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The Electric Vehicle Charging Association (EVCA) is a
not-for-profit organization comprised of leaders throughout the
value chain of the electric vehicle (EV) charging industry to
advance the goal of a clean transportation system in which the
market forces of innovation, competition, and consumer choice drive
the expeditious and efficient adoption of EVs and deployment of EV
charging infrastructure.
 
EVCA thanks the California Air Resources Board (CARB) for the
opportunity to comment on the Electric Vehicle Supply Equipment
Technology Review (Technology Review). EVCA believes this analysis
is essential to CARB administering and updating its Electric
Vehicle Charging Station Open Access regulation. Given that the
market is continually evolving in its development and use of
payment technologies, it is critical for CARB to conduct the
Technology Review at consistent intervals to ensure its regulation
reflects technology and consumer use trends. 

Upon initial review, EVCA recommends future Technology Reviews to
address the following unanswered questions below. We believe this
will better define the scope and extent of the problem CARB is
trying to resolve with its regulation, thus enabling it to better
refine its regulation as needed to increase consumer access to
charging stations
  
How do varying payment technologies and associated equipment differ
in their reliability, if at all? and how does that impact overall
station reliability? 
If there are issues in reliability with any payment technologies,
what are the cost impacts, if any, with repairing them? 
What percentage of Californians are unbanked and/or rely solely on
pre-paid debit/credit cards?
What percentage of unbanked Californians are interested in
purchasing an EV?
What other payment methods do unbanked Californians use?
 
Given that the Technology Review cited "inoperable stations" as a
top issue reported by respondents, we believe a more in-depth
analysis of the reliability of payment technologies is an important
underlying consideration to this regulation. Furthermore, given
that CARB is addressing payment access issues for unbanked
Californians, we believe more data is needed, as noted with
questions 3 and 4 above, to understand the extent of the problem.
We encourage CARB to work with third party researchers, who can
help design robust effective surveys and additional research
methods to answer these questions.

The Technology Review also, after conducting an assessment of
contactless payment penetration and use in the U.S., concluded it
was not yet prevalent enough to justify amending the regulation to
allow charging station companies to use that technology to comply
with the regulation. We encourage CARB, in the next iteration of
the Technology Review, to specify a standard that contactless
payment technology must meet to be considered widely accessible to
unbanked Californians. Providing a clear standard gives industry
certainty on a specific end goal CARB wants the market to work
toward.

We look forward to continued collaboration on this topic. Thank you
for your consideration.