Testimony – Maryland EVSE Regulation Bill SB 913

Testimony Maryland EVSE Regulation and Oversight Bill SB 913

Education, Energy and the Environment Committee – February 18, 2025

The following is a transcript of my testimony to the Maryland Senate Education, Energy and the Environment Committee on SB 913, “Department of Agriculture – Public Electric Vehicle Supply Equipment – Registration, Regulation, and Oversight.”

This legislation would require the Secretary of Agriculture to establish a program to test the accuracy of public electric vehicle supply equipment, ensure the equipment conforms to certain standards, and to adopt regulations that include requiring an uptime of 97% and establishing civil penalties for non-compliance.

It sounds like a reasonable idea at first. After all, we all want better charger reliability and effective use of public funds. But consider that Maryland already passed a 97% uptime law in 2023 with HB 834, yet it’s been sitting there, largely unenforced by the Public Service Commission while reliability has continued to get worse.

Instead of fixing things, it’s prompted the utilities that own the charging stations to ask for millions more in ratepayer money to replace chargers that aren’t even that old. Now, with SB 913 proposing to add more regulations, there’s a good chance it will raise public EV charging costs without offering much benefit in return. That’s why I’m not convinced that doubling down with the same “uptime” requirements is the right approach at this time.

Maryland already mandates 97% uptime for utility-owned chargers. However, when they fail to meet the standard, the Public Service Commission does not penalize them.

Instead, utilities seek approval to spend millions more to replace equipment that is sometimes less than two years old.

My name is Lanny Hartmann.

I was part of a group of 13 EV drivers that visited nearly every fast charger in the state of Maryland to see how they were working. We went to 304 sites and assessed over 1,000 charging ports. Here’s what we found. Tesla and Rivian, who operate just over half of the ports, were nearly flawless—only two were down. Among the rest of the chargers, 31% were dead, offline, or wouldn’t activate.

Why the discrepancy?

Tesla understands that a positive charging experience is crucial for car sales, so they developed their own Supercharger network, prioritizing reliability.

Now, consider the other half of the chargers we evaluated. Those are operated by various owners and networking providers, many funded through state grants or funded by ratepayers.

The various ownership models, differing business priorities combined with the challenge of maintaining and repairing equipment from third-party vendors all contribute to the performance disparity that we observed.

Maryland already mandates 97% uptime for utility-owned chargers. However, when they fail to meet the standard, the Public Service Commission does not penalize them. Instead, utilities seek approval to spend millions more to replace equipment that is sometimes less than two years old.

Despite the existing mandate and additional spending, the uptime has not significantly improved.

I suggest an amendment to remove the uptime regulations. The many exceptions make them difficult to enforce effectively.

Instead, this bill should focus on providing the Weights and Measures Department with the resources they need.

Thank you.

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Tesla Supercharger Price Update in Maryland: December 2024

PluginSites Laurel, MD Supercharger Price
The peak price to charge at the Laurel, MD Supercharger is $0.51/kWh as of December 7, 2024

Tesla revised its Supercharger prices during the first week of December 2024. This update brings a mix of price increases and decreases across the state, with some stations experiencing no changes. In this post, I’ll detail the key changes, explore the factors influencing these adjustments, and provide an interactive table to help you understand the updated pricing at your preferred Maryland Supercharging locations.

Understanding Tesla’s Supercharging Pricing

Tesla’s Supercharging pricing model has traditionally been straightforward, offering a single rate that varies by location. However, this approach has evolved with the introduction of variable pricing, which adjusts rates based on the time of day. This could be to achieve two goals: optimizing grid demand by encouraging off-peak charging and improving station utilization by shifting usage to less busy periods, thereby reducing congestion at popular locations. Under the variable pricing structure, the day is divided into as many as four distinct periods, each with its own price per kWh. These rates act to spread utilization throughout the day which helps to ease crowding and aligns with Tesla’s broader strategy to enhance the Supercharging experience.

According to Tesla’s Director of Charging for North America, Max de Zegher, the company aims to keep prices low to accelerate EV adoption by passing on cost efficiencies to customers, while also ensuring financial sustainability to invest in the network and provide reliable long-distance travel options for EV drivers.

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Maryland Utility-Owned EV Chargers: An Assessment of Online Status in September and October 2024

Virtual Charger Audit

In 2019, the Maryland Public Service Commission approved a pilot program allowing five utility companies to own and operate public charging stations. By regulation, these utilities must maintain a 97% uptime for their charging stations. This means each charging port must be operational and supply electricity at least 97% of the time annually.

Methodology

In September and October 2024, I conducted a series of virtual “charger audits,” using the ChargeHub, Shell Recharge and ChargePoint apps to check the online status of every charging port in the utility networks. While on-site audits are ideal, weekly virtual audits provide a practical way to track the system’s performance remotely.

Data Charts

The following charts illustrate the data collected from these virtual charger audits.

Delmarva EV Charging Availability Chart

65% Avg – Delmarva Charging Ports Online, Sep. 13 – Oct. 20, 2024

L2 Avg: 65% | DCFC Avg: 63%

BGE  EV Charging Availability Chart

90% Avg – BGE Charging Ports Online, Sep. 19 – Oct. 21, 2024

L2 Avg: 92% | DCFC Avg: 77%

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Prince George’s County EV-Ready Legislation Advances in Council Vote

Multi-unit dwelling EV charging station

The people of Prince George’s County, Maryland may benefit from more electric vehicle charging infrastructure being installed in new residential and commercial construction, thanks to the Electric Vehicle Charging Infrastructure in Multifamily and Commercial Developments Act (CB-105-2024). The bill, which recently passed its first phase through the County Council, would require new and significantly renovated developments to include EV charging stations or “EV-Ready” infrastructure in parking lots and garages.

Key Amendments to the Bill

Initially, the legislation proposed that 20% of parking spaces be EV-Ready (pre-wired with a dedicated 40A circuit) and an additional 60% be EV-Capable (having panel capacity and raceways to support future installation). However, recent amendments reduced the EV-Ready requirement to 10%, and the EV-Capable mandate was removed entirely. Additionally, the start date for these requirements has been delayed from January 1, 2025, to January 1, 2027.

Supporting Access to EV Charging

Councilmember Wala Blegay, a key supporter of the bill, believes the legislation is crucial for making EV charging more accessible and convenient for residents. “I personally wanted to buy an EV but frankly didn’t because I saw there were limitations on where I could charge.” 

Ensuring Charging Station Reliability

A key provision of the bill is the EVSE Maintenance Standard, which places responsibility on property owners to maintain EV charging stations in “good condition in all respects, including the functioning of equipment” ensuring that equipment remains functional and reliable—a growing concern in EV infrastructure.

Mixed Reactions

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Hanover, MD – Tesla Supercharger Station

Tesla Supercharger Hanover, Maryland

The Tesla Supercharger in Hanover, Maryland is located on the third level of the parking garage at the Hotel at Arundel Preserve. It features eight charging stalls, each capable of delivering up to 72 kW of power.

Details of this Featured PlugInSite:

Construction Cost

Unknown No public record of construction cost since this did not receive public funding.

Electricity Usage

See Graph for a visual representation of monthly electricity consumption as recorded by the meter.

ver, MD Supercharger throughput kWh

Site Information

Location
Address: 7795 Arundel Mills Blvd., Hanover, MD 21076
County: Anne Arundel
Facility Type: Parking Garage
Coordinates: 39.153270, -76.743849
Directions: On third floor of parking garage at Hotel at Arundel Preserve.
Map Link: OpenStreetMap

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Clear Spring, MD – Potomac Edison Charging Station

Clear Spring, Maryland Potomac Edison ChargePoint EV charging station

Potomac Edison owns and operates a Level 2 electric vehicle charging station in the town of Clear Spring, Maryland. The charging station is located in a public parking lot on N. Hawbaker Cir., one block north of National Pike/Cumberland Street. It’s about a 0.4 mile walk to the library and about 0.3 mile from McDonald’s. The two-port Level 2 charging station is part of Potomac Edison’s EV Driven program and uses the ChargePoint network.

Here are the details of this Featured PlugInSite.

Construction Cost

$22,554.71 Total site construction cost plus $560.00 annual operating cost

Revenue vs Electricity Cost

MetricAmount
Energy Used252 kWh
Revenue$44.52
Electricity Cost$285.91
Deficit-$241.39
Note: This calculation only reflects the difference between electricity costs and revenue as of June 30, 2024. Other operating expenses, such as maintenance and repair costs, are not included.

Electricity Usage

Clear Spring, MD - EV charging utilization Jan. 1 to Jun. 30, 2024
Clear Spring, MD – EV charging utilization Jan. 1 to Jun. 30, 2024

Site Information

Location
Address: N Hawbaker Cir, Clear Spring, MD 21722
County: Washington
Facility Type: Parking Lot
Coordinates: 39.657069, -77.930968
Directions: At SE corner of parking lot on N Hawbaker Cir.
Map Link: OpenStreetMap

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Acredale Community Park – Pepco EVsmart Charging Station

Airedale Community Park Pepco EVsmart EV charging

Pepco manages an EV charging station at Acredale Community Park in College Park, Maryland, with four Level 2 chargers. As of October 10, 2024, all four have been offline for nearly six months. EV drivers have been unable to use this site—which opened two years ago—due to what Pepco describes in their semi-annual report to the Public Service Commission as “communication issues.” Filed on August 1, 2024, the report notes that the “location requires troubleshooting.” This prolonged outage, which appears to have an easy fix, has left EV drivers frustrated and ratepayers—who funded these stations—feeling deprived.

Here are the details of this Featured PlugInSite.

Construction Cost

$91,954 Total site construction cost per the Maryland PSC PC44 EV Pilot Program

CategoryAmount
Labor$54,091
Materials$24,349
Network$5,830
Utility$7,684
Total$91,954

Revenue vs Electricity Cost

MetricAmount
Energy Used3,449 kWh
Revenue$564.82
Electricity Cost$1,003.69
Deficit-$438.87
Note: This calculation only reflects the difference between electricity costs and revenue as of June 30, 2024. Other operating expenses, such as maintenance and repair costs, are not included.

Electricity Throughput Trend

Acredale Community Park EV charging station electricity throughput usage graph June 2024
Acredale Community Park EV charging monthly usage trend in kWh

Site Information

Location
Address: 4300 Metzerott Road, College Park, MD 20740
County: Prince George’s
Facility Type: Park
Coordinates: 38.9995404, -76.9357454
Directions: At SE corner of parking lot.
Map Link: OpenStreetMap

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Charlotte Hall Library – SMECO EVRecharge Charging Station

Charlotte Hall Library SMECO EV charging station

Southern Maryland Electric Cooperative (SMECO) owns and operates this EV charging station at the Charlotte Hall Library in St. Mary’s County, MD. It has a single DC fast charger rated at 50 kW. See all the pertinent details below.

Charger Construction Cost

$106,688.75 Total site construction cost per the Maryland PSC PC44 EV Pilot Program

CategoryAmount
Equipment$81,064.13
Contractor$5,000.00
Network$7,138.00
Utility$13,486.62
Total$106,688.75

Electricity Cost vs Revenue

$1,393.17 Surplus (Since Inception)

MetricAmount
Energy Used31,070 kWh
Revenue$9,028.82
Electricity Cost$7,635.65
Surplus$1,393.17
Note: This calculation only reflects the difference between electricity costs and revenue as of June 30, 2024. Other operating expenses, such as maintenance and repair costs, are not included.

Trend Graph: Monthly Electricity Dispensed in kWh

Charlotte Hall Library EV charging monthly usage trend in kWh
Charlotte Hall Library EV charging monthly usage trend in kWh

Site Information

Location
Address: 37600 New Market Rd., Charlotte Hall, MD 20622
County: St. Mary’s
Facility Type: Library
Coordinates: 38.4732855, -76.7764742
Directions: At SE corner of library parking lot.
Map Link: OpenStreetMap

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Whitmore Garage, Annapolis – BGE EVsmart Charging Station

Whitmore Garage Annapolis BGE EVsmart charging station

Baltimore Gas and Electric owns and operates this EV charging station at the Whitmore Garage in Annapolis, MD. Located on a lower floor of the pay parking garage.

Charger Construction Cost

$151,474 Total site construction cost per the Maryland PSC PC44 EV Pilot Program

CategoryAmount
Labor$90,702
Material$48,872
Network Fees$11,900
Utility Administration
Total$151,474

Electricity Cost vs Revenue

MetricAmount
Energy Used23,843 kWh
Revenue$4,981.42
Electricity Cost$20,806.67
Deficit-$15,825.25
Note: This calculation only reflects the difference between electricity costs and revenue as of June 30, 2024. Other operating expenses, such as maintenance and repair costs, are not included.

Trend Graph: Monthly Electricity Dispensed in kWh

Whitmore Garage EV charging station monthly usage graph
Whitmore Garage EV charging monthly usage trend in kWh

Site Information

Location
Address: 37 Clay St., Annapolis, Maryland 21401
County: Anne Arundel
Facility Type: Pay Parking Garage
Coordinates: 38.978757, -76.496354
Directions: Enter the parking garage from Clay Street.
Map Link: OpenStreetMap

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