Comment Log Display

Good Afternoon,


On behalf of the California Department of General Services (DGS), I
would like to thank the California Air Resources Board (ARB) for
allowing the opportunity to weigh in with comments on the
Volkswagen ZEV Investment Plan.  Through the establishment of
statewide policies and the installation of electric vehicle (EV)
workplace charging infrastructure at state facilities, DGS has been
involved heavily in the adoption of zero emission vehicles (ZEV) by
state fleets and among state employees.  To fund these projects,
DGS relies heavily on outside sources such as, grant programs,
investor owned utility subsidies, and settlement programs (such as
NRG's).  Recently DGS released an aggressive EV infrastructure
goal, in Management Memo 16-07 (attached), to install workplace EV
chargers in 5 percent of all state owned parking spaces by 2022. 
DGS estimates this will amount to approximately 4,500 new workplace
EV chargers at state owned facilities.  Critical to the success of
this new mandate, is securing the funding necessary to complete
these installation projects.  Therefore, DGS is asking that ARB
take the following comments into consideration when developing the
guiding principles for the Volkswagen ZEV Investment Plan.  As
always, thank you for your dedication to ensuring a better and
healthier future for our state.

ZEV Infrastructure

1. Give priority to workplace charging (to include “behind the
fence” charging) initiatives, as it has been shown that access to
workplace charging significantly increases electric vehicle (EV)
adoption rates among employees (especially those who live in
multi-unit dwellings).  

2. Promote partnering with state and local governments to
facilitate and/or fund EV charging installations at government
locations that serve disadvantaged communities.  State and local
government agencies are uniquely positioned to both operate in and
serve many disadvantaged communities throughout the state.  By
partnering with state and local government agencies to install
dual-use (workplace/public) EV charging infrastructure, not only is
the investment promoting adoption of EVs among employees at those
facilities (many of whom live in the same disadvantaged community),
but also among the local residents who seek services at these
facilities.  Additionally, many state and local governments already
have plans (in various stages) to install EV infrastructure. 
Partnering with these agencies could potentially cut much of the
planning costs and maximize the impact of the investment dollars.

3. Partner with public and private fleets to complement existing
fleet EV charging/fueling infrastructure plans.  Whether due to
political initiatives or cost savings, many public and private
fleets are at the leading edge of ZEV adoption and are installing
the necessary infrastructure to support their growing ZEV fleets. 
Many of the EV charging stations needed to support fleet vehicles
are being installed in “fleet only” locations – which are usually
identified based upon cost of installation.  Many of these chargers
sit idle during working hours while fleet vehicles are out in the
field and, if strategically located, could double as workplace
chargers during working hours.  We encourage ARB to provide
guidance that would allow Volkswagen’s ZEV Investment Plan to
include incentives for fleets to expand the scope of planned EV
charger installations to include workplace charging capabilities.