John Warren
Director, Department of Mines, Minerals and Energy
3405 Mountain Empire Road
Big Stone Gap, Virginia 24219

August 24, 2018

Re: Greenlots Comments on the 2018 Virginia Energy Plan

Dear Director Warren,

Greenlots appreciates the opportunity to provide the Department of Mines, Minerals and Energy (DMME) with comments for consideration in the 2018 Virginia Energy Plan.

Greenlots is a leading provider of electric vehicle (EV) charging software and services. The Greenlots network supports a significant percentage of the DC fast charging infrastructure in North America, and an increasing percentage of the Level 2 infrastructure. Greenlots’ smart charging solutions are built around an open standards-based focus on future-proofing while helping site hosts, utilities, and grid operators manage dynamic EV charging loads and respond to local and system conditions. Greenlots leverages numerous partnerships to achieve successful EV charging solutions across the country, and our network supports Electrify America’s nationwide fast-charging network that will soon be in accessible for EV drivers in the Commonwealth. 

Greenlots supports the direction of the 2014 Virginia Energy Plan to increase EV adoption and availability of EV charging infrastructure; however, we wish to encourage DMME to be appropriately aggressive, rather than just supporting incremental growth. Given this, we believe that there is ample opportunity for DMME to outline policy in the 2018 Energy Plan that can help encourage utility engagement in EV charging programs, incentivize the purchase of EVs, create a statewide network of infrastructure, and develop electrification opportunities for medium and heavy-duty vehicles at a scale that will move the market forward and provide significant economic benefits to Virginians.

Create a regulatory pathway for Virginia utilities in EV charging. At this stage of the market ownership, operation, and management of charging infrastructure – including charging stations – is an appropriate and in many respects necessary role for utilities, who are well positioned to steward and maintain infrastructure, and can be financially incentivized to ensure the ongoing operation of charging infrastructure. Leveraging the full assets and capabilities of utilities to accelerate transportation electrification can better ensure that ratepayers are able to benefit from the cost savings. Utility involvement could include the deployment of charging infrastructure programs across a service territory, the development of rates that send more accurate price signals to EV drivers, the integration of EV loads into the grid through managed charging systems, and planning infrastructure investments based on knowledge of where, when, and how EV loads interact with distribution infrastructure. 

The State Corporation Commission (SCC) should be encouraged in the Energy Plan to take a lead in establishing enabling regulations for utilities to deploy EV charging infrastructure. Commissioners should consider the grid and ratepayer benefits of EVs, encouraging a variety of programs, including networked and smart EV chargers. This enabling regulation represents an initial step in the participation of the utilities in transportation electrification. 

Provide financial incentives for EVs. To accelerate transportation electrification, policymakers should provide incentives for the purchase and lease of eligible EV makes and models.  Incentives, such as the previously introduced tax rebate (House Bill 469), are extremely effective in supporting EV adoption, and EV sales are almost double in states that provide incentives  Although House Bill 469 (which would have allowed a 10% state tax rebate on the purchase of an EV) was passed indefinitely, this is the type of approach that could create a real pathway forward for EV adoption in the Commonwealth.

Incentives applied at the point of sale are particularly enticing, allowing dealers to effectively lower the sticker price of these vehicles. These could decline over time and can be coupled with existing exemptions and incentives. The applicability of various potential revenue sources, such as transit funds and revenue from carbon regulations, should be considered.  

Create a statewide EV charging infrastructure plan. The development of a statewide infrastructure plan, as the basis for identification of key sites or jurisdictions for EV charging, can help facilitate the build-out of a comprehensive network that reduces range anxiety and provides drivers with publicly accessible infrastructure. The 2014 Virginia Energy Plan introduced a high-level infrastructure assessment, and we encourage studies to go deeper and identify optimal locations for new charging stations, corridor charging routes for long-distance and interstate travel, opportunities to support shared-use mobility, and connect with key stakeholders like local governments. This infrastructure assessment can help align future investments with the Commonwealth’s $14 million EV charging spend from the Volkswagen settlement, as well as Electrify America’s network of high-powered DC fast chargers.  

Set state EV targets and adopt the ZEV mandate. California’s Zero Emissions Vehicle (ZEV) mandate has been adopted by 9 other states, and Virginia should consider adopting the mandate to encourage the deployment of more EV makes and models in Virginia. According to a study released by EDF, because of the economic, environmental, and health benefits – the net costs to implement the ZEV mandate in states would be negative. In addition to adopting the ZEV mandate, the Commonwealth should set EV registration targets, including for light-, medium-, and heavy-duty vehicles. This can help guide the execution and implementation of other strategies that can help further transportation electrification.  If short of a ZEV mandate, a useful approach is establishing an EV and infrastructure roadmap with specific temporal targets.

Invest in the electrification of medium and heavy-duty vehicles. Medium and heavy-duty vehicles, particularly those incorporated into broader fleets, are ripe for electrification. While electric transit, shuttle, and school buses currently have higher upfront costs, they have total cost of ownership savings, have reduced fuel and maintenance costs, a longer vehicle lifespan, greater potential to reduce criteria air pollutants and greenhouse gases, and provide health benefits for workers, schoolchildren, and community members. For example, the electrification of port equipment at Hampton Roads (e.g., port drayage trucks, shuttle buses, gantry cranes, as well as the use of on-shore power for docked vessels) can yield cost savings, minimize local air quality impacts, and improve efficiency of port operations. These shifts in fleet purchasing behavior, from diesel to electric vehicles, can be enabled through state purchasing contracts for the vehicles and associated charging infrastructure. Statewide voucher programs that reduce the upfront vehicle costs have proven particularly effective in California and New York and should be evaluated for the Commonwealth.

Investments in electric transit, school buses, port drayage trucks, and other heavy-duty vehicles can provide direct benefits to populations that may not directly benefit from home EV charging or light duty vehicle electrification, including in lower income, disadvantaged, and environmental justice communities. Electrification provides public health and social welfare benefits for transportation users and children, equipment operators and port employees, and for many surrounding communities – many of which tend to bear a disproportionate share of pollution (e.g., NOx, SOx, PM). 

DMME has an opportunity to outline a transformative strategy through the 2018 Virginia Energy Plan. A strong emphasis on policies that will advance transportation electrification will not only reduce the reliance on imported fossil fuels, but also increase the use of in-state electricity – providing substantial economic benefits that can be realized across all communities of the state. The policies identified herein can help lower the barriers for transportation electrification and ensure that EVs benefit all Virginians. 

Thank you for your consideration. Greenlots will be available as a resource to DMME through the finalization and implementation of the 2018 Virginia Energy Plan. Please do not hesitate to contact me should you have any questions.

Sincerely,

Thomas Ashley
VP, Policy
Greenlots
tom@greenlots.com