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Tesla official advises energy regulator on electric car infrastructure development


As part of an investigation launched by the Puerto Rico Energy Bureau, a Tesla Inc. official advised the regulator recently on how to improve electric car penetration on the island.

By The Star Staff


Tesla Inc. Senior Policy Advisor Bill Ehrlich gave the Puerto Rico Energy Bureau (PREB) advice recently on how to improve electric car penetration in Puerto Rico as part of an investigation launched by the regulator.


The initiative is also supported by the Electricians Association and the Consumer Protection Independent Office, among other organizations.


Ehrlich addressed matters related to utility ownership, billing for charging services, government supplied land for electric vehicle (EV) infrastructure development, and zoning considerations for EV charging infrastructure. “Puerto Rico’s EV master plan should include measures that ensure continued flexibility that enable a variety of technologies and stakeholders to participate in the growth of EVs and EV charging infrastructure,” he said in written remarks. “The EV and EV charging industries are still at a nascent stage and rapidly evolving.”


Tesla’s mission is to accelerate the transition to sustainable energy through the development of all-electric vehicles and clean energy products including photovoltaic solar and battery storage. Tesla is a U.S.-based manufacturer whose vehicle line-up includes the Model S sedan, Model X crossover vehicle, Model 3 sedan, and Model Y crossover vehicle. The vehicles have all-electric range of up to 405 miles per charge, and industry leading performance and safety ratings.


There are currently two Tesla charging locations in Puerto Rico, one site in Guaynabo and another in Aguadilla.


“Will the utility be able to own and operate charging stations? Emerging best practices around the world are a mix of increasing utility participation and support in the absence of private investment,” Ehrlich said. “It is important to ensure that utility participation complements private investment in charging infrastructure, rather than competes with it.”


The New Jersey Board of Public Utilities (BPU) put forward the idea of a “shared responsibility” model for EV infrastructure in their 2020 EV ecosystem “straw proposal” that promotes appropriate roles for both the electrical utility and private investors. Under the model, electric utilities would be responsible for the wiring and backbone infrastructure necessary to enable a robust number of charger-ready locations, along with the ability to own and operate electric vehicle service equipment (EVSE) in specified circumstances. Non-utility entities, which are referred to as EVSE infrastructure companies, would be primarily responsible for installing, owning and/or operating, and marketing EVSE using private capital. Tesla sees this sort of complementary approach as a best practice on the topic of utility ownership, Ehrlich said.


Another way the utility can support and complement EVSE Infrastructure Companies is by providing “Make-Ready” infrastructure investments and EV infrastructure grants. “Make-Ready” investments most often take the form of the utility providing wiring and backbone up to the customer meter but in some cases can extend beyond the customer meter all the way up to the charger stub such that a customer is only responsible for purchasing the EV charging equipment.


How will charging stations’ owners charge or bill to clients?


“Tesla believes that the best and fairest way to charge EV drivers for charging services is on a $/kWh [kilowatt-hour] basis,” Ehrlich said. “If EV drivers are billed on a $/minute basis there can be a wide difference between how much energy customers receive and what they are billed. For example, two different EV drivers would pay the same price to charge their cars for 20 minutes, but could get two very different quantities of electricity during that period because the speed of charging depends on the model of vehicle, temperature, the battery’s state of charge and other factors.”


To date, 38 states have provided clear guidance that allows for billing on a $/kWh basis without EV charging being considered a “public utility.” Since EV infrastructure companies are utility customers themselves, it does not make sense that they would be considered public utilities given they are served by public utility companies, Ehrlich said.


The Public Services Regulatory Board should make it a priority to determine that the provision of EV charging services does not make an entity a “public utility.”


Opening opportunities to site charging stations at government-owned properties would be welcomed by the charging industry given that site scouting, identification, and development can account for a large part of the deployment timeline. The only caution with opening government sites for development would be the desire to have an open and transparent process by which EV infrastructure companies were awarded sites from the government supply of sites.


“Must zoning allow for complementary uses, like food trucking? There is an opportunity for building partnerships between state and local governments and charging station developers to streamline charging station development,” Ehrlich said. “Streamlining EV charging station permitting is critically important for ensuring the infrastructure development needed to support significant EV deployment is provided in a cost-effective and timely manner to keep pace with driver needs. Local jurisdictions differ widely in their review timelines, mode of submittal, permit fees, and internal review procedures.”


The Consumer Protection Independent Office advised the PREB to provide certain incentives to charging stations, such as exempting them from the payment of municipal taxes. The entity also advised offering credits to businesses that replace their fleet with electric vehicles and exempting from construction permits the solar panels installed to provide service to the charging stations.


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