Mike Litt, Sierra Club DC Chapter
For Public Hearing on B25-0106, the Comprehensive Electric Vehicle Infrastructure Access, Readiness, and Sustainability Amendment Act of 2023
Before the Council of the District of Columbia’s
Committee on Transportation & The Environment
10 July 2023
Thank you for the opportunity to provide testimony for the public hearing on B25-0106, the Comprehensive Electric Vehicle Infrastructure Access, Readiness, and Sustainability Amendment Act of 2023. Thank you, Councilmember Allen and the other committee members and councilmembers for introducing it.
My name is Mike Litt. I am a car free renter in Ward 6. I am a board member of the Sierra Club DC Chapter and am also its Clean Transportation Chair. Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. Here in DC, we have 3,000 dues-paying members and many thousands of supporters.
According to the District of Columbia's Multimodal Long-Range Transportation Plan, also known as “moveDC,” transportation is the District’s second leading source of greenhouse gas (GHG) emissions, accounting for 21% of such emissions.
Therefore, transitioning to a zero-emission vehicle future, coupled with reducing the number of miles traveled by vehicles (VMT) in the first place, is critical for reversing climate change, improving air quality and health, and making the total cost of car ownership lower and more predictable.
Councilmember Allen’s bill would pave the way for a baseline number of electric vehicle chargers to jumpstart the EV demand needed to improve our air quality, protect District residents’ health, and meet the District’s legal requirements to reduce GHG emissions by 60% by 2030 under the DC Climate Commitment Amendment Act.
Please find our recommendations below for strengthening the bill.
Number of EV Chargers
The Comprehensive Electric Vehicle Infrastructure Access, Readiness, and Sustainability Amendment Act of 2023 would pave the way for the installation of 7,500 EV chargers with at least two ports each, capable of delivering at least Level 2 charging across the District by 2027. This goal should serve as a baseline number to jumpstart the EV demand and infrastructure needed to electrify vehicle transportation in the District.
The Sierra Club DC Chapter asks that the Committee on Transportation & The Environment provide information about the modeling, projections, and benchmarks used to arrive at the bill’s goal of 7,500 chargers.
Such information will help the public assess how the bill supports the District’s current electric vehicle goals and efforts and whether goals should be higher.
The transition toward zero emission transportation will require charging infrastructure that can at least meet the District’s goal under the Clean Energy DC Act, for at least 25% of registered vehicles in DC to be zero-emission by 2030.
What percentage of this goal will the EV charging bill help achieve?
How does this legislation support other initiatives that DC has been working toward, including California’s Advanced Clean Cars II rule, which would require an increasing percentage of car sales to be electric starting in Model Year 2027, culminating with 100% of new car sales in 2035?
How do the Committee’s considerations for determining the number of chargers needed compare to the factors considered in the Department of Energy & Environment (DOEE)’s Transportation Electrification Roadmap published last September and its separate, more technical Strategic Electrification Roadmap for Buildings and Transportation in the District of Columbia published this April?
Does the Committee have an estimate for how many chargers, in total, would be installed by the District Department of Transportation (DDOT) under this bill?
The bill requires DDOT to install at least 50 EV charging stations, including at least four in each ward, by January 1, 2024. It does not, however, appear that DDOT would be responsible for installing any specified number of chargers after January 1, 2024, although the bill will “require the District Department of Transportation to install electric charging stations during updates to streetscaping.”
The bill should spur maximum use of the public right-of-way, including utility poles, to meet the District’s EV charging needs.
Under the bill DDOT would be required every three years to submit an Electric Vehicle Infrastructure Deployment and Management Plan, which would include proposed charging sites and analysis to achieve at least 7,500 public charging stations with at least two ports across the District by 2027.
This plan should also include an assessment of how many chargers could be accommodated by the public right-of-way, including utility poles.
The bill should require publicly available, real-time tracking of charging projects
A public facing dashboard with information about funds distributed, the status of charging projects, and progress to goal would provide necessary accountability.
We seek clarification on whether the bill’s requirement for chargers with at least two ports might be affected by federal requirements.
According to the Joint Office of Energy and Transportation, projects funded under the National Electric Vehicle Infrastructure Formula Program (NEVI) and Charging and Fueling Infrastructure (CFI) Discretionary Grant Program must meet federal minimum standards, which include requirements for at least four charging ports.
Even though Councilmember Allen’s letter introducing his bill explains that the bill allows DDOT to use federal dollars to deploy electric vehicle chargers, Sierra Club recommends also including information about potential funding sources for the bill, including but not limited to federal EV infrastructure funds and matching funds, in the bill text.
Deployment and Management Plan
The bill calls for the creation of an Electric Vehicle Infrastructure Deployment and Management Plan by January 2024, to be updated every three years. The Plan requires a description of grid capacity, identification of proposed locations for electric vehicle charging infrastructure and charging stations, equity considerations, minimum standards, and analysis of charging infrastructure deployment and adoption.
How will changes to EV demand and grid capacity be measured and addressed during the three years of EV charging deployment before the next update to the Deployment Plan?
Given the bill’s goal of 7,500 chargers by 2027, an update to the Deployment and Management Plan every three years might not be sufficient for identifying and addressing changing factors on the ground that will affect the ability to achieve that goal in time.
Grid improvements should be required if they are needed and not being made.
We support the bill’s requirement for an assessment of the grid’s capacity but believe that grid improvements should also be required, should the assessment show the grid lacks capacity to meet the electrification goals of the bill and the needs of the District.
All EV chargers installed in the District should be required to follow the same minimum standards for federally funded EV chargers.
Federal regulations include a 97% uptime reliability requirement to ensure chargers are working. Charger reliability is critical for EV adoption by the public.
Public engagement, important for ensuring equity, should be included in the bill text.
The bill’s Deployment and Management Plan will require identification of proposed locations for EV charging stations, but there does not appear to be mention of public engagement in that process. Public engagement is essential to EV adoption across the District and must also explicitly be part of plans to address equitable access to chargers.
DC’s majority fossil fuel-based transportation has contributed significantly to climate change, creating air pollution and health issues that are disproportionately impacting low-income communities and communities of color.
Air pollution is the biggest environmental risk factor for early death, contributing to 85,000 to 200,000 excess deaths in the United States each year. Mobile sources of air pollution emit harmful ozone, the main ingredient of smog, and particulate matter (also known as “soot”), which has been associated with various health problems and premature death. Although the District met the Environmental Protection Agency (EPA)’s standards for fine particulate matter that is smaller than 2.5 micrometers, it did not meet the levels recommended by 101 environmental and public health organizations, including Sierra Club.
Reducing air pollution from fossil-powered vehicles is especially important in communities of color and low-income communities across the District, which face outsized levels of pollution and climate change impacts—resulting in an increased incidence of associated disease and premature death. According to the District’s Transportation Electrification Roadmap, Black residents experienced three times as many deaths per capita from cardiovascular disease as White residents, and children living in predominantly Black communities have significantly higher asthma-related emergency visits—up to nearly 20 times higher—than those in majority-White communities.
The bill would require DDOT to administer an Electric Vehicle Charging Station Grant Program, providing up to $4,500 for the installation of Level 2 stations or $35,000 for fast charging.
The Committee should consider higher grant amounts.
Cost estimates cited by the U.S. Department of Energy (DOE) for Level 2 charging equipment and installation are up to $6,127, with installation costs varying up to 50%.
We encourage the Committee to consider higher grant amounts to offset costs and incentivize more charger installation.
Sierra Club, Plug In America, FORTH, and the Electrification Coalition have published an EV policies toolkit, AchiEVe: Model Policies to Accelerate Electric Vehicle Adoption, which documents EV policies adopted across the country. Colorado’s EV charging grant program provides an example of more generous grant amounts: “Level 2 incentives range from $6,000-$12,500 and DCFC incentives range from $35,000-$50,000. A $1,000 enhanced incentive for disproportionately impacted communities. A 10%-20% match is required for all projects.”
Under the EV charging bill commercial buildings would be required to have at least 15% EV charging-installed parking spaces and 25% that are EV charging ready. Multi-unit buildings would be required to have at least 20% EV charging-installed parking spaces and 20% that are EV charging ready. These requirements would apply after January 1, 2024, for building permits for all new construction or substantial improvements of commercial and multi-unit buildings that have 3 or more off-road parking spaces.
The bill should adopt a stronger definition of “EV charging ready” for its parking requirements.
We recommend using the AchiEVe definition of “EV ready,” which is defined as a parking space with panel capacity, installed breaker raceway and wiring, instead of the bill’s current definition, which only means panel capacity and the space for future installation of raceways. Given that wiring might be going through building foundations, this stronger definition will help avoid the burden of needing to pay for electrical work in the future.
The Committee should consider higher parking requirements.
The parking requirement percentages in the bill are higher than or similar to percentages several other places have adopted. However, Boston adopted a policy that “25% of parking spaces be EVSE-Installed; and the remaining 75% of parking spaces shall be EV-Ready for future installation, to the maximum extent practicable” for new developments that trigger Boston’s Transportation Access Plan Agreement (TAPA) process, which appears to be triggered for all developments of 50,000 square feet or more. And Palo Alto “passed an ordinance in 2014 requiring all new single-family residences and commercial buildings (including multifamily dwellings, mixed-use facilities, and hotels) to be EV-ready.”
Right to Charge
EV drivers who live in multi-family housing should not have to give up hope of driving and charging EVs at or near home. Policies removing restrictions for electric vehicle charging at multi-unit dwellings is crucial to further EV adoption.
We, therefore, applaud the bill’s rights for condo owners and renters to install chargers, which seem in line with right-to-charge policies passed by several states.
We also applaud the overall jumpstart this bill would provide to electrifying vehicle transportation in the District. Please let us know how we can help this committee strengthen the bill and your other efforts to reverse climate change, clean our air, and improve our health.
Thank you for your leadership. And thank you again for the opportunity to submit this written testimony.