Rebates Way Up, Mostly Due to Tesla

DEEP has published stats through June 14th, but for the purposes of this post, we are looking at complete months, thus through May 31st.

As can be seen in the chart at the top of the post, rebates have really spiked. In fact, the 286 rebates in May is the most the program has ever had in a calendar month. This is mostly driven by Tesla.

Below is the trend of rebates by model. That green hockey stick is the Model Y. Price cutting by manufacturers has brought some popular models below the $50K CHEAPR MSRP cap. The Model Y is the best-selling electric vehicle and the best-selling non-pickup vehicle in the USA, and as soon as the base trim level became eligible, it zoomed right to the top in terms of rebate count. The brown line that is currently second is the Model 3. The base trim level Model 3, as well as the reintroduced long-range non-performance version are CHEAPR eligible.

Aside from the Tesla vehicles being the most popular EVs, Tesla has been the best organized in terms of helping eligible consumers claim the rebate. With dealerships, it is bit of roulette as not all of them are up to date on the program or have knowledgeable salespeople. We have also heard that some of the finance companies that dealerships use for leased vehicles don’t accommodate the incentive.

Ford recently announced a price cut for the F-150 Lightning and the base trim level will now qualify for CHEAPR.

Outside of the Tesla models, only the Toyota RAV4 Prime PHEV was rebated in double digits. The RAV4 had been a leader in the number of rebates but has been tracking at a lower level more recently. The Chevy Bolt, particularly the newer EUV variant, had been building as the company began to see daylight in its recall efforts, but that momentum is stalling with the cancellation announcement. The Bolt had come to dominate the value segment. It was small but not that small, with a roughly 238 mile range for about $30K. GM doesn’t comment on future plans before they become firm, but they have dropped hints that they value the Bolt nameplate and, who knows, we may see a variant of it on the new Ultium platform.

This is what May looks like.

New Rebate Plus – Rebates for Income-Limited Individuals

The latest piece of the CHEAPR program to go live was the loosened income standard and pre-qualification voucher for the supplemental income-limited rebates. The pre-qualification voucher enables the buyer to get a “cash on the hood” incentive, rather than be forced to float the cash until a reimbursement arrives. Also, the highly restrictive previous eligibility criteria was expanded to include anyone with an income level up to 3 times the Federal Poverty Level. More detail on this program can be found on this blog post here.

DEEP reported an encouraging early response in terms of voucher requests. To this point, very few rebates are appearing in the data. This shows rebates by month for Rebate +. The program soft-launched, meaning absent a marketing push, on March 29. It feels to us that given the multi-step process, it is too soon to know how well this new program is working.

There are several things that have to happen before a voucher request turns into an incentive.

• How long does it take to get the voucher approved?
• How long will the consumer take to place an order?
• How long will it take for the vehicle to be delivered?
• Is there any dealer friction over the new voucher process that holds up orders?
• How many people get a voucher that they then do not use?

Hopefully, we’ll be in a position to get a better read on this by the fall.

Post by Barry Kresch

Tesla Patrol Car Purchase Price Now Lower Than Ford Explorer ICE Police Vehicle

In 2019, when the Westport Police purchased a Model 3 for use as a patrol car for $52,000 vs. $37,000 for the incumbent gasoline-powered Ford Explorer, it was a good deal. But it had to be proven, as some were skeptical that the savings would be significant enough to overcome the $15,000 purchase premium. In our analysis, we found that when factoring in savings in fuel, maintenance, customization, and expected vehicle life, the Model 3 is projected to save over $50,000 over a 4-year period. The purchase price differential was recouped in the first year. That detailed analysis is here. Fast forward a few years, however, and things have really changed.

The law-enforcement version of the Ford Explorer, which comes with a few augmentations, such as a heavy-duty alternator, to be able to support the customization needs of the police, is now $47,000. The Westport Police expect delivery next month of their third Tesla and second Model Y, purchased this year, for which they paid $53,000. This new Tesla is eligible for Inflation Reduction Act incentives of $7500, making the acquisition price lower than the Ford.

The IRS code section 45W, clean vehicles for fleet incentives, applies to this vehicle. In 2023, obtaining the credit is a little cumbersome because an entity that does not pay taxes must file for “direct pay” to get the funds from the Treasury. This will become easier in January when the transfer provision goes into effect. The buyer transfers the tax credit to the seller and the seller gives the incentive as a rebate, deducted off the invoice price. This article describes the process for non-taxable entities.

The department buys the same Tesla vehicles that consumers buy. The Model Y that the police bought is the lowest-priced trim level – dual motor (AWD), standard range (279 miles). With continuing price-cutting by Tesla, that model, if bought today, goes for $47,740. At that price, it would also be eligible for a CHEAPR rebate of $2250. (CHEAPR rebates for fleet purchases are expected to be implemented within the next couple of months of this writing on 6/27/23.) The net purchase price for a Model Y will be $37,990, or $9000 less than the Explorer.

The Model Y now seems to be the EV of choice for the Westport Police, rather than the Model 3 due to the extra space. At the time the Model 3 was purchased, the Model Y did not yet exist. (The only other police department in the state with an electric patrol car is Wethersfield, which has a Ford Mach-E. The Westport PD also has other EVs for non-patrol duty uses, including these new additions.) A video walk through of a fully customized Model Y and the Mach-E can be found on the Club’s YouTube channel.

Increased Expectations for Vehicle Service Life

When we did the financial analysis in 2021, after the Model 3 had been in service for a year, we built an amortization schedule based on a projected 6-year service life for the Tesla compared to the historical 4 years for the Explorers. (After 4 years, the maintenance costs for the Explorers make it not cost-effective to continue using them as patrol cars.) Three years into the use of the Model 3, the police feel it is quite possible that the 6-year projection may be too conservative. The vehicle is holding up well. Maintenance costs are as low as forecast. The battery is in good shape (and they are monitoring it with Tesla-Fi). They intend to run with it as long as they can. Let’s say, and this may also be conservative, that the 6 years turns into 8 years. That means the capital cost of acquiring patrol cars gets cut in half.

How Is This Not a No-Brainer?

• Lower acquisition cost
• Lower fuel costs
• Lower maintenance costs
• Double the service life
• Better performance

Westport Police Add Electric Utility Vehicle and Electric Motorcycle to Fleet

Both vehicles were on display at the Westport Sunrise Rotary Duck Race fund raiser on June 24th as the department display the ongoing results of its efforts to reduce carbon emissions, as well as benefit from lower EV operating costs.

The photo at the top is the all-terrain utility vehicle. It looks rather like a golf cart, though designed for heavier-duty applications, including the winch on the seen on the front. This vehicle has the life we would all like to have, spending its days at Compo Beach, where it can be used on the sand if needed.

The vehicle is powered by 6 12-volt batteries. These are not lithium-ion. A charge lasts between 8-12 hours.

Vehicle interior.

Zero Electric Motorcycle

Photo is Westport Police Chief Foti Koskinas sporting the new Zero Electric Motorcycle (before he had a chance to change into his uniform). The Zero is a recent arrival and still has to be outfitted with decals and police lights. It will be used for parking and traffic enforcement. It replaces a Harley that was retired.

This stealthy bike has a 17.3 kWh battery, rated for a range of 183 miles city and 85 miles highway. Chief Foti states that those numbers are so far achieved in real world experience.

Besides these two new vehicles, the department has 2 Tesla patrol cars with a third on order, 2 Toyota Prius Prime Plug-in Hybrid, Honda Clarity PHEV, and a BMW i3 Battery Electric Vehicle – seven plug-in vehicles in all plus a Ford Interceptor conventional hybrid patrol car.

The following is a summary of what was reported in the recent CHEAPR board meeting.

Pre-Qualification Voucher Program for Income Limited Persons

This new program soft-launched on March 29th.

There have been supplemental rebates for income-limited buyers (often short-handed as LMI) for new EV purchases, as well as rebates for used EV purchases for several years. These have gotten almost no traction. From the beginning, concerns were expressed that the criteria (participation in certain government assistance programs) were too restrictive and the post-purchase application process, whereby the purchaser had to float the cash for the incentive (as well as live in some suspense that it would come through), were just not realistic.

Those complaints, along with the empirical data, led the legislature to direct changes to the program that became law in Public Act 22-25, passed in 2022. In addition to the government assistance program participation, an income option was added, specifically that households with income of up to 3 times the federal poverty rate would be eligible regardless of program participation. Some examples of 3x poverty: $43,470 for a single person household and $90,000 for a 4-person household.

DEEP reports this has led to an encouraging early response. This is based on vouchers awarded. It doesn’t definitively mean that everyone who received a voucher has used it. That was a subject of discussion when the LMI program was first implemented. Apparently, some other states that had used vouchers had seen low conversion rates, and there was concern about how wasteful the extra admin overhead would be. As of this writing, DEEP has only updated published rebate data through April 13th, and there are no recorded LMI rebates between the end of March and April 13th, so it is too soon to have any visibility.

The next step is for there to be a marketing push. A vendor has been selected and we’ll see how fast the information gets out.

Used EV Rebate

As noted above, the LMI program includes rebates for used EVs. The CHEAPR website indicates which EVs are eligible, just as it does for new EVs. Only vehicles that previously met the criteria for eligibility when new will be eligible as a used vehicle. We thought there might be a willingness to loosen this and it is disappointing this is not the case. We think it needlessly limits the options for the consumer. There is already a gating requirement in terms of income limits. This feels needlessly restrictive.

There are some details that we await. The MSRP cap was lowered, then raised over the course of the program. Is the eligibility based on the current cap or the cap in effect at the time? What if a model has had price changes?

Fleet Incentive Program

A major addition to the program was extending the CHEAPR incentives to fleets. This applies to private fleets, municipalities, non-profits, and tribal entities. Non-profits must provide a Certificate of Legal Existence to prove good standing. According to DEEP, the launch will occur sometime in the third quarter.

The cap is 10 rebates per year and 20 lifetime. The DEEP commissioner has some flexibility to raise the cap for an organization if it is determined to be warranted.

The fleet program applies to new vehicles and the standard rebate only. The MSRP cap of $50K applies here as it does with the consumer.

E-Bike Rebate

The first phase of the e-bike program is scheduled to launch on June 28th with a point of sale voucher for brick and mortar stores. Online sales will come along later. CT residents age 18 or older can apply for a voucher that can be redeemed for an eligible e-bike at a participating retailer. Check with your preferred e-bike retailer to see if they are enrolled in the program.

The base rebate is $500. That can be augmented by an additional $1000 for LMI individuals.

There is an MSRP cap of $3000.

Eligible bikes must have either a UL 2849 or EN 15194 certification. (A pending certification does not count.) This is an important requirement to ensure safe e-bikes are purchased. Generally speaking, and unlike with automobiles, there is a paucity of regulation at this time. There is a lack of awareness that there are unsafe e-bikes out there, and with lithium-ion batteries, you are literally playing with fire.

Update: According to Bloomberg, the program was fully subscribed within 3 days of launch.

Workplace Charging – An Underappreciated Part of EV Charging Infrastructure

UPDATE

This program featured panelists Ryan Boggio from Clean Cities, Marriott Dowden from United Illuminating, and Catherine Duncan from the CT Green Bank. Key discussion points:

• There are benefits with workplace charging that accrue to businesses, fleets, and employees.
• There are considerable financial incentives available to customers of Eversource and United Illuminating to offset the cost of the equipment and installation.
• The CT Green Bank offers affordable financing options, as well as the ability to participate in the state’s nascent carbon credit market and earn money every year for each charger that is installed.

The webinar has been posted on YouTube.

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We need more EV chargers. Lots more. Significant progress is being made, courtesy of recent federal legislation in particular, but the majority of the firepower is concentrated in expanding DC fast charging along major highway corridors, and to a lesser extent, downtown areas. Workplace charging can fill a critical gap and meaningfully contribute to alleviating range anxiety concerns, along with being a big win for employees and their employers.

Workplace charging benefits:

• Creates charging access for employees who lack it where they live.
• Attract/retain employees.
• Can include charging in employee benefits portfolio.
• Induce employees to go electric when they get their next car (especially if it is part of a program that educates them about EVs).
• Company can be seen as an environmental leader and be part of the conversation locally about moving to net-zero.

For those interested in learning more, there is a webinar scheduled for June 29th at 12 PM for one hour, presented by CT Southwestern Area Clean Cities, CT Green Bank, United Illuminating, and the Bridgeport Regional Business Council covering:

• Introduction to workplace charging: understanding the importance of workplace charging infrastructure and its role in supporting the transition to electric mobility.
• Financing an EVSE project: learn from experts at the CT Green Bank and UI as they discuss financing options and opportunities to support workplaces in implementing their EVSE projects.
• Benefits of Workplace charging: discover how workplace charging positively impacts employees, businesses, and the surrounding community.
• Q&A session: engage with our panel of experts and get technical questions answered.

Free registration at this link.

Court Rules in Favor of Rivian’s Motion to Dismiss; Plaintiffs File Motion to Reargue

Note: For those following this case, the docket number is AAN CV 22-6049137 in Superior Court, J/D of Ansonia, Milford. This is the link.

Update: Hearing scheduled for June 20 regarding plaintiffs motion.

June 20 Update: Court denies plaintiff motion for re-argument and sustains Rivian’s objection to plaintiff’s motion.

Rivian needs a license from DMV. Should they get that, and if there are no further appeals, they should then be in a position to begin renovating the site. The plaintiff has 20 days from June 20 to file an appeal if they so choose.

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Rivian seeks to open a service center in Shelton, though they also want to deliver new vehicles at the location. There would be no showroom and no sales activity. Shelton granted an approval for a facility to be located at 2 Mountain View Drive. Mario D’Addario Buick, along with TD Properties, the owner of the D’Addario property, filed a lawsuit to force the Town to rescind the approval.

On May 16, the court ruled in favor of a motion filed by Rivian to have the lawsuit dismissed. The court ruled that the plaintiffs lacked standing due to their arguments not being a zoning issue but rather a licensing issue, which is the province of the Department of Motor Vehicles. Zoning regulations are meant to protect the public interest and are not intended to address business competition. Furthermore, Rivian acknowledged that it cannot carry out any activities that may require a license until it obtains such a license.

On June 5, the plaintiffs filed a Motion for Reconsideration and Reargument. They contend that since D’Addario has a new car dealer license and Rivian does not, they are a protected class of business in this licentiate, and this amounts to illegal competition.

This is not a legal blog and we don’t know whether DMV will get involved or where this will go. This is an earlier post from when the initial lawsuit was filed. Our opinion, in general, is that the dealerships are trying to make it as difficult as possible for direct sales companies to open servicing facilities. We have seen this with Tesla in East Hartford and South Windsor, and now this episode with Rivian.

Post by Barry Kresch

The Direct Sales Morgue is Enlarged By One More Year as Bill Dies in Committee

As the legislative session inches towards its conclusion on June 7th, we have been through another year without enactment of legislation that would permit electric vehicle manufacturers using a direct sales business model to open stores in CT. These bills would permit manufacturers of exclusively battery electric vehicles (BEVs) that do not have an established dealership network (and are not majority owned by a company that does) to open company stores to sell and deliver directly to CT customers. These are companies such as Tesla, Rivian, and Lucid, with others on the horizon.

The proposed legislation would not affect the arrangements that existing dealerships have with their affiliated manufacturers. Governing the dealer/manufacturer relationship was the intent of the laws when they were passed long ago. All these dealer claims about how the franchise laws protect consumers is just smoke.

CT Insider, reporting on the current legislative session, quotes Transportation Committee Co-Chair, Sen. Christine Cohen characterizing the bill as “controversial,” that it would take up a lot of committee and floor time, and lack the votes to pass.

To quote former State Senator Will Haskell (D-Westport) when he previously raised direct sales, this bill is only controversial in Hartford. The way the bill was killed this year is the way it is always defeated – without being called for a vote. The legislators well know that their constituents support this bill. Many legislators are afraid to cross the dealerships, an entrenched and well-funded special interest. By working behind the scenes to prevent the bill from being called, they can have it both ways. They keep the dealers happy and they don’t have to go on the record opposing their voters, not to mention ding their environmental scorecard. (The CT League of Conservation Voters, the organization that publishes the scorecard, views direct sales a pro-environment measure, but the scorecard can only count votes that are cast.)

This blog wagers that a number of these behind-the-scenes “no” votes would turn to “yes” votes if taken publicly.

The CT Insider reporting also quoted Cohen as citing the actions of Tesla CEO, Elon Musk, as being a factor costing support. It is fair to acknowledge this. He is not helping matters. Direct sales used to be referred to as the “Tesla Bill,” but there are now other companies using this model. This blog sees this as a larger issue of consumer choice, EV adoption, and economics. It is the single most effective thing that can be done to accelerate EV sales.

Dealerships at times object even to their own affiliated manufacturers’ efforts to sell more EVs. For example, Ford’s new Model-e program that seeks to more aggressively position dealerships to sell EVs is moving forward, but it has engendered resistance and dealership lawsuits. The CT dealership trade association enlisted several CT federal and state elected officials to speak out publicly against the Ford plan.

Some legislators do openly support direct sales. Included among them is Rep. Keith Denning (D-Wilton), who submitted a direct sales bill this year, which was not raised by the Transportation Committee Chairs. This blog reached out to him and he provided this statement:

Delaware State Court Rules Direct Sales Does Not Violate Franchise Law

A nearby state, Delaware, now has direct sales. This came via the judiciary. A recent ruling from the Delaware Supreme Court held that the language in the franchise law applies only to existing manufacturer-dealer relationships and is not applicable to new companies that operate sans dealerships. Tesla filed the lawsuit.

For this to have a chance to happen in CT, Tesla or another manufacturer would have to file a lawsuit in state court. They are a legitimately injured party and would have the standing to proceed. The unsuccessful efforts to date in CT to legalize direct sales have only gone through the legislature. One potential downside is that if such an action were to be filed, the legislature would likely punt on dealing with it (which is basically what they’ve been doing anyway) until the process plays out. That could take some time. The Delaware case was appealed before it was taken up by the Supreme Court.

Massachusetts is another state in the region where direct sales came about via a lawsuit. However, if there is one takeaway from the Delaware ruling, it is that franchise laws are not uniform across states. The language of the CT law would have to separately be tested.

Consumers Support Direct Sales

The option of buying a vehicle via direct sales is overwhelmingly favored by consumers. When last the issue was polled in CT, 83% were in favor. Support cut across age, party affiliation and ethnicity. (The polling was fielded by public-opinion firm, GQR, with a sample of 500 likely voters and had a margin of error of +/- 4.4% at a 95% confidence interval. More detail is in the linked page.)

Testimonial Unanimity – When there was open testimony in 2021, 81 written testimonies were submitted to the Transportation Committee. If one excludes the 9 from individuals associated with the dealerships and the 3 from Tesla, Rivian, and Lucid, we are left with 69 from members of the public at large. All 69 of them were in favor of direct sales.

When Sen. Cohen remarks that the bill takes a lot of floor time (i.e. inconveniencing the legislators), the reason is that many people register to offer oral testimony. Public hearings package multiple bills into a day of hearings. When direct sales is on the agenda, it becomes a very long day indeed. In past hearings, some legislators have looked visibly annoyed, and some of them verbalized it, that they have to sit through more hearings about direct sales, where everyone but the dealers are in favor. Legislators, generally speaking, exhort the public to get involved. In this case they do, and ironically, it’s a problem for them. This was mitigated in a narrow sense in the short session of 2022, where by prearrangement, only a small number of people were permitted to testify.

Dealerships Now Seek To Block Service Centers

A more recent insidious development is that dealerships have mobilized to block direct sales manufacturers from opening service centers. They want to make getting the vehicles serviced as inconvenient as it is to buy them.

Hoffman Auto sued East Hartford when they granted a permit to Tesla to open a badly needed second service center to complement the existing one in Milford. East Hartford subsequently withdrew the permit and Tesla did not further pursue it. Dealer representatives showed up in force for a hearing in South Windsor regarding a proposed Tesla service center. More recently, Mario D’Addario Buick and TD Properties sued Shelton and Rivian after the Town granted Rivian a permit to build a service center. Rivian’s motion to dismiss is awaiting a ruling. The dealers latch on to anything they can to throw up roadblocks for these companies.

That New Tesla Service Center – It’s In Massachusetts

Tesla is building a new sales and service center in Chicopee, MA. The company was granted an approval by the Chicopee City Council on May 3rd. Chicopee is only about 10 miles north of the CT border off I-91. This location will be more convenient for customers in Hartford and points north than Milford. That sound you hear is those jobs and taxes going to MA. This will take some of the pressure off getting a Tesla serviced locally. It doesn’t change the fact that CT Tesla purchase customers have to pick up their vehicles in Mt. Kisco, NY.

Direct Sales = Greater EV Adoption

Every year there has been testimony before the legislature, the dealer representatives talk about how all-in they are for electric vehicles. Then every year, they keep not selling them, or not that many of them. When we look at the data, we see only modest growth.

Tesla has testified that an ideal scenario in its view is that Tesla becomes a smaller slice of a rapidly growing pie. That hasn’t happened. In fact, the Tesla share of registered EVs is higher now than when we began tracking it in 2017.

New Sierra Club Study

The Sierra Club recently released the third wave of its ongoing EV Shopper Study with fieldwork conducted in 2022. These studies have been fielded in 3-year intervals. Consumers visit or call dealerships to ask about EVs, see if the salespeople are able to answer basic questions, find out whether there is a charged vehicle available for a test-drive, etc. The findings of the new study are as disheartening as those of past studies.

• 66% of car dealerships did not have a single EV for sale. Keep in mind, this includes both new and used vehicles.
• To some degree, supply-chain issues persisted into 2022, but of the 66% of dealerships without EVs, 45% of them said they had no interest in selling EVs.

These numbers are exclusive of companies such as Tesla, Rivian, and Lucid that do not have dealerships, and which obviously want to sell EVs. Also, they are national numbers. The Sierra Club does break the numbers down by region, but the numbers in the Northeast were not that different from the overall profile.

Some dealers make an effort, but we are still a long way from where most or all dealers act like they actually want to sell EVs. This is consistent with what we have been seeing in our ongoing analyses of CT CHEAPR rebate data.

Atlas Public Policy – Direct Sales Would Remove an Estimated 42 Million Metric Tonnes of CO2

Atlas Public Policy builds analytical tools to help policy makers and businesses make decisions. Atlas, in conjunction with the Electrification Coalition, undertook an analysis to assess whether a state’s adoption of direct sales accelerates EV adoption. Their findings were that, indeed, it does. From the report:

• Consumers have reported poor EV buying experiences at dealerships,
• Dealers are incentivized to sell internal combustion engine vehicles rather than EVs due to the dealership revenue associated with future servicing needs,
• Dealer franchise laws add costs for consumers, and
• Giving consumers the freedom to buy via direct-to-consumer models leaves both consumers and manufacturers better off.

The report goes on to forecast what the emissions impact would be if direct sales were to be adopted country-wide. Because it is a forecast, it presents its findings as a range. The midpoint of the range would result in the removal of 42 million metric tonnes of CO2 in the period of 2023-2030.

Bloomberg Analysis

Bloomberg published an opinion piece entitled, “Car Dealership Laws Aren’t Fit for the Electric Age,” in which they looked at EV adoption in open vs. closed states. (The article is behind a paywall.) The results were quite striking with over 3X the EV adoption rates in states with uncapped direct sales, compared to those prohibiting the practice.

The legacy Automotive Industry Is Often Its Own Worst Enemy

One could be forgiven for thinking that the strategy of many of the established automotive companies has been denial.

Ford is a notable exception. They made the Model-e gambit, followed last week by the hugely consequential announcement that the company has negotiated an arrangement with Tesla to give Ford owners access to the Tesla Supercharger network, and that beginning in 2025, Ford vehicles will be manufactured with native Tesla-compatible connectors. In our view, the Supercharger arrangement is a smart move for both companies. It potentially could influence other companies to follow suit. (We understand that existing Ford EV owners will be able to get adapters. We would be interested in hearing from Ford owners who are readers of this blog about how and what Ford is communicating. Please leave a comment.)

CCS stands for Combined Charging Standard and NACS stands for North American Charging Standard. CCS is backed by most manufacturers. Where it says “Tesla” below, it is the NACS connector, which is the standard Tesla uses and has been pushing to be the universal connector, without much success until now. You be the judge of which is the more elegant design. Between Tesla and Ford (and, I suppose, I shouldn’t overlook Aptera; though they haven’t delivered any vehicles yet, they still get points), the majority of EVs on the road will have NACS.

Not all companies are moving aggressively like Ford. Stellantis is a major manufacturer, the owner of Jeep, Chrysler, Dodge, Ram, Alfa Romeo, Fiat, Maserati, and several others. And yet if we look at their profile in CT, they are nearly invisible. They have a modestly successful Jeep Wrangler PHEV and that is about it. (Stellantis represents 1553 of 30,017 EVs registered in CT as of Jan 1 – 1,200 from Jeep, 317 from Chrysler, 36 from Fiat. Only the Fiat are fully electric – BEV and they are not currently being manufactured.) Now, as they play catch-up – they announced a new EV platform – they are laying off thousands. From Yahoo Finance: “The company has about 56,000 workers in the U.S., and about 33,000 of them could get the (buyout) offers.”

Larger Environment

While we’re fighting over the right to buy an EV directly from the manufacturer, China is banning the sale of ICE vehicles that don’t meet its new, stringent emission standard (VI B) by July 1. That could send shock waves across the world as inventories of unsellable ICE vehicles grow. We are seeing states ban the sales of new ICE vehicles as of around 2035.

Closing Thoughts

How dealerships and the legacy automobile industry writ large will ultimately fare is up to them. If they innovate and compete, they’ll be fine. Some of them have embraced EVs, but judging by the data, not nearly enough. In CT, the dealership special interests have thus far been given the message that they can sit back and not worry about it, that change can happen on their timetable, negative consequences for those of us who live in the state be damned.

There are many EV Club members who own or have ordered a Tesla, Rivian or Lucid. For those of us who have made the trek to Mt. Kisco to pick up a Tesla, it stares us in the face that the jobs to build, staff, and maintain the facility are in New York, and the company pays property taxes to Mt. Kisco and a franchise registration fee to NY. Manufacturers selling directly, a large and fast growing industry, are not choosing CT to set up manufacturing facilities, despite our ports, roadways, railways, and highly educated and trained workforce. We lose twice.

Today’s headlines and accompanying disruptions in the oil and gas market punctuate the urgency of moving away from fossil fuels. Allowing direct sales will help CT meet its EV adoption objectives, create green jobs, reduce pollution, and, most importantly, it is what is right for the citizens of CT.

How Can You Help

We agree with Rep. Denning that a direct sales law is not anti-dealer; it is pro-consumer and pro-CT.

We have to ask ourselves why we’re okay with making it harder for CT residents to buy an EV, not easier. Why are legislators ignoring the will of the people and bowing to the dealerships?

Our EV Club is not a political organization (501(c)4). We do not have paid lobbyists prowling the Capitol. We can only operate as a grassroots organization evangelizing for EV adoption, promoting free competition, and being open to new and innovative ways of doing business.

You can be sure that legislators hear from the dealerships and their lobbyists whenever there is a bill. They have to hear from as many of us as possible. Even if you have emailed or called previously, every year is a new game.

The 2024 legislative session will be a short session, which happens in election years. The rules are more restrictive and there may well not be a direct sales bill introduced. But as we get into election season, that will be a good time to make your voice heard.

Tesla Leasing Customers Can Now Pick Up Their Vehicles in Milford

A shout out to Rich from the Tesla Owners Club for announcing this update. Customers who lease a new Tesla will be picking up their vehicle at Milford. To be clear, this does not apply to customers purchasing a vehicle.

This is franchise law related. The franchise laws that are being used by dealers to prevent Tesla and other direct sales manufacturers from selling directly were written so long ago that they don’t apply to leases. Way back when, leasing was not a thing, and the law does not address it.

Tesla has been doing leasing paperwork at Milford for several years now, but hasn’t delivered vehicles there. It sounds like there were some logistical hurdles, which have now been worked out with the Department of Motor Vehicles. No more temporary plates! Permanent plates will be on the new car.

photo credit: Paul Braren/Post: Barry Kresch

IRA Went into Effect with Rule-making Still a Work in Progress

The most challenging part of the rule-making has to do with the rules around battery minerals. The IRA requires a minimum percentage (40% in 2023) of battery critical minerals be sourced either domestically or with a free-trade partner. The IRS is still accepting comments, through June 16th. The EV Club is working with the Electric Vehicle Association (EVA) and the Clean Vehicle Coalition (CVC). Our primary input on this is that manufacturers should certify compliance on a model-year basis since that is how they plan their manufacturing and that is how consumers think about cars. Furthermore, once a model/model year is certified, it should be the manufacturer’s responsibility to ensure compliance. And if compliance isn’t achieved, the manufacturer would be responsible for the resultant tax liability. Let’s keep consumers out of the VIN-checking business and definitely out of exposure uncertainty.

IRS Flexibility

The certification question notwithstanding, what we are hearing is that the manufacturers are generally pleased with IRS rule-making. They expanded the list of free trade partners. They are allowing the OEMs to self-certify and they have 3 options for doing so: point in time, individual vehicle, or average over a defined period of time (year, quarter, month). We are trying to find out the limits of the self-certification and whether there is exposure for the consumer. More to come on this.

What the OEMs are most concerned about is when the foreign entities of concern rule kicks in. They have not figured out how to get China completely out of the equation.

Used Teslas

If anyone has looked at the fueleconomy.gov page to view the makes that are eligible for the used EV incentive, you will see that Tesla is conspicuously omitted. We have been advised that the reason is that the Tesla paperwork is churning slowly through the wheels of the IRS bureaucracy. Tesla is trying to get it unstuck. We expect that to happen reasonably soon.

Leasing

Leasing has emerged as a big loophole. The IRS has ruled that consumer leases are commercial transactions and not subject to any of the restrictions associated with a consumer purchase. All leased vehicles, no matter where the battery comes from, no matter how high the MSRP or the lessee’s income, are incentive-eligible. However, it is our understanding that Tesla, General Motors, and Ford are not passing through the incentives for leasing customers at this time. They are not legally required to do so, but it is not consumer-friendly in our view. If any reader has different information, please let us know.

Transfer Provision

This begins in 2024. The consumer will have the option of transferring the incentive, which is a tax credit, to the seller, who then gives the incentive to the consumer as a rebate. That sounds complicated but it boils down to the incentive becoming cash on the hood, so it’s unequivocally a good thing. Not only does the consumer not have to wait for their taxes to be filed, but for people who don’t have enough tax liability to burn off a tax credit, this will enable them to use the incentive. So, this is an important equity provision. Unlike with a lease, a transfer has to be passed to the consumer. You may ask what happens if the consumer seeks to use the transfer when leasing a vehicle? Good question. To be continued.

Joint Ventures

Could joint ventures be a way to skirt the foreign entity of concern rules? Another good question. Ford announced a joint venture with the big Chinese battery manufacturer, CATL, to build a plant in Michigan. Our understanding is that it is likely that the output of this plant will be incentive-eligible because Ford owns the plant and is licensing IP to make LFP batteries from CATL. Still, we await a final ruling.

Photos by Paul Braren

20 EVSE L2 Chargers at DOT

An EV charger installation at DOT headquarters in Newington is now open. The location is 2800 Berlin Turnpike. The 20 level 2 chargers are from EVSE, LLC, an Enfield, CT based manufacturer. The chargers have J-1772 connectors. They are 40-amp units and there is a 4-hour parking limit. That amount of time should get most vehicles ~140 miles of charge.

These chargers are currently open to the public and the price is right (free)! We do not know how long either of these conditions will last. The chargers are at the DOT building, not in a downtown parking lot, so not the most convenient for someone who does not have business at DOT or the immediate area. But we’ll take more chargers anywhere we can. This location is noted in PlugShare with a number of happy check-ins over the free juice.

One of the features of these chargers is auto-coil. When the cord is disconnected from the vehicle, there is a mechanism to automatically retract the cord into the housing of the charger, which is clearly seen in the photo of charger number 20 below. This is a valuable feature. Many older chargers have cords that need to be manually wrapped, which is a nuisance that people frequently don’t bother doing. The cord ends up flopping on the ground, subject to damage from becoming overly entangled with itself, snow or ice, or cars driving over it. That is the best way to get out-of-service chargers. Whether it is auto-coil or other systems that do a similar thing, this is a best-practice with EV chargers.

The Rivian R1T in the photos has a camper package. This is a third-party package that fits the Rivian. Rivian camper packages have seen lengthy delays.