Above photo by Paul Braren

Successful EV Showcase with Hotel Tours

Thanks to everyone who made this a successful event, with numerous EVs, including Lucid, Rivian, Tesla, Ford, Kia, Chevy, Polestar, and others.

The Westport Police brought their Tesla Model Y patrol car that went into service January of this year.

Tours of the hotel were given. This is the first net-zero hotel in the country, LEED Certified Platinum, Passive House Certified. The hotel has no fossil fuel connection. It is powered by solar, augmented with battery storage. Air-source high efficiency heat pumps provide the heating and cooling. The lighting is high efficiency Power over Ethernet. The elevators have regenerative braking. The kitchen uses induction. The envelope is so tight that if you are in a guest room, about one-tenth of a from I-95, it is totally quiet.

There are over 1000 solar panels on the hotel roof and the solar canopies. There is a bank of Tesla V3 Superchargers and, under the canopy, 12 level 2 chargers with J-1772 connectors. There is already in place infrastructure to install another 12. The level 2 chargers are part of the EV Connect network, though they can also be activated with a ChargePoint account.

This event was jointly produced by the EV Club of CT and the CT Tesla Owners Club. We thank the Tesla Club for its partnership.

Photo above: Ford expects its Mustang Mach-E to qualify for half the incentive; Chevy expects the same for its Bolt.

Battery Rules Issued

January 1 came and went. The new federal incentives in the Inflation Reduction Act became law but the implementing agency, the IRS, had not completed rule-making for several portions of it, most particularly how manufacturers can be in compliance with the new rules for sourcing and refining of critical minerals and battery assembly. The IRS said it needed until March. True to its word, the rules were issued on March 31 and take effect April 18th. This interim period allows manufacturers to determine which vehicles will be eligible and whether the certification will be for the full $7500 credit or only half.

Consumers have gotten a benefit from this delay as more vehicles were temporarily eligible. Many vehicles are expected to lose incentives due the rules. If you have cash burning a hole in your pocket and are in the market, you can still move fast and pick up an EV with the full incentive applied (assuming the other criteria are met). But you have to take possession of it before April 18th. The incentives are applied, in IRS speak, at the “date placed in service.”

What Rules Apply

The rule-making itself is highly technical in nature. The law requires that 40% of the sourcing and refining of critical battery minerals occur either domestically or with a free-trade partner and that 50% of battery assembly takes place in North America during 2023. Going forward, these levels escalate. So, how do you define 40%/50%? The IRS has determined that it is to be based on value. So how does one define value? What is the legal definition of a free-trade partner? (The ink is still wet on some frantic dealmaking that happened so that some friendly nations, e.g. Japan and South Korea, could officially become free trade partners.)

We’ll know on April 17th what vehicles are eligible for how much of the incentive, but it will be a continually evolving list as manufacturers wrangle supply chain logistics and as the requirements escalate. It is possible that a vehicle eligible in one year loses eligibility in a subsequent year if the supply chain has not maintained pace with the requirements. And it has to be done in an environment of (presumably) a rapid ramping up of production volume. This article from Reuters includes statements by some manufacturers regarding which vehicles stand to lose incentives. This is the Department of Energy page that lists qualifying vehicles. It will be updated on April 17th.

Making Sure the Vehicle is Incentive-Eligible

It certainly helps if a manufacturer certifies that a given vehicle is incentive-eligible. But the IRS is officially determining eligibility based on the VIN. This is a new world we’re about to enter, and with all that is being written in the press about how these incentives work, there hasn’t been much discussion of this potential for a consumer to be left in the lurch.

It is possible that two of the same make/model/model year vehicles have different incentive statuses, based on when and where the manufacturing and delivery take place. When filing for the tax credit, the VIN is required and Treasury matches it to its records. It is advisable to check the VIN before buying the vehicle. That can be a hassle, as for a made to order vehicle, the VIN isn’t available until late in the game.

The EV Club, in partnership with the Electric Vehicle Association, recommended that the IRS use make/model/model year and deal with it at the manufacturer level. Our take is that asking consumers to be in the VIN checking business is a clunky way to go. It could cause an unpleasant surprise. It definitely fosters confusion.

For readers of this blog, if you buy an EV after the new rules are in effect, we are interested in hearing about the process and if you felt protected if you were promised an incentive.

Leasing

For those who lease, none of the rules apply, not even North American final assembly. The full incentive applies. Just remember, the finance company gets the incentive. It is up to the consumer to verify it is being passed along, which is not legally required. It is called a subvented lease.

Other Rule-making

Yes, there’s more, particularly the foreign entities of concern rule and the transfer.

Foreign Entities of Concern

The foreign entities of concern rule, which will phase in during 2024 and 2025, will likely include several countries, but is really all about China, which currently dominates the battery mineral supply-chain and has a lot of battery IP. What about Chinese investments in this country? Ford recently announced a joint venture with the big Chinese battery company, CATL, to build a plant in Michigan to manufacture LFP (Lithium Iron Phosphate) batteries. Does this comport with the law? In this case, Ford is banking on the fact that it is only the IP that comes from CATL and that the plant is owned by Ford. This is an article in Politico that discusses it in some detail but stops short of making a definitive statement. Stay tuned.

Transfer Provision

The transfer provision kicks in as of Jan 1, 2024. This year, the incentive is a tax credit. There are two drawbacks to tax credits. The first is that you have to wait until you file your taxes to get the incentive. The other is that you need to have the tax liability to burn it off. The transfer provision allows the consumer to transfer the incentive to the dealer or manufacturer and take the credit as a “cash on the hood” rebate. Unlike with a lease, the law requires the dealer to transfer the full amount of the credit to the consumer. That solves the timing problem. But what about if the consumer doesn’t have $7500 of tax liability? Could there be a claw-back? That seems unlikely. The intent of the transfer provision is, in part, to be an equity measure, so people without tax liability could take advantage of the incentive.

Sandy Munro Unfiltered

Sandy Munro, famous for his willingness to express his (highly informed) opinions in a direct and unfiltered manner, joined the EV Club for a conversation on March 21st. The video has been posted on YouTube and is embedded below.

Munro clearly feels that mainstream press coverage of EV news is often ignorant and at times biased. This was his closing comment about why he holds these discussions with EV clubs and similarly interested audiences:

“My job, really, is to try and dispel as many of these silly rumors that are out there, and this is the only way to it because the normal press doesn’t want to have anything to do with the kind of discussion that we had here today.”

A few items contained in the video:

• On autonomous driving – “FSD is a myth by everybody until we move to Forward Looking Infrared. Lidar and cameras don’t reliably work. Only Forward Looking Infrared (FLIR) can see through everything.” He also mentioned that FLIR is what the military uses and that about half of the work done by his engineering firm, Munro and Associates, is defense-related.
• On batteries – Pouch design does not hold up as well as cylindrical. The expansion and contraction kicks the daylights out of them. Solid state is the holy grail and will last indefinitely.
• The press over-sensationalizes Tesla issues because Tesla doesn’t buy ads. “If you don’t give us ads, we’re going to throw you under the bus.”
• The Tesla Gigacast will produce a body that is much stronger than any sheet metal currently in use.
• What did he find when he pulled out the floor of a Mustang Mach-E frunk?
• Should you be happy to see an ABB charger?

Photos by Paul Braren

EV Club Members Support First Responders

As more EVs are on the roads, and according to CT Department of Energy and Environmental Protection, 9% of CT new car sales were plug-in vehicles in 2022, first responders have to be prepared for them and have incorporated them into their training regimen.

That is why several fire departments have reached out to the EV Club to ask if we could EV owners to bring vehicles to their training sessions. Fairfield is the third time we have done this, and owners brought vehicles to 8 training sessions at the Fairfield Regional Fire School to support the training. The trainees benefit from being hands on with an EV where the trainer can show them where the cables are, where they should be clipped, how to make sure a car is off (since there is no telltale engine hum), and other measures necessary to deal with a motor vehicle incident with an EV.

EVs Are Safe

Much safer than a gasoline vehicle. That was what our contact, Assistant Chief Schuyler Sherwood, said, unprompted. But they have high-powered cables and high voltage batteries and one has to be prepared for this.

This is the third training that the EV Club has participated in. The first responders are a highly engaged audience and these sessions are a lot of fun. The first time we did this, we just dropped the cars off. These last two occasions, owners hung out with the class during the training and were able to interact.

We are happy to help the first responders and are glad they understand that EVs are the future.

Help Us Help You Promote Your EV Showcase Event and Get EV Owners to Exhibit

As consumer interest in electric vehicles has increased, so too, has the number of EV showcases being held around the state. Sometimes they are standalone EV events and other times EVs are part of a larger green fair event or larger automotive event. Sometimes they are official Drive Electric Week events, but others are produced independently by community organizations.

We receive a number of requests to help recruit EV owners to exhibit their vehicles and publicize these events.

The EV showcase season, beginning with Drive Electric Earth Day, commences next month. If you would like us to list your event on our event calendar, include it in email blasts, and ask for EV owner participation, please give us the following information:

• Event name
• Event organizer/sponsor
• Brief event description
• Date, start/end time
• Is it just a showcase or part of a green fair or other event
• Location including postal address
• Are you looking for EV owners to exhibit their vehicles?
• Email and phone contact info to be publicly displayed
• Website url
• Graphic/Photo (JPG, JPEG, PNG). Newer iPhones default to HEIC, which WordPress does not accept. Please convert them before sending to us. 2MB maximum size, but smaller is preferred. If you send us a photo with recognizable individuals, please make sure they are ok with our posting it. A photo from a prior year event works, or the photo can be generic as long as it works. Let us know if you need help. 16:9 aspect ratio preferred. The visual is important in making the listing pop.
• Is there a charge for the general public to attend?
• We only accept events where EV owners who exhibit are not charged to do so.
• If you require a hold harmless form, we can link to it if it is online.
• Other items you think we should know about

We understand if you don’t have all of these items. The more you can provide, the better the listing.

We have already begun to receive notifications. Please give us 6-8 weeks notice if you can.

EV Owners Wanted for Fairfield First Responder Training

The EV club has worked with the fire departments in Westport and Wilton in the past. The photo at the top is from Wilton. They have an EV component to first responder training, where the instructor goes over where the cables and battery are for some vehicles and reviews what to do in the event of a serious accident.

The Town of Fairfield is scheduling first responder training on March 17, 20, 21, and 22. They are looking for vehicles to be there from 11-12 and 1-2 on each of these days, so 8 sessions in all. We are looking for EV owner volunteers for as many or few sessions as you can do. Even if all you can do is 1 session, it is greatly appreciated.

Any EV, whether BEV or PHEV, is welcome.

These sessions happen to be a lot of fun. While the trainer has an agenda, the attendees have a lot of general EV questions. They are an engaged and intellectually curious audience. You needn’t worry about being an expert. Just speak to your experience and what you know.

If you can help out, please go to EVClubCT.com/contact and leave a message. We will coordinate with the Fairfield Fire Department.

An Opportunity to Walk Through the Incentive Details

This blog has written a number of posts about the new EV incentive since the legislation was enacted in August of 2022. We are now in the implementation phase with IRS rule-making in progress. While we have a detailed description on our Incentives page, the law is complicated enough that we decided to devote a meeting to walking through the details and answer questions.

This is a Zoom meeting, scheduled for Thursday, March 2nd, at 7 PM. We are planning for one hour, but if there are a lot of questions, we can hang out a bit longer. Anyone is welcome to attend. Registration is free at this link.

Restructured Residential Managed Charging Incentives

For the first year of the program, there was one incentive program. This was a so-called demand-response (DR) program, where the EDCs would declare demand events during peak load periods on hot days. These occurred during 3-9 PM on weekdays from June through September. They don’t happen all the time, just when demand is very high due to heavy air-conditioning use.

The new plan revises this DR incentive and adds a second level of incentive known as Advanced Managed Charging, or Advanced Tier.

Before getting into the details, let’s zoom out a bit.

As noted, current peak demand periods occur during hot summer afternoons. In a fully decarbonized, meaning electrified world, demand patterns will significantly change. If heat pumps become the primary means of climate control, they will be working hardest on the coldest nights where gas and oil do the heavy lifting now. The summertime demand will be reduced since heat pumps are more efficient than AC compressors. So the Public Utilities Regulatory Authority (PURA) wants to inculcate in consumers the habit of thinking about peak and off-peak utilization as a year round thing, while still responding to the near-term load-shedding needs that occur over the summer.

The Authority directs the EDCs to implement an annual passive managed charging program for the residential Baseline Tier, with the on-peak period of 3:00 P.M. to 9:00 P.M. weekdays

participants shall be eligible for a maximum monthly incentive of $10, so long as the customer charges the EV at least 80% of the time during off-peak hours for the given month

EDCs will stagger start times to prevent “timer peak.”

These new programs are anticipated to be effective as of April 1, 2023.

Baseline Tier

The Baseline Tier is structured in 2 parts with separate payouts.

The first is a Passive Managed Charging tier where participants charge 80% or more of the time during the off-peak period and would be entitled to a $10/mo award. Peak times are 3 PM – 9 PM weekdays for this monthly incentive.

Additionally, the Demand Response Events remain during June to September where participants are encouraged to not opt-out of optional DR Events. There can be up to 15 such events, occurring between the hours of 3 PM – 9 PM per month. Participating (i.e. not opting) out in all events in a given month would entitle a Participant to and additional $20/mo for the four DR months.

In total, customers could earn $120 ($10/mo for 12 months) and $80 ($20/mo for 4 DR months) for a total of $200 in Baseline Tier. The total amount of the incentive remains unchanged; only the structure is different.

Advanced Tier

This tier is referred to as Active Managed Charging, where participants work with their utility to set a daily charging schedule that avoids on-peak charging. Customer inputs the State of Charge (SOC) that they need and a Time Charge is Needed (TCIN) and the utility does the rest. Participant can set these as default, for example, “every day, I need 100% charge at 7am” and the utility does the rest. They can also adjust these inputs as needed. Participant is responsible for not overriding the schedule where that act of overriding causes them to charge on-peak. Participants are able to opt out in such a way twice in a given month and still retain their incentive – any more and they forfeit the incentive in that month. There must be a minimum of two at-home charging sessions during the month. The incentive is $25 per month or $300 per year.

Peak time is the same 3 PM – 9 PM as in the Baseline Tier.

Of the comments noted in the docket, the most interesting was from DEEP, which “opined that rather than limiting charging under this tier to solely off-peak hours, the Advanced Tier should instead allow charging during all hours and provide dynamic managed charging to real-time grid conditions.” That would be an optimal approach as, for example, it would take into account weather and distributed energy resource contributions, rather than the current flat approach of set time periods. Ultimately, that is the way we need to go.

Note: Purchase, installation, telematics enrollment incentives are unchanged. In the original docket there was an enrollment option involving a device that would be placed on a dumb charger. There is no sign that one has been approved. There was no mention of anything about it in the participation data.

Additional Funds

Eversource and United Illuminating, the electricity distribution companies or EDCs, have reported high rates of participation for the DCFC (level 3) part of the program, as well as for the installation of level 2 chargers at Multiple Unit Dwellings (MUD). The MUD incentives apply to buildings with more than 5 units and are governed by the rules for commercial incentives. The Public Utilities Regulatory Authority (PURA) has authorized making more funds available in the near term (by accelerating funds designated for other years). Eversource and UI have compiled waitlists for applications received subsequent to funds depletion which will now be able to be included.

Leasing Program for Level 2 Chargers at MUDs

MUD = Multiple Unit Dwelling.

For these dwellings, defined as having 5 or more units, PURA has directed the EDCs to implement a leasing program for EVSE (chargers) as of February 2023. It is felt that some buildings may find it challenging to foot the upfront cost for multiple chargers/ports, even with the incentives and that leasing could ease overcome that. Furthermore, it allows the homeowner associations or building owners to gain experience with charging and tenant interaction.

The leases will be offered for 5 years, followed by an option to renew for another 5 years (at a lower price to reflect depreciation). At the conclusion of the second lease period, the dwelling will have the option of buying the chargers or allowing the EDC to repossess them.

During the lease period, the EDCs are obligated to engage a third party to maintain the equipment.

These are the prices listed in the December docket for the first 5-year term and are not final. Note that they are reflective of the distance between the EVSE and electric service.

Managed Charging for MUDs

How to charge for the power and offer incentives for load-shedding are complicated in an MUD setting, given that incentives are not always aligned between landlords and tenants, and there could be competition between tenants for less expensive charging slots. The EDCs have been directed to propose a voluntary opt-in managed charging program for MUDs for review by May 1 and implementation by July 1, 2023.

Sanity Finally Reigns

The body-style of an EV determines the MSRP cap for incentive eligibility. Sedans have an MSRP cap of $55,000 and SUVs, pickups, and vans can be eligible up to $80,000. MSRP is defined by the manufacturer suggested base price plus factory-installed options. Dealer installed options, software, taxes, and destination fees are not included.

The first round of classifications issued by the IRS fell in the “What were you thinking” category. For example, the Tesla Model Y 5-seat was classified as a sedan while the 7-seat version, which uses the exact same body, was an SUV.

These classifications have been revisited and it is looking much better. All Model Ys are now SUVs. The same is true for the Ford Mustang Mach-E, which had been classified as a sedan. All versions of the Volkswagen ID.4 are now SUVs.

The old classifications were based on the EPA CAFE standards. The revisions result from moving to the consumer-facing EPA Fuel Economy Labeling standard.

This is the IRS page with all of the vehicles for which a determination has been made.

Best of all, these changes are retroactive to January 1! And because of the delay in battery rule making, all of these vehicles receive the full $7500.

Post by Barry Kresch

CHEAPR as a Proxy for EV-Friendly Dealers

It is not unusual for a consumer to reach out to us, usually after a bad sales experience, and ask if we can recommend a dealership. We have some recommendations from members who have had good experiences, but nothing that covers every vehicle make and every dealership across the state. This is our attempt to at least partially address this.

We are using CHEAPR rebates sorted by dealership within vehicle make as a rough proxy for dealer EV-friendliness. There are some limitations. Not all makes have CHEAPR-eligible vehicles. They may be too expensive (e.g. Jaguar) or they’re just not in the game (e.g. Honda). EV prices have gone up in this inflationary time and the CHEAPR MSRP cap was $42,000 for the first 6 months of the year, rising to $50,000 as of July.  There have been continued difficulties with vehicle availability, but at least we are comparing like to like.

Some dealerships are charging a “market adjustment,” meaning the vehicles are being sold for above the MSRP. That does not get reflected in CHEAPR. The MSRP cap is based on the manufacturer’s base MSRP for the trim level without options. That may, however, have deterred some consumers from doing business with them.

There continues to be wide variation among dealership performance, as in past years. If you know of a dealership but do not see it in the charts, that means there were no rebates associated with it in 2022. Sometimes there seems to be a conflict in that a particular dealership name includes a different make than some of the rebates credited to it. That is because the way the dealership name is represented in the data does not indicate that it sells other makes. I cross-checked all the instances of this and the data are correct.

Mitsubishi, which had only one rebate is omitted. Subaru, also with a low count, is included. Chevy and Toyota drove the biggest numbers. Tesla is omitted for obvious reasons.

Rebates by dealership in alphabetical order by make and ranked by the number of rebates within make. All data from the Center for Sustainable Energy.