RE: In the Matter of Electric Vehicles, EV Infrastructure and Electrification of the Transportation Sector in Arizona (Docket No. E-00000A-21-0104)
 
Madam Chair and Commissioners,
 
On behalf of Arizona Solar Energy Industries Association (“AriSEIA”), Solar United Neighbors (“SUN”), and Vote Solar, we would like to commend Tucson Electric Power (“TEP”) for bringing forward a comprehensive Transportation Electrification Implementation Plan (“TEIP”). We want to make our support known and urge the Commission to act swiftly to approve the TEIP.
 
Our organizations have been thoroughly engaged in developing electrification policy as we believe transportation electrification is key to building a cleaner, more flexible, and more affordable grid. The growth of transportation electrification is also an opportunity to make Arizona a leader in the clean energy transition. TEP’s TEIP provides a comprehensive framework for reaching this ambitious goal. Building out electric vehicle (EV) infrastructure has numerous economic and environmental benefits. Implementation of the TEIP will make it more convenient, affordable, and reliable for Arizonans to adopt EVs, while also reducing air pollution.
 
We would like to highlight and applaud some key objectives TEP laid out in the TEIP. First, we appreciate TEP’s willingness to invest in educational campaigns and outreach. Many customers remain unfamiliar with EVs, so it is important to give customers opportunities to learn more and especially to get hands-on experience driving an EV, as TEP has proposed through their “EV Showcase.” We hope that TEP’s proposal to develop multiple marketing campaigns based on segmented customer data will result in educational campaigns that appeal to a wide variety of TEP customers and are equally accessible in English and in Spanish. This will ensure consumers, especially in disadvantaged communities, better understand the benefits of EVs and how to optimize charging, thereby saving money and reducing peak demand. The plan correctly recognizes that although investments in EV charging will positively lead to a reduction in fuel costs, high peak loads on our grid systems need to be proactively minimized through education and awareness of rate structures.
 
Second, we are pleased that the TEIP includes a variety of incentive options to help residential and commercial customers adopt EV charging infrastructure at their homes and businesses. Incentivizing customers to adopt smart charging equipment that contributes to grid flexibility will save all customers money. Above and beyond the upfront cost of purchasing EV charging equipment, many EV adopters will find that they need to upgrade the wiring in their home or business. This additional cost can be a significant deterrent, so we appreciate that the proposed Smart Home and Smart City Programs include an incentive for a panel upgrade for Low- and Moderate-income (LMI) customers, as well as incentives to pre-wire new homes for EV charging.
 
Third, we commend TEP for including incentives to support charging infrastructure for public transit, micro-mobility solutions, and non-profit rideshares. These investments will help to ensure that Arizona residents who rely on public transportation, or cannot afford an EV, benefit from the electrification of the transportation sector.
 
Fourth, we are glad to see that TEP’s plan considers the needs of fleet customers who will rely on the correct planning tools to create cost-effective fleet transitions. Total cost of ownership calculators (TCO) will enable fleet customers to accurately address their needs while transitioning. The proposed assistance to fleet managers also creates an opportunity to educate managers about strategies and technologies to optimize charging and avoid adding to peak load. We hope to see a more developed plan in the near future.
 
Fifth, we appreciate that TEP’s plan includes considerations to proactively manage the grid impacts of transportation electrification as EV adoption grows. The TEIP proposes a managed charging pilot program that would encourage EV drivers to align charging with times of day when the cost of energy is lower or when plentiful clean energy resources, like solar, are available. Managed charging reduces peak demand, which improves grid resiliency and reduces the need to build additional generation. We hope this pilot will provide TEP with experience and information to roll out managed charging programs for all customers with EVs. In the meantime, we support the recommendation to require customers who use the Smart Home or Smart City incentives to purchase a networked charger to ensure that EV infrastructure installed today has the communications equipment necessary to help improve grid flexibility. We are also supportive of TEP’s proposal to conduct a grid impact analysis focused on optimizing the use of distribution assets. Understanding and planning for the growth of distributed energy resources is the best way to keep grid costs low for all customers.
 
Going forward, we provide the following recommendations for TEP’s consideration to improve the success of the TEIP. First, customers should be provided with additional information regarding the enrollment process and  planned program initiation. We would also like to see how the company plans to evaluate and gather data from customers. Second, we support the recommendation to align the LMI incentive with that of other nearby states, at least $1,300, and distribute it as one lump sum instead of dividing it into separate upgrade allowances. Third, we agree that customers who receive an EV incentive should be required to purchase a networked Level 2 charger. Those receiving this incentive should also be encouraged to enroll in a managed charging program or time of use (TOU) rate when available, with the option to opt-out if appropriate.
 
Once again, the TEIP is a victory for Arizona’s economy. The sooner the plan is implemented, the sooner its plethora of benefits can be reaped. We request that the Commission vote to approve the TEIP and proposed budget during the October Open Meeting.
 
Sincerely,
 
Autumn Johnson
Executive Director
Arizona Solar Energy Industries Association (AriSEIA)
[email protected]
520-240-4757
 
Bret Fanshaw
Western Region Director
Solar United Neighbors (SUN)
[email protected]
602-962-0240
 
Kate Bowman
Interior West Regulatory Director
Vote Solar
[email protected]
703-674-8637

​Arizona Department of Transportation
1655 W. Jackson Street
Phoenix, AZ 85007
 
Director Halikowski and ADOT Staff,
 
On behalf of the Arizona Solar Energy Industries Association (AriSEIA), Solar United Neighbors (SUN), and Vote Solar, we write to thank ADOT for crafting and submitting the National Electric Vehicle Infrastructure (NEVI) Formula Program plan for Arizona.
 
Our organizations would like to express our enthusiastic support for the NEVI program. Electrification of the energy sector, including electric vehicles (EVs), is critical to maximize the benefits of clean energy technologies, reduce pollution, and build a more reliable and affordable grid. Each of our organizations have been thoroughly engaged in developing electrification policy. AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. AriSEIA also advocates for sustainable job creation and encourages utilization of Arizona’s greatest natural resource, the sun. SUN represents solar homeowners, many of whom are also electric vehicle owners or enthusiasts, as they endeavor to install rooftop solar. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar is also working to remove regulatory barriers and implement key policies needed to bring solar to scale.
 
We applaud your department for its vision and for seizing this opportunity to secure $76.5 million in funding for Arizona to build out electric vehicle infrastructure in the state. It is critical to develop Electric Vehicle Supply Equipment (EVSE) along interstate corridors over the next five years for Arizona to reach a clean energy future and to promote quality of life for our residents and businesses. Expanding a strategic network of alternative fuel and charging infrastructure and increasing EV accessibility will accelerate the adoption of electric vehicles, making them more convenient, affordable, and reliable for Arizonans. Building out EV infrastructure will result in a number of significant economic and environmental benefits for Arizona. This includes reducing air pollution from the transportation sector, creating new family-sustaining jobs, boosting the economy, and lowering costs at the fuel pump for Arizonans across the state. In sum, we are grateful to see how the NEVI plan will support the building of a resilient, equitable, accessible, and reliable charging network for Arizonans.
 
Going forward, we provide the following recommendations for ADOT’s consideration to improve the affordability and accessibility of Arizona's transition to clean energy vehicles. The growth of EV charging infrastructure will increase electricity usage, and so it is important to simultaneously invest in distributed energy resources in order to mitigate the need to build additional energy infrastructure. Investments in locally sited solar and storage not only contribute to meeting local energy needs, but improve  the resiliency of the grid. It is important that ADOT encourages EVSE owners to set price structures that incentivize the charging of vehicles during off-peak hours. Charging during times when electricity is less expensive will reduce overall costs. We would like to see ADOT require EVSE owners to establish a communication system that allows  drivers to opt-in and notify the EVSE owner when a system is down so that issues can be fixed with little to no delay. Lastly, ADOT should prioritize the needs of current EV drivers and traditionally underserved communities when making decisions about where EVSE should be sited. We encourage ADOT to continue engaging stakeholders and the public in regular conversations and outreach available in both English and Spanish throughout the implementation of the plan.
 
Now more than ever, Arizona should take significant steps to capitalize on the momentum behind the growth of electric vehicles. Each of our organizations are eager to see the swift implementation of ADOT’s NEVI Plan.
 
Sincerely,

Autumn Johnson
Executive Director
Arizona Solar Energy Industries Association (AriSEIA)
[email protected]
520-240-4757
 
Bret Fanshaw
Western Region Director
Solar United Neighbors (SUN)
[email protected]
602-962-0240
 
Kate Bowman
Interior West Regulatory Director
Vote Solar
[email protected]
703-674-8637