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NEW EVCA ANALYSIS: CARB Electric Vehicle Charging Mandate Will Cost Small Businesses, Retailers and Others $700 Million

Regulations will add $3,000 to the cost of operating each charging station and slow deployment of EV Charging Stations

Sacramento – The Electric Vehicle Charging Association (EVCA) today released a new analysis of regulations from the state air resources board which concludes that the EV charging mandates will cost small businesses, retailers, and other site hosts more than $700 million over the lifetime of the charging stations, including at least $142 million in Southern California.  This includes $76.7 million in Los Angeles County, $10 million in Orange County, and $30.9 million in San Diego County.  

“This technology mandate would not only add unneeded costs to EV charging in California, it will also put the brakes on EV adoption,” said   Abdellah Cherkaoui, Board Chair of EVCA. “While well-intentioned, this will slow the deployment of EV charging stations.  We need more charging stations, not fewer. That’s why we support legislation sponsored by Assembly Member Marc Berman that gives drivers choices in how they pay for EV charging without putting costly technology mandates on station owners.”
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EVCA’s analysis of the Air Resources Board’s regulations finds that the new rules will add $3,000 to the cost of a charging station over its lifetime - $371 for the hardware and $270/year in operations and maintenance (O&M) costs [1].  In total, EVCA finds that these regulations will slow the deployment of EV charging stations and stunt California’s efforts to reach 250,000 chargers over the next 10 years.

EVCA strongly supports legislation AB 1424, which provides a better alternative to the regulations.  AB 1424 gives electric vehicle drivers choices when it comes to paying for EV charging sessions without resorting to technology mandates.

About EVCA:
Founded in 2015, the Electric Vehicle Charging Association is a not-for-profit organization that brings together leaders throughout the value chain of the electric vehicle charging industry to advance the goal of a clean transportation system in which the market forces of innovation, competition, and consumer choice drive the expeditious and efficient adoption of EVs and deployment of EV charging infrastructure.
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EVCA’s full analysis follows:

Don’t Stall California’s Shift to EV Charging



Hundreds of new electric vehicle (EV) models will hit California roads over the next decade. To support this massive growth, drivers need a range of options to pay for EV charging. Yet today, there is a major dispute in Sacramento over the rules governing EV charging payments that could slow the deployment of EV chargers across the state.   
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California is at a crossroads.  The state can give drivers a choice in how they pay for EV charging with the latest in secure options or mandate outdated technologies that will slow the deployment of EV charging stations statewide.  How this is decided will impact the adoption of EVs and EV charging for years to come.

Legislation sponsored by Assembly Member Marc Berman (AB 1424) would expand access to EV charging and allow drivers to pay for charging sessions using the latest secure technologies including contactless credit cards, smartphones, and RFID cards. This framework takes a forward-looking approach and will stimulate investments in the fast deployment of charging stations in rural areas, disadvantaged communities, and in every corner of the state. The legislation has broad support from innovative charging companies that are working to buildout an electrified transportation infrastructure.

By contrast, the state air regulator is imposing a $700 million technology mandate that will slow the buildout of EV charging stations and could very well put drivers at risk for skimming and range anxiety. The California Air Resources Board (CARB) is requiring that every charging station include a specific payment option – legacy credit card readers, which are already being phased out in Europe and Canada over security and maintenance concerns.  

CARB’s Mandate Raises Major Concerns

Cost - $700 million in costs could slow EV charger deployment across California. By CARB’s own calculation, an EMV chip reader mandate will add approximately $3,000 to the cost of a charging station over its lifetime - $371 for the hardware and $270/year in operations and maintenance (O&M) costs[1].  Given that the state still needs to deploy an additional 230,000 stations to reach its 250,000 by 2025 target, that amounts to hundreds of millions of dollars in costs for EMV chip readers. This spending could be used to deploy tens of thousands of additional charging stations.

Statewide this technology mandate would cost $700 million and would be borne by station owners.  In Southern California, we estimate that it would cost at least $142 million including $76.7 million in Los Angeles County, $10 million in Orange County, and $30.9 million in San Diego County.  
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Given the scope of the state’s charging infrastructure needs, EVCA does not believe this is the best use of limited capital, especially considering there are other viable credit card reader technologies currently in use. 

Reliability – EMV chip readers are known to have reliability issues due to weatherization and has taken many gas pumps offline. The state has only 8,000 gas stations, which is less than 1% of the charging stations needed by 2025. This percentage becomes even smaller when taking into consideration how many charging stations the state will need to support its goal of 5 million zero-emission vehicles by 2030. The demands of maintaining the operation of such a large number of chargers will be significantly more complex if charging companies are required to maintain EMV chip readers as well. Contactless card readers do not have these same reliability issues.

Innovation and Future-proofing – Mandating an EMV chip reader now saddles charging companies with one technology that is already beginning to phase out. North American and European companies are increasingly using contactless credit card readers, and neither Canada nor Europe mandate EMV chip readers on their charging stations. By keeping the payment standard technology neutral, the state would enable charging companies to invest in other technologies that are gaining more prominence and would not force the obsoletion of investments in contactless credit card readers to date.
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Bottom line
CARB’s rules would force the installation of legacy credit card readers, which are vulnerable to ‘skimming’ and ‘shimming’ schemes that cyber criminals have used to target consumers.  Cybersecurity experts believe that this approach could allow cyber criminals to target EV drivers and expose them to credit card fraud and identity theft. The U.S. Secret Service regularly warns drivers about the dangers of swiping credit cards at fueling stations through ‘skimming’ and ‘shimming’ schemes. Why would we transplant the security vulnerabilities of yesterday onto the clean fuel options of today and tomorrow?

At a time when lawmakers should be working to protect drivers from fraud and expand access to EV charging in the state, CARB’s misguided mandate would do just the opposite. It would force business owners to install charging stations with legacy credit card readers – a technology that the market is not even asking for. A recent analysis found that at stations where legacy credit card readers are currently offered, drivers chose to use those readers for payments less than 1% of the time.  
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California should be encouraging EV charging investments to be made in underserved areas where it’s needed most, not mandating that stations be built with outdated and insecure technology. 

The stakes have never been higher for EV charging in California.  EVCA supports passage of AB 1424 because it provides broad access to innovative charging stations without imposing unnecessary technology mandates.

Make Your Voice Heard
The California Senate Appropriations Committee is set to take up AB 1424 later this week.  Call or tweet them in support of AB 1424. Tell them you oppose the mandates and support greater driver access to EV charging.  

Senate Appropriations Committee Members
Senator
​​Sacramento Office
​District Office
Twitter Handle
Anthony J. Portantino
(916) 651-4025
​(818) 409-0400
@Portantino
Bob Wieckowski
(916) 651-4010
(510) 794-3900
@BobWieckowskiCA
Brian W. Jones
(916) 651-4038
(619) 596-3136
@SenBrianJones
Jerry Hill
(916) 651-4013
(650) 212-3313
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Maria Elena Durazo
(916) 651-4024
(213) 483-9300
@SenMariaEDurazo
Patricia C. Bates
(916) 651-4036
(760) 642-0809
@SenatorPatBates
​Steven Bradford
​(916) 651-4035
(310) 412-6120
​@StevenBradford
http://findyourrep.legislature.ca.gov/
Picture
Electric Vehicle Charging Association
​Senator Office Building
1121 L Street, Suite 309
Sacramento, CA 95814
Photo used under Creative Commons from EVgonetwork