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
Similarly, BGE described a charging station repair timeline in response to questioning by the Chairman during the PSC Administrative Meeting on March 16, 2022.
We received a report that that CHAdeMO handle was damaged on January 3. We placed the order for a new charging cable on January 7, and we received the cable to do a completely replace out that cable and CHAdeMO connector on February 25. There were several weeks from when it was identified to when we received the replacement cable just due to all of the supply chain issues that we’ve been experiencing with broken parts.
Administrative Meeting – March 16, 2022 video at 32:35
Utilities have various ways of becoming aware of issues with charging stations in their network. BGE noted in the March 16, 2022 Administrative meeting, “if a customer calls the Greenlots 800 number that is listed on the chargers to report a ticket, we are made aware of that immediately.” BGE also stated that they look at PlugShare reviews on a daily basis, and they respond to any customer that provides a negative check in.
Field Evaluation
In late August and early September 2022, I tested all 69 fast chargers in the BGE network and found that 29% had some kind of deficiency. If a charger had an issue, I reported it to Shell Recharge (formerly Greenlots) customer service via their mobile app or 800 number. I shared the results with the Commission in comments filed on September 12, 2022. (ML 242263)
Between November 5 and November 13, 2022, I repeated the testing of all 69 BGE fast chargers. The reliability had worsened – malfunctioning chargers had gone from 29% to 35% of the total. As before, I contacted Shell Recharge to report any issues that I encountered. In many cases, the issues were the same as those I reported during the first evaluation performed two months earlier. I documented the issues and provided this information to BGE. (See Appendix)
Work Group Compromise
In Order No. 90036, issued on January 11, 2022, the Commission directed the EV Pilot Utilities to work with the Public Conference 44 EV Work Group to develop standards for reporting public charging station reliability data. The Work Group has proposed that EV Pilot Utilities report “the most granular data they have” in their upcoming semi-annual reports until the NEVI program rules are finalized and the Work Group can meet to develop final standards that align with NEVI.
Customer-Centered Reporting
I respectfully ask the Commission to clarify the expectation for “granular data” and to require that each EV Pilot Utility provide a list of each charger issue that the utility became aware of via their monitoring software, an EV driver report to customer service or PlugShare, and report on their resolution and status. The report for each issue should include:
- The charging equipment location and station ID
- The date and time the outage or malfunction was first reported and length of time until resolved
- A detailed narrative and timeline of efforts to service, maintain, and repair each issue
- Identification of issues that contributed significantly to excessive charging equipment downtime
- Steps taken to address challenges and prevent the recurrence of excessive downtime
Conclusion
EV drivers are discouraged by the discrepancy between the 98% – 99.7% uptimes reported by network providers and the number of broken chargers we encounter in real life. The Commission needs to hold the utilities accountable. Accountability begins with credible data. The interim compromise resolution proposed by the Work Group will allow the utilities to use the same questionably high uptime numbers that have been reported in aggregate and apply them to individual sites or stations. The data should be based on customer reports and repair tickets.
The success of this pilot program depends on the availability of high-quality data to inform decision-making. We need comprehensive data reporting to begin with the semi-annual reports that are due on February 1, 2023. The Work Group can reconvene when NEVI standards are released to finalize reporting metrics, reliability goals, exemptions, and other details. By holding the utilities accountable and providing credible data, we can ensure the success of this program.
Sincerely,
/s/ Lanny Hartmann
Lanny Hartmann
Columbia, Maryland
