I sent the following to members of the Maryland House of Delegates Environment and Transportation Committee regarding House Bill 969, Electric Vehicle Fuel Sold at Retail – Equipment Requirements, Units of Measure, Sales Price, and Fees
HB 969 – Continued Opposition Following Subcommittee Amendments
Chair Korman, Vice Chair Guyton, and Members of the Committee:
I previously submitted written testimony and testified at the February 27 hearing requesting an unfavorable report on House Bill 969. I write again briefly in light of the amendments adopted yesterday in the Agriculture And Aquaculture Subcommittee.
The amendment requiring itemized receipts is already addressed by NIST Handbook 44, Section UR.3.3, which requires a receipt at the completion of every transaction detailing the quantity of energy delivered, the unit price, and any additional separate charges such as parking fees, including their unit price and total cost. Handbook 44 is explicitly incorporated into Maryland law through Agriculture Article 11-207.1. To the extent other amendments also restate requirements already present in Handbook 44, the same redundancy concern from my original testimony applies. More broadly, codifying select provisions of the NIST Handbooks into Maryland statute creates a known risk: if NIST updates those handbooks, Maryland’s statute may fall out of step with the national standards it was intended to reflect. Advanced Energy United raised a related concern in their testimony, recommending that Maryland harmonize with national standards through the National Type Evaluation Program rather than creating Maryland-specific requirements.
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