Comment Log Display

Carl Moyer Response


Envision Solar enthusiastically supports the electrification of
transportation and deployment of EV charging infrastructure to
support it.  We enthusiastically endorse the expansion of the Moyer
Program to include guidelines for funding off-grid solar electric
vehicle charging infrastructure. We believe this represents another
opportunity for California to continue in the right direction as it
supports increased adoption of Electric Vehicles by providing
alternative funding for charging infrastructure which isn’t grid
dependent and one which represents one of the most flexible,
cleanest and fastest ways to deploy charging infrastructure in the
industry today.

         Envision Solar respectfully urges the ARB to ensure that
any revision to the Carl Moyer Program integrated renewably
generated and stored energy supplies to the EV charging equipment
wherever it makes sense - even when that infrastructure is not
connected to the grid. Care should be taken to ensure that there is
no language in any of the approved plans which prohibits or
discourages the use of locally generated renewable sources of
energy as a source of electricity for Electric Vehicle charging.
Regardless of who owns the infrastructure the plan should allow for
use of funds in the deployment of off grid solutions as well as
grid connected solutions. Entities should not be financially
penalized or otherwise prevented from using off grid solutions to
energize EV charging infrastructure if those solutions present the
best method of energizing the chargers.
There are many compelling arguments in support of the use of
locally generated and stored renewable energy to supply EV charging
equipment:
1.	The civil and electrical upgrades required for grid tied
chargers are often very time consuming. Permitting, engineering and
other design and integration work can take months putting at risk
the aggressive plans California needs to have in place for the
necessary charging infrastructure to support the EV adoption we
hope to see. Locally generated and stored renewable energy products
negate the need for most of the work associated with “make readies”
and can be deployed in minutes not months. Caltrans, DGS, OIG, Cal
State and many other state and local agencies have experienced
these rapid successful deployments. 
2.	Trenching and other construction work results in negative
environmental impacts especially in remote locations. The use of
turnkey solar powered products reduces the environmental impact at
host sites in many cases to zero.
3.	Construction activities are disruptive to the host sites
resulting in negative impacts and unquantifiable additional costs.
There are few or no required construction activities associated
with the deployment of renewably energized products.
4.	Make readies are very expensive. The rapid and impact free
deployment of a renewably energized EV charger is often much
cheaper than the cost of civil works at a site. 
5.	Grid tied chargers may contribute to grid instability when used
en masse in the future. Locally produced and stored renewably
energy not only does not contribute to grid instability but can
reduce it.
6.	Off-grid solar EV charging is the equivalent of a Strategic
Petroleum Reserve for the electric vehicle. The centralized
generation and distribution common to utility grids creates
significant vulnerability to large scale outages. These outages are
currently expensive to businesses and at least inconvenient if not
dangerous to the constituency. In the future when transportation is
electrified grid outages will no longer be simply inconvenient,
they might create the greatest transportation catastrophe yet seen
in California’s history. The result of a multi hour grid
interruption such as we experienced in San Diego in 2012 could
paralyze large segments of the travelling public. While
considerable thought is being given to intelligently managing
charging and shifting loads, all the current solutions still depend
on the grid being available. Hurricane Sandy taught us that we
might lose the utility grid for days at a time. When that happens,
even grid tied EV chargers with local storage will cease to operate
after a period of time. Locally generated and stored renewable
energy which is not grid connected (or can be islanded) is immune
to such interruptions and may offer the only available charging
during disasters. It would seem prudent to require that at least 20
percentage of all EV chargers are not dependent on the centralized
grid but at a minimum there should be no language preventing
entities from taking advantage of these types of solutions when it
makes sense to do so.
7.	The purpose of California’s push to electrify transportation is
primarily to reduce GHGs. 60% of the electricity supplied by the
grid in California is still carbon based. Renewably energized EV
chargers enable 100% emissions free driving rather than “tailpipe
emissions free” driving. 

In summary, we respectfully urge the ARB to ensure that any
revision to Carl Moyer guidelines include language to add locally
generated and stored renewable sources of energy whenever possible
and to further ensure that there is nothing in the approved plans
which might discourage or prohibit such a use. 
We believe that a combination of all available sources of clean
energy will provide the best solution for EV charging as we move
forward. They should not be mutually exclusive. Locally generated
and stored renewable energy EV charging products which can also
connect to the grid probably offer the greatest security, pollution
reduction and long term benefits to the utilities and the rest of
the community. We urge the Air Resources Board to ensure that these
types of solutions are leveraged wherever possible and to further
ensure that the tax payer money is spent on infrastructure which
generates the most benefits in both the short and long terms.

We thank you for your consideration of this matter.