Comment Log Display

ChargePoint appreciates the work the California Air Resources Board
(CARB) does developing, amending, and managing the Low Carbon Fuel
Standard (LCFS) and the opportunity to participate in the public
feedback process. ChargePoint is a world leading electric vehicle
(EV) charging network, providing scalable solutions for every
charging scenario from home and multifamily to workplace, parking,
hospitality, retail and transport fleets of all types. Today, one
ChargePoint account provides access to hundreds of thousands of
places to charge in North America and Europe. ChargePoint is a
participant under the California and Oregon LCFS programs and has
collaborated in LCFS rulemakings in Washington, Oregon, British
Columbia, Canada, and Germany.

ChargePoint would like to provide the following comments in
response to the potential future changes to the LCFS raised by CARB
in the December 7 Public Workshop.

Incentivize investment and align with long-term climate goals:

ChargePoint supports CARB's goal of incentivizing investment and
aligning with California's long-term climate goals. To achieve this
goal, no single amendment to the LCFS will do more to further these
goals than accelerating the pre-2030 carbon intensity (CI) target
and strengthening and extending the post-2030 target. To date, the
LCFS has proven extremely successful at incentivizing innovation
and investment in low carbon transportation fuels: the amount of
non-ethanol low-carbon fuel delivered to California's
transportation fuel market has increased by nearly 2,000% since
2011 (electricity as a transportation fuel has increased by over
150,000% under the LCFS)  and when factoring in the supply
pipeline, California is well on its way to achieving the 2030 CI
target under the program. As a result, many market participants now
have a bearish sentiment on future credit prices which stifles
marginal investment in low-carbon fuel and additional emissions
reductions. In the case of electric vehicle (EV) charging, near
term investments are critical to continue the expansion of charging
infrastructure and accommodate the rapid growth of both personal
and commercial EVs, particularly trucks and SUVs. By amending and
accelerating the pre-2030 CI target and strengthening and extending
the post-2030 target, CARB could better align the LCFS targets with
California's long-term climate goals and create the investor
confidence needed to incentivize the next wave of investment and
move California closer to its mid-century net-neutrality goal. If
CARB is unable to immediately amend the CI schedule, signaling its
intent to do so would improve investor sentiment and bring more
low-carbon fuel and infrastructure to market.

Accelerate transition to ZEVs:

As it relates to leveraging the LCFS to accelerate the transition
to zero emissions vehicles (ZEVs), if CARB is considering extending
the hydrogen refueling infrastructure (HRI) crediting provision to
medium and heavy-duty vehicles (M/HDV) then CARB should extend the
fast-charging infrastructure (FCI) provision to M/HDV as well.
Electrification in the M/HDV segment is happening and as production
scales and more vehicle models become available there will be a
need for non-depot charging infrastructure to serve these fleets
and mitigate fleet owners' risk of stranding vehicles in-route. The
FCI provisions currently in place for light duty vehicles (LDV)
have proven very effective at de-risking and attracting significant
investment in LDV direct current fast charging (DCFC) and the same
can be expected for M/HDV. ChargePoint also supports exploring how
to incentivize more investment in battery storage under the LCFS
and while we do not have specific proposals to lay out at this
time, we support holding technical workshops and gathering more
stakeholder feedback to inform potential mechanisms 

Along with extending the FCI provisions to M/HDV, CARB could help
accelerate the transition to ZEVs under the LCFS by exploring ways
of increasing the rebate amount under the Clean Fuels Reward
program so that the value received by drivers is a higher percent
of the average lifetime value of a single EV under the program. For
example, assuming a passenger EV driver charges roughly 750 kWh per
quarter at home, the statewide electricity CI declines at a modest
rate of 3% per year, and credit prices start at $145 and slowly
decline thereafter, the 10-year lifetime value of the residential
base credits equals approximately $3,000. At $750, the Clean Fuels
Reward rebate makes up only a quarter of this value. Acknowledging
that credit prices fluctuate and may decline faster and cashflows
must be sustained, we would encourage CARB to explore ways,
potentially through a partner such as a green bank, of increasing
the rebate amount to drivers so as to more accurately reflect the
lifetime value of home charging under the program. This should help
accelerate EV adoption and gasoline displacement in the state.

Finally, we propose that CARB recategorize "multi-family" charging
as non-residential under the LCFS to amplify the incentive for
multi-family apartment developers to install charging
infrastructure at multi-family home properties. This would give
multi-family apartment developers more agency in the ability to
recoup infrastructure costs and should accelerate investment in the
segment. Residences of multi-family apartments would still be
eligible for the Clean Fuels Reward and would be more likely to
have access to home charging, increasing the likelihood these
drivers will switch to electric. This small change to the program
may also go a long way in helping transportation network companies
to electrify, as mandated under the California Clean Miles
Standard.

Streamline implementation and enhance exportability:

ChargePoint is active across several North American coalitions to
help stand up LCFS programs and we appreciate CARB lending its
learnings and support to these jurisdictions.

We would express initial support for CARB to develop a single CI
benchmark table for primary obligated and opt-in fuels under an
LCFS to ease the lifecycle assessment burden on outside
jurisdictions. This may be of particular use to smaller states
considering adopting the LCFS. In doing so, CARB could consider
making the model assumptions behind each CI calculation transparent
and easy to adjust in case other jurisdictions see fit to make
changes that may better reflect local emissions factors. 

Thank you for considering our feedback. We look forward to
continuing to participate in the public feedback process.