In the recent make ready order for the light duty vehicles CASE 18-E-0138, New York. Public service commission allowed Future proofing of the EV make ready infrastructure. The Commission directs that no more than eight percent of each utility’s overall Make-Ready Program budget be spent on future-proofing costs.

Vrinda, Inc. (Vrinda) argues that the Commission should make it mandatory for the utilities and developers to pair storage with charging stations as a requirement of futureproofing, to support de-carbonization, address congestion, and eliminate the need for costly upgrades which may get stranded in the future as EV utilization and ranges change.

Key question is should commission allow or disallow and set limits on future proofing?

While it is understood that there is a need to be prudent, but it should be left to the utilities and customer to decide what is reasonable future proofing and cost share. Future proofing is a feature desired by sight host who sees potential for expansion. Utility can finance such cost and defer recovery but should not be required to pay for this business risk unique to site hosts.

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New York State Department of Public Service in its latest order rightly identified need for Medium and Heavy duty (MD/HD) vehicle electrification. But efforts need to be accelerated given disproportionate impact of truck and other MD/HD vehicle led pollution in Low and Medium Income communities. More than 200 warehouses and depots are located in Bronx, Queens and Brooklyn areas with poverty levels of around 20% or more.

NYSERDA has committed $20 million Prize for Medium and Heavy Duty innovation and another $40 million for LMI/EJ community centered innovation.

Following are some key elements.

  • The Medium- and Heavy-Duty Fleet Make-Ready Pilot Program in Con Edison’s service territory shall mimic the “Fleet DC Fast Charger Make-Ready Program” approved in their most recent major rate filing.

  • Con Edison shall implement the Fleet DC Fast Charger Make-Ready Program eligibility and program rules and provide $9 million in total budget

  • O&R to develop Program Implementation Plans in consultation with Staff and in accordance with the program elements outlined below, to be filed within 90 days of issuance of this Order.

  • Participants in the Medium- and Heavy-Duty Fleet Make- Ready Pilot Program that purchase the vehicle through NYSERDA’s Truck Voucher Incentive Program will receive up to 90 percent of the utility-side make-ready infrastructure upgrade costs.

  • Program in EJ/LMI of particular interest

  • ConEd to conduct survey of their fleet DC fast charger program participants

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In the nascent stage of EV market, regulators and policy makers should not restrict new business models.

Let utilities demonstrate business models of ownership where they will always have role. Don't forget majority of small customers choose standard offer for their electricity services today!

California, Virginia, Colorado have allowed some form of ownership of EV chargers by the utility. In California pilots San Diego Gas and Electric proposed to own chargers, In Virginia, Dominion is not only owning chargers but paying for the school bus (Difference between Diesel and electric).

Colorado Xcel has a more refined approach, they are offering customer choice to either build their own chargers or as Xcel to build for them.

Many people have argued that utilities want to grab charging business, they want to control behind customers meters. We wish this was true, in our interactions we found that utilities are reluctant to go beyond customers meters and risking loosing customers. However, they also understand that the role a utility can play to bring new technology and business models to the market. One thing we all can agree that in order to develop competitive markets, we can not shut off biggest market participant and hope that by magic, small bootstrapped companies will be able to innovate. In fact most of the charger providers/ developers are banking on 100% government handouts in the form of make ready incentives, rebates and favorable permitting and siting. In this scenario one can ask " where is the skin in the game from the private sector?"

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