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 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 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.

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

Northeast Electrical Vehicle Symposium

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

PACE

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

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

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

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

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

First Responders

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

Incentives

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

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

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

EV Showcases

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

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

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

Speaking Engagements and Tabling

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

Zoom Meeting Presentations

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

Policy/News

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

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

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

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

Data

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

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

Videos!

Find them on our YouTube channel

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

Global Temperature Rise is Already 1.2 degrees Celsius above baseline

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

Transportation Is Low Hanging Fruit

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

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

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

Advanced Clean Car Regulations II

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

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

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

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

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

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

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

It’s Not Over

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

Freedom!

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

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

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

Grid

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

Charging Infrastructure

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

EV Costs

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

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

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

Flexibility

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

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

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

You Can Help

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

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

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

Policy Matters

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

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

IRA Incentive Update – Transfer Provision Goes Into Effect in January

A Tax Credit Becomes a Point of Sale Rebate

The transfer provision of the federal IRA EV incentive is scheduled to go into effect in January. This provision meaningfully improves upon a tax credit:

• The incentive becomes a point of purchase rebate.
• It can be used by people even if they don’t have the tax liability to be able to use a tax credit.

The IRS published a draft of its rulemaking on October 6 and plans to issue final rules shortly. Much of the rulemaking has to do with implementation details. This is a summary:

• The IRS will be launching a new website called IRS Energy Credits Online and dealers must register with this site to participate. Consumers can only obtain the incentive from a registered dealer.
• Participating dealers will use the site to verify a vehicle’s incentive eligibility, register the sale, and indicate whether (or not) the buyer elected the transfer option.
• For buyers choosing to transfer the credit to the seller, the dealer must reduce the invoice amount by the full amount of the available incentive.
• Dealers must provide written documentation to the customer regarding the vehicle’s incentive eligibility.
• Once the sale is registered, the IRS will issue payment to the dealer within 72 hours. (When the transfer was initially announced, dealers were concerned about the potential to incur significant carrying charges.)
• Dealers get repaid whether or not they have tax liability to absorb a tax credit.
• Consumers must attest in writing that they are eligible for the incentive. This mainly applies to the income caps. A buyer must fall within the caps for either the year they make the purchase or the prior year. If that turns out not to be the case, the consumer must repay the incentive to the IRS.
• Incentive payments do not count as income for either the dealer or the consumer.

This is a link to the IRS press release.

New Webinars Announced for Program Updates

The incentive program from the Public Utilities Regulatory Authority (PURA) that is administered through the state’s two largest utilities, Eversource and United Illuminating gets evaluated every year. Since the program has started, there have been some modifications introduced at the beginning of each year.

Eversource and UI have announced webinars to explain the changes for 2024. The webinar for residential is on Wednesday, Oct. 25th, and for commercial, it is Monday, Oct. 30th. Registration links below.

• EV charging programs for single family homes
  • Wednesday, October 25^th from 1:00 – 2:00 p.m.
  • Register here

• EV charging programs for business, communities and large multifamily residences
  • Monday, October 30^th from 1:00 – 2:00 p.m.
  • Register today

The residential program offers an incentive of up to $500 toward the purchase of a 240 volt charging station and up to $500 toward offsetting the installation cost involved in bringing a 240 volt line from the panel to the garage. There is also a managed charging component, which pays consumers for allowing the utility to throttle charging during peak demand periods. If one takes the incentive for the hardware, participation in the managed charging is mandatory. It is most likely that any upcoming changes will have to do with the managed charging component of the program. It is possible there will be some new approved equipment.

Advocacy Alert: Reach Out To The Legislators on the ACC II Legislative Review Committee

Contact information is provided at the end of this post.

What follows is a not so brief background that could easily be a lot longer. There is also be an upcoming webinar, produced by the Interreligious Eco-Justice Network. Scheduling and registration link here:

Clean Cars, Clean Trucks, and the Fight for Clean Air

Monday, October 30 – 7:00 pm – 8:30 pm

REGISTER HERE – https://cleancarscleantrucksandthefightforcleanair.eventbrite.com

ACC II Is Follow-on to California Emission Standards

When the federal Clean Air Act was passed in 1970, it recognized that California had already established its own regimen of emissions standards. California, particularly the Los Angeles area, had already been grappling with smog for a long time. And so California was given a waiver to continue to establish its own standards, which were more stringent than the federal standards. That is the overly-simplistic history of why there are two standards.

Many states, including Connecticut, have followed the California standard for tailpipe emissions, which became the de facto standard for manufacturers. It was easier for them to live with the more stringent standards than to have different vehicles for sale in different sets of states.

The acronyms that you hear around this are ACC (Advanced Clean Car) regulations and CARB (California Air Resources Board), the state agency that sets the California standards. The first set of ACC regulations addressed light-duty vehicles for model years 2015 – 2025. This follow-on set of regulations, known as Advanced Clean Cars Two or ACC II, begins with 2026, although the CT version would start a year later due to the current timing of enactment. The CT version is the CA version. The choice is binary: use the weaker federal standards or the more stringent CA option.

Why Do We Need This?

It’s obvious, right? Just look at the chart at the top (data from NASA, published by Axios). But, aside from global warming, there are local concerns.

• Air quality in CT is terrible. The state receives failing grades from the American Lung Association and fails to meet federal air-quality standards.
• The transportation sector accounts for about 38% of greenhouse gas emissions but also a significant amount of Nitrogen Oxides, a component of smog, and particulate matter. These contribute to cardio-pulmonary disease, cancer, low birth weight and birth defects.
• ACC II applies to all vehicles, in other words, trucks as well as cars. The pollution profile varies for different classes of vehicles, but it’s all bad.
• This is an important environmental justice measure. Pollution and its public health consequences fall disproportionately on disadvantaged communities.
• The Department of Energy and Environmental Protection, DEEP, analyzed the impact of ACC II on CT and modeled enormous reductions in greenhouse gasses and pollutants as described in the table below.

Health Benefits

According to the American Lung Association, CT can expect the following health-related benefits from cleaner air.

• $11.5 billion in monetized health benefits
• 1,060 premature deaths avoided
• 22,900 asthma attacks avoided
• 120,000 lost work days avoided

Wide Support

It may not come as a surprise that the EV Club supports this, along with other Connecticut EV Coalition members including Save the Sound, Acadia Center, and the Sierra Club, along with numerous other environmental organizations.

Charles Rothenberger, climate and energy attorney at Save the Sound and manager of the Connecticut EV Coalition, spoke at our September 9 Northeast Electric Vehicle Symposium (NEEVS) on this timely topic. “Two decades ago, Connecticut became a leader on cleaner transportation by adopting the Clean Cars I standards. Now it’s time to take the next step in achieving the kind of emissions reductions that the best available science tells us are essential for the health of people and the planet. Taken together, the regulations introduced today will provide long overdue updates to our vehicle standards, placing Connecticut on the path to transforming and modernizing the transportation sector and providing substantial environmental and health benefits for the citizens of Connecticut.”

The most controversial part of the regulations is the requirement that manufacturers no longer produce ICE vehicles as of 2035 (light-duty). Everything has to be a plug-in vehicle, though up to 20% of the plug-ins can be PHEV.

The automotive industry is lining up behind these regs. A number of manufacturers have already announced they are transitioning their fleets to electric roughly in this time frame. The Alliance for Automotive Innovation, a trade association for the legacy manufacturers, has endorsed it, as has the Truck and Engine Manufacturers Association.

The dealers seem to be taking a more neutral position. Their job is to sell what the manufacturers produce. However, the National Automobile Dealers Association states on its website: “Electric and hybrid vehicles are here, and America’s vast franchised dealer network is eager, excited, and essential to the successful deployment to the mass retail market. Dealers are all-in on EVs and are investing billions of dollars in their stores and staff to improve the purchasing experience and reduce barriers to electric-vehicle ownership.”

These regulations are needed to make a meaningful dent in our toxic, climate-warming emissions. The goals in the Paris Agreement of 2015 feel increasingly out of reach absent decisive action.

Its overarching goal is to hold “the increase in the global average temperature to well below 2°C above pre-industrial levels” and pursue efforts “to limit the temperature increase to 1.5°C above pre-industrial levels.” To limit global warming to 1.5°C, greenhouse gas emissions must peak before 2025 at the latest and decline 43% by 2030.

ACC II provides a lengthy time horizon during which there is a gradual transition to zero-emission vehicles. Importantly, they provide a degree of certainty regarding marketplace conditions to the manufacturers, as well as manufacturer incentives for the building of affordably priced EVs.

ACC II Nearing the Finish Line, But a Potential Hurdle Remains

The CT Department of Energy and Environmental Protection (DEEP) received legislative authorization on a bipartisan basis to develop the rule making and conduct the required analysis. That part is finished. There has been a public comment period with a response from DEEP. The Office of the Attorney General has signed off on the regulations. The final step before going to the Governor is for the Legislative Regulation Review Committee to sign off on it. The committee is composed of 14 legislators with equal representation from both parties. The committee’s assignment is to review the regulations for adherence to legislative intent (which they clearly do). Now, some members of the committee are signaling that they may try to block the regulations and the Republican caucus is taking steps to make a public case. Here’s but one example.

If you clicked through to that article, you can see the FUDsters are out in force. And even though this originates with the Repubs, don’t make the mistake of thinking the Dems are immune to the pressure. We will be publishing additional content to address some of the questions being raised about the grid, the cost of EVs, and the economic impact. There’s a lot to shovel. The regulations require a minimum of a tie vote to be enacted.

Please Take Action to Let Regulation Review Committee Members Know Why ACC II Is Positive for Connecticut

We ask your help to support the passage of these regulations. Contact as many of the committee members as you can using their information is below, asking them to support ACCII. You are welcome to use the bullet points above as a guide to your messaging.

Post by Barry Kresch

Beware the Disappearing Incentives

There are 35 EVs (BEV and PHEV) listed as incentive-eligible by the Federal Department of Energy as of October 1, 2023. It is really fewer than that as the website breaks out the different trim levels. For example, there are 8 variations of the Volkswagen ID.4. The DoE website is here. It includes the ability to filter vehicles.

Tesla is publishing incentive alerts on its website, seen in the photo above, warning that some of its vehicles may lose full or partial incentive eligibility. Tesla is more public about it, but it is not alone in bumping up against the moving target of escalating in-sourcing requirements, the looming Foreign Entities of Concern rule, and ongoing IRS rule-making. From what we are hearing, most EV manufacturers could be affected, mostly because it is difficult to quit China as quickly as the legislation requires.

Battery Requirement Changes

These are the changes in the battery requirements that begin in January.

• Critical Mineral Sourcing/Refining increases from 40% to 50%. This minimum percentage must come from either a domestic supplier or free trade partner.
• Battery Assembly – the percentage of battery components that must be assembled in North America increases from 50% – 60%.

Foreign Entities of Concern

The rule that the manufacturers have voiced the most consternation about is the Foreign Entities of Concern (FEoC). This phases in beginning in 2024, followed by part two in 2025. The FEoC mirrors the battery regulations in that half of it applies to critical minerals and the other half to battery assembly. It is the latter half that starts in 2024 with the mineral portion following one year later.

Beginning in 2024, eligible vehicles cannot contain any battery components manufactured in a country so designated. The way to think about it is if you reference the 60% battery assembly requirement noted above, a manufacturer can source 40% of battery components from outside of North America in 2024. However, the FEoC rule specifies that none of that 40% can come from a FE0C. This is obviously about China, but other countries will fall into this designation.

We expect a number of vehicles to lose all or 50% incentive eligibility in 2024. Over time that will likely change, but the next two years are sure to be the most challenging as requirements tighten and new plants have not yet come online.

Ongoing IRS Rule-Making

A large rule-making task was quite literally dumped on the IRS in August of 2022. The wide-ranging IRA legislation, which encompasses much more than EVs, was passed in rather skeletal form, with the implementing agency, The Department of the Treasury, responsible for developing the specific rules. Sometimes this rule-making has run counter to the spirit of the legislation according to some of the legislators who voted for it. For example, the “leasing loophole,” which allows consumers to obtain incentives on vehicles that would otherwise not meet the requirements if purchased, came about because the IRS interpreted a lease as a commercial transaction. The vehicle is sold by the dealer or manufacturer to a captive finance company. This was defined as commercial. The fact that the finance company subsequently executes a lease with a consumer is beside the point from the perspective of the incentive. Commercial transactions fall under a different set of rules that do not include the restrictions that apply to consumer purchases.

Due to the short lead time, the ink has barely been dry on the rules at the time they are due to be implemented. Sometimes the IRS blows through the deadline. The first-year set of battery rules was postponed from January 1 to April 18th of this year for that reason.

The FEoC remains a moving target in this regard. The IRS has advised that the final list will be available before the end of the year, so potentially as little as 24 hours before it is due to go into effect. Maybe there will be an FEoC postponement, similar to what happened with the batteries.

How to Define FEoC

One of the big areas of contention involves not so much designating what countries fall under this rule, but how it is defined. For example, what if a Chinese company opens a plant in North America? What if it is a joint venture with a domestic manufacturer? What if a domestic company builds a factory but licenses technology from a Chinese company? The latter is the most minimalistic footprint and an example is the battery plant that Ford has begun building in Marshall, Michigan. The plant will be producing Lithium Iron Phosphate (LFP) batteries. Ford will own the factory. The workers will be Ford employees. The LFP battery chemistry IP is being licensed from CATL, the big Chinese battery company.

Last week, Ford announced it is pausing construction on this plant. Of course, the company is in the midst of contentious negotiations with the UAW, which is trying to include battery plants owned by the companies in which it has representation at parity wages. But Ford has also commented publicly that it is waiting for IRS determination regarding whether the IRA manufacturing and consumer tax credits are applicable to this plant. It has threatened to greatly downsize the plant if that is not the case.

VIN

While we hope that dealerships are able to offer consumers accurate information regarding whether an EV is incentive eligible, and in our experience Tesla has been pretty on top of incentives, the definitive way to know is to input a Vehicle Identification Number on this federal page. Of course, it would be better to know about eligibility further upstream, but that is what the government has provided.

Lobbying

There are lots of reports of furious lobbying behind the scenes, which occasionally spills into public view, such as the Ford battery plant. But there is more than that. Manufacturers would like to change the determination of vehicle eligibility from the “placed in service date” to the date of manufacture. They obviously have more control over the latter, and it buys them a bit of a grace period since it is earlier.

It has also been reported that manufacturers would like to get Vietnam designated as a free-trade partner for the purposes of battery critical minerals.

The Transfer Provision – Another Big Deal

Tax credits are not the most consumer-friendly form of incentive. You have to wait for it. And not everyone has enough tax liability to be able to use it. The transfer provision is the legislation’s way of turning the tax credit into a rebate. The buyer transfers the credit to the seller. The seller takes the credit and gets reimbursed by Treasury. Also, non-taxable entities can use the transfer provision.

My biggest concern is that the process won’t work smoothly when it is initially introduced. The IRS has been working on the process. It is yet another aspect of rule-making that will likely come down to the wire. Will the dealers and manufacturers be on top of it and not afraid to use it?

Photo at top taken under one of the solar canopies at the Hotel Marcel with the building in the background, from left to right: Daphne Dixon – Live Green CT, Paul Wessel – Greater New Haven Clean Cities, and Analiese Mione, Barry Kresch, Bruce Becker, and Paul Braren from the EV Club who organized the symposium.

“Sold-out” Conference

Well, it was free, but there was more interest than we were able to accommodate and we had to close registration. Early feedback has been extremely positive, such as this message:

“I attended the NEEVS yesterday and had a fantastic time. What a great lineup of speakers/presentations and lots of fun at the car show as well! I’m looking forward to future symposiums in the coming years. …. Again, I had a great time at the symposium (and the lunch was incredible).”

We would like to thank our sponsors: Live Green CT, Greater New Haven Clean Cities Coalition, EVConnect, Maxwell Vehicles, and ChargePoint, without whom we would have been munching on stale pretzels.

Of course, we also thank our attendees for joining us and being an engaged and interactive audience.

The Hotel Marcel provided excellent, eco-friendly hospitality. For anyone who may be nervous about switching from a gas to an induction cooktop, the quality of the food attested to how good induction cooking can be. Even the chafing dishes were induction.

We’ve had some comments about how a small committee was able to put together a jam-packed agenda in a short period of time. If anything, the challenge is less about finding content than winnowing it down to fit within our time parameters. As it was, our 3-hour speaker agenda took 4 hours with too little time for Q&A.

We want to give a shout-out to Rich Jordan, president of the CT Tesla Owners Club, for his help with the car show, to the Westport Police Department and their Model Y patrol car, and to Tesla for bringing vehicles for test drives.

Converted EV Van

Hotel Marcel architect and developer, Bruce Becker, talked about how Maxwell Vehicles converted an ICE van to electric, using a salvaged Model 3 battery and drive train. This van gets a lot of use shuttling guests to downtown New Haven, Yale, Union Station, Tweed Airport, and other destinations.

Out of Spec Dave

YouTube and X (Twitter) personality, Out of Spec Dave from Greenwich, CT, talked about his adventures as a road warrior, having driven lots of different EVs and experienced the many faces of public charging. Not all of them are happy faces. Part of the charging experience is knowing before you get to a charger whether the charger is in service and how fast it is charging. There is a gap in the eco-system here. He has launched the “Rate Your Charge” newsletter. Take a video or photo of your charge, describe your experience, and tag @outofspecdave on Twitter. These are being compiled in a weekly report posted to Twitter. For those not on Twitter, use this Google Doc: https://docs.google.com/forms/d/e/1FAIpQLSd9nE1JOulqidJNacpL230TdswfnnaWBTjdGIaky3ffkHF6EA/viewform?pli=1

PACE

Mark Scully from People’s Action for Clean Energy (PACE) spoke about their program to help municipalities decarbonize and save money in the process. This slide illustrates the cost savings projected in a transition to renewables.

United Illuminating

We get many questions regarding whether widespread EV adoption will crash the grid. While the grid does need to be modernized (and the Public Utilities Regulatory Authority has a grid modernization docket), Rick Rosa from Avangrid/UI discussed using EVs to optimize the grid. This slide is an example of optimization vs curtailment. EVs will be beneficial to the grid for the foreseeable future and, as such, there are incentives for EV owners to participate. See our incentives page for a more detailed description of the program with links to sign up for the residential or commercial incentives. This program is also offered by Eversource and it can offset the costs of buying and installing a 240 volt charger, as well as pay an ongoing incentive to participate in their managed charging programs.

Zoning for EV Readiness

Daphne Dixon of Live Green CT, who has done a lot of work with municipalities, gave a presentation that illustrated the complexity of zoning for EVs but also highlighted the significant benefits as noted in the example below.

All Electric, Zero Emission Home

Paul Braren provided a detailed description of his journey to create an all-electric home (solar roof seen in the photo, powerwall/VPP, 2 EVs, insulation for home and windows, heat pumps, smart panel, electric garden tools) and capture the available incentives. It has been a complicated road. This links to his full presentation.

IRA Transfer Provision

In his update on incentives, EV Club President, Barry Kresch, discussed the implementation of the transfer provision in 2024, and how it changes a tax credit into a point of sale rebate.

Advanced Clean Cars II

CT is a participant in the California Air Resources Board emissions requirements. It is now in the process of implementing the second phase of these regulations, commencing in 2027 through 2035. The rules require manufacturers to sell increasing amounts of zero emission light-duty vehicles, reaching 100% in 2035.  There is a separate set of regulations that would significantly lower emissions for medium and heavy-duty vehicles during this same period. Charles Rothenberger, Climate Attorney for Save the Sound, explained these regulations. The legislature has authorized CT DEEP to proceed with the required multi-step process. The slide below shows where we are and the remaining steps.

There is some concern that when the rules go back to the legislature, in which a bi-partisan review committee is supposed to examine them for legal sufficiency, that there may be an effort by opponents to short-circuit the approvals process. More on that to come.

We hope you see you next time!!!

Tesla Model Y Leads Rebated Vehicles

CHEAPR set another record in June in terms of rebates awarded with 421 rebates, way exceeding the previous high water mark that occurred just one month prior of 286.

The best-selling EV in the country, the Tesla Model Y, leads the field by far with 228, or 54% of all rebates. Other models with double digit rebates

• Tesla Model 3 – 51
• Chevy Bolt – 40
• Toyota RAV4 Prime – 33
• Volkswagen ID.4 – 15

E-Bike Rebates Sizzle

Things you can do in 13 minutes –

• Walk a mile
• Complete a simple crossword
• Reheat last night’s leftovers

Or

• Blow through the entire e-bike voucher budget!

One of the new components of CHEAPR authorized last year in Public Act 22-25, e-bike rebate vouchers, went live in July. It was available for all of 13 minutes before the entire budget was depleted with 6300+ applications received like a bolt of lightning. DEEP had originally budgeted $500,000 for this first year, but increased it to $750,000 when the strong demand became immediately clear. Still, that only extended the shelf-life by a scant few minutes.

Still Awaiting Traction for LMI rebates

There were only 4 of the supplemental Rebate+ incentives awarded to individuals who are income-qualified or live in distressed communities. There is hope for much higher numbers. We still counsel patience. DEEP has reported a good response with respect to the pre-qualification vouchers and the vouchers are good for a year. The public dataset does not contain information on the number of approved vouchers. The 4 incentives were all for new vehicles.

Fleet Rebate Postponement

The one new program component that still awaits launch is the fleet incentives. The eligibility is wide – commercial, non-profit, municipal, tribal entities. The limit is 10 incentives in a single year and 20 total. The standard CHEAPR incentive applies (i.e. not the supplemental), as does the $50K MSRP cap. Reminder, MSRP is defined as the base price of the trim level ordered without accessories. The light-duty program launch had been expected imminently, but DEEP is taking a step back. In the wake of the overwhelming e-bike response, they are looking to be prepared in the event of robust demand.

There is also a medium and heavy-duty vehicle component to this program. This will launch sometime next year.

Burn Rate Running Hot

At the September Board Meeting, DEEP expressed some concern about funds depletion as the program gave out $874,250 (not including e-bikes) in the month of June. They probably don’t need to worry, at least for a while, as Tesla has withdrawn the Model Y standard range. The Tesla website now only lists the long range and performance trim levels, neither of which qualify for a CHEAPR incentive.

The Symposium is Sold Out – People Can Still Come for the Car Show

Get charged up at NEEVS, the ultimate gathering for EV enthusiasts, policy wonks, and all who seek cutting edge guidance on decarbonization.

Please join us at the first annual Northeast Electric Vehicle Symposium (NEEVS) at Hotel Marcel in New Haven on September 9, 2023. EV enthusiasts, electrification and decarbonization advocates, sustainability volunteers and professionals, municipal employees, real estate owners and developers and policy wonks are invited to join us.

Bruce Becker is the lead architect and owner/developer of Hotel Marcel in New Haven, the country’s first zero emissions and Passive House hotel, and Chairman of the EV Club of CT. Bruce will welcome guests as they enjoy a light buffet lunch, and briefly share his approach to hotel e-mobility at Hotel Marcel. Guests have access to Tesla Superchargers, Level 2 chargers under a solar canopy and a custom electric shuttle van.

You will learn firsthand from expert guest speakers about:

1. Hotel Marcel’s guest experience in e-mobility,
2. The state of public EV charging and opportunities for improving it,
3. The latest updates in state and federal EV/EVSE incentives and V2G,
4. Best practices for transitioning vehicles and homes to all-electric,
5. How to move municipalities to 100% clean, renewable energy,
6. The societal and environmental benefits that proposed regulations for light, medium and heavy-duty vehicles under Advanced Clean Cars II (ACC II) provide for Connecticut.
7. Zoning for EV readiness

Date: September 9, 2023

Hours: 12:00-4:30

Host: Hotel Marcel, 500 Sargent Drive, New Haven, CT 06511

Organizer: EV Club of CT

Partner: Tesla Owners Club of CT

Thank You to Our Generous Sponsors: Hotel Marcel, Live Green CT, EV Connect, Chargepoint, Maxwell Vehicles, and the Greater New Haven Clean Cities Coalition.

Speaker Schedule:

2:05-2:30: Charles Rothenberger, Climate & Energy Attorney, Save the Sound will present highlights of the Regulations for Light, Medium and Heavy-Duty Vehicles under Advanced Clean Cars II (ACC II). In July 2023, Connecticut became the latest state to initiate adoption of the Advanced Clean Cars II rule, which will benefit society by requiring manufacturers to increase sales of electric and other zero-emission models within the state over time, culminating with 100% of new sales being ZEV in 2035.

2:30 – 3:00: Daphne Dixon, Co-founder and Executive Director, Live Green Connecticut and Director, Connecticut SWA Clean Cities Coalition, will present about Zoning for EV Readiness, a must attend for municipal decision makers.

Networking and Car Show 3:00-4:30: Enjoy beverages and food at the hotel bar while networking with other guests, and head outdoors to the lot adjacent to Hotel Marcel’s Superchargers to enjoy the car show while networking with EV owners that are members of Tesla Owners Club of CT, the EV Club of CT and the Westport Police Department.