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.
The following is a transcript of my testimony to the Maryland Economic Matters Committee in support of HB 1028, “Business Regulation – Electric Vehicle Supply Equipment – Regulations for Retail Use.” This legislation would require the Comptroller to adopt regulations for the retail use of electric vehicle supply equipment in the State that include requiring an uptime of 97% and establishing civil penalties for non-compliance with the regulations.
To build trust in electric vehicles, reliable charging and transparent pricing are essential.
Good afternoon. My name is Lanny Hartmann.
As an electric vehicle driver, I’ve experienced firsthand both the promise and the challenges of relying on public charging.
Over the past decade, I’ve visited hundreds of charging stations across the country. While many function smoothly, especially those on the Tesla network, a significant number of public charging stations struggle with reliability and uptime.
Millions are being invested in Maryland’s charging infrastructure. Reliability, affordability, and user experience are critical for success.
According to the Department of the Environment, Maryland currently has around 4,000 charging ports, and about 20% of them are in need of maintenance.
In my own testing of about 70 fast chargers in central Maryland, I found that nearly a third of them had issues. These problems included damaged connectors, malfunctioning screens, or the charger would stop abruptly or deliver reduced power.
There’s a need for transparency in charging costs and meter accuracy. I once charged at a station in Hagerstown and was later billed $553 on my credit card. While I eventually got a refund for the mistaken billing, it underscores the importance of accurate metering and fair pricing.
To build trust in electric vehicles, reliable charging and transparent pricing are essential. Fortunately, Maryland is leading the way in setting reliability standards for utility-owned charging stations with HB 834 which the General Assembly passed last year.
Now, with this bill, we have the opportunity to expand upon that success and ensure reliability and accountability for all public charging stations in the state.
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:
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.
The following is a transcript of my testimony to the Maryland Economic Matters Committee in support of the Maryland Electric Vehicle Charging Reliability Act (HB 834). The legislation subsequently passed and went into effect on October 1, 2023. This is one of the first laws of its kind in the United States.
We deserve transparency and accountability for EV charging infrastructure that’s being built with public funds.
My name is Lanny Hartmann. I’m an EV driver and a BGE ratepayer.
For years we’ve been told that public charging has 98% uptime, 99% uptime, even 100% uptime.
Last year a study was released by the University of California that looked at the reliability of the fast chargers in the San Francisco Bay Area. The study found that only [72.5%] were functional.
I had my own concerns about charger reliability so I conducted my own test of fast chargers in Maryland. In August I visited all the fast chargers owned and operated by BGE.
What I found was that 71% of them were fully functional. In other words, one out of three were broken.
For every station that didn’t work, I reported the issue to customer service.
I compiled my findings and presented them to the Public Service Commission at a hearing in September. You have that report in my written testimony.
Two months later I visited all 69 stations again. This time I found that only 65% were operational. The reliability had actually gotten worse.
There is a wide gap between what we’re being told about charging reliability and what EV drivers are actually experiencing.
The PSC and lawmakers need quality data to inform decision making.
We deserve transparency and accountability for EV charging infrastructure that’s being built with public funds.
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?
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.
