Stanley Street

New Britain, CT 06053

Old Saybook

Day:      Saturday, September 21, 2019

Time:    11:00 am to 3:00 p.m.

Location:  Saybrook Point Pavilion

155 College Street

Old Saybook, CT 06475

Oxford

Day:      Saturday, September 14, 2019

Time:    10:00am- 2:00pm

Location:   Quarry Walk

300 Oxford Rd

Oxford, CT 06478

Southbury

Day:      Saturday, September 21, 2019

Time:    10am -2pm

Location:   Southbury Town Hall Green

775 Main Street South

Southbury, CT 06488

South Windsor

Day:      Saturday, September 14, 2019

Time:    9am to 12pm

Location:  South Windsor Community Center (Farmers Market)

150 Nevers Road

South Windsor, CT 06074

West Hartford

Day:      Saturday, September 21, 2019

Time:    9 – 1pm

Location:  West Hartford Town Hall

Main St

West Hartford, CT 06106

Windsor

Day:      Wednesday, September 18, 2019

Time:    5:00 – 8:00 PM

Location:   Bart’s Drive-In Restaurant

55 Palisado Avenue

Windsor, CT 06095