Washington, DC -- The Office of the People's Counsel for the District of Columbia has filed comments in response to the U.S. Department of Energy's (DOE) Request for Information about the impact of integrating electric vehicles (EV) and charging technology into the nation’s power grids. OPC's comments emphasize that federal research, funding, policies, and programs should work to ensure that EV grid integration is equitable, just, affordable, reliable for consumers, and implemented in a manner that most cost-effectively meets federal and local greenhouse gas (GHG) reduction goals. See OPC's entire comments filed on Friday, July 23, here.
District consumers have a strong interest in equitable, just, and affordable EV expansion to meet GHG reduction goals and to improve air quality. Consumers also have a strong interest in the electrification of transportation to help address air pollution. Transportation is a significant contributor to the District’s GHG emissions, comprising 24% of the emissions in 2019. While air quality in the District has improved over the last several decades, many residents still face disproportionate exposure risks because of where they live or work and still face health risks. For example, the American Lung Association’s 2020 State of the Air Report gave DC a failing grade for the period from 2017-2019 because of the number of days that the air was unhealthy for vulnerable populations due to high levels of ozone. In the District, these populations are often predominately Black, Brown and Non-White residents.
OPC calls on DOE to recognize the need to integrate equity analysis into its research planning and to center research questions on the needs of disadvantaged communities, citing the Biden Administration's Justice40 Initiative that would target 40 percent of overall program benefits to disadvantaged communities. OPC urges that for EV grid integration, justice should focus on equitable access to technology, the specific technology needs of the housing for low and-moderate-income residents, prioritizing EV adoption in areas hard hit by transportation related pollution, and prioritizing EV-based public transit, taxis and ridesharing.
OPC is advocating for the development and inclusion of robust consumer protections in DOE research plans. The success of EV transition will depend upon the reliability and integrity of new applications and programs.
"Consumers must be protected and confident in making business transactions and well- educated about their options for EV usage and ownership," says People's Counsel Sandra Mattavous-Frye. "Best practices for consumer education materials and legal protections are among the issues essential to a well-conceived rollout and long-term adoption."
OPC urges DOE to ensure that programs to alter consumer behavior to address the additional demand from EV charging, serve all consumers. OPC supports the adoption of “Time of Use” rates along with broad consumer education to help consumers maximize their savings while also helping to moderate system load. OPC also urges DOE to provide additional research on best practices to evaluate equitable distribution of benefits of EV programs, especially to low-and-moderate-income households that rent, live in multi-use dwelling units, or do not own cars and rely on public transit. Moreover equitable distribution costs should be built into any customer incentive programs, focusing particularly on the energy burden of affected consumers in initiatives funded by ratepayers.
Finally, OPC highlights the need to review and consider the appropriate role of distribution utilities, such as Pepco, with respect to EV services in a restructured energy market, as well as what measures might allow all consumers to begin to see greater benefits by unlocking the potential from billions of ratepayer dollars already invested in advanced technologies such as smart meters.
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