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EV Charger Deployment Standards

On June 9, 2022, FHWA announced a Notice of Proposed Rulemaking (NPRM) for proposed minimum standards and requirements for projects funded under the National Electric Vehicle Infrastructure (NEVI) Formula Program and projects for the construction of publicly accessible electric vehicle chargers funded under title 23, United States Code. FHWA also released additional resources to help states successfully complete their deployment plans and access NEVI Formula Program funding to build out a national network of electric vehicle chargers. These resources include new NEVI Formula Program Questions and Answers and an exception template to help states, particularly rural states, evaluate the best locations for charging stations when it may not be possible to provide charging stations at the required 50-mile intervals.

The deadline for comments will be 60 days following publication in the Federal Register.

DOE V2X MOU

On April 21, 2022, the Department of Energy (DOE) announced the signing of a Vehicle to Everything (V2X) Memorandum of Understanding (MOU) which is intended to bring together cutting-edge resources from DOE, DOE national labs, state and local governments, utilities, and private entities to evaluate technical and economic feasibility as we integrate bidirectional charging into energy infrastructure. The MOU is also intended to advance cybersecurity as a core component of V2X charging infrastructure.

According to DOE, bidirectional plug-in electric vehicles (PEVs) present immense potential for increasing the country's energy security, resilience, economic vitality, and quality of life while supporting the electrical grid. A bidirectional EV fleet could serve as both a sustainable mobility option as well as an energy storage asset that sends power back to everything from critical loads and homes to the grid. A bidirectional fleet could also create new revenue opportunities for EV owners or fleets.

DOE also announced that it will tackle the technical challenges and barriers to the integration of tens of millions of EVs with the electric grid, commonly referred to as Vehicle Grid Integration (VGI) through the EVs@scale lab consortium, which brings together six DOE national laboratories to conduct RD&D in the areas of Smart Charge Management, High Power Charging and Facilities, dynamic Wireless Charging, Codes and Standards, and Cyber Physical Security. In addition to addressing the near-term challenges to VGI to benefit all EV stakeholders, the Lab Consortium will conduct high risk, high reward research on the EV charging and grid integration technologies the U.S. will need in the future.

This collaboration can accelerate and enable bidirectional PEV integration into the electrical grid by identifying and resolving barriers, accelerating commercialization and customer adoption, factoring in security by design, and improving coordination between the electric and automotive sectors through establishing cybersecure bidirectional charging station demonstrations, collecting and analyzing demonstration data, and preparing technoeconomic analyses to evaluate the business case for V2X.

Participants in the V2X MOU include DOE’s Offices of Vehicle Technologies, Electricity, Technology Transitions, and Cybersecurity, Energy Security, and Emergency Response, as well as The California Energy Commission, The California Public Utilities Commission, The City of Lancaster and City of Lancaster Community Choice Aggregator, The City of Los Angeles, Fermata Energy, First Student, Ford Motor Company, General Motors LLC, International Brotherhood of Electrical Workers– Chapter 11, Lion Electric Inc., Los Angeles Department of Water and Power, Lucid Group, Inc. (Lucid Motors), the National Electrical Contractors Association – Los Angeles, Nissan, Nuvve Holding Corp., Pacific Gas and Electric Company, Rhombus, Sacramento Municipal Utility District, San Diego Gas & Electric, Southern California Edison, and Zeem Solutions.

A copy of the complete Memorandum of Understanding can be found here.

The Securing America’s Clean Fuels Infrastructure Act

On March 25, 2021, Senator Tom Carper (D-Del.), Chairman of the Environment and Public Works Committee (EPW), Debbie Stabenow (D-Mich.) and others introduced legislation (S.975) to promote investments in clean vehicle infrastructure, such as electric vehicle charging stations and hydrogen refueling stations for fuel cell vehicles.

The Securing America’s Clean Fuels Infrastructure Act would improve and expand the Alternative Fuel Vehicle Refueling Property Investment Tax Credit (ITC), commonly referred to as “30C,” lowering costs for clean vehicle infrastructure deployment. Providing incentives to build the needed infrastructure to support clean vehicles, the legislation will support American consumers as they move towards more electric and clean energy vehicles.

According to the Sen. Carper, the current 30C ITC structure isn’t adequate for encouraging greater private investments in clean vehicle refueling infrastructure like electric charging stations and hydrogen refueling stations. If implemented, Securing America’s Clean Fuels Infrastructure Act would do three things:

1. Clearly state that the 30C ITC can be applied to each item of refueling property (i.e., each charger) rather than per location.

2. Increase the 30C ITC cap for business investments from $30,000 to $200,000 for each item of refueling property.

3. Extend the 30C ITC tax credit for eight more years from the December 31, 2021 expiration date, which means the 30C ITC would apply to refueling property that is placed in service by December 31, 2029.

The full text of the bill can be found here.

This legislation has broad support from the auto companies, environmental community, and industry stakeholders, including Ford, Honda, General Motors, Volkswagen, Alliance for Automotive Innovation, Electric Drive Transportation Association, the Fuel Cell and Hydrogen Energy Association, Zero Emission Transportation Association, Electrify America, EVGO, Environmental Defense Fund, National Wildlife Federation, Natural Resources Defense Council, Sierra Club, American Lung Association, Clean Air Task Force, Union of Concerned Scientists, Stellantis, Duke Energy, Volta Charging, ChargePoint, EV Box Group, and ABB.

GREEN Act of 2021

On Feb. 4, 2021, Rep. Mike Thompson (D-CA) introduced the GREEN Act of 2021 (H.R. 848).  Main features of the legislation are as follows:

• Builds on current successful tax incentives that promote the deployment of green energy technologies, while providing new incentives for activities that reduce greenhouse gas emissions,
• Encourages residential investments in green energy and energy efficiency,
• Expands incentives for energy efficiency and conservation in homes and buildings, with updated standards,
• Supports widespread adoption of zero-emission cars, vans, and buses through tax credits for purchasing vehicles, and supporting deployment of publicly accessible electric vehicle charging infrastructure,
• Invests in the green workforce by providing tax credits for advanced manufacturing facilities and mechanical insulation installations,
• Advances environmental justice using tax credits for research and other academic programs, and
• Prices greenhouse gas emissions.

Specifically with regard to EVs, the bill would expand the qualified plug-in electric drive motor vehicle credit under Section 30D to apply a new transition period for vehicle sales of a manufacturer between 200,000 and 600,000 electric vehicles (EVs), under which the credit is reduced by $500. The provision replaces the current phaseout period (which begins at 200,000 vehicles) with a phaseout period that instead begins during the second calendar quarter after the 600,000-vehicle threshold is reached. At the start of the new phaseout period, the credit is reduced by 50% for one quarter and terminates thereafter. For manufacturers that pass the 200,000-vehicle threshold before the enactment of this bill, the number of vehicles sold in between 200,000 and those sold on the date of enactment are excluded to determine when the 600,000-vehicle threshold is reached. The provision extends the 2-wheeled plug-in electric vehicle credit through 2026. It also extends the 3-wheeled plug-in electric vehicle credit through 2026.

For used EVs, the bill creates a new refundable credit for buyers of used plug-in electric cars from date of enactment through 2026. Buyers would be able to claim a base credit of $1,250 for the purchase of qualifying used EVs, with additional incentives for battery capacity. The credit is capped at the lesser of $2,500 credit or 30% of the sale price. To qualify for this credit, used EVs must generally meet the eligibility requirements in the existing Section 30D credit for new EVs, not exceed a sale price of $25,000, and be a model year that is at least two years earlier than the date of sale. Buyers with up to $30,000 ($60,000 for married couples filing jointly) in adjusted gross income can claim the full amount of the credit. The credit phases out so that buyers with below $40,000 ($70,000 for married couples filing a joint return) in AGI may be eligible for a reduced credit. Buyers must purchase the vehicle from a dealership for personal use and cannot claim the credit more than once every three years. The credit only applies to the first resale of a used EV and includes restrictions on sales between related parties.

With regard to heavy vehicles, the bill includes a manufacturer credit for the sale of zero-emission heavy vehicles starting after the date of enactment through the end of 2026. Eligible manufacturers may claim a credit of 10% of the sale price of an eligible vehicle, capped at a credit of $100,000 per sale. To be eligible, vehicles must be for domestic use, must weigh no less than 14,000 pounds, must not include an internal combustion engine, and must be propelled solely by an electric motor which draws electricity from a battery or fuel cell.

Regarding fuel cell vehicles, the bill would extend the credit for the purchase of a qualified fuel cell motor vehicle through 2026.

Regarding refueling infrastructure, the bill calls for extending the alternative fuel vehicle refueling property credit through 2026.  Beginning in 2022, the provision expands the credit for zero-emissions charging infrastructure by allowing a 20% credit for expenses in excess of $100,000 (i.e., it allows a credit for expenses beyond the current limit if certain requirements are met). To qualify for this uncapped credit, the property must: 1) be intended for general public use and either accept credit cards as a form of payment or not charge a fee, or 2) be intended for exclusive use by government or commercial vehicle fleets.

The bill has been referred to the House Committee on Ways and Means.

Full text of the bill is available here and a section-by-section summary is available here.

Regulatory and Legislative Tracking Reports for Vehicle Manufacturers and Suppliers

Since 1999, Kardos & Associates LLC has supplied the auto industry with the most comprehensive regulatory and legislative tracking reports available. We currently offer clients the following:

Motor Vehicle Safety & Emissions Regulatory Update (the REG UPDATE)

The REG UPDATE has been tracking US and Canadian regulatory activity impacting the auto industry for over twenty years. Regulations developed by the NHTSA, FMCSA, EPA, FCC, CARB, Transport Canada, and Environment Canada are the focus. For each rulemaking, the Reg Update provides a description of the rulemaking, comment deadlines, effective dates, a docket reference, and links to documents available online. Deadlines and critical path items are color-coded so that you can quickly identify what’s new and important. In addition to being an excellent tool for tracking regulatory activity, the Reg Update is a great archive of past actions. The report contains information on virtually every rulemaking affecting automakers from the past two decades. Approximately 400 pages in length.

U.S. Safety & Fuel Economy Regulatory & Legislative Update
The U.S. Safety & Fuel Economy Regulatory & Legislative Update provides a snapshot of the past month’s legislative and regulatory activities relating to safety, emissions and fuel economy. The report provides brief summaries of notices issued by DOT, EPA, CARB and others. With regard to federal legislation, the report covers newly introduced bills, information on committee hearings, etc. Activities at the state level pertaining to emerging technologies (e.g., automated vehicles, advance driver assistance systems, EVs and EV infrastructure, etc.) are also covered.

Federal Legislation Tracking Report
Our legislative tracking report focuses on matters relating to environment and energy, safety and fuel economy/climate change. The report covers two years-worth of bills (the length of each Congressional session) and includes summaries and status updates for each tracked bill. Links to bill text and related information are provided.

All of our reports are distributed monthly via email as a PDF. Subscribers also get access to an online archive of past reports.

For pricing, contact Dale Kardos at (202) 3064997 or [email protected]. For more information about Kardos & Associates LLC, see www.kardosllc.com.

For a PDF of this information, click here.

CARB Proposed Advanced Clean Trucks (ACT) Regulation and Draft Environmental Analysis (EA)

On Oct. 22, 2019, CARB released it proposed Advanced Clean Trucks (ACT) Regulation and Draft Environmental Analysis (EA) for public comment.   The proposal, if finalized, would require manufacturers of incomplete or complete vehicles > 8500 lbs GVWR with 500 or more annual sales in CA to begin to electrify their fleets starting in 2024. Fleet compliance percentages vary by year and vehicle class.  By 2030, one out of every two Class 4-8 vehicles will need to be electrified.

The rule will be considered by the Board at a hearing which will take place in Sacramento, CA on Dec. 12, 2019 starting at 9 am (PST).

Written comments on the proposal must be submitted no later than Dec. 9, 2019.

All documents concerning the rulemaking are available online at https://ww2.arb.ca.gov/rulemaking/2019/advancedcleantrucks.

Overcoming Barriers to Deployment of Plug-in Electric Vehicles

On April 22, 2015, the National Academy of Sciences (NAS) released its report, "Overcoming Barriers to Deployment of Plug-in Electric Vehicles (2015).” 

Conducted at the request of Congress, the report recommends the following:

• Reinstate tax and other incentives for electric vehicles (EVs) and other low-emitting sources,
• Continue efforts to cut GHG emissions from the power sector,
• Continue to fund battery research aimed at improving batteries and lowering battery costs.

 Other recommendations in the report include:

• The federal government and states should use their incentives and regulatory powers to (1) eliminate the proliferation of plugs and communication protocols for direct current fast chargers and (2) ensure that all PEV drivers can charge their vehicles and pay at all public charging stations using a universally accepted payment method just as any ICE vehicle can be fueled at any gasoline station.

• To increase consumer information and awareness, the federal government should make use of its Ad Council program, particularly in key geographic markets, to provide accurate information about federal tax credits and other incentives, the value proposition of PEV ownership, and who could usefully own a PEV.

• Federal and state governments should adopt a PEV innovation policy where PEVs remain free from special roadway or registration surcharges for a limited time to encourage their adoption.

• Local governments should streamline permitting and adopt building codes that require new construction to be capable of supporting future charging installations.

• To ensure that adopters of PEVs have incentives to charge vehicles at times when the cost of supplying energy is low, the federal government should propose that state regulatory commissions offer PEV owners the option of purchasing electricity under time-of-use or real-time pricing.

• Federal financial incentives to purchase PEVs should continue to be provided beyond the current production volume limit as manufacturers and consumers experiment with and learn about the new technology. The federal government should re-evaluate the case for incentives after a suitable period, such as five years. Its re-evaluation should consider advancements in vehicle technology and progress in reducing production costs, total costs of ownership, and emissions of PEVs, HEVs, and ICE vehicles.

• The federal government should consider converting the tax credit to a point-of-sale rebate based on information about the effectiveness of incentives.

The report notes that the Committee is not recommending additional direct federal investment in the installation of public charging infrastructure.  Instead, they recommend research on the relationship between charging infrastructure availability and PEV adoption and use.

 

Electric Vehicle Readiness

Last month, the Department of Energy released its Guide to the Lessons Learned from the Clean Cities Community Electric Vehicle Readiness Projects.   This report summarizes the lessons learned from 16 government, educational and nonprofit groups that received grants to advance the deployment of plug-in electric vehicles (PEVs). Participants in projects across 24 states and the District of Columbia assessed the barriers to and opportunities for PEV deployment in their regions and prepared and executed readiness plans. The report is designed to be an accessible primer to the key issues in PEV deployment and a roadmap to the detailed research, toolkits, and sample language for local policies contained in the readiness plans.

Department of Energy Announces New Funding to Advance Plug-in Electric Vehicle Technologies

On March 08, 2013, DOE announced more than $50 million in funding for new projects that will accelerate the development of advanced plug-in electric vehicle (PEV) technologies to increase vehicle fuel economy and improve performance. This new funding supports the Energy Department's EV Everywhere Grand Challenge, which aims to make PEVs as affordable to own and operate as today's gasoline-powered vehicles within the next 10 years, and will help to advance the technology goals outlined in the EV Everywhere Grand Challenge Blueprint.

The Energy Department will select new research projects that focus on lowering the cost and increasing the efficiency of PEV components, as well as the development of models and tools to predict these vehicles' performance and help improve fuel economy. The Department will fund projects across five major areas of research and development that cover 12 areas of interest, including:

• Advanced lightweighting and propulsion materials: Advanced materials are essential to reducing vehicle weight while maintaining performance and safety, especially in PEVs. Projects selected in this area will contribute to research in cast magnesium alloys, high-strength steel, and dissimilar material joining.
• Advanced battery development: Advances in battery technology can result in less expensive, more efficient batteries that can enable greater all-electric range. Projects selected in this area will improve cell chemistry, composition, and processing; contribute to battery modeling; or develop advanced electrolytes for next generation lithium-ion cells.
• Power electronics: Improving power electronics can lower the cost, improve the efficiency, and decrease the weight of electric traction systems in PEVs. Projects selected in this area will develop lower-cost inverters and capacitors that are capable of withstanding much higher temperatures than current technology and can be commercially manufactured.
• Advanced heating, ventilation, and air conditioning systems: Auxiliary loads like heating and cooling have a greater impact on the efficiency of PEVs than conventional vehicles. High efficiency heating and cooling systems can significantly increase all-electric driving range while providing a comfortable temperature for passengers. Projects selected in this area will develop and demonstrate technologies to reduce these auxiliary loads.
• Fuels and lubricants: Fuels and lubricants can increase the efficiency of both future vehicles and those already on the road. Projects selected in this area are expected to improve the fuel efficiency of light-, medium- and heavy-duty vehicles.

The Department will accept applications from industry, national laboratories, and university led-teams to address these challenges and enable technologies that will drive innovation in vehicle design.  For more information, click here.  

Monthly Regulatory & Legislative Tracking Reports Available for 2013 - Sign Up Now!

Since 1995, Dale Kardos & Associates, Inc. (DKA Inc.) has been supplying automakers, automotive suppliers and their trade associations with comprehensive detailed regulatory and legislative tracking reports.  Each month, DKA Inc. publishes the following three related, but uniquely-focused, tracking reports:

The Reg Update

The Reg Update is a monthly report that tracks the status of all North American regulatory activity concerning emissions, fuel economy (CO2) and safety (we track all regulatory actions of NHTSA, EPA, California Air Resources Board, Transport Canada, Environment Canada, and Section 177 States (i.e., states that have adopted CA’s Low Emission Vehicle program rules). For each rulemaking, the Reg Update provides electronic links to the latest official publications and includes information concerning comment period deadlines, anticipated future actions, projected implementation dates, and more.  In print since 1998, the Reg Update also serves as a tremendous archive of past actions. 

U.S. Motor Vehicle Safety and Legislative Update

The U.S. Motor Vehicle Safety & Legislative Update is a monthly report summarizing the past month’s legislative and regulatory activity concerning motor vehicle safety, emissions, and fuel economy/GHG issues.  The report provides brief summaries of and electronic links to key Federal Register notices, Congressional bills, public laws, NHTSA interpretation letters, recall listings, defect reports, NCAP test results, etc.  The report also covers financial incentive program announcements coming out of the Department of Energy, California and elsewhere.

Status of Motor Vehicle Related Legislation in the 113^th Congress

This report is devoted to keeping automakers and supplier up-to-date on the status of all legislation pending in the U.S. Congress that may potentially affect the auto industry.  We cover the introduction of all new bills and track their status over the course of the next two years.  We’ll provide updates on any official new activity related to the bill, increases in sponsorship, etc.  The report typically groups bills into the following categories:  Appropriations, Climate Change/GHG/Environment, Financial Incentive Programs, Biofuels and Flex Fuel Vehicles, Funding for Vehicle Development, Safety, Toxic Chemicals, misc.

 Report samples are available via the links below:

1.  Download REG UPDATE (SAMPLE - DEC 2012)

2. Download US Motor Vehicle Regulatory and Legislative Update (Dec 2012)

3. Download 111TH CONGRESS MOTOR VEHICLE LEGISLATION TRACKING SUMMARY (SAMPLE)

Pricing: The above reports can be purchased individually or at a discount (as a package).  A one year subscription is required (12 monthly updates).  For pricing and/or questions, please send an email to Dale Kardos ([email protected]).