Comments to DPU on Utilities Phase II EV Program Filings
PowerOptions recognizes our Members’ need for an incentive program that provides essential financial support to help defray the upfront and ongoing costs associated with EV charging equipment and infrastructure. Transportation electrification is a critical part of the Commonwealth’s decarbonization agenda to achieve 45% emissions reduction in the transportation sector by deploying 750,000 zero-emission vehicles by 2030. Many of our Members have started their own clean transportation efforts and experienced first-hand some of the barriers to implementation. As part of our advocacy work, on September 14th PowerOptions offered the following comments to the Massachusetts Department of Utilities regarding DPU 21-90, 21-91, 21-92: Phase II EV Program Filings of the Distribution Utilities.
Observations on the Current State of Electric Vehicle Charging
PowerOptions has been working with Members for over two years to provide technical assistance for Electric Vehicle Supply Equipment (EVSE) planning and installation. PowerOptions has pre-vetted EVSE equipment suppliers and a network of qualified installers so Members can adopt new and unfamiliar technology with confidence. PowerOptions Members installing EVSE have included hospitals, schools, municipalities, and other non-profits, for employee, fleet, and public charging. All Member installations to date have been Level 2 chargers, due to the available incentives and lower cost of procurement, installation, and operation. There is increasing interest in emerging opportunities to charge fleets such as school buses and other medium-duty and heavy-duty trucks, and some of these use cases will require higher capacity chargers such as Direct Current Fast Charger (DCFC) devices.
There are several barriers to increased adoption of electric vehicle charging infrastructure including capital costs, demand charges, and operations and maintenance of EVSE installations to ensure availability. The Massachusetts Electric Vehicle Incentive Program (EVIP) has provided a critical source of funding to help with the capital cost barrier in addition to the complimentary Make Ready programs in supporting these efforts. However, the funding for these programs has been finite and the operating costs, particularly demand charges, have proven to be a significant issue for many sites, especially those with multiple charging ports where utilization is still growing in advance of widespread EV adoption.
Summary of Pertinent Aspects of Utility Filings
We appreciate the collaboration by the utilities to align their plans more closely than the existing programs, but there are still essential differences that make it challenging for customers to navigate the programs, especially when combined with other related incentive programs. We encourage the Department to require more uniformity in fundamental program structures.
Since EVSE technology, infrastructure, and consumer behavior patterns are still emerging, the Department should conduct a Make Ready mid-term program evaluation with the authority to order a re-prioritization of program funds as needed.
The Fleet programs proposed by Eversource and National Grid are largely disparate, with proposed funding of $2M and $98M respectively. While Eversource has proposed a new pilot fleet assessment program, there is no funding proposed for Make Ready, EVSE rebates, or electric school bus rebates as newly proposed by National Grid. For fleet managers to convert to electric vehicles, financial assistance is needed to build out the supporting infrastructure.
We would like to see details from Eversource on the EVSE proposal for school buses, and the Medium-Duty Heavy-Duty (MDHD) future fleet offering noted as part of its fleet program. We support incentives for school bus rebates, which are critical to defray the high upfront costs, but we request that the DPU review the program’s success and prioritize funding if needed during the program period, to verify the investment as currently allocated.
Innovative Pilot Programs
We support National Grid’s innovative programs for pole-mounted EVSE, storage and DCFC co-location projects, and electric bus rebates, and encourage Eversource to offer similar programs so there is continuity and shared learning across the Commonwealth.
Both National Grid and Eversource indicate that they will need six months from a Department Order in this proceeding to implement demand charge alternatives. The utilities cite the need for billing system updates and training customer service staff. PowerOptions is concerned that relief from demand charges may not be available to Members until mid-2023 since the Department may not issue an Order in this proceeding until the fall of 2022. Demand charges on EVSE with dedicated meters is a significant problem in the present time. While the demand charge alternative rate designs proposed by the utilities are constructive, a six-month lag to implementation after a Department Order is too long.
The Eversource Make Ready program is structured such that all EV charging infrastructure receiving incentives must be individually metered. This requirement is restrictive and a barrier for many large campus customers from a cost and interconnection standpoint. These customers can accommodate the EVSE demand within their campus load profile, and the utilities should provide a submetering option. This could also reduce cost pressure on the demand charge alternative program since these customers would not require any mitigation of demand charges.
We support networking fee stipends proposed by both Eversource and National Grid, as often these additional operating costs can be significant and difficult to recover if station users are not charged usage fees, or if public stations have low initial station utilization.
PowerOptions Members need certainty over capital and operating costs to make investments in EVSE. As the Department evaluates procedural schedules, it is important to keep in mind the lead time for organizations to deploy EVSE and the immediate need for demand charge relief for early adopters with dedicated EVSE station meters. The Make Ready Investment proposals and demand charge mitigation rate designs will remove significant barriers to EVSE investment. This investment is necessary to help foster the required ecosystem of EV charging so that Massachusetts drivers can confidently adopt EVs knowing that charging options are widely available and accessible.