September 16, 2022
Virginia Department of Energy
RE: ChargePoint Comments on the 2022 Virginia Energy Plan
ChargePoint thanks the Virginia Department of Energy for their work to develop a comprehensive Energy Plan (“Plan”). Virginia has been a leader in developing, deploying, and supporting the accelerated adoption of zero emission vehicles (ZEV). We appreciate the opportunity to provide comments.
Since 2007, ChargePoint has created a new fueling network to move all people and goods on electricity. ChargePoint is committed to making it easy for businesses and drivers to go electric, with a world-leading electric vehicle (EV) charging network and a complete set of charging solutions available today. ChargePoint’s cloud subscription platform and software-defined charging hardware are designed internally. They include options for every charging scenario from home and multifamily to the workplace, parking, hospitality, retail, and fleets. There are more than 180,000 ports on the ChargePoint network across North America and Europe and an additional 300,000 ports accessible via roaming agreements.
ChargePoint supports Virginia’s goals to reduce its transportation sector emissions while also providing opportunities for economic growth, employment, and recruitment within the Commonwealth. Within DEQ’s 2018 Greenhouse Gas Inventory, the transportation sector contributed 34% of the Commonwealth’s emissions, transportation electrification is a key factor to reducing transportation sector emissions.
We offer the following comments on the Electric Vehicles and Advanced Technologies section of the Plan. These recommendations were made in relation to the Plan objectives to lower the cost of living, create jobs, bring people to Virginia, and support an encompassing approach to energy policy.
EV Ready Building Codes and Permitting
To support the adoption of EVs, it is critical that drivers have access to convenient places to charge. Most charging occurs at home, and access to home charging is a key factor in determining whether households will adopt an EV as their next vehicle. EV Ready building codes engage new residential, multi-family, and commercial buildings to expand breaker panels, lay conduit, and wire through a raceway to parking spots based on a percentage of parking. This preparation for electric vehicles enables a site to reduce costs, complexity, and disruptive construction by incorporating EV-ready infrastructure at time of construction rather than retrofits.
Numerous studies have been conducted regarding the cost difference between new construction vs. retrofit regarding EV infrastructure. In 2019, ChargePoint and Tesla engaged with the California Electric Transportation Coalition to publish the Plug-In Electric Vehicle Infrastructure Cost Analysis Report, which found that for 10% of spaces at a medium sized office/school parking lot the costs for new construction of EV-capable spaces were $901 vs $4,155 for retrofit construction. In addition to this, the City of Orlando highlighted a local EV-Ready building cost example prior to the passage of the City’s EV-Ready Ordinance in 2021; finding 20% EV-capable and 2% EV-installed contributed to .0009% of total new construction project costs for a 116 unit Affordable Multi-family housing dwelling. ChargePoint urges the inclusion of EV Ready Building Codes within the Plan to address ways to lower costs, increase the availability of EV infrastructure, and provide workforce opportunities to Virginians.
The Commonwealth must also continue work to facilitate expeditious permitting for ZEV infrastructure and work closely with local cities, counties, and utilities throughout Virginia. This work will also benefit the efficient deployment of federal and state infrastructure funds, such as the National Electric Vehicle Infrastructure Program by reducing timelines and project hurdles to EV charger deployment. Best Practices for Electric Vehicle Supply Equipment (EVSE) permitting include:
As the economy transitions to electric mobility, it is crucial to ensure that communities are not left behind in the transition. Lessons learned from broadband buildouts show that it is important to not leave rural communities out of technological advances. ChargePoint supports the build-out of EVSE in rural communities to ensure all Virginians have access to electric mobility. Furthermore, EVSE can be used as a tool to bring revenue to local municipalities by allowing motorists and tourists to charge up while engaging with the communities they are within. Lastly, EVSE installation can be supported by local workforces, presenting an opportunity for legacy workers to transition into clean energy installation and construction. The Virginia Department of Energy should consider how state and utility programs can benefit communities through make-ready and incentive programs that specifically address hurdles rural communities face.
Medium- and Heavy- Duty Fleet
Supporting Medium- and Heavy-duty (MHD) ZEV technology and the necessary infrastructure can reduce the harmful impact conventional commercial vehicles have on our most disadvantaged communities. Charging infrastructure is needed in communities with high concentrations of logistics and delivery hubs that lead to air pollution; along with the locations the MHD vehicles are driving to and from, ensuring they can charge along their route.
Charging infrastructure needs are different for MHD fleets than Light-Duty fleets; this includes the need for “behind-the-fence” charging, higher power (kW) needs, and site design considerations. Grant programs should take note of these differences and incorporate them to encourage fleet eligibility. The Virginia Energy should work in tandem with Virginia Department of Transportation and Virginia Commerce and Trade to identify and utilize federal and state infrastructure funding streams that can promote investments in MHD fleet transitions and fleet infrastructure deployment.
While the Commonwealth has enacted the Advanced Clean Cars program for Light-Duty vehicles, further consideration should be given to adopt the Advanced Clean Trucks (ACT) Rule that focus on Medium- and Heavy-Duty vehicles. In 2020, 15 states and the District of Columbia signed a joint MOU pledging to achieve a 30% heavy duty electric vehicle market penetration by 2030 and 100% market penetration by 2050. Additionally, six of these MOU states have already adopted the ACT standard to set a minimum level of ZEV sales at nearly 20 percent of Class 4-8 sales in model year 2027, nearly 30 percent in model year 2028, and nearly 40 percent in model year 2029. ChargePoint would strongly suggest the Commonwealth adopt ACT to urge a swifter adoption of ZEV vehicles on our highways and aiding in the reduction of NOx, VOC, and GHG emissions from the MHD sector. Based on the adoptions of the ACT plan, manufacturers will be required to sell between 40% and 75% ZEVs to the MHD sector by 2035.
Utility Involvement and Beneficial Rate Design
To ease the transition to electric mobility, prioritizing funding for utility make-ready infrastructure is a key action to addressing one of the most expensive portions of charging infrastructure: the basic electrical wiring and connections required to support the installation of charging infrastructure. These make-ready costs can be a barrier to entry for lower-income drivers and members of disadvantaged communities who often live in multi-unit dwellings. Therefore, we urge the Plan to highlight this opportunity and coordinate with the State Corporate Commission and Virginia Energy to prioritize these utility investments.
Another way to ensure equitable access to EVs and better align the costs of electric “fuel” is through beneficial rate design. One way is to consider time-varying rates; time-of-use rates for EV charging can help align demand with renewable generation, shift charging to off-peak periods, and reduce fuel costs for those who charge off-peak provided that off-peak prices are lower. Another item that can create opportunities for private investment in EVs charging by developers and fleets is demand charge reform. Demand charges can present hurdles to site affordability for fleets and DC fast charger site hosts with potentially large utility bills. Multiple utilities in the United States that have introduced or proposed alternative demand charge rate design that helps support the business case for electrified transportation, and when designed right these rates can balance the utilities cost of service with electrification goals. Dominion Energy has an All-Volumetric Rate below 200kWh per kW (~27% Load Factor) that helps fleets and site hosts find affordability with EVSE deployments. We encourage the Plan to highlight this opportunity and coordinate with the State Corporate Commission and Virginia Energy to enable beneficial rate design.
Site Load and Grid Management
Electric vehicles are projected to have an exponential rise as adoption increases in the United States. Virginia is no different, jumping from approximately 25,000 electric vehicles on the road in 2021 to approximately 44,300 at the beginning of 2022 as shown by Drive Electric Virginia registration data. As EVs grow, so will the need for managed charging habits to better enable grid flexibility and grid reliability.
On a site level, smart networked charging enables load management and power sharing applications to reduce the demand for electrical capacity and peak power at a site. Power coming into the site can be reduced by sharing amperage across a panel, circuit, or facility. Furthermore, power sharing allows a dynamic charging experience that better utilizes the capacity of a site.
At the grid level, electricity demand from EVs can be managed via programs offered by utilities. Some utility companies run demand response programs to defer EV charging electricity usage when demand is high, to times where there is less strain on the grid. In these programs, the utility utilizes the communication capabilities of smart network chargers to send signals directly to the charging to delay or reduce power delivered to a vehicle’s battery. Currently, there are several utilities across the US running such programs like, Green Mountain Power, Xcel Energy, and Portland General Electric. ChargePoint encourages grant and utility programs to proactively think about the benefits of networked charging to enable demand response, power sharing, and load management applications within EVSE programs from the Commonwealth.
We look forward to working with the Commonwealth of Virginia and her various state agencies and stakeholders to implement Virginia’s climate and economic goals.
Public Policy Manager