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
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