CHEAPR Running Hot and Proposed Legislative Changes

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.

CHEAPR fleet rules and priorities

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.

 

2023 CHEAPR Rebates by Model

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.




EVs in CT – Where Are We, How Far To Go

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 Registration Counts for EV Makes and Models

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

BEVs and PHEVs registered in CT, Jan 2024

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.

Top 10 EV Makes in CT Jan 2024

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

And top 10 BEV makes with values.

Top 10 BEV CT Jan 2024

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.

Number of Tesla EVs in CT Jan 2024

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.

Toyota and Lexus EVs in CT Jan 2024

Stellantis

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

Stellantis EVs in CT Jan 2024

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.

Chevrolet EVs in CT Jan 2024

Hyundai

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

Hyundai and Genesis EVs in CT Jan 2024

Ford

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

Ford and Lincoln EVs in CT Jan 2024

BMW

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

BMW EVs in CT Jan 2024

Volvo

Volvo EVs in CT Jan 2024

Kia

Kia EVs in CT Jan 2024

Nissan

Nissan EVs in CT Jan 2024

Volkswagen

VW EVs Jan 2024

Audi

Audi EVs in CT Jan 2024

 

Rivian

Note the electric delivery vans for Amazon.

Count of Rivian EVs in CT Jan 2024

Porsche

Porsche EVs in CT Jan 2024

Subaru

Subaru EVs in CT Jan 2024

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.

Honda EVs in CT Jan 2024

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.

Mercedes EVs in CT Jan 2024

Mitsubishi

Mitsubishi EVs in CT Jan 2024

Mini

Mini EVs in CT Jan 2024

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.

Polestar EVs in CT Jan 2024

Mazda

Mazda EVs in CT Jan 2024

Lucid

Lucid EVs in CT Jan 2024

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.

Jaguar and Land Rover EVs in CT Jan 2024

Cadillac

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

Cadillac EVs in CT Jan 2024

 

 

 

 




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. (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.

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 be 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.