Post by Barry Kresch

The Utilities and PURA Have Worked Out Their Differences

I spoke today to United Illuminating and they advise that they and the Public Utilities Regulatory Commission have come to a meeting of the minds. The EV charging incentives are back and here to stay, that this is not merely a “suspension of the suspension.”

The incentive program is the same for both Eversource and UI, except for some minor differences in approved chargers and telematics vehicles due to the companies using different third-party program implementers. I have been told that Eversource is back online as well, but have reached out to them for confirmation.

UI’s claim is that the dispute centered around timely reimbursement. The program is a pass-through. They get reimbursed for the funds outlay and carrying charges, but do not make a profit on this. Delays in the reimbursement may cause them to delay other investments.

I don’t feel in a position to critically evaluate their position vis a vis PURA, but that is what I heard today. Regardless, it is good news that the dispute is behind us.

Rivian Service Center in Shelton is Finally Open

After a lengthy legal battle, followed by the time necessary to build out the facility, the Rivian Service Center in Shelton, CT has finally opened. Rivian R1S owner and EV Club member, Jeff Manfredonia, sent us these pix after his recent service experience, which he characterized as “excellent” and which included a tour of the facility (no pix allowed in the service area).

The facility is located at 2 Mountain View Drive in Shelton, east of Route 8 and west of the Housatonic River. It was a long road to get to this point.

Dealerships Do Everything They Can to Interfere With Automakers That Use A Direct Sales Model

As we have seen happen with Tesla, a local dealership will step in with a lawsuit using the pretext that the company plans to violate the law. In the case of Tesla, East Hartford was successfully bullied into rescinding a permit, and South Windsor, after the dealerships showed up in force for a hearing, was afraid to grant one. The legal action in the case of Rivian was filed by the local dealership, Mario D’Addario Buick, and TD Properties. The complaint followed the same playbook with the same made-up accusation. The specific language in the filing said Rivian planned to engage in the “sale of new and used Rivian vehicles in violation of Connecticut law.”

After a favorable ruling and an unsuccessful appeal by the plaintiff, Rivian ultimately prevailed. We published multiple blog posts describing these events in this and two earlier posts.

Shelton granted zoning approval in October, 2022 and the subsequent 12 months were consumed by the litigation. The final denial of the plaintiff’s appeals and motions for reconsideration occurred on October 18th, 2023. Rivian then had to renovate the structure for its purposes.

The Facility

This is a service facility with a visitor lounge and service area. There is no showroom and no sales activity of any kind takes place there. The facility will not be used for the delivery of new vehicles. There were reports that Rivian was considering this. We don’t know definitively if that was true but if that were the case, it would skate close to the line drawn in the franchise laws.

Rivian Electric Van

Aside from the R1T pickup and R1S SUV, Rivian manufactures an electric van. The one in the photo is used for Rivian mobile service. The company has an order of 100,000 delivery vans from part-owner Amazon.

Incentive Suspension

This game of chicken that Eversource and UI are playing with the Public Utilities Regulatory Authority has now gotten to the point that EV charging incentive programs are being suspended.

Eversource and UI have essentially the same program whereby they subsidize the purchase and installation of charging equipment. These funds are recovered from ratepayers. EV owners who take advantage of the incentives are required to participate in a managed charging program that pays them to shift their charging to avoid high demand periods. This suspension is not only disruptive for consumers and businesses, it is self-defeating for the larger picture of using demand levers to improve the efficiency of utilizing the grid.

Timing

The UI incentives are already suspended.

Eversource has suspended the Level 3 DC fast charging program. Applications for the Level 2 incentives remain open through May 22nd. After that point, any submissions go on a wait list.

If you are in the process of buying and installing a new charger, the installation must be complete and paperwork filed by May 22 to avoid being waitlisted.

Those who install residential chargers in this pre-suspension period have until June 22 to complete their managed charging enrollment to finalize their eligibility.

New and existing participants in the managed charging program will continue to be paid through the end of the year.

We will provide updates as they become available.

One final note – There are a few municipal utilities in the state that offer incentives for EV charging. These utilities are not regulated by PURA and have nothing to do with the actions of Eversource and UI. The incentive programs at these other utilities tend to be simpler in design, usually covering the charging hardware and installation, but without the managed charging component.

CHEAPR Program Running Hot

The program has been setting records in terms of rebates awarded with each new month. January 2024 was a new high point with 708 rebates as seen in the chart at the top of this post.

CT saw a 47% increase in registered EVs in 2023 relative to the prior year and now a strong start to the year from the perspective of the rebate program. This comes amidst reports of a slowdown in EV sales, a first quarter miss in expected deliveries by Tesla, and a retrenchment announced by Ford and GM. The robust CHEAPR rebates and slower sales can both be true. There is the difference between local and national numbers. And CHEAPR is driven by supply as well as demand, meaning that recent EV price-cutting has enabled more vehicles to be eligible by virtue of now having an MSRP under $50,000.

The other trend in the national reporting is automakers, led by Toyota, shifting emphasis to PHEVs. That is certainly not showing up in the rebate data to this point. Of the 708 rebates in January, 640 of them were BEVs.

Still Waiting for Fleet Incentives

CHEAPR was redesigned in 2022 and there is still one component of the program that is not yet implemented, namely the incentive for fleets. Expectations were that it would go online this spring, but at the board meeting in March, no date was given.

The fleet incentive is potentially a big deal as it applies to municipalities, businesses, non-profits, and tribal entities. A fleet will be eligible for up to 10 incentives in a given year, capped at 20 total. This is only for new vehicles and the MSRP cap applies.

Not everyone will be able to obtain a fleet incentive. With the consumer part of the program running hot and the potential for a high number of fleet incentives, DEEP is prioritizing who can get them. These are the rules that have been developed. The slide was presented at a meeting in December, so never mind about that date.

The next board meeting is in June. We will publish if there is an update.

Summary of 2023 Rebates by Model

Remember, the CHEAPR MSRP cap applies to the base trim level cost of a model, i.e. options not included. This differs from the MSRP cap definition in the federal incentive which includes factory installed options. Not all trim levels of a given model will be eligible. A dealer or manufacturer offering a discount or promotional rate does not reduce the MSRP for the purposes of determining eligibility. Manufacturer repricing does. For these reasons, rebates are not an exact proxy for sales. We know, for example, that the Model Y outsells the Model 3. Also, there are two Model Y columns in the chart as CHEAPR separates the LR AWD version of the Model Y, which they don’t do for the Model 3 for some reason. Taken together, the two Tesla vehicles have almost identical rebate counts.

Since Tesla price-cutting has made more of its models/trim levels eligible, and because Tesla is efficient in letting its customers know when they qualify, the Model 3 and Model Y have dominated. Number 3 is the PHEV Toyota RAV4 Prime, number 4 is the temporarily discontinued Chevy Bolt, and rounding out the top 5 is the VW ID.4.

Program Changes are Afoot

As Advanced Clean Cars II and Advanced Clean Trucks (ACC II/ACT) failed to make it past the legislature, the Transportation Committee raised a bill, HB 5485, entitled “AN ACT CONCERNING TRANSPORTATION INFRASTRUCTURE FOR ELECTRIC VEHICLES.”

It is mostly a study bill and its stated purpose is to assess CT’s readiness for widespread EV adoption and make plans to prepare for it. The bill gives the governor the ability to declare a climate emergency but does not grant any executive authority for him to take action. The governor himself characterized it as a “nothing-burger.” Also, DEEP had already done a lot of research in preparation for ACC II/ACT. If a stronger, more holistic plan to improve EV adoption generally speaking, but especially in distressed communities comes out of it, that would be a benefit.

Arguably, it at least keeps the conversation going. The bill passed out of committee along partisan lines. The Republicans, who led the charge against ACC II/ACT, accuse it of leading to a mandate, even though that is not part of the bill. There can be changes before it comes before a vote in the full chamber. Nevertheless, it has a few specific actions and one of them has to do with redesigning CHEAPR.

The bill directs that CHEAPR be much more heavily focused on distressed communities and individuals with limited income, LMI for short. This is the language, in part: “The bill establishes a CHEAPR program goal to distribute, by January 1, 2030, at least 40% of rebate and voucher funding to a U.S. Census block group in which 30% or more of the population has an income below 200% of the federal poverty level.” A few observations.

• The bill proposes redesigning CHEAPR before the components of the 2022 design have been fully implemented.
• Inexplicably, it proposes to track overall EV adoption using CHEAPR data, rather than the more complete sales and registration data.
• The 2022 changes included the addition of Rebate+ which offers higher incentives for LMI individuals and an incentive for used EVs. These incentives haven’t gotten a lot of traction, but changes to eligibility rules and the implementation of a pre-qualification voucher have led to recent improvements in the rebate levels from almost nothing to ~5-6% of all rebates. Arguably, Rebate+ has thus far suffered from inadequate marketing.
• The current eligibility criteria for Rebate+ is participation in a government assistance program such as food stamps or free school lunch, among others, a household income that is no more than 3 times the federal poverty level, or residing in an environmental justice or distressed community. The proposed definition is different and it would exclude LMI individuals not living in the designated census block groups.
• DEEP would be given the authority to increase LMI incentive levels to an additional 200% of standard rebate levels. At current incentive levels, this would translate to $6750 for a BEV or $3750 for a PHEV should they choose the maximal level. This is in addition to any applicable federal incentive.
• Comparing this proposed new Rebate+ to the current program is not apples to apples. But it does target a similar group, and if the 40% were a hard cap and if it were applied to the program as it exists today, it would shrink it by ~85%.
• There is some additional bonding authority in the bill that could direct additional funds to the program.
• In fairness, the target date noted is 2030, and by then EVs could be less costly than ICE. So, the logic could be that the more general need for an incentive would have lessened. It is not clear what the phase-in process would be.

The full bill text is here. The “Cliff’s Notes” version is here.

A 47% year on year increase in Registrations Still Leaves Us Playing Catch Up

As we recently published, there are 44,313 registered EVs in CT. This includes BEVs, PHEVs, eMotorcycles (eMC), and Fuel Cell (FCEV). The dominant drivetrain is BEV (27,709), followed by PHEV (16,517), eMC (84), FCEV (3). The market has been moving toward BEVs.

The photo at the top of the post looks at the historical trend, the current data point, and what the slope would have to look like for CT to meet its goal of 500,000 registered EVs by 2030. The slope is plotted by calculating a compound annual growth rate from the current level to the goal over the time remaining. This is not the same thing as a forecast.

The good news is that the CAGR works out to a little over 41%, lower than the increase we saw this year. The bad news is the percentage represents a large number of vehicles in the out years. The final year is over 146,000 EVs in that year alone. And that percentage is an increase in net registrations. The corresponding increase in sales would have to be larger to account for turnover.

When the goal of 500,000 by 2030 was set, it was never made clear whether that meant January 1 or December 31. We cut ourselves some slack and used the latter, giving us 7 years to reach that number.

Updated Vehicle Counts Released by DMV

The Department of Motor Vehicles has released its semi-annual update of EV counts that carries us through the end of last year. There were a total of 44,313 vehicles registered, up 47% from one year ago. Of these, 43,868 are BEV or PHEV. The detail for the remainder are not reported. Based on historical data, the biggest piece of the unreported vehicles would be electric motorcycles. There are a few fuel-cell vehicles in the state, less than the fingers of one hand. And, most likely, some blank records.

At the moment, we are working with pieces of the picture. We plan to update the dashboard when we get the complete file.

BEVs Continue to Dominate the Market

Tesla Now Has 16,686 registrations

As can be seen in the photo at the top, Tesla continues to be the dominant brand, with Toyota a distant second. Chevrolet is a very distant second when it comes to BEVs. Below are the top 10 makes with values.

This is the comparison when filtered for only Battery Electric Vehicles.

And top 10 BEV makes with values.

This is the comparison for PHEVs.

And top 10 PHEV makes with values.

Below are the major brands with the individual models displayed, ranked most to least registrations. There is a long tail of brands and the small ones are omitted.

Tesla

The Model 3 still leads due to the installed base, but the gap is narrowing as the Model Y has become the company’s best-selling model. No Cybertrucks were registered as of the end of last year.

There were 6029 new Tesla registrations in 2023. That means there was turnover of 1620 vehicles to get to the new net registration figure of 16,686.

Toyota

Toyota has moved into second position on the strength of its mostly PHEV lineup. The new BEV, the BZ4X, is off to a slow start. There are still a couple of the BEV version of the RAV4 around. This was strictly a compliance car and was discontinued years ago. Somehow a couple made it here even though it was only sold in California.

Stellantis

They have a strong seller in the PHEV Jeep Wrangler. The Fiat 500 is the only BEV.

Chevrolet

Chevy places fourth due to the temporarily discontinued Bolt and the legacy Volt. Bolt sales had been trending upward since the release of the EUV version of the vehicle. Then they had an extensive recall. Sales picked up again as they got through it, but GM canceled it. After public backlash, they uncanceled it and it is now expected to return as a 2025 model year vehicle, using the company’s new Ultium platform. Ultium in general has experienced delays, reportedly due to software difficulties.

Hyundai

Hyundai follows, largely on the strength of the Ioniq 5 and early signs of life from the Ioniq 6.

Ford

After strong starts, the company has had disappointing sales of its F-150 Lightning pickup and Mustang Mach-E.

BMW

The largest of the legacy luxury brands and the final make with over 2,000 registrations.

Volvo

Kia

Nissan

Volkswagen

Audi

Rivian

Note the electric delivery vans for Amazon.

Porsche

Subaru

Honda

These are legacy registrations of no longer for sale vehicles. The company has a new BEV, the Prologue SUV, projected to arrive in the next few months.

Mercedes

Mercedes continues the be the laggard among major luxury brands, far behind BMW. Surprising, given the company’s long history of engineering excellence and many announcements about pivoting aggressively to electric.

Mitsubishi

Mini

Polestar

The Polestar 1 was a high-performance PHEV sports car, imported in limited quantity. There are reports of a corporate restructuring with slow sales of the Polestar 2, introduced roughly 3 years ago. Possibly, it will carry the parent Geely brand. Anyway, the website continues to be business as usual as they are taking orders for the launch edition of the Polestar 3 SUV and have announced a Polestar 4 performance sedan.

Mazda

Lucid

Jaguar and Land Rover

These marques were sold by Ford to the Indian company, Tata. Coming soon is the new Jaguar Electric Architecture. The company plans to transition to 100% electric by 2025! Most Jaguar ICE vehicles will reportedly end production around the middle of this year.

Cadillac

Cadillac, like Chevy, is also waiting with bated breath for GM to scale Ultium.

Federal Tax Credit for Buying/Installing EV Chargers

Before the passage of the Inflation Reduction Act, every residence was eligible for a tax credit of 30% of the cost of the purchase and installation of residential EV chargers up to a cap of $1000. That old credit expired but the Inflation Reduction Act brought it back in a geographically restricted form. (There is a separate program for commercial.) Eligibility is restricted to distressed and non-urban census tracts. After waiting a good long time, and just in time for 2023 tax filings, the IRS has only recently completed its rule-making regarding exactly which census tracts are eligible. Below are the map key and static screenshots, zoomed in to show as much detail as possible. These came from this Department of Energy  interactive map. There are different types of tracts denoted and color-coded, which expire at different points in time. The IRA is around through 2032 but all of these expire by the end of 2030. Note to self: find out why. Perhaps due to the new census, though it feels too soon.

Map Key

Southwest CT

Northwest CT

Northeast CT

Southeast CT

Proposed EPA Rules

Amidst the current contretemps over Connecticut’s stalled efforts to adopt phase 2 of the California emissions standards, known as ACC II/ACT, which stand for Advanced Clean Cars II and Advanced Clean Truck, flying a little less noticeably on the radar screen is a proposed federal EPA rule that could result in roughly two-thirds of vehicles sold by 2032 being electric.

These rules become the default for states not following the California rules and it is good that the gap between the two will be narrower if these rules go into effect. Of course, this being a federal regulatory action, a future administration that is EV-unfriendly could roll them back or loosen them. They can’t do the same to the California rules.

The rules proposed in CT and at the federal level would yield huge reductions in greenhouse gas emissions and provide enormous benefits in public health due to greatly reduced emissions of particulate matter and nitrogen oxides.

The fossil fuel and automotive industries are doing their best to undercut these. We’ve seen the efforts of the Yankee Institute, Heritage Foundation and the misleadingly-named Alliance for Automotive Innovation (lobbying group for the legacy auto manufacturers) to torpedo more stringent emissions standards. While on the one hand, companies such as General Motors and Ford issue press releases promoting how they are aggressively pivoting to electric vehicles, they work behind the scenes to throw sand in the gears. Toyota and Stellantis previously participated in a legal challenge to the waiver California was granted to establish tighter emissions standards that other states could opt-in to follow. (That lawsuit was dropped in 2022.)

4,700 Dealers Send Letter to Biden Administration Against Proposed New EPA EV Rules

One thing that seems a little different at the federal level is that the auto dealerships are playing a more prominent role. Over 4700 dealers have sent a second letter to the Biden administration in January, following an earlier letter in November, that seeks to get the administration to back away from the new standards.

Over 50 Dealers in CT Have Signed The Letter

We have found over 50 dealerships in Connecticut that have signed the letter. They are listed below. These are our neighbors who are actively working against the electrification of transportation to mitigate climate change and improve our air quality. The list is sorted alphabetically by ownership.

As can be seen from the ownership field, the signers are mostly large, multi-dealership owners, in some cases operating in multiple states (though only CT stores are listed here). These are well-resourced entities that seek to forestall EV adoption. It is also a snapshot of an industry that has changed considerably from what once was predominantly a mom and pop business model.

One of the owners on the list, Bradley Hoffman, is a member of the CHEAPR board. CHEAPR is the state’s EV purchase incentive program. Presumably, he has no cognitive dissonance over this.

Sign The Electric Vehicle Association Petition – Dealers Don’t Represent Us

The EVA has fielded a petition for consumers to tell auto dealers, car manufacturers, the EPA, and the Biden administration that dealers don’t represent customers, that drivers support the EPA rules to speed the transition to an all-electric future.

Fisker Ocean pictured above

Transfer Provision Details

The transfer provision is now in place for the federal incentive. This allows the buyer to transfer the tax credit to the seller and take the incentive as, in effect, a point of sale rebate, even if it technically still is a tax credit. Consumers still have the option to take the tax credit the old-fashioned way if they so choose.

The benefit of the transfer provision is the point of sale immediacy, but also the fact that a consumer does not need to have tax liability in order to utilize the credit. (The tax credit is non-refundable and has no carry-forward provision.) Another benefit of the transfer provision is that if you are financing the vehicle, it lowers the amount of interest paid because you are financing a smaller amount. The incentive does not lower the sales tax.

Dealer Registration

A dealership has to register at a portal created by the Treasury Department. This portal captures the transactions, the associated VINs, and enables the process whereby the Treasury issues reimbursement for the incentive to the seller and verifies the transaction at tax filing time. This applies to both new and used EVs. It also applies regardless of whether you are taking the transfer or the standard tax credit. In other words, if you are counting on the incentive, don’t waste your time speaking with an unregistered dealer.

According to Treasury press releases, about 50% of new car dealers have registered. This could still increase over time. Sellers of vehicles that are not eligible may not have a reason to register at present, though they would still need to if they sell used EVs. Not every dealer who registers gets approved, though we don’t have detail as to why that would be. Buyers of a vehicle from an unregistered dealer only get the standard tax credit.

Only a very small percentage of the 150,000 used car dealers have registered. Big sellers like Carmax and Carvana have not registered. Nor has Hertz which has been selling a large number of used Teslas.

There is no master list from Treasury delineating which dealerships have registered. This is very disappointing. The only option for consumers is to directly ask the dealership. (Some dealerships are advertising their registration.) We recommend making sure a dealer is registered before going there to shop if you are thinking about using the transfer.

The dealer issues a seller’s report for the transfer. You must get this before the car leaves the lot. If you do not, the only option available to you is the standard tax credit.

VIN Verification

Final determination of vehicle eligibility cannot be made until a VIN is available. Hopefully, dealers will be supported by their affiliated manufacturers and be able to accurately represent the status of a vehicle, including build to order.

Used EVs

A reminder, incentive-eligible used EVs must be at least two years older than the current model year and have not previously had an incentive associated with the VIN. Almost no used EVs have received an incentive, so for the time being the prior incentive consideration is largely beside the point. The income limits (see below) are half what they are for new EVs and the negotiated price must not exceed $25,000. Used EVs are eligible for the transfer provision. Hopefully, more used car dealers will register. In the near term, the transfer is more likely to be available from a new car dealer that also sells used EVs.

Battery Rules Lead to a Reduction in Eligible Vehicles

The new rules for 2024 are in effect, specifically higher thresholds for battery critical minerals, battery assembly, and the implementation of the first half of the foreign entity of concern (FEoC) rule. For the FEoC, no battery component assembly can take place in China as of this year.

A car must certified by the manufacturer that it meets the requirements and must appear on the EPA list at FuelEconomy.gov to be incentive-eligible.

It is not a surprise that the number of incentive-eligible vehicles has decreased. We expect a gradual recovery going forward as more North American assembly and battery plants come online, and more critical minerals come from eligible sources.

Income/MSRP Cap

The non-battery-related provisions of the incentive rules remain in place.

The income limit is $300K/$225K/$150K for joint/head of household/individual filers respectively. This refers to modified adjusted gross income. You can fulfill this requirement with either your current or prior year income. There is one exception to this, which is if you get married during the year you bought the vehicle and the income of your new spouse put you over the limit, you would not be disqualified.

The federal incentive has an MSRP cap of $55K for sedans and $80K for an SUV. The definition of MSRP includes factory-installed options but not software.

Discounting

We have been seeing reports that several manufacturers, and we have specifically seen reports of GM, Ford, and Hyundai, discounting vehicles to partially or fully compensate for the lack of an incentive. This is an example from GM Authority. Discounting is even better than an incentive because it lowers the sales tax.

Leasing

None of this changes the fact that these rules don’t affect leases. The finance company that holds the lease receives the incentive and it is not subject to battery, assembly or any other rules. The lessor is not required to pass the incentive to the consumer. And leasing costs tend to be opaque due to the different factors that determine them. That places a greater burden on the consumer to obtain the specifics of if/how the incentive is incorporated into the monthly rate. All of that said, however, EV leasing has shot up rapidly, as can be seen in this chart from The Peterson Institute for International Economics, using data from Edmonds. The biggest increases are from non-North American brands, so apparently, the incentive is getting passed along.

Photo above of the school bus battery pack

More EVs and More First-Responder Training

The EV club got its first request a couple of years ago from the Westport fire department asking if the club could have some owners bring their EVs to a training session. Since then, the requests have become more frequent. EVs are a lot more visible now but not widespread enough that help wrangling them isn’t needed. The club has supported trainings in Westport, Wilton, Fairfield, Northvale, Enfield, and now New Haven. This particular New Haven session was organized by Greater New Haven Clean Cities.

Participation

The EV Club greatly appreciates the EV owners who have brought their vehicles to these trainings to support our first-responders. If readers of this blog are interested in participating in future requests – and there will be some, we just don’t know when or where – please reach out to the EV Club using our webform or at info@evclubct.com

Firefighters See Several EVs and Electric Schoolbus

EVs present unique challenges in a serious accident. People may need to be extricated and firefighters must learn where the cable connections are and how to de-power the vehicle (assuming the vehicle hasn’t already done so on its own, which many are programmed to do). And in the event of a fire, special procedures must be employed.

This was a particularly well-attended session with approximately 60 first-responders in attendance.

EVs present were a Kia Niro, Tesla Model Y, Chevy Bolt, Chevy Volt, Ford F-150 Lightning, and an electric school bus.  CT has received a federal grant for 50 electric school buses, so the presence of a bus was timely.

The bus has a 317 kWh battery and gets 200 miles of range. It is equipped for bi-directional charging, though it hasn’t been enabled. One of the issues for bi-directional is that there is still a lot to be learned about how the battery will hold up with numerous additional cycles and who is responsible if it needs to be replaced prematurely. In some places, the utility owns the battery and takes responsibility, but that kind of arrangement is not in effect in CT.