Comment Log Display

June 19, 2015

Clerk of the Board
Air Resources Board
1001 I Street
Sacramento, CA 95814

Re: Low Carbon Fuel Standard Program Amendments for Regulated
Parties for Suppliers of Electricity Used as a Fuel Substitute.
Dear Madam or Sir:

NRG EVgo (“EVgo”) appreciates the opportunity to review and comment
on the referenced amendments to the Low Carbon Fuel Standard
Program as they affect suppliers of electricity used as a fuel
supplement.

EVgo is a leading Electric Vehicle Services Provider (“EVSP”) in
the state of California seeking to grow the market for the future
of California’s EV drivers and the environment.  EVgo has a
multi-faceted business model engaged in expanding both private and
public access EV charging infrastructure throughout California.  As
a company heavily engaged in the development of EV charging
infrastructure, we believe the LCFS credit program can be
beneficial to the continued expansion of our business operations
and the growth of the EV market in California.  The proposed
amendments restrict the ability of EVSPs to generate credits to
public access charging alone, which unnecessarily constrains
incentives for EVSPs in expanding charging opportunities at
multifamily dwellings and workplaces. The success of the EVSP
industry hinges on the viability of a complete ecosystem of EV
charging products covering: home, public access, workplace, and
multifamily.  EVgo would like to see the California Air Resources
Board maximize credit generating opportunities for EVSPs across all
public and private access chargers.

EVgo aims to enroll in the LCFS program shortly and looks forward
to working closely with the California Air Resources Board to
maximize EV adoption.

*Generally, EVgo objects to the elimination of the general category
“electricity services supplier” as a regulated party eligible for
the full suite of credit generation opportunities.*

The policy objectives supporting the use of electricity in the LCFS
should incentivize all market participants to increase
electrification and reduce carbon intensity. Restricting certain
categories of LCFS eligibility to Electrical Distribution Utilities
creates a skewed playing field that unfairly favors utilities over
private market participants such as EVSPs. 

*EVgo respectfully objects to the proposed language of §
95483(e)(1) for failing to include EVSPs as an eligible regulated
party at single- or multi-family residences.*

Expanding EV charging into multi-family residences is a critical
component of EV adoption in California.  EVgo’s business model
includes contracting with apartment communities to provide turnkey
charging services to its residents. The ability to generate credits
through these relationships would provide a significant incentive
to increasing deployment. Owners of multi-family residences have
generally been hesitant to invest in EV infrastructure and manage
the authentication, networking, maintenance and billing activities
needed to serve residents. Permitting EVSPs to generate credits
through the provision of private access residential charging
services would encourage further development and lead to more
opportunities for EV drivers to charge their vehicles during
off-peak hours. 

EVgo requests that § 95483(e)(1) be amended to include verbiage
similar to § 95483(e)(2) or § 95483(e)(4) (assuming “site host”
would include EVSPs) such that EVSPs who have contractual
relationships with property owners or managers to provide charging
services are permitted to generate credits at single- and
multi-family residences.

*EVgo respectfully supports the proposed language of § 95483(e)(2)
including EVSPs as an eligible regulated party at public access EV
charging stations.*

EVgo is investing heavily in public access EV charging stations
across the state of California.  Generating credits through the
LCFS will enable us to expand our offerings and increase the pace
of deployment. Additionally, the public education requirements
align closely with many of EVgo’s current programs and its ultimate
business objectives.

*EVgo respectfully requests clarification of the term “Site Host”
in § 95483(e)(4) to include EVSPs in connection with business and
workplace charging.*

Workplace charging is an essential component of EV adoption in
California.  EVgo welcomes the opportunity to generate credits as
the EVSP of private access charging stations at a business or
workplace.  The term “site host” should be clarified to include
EVSPs who have contractual relationships with a business or
property owner to provide charging services.