Mitigation Trust Proposal
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PALMmO CLEAN RJELS ~\) COALITION November 2 7, 2017 Kendall R. Buchanan Deputy Director, Division of Market and Consumer Services South Carolina Department of Insurance 1201 Main Street, Suite 1000 Columbia, SC 29201 R£: SC Environmental Mitigation Trust- VW Settlement Agreement Dear Ms. Buchanan: We are writing on behalf of the Palmetto Clean Fuels Coalition (PCF), administered by the South Carolina Office of Regulatory Staff- Energy Office (Energy Office). Our purpose in writing is to urge the Department of Insurance, in its capacity as lead agency for the South Carolina portion of the Volkswagen (VW) settlement agreement, to allocate the full15% allowable by the settlement for light-duty zero emission vehicle supply equipment. As a practical matter in South Carolina, this allocation would go toward electric vehicle (EV) charging stations. PCF is South Carolina's designated US Department of Energy Clean Cities coalition.1 PCF is a voluntary partnership of alternative fuel manufacturers, distributors, and supporters who collectively work together to increase the adoption of alternative fuels and advanced vehicle technologies. PCF strives to help public and private entities- as well as individuals- lower fuel costs, improve air quality, and reduce petroleum consumption. PCF held discussions with owners of EVs, electric vehicle supply equipment (EVSE), or charging stations; performed assessments of various alternative fueling stations throughout the State; and consulted with officials at the state and local levels. This work revealed several challenges impeding the development of the EV market in South Carolina - with a lack of charging stations being one such barrier. Therefore, PCF developed a Plug in SC plan both to prepare South Carolina for future EV growth and to recommend strategically targeted charging station deployment sites. Through the efforts of the SC Department of Transportation and PCF, South Carolina recently became the second state in the nation to place alternative fuel corridor signs along its major interstates.2 This effort focuses on public awareness and regional connectivity for alternative fuels, including EVs. While neighboring states are working hard to place their own corridor signs, they are ahead of SC in developing a network of charging stations.3 Virginia released a request for proposal seeking assistance in spending the $12 million (representing 15% of its VW mitigation funds) on EVSE.4 Stakeholders in NC 1 https;/Lcleancities.energv.gov/ 2 bttp:lLealmettocleanfuels.org/afvcorridors 3 httQs:Uwww. afdc.energy.gov/locator /stations/ 4 http:Uwww.deq.virginia.go_vLPrograms/Air/VWMitigation.aspx Palmetto Clean Fuels VW Proposal Page 2 of 8 wrote Governor Cooper also urging that NC "allocate the maximum allowable amount of settlement funds for electric vehicle charging infrastructure and installations." Concerns have been expressed that if South Carolina does not increase its available electric charging infrastructure, movement along the Atlantic Seaboard could be affected. Furthermore, tourists could choose to circumvent South Carolina in their attempt to have charging stations available along their routes. Within the context of this background and knowledge, PCF encourages you- as the beneficiary- to allocate 15% of the mitigation funds for investment in light-duty zero-emission vehicle supply equipment.5 PCF has developed the attached proposal based in part on conversations with electric charging manufacturers, the South Carolina Department of Parks, Recreation and Tourism, representatives from the State's investor-owned utilities, the South Carolina Department of Health and Environmental Control, and the South Carolina Department of Transportation. To support tourism and economic development throughout the State, PCF proposes the strategic deployment of Ieveil, level 2, and DC fast-charging EVSE at highly-trafficked and/or visible locations in need of infrastructure. PCF is also working on ways to expand this initial proposal to invest in additional locations throughout the State, such as major State agencies and tourism attractions. The attached documents serve to establish the basis for this initial recommendation and address the relevant information as referenced on the South Carolina Department of Insurance's website.6 A multitude of factors contribute to the potential for future EV growth in the State. Given South Carolina's strong manufacturing base (especially as it relates to the automotive industry), reliance on tourism, connective interstate network, strong port activity, and commitment to the health and well being of our citizens and environment, South Carolina is poised to be at the forefront of moving goods and people in the cleanest, most efficient, and most economical means possible. To realize its full potential, South Carolina should have the necessary infrastructure in place. The allocation of South Carolina's portion of the VW settlement toward EV charging stations would be a major step in that direction. Again, we appreciate this opportunity and look forward to continuing the work already underway to reduce mobile source emissions and vehicle miles traveled, while promoting the use of alternative fuels and alternative el~frastructure. Maeve S.R. Mason Landon Masters Co-Coordinator Co-Coordinator Palmetto State Clean Fuel Coalition SC Energy Office Enclosures: EVSE Recommendation 5 See Appendix D-2 to the Consent Decree (MDL NO. 2672 CRB (JSC), Eligible Mitigation Actions and Expenditures #9. light Duty Zero Emission Vehicle Supply Equipment. 5 http://doi.sc.gov/889Nolkswagen-iettlement Palmetto Clean Fuels VW Proposal Page 3 of 8 Projected Growth of the EV Sector "In North America, the PEV market has grown by a factor of 10 since 2011, and 2017 is headed toward another record-breaking year" (https://www.navigantresearch.com/ research/ market-data-ev geogra phic-forecasts). According to a new PEV market projection study, EV Outlook 2017, by Bloomberg New Energy Finance group, "By 2040, 54% of new car sales and 33% of the global car fleet will be electric .... EVs become price competitive on an unsubsidized basis beginning in 2025." Advancements in the battery market is a primary factor in this growth. In addition, expanding availability of the low-cost EV models like the Nissan Leaf, Chevrolet Bolt, and Tesla Model 3 are also fueling this growth in the marketplace. Case Reference case j Region Unoted States thousands The Energy Information 7,500 Administration also projects a ... -- growth in EV sales over the next '---------------------------------· several decades. 2.500 -------------------------- ~ ---·= ===== --------------------------- 2016 2018 2020 2022 2024 2026 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 2048 205 - light-Duty Vehicle Sales: Conventional Cars. Gasoline - AE02017: light Duty Vehicle Sales Alternative-Fuel Cars 200 Mile Electric Vehicle - ltght-Duty Vehicle Sales. Alternative-Fuel Cars 100 Mile Electric Vehicle ~ Source U S E11ergy lnfQ(mabon Administration Connectivity Each of the areas that are recommended to receive EVSE are stationed along major corridors that are part of the National Highway System (NHS) Eisenhower interstate and located in South Carolina. These interstates intersect at least one of the three major metropolitan areas in the State. Interstate 1-26 connects three of the State's major metropolitan statistical areas (MSAs) - Greenville, Columbia, and Charleston - in a north-south direction.7 Interstate 1-85 intersects both Greenville and Spartanburg within the State and serves to offer connection to both Charlotte, NC and Atlanta, GA. Interstate 1-77 runs north-south with its terminus in Columbia and therefore serves as a major corridor in the State offering broader connection to Charlotte, NC. Interstate 1-20 runs east-west and intersects Columbia, SC, also serving to offer connection to Augusta, GA. The fifth interstate, 1-95, does not intersect any major metropolitan area in the State, but does serve as a major north-south Major MSA Populations (2012) corridor that spans/connects much of the US Eastern Seaboard. These interstates contribute to an important Source: http://sccommerce.com/ dataa national network of roadways. The total population of South resources/state facts 7 http://www.census.gov/ population/metro/ Palmetto Clean Fuels VW Proposal Page 4 of 8 Carolina is just over 4.5 million. The major MSAs have individual populations that range from 107,456 in Sumter to 767,598 in Columbia.8 Each of the areas recommended also link or intersect the various in state MSAs as well as larger MSAs found in the Southeast. Tourism South Carolina's economy is largely dependent on tourism related to its 187 miles of coastline. Horry County received $3.8 billion in domestic travel expenditures to lead all of South Carolina's 46 counties. Charleston County ranked second with $2.1 billion, followed by Beaufort County with $1.2 billion.9 Range anxiety in relation to EV infrastructure may limit those that own or operate these vehicles from visiting or traveling within the State. A lack of EVSE may also limit visitors with EVs from visiting the State altogether. South Carolina is also home to eight major military installations. Approximately 36,400 active-duty military personnel, 19,100 military reserve personnel, and 10,400 Department of Defense civilian personnel are operating in the State. The most current Statistical Report on the Military Retirement System indicates that over 56,000 military retirees reside in South Carolina.10