Reliability – Plug-In Sites

New Jersey Enacts EV Charging Uptime Legislation

March 19, 2024March 19, 2024 Lanny

New Jersey Bill S3102

Approved by the Governor: 1/16/2024.

New Jersey bill S3102 Establishes uptime requirement for electric vehicle charging station incentive programs.

This statute directs the Board of Public Utilities (BPU) to establish a requirement, as a condition of providing any incentive for the installation of electric vehicle service equipment pursuant to P.L.2019, c.362 (C.48:25-1 et seq.) or any other State law, that the station is operational at least 97 percent of the time, as measured on an annual basis. The law also directs the BPU to develop and implement a process to establish, monitor compliance with, and enforce this requirement. As used in the law, “electric vehicle service equipment” means the equipment, including the cables, cords, conductors, connectors, couplers, enclosures, attachment plugs, power outlets, switches and controls, network interfaces, and point of sale equipment and associated apparatus designed and used for the purpose of transferring energy from the electric supply system to a plug-in electric vehicle.

Call for Enhanced Oversight and Accountability of Electrify America’s Charging Infrastructure

January 23, 2024January 23, 2024 Lanny

Comments to California Air Resources Board (CARB)

The California Air Resources Board (CARB) will hold a public meeting to consider a staff assessment of Electrify America’s Cycle 4 Zero Emission Vehicle Investment Plan on January 25, 2024. The Board will then decide whether to approve or disapprove the plan.

I submitted the following comments to the California Air Resources Board:

To: cotb@arb.ca.gov
January 23, 2024

Re: 24-1-2: Electrify America’s Proposed Cycle 4 Zero Emission Vehicle Investment Plan

Dear California Air Resources Board,

I am writing as a concerned advocate for electric vehicle drivers. Last summer I travelled through the state of California in an electric vehicle. I encountered many of my fellow EV drivers who were having issues with non-functional Electrify America charging stations. Harris Ranch had a line of frustrated EV drivers waiting to use it because most of the six dispensers were down.

The reliability issues surrounding Electrify America’s charging infrastructure have raised significant concerns within the EV community. While the initial intent of the company to address the fallout from the 2015 Dieselgate scandal was commendable, it appears that their efforts have fallen short, leading to a new crisis in the form of unreliable charging stations.

The recent Sacramento Bee article by Ari Plachta highlighting the reliability challenges faced by Electrify America underscores the urgency of addressing these issues. As an active participant in promoting EV adoption, I find it disheartening that a company established with the explicit purpose of rectifying past wrongs is now contributing to hindrances in the widespread adoption of electric vehicles.

The reliability issues reported, including broken screens, faulty payment systems, and slow charging, are significantly impacting the EV user experience. This not only undermines the trust of current EV drivers but also dissuades potential buyers from making the switch.

Electrify America ranking last in consumer satisfaction, as reported by J.D. Power, is indicative of the severity of the problem. The satisfaction score of 538 out of 1,000 is alarming, especially when compared to Tesla’s score of 739.

Unreliable charging infrastructure poses a major hurdle to achieving widespread EV adoption. Reports suggest that approximately 18% of individuals who switch to electric vehicles end up returning to gas-powered cars due to charging inconveniences. Given the magnitude of the issue, I urge the California Air Resources Board to consider the following actions:

1. Enhanced Oversight: Strengthen oversight mechanisms for Electrify America, ensuring that the company adheres to higher standards of performance and reliability. Confidence in California’s public charging network is crucial for the success of EV adoption.

Broken Charging Stations Threaten Maryland’s Electric Vehicle Goals

March 22, 2023March 13, 2023 Lanny

300,000 Electric Vehicles by 2030

Maryland aims to have 300,000 electric vehicles on the road by 2025. As of December 31, 2022, there were 62,744 EVs registered in the state. As the number of EVs in Maryland continues to grow, it is essential that the state’s EV charging infrastructure keeps pace.

One crucial aspect of growing the infrastructure is ensuring that the EV charging stations are fully functional. When they are out of service or malfunctioning, it can create a major inconvenience for EV drivers, especially during longer trips. People who live in apartments and cannot charge at home also depend on public charging to get to work and for other essential travel. Equitable distribution of EV charging is necessary, and the reliability of those charging stations must be ensured as well.

Utility-Owned EV Charging Stations

Maryland is one of the few states that allows regulated utilities to own and operate public EV charging stations, and pass the cost on to the rate base. The Maryland Public Service Commission approved a pilot program that permits over 1,000 charging ports to be run by utilities, including BGE, Pepco, Delmarva Power, Potomac Edison and SMECO. The cost of the program will be passed on to ratepayers, regardless of whether they drive an EV or not. Currently, the stations are losing money, but it is hoped that increased usage will eventually make them self-sustaining financially.

Facing Challenges

Four years into the pilot program, utility-owned charging stations are facing challenges. Despite assurances to maintain high reliability, the results have been disappointing. In a customer satisfaction survey conducted by BGE and published in their semi-annual EV pilot program report, 26% of respondents reported not being able to complete a charging session, and 27% reported broken equipment. Negative reviews on the crowdsourced EV charging app PlugShare have also led to low utilization.

Reliability Standards

When the Public Service Commission was considering the utilities’ EV charging pilot programs, the Commissioners were assured that the public charging network would be maintained to a high degree of reliability. However, there is currently no regulatory standard for charging station reliability metrics, as there is for the grid, which has standards like SAIFI, SAIDI, and CAIDI.

In September 2022, I visited all 69 BGE fast chargers in Maryland and checked how well they were functioning. The results indicated that 29% of the chargers had some kind of deficiency, ranging from complete failure to reduced power output. During a follow-up round of testing two months later, the number of malfunctioning chargers had increased from 29% to 35% of the total. These findings suggest that the reliability of the utility’s public EV charging stations is not meeting the expectations that were set when the pilot program was approved.

Accountability to Ratepayers

These results are not only concerning for EV drivers but also raise questions about accountability to ratepayers. We should be able to trust that the utilities are maintaining their charging stations to a high degree of reliability, as promised. As ratepayers, we deserve to know where our money is going and how effectively it’s being used.

To address these issues, Delegates David Fraser-Hidalgo and Jen Terrasa are sponsoring the Electric Vehicle Charging Reliability Act (HB 834), which sets a minimum uptime standard and requires regular reporting on the performance and cost of utility-owned charging stations. This will provide transparency for EV drivers and ratepayers and help the utilities quickly identify and resolve any issues.

Focus on the Driver Experience

Maintaining reliability is an important step towards ensuring that Maryland’s charging infrastructure is robust. By keeping focus on good EV driver experience and reliable charging infrastructure deployment, Maryland will maintain its position as a leader in EV adoption. The state’s goal of 300,000 electric vehicles on the road by 2025 will only be achievable when the public can charge quickly, affordably and most of all, reliably.

Charger Reliability Transparency

December 13, 2022December 13, 2022 Lanny

The following letter of comment on proposed EV Charger Reliability Standards was filed with the Maryland Public Service Commission on December 12, 2022 (ML 300467)

Re: Case No. 9478 – Public Conference 44 Electric Vehicle Work Group Supplemental Reliability Summary Report

As a BGE ratepayer and EV driver, I respectfully request that the Commission require the EV Pilot Utilities to provide a detailed explanation each time that one of their public charging stations experiences a no-charge event, consumer complaint, or system alert.

The Electric Vehicle Work Group has twice delayed establishing reliability reporting standards for the EV Pilot Utilities. We should not have to wait for federal guidelines for the National Electric Vehicle Infrastructure (NEVI) program to be released. We can begin collecting thorough data on each malfunctioning charger immediately without waiting for those guidelines.

Background

The reliability of public EV charging stations is crucial for providing a positive experience for EV drivers. As ratepayers, we deserve accountability for the money used to build the utilities’ public charging stations. When the Commission was considering the EV charging pilot programs, BGE assured us that they would maintain public charging stations to a high degree of reliability.

We have a regulatory obligation to maintain the charging networks much like any other distribution asset that we have. This is going to avoid situations where you have prolonged EV charger outages due to a breakdown or subsequent vandalism or any sort of things that could befall one of these chargers, and it is our goal of course as always to provide excellent customer experience for those EV chargers.
Sept. 6, 2018 Hearing Video at 2:34:38

Network Vendor Statistics

Based on the Shell Recharge Solutions Sky network dashboard, BGE reported 95% uptime (99% if “unknown” is counted) in the most recent semi-annual report. The PHI Utilities reported an aggregate uptime of 99.7% and SMECO reported an “overall uptime of over 98%.”

Potomac Edison uses the ChargePoint network and provides quarterly uptime for each charging station. They also give details on the steps taken to repair each outage. For example:

On February 21, 2022, PE notified drivers that the charging station located on the right, at the Friendsville Veterans Memorial Park, was out of service. PE and ChargePoint actively worked on resolving the issues across three site visits with technicians on February 15, 2022, March 4, 2022, and March 11, 2022 (descriptions above). The site was partially operational on February 15, 2022, (meaning 1 of 2 DCFC was operational) and fully operational on March 11, 2022, (meaning 2 of 2 DCFC was operational). PE posted outage notifications on PlugShare and the ChargePoint applications notifying customers of the extended outage at the Friendsville Veterans Memorial Park.
Potomac Edison Semi-Annual Report – August 1, 2022, ML 241711, page 14

Sabotage

November 18, 2022February 13, 2024 Lanny

Oh my god, it’s a mirage.
I’m tellin’ y’all, it’s sabotage.
– Beastie Boys

Politicians never miss an opportunity to remind us of what they’re doing “for the people.”

One such missive came this week from the Office of House Majority Leader Steny Hoyer. A press release marked the one year anniversary of the $1.2 trillion Bipartisan Infrastructure Law (BIL).

The BIL includes $7.5 billion of funding for a National Electric Vehicle Infrastructure (NEVI) plan. Companies are lining up to get a piece of the EV charging infrastructure pie.

The Congressional press release happened to quote my recent remarks to the Washington Post to illustrate “how the Bipartisan Infrastructure Law is delivering results For The People in all fifty states.”

“Drivers of electric vehicles that use a different plug [than Tesla] need a network of chargers that are convenient and reliable. That’s what is exciting about the national electric vehicle infrastructure plan.”
Lanny Hartmann

The key word here is, “reliable.” Drivers of electric vehicles (The People) need chargers that are solidly reliable.

Do the politicians, government officials, and company executives who cut the ribbons to inaugurate new charging stations understand that The People often suffer once the cameras go away?

Charging Failed – BWI Cell Phone Lot EV Chargers

October 25, 2022August 29, 2023 Lanny

After the Ribbon Cutting

The EV chargers at the BWI Airport Cell Phone Lot are an impressive backdrop for a photo opportunity. The towering units adorned with BGE logos looked appropriately stylish and high-tech the morning of May 24, 2021. Dignitaries clutched gigantic scissors and on “3, 2, 1,” snip, the ribbon fluttered to the ground. Such was the celebratory atmosphere less than a year and a half ago.

This is another example of our work to make Maryland a national leader in electric vehicle infrastructure.
Maryland Secretary of Transportation Greg Slater – May 24, 2021 press release

I’ve been here for 20 min and still haven’t been able to even start charging.
Nissan LEAF driver at BWI Cell Phone Lot – Sept 18, 2022 (PlugShare)

30,000-Foot View / Three-Foot View

The speeches at EV charger ribbon cuttings predictably weave tales of a bright vision for electric vehicles and electric vehicle charging infrastructure.

Expanding access to electric vehicles and infrastructure is a major step toward ensuring a cleaner and brighter future for our community.
BGE CEO, Carim Khouzami – May 24, 2021 press release

The 30,000-foot view from the lectern soon gives way to the “three-foot view” of an EV driver. Three feet is about the distance that we stand from a charging station as we poke at screens and wave cards attempting to charge.

The three-foot view is the perspective of the hopeful EV driver. It’s what remains long after the shards of ribbon have been whisked away. There are no cameras to capture the event for the six o’clock news. Just a low battery and an EV driver anticipating the flow of electrons.

The 30,000-foot view is fuzzy on details. The three-foot view can be brutally sharp.

4 DC Fast chargers here. 1 down for maintenance, the other 3 have a “tower” error.
BMW i3 driver – Feb 1, 2022 (PlugShare)

Error Code

In my test of BGE chargers in August, one of the four chargers at BWI Cell Phone Lot did not function as expected. When I returned 11 days later for a follow up evaluation, that unit still did not function. Thirty days after the first test, the charger was working. But by that time, two different machines wouldn’t start.

I Tested Every BGE Fast Charger in Maryland – Here’s What I Found

September 15, 2022November 30, 2022 Lanny

Rationale

It’s been over three years since the Maryland Public Service Commission approved an EV charging pilot that allows the utilities to use ratepayer funds to own and operate public charging stations. When they petitioned for approval of the pilot, my utility, BGE, had assured regulators that their public EV charging stations would be highly reliable and that they would respond quickly to resolve outages and issues. How are they doing in that regard? I wanted quantitative data to find out.

95% to 99% uptime is the range described in the utilities’ semi-annual EV charging reports. That seems quite optimistic compared to what other EV drivers and I have experienced. The only way to actually find out the ground truth is to go out and visit the chargers. I chose to evaluate all the utility-owned fast chargers in the BGE service territory.

Professor David Rempel of the University of California, Berkeley recently published a study on the reliability of the public (non-Tesla) electric vehicle fast chargers in the San Francisco Bay Area. The results showed that more than a quarter of the chargers in the Bay Area were not functioning or had a design failure. The non-functioning stations suffered from non-responsive displays, payment system failures, initiation failures, network failures, or damaged connectors.

The Berkeley study utilized a group of volunteer EV drivers who visited the chargers and tested each one by plugging into their EV and attempting to charge for two minutes. The methods used in the Berkeley study inspired the procedure that I used to test the fast chargers in Maryland.

Procedure

Between August 28 and September 6, 2022, I tested all 69 public fast chargers that are owned and operated by BGE. I created a map of the charger locations and divided the locations into manageable groups that I could visit and evaluate over a number of days.

I drove to each site and worked through a checklist of tasks to test each fast charger. First I took a series of photos of the chargers. Then I recorded the Station ID, model and serial number of each unit. I visually inspected the equipment including the display, cables and connectors for damage. I documented the online status of the charger in the Shell Recharge mobile app. Then I attempted to initiate a charge via the app. If the unit began charging, I let it run for two minutes. Meanwhile I took note of the charging speed and made sure that the charger was operating as expected. After two minutes, I’d stop the charge and then attempt to initiate a charge using the RFID card reader.

If a charging session failed, I reported it to Shell Recharge customer service. This should have alerted BGE of the specific chargers that were having issues. In many instances, when I reported the issue, Shell Recharge responded that a service ticket had previously been created.

Results

A charger was classified as fully functional if it authorized via the Shell Recharge app (or started free), initiated a charge, and maintained the expected charging speed for two minutes.

71% (49) of the BGE fast chargers were fully functional as defined above.

14.5% (10) of the chargers were completely inoperable.

2.9% (2) consistently displayed error codes and would not charge.

4.4% (3) were offline and did not respond via the app. However, these did initiate via a tap of a Shell Recharge RFID card. Most drivers however do not carry a Shell Recharge card.

7.2% (5) initiated a charge but delivered very low power, around 15 kW. That is a fraction of the 50 kW rated power for those stations.

ChargerAudit – Crowdsourcing EV Charger Reliability Data

August 23, 2022November 30, 2022 Lanny

An experiment, born today on social media.

EV drivers on Twitter are frustrated by broken chargers and the lack of transparency around charger uptime metrics.

Version 0.1 of the Citizen #ChargerAudit Project is very simple.

US Transportation Secretary Says NEVI Program Will Prioritize EV Charging Experience

July 21, 2022November 30, 2022 Lanny

Transportation Secretary Pete Buttigieg testified before Congress on July 19, 2022 about transportation infrastructure.

During the House Committee on Transportation and Infrastructure hearing, Rep. Carolyn Bourdeaux of Georgia’s 7th district asked Secretary Buttigieg about the National Electric Vehicle Infrastructure (NEVI) program and how the Administration has prioritized the charging experience for consumers “to ensure it’s easy, consistent, and mirrors their current experience at the pump.”

Buttigieg responded, “There’s tons of opportunity but a lot of challenge in getting it right for this electric vehicle infrastructure especially because we’ve not had something like this at scale in the US. It’s very different from the infrastructure for fuel and gas cars. We need to be mindful of that as we go.”

You can imagine, if you are taking a road trip and every third or fourth gas pump didn’t work.
Pete Buttigieg

One thing we are thinking about in particular in regard to the consumer experience is making sure that these charging stations are interoperable and are available. You can imagine, if you are taking a road trip and every third or fourth gas pump didn’t work, or if you had to be a member of a particular gas station chain in order to even use the pump. That would not be a positive or efficient experience. In some places, in some cases in the past, that’s what some EV drivers have faced. So we need to make sure that we are not only getting the dots in the right places on the maps, but paying attention to the quality as well as the quantity of these EV charging stations, especially those that would be supported with taxpayer funds.

Thank you Representative Bourdeaux for asking about the consumers’ experience at EV charging stations. And thank you Secretary Buttigieg for assuring Congress that the Joint Office is mindful of the quality of the EV charging stations that will be installed as part of the National Electric Vehicle Infrastructure Program. Reliability of public charging is an important issue. I look forward to seeing how the Administration will ensure accountability.

EV Charger Reliability Standards Report Issued by Maryland PSC Work Group

July 20, 2022November 30, 2022 Lanny

“Consistently delivering on your promise reinforces trust.” ― Bernard Kelvin Clive

Will people develop trust that electricity can replace gasoline as “fuel” for their transportation? This must happen before electric vehicles enter mainstream adoption. Sure, we are told by advocates that 90% of charging is done at home. But we also know that ubiquitous public charging is important to ensure equity so that all citizens may benefit from driving electric. After all, many people do not have access to charging at home or work. For those folks, DC fast chargers are practically their only option. And those chargers better deliver on the promise of convenience, reliability and affordability. Otherwise, people won’t trust the chargers. Consequently, they won’t trust electric cars.

On January 14, 2019, the Maryland Public Service Commission approved a five-year pilot program to allow utilities to install public EV charging stations in their service territory. The utilities promised to maintain a high standard of uptime. BGE was quoted in the Carroll County Times saying, “BGE is being held to the same reliability standards as our electric distribution system, so they must be operational at all times.”

Some EV drivers have raised concerns that the utilities’ public EV chargers are not as reliable as we’d hoped they’d be. The Maryland Public Service Commissioners heard that a charger at Howard County Community College had been down for weeks while the one next to it only delivered a fraction of its promised charging speed.

EV Charger Reliability Standards

In January 2022, the Commission directed the utilities to work with a stakeholder work group to develop public charger reliability standards. The standards, if approved, would be used in the semi-annual progress reports that utilities are required to submit. The standards were to be filed prior to the next semi-annual reports which are due August 1, 2022.

Work Group Asks to Delay Uptime Reporting Until Next Year