The Equivalent Of 52% of EVs Added To The File in 2020 Turned Over

EV registrations in Connecticut increase 18.2% in 2020, a not great number in a very difficult year. However, as difficult as the year may have been, CT can be its own worst enemy with no direct sales and an underperforming purchase-incentive program. The chart below breaks this into the first vs second half of the year, clearly showing the effect of the lockdown followed by a modest recovery.

In January 2020, there were 11,677 EVs registered in the state. 4408 vehicles were added to the file over the course of the year. But we ended the year at 13,800. In other words, there were 2285 EVs that left the file. The numbers varied considerably by brand. Tesla had the lowest percentage of the major brands with the equivalent of 33% of the incoming vehicles turning over. Honda had the highest percentage, and off-the-charts 462%. Which makes sense, since Honda basically stopped selling its one plug-in model, the PHEV Clarity, in 2019. (We hear it is coming back.) As cars were sold or leases expired, no replacements were entering the fleet. This table lists the top makes, ranked by the number of EVs registered on January 1, 2021.

The same data drives the chart at the top of the post. Each of the components is its own bar. The table and the bar chart come from the EV Dashboard, where they have full interactivity and slicers.

The obvious question is why the differences. We can try to infer. Some of it may have to do with leasing. A dealer on the CHEAPR board meetings reports that leasing is 50% of his new car business. That is higher than the national norms we’ve seen in Statista and other sources, but there is no doubt that leasing is big. Tesla came late to leasing and has yet to offer a buy-out option. And their cars have longevity. It is quite possible that a higher percentage of buyers equates to lower turnover.

One comment mentioned by a dealer during a CHEAPR board meeting bears repeating. This person said that a significant portion of EV leasing customers coming to the end of their lease return to ICE in order to save money, especially given that they cannot get another CHEAPR incentive due to the program’s once per lifetime limit. His suggestion: allow leasing customers to get the incentive twice but cut it by 50%. It’s a thoughtful suggestion and would also have the benefit of lowering the program’s burn rate for 2-3 years until it normalizes.

Aside from leasing, there is sales volume. Chevrolet and Ford, which are the largest brands with net negative registrations (i.e. turnover in excess of 100%) similarly suffer from a variation of what is happening with Honda, namely cancellation of nameplates coupled with a lack of other sales volume to replace the departing vehicles. In the case of Chevy, the near-term recovery plan is a redesigned and lower-priced Bolt and a reasonably priced EUV Bolt variation. We’ll know at the end of the year how these will have fared. Ford, on the other hand, has what may be a significant win with the Mach-E, the EV crossover Mustang. There is a limited production run in 2021, which has been reportedly sold out (with dealers tacking on extra markup as reported in Carbuzz.com).

Similarly, the 99% BMW turnover and the 84% Nissan turnover indicate stasis. On the flip side, low turnover from Hyundai, Porsche, Volvo, and Audi could indicate some renewed vigor. Sales volume for the Audi is currently very low, but an ultra-premium brand like Porsche, placing in 9th position, indicates some success in a niche market. However, there are a lot of cars vying for this small segment, with the new Tesla Model S Plaid, for which it is too soon to have registration data,  the presumptive early favorite.

Higher Incentive Levels, Low MSRP Cap, New Income-Limited Incentives

Note: This page is updated to note that the new incentive levels have been implemented as of June 7, 2021. The CHEAPR home page has been updated but we think the explanation below is clearer. If you do look at the CHEAPR page, please ignore the $9500 incentive headline. Nobody will get that level of incentive. It would only apply to an income-limited individual buying a fuel-cell vehicle this year, which is ridiculous since there aren’t any fuel-cell vehicles for sale in the state, and how would an income-limited individual afford an expensive fuel-cell vehicle.

An updated set of rules was adopted by a 6-3 vote of the CHEAPR board that supersedes the last rule change made in October 2019. Here are the most relevant changes:

BEV = Battery Electric Vehicle, PHEV = Plug-in Hybrid Electric Vehicle, MSRP = retail price

Major Changes

• No difference in incentive levels based upon EV range.
• Higher incentive levels for the remainder of 2021.
• New income-limited incentive for used EVs
• New income limited supplemental incentive for new EVs
• Likely effective date is on or about April 1.

There is no longer a difference in the size of the incentive as it relates to the range of any given BEV. Incentives are higher across the board. The MSRP cap was left unchanged at $42,000. There are new income-limited incentives for used EVs and a supplemental incentive for new EVs. The supplemental gets added to the base incentive for qualifying income-limited individuals buying a new BEV or PHEV. There is no MSRP cap for a used EV.

The CHEAPR incentive limit has been increased to twice per driver per lifetime. And the clock resets as of June. If you already received a CHEAPR rebate before then, you are entitled to two more. (It is different than the federal tax credit which can be used each time someone buys or leases a new EV.)

Other CHEAPR Program Details

There is still a fuel cell incentive and the MSRP cap for an FCEV is still $60,000, though there is none of that type of vehicle being brought into the state presently.

Dealers receive an incentive of up to $125. This, once upon a time, was higher. DEEP, in its analysis for its EV Roadmap, questioned whether the dealer incentive accomplished its objective because most of the time it was not being passed along to the salesperson, which was the basic idea. However, it remains in this reduced form.

Income-Limited Incentives and Eligibility

The incentive for a used EV applies to purchases from a licensed dealer. This applies to any dealer of used cars, not just new car dealers that also sell used vehicles. It does not apply to private sales.

An individual’s eligibility for the income-limited incentive is determined by whether that person is already participating in certain assistance programs. Administratively, this is simpler than performing an income verification, but it still takes a few steps and involves a lag in receiving the money. These are the programs that are determinative:

Unlike the way the primary part of the program works, where it can be cash on the hood, the buyer completes an application to confirm eligibility based on one of these programs. DEEP estimates that it will take about a month to process the paperwork at which point a rebate check will be issued. This process can be done online (desktop or mobile) or via postal mail. This is the workflow:

Since nobody wants an applicant to get a surprise denial, DEEP promises outreach and education so that buyers understand what is involved and whether they qualify before filling out the application.

Incentive Structure

As noted in the table at the top of the page, someone buying a new BEV will receive a $2250 incentive. However, the way it is actually structured is that the base incentive of $1500 from the current program is actually retained and a “stimulus increase” of 50% is added to it. This additional stimulus is earmarked for calendar 2021, funds permitting. It will be tracked and reviewed regularly. This is why you get that odd $1125 number for a used PHEV. The base is a more neatly rounded $750. Each incentive size will then revert to its base level in 2022. We will update our information as it gets confirmed closer to the end of the year.

Start Date

The changes take effect as of June 7th, 2021. The income limited used and supplemental incentives are now ongoing, but the higher incentive levels may revert to the old levels at the end of 2021.

Our Take

The Connecticut EV Coalition made a proposal to the board that would have raised the stimulus to $2500 for BEVs and the MSRP cap to $50,000. The incentive including the stimulus adder is close to our proposal but the MSRP cap remains at a level that excludes too many vehicles. According to Cox Automotive, the average cost of an EV is $55,600. MSRP caps exist in other states but at much higher levels: MA – $50,000, NJ – $55,000, NY – $60,000. Given that the program was about 70% underspent in 2020, we expect it will underperform in 2021, though to a lesser degree.

We like the introduction of the equity aspect of the program, particularly the used EV incentive, as this market is not well-developed.

This structure of an incentive plus a stimulus adder is not the most consumer-friendly formulation. This allows the incentive to revert to a lower level after this year without making a formal change to the program. It is administratively convenient, but it has the potential to be confusing. To the consumer, it will still be a change. We think the incentive should be the incentive and if it needs to be changed, it needs to be changed.

The fuel cell incentive is there because the state is trying to be supportive of this industry. We are not sure if there will be a compelling and cost-effective case for hydrogen in light-duty vehicles, especially green hydrogen. Be that as it may, our main issue with this is the way it has consistently been used as a misleading headline. It has now been made even more misleading.

Rivian mobilizes reservation holders for support

For those holding reservations for an electric pickup truck or SUV from new EV-exclusive manufacturer Rivian, where and how they will get possession of their vehicle when deliveries begin later this year remains unknown. Like Tesla, they are going the direct sales route. Unlike Tesla, they are just getting started and running the direct sales gauntlet in many states across the country. The issue is once again before the legislature in CT. This club supports it (SB 127). Below is the text of the letter sent by Rivian:

Updated CT EV Registration Files

Post by Barry Kresch

2020 was a difficult year to say the least with overall domestic automobile sales sliding 15% from 2019. Against that background, EV registrations in CT (a related, but different, metric) edged up 18.2% to 13,800 EVs of all stripes. EVs are defined the way they are by the state as battery electric vehicles (BEV), plug-in hybrids (PHEV), battery electric motorcycles (BEMC), and fuel cell electric vehicles (FCEV). The growth rate was slower than in the prior two years, which were 25.7% and 47.8% respectively. It is roughly that last rate of growth from 2 years ago that is needed on a consistent basis if the state is to hit the goal in the Zero Emission Vehicle Memorandum of Understanding. At this rate, CT falls further behind every year.

BEVs Lead the Way

BEVs led the way with a 28% increase, followed by PHEVs up 7.5%. There are only 24 BEMCs and 3 FCEVs, the latter of which are not currently available to buy or lease in the state.

PHEV growth has flattened since 2019.

Tesla Again Leads By a Wide Margin

The chart below is an excerpt of the makes with the largest number of registered vehicles. Tesla continues robust growth (and they’re not allowed to open stores here, why???). Astonishingly, there is no other manufacturer with a strong increase. There are some that modestly increased (Toyota, Volvo, Audi, Subaru, Nissan), others that are basically flat (most), and a few major players that posted declines (Chevrolet, Ford, Honda). This is a decline in net registrations. It is a function of how many cars they sold versus the turnover in the existing base. Chevy is seeing older Volts exit the file. Honda has stopped trying to sell the Clarity in CT. There could be a change next year for Ford depending on deliveries of the Mustang Mach-E.

Tesla was responsible for 47% of the vehicles entering the file.

This brought its net share to 43%, up from 40% in July.

This trend is most dramatically illustrated in this growth contribution waterfall chart, which takes the YOY difference in registrations by make and divides it by total net new registrations. This reflects both positive and negative contributions.

Watch this space. More to come…..

DMV Releases Updated EV Registration Data

There are 13,800 EVs registered in CT as of January 1, 2021, according to data released by the Department of Motor Vehicles in its statutorily required semi-annual reporting. This represents an increase of 18.2% over the 11,677 EVs registered in January 2020. This is a lower rate of growth relative to 2020 over 2019, when it was 25.7% (and way lower than Jan 2019 over Jan 2018, when it was 45.8%). The featured image at the top of the post contains the number of registered EVs for each data point that we have obtained from the DMV. This began in 2017 with annual updates, then moving to semi-annual updates in 2019.

The pandemic induced lockdown and severe recession led to highly restrained growth of 8.1% during the first half of the year. Things picked up a little in the latter half of 2020 when the rate was 10.1%.

A total of 4,408 EVs were added to the file in 2020. This means that there was turnover of 2,285 vehicles.

Briefly, the DMV is reporting a snapshot of registrations. Vehicles can be added to the file as a result of the acquisition of a new vehicle, a used vehicle, or someone moving into the state who already owns an EV. Vehicles can leave the file due to the owner selling the car, having an expiring lease, or moving out of state.

The DMV has only reported these top line numbers as of the date of this publication. Subsequently, we will receive more detailed data including fuel type, city, make, and model. The diagnostic details are what really tell the story.

We do not have the “full file” of all vehicles and so we are not able to say how EVs trended relative to ICE vehicles. There has been reporting that EV sales have generally held up a little better, but we can’t comment on CT specifically.

The state continues to lose ground with respect to the goals articulated in the Multi-State ZEV Action Plan Memorandum of Understanding. I have updated the needed compounded annual growth rate chart, and the curve is going in the wrong direction. In this case, up means we’re down. As of January 1, a CAGR of 49.02% would be required to reach 500,000 EVs by 2030. This is up from 47.29% in July and 45.6% one year ago.

This is a copy of the statewide EV Program straw proposal that the Public Utilities Regulatory Authority has released. Public comments are being accepted until Jan. 29. Sorry, but this is not downloadable from our website.

17-12-03RE04 Straw Proposal

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.

Aptera to Visit CT

This is still tentative but we think it will happen. This will be a cool event, so we thought we’d tease it.

Aptera is a 3-wheeled vehicle with integrated solar. Due to its lightweight design and low drag coefficient, the trim level with the largest available battery pack has a range of 1,000 miles for about $46,000. The solar array can charge 44 miles on a sunny day.

The event is anticipated to occur in mid-2021. It is a test drive event so it will be outdoors. Masking and social distancing requirements will probably still be in force at that point, but it worked out well for the Polestar event a couple of months ago.

Further information will be posted when available.

CHEAPR Remains in a Limbo Which Might End Soon

The combination of the 2019 legislation authorizing a modest, but steady funding stream, along with new program elements, and changes made by DEEP to the program in October 2019 that were more financially conservative have left the program in limbo. There has been a notice that “CHEAPR is EVolving” on its website for a year that there will be revisions but these have not been finalized.

The immediate impact of the October 2019 changes has been a dramatic underspending relative to the budget. Through November, the program awarded 589 rebates with a value of $629,500 against a budget of $3 million. The program incurs some other costs aside from consumer rebates, namely dealer incentives and admin charges paid to the program administrator, the Center for Sustainable Energy. DEEP has projected a final underspending of $2.2 million. Fortunately, these funds will roll over into 2021.

Program Parameter Changes and COVID-19

The downturn in rebates was made even more severe by the pandemic and recessionary economy, and this perfect storm led to the extremely low numbers we have been seeing through all reported data for 2020. November continued the pattern with only 40 rebates awarded. This chart of rebates by quarter for 2019 and 2020 illustrates this clearly. The downturn began in Q4, 2019 (the changes were made mid-October of that year), declined further in Q1, 2020, when the economy was still strong for the first 10 weeks, and then really tanked in Q2, 2020 during the lockdown. There has been a modest recovery since then (keep in mind that Q4, 2020 includes only 2 months of data).

New CHEAPR Structure and Forthcoming Vote

Responsibility for CHEAPR transitioned from DEEP to a board that was authorized by the legislation and had a quorum by the beginning of the year. DEEP still retains a presence on the board and administratively the board lives within DEEP. The board has been divided and no fewer than 9 scenarios have been modeled and recently presented to the board. These represent different levels of incentives, where to place the MSRP cap, the newly authorized income-limited incentives for used EVs, and a supplemental incentive for new EVs, as well as a possible temporary increase in incentive levels as a stimulus.

We expect a vote to occur sometime in the next few weeks.

This is the position of the EV Club of CT and the broader CT EV Coalition:

• Raise the MSRP cap and incentive levels to where they were before being lowered in October 2019.
• Implement an income-limited used EV incentive.
• Implement an income-limited supplemental incentive.

We feel the finances, especially given the rollover funds, are adequate to support this model in 2021. The EV Coalition plans to seek additional funding for the program for 2022. There is the possibility that funds may be forthcoming from the Transportation Climate Initiative beginning in 2023. Finally, we want to thank everyone who submitted public comments when they were solicited by DEEP over the summer.

At such time as the program revisions are finalized, the updates will be posted to the incentives page on this website.

2 Environmental Wins Conclude the Year

2020 is a year most of us will be happy to see in the rearview mirror. But the last couple of weeks have brought two wins that deserve to be celebrated.

Transportation Climate Initiative

Governor Lamont signed the Transportation Climate Initiative Memorandum of Understanding today, December 21. TCI is a cap and invest program that will place a tax on fossil fuel at the wholesale level that will yield funds for the state to invest in clean transportation. It is anticipated that $89 million could flow to the state in 2023, rising to $117 million in 2032 with a reduction in greenhouse gas emissions of 26%. The program is similar in overall design to the RGGI cap and invest program that has been in place for power plants. The TCI iteration is more complex in that there are many more point sources of pollution. The reason the funds are not anticipated until 2023 is that there is still a considerable amount of rulemaking that has yet to occur. For a thorough piece of reporting on this, see this article in the CT Mirror.

Monetizable Credits for EV Charging Stations

The second piece of good news is that the CT Green Bank has established a carbon credit monetization program for the owners of EV charging stations. This is not for residential owners. It is for businesses or other entities that control dozens or hundreds of charging stations. Details here.

CHEAPR

We have been closely following the CHEAPR saga, the year-long and still unresolved effort to revise program parameters, and have been publishing monthly program status from the CHEAPR dataset. It is anticipated that the board will vote on this reasonably soon.

Events

2020 started off with one of the best-attended events in the club’s history when Westport Police Chief, Foti Koskinas, brought the fully customized Tesla Model 3 cruiser to a club meeting in February. After that, the pandemic lockdown threw sand in the gears of our event planning, though we still managed to hold 2 socially distanced outdoor events. The first was a fully-subscribed EV parade, held in partnership with Sustainable Fairfield, during National Drive Electric Week. The second was a test-drive event of the Polestar 2 BEV and the Polestar 1 PHEV.

There are a number of new EV introductions anticipated for 2021 and we hope to preview some of these for members. One thing that we can tease is a tentatively scheduled mid-year test-drive event for the new Aptera EV, a 3-wheeled vehicle with fully integrated solar and the lowest drag coefficient of any vehicle, the top trim level has an electric range of 1,000 miles for about $46,000.

As we were forced to move into Zoom mode to hold events, we lined up several speakers. We had Gabe Shenhar from Consumer Reports give us a detailed, early preview of his Tesla Model Y test-drive. Peter Millman spoke to us about Community Choice Aggregation, and John Erdman of FreeWire spoke about their charging solution with a self-contained battery that allows DCFC high-speed charging while avoiding demand charges.

Data

We continued with our tracking of EV adoption levels in the state, which is published to the website via the Interactive EV Dashboard. This is the only publicly available, free-of-charge, resource for this level of detail that we are aware of. We also submitted an information request to obtain CHEAPR rebates by dealership. We have had numerous requests for dealership recommendations and this was our way of responding to this using quantifiable data that applies statewide.

Opinion Leadership

The club continues to present to interested organizations, participate on panels, respond to media requests, and publish opinion pieces, in the latter case with Op-Eds in The Hartford Courant, The Hartford Business Journal, and CT News Junkie.

As we gradually emerge from this pandemic cocoon, we look forward to a more active year in 2021. We have a speaker on January 14th who will be discussing a federal carbon tax proposal. You may ask how this intersects with TCI and that is one of our questions.

Best wishes for a safe and healthy holiday season!