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

Battery Rules Issued

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

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

What Rules Apply

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

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

Making Sure the Vehicle is Incentive-Eligible

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

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

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

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

Leasing

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

Other Rule-making

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

Foreign Entities of Concern

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

Transfer Provision

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

Sandy Munro Unfiltered

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

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

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

A few items contained in the video:

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

Updates on CHEAPR Implementation

Almost one year ago, SB-4 was voted into law as Public Act 22-25, an environmental omnibus that made extensive changes to CHEAPR, the state EV purchase incentive program. The easiest change, raising the MSRP cap from $42,000 to $50,000 was implemented in July. The other changes required extensive platform revisions and we are just now getting to the point where these other items will go live. Below is the slide from the deck that DEEP presented that outlines the timetable.

Revised income-limited (LMI) program

The program remains on track to launch the revised income-limited program, including a pre-qualification voucher in second quarter. Our guess is that it will likely be toward the end of the quarter, especially since they have yet to make a final selection of a marketing vendor. These LMI rebates are known as Rebate+ New and Rebate+ Used.

To recap, the new LMI program expands eligibility to individuals or households earning up to 3 times the federal poverty rate. The current program requires enrollment in designated governmental assistance programs, which is more limiting. The other important addition is the ability to become qualified before the purchase and get a voucher. This way the incentive will be cash on the hood like the standard CHEAPR rebate. The current post-purchase process will be retained, as well, for the sake of continuity. We suspect it will fall away in time but that will be based on utilization data.

The LMI rebate for new vehicles is $2000 that gets added on to the standard $2250 rebate. There is also a $3000 rebate for used EVs. Used rebates can only be obtained if the vehicle is purchased through a dealer (either a new car dealer that sells used vehicles or a used car dealer), in other words, not through a private sale.

The LMI incentives have really struggled for traction since they were introduced, with only 8 being given out during calendar 2022 (5 new, 3 used). This change is sorely needed, along with effective marketing.

Expanded Options for Used EVs?

The eligible used vehicles for the Rebate+ Used have been restricted to vehicles that were eligible for the standard rebate when new. We never saw the point of that since these are income-limited rebates. We feel any used EV should be eligible. We have spoken to DEEP about this and we expect there will be a revision here, which would be effective when the new Rebate+ program goes online in a couple of months. Stay tuned.

Expansion to Non-Residential

At present, the incentive is available only to individuals. In the third quarter, referenced in the slide as “CHEAPR Fleets launch,” eligibility will be expanded to businesses, fleets, non-profits, municipalities, and tribal entities. This could potentially be a huge pool of purchasers. These entities are capped at 10 incentives in one year and 20 total.

E-Bikes

The state will incentivize e-bike purchases, something that was left out of the federal IRA legislation. This will be a gradual rollout over the remainder of the year, with possible tweaks continuing even after that. It is possible for an LMI individual to get as much as $1500 towards the purchase of an e-bike with an MSRP of no more than $3000.

Program Performance

CHEAPR has been underperforming for years, defined as spending below its budget. It started to happen in a serious way in 2019 when the MSRP cap was lowered from $50K to $42K. The reversal of that as of July 2022 is helping, though we are in a more difficult environment at this time with higher prices and constrained supply chains.

The program rebated $1,894,000 for 1174 rebate instances in 2022. This remains less than the program’s old budget of $3MM annually, and way less than its new budget which is between 2-3 times that, depending on how much is collected in greenhouse gas fees. Not to mention that unused funds rollover. There is a substantial available war chest to fund the expanded program.

The 1174 rebate number is less than the 1408 in 2021. However, the pace picked up in the second half of 2022 after the MSRP cap increase, increasing 69% (737 vs 437) over the first half, and slightly higher than the 696 of the second half of 2021. The 216 rebates in Jan and Feb of 2023 are pacing well ahead of the corresponding period from 1 year ago when the number was 116.

34% Utilization Rate

The biggest area of concern is the utilization rate. which DEEP reported to be 34%. In other words, 34% of rebate-eligible vehicles actually got a rebate. This has been an ongoing pain point and has been the single biggest reason that it has been difficult to budget for this program. There could be several reasons for this: lack of promotion/consumer awareness, lack of dealership participation, and potentially important, we have heard that not all finance companies, which hold the title to leased vehicles, have set themselves up to deal with the rebate.

The changes to the program made in PA 22-25 are good ones and we will do our part to get the word out.

Photos by Paul Braren

EV Club Members Support First Responders

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

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

EVs Are Safe

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

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

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

Tesla Debuts Combo Port to Accommodate CCS Charging

The photo above, taken by Paul Braren at the Tesla Superchargers in Brewster, NY, displays the new Tesla “Magic Dock.” That is the hunk of plastic at the upper left of the connector. The Tesla connector is plugged into a Combined Charging Standard (CCS) adapter.

Federal NEVI Funding Moves Tesla to Accommodate Open Standard

The background is the National Electric Vehicle Infrastructure (NEVI) part of what is referred to as the bipartisan Federal Infrastructure Bill that predated the Inflation Reduction Act (IRA). There’s money in the air, $5 billion from this legislation, as well as additional funds in the IRA, but proprietary technology will not qualify for federal grants. The CCS standard is used for DC fast charging for every non-Tesla EV. The Tesla charging network is already the most robust. This will enable them to tap federal funds to further accelerate their expansion. The Tesla network has very strong uptime and performance metrics and its entry into the CCS charging space promises to be a major boon for non-Tesla drivers.

7,500 combo chargers by the end of 2024.

As included in a White House press release, “Tesla, for the first time, will open a portion of its U.S. Supercharger and Destination Charger network to non-Tesla EVs, making at least 7,500 chargers available for all EVs by the end of 2024.” That number includes destination chargers, which are level 2 chargers, and it did not specify a breakdown of destination vs Superchargers.

Using the Magic Dock

When a driver uses this combo connector, the smartphone app will tell the charger what kind of car it is. At present, the app is a Tesla app, which can be downloaded by owners of non-Tesla EVs. We’ll see if that creates a problem with the Feds if they demand a more open system. If the app recognizes a Tesla, the charger will unlock only the Tesla connector. For other vehicles, it will unlock the connector with the CCS adapter attached. In the latter case, the CCS adapter will be locked to the Tesla connector so that someone doesn’t make off with it. At present, there are only a small number of these combo chargers installed. According to the Tesla charging network maps, none are in CT; they are only in New York and California.

There is one other issue. This photo is a V3 charger. At Tesla chargers, vehicles back in and the charging port is at the driver’s side-rear of the car, similar to where a gas tank is usually located. The length of charger cord needed to reach the port is pretty short. Different manufacturers locate charging ports in different places on the car. There have been reports of vehicles parking at an angle or horizontally, and taking up multiple spaces, in order to be able to plug in. It is not a simple matter to switch out these cords for longer ones. They are liquid cooled and would experience power loss. Tesla has removed the bollards from at least some of the superchargers, which would provide a tad more wiggle room. Hopefully, nobody crunches into something they shouldn’t!

The solution is a new design, which is what Tesla has previewed here:

The V3 is on the right and the new V4 is on the left. Note the different style of connector with a considerably longer cord, external mounting, and much taller unit in general. That seems to be a good answer. Now we await word on the timing of the planned rollout, which may well be contingent on the timing of the grant funds.

Automotive Engineer, Teardown Specialist, and Unlikely YouTube Rockstar, Sandy Munro, to Speak to EV Club.

Zoom meeting date and time: March 21st at 4 PM. Free registration at this link.

Munro has become well known for his “teardowns,” where he literally takes a vehicle apart in his facility and does a detailed engineering dissection. He has analyzed pretty much every EV in the market, along with many ICE vehicles.

Munro has been a longtime automotive engineer, having worked at Valiant Machine and Tool Company and Ford Motor Company before starting his own consultancy, Munro and Associates, specializing in lean design (according to his Wikipedia entry). Munro’s “design first” approach, attention to detail, and no-nonsense manner of communicating has enabled him to significantly reduce manufacturing cost for his clients, while improving product quality and consumer experience.

Many of us in the EV world became aware of him when he launched his YouTube channel in 2018, 30 years after the establishment of his consultancy, with a teardown of the then new Tesla Model 3. When the world pivoted to digital during the pandemic, his YouTube awareness greatly increased.

His teardowns and detailed reporting pre-date YouTube. A 2015 report on the BMW i3 ran 23,793 pages. As a stunt in 2020, Munro made the report available for ten bucks (original selling price at the time of publication was $89,000 according to Inside EVs. The download link is no longer live.)

The Munro Live YouTube channel is up to 358,000 subscribers. Join us for a conversation with Sandy Munro (CEO) and Cory Steuben (President). See you on the 21st!

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

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

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

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

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

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

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

EV Owners Wanted for Fairfield First Responder Training

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

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

Any EV, whether BEV or PHEV, is welcome.

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

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

Update: 4/27/23

The installation of 12 chargers is complete, including Eversource installing transformers and the town wiring them to the charging units. They have not yet been turned on. We await word from the Town when that will be and if there will be a fee to use them.

Baldwin Parking Lot to Host EV Chargers

The photo shows several JuiceBar Level 2 chargers being installed in the Town owned Baldwin Lot in downtown Westport. According to CT-based manufacturer, JuiceBar, they have been commissioned to install 12 of these units. The Town of Westport advises that they have also installed all the necessary conduits, circuitry, etc. to accommodate an additional 12 units, the timing for which is to be determined. The Town also advises that all going forward planning for parking now includes EV charging.

From the Town’s perspective, the installation is complete. What remains is for Eversource to do its part – pulling in the primary service cables, setting the new transformer, and wiring it to their side of the electric meter so the distribution panels will become energized. Eversource has not given a specific date. The Town estimates 4-6 weeks.

These are 80 amp units, which is as powerful as it gets for a 240 volt, Level 2 charger. Most level 2 public chargers are 30 or 40 amps. Where that matters is charging speed for vehicles that can take advantage of it. A vehicle’s onboard charger converts the AC current to DC and controls the flow of energy. It takes an onboard charger of 19.5 kW to fully utilize this level of power, which will deliver over 80 miles of range per hour of charge. If your vehicle’s onboard charger is lower than 19.5 kW, and most are, it simply means the rate of charge will be slower. It will not damage the battery. It is forward-looking that a unit with this amount of power is being installed. The capacity of onboard chargers is steadily increasing as battery technology improves.

To be clear, these are not Level 3 DC fast chargers. These chargers are located in a lot where vehicles are typically parked for an hour or two as there are numerous stores and restaurants in the immediate area. But now that hour or two can bring with it a substantial amount of charge, as opposed to the relatively token amount of mileage on many of the low-powered units that are out there.

These units have J1772 connectors.

The charging may be free when the units are first fired up. The town has provided free charging at its other EV chargers (library, Town Hall, both Metro-North depots, Staples). That will change. When and how much has not yet been decided.

An Opportunity to Walk Through the Incentive Details

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

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