Toyota Dominates May Rebates

The two plug-in hybrid offerings from Toyota dominated the rebate activity for May. The Prius Prime (44 rebates) and the RAV4 Prime (30 rebates) together accounted for 61% of the 123 May rebates. (The April count was slightly restated to 125.) The only other vehicles in double figures were the Chevrolet Bolt (12) and Hyundai Kona (10). May marked the first appearance of a VW ID.4 with one rebate. Driven by Toyota, the balance of the rebates tilted heavily toward PHEVs, 85 vs. 38 BEVs.

The program spend continues to pace well under the available funds. The new incentives will help somewhat, but we doubt by enough.

There has been some press about the program this week as the Governor’s office issued a release about the new program, which was picked up by a number of newspapers. Readers of this blog will know that the CHEAPR board approved these modifications in February, but implementation only recently happened on June 7th.

The big headline numbers that are featured, such as up to $7500 in rebates, or on the CHEAPR home page, up to $9500, only apply to Fuel Cell vehicles, which are not currently for sale in the state. But the higher rebates and income-limited incentives are now live and we will see the early reporting in one month.

All rebates by model in the table below:

EVs = Clean Air

“If I could wave my magic wand and we all had electric cars tomorrow, I think this is what the air would look like,” said Ronald Cohen, a professor of atmospheric chemistry at UC Berkeley who has been studying the effects of the stay-at-home orders on air quality, as reported recently in the LA Times.

The Electric Vehicle Roadmap prepared by the Connecticut Department of Energy and Environmental Protection (DEEP) has been recently released. For all the research and policy thought that went into it, and there is quite a lot, the report reads with a striking lack of urgency and overlooks opportunities to start making immediate progress.

It is tragic that it took a pandemic and its collateral economic damage for us to breathe clean air. CT air quality is often poor as detailed in the Roadmap (p. 12). Worse, preliminary findings from a study conducted at Harvard Medical School indicate that breathing polluted air increases COVID lethality.

As bad as what we are currently enduring may be, it presents an opportunity for us to make changes. If we make the right choices, we can always have clean air, respond to the climate crisis, and create new green jobs. But this requires action. The recommendations in the Roadmap are mostly of a tentative or preliminary nature. These are a few examples.

Demand Charges

If we are to have enough public charging to mitigate range anxiety, we need more public DCFC (fast chargers), particularly along the Interstates. It isn’t happening because utility demand charges, which weren’t developed with EVs in mind, make commercial installations economically unviable. Note the “out of order” level 3 chargers on I-95 and the Merritt Parkway (our information is that out or order = turned off).

Demand charges are extra fees imposed if electricity usage exceeds a certain threshold. The purpose is to pay for the infrastructure needed to support peak usage periods and it affects commercial customers. The fees can be substantial.

Pacific Gas and electric in California presented a rate design solution to the regulatory board in 2018 that would use a subscription formula to avert demand charges. The California Energy Commission released an extensive study of how to think about demand charges in an EV world in April 2019.

In contrast, this is the recommendation in the Roadmap: “DEEP recommends exploration of a sliding scale tariff approach for both Eversource and UI that is responsive to DCFC station utilization and EV market penetration.”

There is currently a temporary three-year demand charge waiver in place in CT. We’re one year into it. Few seem to be aware of it. Regardless, a temporary waiver isn’t going to accomplish anything due to the risk of stranded assets. The CT Public Utilities Regulatory Agency has recently issued an RFP for Program Design Proposals with a deadline of July 31. In other words, we’re just getting started.

Time of Use

Time of Use pricing (TOU) is an important consideration both for making EV “refueling” cost-efficient as well as for grid optimization. If you have ever visited this Eversource page, you will see how little CT consumers have to work with. Or if you have tried the energy savings calculator on cutmybill.com, the limitation of only using normative data makes it of little use.

Utilities in Vermont, California, New York, and Massachusetts have implemented residential incentive programs that may include paying for a networked level 2 EV charger or moving the charging to a lower rate for off-peak times. It not only saves the customer money; it saves the utility money as well due to avoidance of adding capacity. Con-Edison in New York has an incentive that works with a device that accesses the vehicle’s telemetry and awards rebates for charging that occurs during off-peak times (even outside of Con-Ed territory).

That said, this is a complex and utility-specific topic. It involves considerations of whole-house or EV only. The latter requires either sub-metering or a networked level 2 charger. The recommendations in the Roadmap on page 68 are, “…explore the potential for an active managed charging program that incents EV drivers to charge during off-peak periods.” “…current TOU rate tariffs should be optimized…” “DEEP will continue to monitor…programs in other jurisdictions…” DEEP alone can’t implement TOU. The utilities must do it. The regulators need to approve it. We would have preferred to have seen more specific recommendations.

State Fleet

CT maintains a fleet of about 3,500 vehicles. The Roadmap recommends, “DAS (Department of Administrative Services) should develop a detailed light-duty fleet transition plan that outlines annual EV procurement targets for the state fleet, beginning with a 5 percent target of eligible state vehicles in 2020…” We assume “eligible” means mainly sedans, since that is the bulk of currently available EVs.

By way of contrast, New York City has replaced a third of its fleet of sedans with EVs as of 2019 and is targeting having 4,000 on the road by 2025. They report a savings of $550 per year per vehicle in fuel and maintenance for an EV sedan relative to its internal combustion engine (ICE) counterpart. And, by the way, they installed 568 charging stations and counting to support this fleet, 65 of which are solar-powered. Finally, the city plans to cut its fleet by 1,000 vehicles as part of an effort to reduce on-road miles traveled. Based on the experience of NY and others, including some municipalities in the state, CT can move much more quickly with low risk.

Heavy-Duty Vehicle Vouchers

As noted in the Roadmap, California and New York have implemented voucher incentive programs to offset the acquisition cost of clean heavy-duty vehicles. CA has used this program to fund the deployment of over 4,000 such vehicles. The Roadmap: “DEEP will continue to monitor the effectiveness of freight truck voucher incentive programs in accelerating the adoption of freight trucks.”

Transit Buses

The Roadmap addresses buses: “on and after January 1, 2030, at least thirty percent of all buses purchased by the state shall be zero-emission buses.” If “at least thirty percent” equals 40% for the sake of argument, that means that the fleet would be 33% electrified by 2040.

New York City plans for its entire transit bus fleet to be zero-emission by 2040.

Purchase Incentives

CT has an EV purchase incentive called CHEAPR. Funding was renewed by the legislature last year at $3 million annually for 5 years beginning with 2020. The incentive plan in New Jersey funds $10 million per year, which translates to 50% higher per capita. And CHEAPR is pacing 75% under budget for this year due to restrictive parameters imposed in October 2019. The MSRP cap should be raised and the rebate levels re-evaluated.

The enabling legislation for the new CHEAPR funding also authorizes an incentive for used EVs with an income cap. Good idea, as there are more than twice as many used vehicles sold each year relative to new vehicles, and it would make EVs more accessible to car-dependent lower-income households. The Roadmap recommends contracting with a program administrator. It is fine to go outside for needed expertise. We just don’t understand why it wasn’t done a year ago when the legislation was passed.

Direct Sales – MIA

A glaring omission is direct sales. This refers to what has been known informally as “the Tesla bill,” which would allow Tesla to open stores in CT. (It goes beyond Tesla as there are other EV startups looking at this model). This is a politically fraught topic, but what is most disappointing is the way that politics seems to have influenced what is supposed to be a comprehensive policy document. Doing away with the antiquated dealer franchise laws wouldn’t cost the state a penny (it would generate revenue) and would accelerate EV sales immediately.

As of January 1, 2020, there were 11,677 EVs registered in CT. The Multistate ZEV (Zero Emission Vehicle) Action Plan that the state has signed onto calls for about 500,000 registered EVs by 2030.

Many of the subject areas covered in the Roadmap involve more than just DEEP. However, other states have already implemented pilot studies or EV-friendly policies. They’ve run the numbers, and they see that moving to EVs lowers pollution, saves money, and brings benefits to the grid. We can learn from them while simultaneously moving forward. CT is behind the curve, yet this Roadmap takes the scenic route.

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.

CHEAPR Update

Connecticut Hydrogen and Electric Automobile Purchase Rebate, in case you were wondering, is what the acronym stands for. CHEAPR has been with us for a while now. It was passed in 2015 and has handed out 5267 rebates (through August 31), totaling over $10 million for the purchase of fuel-efficient EVs. (There were 10,797 EVs registered in the state as of July 1, so it sure seems like it has been a factor.)

If you go on the program’s website today (Oct. 1), it indicates that there is only $60,958 in remaining funds. But HB 7205, passed in the 2019 legislative session, authorizes a replenishment due to take effect today, which will hopefully be reflected soon, and which funds the program through 2025.

Keep in mind, CHEAPR is a rebate. It is not a tax-credit like the Federal incentive, and there are no manufacturer sales caps. The rebate is more consumer-friendly in our view.

Current Incentive Levels

CHEAPR standards have changed over time. The basic idea of the rebate size being driven by zero-emissions range is still present, but as cars have changed, so have the criteria. This is the current incentive breakdown:

As the chart indicates, incentives are available for plug-in hybrid vehicles (PHEV), battery electric vehicles (BEV), and fuel-cell electric vehicles (FCEV). The implication is that FCEVs have much greater range than a BEV. That isn’t entirely the case. A Tesla Model 3 has up to a 310-mile range, Chevy Bolt gets 238 miles, Hyundai Kona is rated at 258. There are two FCEVs currently registered in the state. Both are Toyota Mirais, rated 312 miles. The other two FCEVs that we are aware of are the Hyundai Tucson (265 miles), and the FCEV version of the Honda Clarity (366 miles). There were no rebates given for either of the FCEVs.  (It is also hard to find one within the price cap.) We’re not entirely sure about the consistency here, but range is the stated principle.

The amount of incentive given for a lease may not be as straightforward as it gets folded into the mathematics of the lease payment calculation by the dealer. As the saying goes, your mileage may vary.

Many CT dealers are interconnected with the DMV/CHEAPR and will handle the paperwork. They often just take the incentive off the price of the vehicle they deliver. It saves the work of filing for the rebate, but we recommend carefully reviewing the invoice with the dealer in order to accurately set expectations regarding the price.

Price Cap

There are other requirements associated with CHEAPR. Eligible vehicles must have an MSRP below $50,000. (Originally, the cap was set at $60,000.) This makes ineligible a number of expensive EV entrants such as the Tesla Models S and X, Jaguar i-Pace, Audi e-Tron, and others. The Tesla Model 3 is eligible for the lower trim levels. It is possible to get the long-range (310-mile) Model 3 for under $50,000. We expect there to be trim levels of the forthcoming Model Y that will also be eligible, based upon what we see on the Tesla website. With respect to the FCEVs, the Honda Clarity base trim price is $59,365, Toyota Mirai is $59,430, Hyundai Tucson – $50,875 (FCEV base prices are from Car and Driver). Based on these MSRPs, it would appear they would all be too expensive to qualify, but they are listed as eligible on the CHEAPR website. We are only aware of the availability of these vehicles via lease. If you’re going that route, it seems prudent to verify the eligibility before concluding the transaction.

Once Only

Unlike the Federal tax credit, which is associated with each vehicle, the CHEAPR rebate is tied to the person receiving it. This rebate can be claimed one time only. It can be used for multiple vehicles if different (licensed) members of the household are the registrant. Pro-tip: Don’t co-sign for a vehicle because you will both get dinged for the use of the rebate.

Where Can You Buy It

In order to be eligible, it is required that the vehicle be purchased from a dealer doing business in CT. (The dealer gets a little taste, too.) If you buy that Chevy Bolt from a dealer out of state and transfer the registration, you will not get the rebate.  The exception to this is Tesla, which does not have dealers, and which has been barred by CT law from opening stores in the state. But the Model 3 trim levels that are below the price cap are eligible and Tesla will work with you on the admin.

New vs Used

This incentive applies to the purchase or lease of a new vehicle only. There is language in HB 7205 (line 142) authorizing DEEP to set income and incentive thresholds for purchases of used vehicles. We contacted DEEP for clarification and were advised that the rules as stated on their website are what govern eligibility, and these rules state, specifically, new vehicles only.

This is the link to the CHEAPR website. It lists all of the eligible vehicles as well as the rules and program stats.

Representative Jonathan Steinberg (D-136) Kicks Off The Session By Advocating for Added CHEAPR Funding (Photo: Bruce Becker)

Presenters: Dana Lowell (not pictured) of MJ Bradley and Associates; (left to right) Emily Lewis, Policy Analyst for Acadia Center; Mustafa Salahuddin, president of the Amalgamated Transit Union Local 1336 in Bridgeport; and Kevin Killer, Director of Public Policy for Chargepoint

A full house

A full meeting room of people assembled to hear a panel on EV public policy, specifically the economic benefits of moving to more extensive EV adoption. Along with the panelists noted above, the crowd also heard from Representatives Jonathan Steinberg (D-136, Westport) and Roland Lemar (D-96, East Haven), who is co-chair of the Transportation Committee. The panel was co-moderated by Claire Coleman, climate attorney for the CT Fund for the Environment, and Bruce Becker, president of the Electric Vehicle Club of CT.

The topic of the panel was how increased adoption of EVs will confer significant economic benefits to the state of CT and its residents.

Among the specific topics covered were continued funding of CHEAPR, the state program of rebates for EV purchasers; time-of-use utility rates; the impact of EV charging on utilities and ratepayers; and the benefits of moving to electric buses in our transit systems. For example, Mr. Lowell pointed out that, by law, the additional net revenues that would flow to utilities from EVs plugging in would have to be returned to ratepayers, lowering bills by an average of about $150 annually. And, if the charging were to occur primarily during off-peak hours, this would contribute to smoothing the power-utilization curve throughout the day. A good summary of the proceedings can be found in a write-up done by The Day of New London.

The EV Club of CT showed up in force for the day’s events, which included meetings with legislators and legislative aides in addition to the forum. Aside from Becker, club members Phil Levieff, Dawn Henry, R. Murali, Demetri Spantidos, Analiese Paik, Virgil de la Cruz, and Barry Kresch made the rounds.

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.