July 22,
2022
Liane M.
Randolph, Chair
California Air
Resources Board
1001
“I” Street
Sacramento, CA
95814
RE: Peninsula Clean
Energy Advanced Clean Cars II Comments – Require 16 Amp Level
1 Charging Capability
Dear Chair Randolf and
Members of the Board,
Peninsula
Clean Energy authority (“PCE”) submits these comments
to the California Air Resource Board (“CARB”) in
regards to the Advanced Clean Cars II (“ACC II”) draft
regulations.
PCE, a
community choice aggregator (“CCA”), is the official
electricity provider for San Mateo County and the City of Los Banos
in Merced County. Founded in 2016 with a mission to reduce
community greenhouse gas emissions, the agency serves 315,000
customers by providing more than 3,500 gigawatt hours annually of
carbon-free energy. As a community-led, not-for-profit agency, PCE
makes significant investments in our communities to expand access
to sustainable and affordable energy solutions. PCE is on track to
deliver electricity that is 100% renewable by 2025. PCE’s EV
Ready Program is a $28 million electric vehicle (“EV”)
charging infrastructure program seeking to install 3,500 charging
ports at public and multi-unit dwelling sites in our community over
four years.
In
general, PCE applauds CARB staff in its efforts to accelerate
electric vehicle (“EV”) adoption and provide more
equitable access to EVs in California and joins other commenters in
support of increased annual EV targets, increased ranges for
all-electric and plug-in hybrid vehicles, improving charging cords
to dual-voltages and longer lengths, more affordable (low MSRP)
EVs, etc.
We reserve
our comments to focus on one Level 1 charging as a means to further
improve access to a convenient and accessible place to plug in at
home and has otherwise not been addressed in the draft regulations.
We encourage CARB to include regulations that mandate that
automakers allow EV drivers to set the charge level of their Level
1 charging, with a maximum of 16 amps when drivers are using
dedicated 20-amp circuit for their Level 1
charger.
As noted
in the Initial Statement of Reasons, Level 1 charging provides
significant convenience and cost avoidance benefits to EV drivers
by allowing them to “make use of the supplied cord with
existing residence circuits and no additional costs to either
modify the home wiring or buy a different charger.” PCE agrees. Level 1 is a
commonly used, “out of the box” charging solution that
meets the daily needs of most EV drivers with no installation costs.
Allowing drivers to control their Level 1 charge rates in the
vehicle and letting drivers charge at 16 amps if they have a
dedicated 20-amp circuit will improve the Level 1 charging
experience for the many EV drivers that charge this
way.
Several
vehicles already have the capability to change Level 1 power
levels, demonstrating its benefit to customers and that automakers
are capable of implementing this feature. The draft regulations
note that several automakers such as BMW and Hyundai allow drivers
to set their charging level between 8 – 12 amps. Tesla also allows drivers to
set their Level 1 charging rate up to 16 amps.
The
practical benefit of this proposal is that drivers would be able to
get more range on an overnight charge with Level 1 charging thereby
improving their overall EV driving experience. An EV that limits
Level 1 charging at 12 amps (or 1.4 kW), provides approximately 60
miles of range over a 12-hour overnight
charge. Allowing an EV driver to
charge up to 16 amps on their Level 1 charger would increase the
power to 1.9 kW, yielding over 80 miles of range overnight, a
considerable difference.
In
PCE’s EV Ready charging rebate program, we offer free technical
assistance to multi-family property owners and other EV charging
site hosts to help them install as many charging ports as possible.
For sites with significant parking dwell times, such as
multi-family housing, which averages over 12 hours of parking
times, Level 1 is often the ideal solution to contain costs and
provide maximum access without incurring major electrical service
upgrades. In these projects, PCE designs Level 1 charging
receptables on dedicated 20-amp circuits, since Teslas, as the most
common EV make in California, already offer the option charge at 16
amps. Our hope is that other automakers will follow suit and these
Level 1 receptables can be used to their maximum potential and
provide greater overnight charging across other vehicle
brands.
In
summary, allowing EV drivers to control their power level when
charging on a Level 1 charger, including the ability to charge up
to 16 amps, will improve the charging experience for many EV
drivers and would be straightforward to implement, particularly
since Tesla has already done so. PCE encourages CARB to utilize the
ACC II regulations to improve Level 1 EV charging by requiring
automakers to implement this capability for the benefit of EV
drivers.
Thank you
for your consideration of these comments and please don’t
hesitate to contact me if you have any additional
questions.
Phillip Kobernick
Programs Manager, Peninsula
Clean Energy