Interim Solutions needed while New York Public Service Commission moves forward on longer term truck charging infrastructure programs

By Pamela MacDougall and Cole Jermyn

UPDATE: Since the publication of this blog post on April 27, 2023, the New York Public Service Commission has made meaningful progress within its new Medium- and Heavy-Duty Electric Vehicle Charging Infrastructure proceeding. The PSC accepted comments on its initial questions from several dozen parties including EDF, and technical conferences are expected this fall. Despite this, the proceeding will likely continue into next year, leaving many early adopter fleets without sufficient access to charging infrastructure and potentially setting the state behind on its electrification goals. With deadlines from the Advanced Clean Trucks rule and emissions reductions goals from the Climate Leadership and Community Protection Act rapidly approaching, now is the time to kickstart the deployment of truck and bus charging infrastructure in New York. The state must implement interim solutions while the PSC continues to move forward. Primarily, changes can be made to the medium- and heavy-duty make-ready pilot program by expanding its eligibility to be more accessible to different types of fleets, depot owners and repair shops. Additionally, the program’s budget can be expanded, as the Commission’s Staff has already proposed. The Commission must also work with its sister agencies including the New York State Energy Research and Development Authority and the Department of Transportation to support near-term deployments of charging infrastructure. Not only will these solutions help provide the charging infrastructure that fleets need now, but the PSC will have the learnings it needs to have a full-scale medium- and heavy-duty charging program in the future. Environmental Defense Fund commends the PSC for the progress made so far on the proceeding and is looking forward to working with the commission to ensure no time is wasted in deploying necessary charging infrastructure improvements.  

After much anticipation, New York is taking a significant step to accelerate the rollout of zero-emission trucks and buses. Last week, the New York Public Service Commission formally opened a proceeding aiming to deploy the charging infrastructure needed to serve medium- and heavy-duty electric vehicles. This is a critical opportunity for the state and its utilities to make real progress towards achieving New York’s ambitious climate and truck and bus electrification goals.

New York is already on its way to get these vehicles on its roads and to meet these targets — having adopted California’s Advanced Clean Trucks Rule in 2021, which requires auto manufacturers to invest in, produce and sell an increasing percentage of zero-emission trucks. The state also aims for all new school buses to be electric by 2027, with school bus fleets ready to fully electrify by 2035. But to carry these objectives through, regulators and utilities must ensure that there is sufficient charging infrastructure to adequately support the coming zero-emission vehicles.

Although New York has existing pilot charging programs, several issues in the current programs have limited their use. To fix this, EDF, along with a group of other non-profits, filed a petition with the PSC in 2022 calling for this dedicated, comprehensive proceeding.  While improvements to the current pilot programs are coming, the issue of truck and bus charging will not be solved by nibbling around the edges of past programs.

For these charging programs to be effective, there must be a holistic effort that includes support for make-ready infrastructure, requirements for extensive marketing and outreach, proactive planning and managed charging, such as:

• Robust support for make-ready infrastructure — Make-ready infrastructure, which includes the infrastructure needed to bring electricity from the grid to a customer’s meter and on to their chargers and the grid upgrades to power the new chargers, represents a substantial up-front cost for electrifying fleets. Covering some or all of these costs will lower the cost of electrification and encourage multi-state fleets to prioritize a transition to zero-emission vehicles in New York. Recent analysis commissioned by EDF shows that spreading truck and bus make-ready costs across all utility customers can actually benefit them, as the added utility revenue from these vehicles charging matches or outpaces the costs involved. This could drive down electricity prices for all ratepayers while providing strong encouragement to fleets to electrify.
• Robust Marketing, Education, and Outreach — Developing programs that help both fleets and utilities share information must be a focus of the proceeding. The PSC must require the utilities to actively identify and reach out to fleets to discuss their electrification plans and how they can help in the electrification process. This work will give the utilities access to the best available information on how fleet electrification may impact their systems and what upgrades will be needed and when. The PSC must also ensure that community groups and environmental justice organizations have clear, real opportunities to share their priorities and concerns around truck and bus electrification, both as part of this proceeding and throughout the implementation of the utilities’ programs.
• Proactive Forecasting and Planning — Expanding New York’s grid capacity is paramount to support a transition to zero-emission trucks and buses. The earliest fleets to electrify have been more likely to do so at sites where sufficient grid capacity already exists for their chargers. However, as medium- and heavy-duty vehicle electrification becomes widespread, bringing additional fleets online will require distribution system upgrades that can take several years. This timeline conflicts with New York’s rapid electrification targets, as well as the normal purchase timeline for these vehicles. To shorten this timeline, utilities need the authority, with proper oversight and guardrails on spending, to start work on system upgrades where necessary in advance of fleet electrification. The PSC has recognized this, directing the proceeding to identify “high priority infrastructure upgrades before issues stemming from capacity needs arise.”
• Distributed Energy Resources and Vehicle-Grid Integration as Grid and Fleet Solutions — While distributed energy resources and vehicle-grid integration can add up-front costs to projects, they can also provide long-term benefits. Tools like on-site solar and battery storage can help fleets decrease their charging costs by shifting charging away from high-demand periods on the grid and reducing a fleet’s peak demand. Fleets can also implement managed charging to control when and how quickly charging happens to decrease costs and grid impacts. During the highest demand periods, vehicle-to-grid technology allows EVs to send power back to the grid if necessary. These solutions benefit the entire grid by reducing customers’ impacts on the system, mitigating the grid upgrades needed to serve them and reducing the cost to ratepayers.

The PSC now has an opportunity to be a national leader in the transition to zero-emission truck and bus deployment and push the state closer to its climate goals. Widespread adoption of zero emission trucks and buses will reduce greenhouse gas emissions and harmful local air pollution, benefiting the climate and the health of communities throughout the state. The proceeding must now move quickly and thoughtfully to support the near-term tasks needed to expand and improve charging infrastructure. It is long-awaited, much-needed and EDF is excited to continue to engage in this critical work.