New York regulators extend comment period on electric vehicle whitepaper

Staff noted that a key goal of its proposal is to accelerate the development of charging infrastructure needed to support the expected EV growth through 2025, to coincide with New York’s goal of deploying 850,000 zero emission vehicles by that year

The New York State Public Service Commission, in a notice issued on March 30, said that the comment period on the state “Department of Public Service Staff Whitepaper Regarding Electric Vehicle Supply Equipment and Infrastructure Deployment” filed in January is extended, such that initial comments are sought by April 27, with reply comments requested by May 11.

As noted in the whitepaper, staff recommends that the commission establish a statewide “Make-Ready Program” that would provide incentives to light duty electric vehicle supply equipment and infrastructure (EVSE&I) for “Level 2” and direct current fast charger (DCFC) stations.

As noted in the filing, existing Level 2 stations provide 3.3 kW-20 kW charging levels, and some stations are networked, meaning they connect to a back-office network via an internet connection in order to facilitate communicating with the station, transmitting data, and processing payments.

The Make-Ready Program would improve electric vehicle (EV) charging station economics by covering up to 90% of the costs to “make-ready” a site for EV charging, staff said, noting that those costs currently present an economic barrier to EV charging station developers.

Staff noted that it also proposes that the state’s investor-owned electric utilities — referred to as the joint utilities — be required to incorporate EV charging scenarios into their annual capital planning processes, referred to as the EV Charging Infrastructure Forecast, to encourage thoughtful siting of charging infrastructure.

Staff said that its proposal would serve the state well by encouraging accelerated, forward-thinking development of charging infrastructure that is expected to provide New Yorkers with more than $2.6bn in net benefits and provide support for the achievement of the state’s transportation electrification and clean energy goals.

Staff noted that a key goal of its proposal is to accelerate the development of charging infrastructure needed to support the expected EV growth through 2025, to coincide with New York’s goal of deploying 850,000 zero emission vehicles (ZEVs) by that year. The infrastructure required to “make-ready” a site for EV charging is a significant upfront investment for developers, staff said. Noting the low penetration of EVs on the road today, staff said that it is difficult to recoup installation costs from charging revenues due to low station utilization.

A typical DCFC station in New York is not expected to be profitable over the initial 10-year period of operations, barring utility investment in make-ready or another incentive source, given current station economics, staff said.

“By stimulating station development now and assuaging range anxiety, drivers will be more likely to transition to EVs early, accelerating achievement of the state’s goals and realizing the benefits associated with EVs,” staff said. “DPS staff expects that improved charging station economics driven by increased utilization would support stepping down the incentive levels periodically during the Make-Ready Program, and the program would serve as an effective bridge to a fully self-sustained EVSE&I market.”

Staff said that its proposed Make-Ready Program would offer an incentive payment to cover a percentage of the costs to make-ready infrastructure for new Level 2 and DCFC stations that are publicly accessible, meaning without access fees or restricted access. Staff noted that the Make-Ready Program would require the developer to oversize all components that may be future-proofed with minimal incremental cost to accommodate upgrades to the quantity or charging capacity of chargers at the station as EV standards and penetration levels change and increase over time.

Level 2 stations using the standard Society of Automotive Engineers (SAE) Electric Vehicle Conductive Charge Coupler J1772 (SAE J plug) would be eligible to receive 90% of the average utility service territory make-ready cost if all eligibility criteria are met, or 50% of the average utility service territory make-ready cost if the station does not meet the accessibility criteria.

Staff added that standardized, non-proprietary DCFC plug types would be eligible for 90% of the average utility service territory make-ready cost if all eligibility criteria are met, while non-standard plug types would receive 50% of the average utility service territory make-ready cost.

As a result of the Make-Ready Program, stations developed in the first year are expected to have a positive 10-year net present value (NPV) for all regions and DCFC site configurations, except for the larger 150-kW DCFC stations located in Upstate New York, staff said. Given that highly visible and publicly accessible infrastructure plays a vital role in assuaging range anxiety, staff said that it proposes that the seven Upstate Regional Economic Development Councils (REDCs) be designated as “strategic locations,” eligible for limited additional incentives. Staff added that it recommends that at least four locations with four 150-kW DCFC plugs at each site should be developed in each Upstate REDC through a competitive procurement in the first year of the Make-Ready Program to develop a minimum DCFC network to enable travel in Upstate New York and encourage EV adoption.