re:Charge Comments on NY's EV Make Ready Program

May 13th, 2023

Hon. Michelle L. Phillips Secretary to the Commission New York State Public Service Commission 3 Empire State Plaza Albany, NY 12223-1350

Re: Comments on Case 18-E-0138, Electric Vehicle Make-Ready Program Midpoint Review and Recommendations Whitepaper

Dear Secretary Phillips,

On behalf of re:Charge, we would like to thank you for the opportunity to provide our thoughts on the midpoint review of the Electric Vehicle Make-Ready Program for New York State. re:Charge is a New York-based company established because of the promise of shared electric micromobility to reshape urban communities toward a healthier, greener, and more equitable future. We have developed universal charging stations that will redefine how people use electric bikes, scooters, and other devices in public places. re:Charge stations will generate cost savings for shared mobility operators; improve safety, durability, and reliability for consumers; and unlock value for investors through the unique use of wireless power transfer technology. We would like to thank the Department of Public Service staff for its consideration of the addition of electric micromobility charging infrastructure to the EV Make-Ready Program. These are excellent first steps toward more diversification in our electric vehicle options that will also stimulate the use of electric micromobility.

Why Electric Micromobility? Electric micromobility options, such as ebikes and escooters, have the potential to simultaneously move the United States towards net zero emissions, while avoiding many problems tied to electric cars and trucks and continued automobile dependency. The benefits of the broader inclusion of electric micromobility into our transportation systems are many. They include:

• Environmental Benefits: Combating climate change through the reduction of greenhouse gas emissions is the most important environmental challenge of our time. In the United States, nearly 30 percent of all greenhouse gas emissions come from the transportation sector. In order to reach the Climate Leadership and Community Protection Act goals to reduce greenhouse gas emissions by 85 percent by 2050, New York State needs to transition its transportation system away from the use of fossil fuels and towards EVs of all types powered by renewable energy sources. While the electrification of cars, trucks and buses is important, the ability of such a shift to reduce overall carbon emissions is limited by the sources of electricity currently used to power the vehicles, the need for electrical grid upgrades for energy transmission, the length of time it will take to transition our fleet to EVs, and the current cost of EVs which put them out of reach of most middle- and low-income households. Given that 60 percent of the trips in the US are under five miles in distance, we believe electric micromobility must be a larger part of the solution if we are going to reach the climate goals set by NY State, the federal government, and the world.

• Energy Efficiency: Even under the most ambitious, best-case scenarios of EV adoption, Americans will still need to reduce the amount we drive to meet our climate goals. The need for improved access to transit, and better infrastructure for biking and walking, are critical in achieving a reduction in vehicle miles traveled, yet the focus on the electrification of cars, trucks and buses as the only solution to the climate crisis is limiting our options, and drawing much needed funding away from more energy-efficient and equitable modes of transportation. Electric micromobility has the potential to reduce overall emissions by moving trips away from cars and trucks, especially for short distances. A recent Transportation Research and Education Center whitepaper has found that 62 percent of ebike trips in North America replaced a trip that would have otherwise been taken by car. Increasing urbanization will likely lead to a larger percentage of car trips that could be replaced by bikes or scooters, especially if those vehicles are electric. It is important to note that the energy required to charge a single car could be used to charge hundreds of electric bikes and scooters if charging infrastructure was in place for their use.

• Equity: The rapid acceleration of EV adoption is also raising concerns about transportation equity, with low-income communities potentially being “redlined” in the move towards electric vehicles. While lower long-term maintenance and fuel costs associated with EVs will ultimately benefit low-income communities, there are significant issues related to income disparity that must be addressed. To date, the high cost of EVs has led to a lower percentage of such vehicles being sold in these communities. Public charging also tends to be more expensive than at home charging, but residents of multi-unit dwellings are less likely to have a convenient place to charge at home. Finally, while greenhouse gas emissions from EVs may be eliminated, the particulate matter generated by tire wear and vehicle braking may be greater in heavier EVs thus offsetting some of the emissions benefits gained from electric powertrains. This is especially acute in low-income communities which are often nearby or adjacent to highways. Including electric micromobility in the state’s EV charging programs will help to create a level playing field that supports equitable and sustainable new mobility.

Current Micromobility Implementation and its Challenges During the pandemic, the sales of personal use of ebikes and escooters surged, a trend that has accelerated as high gas prices and concerns over the climate have forced people to rethink their travel habits. Ebike sales grew 16 times faster than regular bike sales, and in 2021 ebike sales grew by over 240%. In fact, the most popular electric vehicle in the United States is an ebike, and popular bike share systems in major US cities, like Citi Bike in NY and Divvy in Chicago, are becoming increasingly electrified.

But as the use of electric micromobility expands, many shared micromobility operators struggle with profitability due to high charging costs. In shared use systems, electrified fleets of bikes and scooters require frequent battery charging, so batteries or even whole vehicles are swapped while on the street. This is a service that is currently performed by large teams of technicians and service vehicles who will either replace batteries in the field, or pick up and return depleted battery vehicles to an operations center for charging. This is a costly process that creates profitability headwinds while also generating additional greenhouse gas emissions and traffic congestion, two problems micromobility was supposed to resolve. These issues are exacerbated as many markets have multiple shared mobility operators seeking to address the same problem using similar costly solutions. Due to short-term operations contracts with cities, and other competitors in the same market, shared mobility operators have not invested in the on-street charging infrastructure needed to solve the charging problem. Additionally, shared mobility operators have been perceiving the process of connecting potential charging stations to the grid as a significant challenge they have not been willing to address yet.

At the same time, private owners of light EVs lack access to publicly available charging infrastructure. As a result, charging is almost exclusively done in the home which complicates and discourages the use of more environmentally-friendly transportation options while at the same time creating an increased risk of fires from poorly maintained ebike and escooter batteries. In fact, in New York City between 2021 and 2022 fires caused by ebike and escooter batteries resulted in 10 deaths and 226 injuries.

In spite of their popularity and importance within our transportation systems, funding options for micromobility charging infrastructure are few and far between. Unlike electric cars, trucks and buses, federal and state funding has not been made available to rectify the lack of electric micromobility charging infrastructure. In fact, of the $7.5 billion allocated to the National Electric Vehicle Infrastructure (NEVI) program, zero dollars were allocated to support the electrification of bikes and scooters. In New York, the original EV Make Ready program, and its partner program the New York State Energy Research and Development Authority’s (NYSERDA) Charge NY, which was designed to help buy down the cost of EV charging stations themselves, do not support charging infrastructure for electric micromobility. The recommendations from Department staff, if adopted, have the potential to rectify that disparity.

Potential Use of Electric Micromobility Charging Funds re:Charge wholeheartedly supports the Department staff’s recommendations to allocate additional funds to the EV Make Ready program to support charging infrastructure for electric micromobility, and there are any number of electric micromobility programs in the state that could stand to benefit from additional funding for micromobility charging infrastructure as proposed. These include, but are not limited to:

• Centering People, Place and Policy for Buffalo's Clean Mobility Future This program will establish ebike lending libraries in the lower income areas of East Buffalo. This is part of NYSERDA’s Clean Neighborhood Challenge, which was created and funded by the original EV Make Ready Order. Funding to support grid connections for electric micromobility charging stations could increase the usability of the system by ensuring electric bikes are charged and ready to be ridden.

• Capital District Transportation Authority (CDTA) Bikeshare Program CDTA is expanding its existing bikeshare program to include ebikes. Given CDTA’s geographic spread of over 2,300 square miles, keeping vehicle batteries charged from a central operations facility would be a challenge. On-street charging stations for the CDTA system would increase system reliability for customers, while dramatically reducing operating costs. With additional resources, CDTA would be able to increase the number of charging stations and use their existing resources for the purchase of additional ebikes.

• Citi Bike Citi Bike is the largest and most successful bike share program in North America. Micromobility charging infrastructure funding, as proposed by Department staff, could be used to support Citi Bikes’s growing fleet of ebikes and reduce the need for on-street battery swapping which generates added congestion and greenhouse gas emissions from service vehicles.

• New York City Housing Authority (NYCHA) Micromobility Demonstration Per its 2023 Progress Report on NYCHA’s Sustainability Agenda, NYCHA and Con Edison will install outdoor charging and storage stations for micromobility devices at four locations– Queensbridge North and South in Queens, De Hostos in Manhattan, and Van Dyke in Brooklyn. This year Con Edison will release a request for proposals (RFP), seeking a vendor to provide the outdoor charging infrastructure and subsequent operations and maintenance of the installed equipment. Funding for the charging stations through the EV Make Ready program could reduce the costs of the program overall and potentially allow for a great number of pilot locations.

Recommendations To our knowledge the proposals outlined by Department Staff are the first of their kind in the United States and could serve as a model around the country. re:Charge stands ready to help support this effort in any way possible. We do, however, have some suggestions on how the program could be improved. Our recommendations are as follows:

1. The Make Ready program should provide financial and administrative support to facilitate the installation of metered service (20A, 110V single phase would suffice) at dedicated locations where micromobility charging stations could be deployed. Given the scale of downstate shared micromobility programs, like Citi Bike and other escooter pilot programs, and the potential for other electric micromobility projects throughout the state, we recommend additional funding should be allocated beyond the $25 million proposed by Department staff.

2. The current proposed split of funding between upstate and downstate should be adjusted to allow these programs to reach into more Disadvantaged Communities in Upstate New York that are being left out of the EV revolution. For example, a network of charging stations could be located along the Empire State Trail, providing mobility for millions of upstate residents and visitors.

3. In much the same way that funding for EV charging equipment, as a complement to the Make Ready utility work, where the Charge Ready NY program was added to help buy down the cost of the charging stations themselves, re:Charge recommends additional funding be allocated as part of the NYSERDA-managed Charge Ready 2.0 program to help pay for the cost of electric micromobility charging stations.

4. Where appropriate, we encourage the co-location of standard EV charging stations with charging stations for electric micromobility so utility work to create grid connections is only done once. This “dig once'' approach is inline with guidance from the United States Department of Transportation.

5. Staff specifically requested comments on the importance of fire suppression infrastructure for electric micromobility charging. re:Charge certainly recognizes these concerns, and we feel that outdoor charging for electric micromobility will be the best way to reduce the risk of fires. And as with standard EV charging stations located, for example, in parking garages, no additional fire suppression is needed for outdoor public charging.

Thank you for the opportunity to share our comments and offer our recommendations. We appreciate the New York State Public Service Commission’s openness to receive input from all interested parties and we stand ready to play a key part in the rollout of electric charging infrastructure in New York, particularly in the expansion of micromobility . We are also more than willing to participate in any technical working groups if needed. Please feel free to reach out to us if you have any questions or if any of our proposals need further explanation.

Sincerely,

Julien Bouget, CEO re:Charge jbouget@recharge-e.com 518-618-2006