For New York to combat climate change and achieve its ambitious climate goals, preparing infrastructure for the transition to an electrified transportation system will be critical. New York Department of Public Service Staff proposed a major step forward for electric vehicle (EV) charging in New York with their release of a Whitepaper Regarding Electric Vehicle Supply Equipment and Infrastructure on January 13, 2020. The Whitepaper recommends a $582 million utility-based make-ready charging infrastructure program that is designed to support what New York needs to meet its commitment to 850,000 zero emission vehicles on the road by 2025. If approved, the program would support deployment of tens of thousands of public and workplace Level 2 plugs and thousands of public direct current fast charging plugs—the largest utility charging infrastructure program outside California—and would help to make New York a national leader on EVs.
Range anxiety – the fear of being unable to find suitable charging to enable one’s full range of travel – continues to be a primary impediment to EV adoption, and for vehicle owners without dedicated off-street parking, convenient and accessible public EV charging infrastructure is critical to enabling EV ownership. Utilities have both the means and incentive to support EV deployment of EV charging infrastructure in key locations, and elsewhere in the country have been approved to invest more than $1 billion in charging infrastructure programs.
New York’s embrace of a proactive role for utilities in supporting the transition to EVs follows years of effort and persistence. In 2015, the Sierra Club began advocating in the Public Service Commission’s Reforming the Energy Vision proceeding for the Commission to address the utility role in supporting transportation electrification. The Sierra Club submitted a letter requesting that the Commission open a docket to explore the utilities’ role in assisting a transition to EVs and urged the Commission to solicit proposals from utilities on how to facilitate EV and EV charging infrastructure deployment. This initial advocacy sparked a lengthy stakeholder process facilitated by New York’s distribution utilities that culminated in a disappointingly anemic joint “EV readiness framework” and a handful of demonstration project proposals.
Unsatisfied, the Sierra Club, joined by the Natural Resources Defense Council and a diverse coalition of 39 other environmental groups, labor unions, environmental justice organizations, automakers, business organizations, and EV charging infrastructure companies, submitted a formal Petition to the Public Service Commission calling on the Commission to open a proper investigation into the role for utilities in supporting the transition to EVs.
The Commission responded. In April 2018, it addressed the Petition by opening a new docket “to consider the role of electric utilities in providing infrastructure and rate design to accommodate the needs and electricity demand of EVs and EV [supply equipment]” including “explor[ing] cost-effective ways to build such infrastructure and equipment.” Following a technical conference and solicitation of detailed input from many stakeholders, Staff produced their Whitepaper with its ambitious make-ready charging infrastructure program proposal.
Accelerating deployment of EV charging infrastructure is critical because New York is not on track to achieve its EV obligations. New York is a member of an 8-state Zero Emission Vehicle Memorandum of Understanding that obligates it to place 850,000 zero emission vehicles on the road by 2025. There are currently fewer than 50,000 registered EVs in New York. The DPS Staff estimates that supporting 850,000 EV will require approximately 80,000 workplace Level 2 charging plugs, 50,000 public Level 2 plugs, and 3,300 public direct current fast charging plugs —a dramatic increase from the fewer than 4,000 total charging plugs currently in the State—and its proposal is designed to put the State on track to meet those numbers.
Under Staff’s proposal, utilities would underwrite 90 percent of the cost of the “make-ready” infrastructure and installation (i.e., the infrastructure and work on the customer side of the meter between the meter and the EV charger hub) for publicly-accessible Level 2 and direct current fast chargers. For workplaces and apartment buildings, the utility share would be 50 percent of the make-ready costs. Staff projects that, with these incentives, the majority of charger installations will have a positive cost proposition over ten years (this excludes fast chargers Upstate, for which it is proposing additional incentives). With an eye to equity considerations, the Whitepaper directs that 20 percent of each utility’s budget for direct current fast chargers be used for chargers within 10 miles of a disadvantaged community.
There is a lot to celebrate in the Staff proposal, but also room for improvement. Staff’s proposal does not address incentives for charging infrastructure to support medium- and heavy-duty vehicles or much-needed rate design to minimize the grid impacts and maximize the benefits of EV charging. The Sierra Club looks forward to continuing to work with other stakeholders and the Department of Public Service to lock in the gains and address the missing pieces, to ensure that New York leads on creating a fossil-fuel free transportation system that works for all.
-by Sierra Club ELP Senior Attorney, Josh Berman