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Comments for NH PUC Regarding EV Related Policies:

A cutaway of an electric vehicle. Image: Department of Energy.

Randolph Bryan, NH Resident, EV Enthusiast 12 February 2020

The New Hampshire Public Utilities Commission (NH PUC) is soliciting comments on the state’s Electric Vehicle (EV) adoption policies as specified in SB-575-FN, enacted in 2018. Objectives should focus on Rate Design Standards for EV applications and Residential/Commercial Time of Use (ToU) rate offerings for EVs. I offer my comments and suggestions to the NH PUC for consideration. Subject matter references are available upon request.

Background: EVs are now commonly regarded as heir apparent to become the dominant transportation drivetrain. This is predicted to happen relatively quickly (new car sales over 15 to 30 years) due in part to growing immediate need for clean energy solutions, improving cost – capabilities of EVs (battery technology and performance, lower manufacturing cost), and that EVs are substantially lower cost to operate (fuel and maintenance). EV prices have reached initial price parity with internal combustion engine (ICE) vehicles for some cases and will do so across the board by 2025, with most passenger car applications at parity by 2023. Adoption of EVs will likely continue to increase aggressively.

A critical market trend in the U.S. and world markets are growing mandates for substantial and full change away from internal combustion engines (ICE) by dates ranging from 2035 to 2050 (China, UK, Europe, Cal-Zev). The California Zero Emission Vehicle (CAL-ZEV) mandate states (including all New England except NH) have adopted ever stricter change schedules and incentivizing policies with commensurate success in change achievement. This is our immediate neighborhood and NH’s policies can’t afford to be left behind (attractiveness for business and tourism).

All the major car manufacturers are now committed to change most or all of their drivetrains to electric over the coming 10 to 20 years (notably Volkswagen and GM, with Ford, Toyota, BMW, and Nissan not far behind). Chinese EV manufacturers are among the largest in the world and poised to enter the U.S. in the coming years. Tesla has set the standard for EVs with great success, and, is gaining market share from the legacy majors.

At UC Berkley, a recent Berkeley Evaluation and Assessment Research (BEAR) study also concluded that EVs are good for the host state economy due to the increased portion of operating expenditures that remain in-state and improved air quality. This would be true for NH, also.

For utility and PUC consideration, residential and commercial solar can impact home and building energy use, but the addition of EV requirements will push demand higher than most on-site solar sources can supply, ensuring connection to the grid is needed.

EVs will represent considerable new load and revenue for the utilities. Much of the added load could be handled with few upgrades to the existing infrastructure if charging occurs during off-peak hours. This could allow lower electricity rates (better utilization of infrastructure) but won’t happen without policies and rates to encourage this behavior. Also, it is reasonable to expect that not all EV charging requirements will be met by off-peak charging. So, additional power resources will be needed during peak and shoulder hours. Solar deployments (residential, commercial, municipal, and utility) can provide peak time power and energy sources that can offset the added load. Large and small solar deployments should be aggressively pursued, especially utility scale deployments.

Also, the NH PUC should consider that it is difficult for EV Service Operators (EVSOs) to be profitable. Car charging locations are critical for EVs to be adopted by the public and for EV tourists to feel comfortable about coming to NH. The nature of car charging sites is that the demand is spiky (car charging at high rate or not at all). Under low site use scenarios, typical of initial years of a charging location, demand charges tend to dominate the cost of electricity and make it far higher than, say, residential rates or most commercial use rates.

To encourage EV adoption in NH, I offer various objectives and policies to consider.

Policy objectives to consider for rate design

Policies to consider

Enable EVSOs to make money. Lower or eliminate demand charges for EVSOs. Allow re-sale of kWh for chargers (done).
Spread charge infrastructure to low-income and non-garage multi-tenant dwellings. Encourage make-ready commitments to low-income and non-garage multi-tenant dwellings. Include ‘make-ready’ in building codes
Prepare for faster grid technology change. Consider faster depreciation for utility CapEx.
Lower the high cost of NH electricity. Encourage faster adoption of lower cost renewables. Encourage off-peak charging. Encourage V2G use of customer EVs.

Policy objectives to consider for ToU rate design

Policies to consider

Encourage off-peak charging. Adopt dedicated residential and commercial EV charge circuits. Allow ToU rates on residential charge circuits.
Encourage V2H/G power exchange. Prepare for V2H/G trials. Expand net-metering to include V2G uses.


EVSO means EV service operators.

ToU means time of use.

V2G means vehicle to grid – sharing power to/from grid to vehicle.

V2G/H means vehicle to grid or home – vehicle to home is a subcategory of vehicle to grid, using the vehicle only to provide power to/from the home.

CapEx means capital expenditures like buying equipment versus operating costs.

Make Ready is a term used by utilities to describe commitments and polices to bring grid power close to the end use point (like a parking lot of a multi-tenant building where no power currently exists).  This brings down the initial cost of installing charging equipment in some places, making it easier to justify.

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