April 22, 2013
I am writing to comment on the Second Notice Order published by the Illinois Commerce Commission on the Certification Requirements Applicable to Vendors that Install Electric Vehicle Charging Stations. First of all, I commend the state and the Commission for taking the initiative on this emerging topic and working with a variety of stakeholders to ensure a fair and clear standard.
My main concern with the requirements as laid out in the Second Notice Order is that the burden of informing the utility of the installation of an EV charging station lies entirely with the customer. While I agree that this will streamline and simplify the process, I’m concerned that this may chill or frustrate consumer participation in the EV market. While in theory installing a charging station is comparable to installing a mini-utility on personal property, most people will not think of it this way. Most consumers will probably view a charging station as simply a large outlet, not that different in substance from the outlets in their homes, despite any differences in form. This is indeed part of the allure of the EV - the ease of use and the consumer’s access to and familiarity with the technology. Requiring the consumer to file a set of detailed forms that will no doubt be written in industry jargon with plenty of disclaimers and conditions will conflict with and possibly cancel out the attraction of such simple technology.
I urge the Commission to change this aspect of the requirements and instead make it the responsibility of the installer to provide notice to the utilities. As is required elsewhere in the application for an installation, an installer must be trained and certified through a Commission approved program. Thus the installer will already have the expertise to make filing the forms less burdensome and timely. They would be filing the same form multiple times, becoming more efficient and integrating it into the schedule of an EV charging station installation. I agree with the Ameren Illinois Company’s assertion that having two sets of notifications to the utilities is redundant, but I don’t agree that the burden should fall on the part of the lay person involved in the transaction, but rather the professional that is trained and knowledgable.
However, it might make sense to distinguish between those installing the stations for personal use, and those installing it for commercial use. I think that it would be more reasonable to require someone choosing to start operating a charging station as a business to complete all of the notification documents than to require it of someone just putting a station in their garage. I do agree with the requirement that a consumer notify the utility if they plan on changing their charging station from personal use to a commercial entity. By choosing to enter the commercial electricity market, that person has voluntarily taken on the responsibility of educating themselves about and conforming with electricity regulations. This notification requirement will also filter out those consumers that want to abuse the availability of new technology for personal gain.
As an Illinois resident, I am extremely excited that the state is proactively encouraging and supporting the potential of electric vehicles. I sincerely hope that this commitment to emerging technologies and reducing reliance on fossil fuels will also be reflected in other state policies and actions of the Commerce Commission. I’m not familiar with the State’s incentives (if any) for solar panels on personal homes, but I think that connecting these two technologies would be a great way to reduce the state’s greenhouse gas emissions. I would love to see some acknowledgement of this possibility in the regulation of charging station installation, or perhaps a placeholder that can be later amended if the cost of solar decreases enough that it is more economically feasible.
I hope you will take my comments into consideration, and thank your for your time and the work you are doing.