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Comments to the New York Public Service Commission on Medium- and Heavy-Duty Electric Vehicle Charging

Together with Resources for the Future, we submitted comments to the New York Public Service Commission in response to questions posed by the Commission about addressing barriers to medium- and heavy-duty electric vehicle charging. Our comments focus on the possibility for managed charging to reduce infrastructure needs and on additional considerations to optimize emissions outcomes. Our comments are centered around depot charging and draw on research that examines fleet charging needs in a depot setting. 

Our comments offer the following observations and recommendations:

  • Charging customers can manage their charging in a number of ways. For example, they can shift their own maximum load to avoid the statewide system peak and/or the network peak, flatten their demand during the period when they charge, and/or fluctuate charging speeds to provide grid services. The various objectives with respect to which charging load can be managed may not always align with one another.

  • To the extent they have the technical capability to do so, charging customers should be expected to optimize for their own lowest cost of charging, accounting for (if applicable) utility rates, supply charges of all kinds, payments for grid services provided by the customer, and any incentive payments and/or penalties arising from managed charging programs. To maximize the reduced infrastructure need enabled by managed charging, the combined effect of these myriad price signals will need to incentivize charging behavior that minimizes distribution system impacts.

  • Existing research suggests that consideration of the relationship between fleet operations and the pricing environment – and the resulting grid implications – is highly fact-specific. In the case of New York truck and bus fleets and the actual pricing associated with existing tariffs, wholesale markets, and applicable programs, there appears to be an unmet research need.

  • When diesel fuel is replaced with electric generation, the exact emissions outcomes from electrification will depend in part on what electric generation is dispatched to serve the new load.  Electric infrastructure cost mitigation and overall emissions reductions are two different potential goals of managed charging, and a pricing environment designed to optimize for one cannot also be expected to optimize for the other.  

  • To prevent incremental generation from resulting in more air emissions than necessary while still prioritizing infrastructure mitigation, the Commission would need to consider the impact of the managed charging pricing environment and consider adjustments if fleet owners and operators are incentivized to use highly-emitting generation. Ideally, this would be done based on localized data and would be regularly revisited in response to changes in grid make-up.

  • The Commission must be mindful of the risk that price signals associated with charging could discourage charging altogether, giving rise to lost opportunities to reduce diesel emissions. This is especially critical because, although electric pricing includes some elements that lead electricity users to internalize some of the pollution costs they impose on society, diesel users face no comparable price signal.