Utility Demand Charges Keep Level 3 Charging Stations Dark

We have quite a few posts addressing range-anxiety in its various forms. Even though most EVs have enough range to get you through your typical day, we all have occasions where we drive to a destination that exceeds the range of the vehicle. Without the certainty of being able to charge en-route, there is the danger of the battery turning into a very heavy brick. This possible low frequency, but high impact, event is enough to give pause for many folks considering an EV purchase.

A particular CT flavor of this can be found at rest areas on I-95 and the Merritt Parkway. For example, the I-95 southbound rest area in Darien and the Merritt Parkway northbound rest area in Greenwich have CCS and CHAdeMo level 3 chargers that aren’t working. (Presumably, this is the case at other rest areas that we haven’t been to). These charging stations are not broken. They are just turned off.

The reason is simple: demand charges.

What are demand charges

Utilities build out their infrastructure to handle anticipated peak demand. Demand charges are what pay for that. For non-residential classes of clients, the utility imposes demand charges based on their peak power usage and they are substantial. Whereas a residential user pays a cost per kilowatt-hour charge typically of approximately 17 – 20 cents, demand charges could be over $13 per kWh, plus a higher distribution fee. If you would like to see for yourself, here is the (complicated) rate structure used by Eversource.

Demand charges have been around for around 100 years, since the early expansion of electric service throughout the country. Aside from paying for infrastructure expansion, they are intended to spread demand into non-peak usage times in order to lessen the need for that expensive infrastructure.

Electric vehicle charging stations obviously draw current, especially the level 3 DC fast chargers that are needed along the Interstates to facilitate a long drive. The power-draw required to obtain an 80% charge in 15 – 30 minutes is sufficiently high (especially if multiple chargers are in simultaneous use) that the threshold for demand charges may kick-in. Our information is that the companies that run the food and gas service at the rest areas did not install the chargers, and it was a shock (electricity makes for way too easy puns) to them when they saw what demand charges were doing to their electric bill. So they turned them off.

Why Demand Charges for EVs Require Rethinking

While demand charges have served a purpose, it is time to rethink how these are handled with respect to EVs for a few reasons.

• Lack of charging infrastructure is a major barrier to EV adoption, and EVs are an important factor in mitigating climate change. In this sense, an inability to charge undercuts a social good.
• Utilities are the new fuel stations. They stand to reap a tremendous amount of business with widespread EV adoption. With EV charger demand charges, they are working against themselves.
• EVs will stimulate use in off-peak hours. Most charging, over 80%, is done at home, and most of this is done at night. In other words, EVs bring load-management benefits to the utilities. If there were a more robust time-of-use rate card available in CT, this would be even more true. Also, at a presentation done at DEEP in January 2019, Dana Lowell of M.J. Bradley Associates stated that the excessive (for want of a better term) net revenue resulting from EVs in this heavily regulated industry would be returned to the ratepayers. In the EV nirvana of 2 million EVs registered in the state, he estimated it would amount to $150 annually per household.
• This is speculative at this point, and a little off-topic, but it is technically possible for EV batteries to be bi-directional, also

  

  referred to as V2G (vehicle to grid). At times of peak demand, the energy residing in charged EV batteries could be tapped to fulfill demand, and then be recharged when demand subsides. The part of this that is on point is that there needs to be a lot of battery capacity out there to make this a viable strategy. A pilot study intended to test the bi-directional technology, underwritten by Con-Edison, is being run in Westchester County with electric school buses.

The bottom line is that EVs come with more ramifications with respect to the grid, and more opportunities for society as a whole, than a factory or commercial building. Other states are further along than CT in bringing innovation to approaching this dilemma.

To be sure, demand charges are just a single piece of the larger EV policy puzzle. It is a subset of what is referred to as “rate-design.” DEEP produced a 71-page “Draft EV Roadmap” that does a good job of covering the waterfront in terms of all related policy areas, though the language in this document, released in October 2019, is worded in terms of evaluation or investigation. In other words, there is still a long way to go. The section on demand charges is on page 44.

Tesla Chargers

There are Tesla chargers on the Interstates and these do work. That is because Tesla takes responsibility for them. They may be carrying a contingent liability, but their forward-thinking decision to install their own charging network and not wait for the rest of the world to catch up means that Tesla drivers have a wider array of charging options.

Waiver

There is an Eversource program to grant a demand charge waiver for independently metered charging stations that are open to the public, but that the waiver is temporary. It substitutes average per kWh charges. We don’t have a sense that this has been promoted aggressively. The waiver was for 3 years, but the clock has been ticking and it is currently closer to 2 years. A temporary waiver doesn’t really accomplish much unless there is something in place to address the underlying problem when it expires.

There are options other than an outright waiver to address this. We reached out to Eversource and were advised that the Public Utility Regulatory Authority will review the rate after the 3 year period ends and decide if changes are needed to the rate structure.

Interesting Approaches to EV Incentives in Neighboring States

This blog has published a number of articles about the recent changes in the CHEAPR program and how they have impacted rebates. Our feeling is that these changes were misguided and have sub-optimized the program’s effectiveness. We were told by DEEP that there was a concern about depleting funds in Q4 2019. We respect the concern but still feel that it was not managed well. And it has gone away for the near-term with the replenishment authorized by HB 7205, though the earlier levels have not been restored as of this update in late February 2020.

The changes in the MSRP cap from $50,000 to $42,000, along with reductions in the size of the rebates, caused a steep falloff in the number of rebates and total dollar amount rebated, such that they are pacing well under the current allocation.  The vehicle most impacted was the Tesla Model 3, though there were significant declines among the Chevy Bolt and Nissan Leaf as well.

As of this writing, we still await an announcement with respect to used EVs. A used EV incentive was authorized in HB 7205, but DEEP, which has been in the process of standing up a new board for CHEAPR, has not yet acted, nor posted anything on their website about when it might. When it does, this post will be updated.

Impact on Efficiency

All state incentive programs tinker with incentive levels and rules. Technology changes, and, of course, funding streams vary in size. Focusing on the former, the point of changing the parameters to keep up with the technology is intended to incentivize a longer electric range equating to lower emissions. Unfortunately, recent changes in CHEAPR have had the opposite effect. From the period January 4 to October 2, 2019, the weighted average electric range of incentivized EVs was 219 miles. Post incentive change, October 28 to December 31, 2019, this number declined to 176 miles. This happened because the changes hit BEVs much harder than PHEVs. This calculation does not normalize for incentive levels which were slashed across the board, and which would cause the dollar amount per electric mile to decline even though BEV rebates and efficiency got crushed.

So what are the highlights in New Jersey, New York, and Massachusetts?

Beginning with max MSRP, all of these states have caps that are at least as high as CT used to have.

NJ – $55,000

NY – $60,000

MA – $50,000

NY has a little extra spin, which is that, even though the base level incentives don’t apply over the cap, the state still offers a $500 rebate for any EV with a cost higher than $60,000.

Efficiency

New Jersey goes at efficiency head-on. The rebate is directly tied to the range: $25 per mile, up to $5000. (That’s 200 miles for those who don’t have calculators handy.) It is the most generous of the incentives in this region at the top end and it doesn’t get more linear than that.

MA has made ineligible PHEVs with a range of under 25 miles. This seems like a sensible adjustment at this point in our EVolution. There is also an incentive for used EVs. It is offered through the TMLP and MGED utilities and only applies to their territories. There is no gradation, just a $900 incentive with a purchase price cap of $15,000. The price cap was set relatively low because the used EV incentive is intended to target less affluent buyers. It was felt that this cap is low enough that they don’t have to get involved with burdensome income-verification procedures.

Dealership Data

A distinguishing feature of NY is that they publish rebates by dealership. That is a great idea! The dealership landscape is still fraught for EVs. The recent Sierra Club EV Shopper Study reported that 74% of dealers do not have a single EV on their lot. Our club did a lot of the fieldwork (dealer visits) for the Sierra Club in CT, and some interviewers reported that even where dealers are selling EVs, the salespeople would push them toward ICE vehicles. That said, some dealerships do make the effort to sell EVs, and we try to support them. We have people come to us for dealer recommendations, and we help them when we can, but data such as this show objectively and comprehensively which dealerships are walking the walk.

We think that raising the MSRP cap should be the top priority. That, along with adopting a rebate scale that better incentives efficiency, along with providing dealer transparency, would be a big improvement.

UPDATE: MARCH 1, 2020

This is a notice that has been posted on the CHEAPR website, so perhaps they are acting on one or more of these points.

Changes to CHEAPR Cause Rebates to Plummet and Bring Down Overall Results for CT

In addition to the rebate data, we now have data for EV sales nationally and EV registrations in CT for the full year 2019 to provide greater context to what appears to be some seriously misguided decision-making going on in CHEAPR-land.

As noted in earlier posts, the changes made to reduce the size of the rebates, and arguably, more importantly, lower the price cap for eligibility, have caused rebates to plummet 71% in units and 87% in dollar volume. At the current run-rate, the program will only expend about $520,000 of its $3-million allotment.

Tesla Model 3 rebates fell 92% and accounted for 70% of the overall decline. Chevy Bolt rebates fell 85% and Nissan Leaf rebates dropped 75%. Both the Bolt and Leaf declines came from much lower starting points than the Model 3.

We now have CT EV registration data for 2019, and we have two points in time, July 1, 2019, and Jan 1, 2020, enabling the separate evaluation of the first vs second half of the year. As seen in the chart below, from Jan 1, 2019, to July 1, 2019, EV registrations rose 16.2%. From July 1, 2019, to Jan 1, 2020, they rose 8.2%. The changes to CHEAPR took effect on October 15 and correlate with the declining rate of increase.

This is counterpointed by the fact that nationally, sales of EVs were 22% higher in the second half of the year.

CT and the rest of the country are headed in different directions.

Rebates Are Down 81% Based on Early Data

CHEAPR is the Connecticut EV purchase incentive program, administered by the Connecticut Department of Energy and Environmental Protection (DEEP). As of October 15, DEEP lowered the incentive levels for all battery electric vehicles, plug-in hybrid vehicles (but not fuel-cell vehicles), as well as lowered the price cap that determines vehicle eligibility. We described these changes in detail here.

As reported in the YaleDailyNews.com, “DEEP representatives told the News that the incentive decreases were necessary to keep the program running.” In other words, they are worried about running out of funds. In legislation passed earlier this year, CHEAPR was funded to the level of $3 million per year through 2025.

Our concern has been that the reductions are too large and that the lower price cap would exclude, in particular, the number one selling EV (by a mile), the Tesla Model 3. The early data seem to bear this out.

DEEP publishes data with a bit of a lag, and as of this writing on Dec. 8, there was a Dec. 2 update published with data through October 31. Also, there isn’t individual day granularity; there are certain interval boundaries that we have to work with. Finally, we don’t know if purchases made before the change, but where the vehicles were delivered afterward, are grandfathered in. All that said, the pattern that emerges is so clear it is like a punch in the nose.

We were able to isolate two 13-day periods, just before and just after the change, something of a “light switch” test. These periods are 9/24 – 10/6 and 10/19 – 10/31.

The number of vehicles for which rebates were issued declined by 81% (from 119 to 23). The dollar amount of the rebates is down 90%. The number of Model 3 rebates declined from 58 to 5. If a straight-line run rate is calculated from the post-change 13-day period, the program would disburse slightly over $600,000, well below the $3 million allotted cap.

Interestingly, if we look at the past 12 months of disbursements before the change (as close as we can get, 10/11/18 to 10/6/19), the amount disbursed was $2,867,500. Are they solving a problem that doesn’t exist?

It is possible that their internal projections that led to the reductions are based on sales forecasts that aren’t supported by current trends. In the legislation that authorized the funding, there is a provision to establish rebates for used vehicles, which has not been done to date. From our perspective, this is the tail wagging the dog. Let’s make the program work. If it runs over budget, we would rather deal with a problem of success. If these changes hold, it will have undermined the intent of the legislation passed in the spring.

The data from DEEP

Dates are noted in the upper right corner.

We expect to publish a subsequent update as more data become available.

This is the text of a letter that was sent to DEEP in response to the issuance of their EV Roadmap, which was published last month.

November 12, 2019

Commissioner Katie Dykes

Deputy Commissioner Vickie Hackett

CT Department of Energy and Environmental Protection 79 Elm St.

Hartford, CT 0610 DEEP.EnergyBureau@ct.gov

Dear Commissioner Dykes and Deputy Commissioner Hackett:

Thank you for the opportunity to provide comments in response to DEEP’s October 11, 2019 Notice and Opportunity to Comment on its draft Electric Vehicle Roadmap for Connecticut (draft Roadmap). The Connecticut Electric Vehicle Coalition (the EV Coalition or EVC) is a diverse group of clean energy advocates and businesses, organized labor, and environmental justice groups that support policies that will put more electric vehicles (EVs) on the road in Connecticut to achieve significant economic, public health, and climate benefits for our state.

The Connecticut EV coalition strongly supports the state creating a more strategic and ambitious strategy on zero emission vehicle (ZEV) deployment, one of several key strategies that will help the state tackle climate change, improve the public health and air quality, as well as create economic development opportunities for the state.

The EV Coalition appreciates the significant work that went into developing the draft Roadmap and looks forward to working with the Department to finalize a product that will serve as a useful guide for stakeholders and the State in equitably achieving transportation sector emissions reductions consistent with Global Warming Solutions Act (GWSA) goals.

The transportation sector is the largest source of greenhouse gas emissions in the State and responsible for the majority of smog-forming nitrogen oxide emissions. Connecticut will not achieve its GWSA commitments or achieve health-protective ambient air quality standards without significant electrification of transportation and reductions in vehicle miles traveled. To be effective, we believe that the Roadmap must strike the right balance between providing sufficient direction and avoiding over-prescription. The Roadmap should provide clear guidance to relevant market actors about expected roles and responsibilities and clarify both prioritization and timing for the recommendations in the document. At the same time, the Roadmap should eschew prescribing specific technologies, particularly given that technologies in the transportation sector are rapidly evolving and detailed specifications may become less appropriate over the duration of the Roadmap’s planning horizon.

With regard to prioritization, the Roadmap should clearly identify what needs to happen and when in order to ensure the state is on track to meet climate goals. The final Roadmap should include timeframes for its recommendations and identify high priority actions. As discussed further below, those high priority actions should include establishing aggressive public fleet electrification goals, including goals for transit fleets; conducting outreach to environmental justice communities to better understand local transportation and design electrified transportation solutions appropriate to each community; creation of a low-income EV rebate that is available for purchase of both new and used vehicles to help get more low-income residents into EVs; requiring the state’s utilities to develop electric rates that mitigate the impact that current demand charges have on deployment of fast-charging stations; recommending the adoption of EV-ready building codes so that all new construction is pre-wired for Level 2 EV charging; and recommending the elimination of the prohibition on direct sales of EVs in Connecticut, along with additional incentives for existing dealers to increase sales of EVs.

In prior comments, the EV Coalition urged DEEP to support its Roadmap with analysis of public charging infrastructure needs.1 We appreciate DEEP using the EVI Pro-Lite tool for this purpose in the draft Roadmap.2 DEEP should clarify, however, why the infrastructure need figures identified in the Roadmap using the EVI Pro-Lite tool differ from those provided in the final Governor’s Council on Climate Change recommendations,3 and include figures regarding the charging infrastructure needs for supporting 500,000 ZEVs in Connecticut in 2030. In addition, we urge DEEP to conduct sensitivities around key parameters (e.g., ratios of plug-in hybrid electric vehicles to battery electric vehicles, distributions of battery ranges across the vehicle fleet, and availability of home charging) to better understand ranges of public and workplace Level 2 (L2) and DC Fast Charging (DCFC) plug needs for 2030.

Recommendations regarding Equity:

The draft Roadmap minimally addresses equity and environmental justice issues. We commend the acknowledgement to prioritize these communities, but believe the final Roadmap needs to go further. Connecticut’s current transportation sector favors the single-occupancy vehicle and trucks. Low-income and minority communities are often among the worst affected by air pollution caused by these vehicles, affecting their respiratory and cardiovascular systems, and the environments in which they live. Any further action to electrify the state’s transportation sector needs to address outstanding equity issues. While the policies noted below are addressed within our comments on the relevant sections of the draft Roadmap, we present them below for emphasis.

Connecticut should provide incentives for the purchase of older model EV’s in order to expand the option of an EV purchase to low and moderate-income households. Currently, our EV rebates only apply to the sale or lease of a new EV, this should be altered to include a low- income rebate applicable to both new and used EVs so lower-income households can take advantage of the program.

In addition, a minimum percentage of the benefits of electrified transportation programs should be established for environmental justice communities and state-identified Economic Opportunity Zones. In addition to the types of community-specific programs intended to identify electrified solutions to the specific transportation needs of these communities (discussed below), it may be appropriate to carve out a percentage of EV charging stations to be sited in environmental justice communities particularly in areas where residents shop, work, and attend school and church.

Since public transportation is more widely used in low-income and minority communities the Roadmap should also prioritize the need for more electric buses and school buses. Electric buses do double-duty – they reduce emissions and take cars off the road, lessening Connecticut’s road congestion problems.

With the proper mix of EV charging stations, EV rebates, and electric buses, we can ensure that the Roadmap properly acknowledges our most overburdened and underserved communities.

Recommendations regarding Public and Private Fleets:

 While public fleets comprise only a small fraction of total vehicles in Connecticut, they are ideally designed for the state to truly “lead by example.” Studies show that increasing consumer awareness and familiarity with electric vehicles is important in influencing consumer purchasing decisions. Public fleets are one of the areas where Connecticut has the greatest direct control over the rate of vehicle electrification and creates opportunities to (1) increase direct EV driving experience with state employees and (2) increase the public visibility of EVs on our roads.

The current recommendation regarding the state fleet in the draft Roadmap—that the state “should consider setting targets for annual EV procurement for the state fleet, beginning with the goal of 5 percent of state vehicle in the first year”—is too weak: The state must set aggressive targets for electrifying public fleet vehicles.

Section 93 of Public Act 19-117,4 establishes several targets for EV deployment within the state fleet, which should inform the recommendation in the EV Roadmap.

• PA 19-117 requires, beginning January 1, 2030, that at least 50 percent of cars and light-duty trucks, and 30 percent of buses, purchased or leased for the state fleet to be “zero-emission.”
  • In light of the state’s express policy of reducing GHG emissions and need to reduce other air pollutants, we urge the state to go beyond the minimums established by the legislature and adopt a policy of procuring 100 percent zero-emission vehicles where such vehicles meet the performance needs for which they will be used, leading to stronger public fleet commitments: with a goal of ensuring that at least 50 percent of the cars and light-duty trucks and 30 percent of transit buses in the State’s fleet are zero-emission by 2030.
• PA 19-117 expands the Department of Administrative Services (DAS) commissioner’s annual legislative reporting requirements to include a procurement plan that aligns with these state fleet requirements and a feasibility assessment for the state’s purchase or lease of zero-emission medium and heavy-duty trucks; and
  • In alignment with the policy recommendation above, the feasibility analysis should be limited to the ability of commercially-available zero-emission vehicles to meet the performance needs required by the state. Any cost-benefit analysis should include estimated fueling and maintenance costs over the full useful life of the vehicle.
• PA 19-117 requires the DAS commissioner to study the feasibility of creating a competitive bid process for procurement of zero-emission vehicles and buses, and authorizes the commissioner to proceed if it would achieve cost savings.
  • The final EV Roadmap should encourage DAS to explore this option, as well as the possibility of joint procurement opportunities with municipalities and other

Regarding DEEP’s recommendation to update and publish guidelines for the installation of EVSE at state-owned facilities and public and private EV charging stations, DEEP has the authority to do this, and we encourage the agency to move forward with this activity. Using its ability to “lead by example,” state-owned and operated facilities should adopt minimum percentage charging requirements for parking areas, and such requirements should be included within all state-funded school construction projects. DEEP promoted similar recommendations to be included within the state building code for new residential and commercial construction, and these recommendations should establish the floor for state-owned and operated buildings.

Connecticut should support and incentivize electrification of private fleets by: (1) working with private actors and utilities to provide advisory services to fleet owners considering electrification; (2) developing rebates or incentives to support associated charging infrastructure needs; and (3) requiring utilities to develop rate designs that mitigate the impact of demand charges.

Recommendations regarding EVs beyond LDVs:

We strongly support incentives to electrify MDV and HDV. Connecticut should look to New York’s truck voucher incentive program5 to identify ways to incentivize purchases of cleaner, electric MDV and HDV.

While we encourage including fleet conversion to EVs as part of the electric utilities’ distribution system planning, DEEP should recognize that private fleet charging depots will likely need to be sited on-premises, so it may not be possible to target underutilized electric distribution circuits for fleet charging depots.

Accordingly, we should not let load decisions be the sole determinant in driving our EV infrastructure decisions. While it is clear that there are potential benefits from using EVs as a source of load smoothing and energy storage, the EV Roadmap should prioritize infrastructure investment where such investments will meet EV demand and benefit local communities. The goal should be to develop a comprehensive plan for building out our charging infrastructure in a manner that maximizes the combined, total benefits of increased EV deployment.

As noted in the GC3’s December 2018 Report, some of the largest GHG reductions from the transportation sector are likely to be achieved by increased investment in EV buses6, and these investments will likely be in our largest cities and most heavily-trafficked transportation corridors. While these are likely not areas with excess distribution capacity, nevertheless this is one critical area where investment must be made. The electric distribution companies (EDCs) should provide location-specific maps where excess distribution capacity exists so they may be evaluated against other criterial that would support investment in EV charging infrastructure.

Additionally, EV time-of-use rates can be an effective mechanism for shifting vehicle charging to off-peak times when the distribution system may be otherwise underutilized.

With respect to the pending California Advance Clean Trucks rule, we encourage Connecticut to continue to develop policies that leverage California’s authority to enact stringent motor vehicle emissions standards and polices beyond the floor established by the federal government. We should not pause our efforts pending the outcome of the current federal lawsuit, but rather position ourselves to act quickly when the court rules in favor of California and Section 177 states, including Connecticut.

Recommendations regarding Expanding EV Charging Infrastructure:

1. Building codes and permitting requirement recommendations

To encourage widespread adoption of EVs to meet Connecticut’s GHG reduction goals, policies must support the necessary infrastructure build-out to encourage consumer confidence with respect to “range anxiety” and support public education regarding EV technology. One critical component is expanding EV charging infrastructure, particularly in settings that vehicle purchasers cannot directly control (e.g., charging in public and semi-public/workplace settings, charging at multi-unit dwellings). It is also critical that new construction be capable of supporting EV charging infrastructure so that charging stations can be cost-effectively added as the need for them grows.

There is widespread consensus that the best time to prepare a location for the future installation of EV charging infrastructure is during the initial construction, rather than post-construction retrofitting. A recent analysis by Energy Solutions for the California Electric Transportation Coalition (CalETC) found that installing EV ready parking spaces during a building retrofit can save four to six times the cost of a standalone installation.7

The EV Coalition strongly supports the adoption of EV-ready building codes. DEEP must be an active participant in the adoption of updated building codes to ensure the necessary accessibility to EV charging as market penetration of EVs increases. To that end, DEEP should support adoption of EV-ready legislation through provision of templates for use in municipal building codes and zoning ordinances. The State has been presented with the opportunity to support EV-ready construction and has so far failed to act. The Code Adoption subcommittee of the State Codes and Standards Committee recently declined to adopt “EV ready” standards for new residential and commercial construction, citing increased cost and the relatively low number of EVs currently registered in Connecticut. This narrow view fails to adequately take into account the cost of building retrofits to accommodate charging infrastructure, as well as the clear market and industry signals regarding the future trajectory of EV adoption nationwide. The State must take this opportunity to support EV-ready infrastructure and enable Connecticut to lead the way toward an emissions-free transportation sector.

Additionally, local zoning requirements must not act as a barrier to deploying EV infrastructure in residential or commercial structures. Rather, requirements should encourage expansion of EV-ready infrastructure. Parking requirements must take into account the need to support a minimum level of EV charging spaces, as appropriate for the particular building structure. At a minimum DEEP should support building codes that mandate 10 percent of spaces be pre-wired for EV charging. Relating to ADA requirements, the Codes committee need not establish new ADA-compliant requirements; rather, the committee needs only to clarify how EV charging stations should comply with existing ADA requirements.

We support DEEP’s recommendation to consolidate permitting for Level 2 EVSE and DCFC installations. Such permitting would be better streamlined if: (1) applications could be submitted electronically and (2) a schedule of permit prices were published.

1. Siting recommendations

While grid impacts should be minimized if and when possible, that should not be the sole determining factor in site selection. Rather, demand and transportation needs should be allowed to shape charging infrastructure location.

1. Public charging infrastructure ownership recommendations

The EV Coalition supports DEEP’s recommendation that EDCs be permitted to rate-base make-ready investments in EV supply equipment in appropriate contexts. Utilities are uniquely positioned to encourage development of public EV charging infrastructure. DEEP should advocate in the PURA docket a clear expectation that utilities will submit proposals to support deployment of public EV charging stations.

As discussed further in other sections of these comments, carve-outs to ensure a percentage of EV charging stations are located in low-income and underserved communities are well-intentioned, but may not be the best way to support the transportation needs of these communities. The objective should be to improve access to clean, electrified transportation options that also improve public health, rather than proportional deployment of EV charging stations. Investments in low-income and underserved communities must be tailored to their specific transportation needs. For example, investments in electrified car or ride-sharing services or electrified transit buses may be more beneficial than charging infrastructure for certain communities. Community-specific assessments are necessary to determine the transportation needs of different communities.

Recommendations regarding Consumer Charging Experience, Interoperability, Pricing Transparency, and Future Proofing:

Fostering a positive consumer charging experience is critical to the successful transition to EVs in Connecticut. The challenge in addressing consumer experience through recommendations in the Roadmap is that, because technology is evolving so rapidly in this space, there are risks about being too prescriptive about specific technologies. As noted throughout these comments, the Roadmap should avoid dictating specific technological requirements.

For example, with regard to the proposed requirement that new electrical infrastructure installed at publicly funded DCFC stations be capable of supporting 150 kW charging stations or greater, we appreciate the intent of ensuring future-proofing of investments. However, the Roadmap should be crystal clear that this requirement pertains to the EVSE and not to the chargers themselves. In other words, the “make ready” infrastructure should be future-proofed to support the eventual installation of at least 150kW, but it does not make sense at this time to require actual installation of 150 kW chargers at every DCFC location. With regard to forms of payment, rather than prescribing specific requirements, it is preferable to defer to the existing statutory requirements on this issue found in C.G.S. § 16-19ggg.

With regard to signage and other standardization of charging experience, regional cooperation in this area is important as the region is relatively small with a large amount of cross-border traffic. Driver confusion regarding the availability of charging stations in neighboring states will negatively impact public perception and consumer adoption of EVs.

Finally, we support the draft Roadmap’s recommendation to establish a fine for ICE-ing and authorize state and municipal police and parking enforcement authorities to ticket vehicles in

violation of the law. This is low-hanging fruit and should be adopted. EV charging stations need to be available for EV drivers when needed.

Recommendations regarding Residential and Workplace Charging:

We support adoption of a right-to-charge law prohibiting Multi-Unit Dwellings (MUDs) and condominium associations from restricting lessees or condo owners with designated parking spaces from installing EV charging equipment and associated metering. Relevant stakeholders (e.g., condo owners) should be involved in the legislative process. In other jurisdictions this has led to common-sense approaches that were widely supported.

We further support DEEP’s efforts to ensure that the PURA docket evaluates and addresses approaches to manage EV load, which can take the form of rate design and/or managed charging or demand response programs. Technology needs to be able to support load management.

DEEP should adopt policies to encourage workplace charging in a manner that is technology-neutral and future-proofs these investments. For example, new infrastructure should be able to support L2 charging. The installation cost for L2 wiring is similar to the installation cost of L1 wiring. Thus, there is little value add to wiring only to support L1 charging.

Recommendations regarding Rate Design:

Rate design can be an effective tool for helping to manage EV load, and will be increasingly important as the number of EVs charging in Connecticut continues to increase. We agree with DEEP that if EV-only rates are going to be implemented, it is critical that they not require an additional revenue-grade meter, the cost of which is likely to cancel out the potential savings that an EV owner could accrue through off-peak charging. There are multiple alternatives to second meters to measure the EV component of household load. It can be measured using the embedded metering in smart, networked L2 chargers and advanced household meters that can parse load and identify the EV-specific component. We anticipate that EV load will soon be able to be measured through the communications capabilities of the vehicles themselves. The EV Roadmap should endorse the development of rate designs, including EV-only rate designs, that will help manage EV load. But in light of the rapid technological advances occurring, it is important that the Roadmap not be overly prescriptive about technologies through which EV-only rates can be implemented. The Roadmap should call for the utilities to be taking a proactive role and taking responsibility for managing EV load.

In addition to being a tool for managing EV load, rate design can be critical to removing barriers to deployment of DCFC stations. Demand charges are a major barrier to deployment of public (non-fleet) DCFC. As analyzed by RMI in the context of EVgo’s charging station fleet in California,8 particularly at low levels of utilization, demand charges can swamp volumetric charges under traditional commercial demand rates, thereby undercutting the business case for private installation of DCFC. Demand charges can also pose a barrier to fleet charging, including for depot charging of transit buses. Developing rate designs that address this barrier is critical to enabling deployment of electric transit buses in the state.

The concept of Eversource’s Rate Rider (which shifts the demand charge into the volumetric charge)9, is well-intentioned, but the current language of the Rate Rider is vague and confusing. There are good examples around the country of modifications to traditional demand charges that send appropriate price signals to station owners such as the recently-approved PG&E throughput-based subscription fee approach.10 Ultimately, we recognize that there is no one-size-fits-all approach to designing alternatives to traditional, demand-based rate structures. Each utility will need to design a rate that works best for its service territory. Regardless of the manner by which utilities address this challenge, their respective solutions should (1) be equitable and available to all DCFC, both existing and new, and (2) address the challenge through a predictable, transparent, and sustainable rate design, rather than a short-term incentive.

Recommendations regarding Innovation:

We appreciate the enthusiasm in the draft Roadmap for vehicle to grid (V2G) technology.

In the long term, when EVs are widespread, it will be valuable to be able to harness the stored energy in the batteries of parked vehicles. However, we do not believe that V2G should be identified as a high priority in the final Roadmap. Rather, it is critical in the near term to develop strategies for effective unidirectional smart charging (V1G) management of new EV load.

Recommendations regarding Leveraging Incentives to Promote Equitable, Affordable EV Adoption—CHEAPR Program:

The CHEAPR program has the potential to greatly boost EV adoption. Indeed, studies and modeling show that rebates that reduce the up-front purchase price of vehicles are a strong driver of EV adoption.11 Based on modeling that Synapse Energy Economics conducted for the Sierra Club in New York, it may be valuable to increase the sizing of the CHEAPR rebate for battery electric vehicles.12 Ultimately, the incentives should be sized such that the CHEAPR incentive, in addition to other federal and state incentives, is projected to put Connecticut on track to meet its transportation sector GHG commitments.

Additionally, the CHEAPR program will need to be scaled up to achieve 500,000 ZEVs on Connecticut roads by 2030 in order for the state to meet its climate goals.13 To that end, CHEAPR will need a large and sustainable source of funding. DEEP should explore the possibility of utilizing the Transportation and Climate Initiative (TCI) as a funding source for the CHEAPR program.

DEEP should also evaluate the merits of a low-income adder to the rebate in conjunction with other potential strategies to promote access to EVs for low-income and underserved communities, and extending the low-income rebate to the purchase of used vehicles. One alternative that warrants further consideration is a “cash for clunkers” program similar to what California and British Columbia have developed.

Finally, the EV Roadmap should recommend elimination of the current prohibition on direct sales of EVs, which is stifling sales of EVs in the state. The models that comprise the majority of national EV sales are not being sold in Connecticut. At the same time, the Roadmap should recommend additional incentives for existing auto dealers to increase their sales of EVs. More outreach to dealers regarding the existing CHEAPR dealer incentive is needed, given low levels of awareness by dealers, and additional incentives should be explored, such as: state reimbursement of the percentage of dealership local property tax equal to the percentage of EVs sold by the dealer each year, to a cap of 50%; state waiver of state income tax on all staff salaries based on percentage of EVs sold, to a cap of 50%; reimbursement of 100% of EV charging infrastructure and charging electricity costs at all CT dealer locations; free training for all CT dealers in EV sales using the PlugStarDealer.com program or a similar program; and/or higher CHEAPR rebates for all dealer cars used as service loaners and company cars.

Recommendations regarding Education and Outreach:

We support a coordinated approach to education and outreach among state actors and support a role for utilities and OEMs.

Connecticut should continue to support and participate in the regional Drive Change Drive Electric (DCDE) campaign and the Destination Electric Program to build upon and increase consumer awareness in the state and the region. We support the partnership framework among automobile manufacturers and state governments of the DCDE Campaign. While the campaign provides good web-based resources for learning about electric vehicles, there may be additional opportunities for proactive outreach and promotion. Such opportunities include cross-linking with other relevant state (such as DMV) and municipal (particularly for the Destination Electric program) websites.

We agree that OEMs should (and must) be active participants in advertising and marketing EVs in Connecticut, leveraging their years of experience in promoting conventional vehicles. Among the roles OEMs can play:

• Creation of informational and marketing materials for dealerships. While we assume that OEMs currently do this to some extent, we recommend an expansion of these efforts targeted to EV
• Providing additional dealer incentive for EV
• Providing supplemental consumer rebates for EV Purchases. For example, Nissan has partnered with the CT Green Bank to provide an additional manufacturer incentive of between $2,500 and $5,000 for the purchase of a Nissan Leaf.
• Providing well-promoted community “Ride and Drive” events, in partnership with the state, municipalities, and local businesses.

As noted above, we strongly support the recommendation to conduct focused outreach in underserved communities to inform the development of integrated approaches for deploying electrified transportation services strategically and addressing barriers to EV ownership by low- income households. We emphasize that the deployment of electrified transportation services should be informed by community priorities with respect to the type of services desired, whether that is increased access to light-duty EVs to replace older, unreliable personal transportation or the deployment of more electric buses and other clean transit options, with increased convenience and affordability.

Recommendations regarding Funding Mechanisms to Support Sustainable Incentive and EV Infrastructure Programs—VW EVSE:

VW EVSE expenditures should be coordinated with the utility programs that arise from the PURA ZEV docket.14 DEEP should focus on ensuring that key market segments, such as MUD L2, public transit corridor DCFC, and in-town DCFC, are being addressed.

A portion of the VW funding should be earmarked to support access to electrified transportation for communities that bear an outsize share of transportation emissions. DEEP should conduct outreach into these communities to better understand transportation needs and use VW EVSE funds to support charging infrastructure for transportation programs that will meet these needs (for example, communities that could be better served by car or rideshare programs). This is preferable to simply deploying a percentage of stations in overburdened communities.

Respectfully submitted,

The Connecticut Electric Vehicle Coalition

• Acadia Center*
• Connecticut Fund for the Environment*†
• Connecticut Green Buildings Council
• Connecticut Nurses Association
• Connecticut Roundtable on Climate and Jobs*
• Connecticut Citizen Action Group
• ConnPIRG
• Conservation Law Foundation
• ChargePoint*
• Chispa-CT*
• Clean Water Action*
• CT League of Conservation Voters
• CT 350
• Drive Electric Cars New England
• Eastern CT Green Action
• Electric Vehicle Club of Connecticut*
• Energy Solutions, LLC
• Environment Connecticut*
• Greater New Haven Clean Cities Coalition,
• Hamden Land Conservation Trust
• Hartford Climate Stewardship Council
• International Brotherhood of Electrical Workers*
• Interreligious Eco-Justice Network
• New Haven Climate Movement
• Northeast Clean Energy Council
• People’s Action for Clean Energy
• Proton OnSite
• Plug In America*
• RENEW Northeast
• Sierra Club*†
• Solar Connecticut,
• Tesla,
• Union of Concerned Scientists

* Connecticut EV Coalition Steering Committee Membership

Footnotes:

1 CT EV Coalition Feb. 21, 2019 Cmts at 2.

2 Draft Roadmap at 20.

3 Governor’s Council on Climate Change, Building a Low Carbon Future for Connecticut 29-30 (December 18, 2018).

4 An Act Concerning the State Budget for the Biennium Ending June 20, 2021, and Making Appropriations Therefor, and Provisions Related to Revenue and Other Items to Implement the State Budget.

5 See NYSERDA, New York Truck Voucher Incentive Program, available at https://www.nyserda.ny.gov/All- Programs/Programs/Truck-Voucher-Program.

6 See Governor’s Council on Climate Change, Building a Low Carbon Future for Connecticut (December 18, 2018).

7 Energy Solutions, Plug-In Electric Vehicle Infrastructure Cost Analysis Report for CALGreen Nonresidential Update (September 16, 2019), available at: https://caletc.com/energy-solutions-report-finds-that-increasing-the- number-of-electric-vehicle-capable-parking-spaces-at-new-buildings-and-adding-ev-capable-parking-spaces-to- existing-buildings-when-undergoing-certain/.

8 Rocky Mountain Inst., EVgo Fleet and Tariff Analysis Phase 1: California (Apr. 2017).

9 Available at https://www.eversource.com/content/docs/default-source/rates-tariffs/ev-rate- rider.pdf?sfvrsn=e44ca62_0.

10 See PG&E, PG&E Proposes to Establish New Commercial Electric Vehicle Rate Class (Nov. 5, 2018), available at       https://www.pge.com/en/about/newsroom/newsdetails/index.page?title=20181105_pge_proposes_to_establish_new

_commercial_electric_vehicle_rate_class; PG&E, PG&E’s Commercial Electric Vehicle Rate (Nov. 20, 2018), available at https://caltransit.org/cta/assets/File/Webinar%20Elements/WEBINAR-PGE%20Rate%20Design%2011- 20-18.pdf.

11 Studies have found a significant increase in EV sales with the implementation of rebates among low- and moderate-income households. Scott Hardman, The Effectiveness of Financial Purchase Incentives for Battery Electric V9ehicles, 80 Renewable and Sustainable Energy Reviews 1110 (2017), https://phev.ucdavis.edu/wp- content/uploads/2017/09/purchase-incentives-literature-review.pdf.

12 Synapse Energy Economics, Inc., Transforming Transportation in New York: Roadmaps to a Transportation Climate Target for 2035 (September 2019).

13 See Governor’s Council on Climate Change, Building a Low Carbon Future for Connecticut 28 (December 18, 2018).

14 PURA Docket No. 17-12-03RE04.

† To whom correspondence should be directed. Josh Berman, Sierra Club. Email Josh.Berman@sierraclub.org or phone (202) 650-6062. Charles Rothenberger, Connecticut Fund for the Environment. Email crothenberger@ctenvironment.org or phone (203) 787-0646, x122.

The Department of Energy and Environmental Protection (DEEP) issued the attached Notice of Technical Meeting for February 8, 2019, from 9 a.m. to 4:30 p.m. ET, in the Gina McCarthy Auditorium, DEEP Headquarters, 79 Elm Street, Hartford, Connecticut. 

The purpose of the technical meeting is to inform the recommendations of the EV Roadmap. The technical meeting will consist of four panel discussions with subject matter experts presenting on key topics, followed by a question and answer session with the audience. 

November 26, 2018

AN ELECTRIC VEHICLE ROADMAP FOR CONNECTICUT

NOTICE OF SCOPING MEETING AND OPPORTUNITY FOR PUBLIC COMMENT

As recommended by the Comprehensive Energy Strategy issued on February 8, 2018, the Department of Energy and Environmental Protection (DEEP) initiates this proceeding to develop an electric vehicle roadmap (EV Roadmap) for Connecticut. The EV Roadmap is anticipated to identify Connecticut-specific policies, programs, and strategies that the State of Connecticut should pursue to optimize deployment of electric vehicles (EVs) and associated infrastructure. Moreover, the EV Roadmap is intended to support development of a self-sustaining EV market, and ensure that increased electricity demand from EV deployment is a benefit rather than an impairment to the electric grid.

DEEP will conduct a scoping meeting on December 14, 2018, at 10 a.m. EST, in Hearing Room 2 at DEEP’s New Britain Office, Ten Franklin Square, New Britain, Connecticut. The purpose of the meeting is to brief stakeholders on the proposed scope of the EV Roadmap proceeding and to take public comment on the proposed scope of the EV Roadmap, which is provided below.

Draft Scope EV Roadmap

Overview

The EV Roadmap will outline the 2030 vision and objectives necessary to support the deployment of increasing numbers of light-duty zero emission vehicles (ZEVs) in Connecticut necessary to meet air quality and climate goals and to inform the parameters DEEP will consider when soliciting electric vehicle supply equipment (EVSE) infrastructure proposals under the VW NOx Mitigation Grant. In so doing, the document will review and describe a summary of user trends and projections, regional and federal efforts to date, and zero emission options beyond light-duty fleet applications.

Accelerating ZEV adoption and creating a robust fueling infrastructure Even with increasing demand, a growing roster of vehicle models, and an expanding network of both public and private infrastructure, the EV market is still in an early stage of maturation. To further support development of a self-sustaining EV market and the necessary infrastructure, the EV Roadmap will build on existing efforts already underway and make recommendations on the following elements:

• Education, outreach, and marketing
• Public and private fleet strategies
• Sustainable funding in the form of incentives, financing, manufacturer partnerships, or other
• Partnering with dealerships
• Bringing clean transportation options to low- to moderate-income communities
• Streamlining building codes and permitting
• Future proofing
• Interoperability
• Consistency of customer experience
• Data collection (EV registrations, charging station data, etc.)

Fueling/charging cases

Increasing market penetration of ZEVs requires increased deployment of fueling/charging infrastructure. In turn, accessible and reliable infrastructure will support and encourage further adoption of ZEVs in the state. Building out self-sustaining fueling/charging networks will require ongoing private-public partnerships and open communication to ensure that planning efforts are coordinated among multiple fueling/charging cases, including public, residential, and workplace charging.

The EV Roadmap will discuss and make recommendations on the following fueling/charging cases:

Public

• Public charging infrastructure ownership models
• EV fast charging
• Corridors, destinations, state facilities and properties, around town
• Hydrogen refueling stations

Residential • Single family homes

• Multi-unit dwellings

Workplace

• Workplace charging opportunities
• Outreach to promote workplace charging
• Opportunities to reduce impact of charging during peak hours
• Workplace charging host guidance
• Leadership recognition

Rate design and demand charges

Rate design and demand charges for residential, commercial and industrial customers set market signals. Market signals may be necessary to encourage beneficial off-peak charging that improves the efficiency of the grid and reduces costs for all electric ratepayers. Further, ZEVs can be a demand- response resource and/or function as distributed energy storage, enabling a reduction in investments in new electricity infrastructure and shifting load from peak to off-peak hours.

The EV Roadmap will explore and recommend crafting a rate design and demand charge strategy that encourages EV adoption while mitigating adverse electric demand and costs and harnesses the benefits of EV flexible load capabilities.

ZEV’s beyond light-duty vehicles

The EV Roadmap will discuss emerging applications for medium- and heavy-duty vehicle and non- road electrification in order to identify cost-effective strategies that target transportation electrification opportunities beyond light-duty vehicles including fleet and freight applications.

Planning forward with VW EVSE

As a part of the Volkswagen settlement, Connecticut has been allocated almost $56 million for use towards offsetting the excess oxides of nitrogen (NOx) emissions caused by VW’s actions. DEEP’s plan for the allocation of VW funds is set forth in the State of Connecticut Mitigation Plan and focuses on extensive mitigation projects to reduce NOx from a wide array of mobile sources. In accordance with a federal Consent Decree (Appendix D-2), Connecticut reserved up to 15 percent of these funds for electric and hydrogen vehicle infrastructure/EVSE.

EVSE project funding, like NOx mitigation funding, will be awarded through an open, competitive and transparent process that will comply with all applicable state and federal procurement requirements.

In November 2018, DEEP issued $12.1 million for a variety of clean air projects. DEEP will offer additional rounds of funding at a later date and will include a competitive grant opportunity for electric and hydrogen vehicle charging/fueling infrastructure. The EV Roadmap will both inform and outline funding priorities in this category.

DEEP plans on following the preliminary timeline detailed below:

Action Preliminary Timeframe DEEP initiates EV Roadmap proceeding and notices scoping meeting November 21, 2018 DEEP scoping meeting December 14, 2018, at 10:00 a.m.

Comments due on proposed scope December 20, 2018, by 4:00 p.m.

DEEP technical meeting January 2019 DEEP issues draft EV Roadmap February 2019 DEEP hearing on draft EV Roadmap February 2019 Comments due on draft version EV Roadmap March 2019 DEEP issues final EV Roadmap April – May 2019

By way of this Notice, DEEP is accepting public comment on the proposed scope of the EV Roadmap proceeding through December 20, 2018, by 4:00 p.m. EST. Written comments may be filed electronically on DEEP’s website or submitted to DEEP.EnergyBureau@ct.gov. All materials submitted by stakeholders in this proceeding will be posted on DEEP’s Energy Filings website under the matter “EV Roadmap.” Any questions can be directed to Debra Morrell at (860) 827-2688 and/or via e-mail at DEEP.EnergyBureau@ct.gov.

The Connecticut Department of Energy and Environmental Protection is an Affirmative Action/Equal Opportunity Employer that is committed to complying with the requirements of the Americans with Disabilities Act. Please contact us at (860) 418-5910 or deep.accommodations@ct.gov if you: have a disability and need a communication aid or service; have limited proficiency in English and may need information in another language; or wish to file an ADA or Title VI discrimination complaint. Any person needing a hearing accommodation may call the State of Connecticut relay number – 711. Requests for accommodations must be made at least two weeks prior to any agency hearing, program or event.

Notice filed with the Secretary of State on November 26, 2018.

Clean Transportation Forum in Hartford

These are the details of the upcoming forum:

The CT Department of Energy and Environmental Protection is tasked with developing a “roadmap” to optimize EV deployment as part of the state’s commitment to greenhouse gas reduction and the multi-state ZEV Action Plan.

The EV Club of CT is on the steering committee of the CT Electric Vehicle Coalition (EVC). EVC has written the following letter to DEEP discussing the considerations that should be part of any such roadmap. (The members of the EVC can be found at the end of the letter.)

December 20, 2018

Commissioner Rob Klee

Deputy Commissioner Mary Sotos

CT Department of Energy and Environmental Protection 79 Elm St.

Hartford, CT

Dear Commissioner Klee and Deputy Commissioner Sotos:

The Connecticut Electric Vehicle Coalition (“the EV Coalition” or “EVC”) is a diverse group of clean energy advocates and businesses, organized labor, and environmental justice groups that support policies that will put more electric vehicles (“EVs”) on the road in Connecticut to achieve significant economic, public health, and climate benefits for our state. The Connecticut Electric Vehicle Coalition appreciates the efforts of the Department of Energy and Environmental Protection (DEEP ) to “identify Connecticut-specific policies, programs, and strategies that the State of Connecticut should pursue to optimize deployment of EVs and associated infrastructure” through the development of an EV Roadmap. The Connecticut EV Coalition strongly supports the state creating a more strategic and ambitious strategy on zero emission vehicle (“ZEV”) deployment, one of several key strategies that will help the state tackle climate change (1), improve the public health and air quality (2), as well as create economic development opportunities for the state (3).

The EV Coalition recommends that DEEP approach the EV Roadmap by first identifying targets for vehicle electrification based on the State’s climate goals, focusing on the State’s 2030 goal of reducing GHG emissions economy-wide 45 percent below 2001 levels (4). The Governor’s Council on Climate Change’s recently released draft report identifies the need to electrify 20 percent of the passenger vehicle fleet (500,000 vehicles), 30 percent of buses, light commercial trucks and refuse trucks, and 35 percent of single use short haul trucks by 2030 consistent with the State’s legislated climate goal (5) which should guide the targets in the Roadmap. Once the vehicle goals are identified, the EV Coalition urges DEEP to model the associated charging needs (both public and private, Level 1, 2 and DC fast charging) for a realistic range of assumptions regarding future vehicle capabilities (e.g., ratios of plug-in hybrid electric vehicles to battery electric vehicles, distributions of battery ranges across the vehicle fleet, and availability of home charging). This analysis can be readily undertaken using the National Renewable Energy Laboratory’s (NREL’s) publicly available EVI-Pro Lite tool,6 which can produce a sensitivity analysis around the results by varying the input assumptions.

Finally, the EV Coalition urges DEEP to identify policies and strategies that can put Connecticut on the trajectory required to meet its 2030 vehicle electrification and charging infrastructure goals, while minimizing adverse impacts to the grid and maximizing the benefits of the new electric load. This strategy identification should include clarifying roles and responsibilities for the full range of stakeholders, including actions that need to be taken legislatively, those that can be taken administratively at the state level, actions that should be undertaken by the State’s utilities, and those that should be pursued at the local level.

While the Draft Scope EV Roadmap identifies a number of key strategic areas and important considerations for accelerating deployment of ZEVs in Connecticut, which are discussed in greater detail below, for the Roadmap to truly be able to guide decision-making around EVs in the coming years, we urge DEEP to embed it in the type of analysis regarding 2030 vehicle and charging infrastructure needs identified above. In developing the Roadmap, we also urge DEEP to be cognizant of equity impacts of its recommendations and focus on expanding not just opportunities for EV ownership but also access to the benefits of electrified transportation (e.g., through electrified shared-ride or ride-hailing services, through electrified transit bus options, etc.).

Accelerating ZEV Adoption

There are a range of barriers to EV adoption including vehicle purchase price, lack of consumer education and information, and range anxiety due to inadequate publicly-accessible charging infrastructure. The EV Coalition urges DEEP to address each of these barriers to EV adoption in the EV Roadmap and identify levers that the State can pull that will help to overcome them (7).

The EV Coalition supports specific recommendations and strategies around ZEV adoption, including addressing all the topics proposed by DEEP, and briefly comments on the following included in DEEP’s list:

• Education, outreach, and marketing. The EVC agrees that DEEP should propose improved and coordinated education campaigns in the Roadmap.
• Public and private fleet strategies. The EVC supports public and private fleet strategies,and the establishment of state fleet EV deployment targets. Bulk purchases will help reduce purchase price. As noted in the GC3 draft report, the State must lead by example by quickly shifting all fleet vehicle purchases to electric. This will help bring down vehicle costs. The state can further increase the efficacy of this strategy by coordinating with other like-minded states and municipalities to engage in bulk purchasing. Both California and Massachusetts have recognized the importance of aggressive state fleet EV mandates, and Connecticut should explore savings that could accrue from multi-state bulk purchasing programs (8).
• Sustainable funding in the form of incentives, financing, manufacturer partnerships, or other. The EVC supports the policy objective of ensuring a stable source of funding for CHEAPR at least through 2025 to ensure that all interested purchasers can take advantage of EVs. Incentives should be designed to equitably increase access to EVs by offering an income eligible program that offers bigger rebates and used-car rebates for customers in lower income brackets. The EVC also recommends that a board is established to oversee the rebate program, and to establish a process for setting and altering rebate levels, including low income rebates and eligibility, and program evaluation. This Board should set up structures for monitoring and evaluation of EV access to make sure all residents, especially those most impacted by air pollution, have accesses to both clean public transit and vehicles, as well as needed EVSE.
• Partnering with dealerships. EVC supports better partnerships with dealerships to increase their engagement of consumers interested in buying electric, for instance workshops and ride-and-drives sponsored by the State, dealership groups, and EV stakeholders, as well as trainings for dealerships that enhance electric car expertise and sales capabilities (9).
• Bringing clean transportation options to low-to-moderate-income communities. In addition to income eligible rebates, the Roadmap should focus on electrifying our public transit system, and could explore how the state can incentivize rideshare services to utilize ZEVS.
• Streamlining building codes and permitting. EV-ready building codes are critical to reducing the cost of equipping buildings with the charging equipment needed to support accelerated adoption of electric vehicles.
• Interoperability: The EVC believes that it should be easy for any charging station to be used by any driver accessed through any system. For any state-facilitated or ratepayer-supported programs, the EVC urges DEEP to consider strategies to maximize interoperability and consumer access.
• Data collection (EV registrations, charging station data, etc.) The EVC supports improving the state’s data collection and monitoring regarding both EV registrations and charging stations, while maintaining consumer privacy.

In addition to the above topics, the EV Roadmap should address increasing Connecticut consumers’ access to EVs. The EVC supports allowing direct EV sales to consumers or other alternative business models. Allowing direct sales would increase the availability of additional EV models, grow public awareness of EVs generally, and encourage build-out of public and private charging infrastructure.

Creating a Robust Fueling Infrastructure

There are also important barriers to deployment of EV charging infrastructure that will be necessary for EV adoption, such as the challenge that demand charges pose to the business case for direct current fast chargers at low levels of EV penetration. The EV Coalition supports the EV Roadmap’s inclusion of strategic charging infrastructure planning, including how the state should approach the EVSE Infrastructure Proposals under VW NOx Mitigation Grant and more broadly looking at public-private partnerships for public, residential and workplace charging. We have previously urged the state to move forward as quickly as possible to take advantage of and begin benefiting from settlement funds available to expand Connecticut’s EV charging infrastructure and make other critical advancements toward electrifying our transportation sector (10).

The Roadmap could address utility’s role in building out Connecticut’s charging infrastructure, but only to the extent that incorporating this topic would not slow down recommendations and progress made through PURA’s grid modernization docket. Utility investment in make-ready infrastructure, for example, can complement the competitive market, address coordination problems, and help to overcome barriers to entry in important market segments, including low-income communities and multi-family housing.

In addition, the EV Roadmap can help direct a discussion about how to overcome the barrier that demand charges pose to build-out of DC fast charging infrastructure. Many approaches are being tested around the country including demand charge holidays, off-bill rebates, and rate structures that shift some portion of the demand charge into the volumetric charge. In Connecticut, Eversource has been testing this latter option through the EV Rate Ride pilot, which has saved publicly available charging station owners thousands of dollars annually (11). Another example is Pacific Gas & Electric’s recent proposal to replace demand charges with a lower rate based on the installed capacity to which a charging customer is willing to subscribe, subject to a significant overage charge, as well as a time of use component.12 Any EV rate design reforms should be structured to be consistent with the state’s goals of grid modernization and improved integration of distributed energy resources (DER), including solutions that retain compatible price signals for multiple and different types of DER-like storage.

Smart, Standards-Based EV Integration & Consumer Market Signals

The EVC supports DEEP’s plans to identify strategies that will minimize adverse impacts and maximize benefits of new electric load, including encouraging off-peak charging and utilizing ZEVs as a demand response resource. Smart integration of EVs into the grid can help maximize GHG emissions reductions by optimizing grid utilization. Through appropriate customer signals (e.g.time-of-use rates or off-peak charging incentives), the flexible load of EVs can better integrate renewable resources or shift load by charging at periods of low demand. These changes improve the efficiency of the grid and reduce costs for all ratepayers, while at the same time improving the economics of operating an EV. In seeking to manage EV load, there must be careful consideration of customer experience and choice to assure that the steps taken to shape the load curve from EV charging do not inadvertently deter EV adoption or disincentivize the deployment of EVSE at a wide range of appropriate locations. Because these issues are being explored in the current grid modernization before PURA,13 the EV Roadmap should only address them if timing aligns.

ZEV’s Beyond Light-Duty Vehicles

The EVC supports the EV Roadmap including the evaluation of deployment opportunities for medium and heavy-duty vehicle and non-road electrification. It is especially important for the state to address zero-emission buses and electrified public transit options to promote equitable access to clean transportation. The roadmap should therefore focus on addressing additional policy levers needed to electrify our transit buses as quickly as possible. Specifically, DEEP should look at how the state can better leverage VW settlement funds to accelerate the deployment of electric transit buses and electric school buses. The first round of funding resulted in a disappointing number of proposals around electrification. DEEP should look at how other states have used the diesel mitigation funds to support electrification, and potentially revise the mitigation plan and future project solicitation guidelines to better support and encourage electric vehicle investments, including for public and private buses.

1 EVs have zero tailpipe emissions, and even with New England’s electricity mix today, these vehicles cut GHG emissions as much as 75% compared to conventional vehicles. These emissions savings will only increase as the region continues to clean and modernize the electric system, and move toward a 100% renewable future. See Acadia Center, Energy Vision 2030, available here: http://2030.acadiacenter.org/

2 American Lung Association, Clean Air Future: Health and Climate Benefits of Zero Emission Vehicles (Oct. 2016), available at http://www.lung.org/local-content/california/documents/2016zeroemissions.pdf. See also http://www.lung.org/local-content/california/documents/national-clean-air-future-report.pdf.

3 A study of economic impacts of EV deployment in California, for example, showed that ZEVs are a catalyst for growth. In California alone, the ZEV market will create 100,000 additional jobs across all economic sectors by 2030. See David Roland-Holst, University of California Berkeley, Plug-in Electric Vehicle Deployment in California, An Economic Assessment (Sept. 2012), available at https://are.berkeley.edu/~dwrh/CERES_Web/Docs/ETC_PEV_RH_Final120920.pdf. Similar modeling should be done in Connecticut.

4 Public Act 18-82.

5 Governor’s Council on Climate Change, Building a Low Carbon Future for Connecticut: Achieving a 45% GHG Reduction by 2030 (released Dec. 18, 2018), at 28, available at https://www.ct.gov/deep/lib/deep/climatechange/publications/building_a_low_carbon_future_for_ct_gc3_recommendations.pdf.

6  EVI-Pro-Lite is available through the Alternative Fuels Data Center at https://afdc.energy.gov/evi-pro-lite.

7 See CT EV Coalition Comments on Draft CES dated September 19, 2017.

8 See Commissionon Future of Transportation in Massachusetts, Choices for Stewardship: Recommendations to Meet the Transportation Future, available at https://www.mass.gov/files/documents/2018/12/14/FOTCVolume1_1.pdf. See also Hiroko Tabuchi, The New York Times, California Requires New City Buses to Be Electric by 2020, Dec.12, 2018, available at https://www.nytimes.com/2018/12/14/climate/california-electric-buses.html.

9  See e.g., PlugInAmerica, Plug Star Dealer Program, https://pluginamerica.org/plugstar/dealership/.

10 See EVC Letter to Governor Malloy dated November 1, 2017.

11 CT’s own EV Rate Rider is a good example of how rate design can support EV deployment. PURA Docket No.13- 12-11,

http://www.dpuc.state.ct.us/dockhistpost2000.nsf/8e6fc37a54110e3e852576190052b64d/46cfb43aff01dbd28525829c00736078/$FILE/Att%201-3%20Electric%20Vehicle%20Pilot%20Filing.pdf.

12 PG&E Proposes to Establish New Commercial Electric Vehicle Rate Class, Nov. 5, 2018, https://www.pge.com/en/about/newsroom/newsdetails/index.page?title=20181105_pge_proposes_to_establish_new_commercial_electric_vehicle_rate_class.SeealsoRobertWalton,UtilityDive,PG&EMimicsSmartPhoneDataPlanswithEVChargingRateProposal,Nov.9,2018,https://www.utilitydive.com/news/pge-proposes-new-rate-class-for-commercial-ev-charging/541799/.

13 SeePURADocketNo.17-12-03: PURA Investigation into Distribution System Planning of the Electric Distribution Companies, Connecticut Electric Vehicle Coalition Joint Principles on Grid Modernization and Electric Vehicles,Sept. 26,2018.

*          *          *

We look forward to engaging with DEEP on these important topics.

Respectfully submitted,

The Connecticut Electric Vehicle Coalition

• AcadiaCenter*†
• Connecticut Fund for the Environment*†
• Connecticut Nurses Association
• Connecticut Roundtable on Climate & Jobs*
• Connecticut Citizen Action Group
• ConnPIRG
• Conservation Law Foundation
• ChargePoint*
• Chispa-CT*
• Clean Water Action*
• CT League of Conservation Voters
• CT350
• Drive Electric Cars New England
• Eastern CT GreenAction
• Electric Vehicle Club of Connecticut*
• Energy Solutions, LLC
• Environment Connecticut*
• Greater New Haven Clean Cities Coalition, Inc.
• Hamden Land ConservationTrust
• Hartford Climate Stewardship Council
• International Brotherhood of Electrical Workers*
• Interreligious Eco-Justice Network
• New Haven Climate Movement
• Northeast Clean Energy Council
• People’s Action for CleanEnergy
• Proton OnSite
• Plug In America*
• RENEW Northeast
• Sierra Club*†
• Solar Connecticut, Inc.
• Tesla,Inc.
• Union of Concerned Scientists

* Connecticut EV Coalition Steering Committee Membership

† To whom correspondence should be directed. Claire Coleman, Connecticut Fund for the Environment. Email ccoleman@ctenvironment.org or phone (203)787-0646. Josh Berman, Sierra Club. Email Josh.Berman@sierraclub.org or phone (202)650-6062. Emily Lewis, AcadiaCenter. Email elewis@acadiacenter.org or phone (860)246-7121 x207.

Pre-election candidates debate.

Organized by the Westport Green Task Force, these are the logistics:

Thursday, November 1st, 2018

7p.m. to 8:30 p.m.

EARTHPLACE, THE NATURE DISCOVERY CENTER

10 WOODSIDE LANE, WESTPORT, CT

Hear what the candidates have to say about environmental issues, policies, and plans that affect Westport and CT.

State Senate District 26:

Senator Toni Boucher (R) vs William Haskell (D)

State Senate District 28:

Senator Tony Hwang (R) vs Michelle Lapine McCabe (D)

State House District 136:

Representative Jonathan Steinberg (D) vs. Greg Kraut (R)

(Note: Mr. Kraut declined to participate)

State House District 143:

Representative Gail Lavielle (R) vs Stephanie Thomas (D)

Do you have questions you want to have answered?

Submit them to gtf@westportct.gov

The Electric Vehicle Coalition of CT has sent an open letter to the Public Utilities Regulatory Authority that communicates key principles with respect to EVs and grid modernization.

Bruce Becker, President of the EV Club of CT, stated, “A study by Natural Resources Defense Council (NRDC) indicates EV adoption will reduce utility bills for all CT customers by $500 million by 2050 while reducing vehicle operating costs for EV owners by $1.9 billion. Therefore, PURA must incentivize EV adoption to make energy cheaper and cleaner for CT residents.”

The full text of the letter is below:

September 26, 2018

Jeffrey R. Gaudiosi, Esq. Executive Secretary

Public Utilities Regulatory Authority

10 Franklin Square

New Britain, CT 06051

Re: Docket No. 17-12-03: PURA Investigation into Distribution System Planning of the Electric Distribution Companies, Electric Vehicle Coalition Principles on Grid Modernization and Electric Vehicles

Dear Mr. Gaudiosi:

The CT Electric Vehicle Coalition,a diverse group of clean energy advocates, organized labor, and environmental justice groups, commends PURA for including electric vehicles in its scope of the Grid Modernization proceeding. Electric vehicles (EVs), which encompass not just passenger vehicles, but medium-and heavy-duty vehicles, are critical technologies Connecticut must deploy to meet its greenhouse gas (GHG) reduction requirements and Zero Emission Vehicle Memorandum of Understanding commitments. EVs have zero tailpipe emissions, and even with New England’s electricity mix today, these vehicles cut GHG emissions as much as 75% compared to conventional vehicles.(1) These emissions savings will only increase as the region continues to clean and modernize the electric system. Importantly, EVs also reduce harmful air pollution, create economic development opportunities, and reduce reliance on imported petroleum fuels. Recognizing these benefits, the state has committed with other Northeast and West Coast states to put 3.3 million of these vehicles on the road by 2025.

Utilities could help spur the advancement of EVs through a range of new policies and programs.  Smart integration of EVs into the grid can help maximize GHG emissions reductions by optimizing grid utilization. Through appropriate customer signals, the flexible load of EVs can better integrate renewable resources or shift load by charging at periods of low demand. These changes improve the efficiency of the grid and reduce costs for all ratepayers, while at the same time improving the economics of operating an EV. Broad deployment of EVs also hinges on widely available charging infrastructure, which utilities have a role in supporting. Utility investment in make-ready infrastructure, for example, can complement the competitive market, address coordination problems, and help to overcome barriers to entry in important market segments, including low- income communities and multi-family housing.

Utility programs and investments to support EVs must align with broader principles of utility regulation, including grid modernization and rate design. As such, the CT EV Coalition requests PURA to consider the following principles, particularly how they impact EV deployment, within the Grid Modernization docket.

(1) Acadia Center, Energy Vision 2030, available here: http://2030.acadiacenter.org/

PRINCIPLES ON GRID MODERNIZATION AND ELECTRIC VEHICLES IN CONNECTICUT

• Rate design must be improved. Granular, efficient, and technology-neutral pricing must be developed to support new technologies and promote Connecticut’s public policy goals. Demand charges are a major barrier for several EV charging applications, and Connecticut has a beneficial pilot that eliminates demand charges for certain types of EV charging stations. Further reforms to rate design, including broader adoption of time of use rates without demand charges, can simultaneously accelerate EV adoption and incentivize EV charging at optimal times.
• Equity and access should be incorporated into a wide range of EV programs. This includes rate design and programs to increase access to electric transportation and EV charging stations in underserved and marginalized communities.
• Education and outreach strategies are needed to support well-designed programs. Consumer awareness and understanding are crucial to adoption rates and achievement of program goals.
• Distribution system planning must be improved to include local clean energy alternatives to traditional infrastructure. Methods must be developed for a stronger consideration of clean, local resources, including EVs as flexible load and distributed storage.
• Promotion of interoperability and data disclosure should be conditions of participation in utility investment programs. Connecticut should generally apply consumer-friendly regulations to all public EV charging stations, notably pricing disclosure, measurement accuracy, and open access. In addition, key charging station objectives can be included conditions of participation in utility investment programs, such as interoperability of charging connectors and data disclosure.
• The utility business model must be changed to incentivize policy-driven outcomes. Utilities must shift their business model to rely less on return on capital investment and more on performance incentives for consumer and environmental outcomes.
• Utility benefit-cost calculations must be updated to reflect the public interest. These calculations should be applied to all types of new utility investments, including those that facilitate EVs. Through this proceeding, PURA could explore options for including GHG reductions and petroleum fuel savings in benefit-cost calculations.
• Robust stakeholder input and processes are needed to inform any utility programs.

The Connecticut EV Coalition respectfully requests that this multi-phase grid modernization proceeding include a track to carefully evaluate regulatory mechanisms to ensure smart integration of EVs into the grid, which takes into consideration the grid modernization principles above, and addresses the appropriate roles for utilities with respect to EV acceleration and deployment of EV charging infrastructure. We look forward to engaging with PURA on these important topics.

Respectfully submitted,

The Connecticut Electric Vehicle Coalition

• Acadia Center*†
• Connecticut Fund for the Environment*
• Connecticut Nurses Association
• Connecticut Roundtable on Climate & Jobs*
• Connecticut Citizen Action Group
• ConnPIRG
• Conservation Law Foundation
• ChargePoint*
• Chispa-CT*
• Clean Water Action*
• CT League of Conservation Voters
• Drive Electric Cars New England
• Eastern CT GreenAction
• Electric Vehicle Club of Connecticut*
• Energy Solutions, LLC
• Environment Connecticut*
• Greater New Haven Clean Cities Coalition, Inc.
• Hamden Land Conservation Trust
• Hartford Climate Stewardship Council
• International Brotherhood of Electrical Workers*
• Interreligious Eco-Justice Network
• New Haven Climate Movement
• Northeast Clean Energy Council
• People’s Action for Clean Energy
• Proton On Site
• Plug In America
• RENEW Northeast
• Sierra Club*
• Solar Connecticut, Inc.
• Tesla, Inc.
• Union of Concerned Scientists

* Connecticut EV Coalition Steering Committee Membership