APPA Offers Recommendations To Department of Transportation On EV Issues

February 10, 2022

by Paul Ciampoli
APPA News Director
February 10, 2022

In comments filed with the Department of Transportation (DOT) on electric vehicles (EVs), the American Public Power Association (APPA) recommends that stakeholders talk to utilities early about connecting to the grid so that utilities can plan for new load and urged the DOT to provide clear guidance and definitions on what it means to be a rural, underserved, or disadvantaged community.

APPA’s comments came in response to an RFI published on Nov. 29, 2021 by the DOT, in response to the Infrastructure Investment and Jobs Act’s directive to develop guidance for two programs:

  • National Electric Vehicle Formula Program: $5 billion in funding to states to strategically deploy electric vehicle (EV) charging infrastructure
  • Charging and Fueling Infrastructure Program: $2.5 billion competitive discretionary grant program to deploy public EV charging infrastructure, hydrogen, propane, and natural gas fueling infrastructure

In each of its responses to questions or topics included in the RFI, APPA includes a number of specific public power utility examples tied to the specific question or topic.

With respect to APPA’s recommendation that stakeholders talk to utilities early about connecting to the grid, APPA said the utility can educate stakeholders on processes, timeframes, rate options, incentives, pilot programs, and any other relevant offerings. Utilities can provide technical expertise and help with future proofing charging infrastructure assets, APPA said. 

“Reliable electric service remains the key goal for utilities as EV deployment increases. Utility and stakeholder EV charging discussions gives the utility visibility into a stakeholder’s transportation electrification goals and plans. This helps utilities conduct load forecasting and determine grid impacts, particularly at the distribution level,” APPA said.

Over the history of the electric grid, “utilities have continuously adapted to new technologies and load. From electric load growth from the commercialization of air conditioning to large key accounts like data centers moving into a utility’s service territory, the goal of serving customers reliable and affordable electricity has remained paramount.” 

Public power utilities are monitoring EV adoption trends, conducting load forecasting, and studying charging behavior to determine grid impacts, APPA noted.

Some public power electric utilities are exploring active managed charging, where vehicle charging is controlled, while others are piloting or implementing passive managed charging practices, such as time-of-use (TOU) rates and bill credits for off-peak charging. Electric rates are designed to fit local conditions and may reflect times of excess solar or wind capacity.  

EV Charging Infrastructure In Rural corridors And Underserved Or Disadvantaged Communities

Equity is embedded within the public power business model, APPA said. Public power electric utilities are not-for profit and have an obligation to serve their local communities.

“Numerous public power systems serve disadvantaged, underserved, and rural communities. Level 2 and Fast Charging infrastructure in these communities is important to ensuring equity in transportation electrification. EV adoption is traditionally lower in these communities, which can make the business case for charging infrastructure deployment without incentives more difficult. In rural areas, fast charging stations will be crucial to help EV drivers travel across longer distances.”

 APPA recommends that DOT provide clear guidance and definitions on what it means to be a rural, underserved, or disadvantaged community. Utilities would also benefit from federal technical assistance, tools, and resources to help identify these populations within their communities, it said. 

 Public power utilities have initiated various programs to support equitable EV adoption including deployment of charging in underserved areas such as in multiunit dwellings, incentives for low to moderate-income customers, educational offerings, and working with fleet operators such as public transit and ride sharing companies who may serve or be operated by underserved communities. 

Existing EV Charging Infrastructure Programs And Incentives

 Meanwhile, APPA said that public power utilities are developing a range of programs to support EV infrastructure within their community, covering areas such as education/awareness, charging infrastructure deployment, EV fleets, EV rates and incentives. 

 “EV knowledge and awareness remains a barrier in advancing the EV market, so public power utilities are helping educate their communities about EVs and charging infrastructure. Information is disseminated via utility websites, social media, newsletters, and in-person events like ride-and-drives. As trusted energy advisors within their communities, public power utilities have a unique opportunity to educate customers about the benefits of EVs.”

Range anxiety remains another obstacle to EV adoption, so public power utilities are supporting charging infrastructure deployment. This can span from owning and operating charging stations, to building make-ready infrastructure, to providing incentives for charging infrastructure for residential and commercial customers, DOT was told.

Public power utilities are also looking to lead by example and deploy EVs within their own vehicle fleets. This helps increase awareness of EVs within the community and provides utilities with first-hand experience with the technology. “Our members also serve as an advisor to fleet operators, helping advance charging infrastructure deployment within their communities.“

EV rates are another element of numerous public power EV programs. A range of designs have been implemented including TOU, subscription pricing, rate discounts, and off-peak bill credits to EV customers. These specialized offerings can help incentivize EVs, save EV drivers money, and help utilities manage load by encouraging off-peak charging. Ratemaking at public power utilities is conducted in an open and transparent manner and is subject to approval by the utility’s governing body, APPA said.

Fostering Enhanced, Coordinated, Public-Private Or Private Investment In EV Charging Infrastructure

APPA said that utilities should be a part of the discussion early and often for charging infrastructure projects no matter the role of the utility. “This engagement will allow public power utilities to plan for future load and any upgrades as well as provide crucial advice on how to deploy this infrastructure.”

Utilities can help size transformers, advise on electrical service upgrades, rate design, demand side management, and navigating this emerging technology and DOT should not limit project eligibility based on charging infrastructure ownership model. Utilities should be allowed to own and operate charging infrastructure, the trade group said in its comments.

Grant Programs

APPA also addressed the topic of administering competitive grants under the Charging and Fueling Infrastructure Program for corridor and community charging.

It said that grant programs should be designed with flexibility in mind and that grant administrators should ensure that grants and funding opportunities are available to all those willing – including public power.

APPA also argued that federal agencies, like the U.S. Department of Energy and DOT should provide technical assistance and share best practices among stakeholders.

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