Public Comments Regarding Volkswagen Settlement Beneficiary Mitigation Plan

Size: px

Start display at page:

Download "Public Comments Regarding Volkswagen Settlement Beneficiary Mitigation Plan"

Madison Gallagher
5 years ago
Views:

Appendix A Information regarding Oklahoma s Electric Vehicle Supply Equipment (ESVE) buildout in reference to the Oklahoma Department of Environmental Quality s (DEQ) development of Oklahoma s

1 Appendix A Information regarding Oklahoma s Electric Vehicle Supply Equipment (ESVE) buildout in reference to the Oklahoma Department of Environmental Quality s (DEQ) development of Oklahoma s Volkswagen Beneficiary Mitigation Plan (BMP) Public Comments Regarding Volkswagen Settlement Beneficiary Mitigation Plan December 5, 2017 Authored by: Adriane Jaynes, INCOG Energy Programs Manager ajaynes@incog.org

2 Contents Electric Vehicle Charging... 3 Recommendations... 3 Background... 3 Charging Venues... 4 Types of Charging Equipment... 5 Siting Considerations... 5 Potential Charging Sites... 7 Considerations... 8 Sample Equipment Vendor Costs Page INCOG Comments, Appendix A

Electric Vehicle Charging Recommendations We encourage ODEQ to utilize the full 15% of the settlement funding eligible for public electric vehicle charging throughout the state.

To move Oklahoma forward and proactively prepare for the coming increase in EV and PHEVs, INCOG recommends developing an accessible, user-friendly EV charging network.

3 Electric Vehicle Charging Recommendations We encourage ODEQ to utilize the full 15% of the settlement funding eligible for public electric vehicle charging throughout the state. This will position the State of Oklahoma to better serve residents and visitors who choose to purchase one of the growing number of electric vehicles. To move Oklahoma forward and proactively prepare for the coming increase in EV and PHEVs, INCOG recommends developing an accessible, user-friendly EV charging network. The network should focus primarily on strategically located DC Fast charging near highway interchanges, and Turnpike travel plazas, at 50-mile intervals, providing easy charging access to EVs traveling longer distances, which will increase as battery ranges get longer and longer. In addition to DC Fast Charging, strategic Level 2 charging at destinations with regional draws should also be considered. For example, Level 2 charging near the Chesapeake and BOK arenas will allow out of town visitors to charge during a concert or event, and have a full charge to drive home without the need to stop at a DC Fast charger. This network will show Oklahoma s commitment to providing EV charging options to customers and visitors who choose to purchase electric vehicles, and enable more Oklahomans to choose electric vehicles when they make their next car purchase. Background Though internal combustion vehicles currently dominate our roads, there is growing evidence to suggest this will not be the case in the coming decades. General Motors believes in an all-electric future. Although that future won t happen overnight, GM is committed to driving increased usage and acceptance of electric vehicles through nocompromise solutions that meet our customers needs. Mark Reuss, GM executive vice president of product development, October Chevy Bolt EV In the next 18 months, GM says, the company will introduce the first two of at least 20 new all-electric vehicles (EVs) planned to launch by In addition, Ford has promised 40% of its fleet will have EV options by 2024, and Volkswagen is planning 30 EVs in its lineup by Volvo pledged to make only electric and hybrid cars after 2019, and Jaguar has made the same promise for In mid-november, Tesla unveiled a prototype for an all-electric semi-truck, with a 500-mile range when fully loaded and traveling highway speeds with a cost per mile that is lower than diesel, and a new version of its classic roadster, now with 600-miles of range at highway speed. Production will begin in 2019 and 2020, respectively. To date, global automakers have announced nearly 150 new EV models. The growing list of bold, transportation electrification plans is not limited to automakers. Several countries are discussing bans on the sale of internal combustion engines. 3 Page INCOG Comments, Appendix A

France and England have set a date for ban implementation of 2040. India is eyeing 2030 for a phase out of gas and diesel powered vehicles.

4 France and England have set a date for ban implementation of India is eyeing 2030 for a phase out of gas and diesel powered vehicles. Germany, China, and the state of California are exploring similar policies with varying dates. With so many of the world s major economies exploring bans on the sale of internal combustion engines and major car manufacturers publicly discussing short and longterm plans moving toward transportation electrification, it is clear that the State of Oklahoma must begin planning for this paradigm shift to ensure residents, customers, and visitors have access and ability to drive across the state using the fuel of their choice. As of September 2017, there are 1,864 EVs registered in Oklahoma, a 40% increase over 2016 figures. EV sales in Oklahoma are projected to grow by at least this rate in the coming years, as well. In fact, the existing preorders of just two of the 15 EV models anticipated to hit the Oklahoma market in 2018 the Tesla Model 3 and the 2018 Nissan LEAF will push Oklahoma s EV growth to 40%. Looking forward, Bloomberg New Energy Finance released its long-term outlook for EVs in July of In their view, EVs will account for all of the growth in global vehicle sales within the next decade. Charging Venues National studies show that 86% of EV charging takes place at home. When considering EV charging needs, it is helpful to regard charging behavior as more similar to powering a smart phone than fueling a traditional gasoline car. To achieve maximum functionality of phones, we charge them when we are at home, typically at night, then they are ready to meet our needs the following day. Sometimes it might be necessary to charge up at work, but for the most part on a typical day, the battery meets daily needs from home 4 Page INCOG Comments, Appendix A

For now, charging batteries takes longer than putting a liquid fuel into a vehicle. A well-designed charging network should consider these factors and plan accordingly.

5 charging. The same is true with electric vehicles: charging overnight at home is the easiest and most cost effective way to operate an EV. What about the other 14% of the time when home charging is not enough? Statistically, privately owned cars are parked 95% of the time. For now, charging batteries takes longer than putting a liquid fuel into a vehicle. A well-designed charging network should consider these factors and plan accordingly. Potential Charging Venues Types of Charging Equipment Charging times, voltage, and equipment cost vary greatly between the different categories of charging. Level 1 is the slowest charging method, followed by medium-speed Level 2, and DC Fast charger, which offer rapid charging. A breakdown is shown below. Siting Considerations Not all types of chargers are appropriate for all locations, and great attention must be paid to many factors when deciding where to install charging equipment. Slower chargers aimed at in-city driving should be placed where cars will likely be parked for significant periods, not following the gas station model of requiring drivers to 5 Page INCOG Comments, Appendix A

travel to a separate location designed for fueling. For example, the most common location for a car to sit for extended periods is at the workplace.

6 travel to a separate location designed for fueling. For example, the most common location for a car to sit for extended periods is at the workplace. New generation EVs have miles of range, and we will begin to see EVs driving farther distances, between regions, and on road trips. There are two strategies which should be employed together to accommodate these EVs. The first strategy is placing Level 2 charging at popular destinations with regional draws. By putting chargers at locations such as zoos, museums, concert venues, and other locations where people already plan to spend a significant amount of time, we can allow people to drive their EVs from neighboring cities, enjoy attractions for several hours while charging their cars, and then leave with a full charge. The second strategy for accommodating longer range EVs is building a strategically located network of DC Fast chargers. These chargers can replenish a battery s charge in minutes, and charging times vary depending on the battery size, power of the charger, and how depleted the battery is when plugged in. Ideal locations for DC fast chargers have amenities drivers need on a road trip. Locations should be near highways, have easy access to food and bathrooms, be well lit, and generally feel safe and welcoming. In Tulsa, the Tulsa Hills shopping center is a good fit for DC Fast Charging. With good lighting, many restaurants, easy access to US Highway 75, close proximity to I-44 and the Creek Turnpike, Tulsa Hills provides the accessibility and amenities drivers want. In the map above, areas highlighted in red indicate highway accessibility and concentrations of through traffic in the Tulsa Transportation Management Area. 6 Page INCOG Comments, Appendix A

Potential Charging Sites In 2016 INCOG and ACOG, with support from ODOT submitted a request to USDOT for all Interstates in Oklahoma to receive designation as Alternative Fuel Corridors.

Chrysler Pacifica Plug-In Hybrid In these two plans, extensive planning was done as to potential locations of DC Fast charging stations.

These two documents contain many maps of existing and proposed locations, as well as traffic counts, and Tesla Model 3 detailed route information.

7 Potential Charging Sites In 2016 INCOG and ACOG, with support from ODOT submitted a request to USDOT for all Interstates in Oklahoma to receive designation as Alternative Fuel Corridors. This request was accepted, and in November 2017 INCOG, with support from ODOT, submitted a request for US Highways 75, 69 and 412 to receive the same designation. Chrysler Pacifica Plug-In Hybrid In these two plans, extensive planning was done as to potential locations of DC Fast charging stations. A map of possible locations for eastern Oklahoma, submitted to USDOT in the 2017 nomination, is below. These two documents contain many maps of existing and proposed locations, as well as traffic counts, and Tesla Model 3 detailed route information. These documents can be provided to ODEQ as additional resources upon request. The 2016 designation of I-44, I-40, and I-35, along with the anticipated 2018 designations of US-75, US, 69, and US-412 emphasizes their strategic importance not only to the Oklahomans who live along these routes, but also to people and business across the United States who rely on them for travel to Oklahoma and throughout the region. Therefore, INCOG recommends that these routes be prioritized for EV charging, and that ODEQ works with ODOT to ensure proper signage denotes these routes. 7 Page INCOG Comments, Appendix A

8 Considerations EV charging is an evolving technology. It is imperative that Oklahoma look to more experienced states with EV charging to ensure we do not repeat mistakes. Lessons learned in other areas include: Work with the local utility from the beginning of the project. o Prior to deciding on a location, contact the utility to check power supply. Choosing a site with inadequate power supply can exponentially increase the installation costs. o Ask the utilities to take on the installation costs and allow settlement funding to pay for the charging equipment. DC Fast chargers should accommodate as 2-3 charging standards if possible, as manufacturers have not yet arrived at a standard plug type. To the greatest extent possible, equipment should be selected which is somewhat future proof. Charging equipment is currently available which can charge today s cars at kwh, but also has the capacity to be upgraded as needed to accommodate the cars in the next few years which will be able to accept charges at much higher rates. Credit card and ongoing networking fees have taken many charging station hosts by surprise. Pricing charts are available for reference in the Appendix. o Particularly with Level 2 charging, adding the ability for customers to pay for charging can sometimes cost more than can be recovered in the near term through payment for charging services. o State regulations have not yet been updated allowing the resale of electricity by non-utilities. There are ways to work around such regulations, and many are employed successfully in other states, but none have yet been tried in Oklahoma. Because of this, many charging hosts are opting to install less expensive chargers and give away the electricity for free. In Tulsa, the commercial electricity rate is approximately $0.06 per kwh, so to completely charge the 60 kwh battery of a Chevy Bolt would cost $3.60. If you have a controlled access parking facility, consider pricing spaces with charging access at a slightly higher cost and requiring a special permit to use them. This keeps overhead low, and provides a method of electrical cost recovery. In the same way any driver can drive up to any gasoline pump, insert their credit card, and buy gas, EV refueling should be relatively seamless to the consumer. Some charging networks require users to register as customers of the utility serving the station. Others require a variety of proprietary apps or RFID cards to utilize different brands of chargers. These steps are cumbersome and add confusion to the process. To the greatest extent possible, steps should be taken to reduce these barriers and make charging as easy as filling up with gas. Any charging infrastructure installed should also include a commitment from the charging host to reserve the associated parking spaces exclusively for EV charging, 8 Page INCOG Comments, Appendix A

9 with non-evs subject to towing. All too often EV drivers are left stranded because non-evs block the chargers. Project budgets should encourage inclusion funds for signage and/or painting the parking spots to note their use for EV charging. Ideal locations for DC fast chargers have amenities drivers want on road trips. Locations should be near highways, have easy access to food and bathrooms, be well lit, and generally feel safe and welcoming. Ensure maintenance contracts are in place before project completion to minimize equipment downtime. Cooperative purchasing agreements can significantly reduce the cost of charging equipment. Resources such as the Fleets for the Future program through the National Joint Powers Alliance should be considered to reduce the purchase price of equipment. Consider maximizing accessibility when siting stations. A well-sited charging station can serve multiple parking spaces. See the following illustrations. DC Fast Charging Standards, and Car Manufacturers Utilizing Each Source: ABB 9 Page INCOG Comments, Appendix A

10 10 Page INCOG Comments, Appendix A

11 11 Page INCOG Comments, Appendix A

12 Sample Equipment Vendor Costs The list below of charging equipment manufacturers is not exhaustive, nor does it constitute an endorsement of any brand. Pricing is included to provide a range of price points for reference and planning purposes. Pricing was obtained in fall of 2016, and is subject to change. Installation costs listed here are estimates based on best-case scenarios. Costs will be much higher if electrical supply upgrades are necessary. Level 2 Charging Equipment Vendor Price Comparison Vendor Equipment Cost Delivery Installation Cost (Estimate) Total Upfront Cost BTCP $3,600 $3,500 $125 $7,225 ChargePoint $7,210 $4,000 $100 $11,310 Clipper Creek $1,075 $2,500 $100 $3,675 EFACEC $4,812 $4,000 $100 $8,912 Telefonix $1,795 $2,000 $100 $3,895 Level 2 Ongoing Optional Maintenance & Operational Cost Comparison, by Vendor Vendor Optional Extended Warranty Maintenance Contract Charger Networking Fees Credit Card Networking Fees Total Optional Annual Fees Per Unit BTCP $360 $384 $480 $1,224 ChargePoint $645 $280 $925 Clipper Creek n/a minimal, tbd n/a minimal, tbd EFACEC 2 yrs. included tbd $240 $240+ Telefonix n/a minimal, tbd n/a minimal, tbd DC Fast Charging Equipment Vendor Price Comparison Vendor Equipment Cost Delivery Installation Cost (Estimate) Total Upfront Cost ABB $35,000 $10,000 $795 $45,795 BTCP $23,500 $5,000 $600 $34,100 EFACEC $25,683 $15,000 $600 $41,283 DC Fast Ongoing Optional Maintenance & Operational Cost Comparison, by Vendor Vendor Optional Extended Warranty Maintenance Contract Charger Networking Fees Credit Card Networking Fees Total Optional Annual Fees Per Unit ABB $2,610 $2,880 $480 $480 $3,840 BTCP $2,820 $504 $215 $3,539 2 yrs. EFACEC tbd $240 $240+ included 12 Page INCOG Comments, Appendix A

RE: Comments on Proposed Mitigation Plan for the Volkswagen Environmental Mitigation Trust

May 24, 2018 Oklahoma Department of Environmental Quality Air Quality Division P.O. Box 1677 Oklahoma City, OK 73101-1677 RE: Comments on Proposed Mitigation Plan for the Volkswagen Environmental Mitigation