The first Tesla Superchargers on the East Coast opened ten years ago on December 21, 2012.
The Milford Travel Plazas on I-95 in Connecticut and the Delaware Welcome Center in Newark were the seventh and eighth Supercharger Stations built by Tesla. These were the first locations outside of California, where the first six Superchargers had opened a few months earlier. These two East Coast Superchargers allowed Model S drivers to travel between Washington, DC and Boston. As of 2022, Tesla reports that there are over 4,500 Supercharger Stations open worldwide.
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.
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
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?
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.
The map above shows the locations of DC Fast Chargers planned by awardees of the Maryland ECGP Round Two.
Electric Corridors Grant Program – Round Two Awards
A year ago, Governor Larry Hogan announced the first of three rounds of funding for the Maryland Electric Corridors Grant Program (ECGP) funded by Maryland’s portion of the VW diesel settlement. The first round included 36 public DC fast chargers at 13 locations along designated Alternative Fuel Corridors. Many of these locations that were announced last year have yet to be built.
Round two includes 35 chargers at 13 additional locations.
Blink requested $1,684,189.50 in grant funding for 12 chargers at six Royal Farms stores plus an Exxon station in Grantsville in far Western Maryland. The six Royal Farms stores used to have 50 kW chargers on the ChargePoint network. Those have been shut off and each of the newly funded locations are approved to get two 180 kW Blink chargers.
An Exxon station in Big Pool, MD was approved for two 150 kW fast chargers. Big Pool Exxon requested $373,913.60 but it is not clear if they were approved for the entire amount. The grant has a cost share component so the recipients are required to pay a percentage of the total cost.
EVgo asked for $895,000.00 in Round 2 funding to place 19 fast chargers at 5 locations. One of those locations, the Wawa in Beltsville, seems to have already been built.
Maryland ECGP – VW Settlement
The funding comes from the Volkswagen diesel settlement. Maryland was allocated approximately $75.6 million to use on projects to reduce the effect of diesel emissions. Up to 15% ($11.3 million) of Maryland’s Volkswagen Mitigation Plan funding can be used for EV charging infrastructure.
Maryland decided to release the funding in three rounds of public-private partnership grants. The first round included $3.7 million for DC fast chargers and Level 2 workplace charging.
Maryland Alternative Fuel Corridors
The Maryland Electric Corridors Grant Program is for fast charging stations along Alternative Fuel Corridors that have been designated by the Federal Highway Administration. The Alternative Fuel Corridors for electric vehicles include US Routes 50 and 301 on the Eastern Shore and I-68 / I-70 in Western Maryland.
Funding Award Chart
The chart below details the applicants’ locations, number of chargers and funding amounts.
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.
“Price is what you pay. Value is what you get.” – Warren Buffett
The price of a gallon of gas never differs much between gasoline retailers in my area. I’ve paid attention to gas prices lately as they have soared above $5.00 and then retreated a bit. Even though I don’t buy the stuff, a gallon of gasoline at the Exxon station on the corner never varies more than a few cents from the price advertised at the convenience store across the street. Public EV charging prices may be more stable in comparison, but they are not particularly uniform. How do EV charging prices get determined? Public documents from Fairfax County, Virginia give us a glimpse into their particular process for price setting.
Public Charging Fees Set by Fairfax County Board of Supervisors
This month, the Fairfax County Board of Supervisors approved a $0.30 per kWh fee for EV charging on county property. They also set an idling fee of $2.00 per hour.
The 30 cents per kilowatt hour is to be paid by members of the public as well as by county employees who charge their private electric vehicles while at work. The “dwell-time” fee of $2.00 per hour kicks in when the vehicle is finished charging after a 10-minute grace period.
The idling fee is to motivate EV drivers to vacate charging spaces at county office buildings when their battery is full. The idling fee is also deliberately intended to apply at Park-and-Ride and Metro garages where EV drivers cannot move their vehicles in the middle of the day. More on that later.
How did Fairfax County come up with these fees? Let’s take a look.
$0.30 per kWh for EV Charging in Fairfax County VA
A report titled “Establishment of Retail Fees for the Charging of Electric Vehicles at County-Owned Charging Stations” was prepared by county staff for the Board of Supervisors. It detailed the rationale for the $0.30 per kilowatt hour pricing and $2.00 per hour dwell-time fee.
The report said that the most important considerations in setting the fees were (1) the costs that are to be recovered by the fees; (2) the user’s ability to access and move their vehicle when charging is completed, and (3) competitiveness with the fees charged by other stations located nearby.
The methodology used to determine the pricing weighed the relative merits of a cost recovery method vs a competitive market approach. The report concluded that while cost recovery was an important consideration, pricing that remained in line with the competitive market took precedence. “Prices that are too high in comparison to those charged by other providers are likely to lead to reduced demand for the service absent some unique benefit.”
Level 2 Prices Conflated with DC Fast Charging
Fairfax County surveyed fees by various EV charging providers in the county but they did not distinguish between Level 2 and DC fast charger pricing. The fees that they compared are summarized in Table 1 of the report:
Access to reliable and affordable charging where people live is essential to the widespread adoption of electric vehicles.
Robert Borkowski is fortunate to have a garage at his home at Clarksburg Condominium II in order to charge his Tesla. But many of his neighbors in Montgomery County, Maryland do not have a private garage or parking space to install a personal EV charging station. As President of his condo association, Robert decided to look into installing shared charging stations for residents of his condo community who do not have a garage or dedicated parking.
Clarksburg Condominium II Community Buy-in
Getting approval for the project required a “yes” vote from two-thirds of the condo residents. The association sent out a survey to gauge interest among residents for EV charging. Supporters of the project held several community meetings to answer questions and address concerns. They set up a Frequently Asked Questions page on the association’s website about the proposed EV charging stations.
Maryland EVSE Incentives
Taking advantage of available EV charger incentives helped the association manage out of pocket expenses. Keeping the cost down helped persuade some residents who initially opposed the project because of budget concerns. The Maryland Energy Administration (MEA) offers a 40% rebate for qualifying EVSE installations. The condo association also applied for incentives from their utility company. Potomac Edison offers up to $20,000 through their EV Driven Multifamily program. In total, the project cost around $60,000. Incentives from the state of Maryland and Potomac Edison amounted to around $44,000. The net cost to the association was around $16,000 after incentives.
The association had to pay the entire costs for the construction up front before receiving the rebates. The Montgomery County Green Bank worked with City First Enterprise’s Small Business Energy Savings Support Program on a $60,000 loan to help facilitate the electric vehicle charging project.
The condo association selected six JuiceBox PRO commercial grade EVSEs from EnelX for the project. These units are connected to a network with accompanying monthly service fees. This allows residents and visitors to pay for their kWh usage via a mobile app. The initial cost for residents is $0.20 per kWh. Visitors can charge for $0.30 per kWh.
The six 40A JuiceBox PRO commercial EVSE (Electric Vehicle Supply Equipment) are on a new dedicated 400A 3-Phase commercial service. The infrastructure includes capacity to install 11 additional EVSEs in the future.
Delegate David Fraser-Hidalgo highlights the progress of EVs in Maryland as Clarksburg Condominium II President Robert Borkowski looks on.
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.
