1

The Geography of Federal EVSE Tax Credits

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

Map Key

Southwest CT

Census Tract Codes - SW CT

Northwest CT

Census Tract Codes - NW CT

Northeast CT

Census Tract Codes - NE CT

Southeast CT

Census Tract Codes - SE CT




Dealers Hit The Brakes On EVs

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.

 

Dealerships signing letter to Biden administration 2

Dealerships signing letter to Biden administration 1

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.

 




Transfer Provision is Now Live

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. 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.

The transfer provision does come with its own set of wrinkles.

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.

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.

EV Leasing and IRA

 

 

 




EV Club Supports New Haven First Responder Training

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.

EVs at training

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.

EV School busSchool Bus 12 volt battery

 




Signs of Life for Income-Limited Rebates

Above chart is the monthly rebate trend through November 29, 2023. Recent months tend to get restated higher in subsequent updates.

LMI Program Focus

The CHEAPR program has always had a focus on making an EV more affordable for those who otherwise might find the purchase price too high a barrier. There is an MSRP cap to avoid subsidizing the most expensive vehicles. (Until the recent Tesla price-cutting, Teslas were mostly not eligible.) The program also offers consumers with limited income an extra subsidy, as well as a used EV incentive. The standard for doing so was loosened somewhat in 2023 and now applies to households with an income of no more than 3 times the federal poverty level. This translates to $43,740 for a single person or $90,000 for a family of 4. (These numbers get adjusted every year.)

This revised incentive, often referred to as “LMI” for lower-middle income, also offers a “pre-qualification” voucher. Qualified purchasers obtain the voucher ahead of time, and the amount of the voucher can then be deducted from the price of the vehicle at the time of the sale. Even though it’s more complicated to administer, it represents an improvement for the consumer. Buyers now know ahead of time that they are approved for the rebate and no longer have to front the cash as they did with the earlier program design.

This revised program soft-launched in March of this year. Due to the one-year shelf-life of the voucher, it was expected that there would be a lagging effect. DEEP has reported high interest in the voucher, though specific data are not reported. We can only see the reporting based on redemption. There has definitely been an increase in recent months. We hope they will be higher as more vouchers are in circulation. The chart below tracks the monthly redemptions for 2023 through November. It is likely that November will be restated higher with the next release.

LMI CHEAPR Rebates by Month

 

Overall Rebate Volume Slackens But Is Likely to Recover

This is shown in the chart at the top of the post. We believe that this had to do with the base trim level Model Y having been temporarily withdrawn from sale by Tesla as it redesigned the vehicle, and perhaps augmented by the Chevy Bolt’s increasing scarcity as the model sunsets for the time being. The standard range Model Y is back now with an LFP battery, rear-wheel drive configuration for $43,990 (at least today), well under the CHEAPR MSRP cap. The Model Y AWD long range is also under the cap at $48,990. We expect rebate volume to pick up again. CHEAPR has dispensed about $6.8 million year-to-date and is on pace to reach $8 million. This is quadruple what it was in 2022 and is due to greater model availability and the increase in the MSRP cap to $50,000.

Models

The most rebated vehicle this year is the Tesla Model 3 with 927 rebates, followed by the Model Y with 681. These are followed by the Toyota RAV4 Prime (380), Chevy Bolt (274), Volkswagen ID.4 (204), and Hyundai Ioniq 5 (116). All other models were <100.

Fleet Rebates Coming

The final program component included in the 2022 legislation is the rebate program for fleets. It is expected to launch sometime this spring. These apply to commercial, municipal, tribal, and non-profit entities – in other words just about all fleets. Fleets are eligible for up to 10 rebates in a calendar year and 20 total.

There is potentially significant demand for these rebates. Given that potential, and the program having a pretty high burn rate generally, not every applicant will necessarily be granted a rebate. Below is a slide from DEEP indicating how they are prioritizing rebate requests. Please note, the final contours of the program are still being developed.

CHEAPR Fleet Rebate Prioritization

The reason for these gating criteria is to avoid a lapse in available funds that would cause the program to be paused, like what happened in New Jersey. The rebate size and MSRP cap are the same as with the consumer rebates.

Rebates will be pre-certified (and the funds reserved) with post-purchase repayment.




Here’s What Is Going On With The Federal Incentive

The Chevy Blazer, pictured above, is one example of a vehicle losing the incentive.

Most EVs Lose Federal Incentive Eligibility

Unsurprisingly, as we have been forecasting for months, many EVs lost eligibility for the federal IRA incentive. This is due to the step-up in battery critical minerals sourcing and battery component manufacturing requirements, as well as the first half of the implementation of the foreign entities of concern rule. EV advocacy groups, manufacturers, and others have provided input to the Treasury Department during the public comment periods as this was all foreseeable. But not many changes were made.

Below is the list of every BEV and PHEV that is incentive-eligible as of January 4. This is fluid, and vehicles that have lost eligibility can regain it at any time. Manufacturers are wrangling their supply chains to become IRA-compliant as quickly as they can. These are screenshots directly from the Department of Energy (DOE) Website. We advise checking the DOE website for updates if you are in the market as it is updated continuously. We expect to be in this period of volatility for a couple of years.

BEVs

Incentive-eligible BEVs

PHEVs

Incentive-eligible PHEVs

There are some notable absences here, such as the two less expensive trim levels of the Tesla Model 3, every GM vehicle not named Bolt, and the Ford Mustang Mach-E to name a few.

Notice what is listed to the right of each MSRP: “Check VIN.” The DOE website is intended as a general guide, but the determination for a specific vehicle is made at the level of, well, the specific vehicle. Manufacturers must register eligible VINs with the Treasury. Consumers must list the VIN on their tax return and are able to check VIN eligibility on the DOE website.

Same Model, Different Incentive

Different vehicles of the exact same make/model/model year can have different incentive eligibility. It could due to changes in manufacturing supply chains during the model year. It could be timing, as model years are most frequently introduced in the fall, but the requirements change on January 1. The eligibility is also based on the “date placed in service,” which is the date the consumer takes possession. An eligible vehicle on December 31 may no longer be eligible on January 1. (Part of our input was to align the requirements with model year to minimize this. Manufacturers suggested at least basing it on the date of manufacture.) Finally, as foreign automakers stand up manufacturing in North America, there can be a mix of imported and domestically produced vehicles of the same model, potentially on the same dealership lot.

Yellow Flag

If a vehicle is purchased from inventory, there is a VIN. But for build to order purchases, there will not be a definitive incentive eligibility determination until the VIN is available, which is often a short time before delivery. In a dealership environment, where salesperson EV knowledge can be lacking, consumers will need to be vigilant. We wish there were an easier answer.

GM Workaround

GM lost incentives for all its EVs other than the soon to be discontinued Bolt but is discounting those previously eligible vehicles by $7500 until they regain eligibility, as reported by Reuters and others. GM attributed the incentive setback to minor components which are being re-sourced and expected fairly soon. Anyway, a discount is even better than an incentive because it also reduces the sales tax.

Reminders

None of this incentive mishegoss applies to leased vehicles. However, the seller has discretion regarding whether to pass along the incentive.

The transfer provision goes into effect this month. Tax credits can be transferred to the seller with the consumer receiving a point of purchase rebate. It also benefits buyers who would not otherwise have enough tax liability to burn off a tax credit.




Tesla Store Grand Opening at Mohegan Sun

Photo above – Mohegan Sun President Jeff Hamilton cuts the ribbon in front of the Tesla store

Tesla Store Opens on Tribal Land

It has been a long time coming. Finally, Connecticut consumers have a place to go to buy a Tesla and, importantly, take delivery without leaving the state. The new Tesla store at Mohegan Sun is open for business and delivered its first vehicles today. This will help alleviate the crush many of us have experienced at the Mt. Kisco, NY delivery center that we have been forced to go to in order to get our vehicles. It also simplifies the registration process – no more temporary plates.

All deliveries for CT will be at Mohegan Sun. It is a longer distance for residents of the western portion of CT than MK.

The center will have a sales staff and offer test drives, aside from making deliveries.

Federally recognized tribes have sovereignty and the state franchise laws do not apply. These laws have thus far prevented Tesla and other EV manufacturers (Rivian, Lucid, and Fisker with more on the horizon) using the direct sales model from opening stores in CT. The tribe makes its own laws.

The Tesla store will be open 7 days a week.

Tesla has a service and leasing center in Milford, CT. Consumers are able to take test drives there as well.

Who Didn’t Show? Elected officials.

Several elected officials, including the governor, were invited to the ribbon cutting. None came. Like Tesla opening a CT store, this is another historic first. Since when do pols not show up for a ribbon cutting? (Governor Lamont did issue a statement that called the center good news for consumers.) This illustrates how divisive the direct sales issue is – in Hartford. Among consumers, the issue polls 80 – 90% favorable.

75 Destination Chargers, Going to 100+

Mohegan Sun reports that sustainability initiatives are a major part of its commitment to economic growth, tourism and community support. Jeff Hamilton, GM of Mohegan Sun, who described sustainability as part of the tribal cultural heritage, announced that its collaboration with Tesla includes the installation of Tesla destination chargers, which will be in all 3 parking garages and number 75 in total when the installation is complete in the late summer of 2024. Future plans call for an expansion to over 100.

A Big Day But Only A First Step

Lori Brown, Executive Director of CT league of conservation voters, speaking at Mohegan Sun Tesla store ribbon cuttingZach Kahn, Senior Policy Manager for Tesla, speaking at ribbon cutting for Tesla store in Mohegan Sun

Lori Brown of CTLCV                 Zach Kahn of Tesla

Lori Brown, the Executive Director of the Connecticut League of Conservation Voters, noted that today’s event is a win for the environment but that given the climate crisis, we cannot act fast enough. Speaking of direct sales, she noted that “we need to adopt and harmonize laws to get there.”

Zach Kahn, Tesla Senior Policy Manager, East Region, noted the importance of how this facility contributes to sustainable development in eastern Connecticut. He also noted that the state is not nearly on pace to meet its stated goal for EV adoption. (The EV Club agrees with him on this point. The state’s target is for 500,000 registered EVs by 2030 and we only have 36,269 now.)

Tesla and Mohegan Sun also noted their tribal workforce development initiative with Tesla jobs in the offing, an important, if sometimes overlooked, benefit.

EV Club CT team at Mohegan Sun Tesla ribbon cutting

EV Club in front of the new Tesla Store. From left to right – Paul Braren, Will Cross, Phil Levieff, Bruce Becker, Barry Kresch, Demetrios Spantidos, and Lori Brown of CTLCV

It was a good day! The EV Club was glad to be a part of it.




New Policies for Westport EV Chargers

Photo of Baldwin Parking Lot in downtown Westport

No More Free Juice

It shouldn’t come as a surprise. It was not expected that taxpayers would fund free charging forever.

Baldwin was the catalyst, but the policies described below are intended to apply to all town-owned parking areas, and going forward planning for parking includes consideration for EV charging.

The Board of Selectwomen today approved a charge of $.35 per kWh.

Baldwin is a timed lot, and the 3-hour limit applies to the EV spaces as well. There will be a 15 minute grace period before the vehicle is assessed an idling charge of $10/hour, billed in 15 minute increments.

If a vehicle pulls into one of these spaces with a near-depleted battery, 3 hours will not be enough to fully charge it. If the vehicle has an onboard charger of around 11 kW, some back of the envelope calculations indicate that it will be able to get about 30 kWh of charge, equating to roughly 130 miles of range, for a cost of $10.50.

Chargers at the town’s two train stations are exempted from any idling charges.

The charging spaces are for EVs that are charging only. Aside from combustion (ICE) vehicles, it is not permitted for an EV that isn’t charging to use one of these spaces. Citations will be given. We don’t know what the penalty will be, but currently if an ICE vehicle parks in an EV space at the train depot, a $25 fine is assessed.

The new policies will go into effect in January. Free juice reigns for the holiday.

12 chargers, 80-amp units (powerful for AC), have been installed at Baldwin with infrastructure for 12 more for when the time comes. The incentives available through Eversource provide for this kind of future-proofing. The chargers have J-1772 connectors.

Contretemps

Whenever public chargers are installed, it seems to generate some level of controversy.

We hope that nobody thinks installing public chargers is a bad thing. Given the importance of EV adoption in reducing greenhouse gases and other pollutants, and ongoing consumer concerns about range anxiety, public chargers are needed. These can be the powerful DC fast chargers, usually located along highway corridors, but also the less expensive level 2 AC chargers, such as those in Baldwin, in locations where there is more dwell time.

EVs currently account for about 7% of all vehicles registered in Westport. While Westport residents will no doubt use the chargers, it would be a mistake to think that all shoppers/diners are from Westport and that everyone in Westport has access to home charging.

Prime Access

These chargers are located near the front of the lot. It is common to see EV chargers located in what might be considered the prime spots for a parking lot or a building. We have heard the term “elitist” used to characterize this practice. The much more pedestrian explanation is proximity to the power source. Installing the chargers at the back of the lot would require more trenching and would be more expensive. (In a new-build situation, it is much easier to do this.)

In the EV community, most would prefer if the chargers could be located toward the “back of the lot.” Less tsuris.

Ongoing Evaluation

Since being energized, the chargers have been busy. Who doesn’t like free? Topping off may become a less frequent behavior when there is a fee that is higher than charging at home, plus an idling fee. These chargers are connected via the EVConnect service, as all town chargers either are or will be, and charging data, along with consumer feedback, will be used to inform future charger-related decisions.

Charging per kWh

As noted above, the fee is based on the kWh consumed in a given charge. Public EV chargers typically charge either using this method or by the minute. We think a per kWh fee is inherently fairer. You pay for what you use and slower charging vehicles are not penalized.

 




EV Club 2023 – Year in Review

 

2023 was a notable year for the club as it produced a fully subscribed symposium and began a partnership with People’s Action for Clean Energy (PACE).

Northeast Electrical Vehicle Symposium

The EV Club produced its first conference, along with an EV showcase, in conjunction with the CT Tesla Owners Club. It was fully subscribed and is planned to be an annual event. It was hosted at the zero-emissions, LEED Platinum Hotel Marcel in New Haven, and covered topics ranging from the Advanced Clean Cars regulations to electrifying one’s home, EV incentives, utility programs, local EV-friendly zoning and a keynote from You-Tuber Out of Spec Dave. Recap here.

PACE

We have been working increasingly closely with the PACE (People’s Action for Clean Energy) organization. Our collaboration began with data, as we contributed the vehicle data we obtain to the data they use to analyze municipal energy use. This is a service that PACE offers this free to any municipality – they’ll quantify energy use and show where there are opportunities to move to decarbonize.

We are aligned on policy as both organizations support direct sales, regulations for clean vehicles, the Energy Data Bill of Rights, and expanded distributed and shared solar.

We support each other’s events. This allows each of us to improve coverage throughout the state.

PACE offers a number of services for communities, including supporting HeatSmart campaigns for heat pump adoption, help with solar canopy siting, and data on building efficiency.

Finally, PACE has also been giving the club some financial support. We may be a volunteer organization, but we do have expenses! They also accept donations on our behalf. Go here. After clicking on an amount, you will go to a page that allows you to designate how you would like the donation to be used. Choose “create your own,” and type in “EV Club.”

First Responders

The EV Club continues to support our first responders when they hold EV training events. This year we worked with Fairfield, Windsor Locks, Northville, and Middlebury.

Incentives

Incentives are now more numerous, more complex, and a moving target. We decode them and keep up to date with changes for the federal and state EV purchase incentives, as well as the charging incentives offered by the utilities. This is our incentives page. We have worked with a number of individual members to sort through these and help with questions. We also had the opportunity to speak at length with Eversource regarding how to operationally improve the consumer experience with respect to incentives and dealing with voltage sags and transformer sizes that could limit solar production.

Our near term outlook is that the Foreign Entity of Concern rules, the first half of which take effect in January 2024, will cause a reduction in the number of incentive-eligible EVs.

The other important near term item is the transfer option. This enables the consumer to obtain the incentive as a point of purchase rebate rather than a tax credit. The consumer has an option to do one or the other. Aside from getting the incentive sooner, it also enables people who do not have the tax liability to burn off a tax credit to be able to utilize the incentive.

EV Showcases

We continue to support as many EV showcases as we can by helping to publicize the events, and recruiting owners to exhibit their vehicles. We encourage all EV owners to participate in these as it is a great way to discuss the virtues of driving electric and leave out the politics. We also supported and participated in events by Electric Car Guest Drive in New York.

The Club itself staged 2 showcases, one in May and a second in September as part of the Symposium. We were happy to include a Tesla Model Y patrol car owned by the Westport Police. We thank the CT Tesla Owners Club for working with us on these and for arranging for Tesla to give test drives.

If you would like us to post your showcase event, please see this post about the information we need.

Speaking Engagements and Tabling

  • Stonington Energy Fair
  • Fairfield Warde High School
  • Interreligious Eco-Justice Network Forum on Advanced Clean Cars II, Greenwich
  • Central Connecticut State University

Zoom Meeting Presentations

  • SPAN – smart panels – what they’re about and what is involved in installing one in your home
  • Renowned teardown artist and automotive engineer, Sandy Munro, tells it like it is
  • IRA deep-dive into the EV incentives

Policy/News

  • Rivian, after fending off a dealership lawsuit, has broken ground on a service center in Shelton.
  • First Tesla Magic Dock in CT.
  • Participation continues with the national Electric Vehicle Association Policy Committee.
  • The last couple of years have been difficult regarding state level environmental legislation. Advanced Clean Cars II is stalled. It is possible it may come back but not certain. We continue to support a direct sales bill and the Energy Data Bill of Rights.
  • EV Club CT had a presence at the Cybertruck Reveal Event.
  • EV Club is happy to work with municipalities on EV charging, such as the new installation of 12 level 2 chargers (80 amp) in Westport.

EV Club Invited to Grand Opening of Tesla Sales and Delivery Center

This is the facility that is being built on tribal land at the Mohegan Sun Casino complex. The event is 12/20 and registration is here.

Much of the reporting in the mainstream press about this facility labels it as a loophole or a way to skirt the law. We believe this to be a mischaracterization. Tesla is following the law. Federally recognized tribes hold sovereign power on tribal land. It is up to the Tribal Council to approve such a facility and they don’t run scared from dealerships.

Data

We were able to bring the EV Dashboard back, tracking the level and characteristics of EV adoption in Connecticut. Access to data was granted courtesy of Atlas Public Policy, but sourced from the Department of Motor Vehicles.

Continued tracking of EV rebates by dealership, which is our proxy for which dealers are EV-friendly (applicable, obviously, only to those that sell CHEAPR-eligible vehicles). This typically gets updated around March of each year – it depends on when the data get published by DEEP.

Videos!

Find them on our YouTube channel

  • New electric police patrol cars in Westport and Wethersfield (Tesla Model Y and Ford Mustang Mach-E, respectively)
  • Owner video – Andre and his Polestar 2
  • Fairfield First Responder EV training
  • Sandy Munro and Corey Steuben riffing about all things EV and batteries (Meeting recording)
  • Inflation Reduction Act Deep Dive (Meeting recording)
  • Tesla Magic Dock Closeup
  • Smart Panel discussion with SPAN (Meeting recording)
  • Hotel Marcel Tech Deep Dive – Bruce Becker, Paul Braren, Will Cross

 




Banning The “Ban With No Plan” Is Not a Plan

Global Temperature Rise is Already 1.2 degrees Celsius above baseline

The reporting coming out of COP 28 is that the mean temperature is already 1.2 degrees Celsius above the pre-industrial baseline and headed to exceed the critical 1.5 degree threshold by the end of this decade. With 10 months of data in hand, 2023 has already been declared the hottest year on record by a margin comfortable enough to be “safe” regardless of what happens in November and December. There is urgency here. It is not just about whether change will happen but how fast.

Transportation Is Low Hanging Fruit

We have to decarbonize everything, but some sectors of the economy are a heavier lift than others.

  • Extracting CO2 from the atmosphere and sequestering it in concrete: hard
  • Producing enough green hydrogen to power heavy industry: hard
  • Aviation: hard
  • Ground transportation: relatively easy.

In Connecticut, the transportation sector is the responsible for a larger amount of greenhouse gas (GHG) emissions than any other at about 38% of the total, as reported by the Department of Energy and Environmental Protection (DEEP). EV models are becoming more plentiful all the time and generous incentives are available for purchase and charging.

Advanced Clean Car Regulations II

Connecticut, which has been following California vehicle emission rules for ~20 years and is a signer of the Zero Emissions Vehicle Memorandum of Understanding, has been going through the process of adopting the second phase of the California standards. The first phase expires in 2025.

These regulations, which apply to all classes of vehicles (the earlier regulations only applied to light-duty vehicles) would dramatically lower GHG, as well as particulate matter and nitrogen oxides. Aside from climate benefits, there are significant public health and economic benefits. CT suffers from terrible air quality, and we have the asthma rates to prove it.

A more detailed description of ACC II benefits with data are in this earlier post.

The regulations would require the phasing out of the sale of new internal combustion (ICE) light duty vehicles (and reducing the proportion of ICE heavy duty vehicles) by 2035. A portion of the EVs are permitted to be of the plug-in hybrid variety. ICE vehicles already in the fleet are not banned, nor are sales on the secondary market. It does, however, provide opponents a convenient line of attack as a “ban on gas cars.”

Phase 2 of Advanced Clean Car Regulations Blocked by Legislative Regulation Review Committee

Against this background, the legislature has blocked ACC II. The final step of the approval process, the step that follows legislative authorization, DEEP rule making, public comment, DEEP response, and a determination of legal sufficiency by the Attorney General’s office, is for a bipartisan legislative committee to make a determination regarding whether the regulations comport with legislative intent. The remit of the committee is narrow, but a GOP-led effort took it upon themselves to decide to overrule what had been authorized.

The bipartisan committee is made up of 8 members of each party, unlike the legislature as a whole where the Democrats hold a 2:1 edge. The regulations needed at least a tie vote to pass but all of the Republicans were against it and two Democrats, reportedly Senators Osten and Hartley, were wavering with at least one being a likely negative vote. With prospects cloudy, the governor pulled the regs before the vote.

It’s Not Over

The legislature could still authorize it. Democratic leadership will take the temperature of the caucus early in the coming week and then decide whether to raise it before the full body. The outlook isn’t particularly encouraging at this point.

Freedom!

House Minority Leader Vincent J. Candelora, R-North Branford, an opponent of the regulations, as reported in the CT Mirror, said,  “This is about protecting the residents of Connecticut and providing them choice.”

It feels good to know we are now protected, that we have the freedom to breathe dirty air, the freedom to do nothing to mitigate climate change, and the freedom to signal that new green economy jobs should go to other states.

In effect, Mr. Candelora and his colleagues are saying, “Let the market drive EV adoption,” a.k.a. the “business as usual case.” The point of policy is to accelerate the curve faster than BAU. A GOP flyer labels this the “ban without a plan.” This removes the context because, in fact, there is a plan. These are a few points regarding objections raised about the grid, charging infrastructure, and EV costs.

Grid

  • As we move to a carbon-free society where everything is electric, it will be necessary to upgrade the grid. That is why DEEP and the Public Utilities Regulatory Authority (PURA) have a grid modernization docket.
  • EVs are relatively grid-friendly since so much of the charging is done at night, during off peak times. This is a slide from the presentation that United Illuminating gave at the Club’s Northeast Electric Vehicle Symposium in September illustrating the benefits of off-peak EV charging: Grid Optimization using electric vehicles from United Illuminating
  • There is already a program in place that incentivizes Eversource and UI customers with home charging to charge during off-peak periods.

Charging Infrastructure

  • There are over 700 public charging stations with over 2000 ports in CT, per the Department of Energy for the roughly 35,000 EVs, of which about 23,000 are fully electric. (And, yes, we know that vehicles transiting the state need to charge as well.) But, we’re not starting from a bad place. The number of chargers needs to grow along with the increase in EV adoption, and the chargers have to be available throughout the state.
  • The federal Infrastructure and Jobs Act was passed about 2 years ago. Between the federal funds and state matching funds, there will be over $60 million invested in public EV charging stations. There have been no shovels in the dirt as yet, as the process took a while to get finalized. DOT expects installations to begin in 2024.
  • There are incentives for the purchase and installation of EV chargers for both residential and commercial customers, developed by PURA and available through Eversource and United Illuminating. Some of the municipal utilities are offering incentives, as well.
  • EV chargers are eligible for grants from the pool of Volkswagen “dieselgate” settlement funds.

EV Costs

  • It is true that the purchase price of an EV is higher than a comparable internal combustion (ICE) vehicle. But it’s not that much higher, at least according to recent data published by the Kelly Blue Book:

EV vs ICE purchase price

These prices do not take into account incentives. At the present moment, assuming all qualifications are met, a buyer of a new electric vehicle can get a $7500 federal incentive and a $2250 CT incentive. CT also offers a higher incentive for lower income buyers. See our incentives page for more detail.

  • Including operating and maintenance costs, in other words, the total cost of ownership, EVs are more economical relative to ICE. According to the Natural Resources Defense Council: “Bottom line: You can bank on saving across the life of your electric vehicle.” According to Money Magazine: “Upfront costs may be higher for EVs, but these cars are also much cheaper to operate and maintain — and the savings can add up. Over the life of your car, you will often spend less by buying electric.”
  • EV prices will definitely come down going forward. The technology continues to advance across the board, but two reasons in particular are battery costs and scale.
    • Bloomberg New Energy Finance states, “BNEF expects average battery pack prices to drop again next year, reaching $133/kWh (in real 2023 dollars). Technological innovation and manufacturing improvement should drive further declines in battery pack prices in the coming years, to $113/kWh in 2025 and $80/kWh in 2030.” $100 per kWh is considered cost-parity with ICE.
    • Outside of Tesla, none of the manufacturers have thus far fully benefited from scale economics. That will change. These proposed regulations will accelerate that change.

Flexibility

Moving to EVs, let alone decarbonizing the economy overall, involves a complicated policy landscape at the federal, state, and even municipal level. Everyone recognizes this. In fact, in the FAQ document prepared by DEEP, it is stated,  “If we get to a point where it appears that the technology or the infrastructure deployment is such that we would not be able to meet the standards, the standards will change to help suit our needs. This has happened on several occasions in the past with the California standards.”

The vision of a hellscape where many cannot afford a car, and those that can will get stuck is simply not going to happen.

We would like to call out a very good myth vs reality opinion piece published in CT News Junkie, written by Rep. Christine Palm.

You Can Help

Without these regulations, we are back to a world where we really do have no plan, where we are back to passing non-binding resolutions that don’t deliver results.

You can help. Reach out to your legislator and tell them you support adoption of ACC II.

The big environmental advocacy groups, such as Save the Sound, CT League of Conservation Voters, and the Sierra Club are telling folks to reach out to Democrats since it is assumed there will be no Republican support and the Dems control the legislative agenda. We would encourage contacting your legislator regardless of party. CT participation in the original California standards had near-unanimous bipartisan support. There was some Republican support for these latest regs. It is unfortunate that clean vehicles and the environment have become part of the culture war.

Policy Matters

As a closing note, Bloomberg New Energy Finance reported this week that the Inflation Reduction Act is responsible for about $100 billion of newly announced investments in EV and battery plants. ACC II is complementary policy that will enable manufacturers to scale more quickly and for consumers to make use of the output of these new manufacturing facilities.

CT air quality is not in compliance with federal standards. Electrifying transportation is the easiest way for us to get there. If these regulations ultimately do not get enacted, the way forward will be harder, and in all likelihood, we will face a future remain out of compliance indefinitely.