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** EV Ordinance Under Consideration Tonight

From: domainremoved <Bob>
Date: Tue, 28 Aug 2018 08:02:37 -0700

Dear City Council Members,

We recommend that the city NOT pass the EV charging station ordinance at
this time for the reasons described below.

The proposed ordinance is well intended but will have unintended
consequences as it seeks to solve a problem that has not been defined and
we do not believe exists. Alternatively, we recommend that the city monitor
the uses of existing EV charging stations to asses the adequacy of supply
and to act if and when needed to address any issues that will then have
been defined.

We have studied this issue in great detail for our recently completed 195
unit apartment community at 777 Hamilton and Station 1300 a mixed use
development currently under construction that will include nearly 1000
parking spaces. Like all building owners we are focused on meeting the
current demand for EV charging and having the infrastructure and
appropriate technology to meet future demand. To not do so would put us at
a competitive disadvantage. We are highly motivated, like all building
owners and major employers, to get it right.

We will not be affected by this ordinance since Station 1300 building
permit applications have all been deemed complete and our garage is only 6
months from completion. Our comments are offered as members of the
community with some knowledge of the issue and who want to see the city get
it right.

Salient points for your consideration are summarize, and explained in
greater detail, below.

1. Justification for the ordinance has not been established.

2. Market forces, not regulatory guesses, should determine the
provision of EV charging station.

3. An over supply of EV charging stations reduces parking for non-EV
vehicles, which will not park in EV spaces.

4. The demand for charging stations at places of work is diminished
because EV owners have a cost incentive to charge at night not during
business hours.

5. Demand for non residential charging stations will be dampened by the
ever increasing driving range of EV’s.

6. The residential requirement for 100% of units to have charging
station is excessive. (At 777 Hamilton 6% of residents own an EV.)

7. Technology is changing rapidly in this embryonic industry. 2018
chargers will be obsolete by 2023; so why install now for a guestimate of
2023+ demand.

8. Do not wire for future EV spaces. Wiring requirements will change
over time. Install conduit, and pull wires when needed.

*Justification---*No where in the staff report or ordinance is there a
statement of the problem and how the ordinance will address that problem.
Instead we are given the explanation that “several members [of the City
Council] expressed interest in expanding the regulations” (Staff Report
18-168-CC, pg 1) and the truism that “access to EV infrastructure is an
important part of making EV a success” (pg 2). It is not demonstrated that
the EV charging needs in the city are not or will not be met under current
Cal Green regulations. We have an admirable desire that is not supported by
any factual assessment of demand or the amount of supply dictated by the
proposed ordinance.

*Current EV Charger Supply Greater than Demand*—At 15% of commercial
parking spaces, the number of EV charging spaces will be substantially
greater than demand, thereby leaving EV chargers spaces empty. Non-EV auto
drivers are inclined not to park in an “EV space”. Effectively, this City
ordinance would reduce the number of available parking spaces in any
development by requiring more EV charger spaces than currently demanded. At
our Hamilton apartment community of 195 apartment units, there are
currently 12 EV autos (6% of the units ) owned by residents. The proposed
requirement of one EV charger per unit is 15 times more than current demand
as shown by a new apartment community with a very tech oriented resident
population. At Hamilton, we installed more EV charger spaces than
required because we knew our residents would demand more than the required
number….we needed to meet market demand for EV spaces or we would suffer
from lower occupancy and rents. *Do not artificially reduce parking
supply by creating more EV spaces than there is demand*.

*EV Auto Owners Charge at Night*—As stated in your staff report, “*most EV
charging occurs overnight at homes*” because the electric rates are
multiple times lower for EV owners who have a charging station at home. So
EV auto owners will not charge their vehicles at commercial locations
during daytime hours that have higher rates.

*EV Auto Range is Increasing*--Tesla, which had the largest market share of
EV autos in 2017 (about 1/3 of the EV only market), has a vehicle range of
310 miles. The second highest market share (at about 20%) is the Chevy
Bolt with a range of 240 miles and the Nissan Leaf (third in market share
at 15%) has a range of either 151 miles for the base model or 225 miles for
the “Plus” version. With these battery ranges and the average commute
time to a Menlo Park employer being 22 minutes (about 10 miles), there is
no reason for a worker to charge an EV auto at a much higher electricity
rate while at work or shopping. EV chargers at retail or office locations
are used at a significantly lower rate than the actual EV auto ownership
(less than 5% in California in 2017).

*EV Charging Technology is Changing*—The Staff Report states:

*A typical level 2 charger costs around $7,500 with additional cost for the
installation and the costs for a level 3 charger would be greater. The
cost associated with the installation of the conduit and wiring typically
includes the cost of materials and the labor associated with the cutting of
concrete and asphalt, trenching and the installation of the conduit and
wiring, with the cost increasing when the EV charging stall is further from
the electrical supply equipment. A typical cost for a distance of less than
100 feet is approximately $25,000 for a single charger installation. There
is some economy of scale for a multiple charger installation, however, the
cost does increase.*

Installing EV chargers for office buildings, retail developments and
multi-family projects is an expensive undertaking. Increasing that
percentage required from 5% to 15% of the parking spaces for commercial and
to one per unit for residential developments of more than 3 units will have
a dramatic increase in the costs. As stated above in the City Staff
report, if you use the low cost of $7,500 per charger that would have
increased the cost of our Hamilton apartments by over $1.3M with 90% + of
those newly required chargers not being used. The EV charger technology
is changing rapidly so the EV chargers installed in 2018 may be obsolete in
2023 rendering many never used installed EV chargers useless or in need of
an upgrade. Just a few years ago, no one thought that cell phones would
be charged wirelessly……when will that be the case for EV charging causing a
revolutionary change in infrastructure?

*EV Ready Parking Spaces Should Not Include Wiring*—As stated above, with
technology changing rapidly including wiring in the EVSE (Electric Vehicle
Supply Equipment) ready spaces will most likely be a waste of money as
different wiring or improved wiring will be needed so owners will have to
replace the wires in the conduit. Including conduit to the spaces is a
good practice as conduit can handle whatever technology improvements are
made in the future.

We are all interested in facilitating EV’s and as building owners we are
well incentivized to meet the demands of our tenants. Let’s monitor the
situation and develop an ordinance if and when needed. New development in
the Willow corridor will offer ample opportunity to test the provisions of
what is being proposed city wide.


Bob Burke and Steve Pierce

Greenheart Land Co.
Received on Tue Aug 28 2018 - 08:02:22 PDT

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