US DOT EV Charging Program - Seeking Comments

The US Department of Transportation just issued a request for information in the Federal Register for comments as they develop guidance on their EV Charging Program. Comments are due January 28th. I just posted my comments to the docket. Much of my focus was on directing the program toward its guiding principle of reducing carbon emissions. With that goal, is it more effective policy to subsidize charging stations (just like we did with call boxes in the 1990s pre-cell phone) or taking an equity based approach toward investments this time. Maybe the greatest impact on carbon emissions can be achieved through expansion of urban household based EV charging infrastructure, with support to low and middle income households. And maybe think about e-Bikes as a means toward the desired outcome. Here are my comments to FHWA.

Consideration #1: Distance between EV charging

There are two ways to look at this consideration. First, to meet the goal of addressing climate change through reduced carbon emissions and, second addressing non-urban travel. Since reduced carbon emissions is a guiding principle of the program focus should be upon where the greatest reduction can occur. Since 1980, the share of USA vehicle miles traveled (VMT) in urban areas has been growing to now over 70% of the over three trillion VMT per year. Much more of the urban VMT occurs in stop and go travel (below 30 mph) where the greatest emissions occur, as compared to rural areas. Therefore, the greatest impact EV can have on carbon emission can be garnered in urban areas. The average vehicle trip length in most metropolitan statistical areas (MSAs) in the USA is less than 15 miles. For work trips it is about 25 miles. What does this mean?

·???????With EV ranges growing to 200 to 400 miles, there are very few urban vehicle trips that cannot be serviced from a household charge – meaning the need for independent public charging stations in these settings should be minimal.

·???????Urban charging investment should focus on meeting urban household needs at the point of residence – increasing the number of households with access to charging.

·???????The key component of a household charger is a 240V outlet in the garage (costing $300-$800). While for many folks who can afford an EV, this charge is within reason. However, for lower income households, it is a barrier to EV use.

·???????New houses, in-fill houses and remodels (over $100,000) should have the resources to include a 240V in each house – this may require coordination with local agencies and electrical codes to establish this for all new/renovated housing stock (a trivial cost of a large expenditure). This one act would have substantial impact on emission reduction by eliminating the barrier to home charging. Government subsidy should not be necessary for this type of investment.

·???????The same holds for commercial sites and fleet vehicles. Those businesses should be able to support these facilities (for example urban office buildings, restaurants, theaters, event centers or retail where durations are long enough to complete charging). It may be appropriate for local governments to require these parking space types, similar to requirements for off-street parking or parking for person who are disabled. This could become part of transportation demand management conditions of approval for new commercial land uses (through the use of a model “condition” of development). The owner could contract out the service which derives revenue from the sale of electricity at the charging station (and provides maintenance accountability). Again, government subsidy should not be necessary for this type of investment.

·???????For multi-family housing, few have charging capabilities. This is a potential area for government investment, particularly for lower income housing (not for luxury apartments). Most important would be who maintains the charger. Whereas for homeowners that is clear, landlords may not be suitable stewards of a capital-subsidized charger. Initial capital subsidies in the past decade to build charging stations were not supported with adequate maintenance and many of these facilities became inoperable/non-serviceable. In multi-family complexes with garages, this may be easier (both in terms of durability and power metering to the tenant). Most apartments have outdoor parking. Another public investment would be to develop cost-effective carport solar charging station technology as many apartments have carports. This could be applied to new or retrofit circumstances in urban settings.

In summary, government investment in urban areas would focus on resident point of charge strategies rather that a criterion for distance between publicly available EV charging. This would have the greatest potential for reducing carbon emissions nationally based upon the vast number of trips that are carbon emission intensive.

In the second case of non-urban travel has a substantially lesser impact on reducing carbon emissions. Intercity and rural travel (due to the long trip lengths) are made with few stops at speeds of 40+ mph – some of the most efficient internal combustion engine operating conditions. Not only are there fewer trips, the delta between gas-engine and EV is less also. Because of the longer trip lengths, presence and spacing of EV charging infrastructure makes the difference between using an EV and using a gas/diesel vehicle. Much of the interstate freeway system is equipped with charging stations at rest areas. These along with truck stops/freeway-oriented retail are ample to service interstate needs (one change might be to include minor food-cart, retail at rest areas to address time loss for recharging in a more efficient manner – as federal laws prohibit most retail in rest areas).

However, the vast majority of rural areas are not served by these interstate roadways. Government investment may be appropriate for charging stations in fueling/mini-mart/fast food locations on state highways and in rural towns. With current range batteries, 50-mile spacing minimum may be a reasonable grid. The development of solid-state batteries will likely eclipse current views about range (substantial public capital that is not useful today).

Consideration #2: Electric Grid

The top issue here is the need for quick charging. While Level 1 or 2 are adequate for residential applications (or commercial points with long-stop durations), charge time for continuous travel is huge barrier when charging goes beyond 15 minutes. Level 3 charger outputs range from 50 kW to 350 kW. While the number of urban trips is large, much of the charging can occur overnight (with long range batteries). However, longer, rural, cross-country trips demand fast charging to minimize down time. The need for quick charging can have the potential to create surges in power in remote areas that may not be equipped to address such surges. This may require research of battery systems to address peak surges more effectively. While quick charge is key to long-trip travel, the number of long trips relative to carbon emissions benefits is lower. Government investment here should focus on the research of peak surges and how to best manage this impact on the grid – particularly if quick charging were to proliferate in urban settings. Managing quick charging in urban areas is important, particularly since viable options exist for most daily use through evening household charging and/or peak pricing.

Consideration #3: Proximity Charging Infrastructure to Off-Highway Travel Centers

The carbon emission reduction of investments in this area need study. In an urban area, there may be not need for subsidy – provision should be a cost of business or a condition of development through local agency codes (which a good model uniform code recommendation may be a worthwhile investment by the EV Charging Program). Outside the MSAs in the USA, investment may be necessary to achieve the 50-mile grid. Subsidies should be used to fill gaps in rural, intercity areas and pair placement with common traveler resources (off-highway travel centers).

Most important for the EV Charging Program would be the development of uniform standards for data for EV charging stations such that information critical to the consumer is available openly and transparently for third-party data compilers to share with the public. Open access to ANY EV charging station – and most importantly any EV charging station that receives and public support – should include:

·???????Location

·???????Type (Level 1-2-3-….)

·???????Availability (in service, occupied)

·???????Cost

This information is critical for long trip travelers (no different than finding a gas station) and should be integrated into the EV driver assistance systems (automotive, SAE collaboration). From a consumer (and governmental performance management) perspective, having a standardized metric established (similar to airline on-time arrival) for the charging station availability (i.e., % out of service time) is critical to assure maintenance, improve performance and consider in grant awards.

Consideration #4: Underserved and Rural Communities

The federal investment in EV charging should focus on equity. While the reduction of carbon emissions is the guiding principle, many people and businesses have the resources to invest in this infrastructure without government assistance. The CAFé standards assure that EVs will be a part of the future toward reduced carbon emissions. Therefore, investments by the federal government should tend to focus not on those who have means or would profit otherwise from the development of EV development, but on the demand side where barriers exist to deep penetration of household access to EVs. In urban areas, low/middle income assistance to support EV penetration should be the sole focus – not higher income households and businesses with independent means. For example, as noted earlier the federal program in urban areas should:

·???????Subsidize lower and middle income single family homeowners with 240v outlets and charging stations (maybe to the point that for $50,000 incomes and less it is free and for $50-150K incomes it is a tier % discount – but no discounts above that). Using the EV purchase rebate example, why would the USDOT consider going forward that it is good policy to subsidize EV purchases with $7500 for household incomes over $150,000 when the market penetration created by such policy is 1-2% over more than a decade).

·???????Require new house construction to provide 240v outlets through model code revisions. Subsidize new low-income, single-family houses with charging stations in garages.

·???????Subside low-income, multi-family housing installation of charging stations (not for luxury apartments – they should be addressed through code requirements for all new, remodel, retrofit permits).

·???????Review 50-mile grid and subsidize charging stations in urban areas only if there is a gap is services (unlikely).

For rural areas, consider programs/grants for local businesses and traveler service hubs to fill out a dense 50-mile grid through subsidies. For rural homeowners, make home charging subsidies available for households below $100,000 income.

Consideration #5: Maintenance

There are far too many subsidized EV charging stations across the county that are in a state of disrepair. This happened with the initial programs that focused on the infrastructure installation as the goal but not the operation and maintenance.?To abate this, for any grant program to install EV charging capital, there should be a simple agreement to maintain the equipment for its designed service life (5-10-15 years). If a third-party contractor is utilized in implementation, they should be required to the same agreement terms. By obtaining and maintain availability data, this could be utilized as a performance metric in grant funding (below a level of historic availability = no funding).

US DOT should be wary of large, subsidized expansion of charging stations. Case in point, in the 1980s/1990s the need for communication on major highway as identified as a need and call boxes were expanded rapidly. Virtually none exist today after such a significant investment. Technology (cell phones) replaced them. With solid state batteries on the horizon and the potential for longer range batteries with quicker charge times, making sure equipment is durable for foreseeable technology developments is critical. We will not achieve the desired maximum reduction in carbon emissions if we do not seek to optimize use of investments. Therefore, focusing on urban point of residence (which is a durable investment) should be a priority now until technology settles out in the next decade.

Consideration #6: Incentives

As mentioned previously, developing mode code changes to require 240v outlets in all new single-family houses (new, reconstruct, retrofit, infill) may be more of a requirement than incentive but should be given high priority. Providing subsidies to urban low/middle income for charging stations, providing subsidies for low-income multi-family housing to install charging stations and/or providing subsidies to fulfill the 50-mile grid in rural area are incentive priorities.

Consideration #7: Foster Public/Private or Private Investment

See #6 for subsidies. Additionally, making certain that standards exist for things such as charging connectors so no one has to worry about having the wrong connector (SAE J1772). No funds should go to non-uniform systems as they are anti-consumer and form barriers to EV penetration. If private companies want to go it alone with their own equipment and funding – that is fine – but no public funds should be used for non-standard equipment.

Consideration #8: Time to Charge

While faster charging is always better – context is everything. Level 1 or 2 charging in household (overnight setting) is totally adequate – particularly in an urban setting. However, on the open road (inter-city, rural) and for freight movement – time is king. Fast charging investments by the US DOT should be focused on interstate, rural long-distance needs – NOT urban. Urban areas have the means to address those needs without assistance.

Consideration #9: Other

While not part of the request, one thing that has emerged with EV charging is the placement of the charging cord relative to pedestrian ways. The cord when placed over a sidewalk or pedestrian path can impact accessibility. This can happen in multi-family settings when the charging station is not properly placed relative to the charging port of the vehicle. Some research should go into the best practices for positioning chargers and their cords to not create impacts to accessibility. Additionally, charging of vehicles by persons with disabilities should be evaluated further to make sure EVs are accessible for all persons.

Finally, with the goal of reduced carbon emissions, investments (particularly for lower income households) in electric bicycles may be better use of EV investment dollars than independent charging stations. This should be researched prior to significant charging station outlays.