2020 National Annual Report to U.S. EPA Public Version

1 2020 National Annual Report to U.S. EPA (Proprietary and Confidential)

Contents 1. Introduction ...... 3 2. A Network of Electric Vehicle Charging Stations ...... 4 2.1. Introduction ...... 4 2.2. Electrify America’s DC Fast Charging Network ...... 4 2.2.1. Acquiring Sites in Station Target Zones ...... 4 2.2.2. Constructing a Network of DC Fast Charging Stations ...... 5 2.2.3. Ultra-fast Electric Vehicle Charger Technology ...... 7 2.2.3.1. Chargers and Equipment Ordered and Delivered ...... 9 2.2.4. Electrify America Ultra-Fast Charging Station Operations ...... 10 2.3. Level 2, Workplace, and Multiunit Dwelling Charging Stations ...... 11 2.3.1. Charger Technology ...... 12 3. Education, Awareness, and Marketing ...... 13 3.1. Brand-Neutral ZEV Education and Awareness Media Campaign ...... 13 3.2. Sponsorships ...... 15 3.3. Branded Marketing ...... 16 4. Vendor Survey ...... 18 5. Corporate Citizenship ...... 19 5.1. Enabling Electric Transportation ...... 19 5.2. Environmental Sustainability ...... 20 5.3. Community Engagement and Impact ...... 20 5.4. Equality and Diversity ...... 21 6. Update on Cycle 2 Spending Forecast...... 23 7. Schedule of Creditable Costs ...... 24 8. Supplemental Schedule of Creditable Costs ...... 28 9. Attestation by Third-Party Reviewer ...... 31

2 2020 National Annual Report to U.S. EPA

1. Introduction Electrify America, LLC, is investing $2 billion in financially sustainable business opportunities that advance the use of Zero Emission Vehicle (ZEV) technology, $800 million of which must be spent in California. From its inception in 2017, Electrify America has moved rapidly to implement its $2 billion ZEV Investment Commitment.

As detailed below, Electrify America’s activities in 2020 were focused on implementing the Cycle 2 National ZEV Investment Plan and adapting to operating during the COVID-19 pandemic.

During 2020, Electrify America opened 152 Figure 1 - Electrify America Celebrated its 500th Station new public charging stations with 624 Opening in November 2020 individual DC fast chargers network wide, at a pace of approximately three stations per week. Electrify America completed two cross-country routes, which allow electric vehicle (EV) drivers to travel from coast to coast using the largest open DC fast-charging network in the United States.

Consistent with Electrify America’s focus on providing a high-quality charging experience, Electrify America also introduced simple, kilowatt-hour pricing in California and 24 other states; launched “Plug&Charge” capabilities across the nationwide network; and significantly expanded customer service and station monitoring capabilities.

Electrify America continued investing in the “Normal Now” brand-neutral education and awareness campaign, and it also launched the “Hello, Freedom” campaign, which promotes the freedom to travel among electric vehicle (EV) owners and intenders. Electrify America also enabled virtual ride and drive activities during the COVID-19 pandemic and sponsored the education and awareness building activities of other organizations.

Electrify America publishes this annual report to share the progress and impact of its Cycle 2 investments in 2020.

3 2020 National Annual Report to U.S. EPA

2. A Network of Electric Vehicle Charging Stations 2.1. Introduction As laid out in the Cycle 2 National ZEV Investment Plan, Electrify America is developing a network of electric vehicle charging stations along highly traveled highway corridors, on critically important regional routes, and in 18 carefully selected metropolitan areas (Figure 2). The planned network, when combined with investments made in Cycle 1, will consist of approximately 3,500 DC fast charging dispensers at approximately 800 charging station sites built or under development nationwide, including in California. The network deploys cutting-edge technology to deliver convenient and customer-centric charging, connecting California to the Electrify America national1 network in 45 other states.

2.2. Electrify America’s DC Fast Charging Network In 2020, Electrify America continued development of Cycle 2 DC fast charging stations by identifying target locations (known as “target zones”) for each station location using a proprietary station siting methodology; securing real estate on which to build each station; and then designing, permitting and constructing stations at each site secured.

2.2.1. Acquiring Sites in Station Target Zones Electrify America must acquire access to a site in each target zone before it can build a DC fast charging station.

In each target zone, Electrify Figure 2 - Electrify America's Cycle 2 National Investments America considers multiple real estate leads, based on their unique attributes, such as the availability of three-phase power, site lighting, and access to customer amenities. Throughout the site acquisition process, Electrify America works closely with 196 electric utilities to identify efficient locations from a grid perspective and those with the lowest service connection costs for Electrify America. To acquire high- quality sites, Electrify America has also entered into master agreements with 48 large-scale real estate owners that provide access to sites nationwide,2 including agreements with Love’s Travel Stops, Meijer,

1 The Annual Report to EPA covers investment in the United States, excluding California, pursuant to Section 2.9 of Appendix C of the Partial Consent Decree. Unless noted otherwise, “national” or “nationally” refer to the United States, excluding California. 2 Electrify America’s announced real estate station site hosts with multiple stations include Albertsons, Bank of America, Brixmor Property Group, Brookfield, Casey’s General Stores, DDR Corporation, Federal Realty Investment Trust, Fulcrum Property, Global Partners LP’s Alltown, Jamestown, Kimco Realty Corporation, Kroger, Kum and Go, Love’s Travel Stops, The Macerich Company, Meijer, Pan-Cal Corporation, the Save Mart Companies, Sheetz, Inc., ShopCore Properties, Simon Property Group, Site Centers Corporation, Target Corporation, ValueRock Realty Partners, Walmart, Washington Prime Group, and Westfield.

4 2020 National Annual Report to U.S. EPA and Westfield announced in 2020. Electrify America also collaborates with owners of desirable individual properties across the nation. 2.2.2. Constructing a Network of DC Fast Charging Stations Electrify America made significant progress towards the permitting, construction, energization and commissioning of ultra-fast charging stations during 2020, opening ultra-fast charging stations over the course of the year at a network-wide pace of approximately three stations per week. The 152 stations opened during the year included 82 stations nationally. In the summer, Electrify America completed its first cross-country routes – from Washington, DC to Los Angeles and from Jacksonville to San Diego.3 Nationally, the number of station sites permitted increased 39%, the number of stations constructed increased 32%, and the number of stations commissioned increased 27%, during the year.

The COVID-19 pandemic emerged as one of Electrify America’s greatest challenges in March 2020. Electrify America responded by Figure 3 - National Site Construction Status prioritizing the health and wellbeing of employees, vendors, and contractors, implementing mandatory telework and imposing travel restrictions that remained in place through the end of 2020.

However, by adapting rapidly to COVID-19 related restrictions by governments and station site hosts, Electrify America was able to make significant progress in its station development pipeline over the year. While the pace of station deployment slowed in Q2, Electrify America opened 58 ultra-fast public charging stations nationwide in the final quarter – a pace just short of a new station opened every business day. Electrify America also opened its 500th station nationwide in Q4.

To accomplish this rapid development pace, Electrify America has contracted with highly qualified and experienced engineering and construction firms to complete DC fast charging station permitting, design and installation work. These contracting firms, which together employ nearly 7,000 people nationwide, have managed the installation of thousands of DC fast

3 “Electrify America Completes Its First of Two Electric Vehicle Fast Charging Cross-Country Routes.” June 24, 2020. https://media.electrifyamerica.com/en-us/releases/100

5 2020 National Annual Report to U.S. EPA chargers across the U.S., making them some of the most experienced engineering and construction companies in the industry.

Although Electrify America opened ultra-fast charging stations at a rapid pace during 2020, in some areas of the country Electrify America and its contractors continued to encounter challenges and issues, particularly with regard to “soft costs,” such as permitting timeframes and utility station energization.

The emergence of “soft costs” as a barrier to charging station deployment was well documented in a landmark 2019 Rocky Mountain Institute report, which concluded:

To our surprise, we found that the greatest opportunity for cost reduction lies in “soft costs”: process costs, marketing costs, opportunity costs, the cost of delays in permitting, and so on …. We strongly suspect that soft costs are a big part of the reasons why charger installation costs in the United States are three to five times the cost of the charger itself, a much higher ratio than that seen in Europe…. Indeed, soft costs were frequently cited as more significant cost drivers than charging station hardware in the United States.4

In Electrify America’s Figure 4 - New Jersey Permitting Duration experience, these soft costs result from delay. In particular, the average time to complete the permitting process for DC fast charging station sites in New Jersey was 108 business days, or about five and a half months – roughly twice as long as the average length of permitting processes in the rest of the nation. In 2020, Electrify America worked with New Jersey’s legislative leadership with the goal of addressing this barrier to EV adoption and charging station investment in New Jersey.

Electrify America also encountered challenges with new utility service interconnection processes across the nation, and this process now takes 23 weeks on average. The quantity of locations and magnitude of power required at Electrify America’s ultra-fast charging station sites requires significant effort from utilities to validate power availability, design utility service, create easements, and schedule construction crews.

In some, but not all, cases, adding an Electrify America charging station requires upgrades to the utility’s distribution system.

As of the end of 2020, Electrify America had requested but not received the final engineering design for interconnection from utility companies at 51 station sites. Electrify America had completed station construction at 38 sites that were not yet open to the public because they were awaiting the addition of

4 Chris Nelder and Emily Rogers. “Reducing EV Charging Infrastructure Costs.” Rocky Mountain Institute, 2019, https://rmi.org/ev-charging-costs.

6 2020 National Annual Report to U.S. EPA electrical equipment (e.g., transformers), utility inspection, utility energization and commissioning. Of these, nine station sites had passed final utility inspection and were awaiting energization.

Utility interconnection delays during 2020 can be partially attributed to the COVID-19 pandemic, which made it more difficult to complete easements between the utilities and the station site hosts. Easements are necessary to add electrical service to Electrify America’s stations, and they must be physically signed by executives at both the utility and the site host in the presence of a notary public. With many Americans working remotely and avoiding physical contact with others, and with the retail industry experiencing significant economic upheaval and staffing changes, notarizing documents physically and in-person emerged as a significant cause of delay. Unfortunately, unless local governments begin accepting the validity of electronic notarization, Electrify America anticipates that this cause of delay will persist into 2021.

2.2.3. Ultra-fast Electric Vehicle Charger Technology Electrify America’s customer-centric stations use the most advanced technology ever deployed for convenient, fast charging. In 2020, Electrify America focused on using this technology to provide the highest quality open network charging experience in the industry.

Electrify America’s charging systems were the first 350 Figure 5 - Electrify America's Transformational kW chargers with state-of-the-art liquid-cooled cables Ultra-fast Charging Technology certified to UL standards in the United States.5 The Electrify America ultra-fast charging network has grown to be by far the largest ultra-fast, non-proprietary network in the United States. In Q4 2020, Electrify America charging stations made up approximately 85% of all non- proprietary charging stations in the country with chargers capable of delivering maximum power levels at or above 120 kW (Figure 6).

Electrify America’s highway and regional route stations are equipped with chargers capable of delivering maximum power levels from 150 kW to 350 kW. The chargers are also able to step down to lower power levels for vehicles equipped for lower powered DC fast charging. At maximum continuous power, 350 kW chargers are able to deliver approximately 20 miles of range per minute to a vehicle capable of receiving such power, vastly improving the customer experience.

Metro charging stations feature configurations of either three, four or six DC fast chargers, reducing queuing times

5 Neither liquid-cooled cables nor 350 kW charging had been deployed commercially in the United States before the Electrify America network. As a result, Electrify America leases the Center of Excellence for equipment quality control and validation.

7 2020 National Annual Report to U.S. EPA and providing redundancy in high-utilization urban areas. A significant fraction of metro stations feature 150 kW chargers, and Electrify America is increasing the power level of its DC fast chargers with lower power levels where it is appropriate and feasible.

Electrify America’s public Figure 6 - Electrify America Stations Account for 85% of 120+ kW Charging DC fast charging stations support both the CCS Combo and CHAdeMO connectors.6 In recent years, an increasing percentage of non-Tesla EVs sold in the U.S. have relied on the CCS standard, and CCS is now the non-proprietary standard of choice for 31 automakers in the U.S. market.7 In July, the last auto alliance selling vehicles with CHAdeMO ports in the United States announced that its new models would use the CCS standard in North America. Electrify America’s public ultra-fast stations typically have more CCS chargers than CHAdeMO chargers per station site, but Electrify America continues to see more use of CCS chargers on a per-charger basis. In 2020, CHAdeMO chargers delivered 11% of the power dispensed at Electrify America stations nationally, decreasing from 15% in 2019. In 2020, Electrify America monitored these usage trends extremely closely and concluded that the current network of CHAdeMO chargers provided by Electrify America and other charging companies is likely to sufficiently meet the future needs of CHAdeMO vehicle drivers.

All of Electrify America’s public DC fast charging stations accept multiple forms of payment, and memberships are never required, in order to ensure an easy and open customer experience. In 2020, we continuously improved the payment experience by mobile app (Electrify America’s app and some automaker apps) and by credit/debit card readers through software updates.

In Q4, Electrify America became the first charging provider in North America to launch “Plug&Charge,” which allows EV owners to begin a charge without reaching for their wallet, smartphone or bank card.8 After a brief online registration, drivers can automatically pay for charging by simply plugging in their EV. The charger communicates with the vehicle to identify, authenticate, authorize and bill the customer’s registered account for the charging session. The entire process allows for a seamless charging experience for the customer. This capability was enabled at all Electrify America chargers across the U.S. in advance of the December arrival of Plug&Charge-capable EVs, including the 2021 Ford Mustang Mach-E.

6 Some models of vehicles utilizing proprietary charging systems must use an adapter at Electrify America stations. 7 “Electrify America Comment regarding Staff Workshop on Future Equipment Requirements for CALeVIP.” December 14, 2019. https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=17-EVI-01 8 “Electrify America Simplifies Charging Experience with Innovative Plug&Charge Payment Technology.” November 16, 2020. https://media.electrifyamerica.com/en-us/releases/123

8 2020 National Annual Report to U.S. EPA

Figure 7 - Electrify America Implemented Plug&Charge in 2020 The Plug&Charge feature is enabled by advanced vehicle-to-grid communication technology that utilizes encrypted security measures. It follows the ISO 15118 standard, an international standard that outlines the secured communication protocol that an EV and charging station should use to recharge the EV’s battery. It enables simplified charging functionality for the CCS connector.

Finally, all Electrify America DC fast charging stations support cellular connectivity and are networked, using open protocols compliant with Open Charge Point Protocol (OCPP) version 1.6 or higher.9 These capabilities were managed for Electrify America in 2020 by Greenlots.10 Electrify America has also exchanged roaming specifications with most U.S. charging networks.

2.2.3.1. Chargers and Equipment Ordered and Delivered Electrify America ran a series of competitive solicitations in 2019 in order to procure the hardware needed to build Cycle 2 ultra-fast charging stations. Chargers are scheduled to be delivered to station sites upon commencement of construction. During 2020, 430 DC fast chargers were delivered to new station sites.

In 2020, Electrify America made the decision, after a detailed analysis, to replace some Cycle 1 chargers in order to meet customer reliability expectations in the most cost effective manner. Primarily during Q3, Electrify America replaced 482 chargers, and the reliability of these charging stations has dramatically improved.

Electrify America has also ordered battery storage capacity to mitigate high demand charges, reduce on- peak energy charges, and ease grid loads.11 During 2020, Electrify America identified destinations of battery systems based on site-specific limitations, ongoing changes in utility rates, and utility grid needs nationally. By the end of the year, all of the 51 applications that Electrify America submitted to electric utilities for permission to connect battery systems had been approved, and 33 battery systems were operational.

9 Electrify America’s public stations will be equipped with back end systems that can use Open Charge Point Interface (OCPI) 2.1 to communicate with other networks and Open InterCharge Protocol (OICP) to be able to connect to roaming platforms, when a business agreement is secured, in a manner that does not require use of any particular firm’s intellectual property. 10 The network controls are hosted by Amazon Web Services (AWS), which allows a high security standard. Electrify America undertook intensive testing to approve AWS as a safe and secure environment, as well as security audits of Greenlots as part of the licensing of the network. Also, Electrify America selected a vendor to perform architecture reviews and penetration tests to provide data security. 11 “Electrify America Adds Tesla Battery Storage To More Than 100 New Charging Stations.” February 4, 2019. https://media.electrifyamerica.com/en-us/releases/48

9 2020 National Annual Report to U.S. EPA

Electrify America was ultimately successful in gaining approval for these behind-the-meter systems, but we encountered numerous challenges, including utilities that had no process in place and many that considered the storage to be added load or generation. These battery systems are designed to reduce peak load and lower demands on the distribution system. Treating them as new load – in addition to the EV charging station load – serves as a barrier to rapid deployment efforts, and frequently leads to rigorous, time-intensive interconnection studies.

2.2.4. Electrify America Ultra-Fast Charging Station Operations Electrify America is committed to providing a reliable, high-quality, and customer-centric charging experience. In 2020, assuring a quality charging experience was our highest priority, and Electrify America increased customer service, network operations, training, and service capabilities.

Over the course of 2020, Electrify America saw a substantial increase in customer activity and station utilization, whether measured by the number of sessions or kWh delivered. Between January and December, the number of monthly charging sessions rose more than 80% (from 11,580 to 20,936), and the number of charging sessions per open charger increased 48% (from 8.3 to 12.3). These gains were accomplished despite an approximately 60% reduction in utilization at the beginning of the COVID-19 pandemic. Electrify America expects that station utilization will continue to rise as the public health conditions improve.

To support increasing customer activity and station utilization, Electrify America increased the capacity of its network operations center in 2020. In Q2, Electrify America launched an effort to consolidate existing training materials and to develop new trainings and curricula for the Customer Support Center, the network operations center, the station commissioning team, and service and maintenance field technicians. This comprehensive training approach facilitated more seamless operation of Electrify America’s ultra-fast charging station network.

As Electrify America’s stations are not staffed, the Electrify America Customer Support Center plays a critical role in ensuring reliable, customer-centric charging experiences. Twenty-four hours a day, seven days a week, the Customer Support Center team provides support for customers, whether they need assistance initiating a charge at an Electrify America charging station or have general questions.

Electrify America recognizes the importance of providing our customers with a reliable, seamless, and stress-free experience when contacting the Customer Support Team. Calls in to and out of our Call Center are evaluated on an ongoing basis to ensure we are consistently providing customers with an experience that exceeds their expectations. Evaluated calls are shared with the team to review strengths and learning opportunities as we are continuously striving to promote greater ZEV adoption and strengthen customer relationships.

The Customer Support Center staff provides excellent and prompt customer service. In 2020, the Customer Support Center handled 47,477 calls, a 79% increase from the call volume in 2019, and the average wait time to speak with a Charging Specialist was just five seconds. In 2020, the average call length was just under nine minutes.

10 2020 National Annual Report to U.S. EPA

As the Electrify America network continues to grow, the scale of the operation and the methods by which customers can engage in conversation with the Center’s team has expanded. For example, contact center staff also assist customers via chat and respond to customer email and direct messages sent via social media platforms.

To increase and simplify access to stations, Electrify America expanded collaboration with automakers. In April, Electrify America and Kia launched a special pricing plan for Kia Niro drivers.12 In June, Electrify America and Ford announced that buyers of Ford’s Mustang Mach-e would receive approximately five “complimentary 'fill-ups'” at Electrify America stations.13 And in September, an eighth automaker announced complimentary charging on Electrify America’s network when Volkswagen of America announced that buyers of its new ID.4 electric SUV would receive three years of unlimited charging at Electrify America stations.14

Electrify America also focused on simplifying the charging customer experience in 2020. In September, Electrify America began to charge customers in California and 24 other states by the kilowatt-hour (kWh). Electrify America listened to feedback from electric vehicle owners, potential customers, and longtime industry advocates, which demonstrated the growing preference by EV drivers for pricing by the quantity of energy delivered to the vehicle. The new pricing structure is fair, consistent, and delivers a simplified charging experience. Rates start at $0.31 per kWh.15

In order to ensure that the Electrify America network is open and accessible to customers regardless of the brand of vehicle they drive or their charging network membership, Electrify America’s public DC fast charging stations accept credit and debit card payments via a card reader on every charger. However, Electrify America users increasingly preferred app activation in 2020, with only 24% of sessions activated by credit or debit card, down from 34% in Q4 2019.

2.3. Level 2, Workplace, and Multiunit Dwelling Figure 8 - EV Charging at Workplace/MUD Sites Charging Stations In 2020, Electrify America continued to work with its turnkey vendors (EV Connect, Greenlots and SemaConnect) to provide charging services at workplace and multiunit dwelling charging stations built during Cycle 1. More than 1,190 charging ports across 227 sites were operational. In 2020, the program’s L2

12 “Electrify America, Kia Motors America Offer DC Fast Charging Plan for Kia Niro EV drivers.” April 8, 2020. https://media.electrifyamerica.com/en-us/releases/93 13 “Ford Mustang Mach-E Customers to Receive Up to Five Complimentary 'Fill-Ups' at Electrify America Charging Stations.” June 15, 2020. https://media.electrifyamerica.com/en-us/releases/99 14 “Electrify America and Volkswagen of America Announce Agreement Providing Unlimited Charging Plan for Owners of the All- New 2021 VW ID.4 Electric SUV.” September 21, 2020. https://media.electrifyamerica.com/en-us/releases/112 15 “Electrify America Introduces New Pricing Structure Featuring Kilowatt-Hour Pricing in 23 States and District of Columbia; Reduced Rates for States with Minute-Based Pricing.” September 16, 2020. https://media.electrifyamerica.com/en- us/releases/111

11 2020 National Annual Report to U.S. EPA workplace and MUD stations delivering approximately 1.1 gigawatt-hours to vehicles. 2.3.1. Charger Technology Electrify America-funded workplace and MUD charging stations funded during Cycle 1 typically have four to six L2 chargers, each with a minimum power level of 6.6 kW. The chargers provide 20 to 25 miles of driving range per hour of charging for a typical EV using the non-proprietary SAE J1772 connector, which can be used with all electric vehicles in the United States.

Electrify America’s L2 vendors own, operate, and maintain their own electronic data networks in support of L2 chargers installed and operated on behalf of Electrify America, as well as those installed independently of the program’s efforts. Electrify America owns the data from these charging stations. The chargers installed under this program will be on vendors' networks.

12 2020 National Annual Report to U.S. EPA

3. Education, Awareness, and Marketing 3.1. Brand-Neutral ZEV Education and Awareness Media Campaign Over the course of 2020, Electrify America continued its “Normal Now” education and awareness campaign to educate consumers about the reasons to purchase a ZEV. The campaign – which was recently awarded an “Outstanding Achievement in Internet Figure 9 - Normal Now Spanish- Advertising” award by the Web Marketing Association for producing Language Mobile Landing Page the “Best Automobile Online Ad” of the year –accomplished more than 502 million impressions (i.e., listeners and viewers) nationally during 2020, and increased the total impressions from Electrify America’s education and awareness activities to date to more than one billion impressions across all 50 states.16

The Normal Now campaign, developed by San Francisco-based communications firm Eleven, aims to introduce and normalize zero- emission vehicles for the vast majority of Americans who are not aware of or have never considered switching to a ZEV. Through comical 15-second videos, GIFs and still images, the Normal Now campaign draws comparisons between “new technology” of the past – including cell phones, smart watches and online dating – that were “weird at first,” but are normal now – just like EVs. The campaign’s education and awareness efforts include brand-neutral digital and paid search campaigns and a bilingual landing page (www.NormalNow.com) that provides an overview of the benefits of both battery electric and hydrogen fuel cell electric ZEVs, with links to third-party websites containing robust content for users.

Figure 10 - Normal Now At the beginning of 2020, during preparations for Flight 2 of the Cycle 2 Paid Social Ad campaign, Electrify America paused Normal Now media activities due to the COVID-19 outbreak. During the pause, Electrify America conducted sensitivity research to determine whether the “Normal Now” message could be perceived as insensitive in the context of the pandemic. In Q2, the sensitivity research was completed and the “Normal Now” campaign slogan was preserved. Teams then resumed work on Flight 2 production, and paid media launched in Q2, including new paid social, digital banner ads, and podcast assets. In Q3, new digital video and National Drive Electric Week banner ads went live.

Our team also conducted an A/B test of NormalNow.com in May 2020 in order to test the original landing page creative against a more modern-looking alternative. The new, modern-looking landing page performed significantly

16 “The Web Marketing Association is proud to present this 2021 Internet Advertising Competition Award for Outstanding Achievement in Internet Advertising.” http://www.iacaward.org/iac/winner/18230/truex-and-phd-wins-2021-iacaward-for-electrify-america-normal-now.html

13 2020 National Annual Report to U.S. EPA better, and 100% of online advertising traffic began driving to the new “modern looking” site by the end of Q2.

In July, Electrify America conducted another round of cultural sensitivity research, in order to ensure our advertising campaign “Normal Now” was perceived as sensitive given the current political environment and national civil rights movement. The results were finalized in August, and demonstrated that there was not serious public concern regarding the cultural appropriateness of the campaign. In the second half of the year, our teams conceived new out of home (OOH) placements for the Brand Neutral campaign, which went live in Q4. In late September, in partnership with Plug In America, our team launched various National Drive Electric Week digital ads, such as podcast placements with theSkimm, digital banners, and paid social.

Table 1 below illustrates how the Normal Now campaign’s more than 502 million impressions (i.e., listeners and viewers) nationally broke down by media type for the year. Media ran across all major channels, with digital media continuing to play a strong role in the messaging strategy.

Table 1 - National Normal Now Impressions

Total National Impressions Media Type 2020 Impressions Streaming Audio 35,626,383 Search 3,327,785 Digital/Video 136,421,771 Social 230,393,613 Podcasts 24,352,647 OOH 72,673,620 TOTAL 502,795,819

In addition to measuring the number of impressions accomplished, in 2020 Electrify America also worked with Comscore, a leading third-party media measurement and analytics company, to measure the effectiveness and impact of Normal Now advertising. Comscore surveyed approximately 6,000 Americans, about half of whom had been exposed to the Normal Now campaign, with the remaining group serving as the control group. The survey showed that Electrify America’s Flight 2 led to a statistically significant decrease in concerns surrounding range anxiety in electric vehicles. However, concerns about Affordability and Accessibility did increase, suggesting the need for messaging that directly addresses these concerns.

Other notable results of the 2020 campaign include:

● Paid social delivered a combined 230 million impressions ● Paid search accounted for 72% of the NormalNow.com actions (4.2% year over year increase in the paid search click-through rate)

14 2020 National Annual Report to U.S. EPA

● Pandora has served as the top performing partner in Streaming Audio, driving 77% of the site visits for this channel (Due to this we optimized paid media funds into this partner throughout the year to help increase performance) ● Podcast activations delivered 24 million impressions, which over-delivered at 146% (The Comscore report also shows that audio advertisements were the most effective in driving lift in Top-of-Mind Awareness and alleviating Range Anxiety) ● OOH units were secured in 21 malls nationally and delivered 72 million impressions. On average, our units drove an average dwell time of 5.9 seconds, and we saw this most consistently among males 45–54. This exceeded the benchmark, which is on average 2.0 seconds.

To facilitate even greater impact and increase the total number of impressions in collaboration with others, Electrify America provides the “Normal Now” creative assets for complimentary download and use in local markets to help spread ZEV awareness, consideration, and adoption via the website https://toolkit.normalnow.com/. In 2020, the Normal Now digital asset manager had a total of 668 unique downloads.

3.2. Sponsorships The Cycle 2 National ZEV Investment Plan states that “there may be occasions where it would be reasonable for Electrify America to further education and awareness of ZEVs … by supporting the programs, activities, or events of an industry or non-profit organization.”

In 2020, Electrify America sponsored a number of organizations to conduct education and outreach activities meeting these criteria. Electrify America sponsored Forth Mobility’s National E-Mobility Equity Conference from November 12-13, which was held as a virtual event. This conference brought together approximately 750 attendees to facilitate conversations about strategies and best practices for engaging communities hit worst by air pollution, as well as how to integrate equity into the clean transportation ecosystem. Electrify America also sponsored the “Increasing Consumer Awareness of EVs” webinar, which focused on strategies to advance electric vehicle technology and current studies of EV awareness, including panelists from Forth, UC-Davis ITS, and Cox Automotive.

Electrify America also sponsored Plug In America to conduct virtual ride and drive events in support of National Drive Electric Week, including 17 events nationally. Virtual ride and drives, conceived in response to the COVID-19 pandemic, feature videos of EV drivers providing a tour of their vehicles and taking viewers on a ride-along, as well as informing the audience about charging, incentives and best practices for driving EVs. In some cases, the events included a live Zoom event so that audience members could directly ask EV drivers about their experience. Although these event sponsorships were transitioned from in-person to virtual events, Electrify America continued to credit them as Access investments in 2020.17

17 Consistent with Appendix 3 of the public version of the Cycle 2 National ZEV Investment Plan, ride and drive activities are creditable as Access investments.

15 2020 National Annual Report to U.S. EPA

Electrify America also sponsored Portland General Electric Company’s innovative “Oregoin’ Electric” campaign, which included a smartphone app that provided educational materials about driving electric in the State of Oregon. The app included a quiz feature that tested users on their EV knowledge, allowing them to gain points and win prizes.

The brand-neutral education and awareness activities sponsored by Electrify America in 2020 are shown in Table 2 below.

Table 2 - National Sponsorships in 2020

Partner/Entity Sponsored Activity 2020 Activities / Accomplishments - Convened 750 attendees for National E-Mobility Equity E-Mobility Equity Conference on strategies for engaging communities hit worst Conference and by air pollution, and how to integrate equity into the clean Forth "Increasing Consumer transportation ecosystem Awareness of EVs" - Held "Increasing Consumer Awareness of EVs" webinar webinar focused on current studies of EV awareness, including panelists from Forth, UC-Davis ITS, and Cox Automotive - Hosted virtual ride and drive events between 9/26/2020 and National Drive Electric 10/4/2020 in Texas; Richmond, VA; Columbia, SC; Ithaca, NY; Week - Virtual Ride & Maine; Georgia; New York; Maryland; Massachusetts; Oregon; Plug In America Drive events and Arkansas/Louisiana; Knoxville, TN; Liberty Lake, WA; Missouri; webinars Oklahoma; and Columbus, OH. - Hosted virtual event for North Carolina on 12/17/20 - Launched campaign providing Oregon residents with a unique approach to learn more about going green Portland General "Oregoin' Electric" - Developed the "Oregoin’ Electric" app for users to download Electric Co campaign and app to play daily games and win prizes - Included information about state-wide EV options and a quick quiz-style game on electric vehicle travel to receive points

3.3. Branded Marketing In 2020, Electrify America continued its nationwide branded marketing campaign, with the goals of increasing utilization of Electrify America’s charging infrastructure and awareness of the Electrify America brand.

Consistent with the Cycle 2 National ZEV Investment Plan, the campaign used digital media channels in 2020. In Q1, Electrify America continued to run assets from Cycle 2 Flight 1, including online banner ads that show comparisons to “classic car” moments, such as hitting the open road, strapping children into the back seat, and going through a drive-thru, emphasizing that the electric car experience includes all these same situations. The key messages of the campaign centered on building range confidence and demonstrating to both EV drivers and those considering an EV purchase that Electrify America’s extensive DC fast-charging network could provide them with the same freedom to travel as gasoline- powered vehicles.

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The development of creative concepts for Flight 2 branded media began during Q2, ultimately centering on the notion of “Hello, freedom.” This core message was developed in light of the COVID-19 pandemic, speaking to the freedom that EV drivers can experience on the road and Figure 11 - Branded Media reinforcing that they can find chargers near where they want to be. This Social Ad campaign, which launched in August and ran through the end of Q4, featured Electrify America’s first broadcast spot, as well as digital display, paid social, streaming audio/podcasts, OLV/DTV assets, and ongoing social media efforts across Twitter, Facebook, YouTube, and Instagram.

The Cycle 2 branded campaign delivered over 169 million impressions throughout the year. There were a handful of pauses due to Facebook boycotts, wildfires, and COVID-19. However, these pauses did not impact our ability to drive station utilization, membership sign-ups, and app downloads over the course of the year. The 2020 campaign featured many different media channels—including a partnership with Waze, Gmail ads, and partnerships with EV sites and publications—as well as larger activations such as digital display, streaming audio, online video, and social media on Twitter, Facebook, and Instagram.

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4. Vendor Survey Figure 12 - Electrify America Contractors Electrify America surveys its vendors semi-annually Construct a Charging Site regarding the economic impact of its investments. The survey for the second half of 2020 was conducted over a three-week period, and respondents were repeatedly notified of its importance to Electrify America’s reporting requirements.

Electrify America appreciates the time and effort its vendors put into completing the survey. Seventy-eight firms voluntarily responded – 17 more than for the Q2 2020 survey.

Nearly 8,800 workers were employed by responding vendors and subcontractors to work on Electrify America projects from July to December 2020. In addition, Electrify America is creating new jobs and sustaining existing jobs. Survey respondents indicated that over 1,200 jobs were either created or sustained because of work with Electrify America during the second half of 2020.

Eighteen vendors qualify as small businesses, while six vendors reported qualifying as woman- or minority-owned entities.18

18 Non-profit organizations qualify as minority-owned or women-owned based on Board of Directors composition.

18 2020 National Annual Report to U.S. EPA

5. Corporate Citizenship Corporate Social Responsibility (CSR) is at the heart of everything Electrify America does. Our company’s mission is to enable electric transportation, and that goal frames all of our activities. From ZEV infrastructure, to education, awareness, and access campaigns, to our Green City initiatives, each project and commitment we undertake helps lead the way toward a more electrified, more sustainable future.

In addition to our focus on enabling electric transportation, in 2020 Electrify America established three additional pillars that round out our CSR efforts: environmental sustainability, community impact, and equality and diversity. The activities and goals detailed below offer examples of our commitment to customers and to the larger public under each pillar. We also recognize that CSR is a journey, and that Electrify America’s approach to CSR will evolve as we seek out new ways to be corporate stewards.

5.1. Enabling Electric Transportation When Electrify America began in 2016, 50 kilowatt (kW) charging was state-of-the-art technology, charging stations were limited to a few major metro areas and a handful of corridors, and Tesla was the only automaker selling vehicles with charging faster than 100 kW. Today, in part due to Electrify America’s ultra-fast 150 kW and 350 kW charging stations, nearly every automaker, from Ford to Hyundai to Lucid, is deploying, or has announced plans to deploy, high-powered vehicles.

Example activities for Enabling Electric Transportation include:

 Ultra-Fast Charging: Electrify America’s network of 150 kW and 350 kW chargers reduces the time customers spend charging. As a result, nearly all battery electric vehicles that came to market in 2020 had charging speeds of at least 100 kW. Moreover, the availability of a 350 kW charging network has inspired several automakers to develop 800 volt vehicle platforms that enable vehicles to charge up to 20 miles per minute.  Plug&Charge: Electrify America’s network features Plug&Charge capabilities at all of our DCFC stations, offering drivers with capable cars the ability to drive up, plug in, and charge. This service allows for a much faster and better customer experience, as the vehicle and charger seamlessly handle all authorization, payment, and charging Figure 13 - CHARGED EVs Best-in-Test Award steps.  Customer Experience: Electrify America has achieved industry-leading quality – in December 2020 Electrify America received the CHARGED EVs Charging Infrastructure Best-in-Test award.  Education & Awareness: Electrify America’s marketing efforts have garnered more than one billion impressions, driving awareness of ZEVs and charging options through traditional, digital, and social engagement. A recent Comscore assessment shows that the Normal Now

19 2020 National Annual Report to U.S. EPA

campaign has significantly decreased concerns about range anxiety of electric vehicles.  Speaking Engagements: Electrify America executives and staff were frequently asked to speak at meetings, conferences, and other nationwide events regarding ZEVs, charging technology, and e- mobility. Electrify America cannot accept all invitations received, as we must focus our resources on ZEV infrastructure and investment executions. However, Electrify America participated selectively in events specifically focused on ZEV technology that are likely to grow ZEV awareness and that are consistent with Electrify America’s obligations and the spirit of the National Outreach process.

As a company we are focused on helping spur the e-mobility revolution through our investments in nationwide charging infrastructure, public education, awareness, access, and marketing activities.

5.2. Environmental Sustainability Electrify America is committed to being carbon-neutral, powering our stations with renewable energy where feasible, and building infrastructure sustainably. For example, in 2020 Electrify America pursued the following Environmental Sustainability activities:

 Charging Powered by Renewable Energy: All energy delivered to customers at Electrify America’s California stations is already powered by renewable energy, through the purchase of renewable energy credits (RECs) from California producers. This effort ensures that our stations’ renewable energy is additional to the renewable energy generation required under California’s Renewable Portfolio Standard and meets the California Air Resources Board’s rules for zero-carbon electricity. In parallel, we are exploring options for renewable energy procurement for the remainder of our national network. Electrify America also deployed its first solar canopy, at a station in the Mojave desert, in 2020.  Building Grid Assets: We are also helping to decarbonize the grid by drawing power from renewable energy for battery storage, along with solar charging solutions at Electrify America stations. As detailed above, by the end of 2020, Electrify America had permission from utilities to install 51 behind-the-meter energy storage systems, and 33 systems were operational. Batteries, on-site solar photovoltaic (PV), and advanced technology are part of our investments to ensure that our stations are grid-friendly.

5.3. Community Engagement and Impact Electrify America’s ZEV Investment Commitment is creating opportunity in the electric vehicle charging industry, and among companies and organizations that work at the community level. To date, Electrify America has contracted with 312 vendors for a total contract value of $712 million. As noted above, Electrify America’s vendor survey showed that nearly 8,800 people worked professionally on Electrify America’s investments in 2020, and more than 1,200 jobs were created or sustained due to the investment.

Driving progress on ZEV adoption requires collaboration with stakeholders across the ZEV space. In the summer of 2020, Electrify America launched its third National Outreach process to receive feedback from state, local, and tribal governments; academics; interest groups; customers; automotive companies; infrastructure suppliers; utilities; and the general public. This effort combined a public-facing

20 2020 National Annual Report to U.S. EPA submissions page on Figure 14 - Cycle 3 Outreach Efforts ElectrifyAmerica.com with dozens of stakeholder discussions and a review of academic literature to gather the latest insights and thinking on ZEV investment priorities.

From our webpage alone, Electrify America received over 900 unique submissions. Because the COVID-19 pandemic impacted our ability to travel and meet with some stakeholders in person, we strove to create meaningful engagement through webinars, video meetings, phone calls, and emails. Electrify America is very appreciative of everyone who took the time to send us a submission.

5.4. Equality and Diversity Electrify America’s diversity and inclusion efforts span both internal and external activities in order to help effect a greater impact. We strive to achieve diversity and inclusion in our approach to hiring and engaging suppliers. We have an emphasis on engaging in sponsorships that support education and awareness activities focused on diverse audiences including minority groups and the LGBTQ+ community. Internally, in 2020 Electrify America strengthened corporate processes including recruiting and staffing, supplier diversity, request for proposal (RFP) evaluations, review of sponsorships and marketing. Some Equality and Diversity activities in 2020 included:

 Recruiting: Electrify America believes diversity in backgrounds and experiences within our team is an important part of our cultural fabric and a key to driving ZEV adoption. To achieve this diversity, Electrify America and its parent company have implemented a set of recruiting practices that promote career openings to traditionally underrepresented groups including women, racial minorities, and members of the LGBTQ+ community.  Diversity and Inclusion Committee (IDEA): Electrify America believes in diversity and inclusion in the workplace and has formed the IDEA (Inclusion, Diversity, Equality, Awareness) Committee to underline that commitment. This committee focuses on the support and advocacy for better and equal outcomes for all areas of diversity and inclusion, including but not limited to gender, race, sexual orientation, religion, and age. A core part of the committee’s mission statement is the recognition of the intersection of environmental impact and environmental justice.  Supplier Diversity: Electrify America is committed to ensuring that investment reflects the rich and diverse characteristics of the nation and its people. To meet this commitment, Electrify America staff conducts outreach efforts and activities to: ensure potential new suppliers and contractors are aware of RFP opportunities resulting from the ZEV Investment Commitment; to encourage greater participation by underrepresented groups and community based organizations, including certified veteran-, women-, and minority-owned businesses; and to assist applicants in understanding how to participate in the RFP process.

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Electrify America’s purchasing team maintains a list of potential minority-, women-, and veteran- owned vendors, and the team has established attracting diverse suppliers as a key internal goal. Electrify America includes language in all RFPs indicating our commitment to a diverse vendor base, and bidders to Electrify America RFPs are asked to include information regarding certified minority-, women-, and veteran-owned business enterprise participation along with their proposal. On a semi- annual basis, Electrify America continues to survey its vendors to assess the job creation and economic activity occurring as a result of the ZEV Investment Commitment.

In summary, in 2020 Electrify America embraced CSR and sought to be a CSR leader in the ZEV industry. Our four CSR pillars are the keys to unlocking clean and equitable transportation for everyone.

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6. Update on Cycle 2 Spending Forecast During Cycle 2, Electrify America is making all possible efforts to fulfill its Appendix C ZEV Investment Commitment to incur $300 million in creditable Cycle 2 costs by the end of December 2021. However, as of the drafting of this document, Electrify America anticipates a potential shortfall in Cycle 2 spending through December 2021 due to delays in charging station investment spending resulting from the COVID-19 pandemic. Electrify America will invest $300 million, consistent with the Cycle 2 National ZEV Investment Plan, but it is possible that these investments will be delayed to 2022.

As detailed above, Electrify America acted aggressively to address the COVID-19 emergency early in 2020. With the health of our employees a top priority, a moratorium on employee travel and meeting attendance went into effect in the first week of March, and mandatory telework and employee stay-at- home policies took effect during the second week of March and continued through the end of the year. The Electrify America team continued to work remotely in an extraordinarily dedicated fashion. And consistent with guidance from the U.S. Department of Homeland Security and the California Energy Commission that EV charging stations are critical infrastructure providing an essential service, Electrify America charging stations remained open and available to those who needed them.

Due to forces beyond its control, Electrify America’s investment may be substantially delayed. The national emergency and stay-at-home orders implemented across the United States slowed or stopped ultra-fast charging station site evaluation, site selection, permitting, construction, utility interconnection, inspection and commissioning activities for a period of time. Some site hosts – especially those that provide essential services – prohibited construction activities during the emergency. And Electrify America required our suppliers, vendors, and contractors to follow the applicable regulations and guidance regarding the health and safety of their employees during the pandemic. Dozens of active construction sites were demobilized.

While this report details how Electrify America adapted to the COVID-19 pandemic and took measures to help mitigate these significant and material delays, there remains the possibility that the pandemic could adversely affect Electrify America’s ability to deliver on ZEV Investment commitments as scheduled.

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7. Schedule of Creditable Costs For the reporting period of January 1, 2020, through December 31, 2020, Electrify America had the following creditable costs. Creditable Costs are in accordance with the final National Creditable Cost Guidance, approved by EPA in a letter dated March 21, 2017, and the California Creditable Cost Guidance, approved by CARB in a letter dated August 4, 2017, as those documents were amended by the First Supplement to the Creditable Cost Guidance dated March 12, 2019 and approved March 13, 2019.

Electrify America formally requests that EPA confirm that all costs expended during the period covered are creditable costs.

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Electrify America, LLC Schedule of Creditable Costs for Fiscal Year ending December 31, 2020 (in U.S. Dollars)

Creditable Costs California National Total

ZEV Infrastructure Investments DCFC Infrastructure Investments Green City Infrastructure Investments L2 MUD & Workplace Investments Other Infrastructure Related Investments Total - Investments 69,440,974 104,027,688 173,468,662

ZEV Infrastructure Expenses Call Center Credit Card Processing Fees Creditable Electricity Charges Land Lease Maintenance Expense Networking Fees Site Acquisition and Identification Other Operating Expenses Subtotal - ZEV Infrastructure Expenses 11,685,205 36,514,104 48,199,309

Green City Expenses Car Share Infrastructure Marketing SMUD Storage Shares Subtotal - Green City Expenses - - -

Education and Marketing Expenses Brand Neutral Education Branded Marketing Subtotal - Education and Marketing Expenses 10,896,895 13,160,048 24,056,943

Overhead Expenses Facilities Costs Legal Maintenance Miscellaneous Personnel Costs Personnel-Related Costs Property Taxes Service Level Agreements Telecom Subtotal - Overhead Expenses 6,542,277 11,759,096 18,301,373

Total - Expenses 29,124,377 61,433,248 90,557,625

Grand Total - Creditable Spending 98,565,351 165,460,936 264,026,287

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Notes: 1. The basis of cost presentation is accrual accounting in accordance with VWAG IFRS accounting standards (reference VW IFRS Handbook – May 2019). The acquisition of capitalizable assets (i.e. additions to property, plant and equipment) are reported in the Schedule of Creditable Costs when the costs are incurred. 2. Creditable Costs are in accordance with the published National Creditable Cost Guidance approved by EPA in a letter dated March 21, 2017 and the California Creditable Cost Guidance approved by CARB in a letter dated August 4, 2017, as modified by the Creditable Cost Supplement approved by CARB and EPA on March 13, 2019. 3. Reported overhead expenses in any given year will be provisionally treated as creditable, but EPA/CARB will only approve overhead costs for a particular investment cycle where the average overhead over a given 30-month cycle ends up being at or below the threshold specified in § 5.1 of Appendix C-1. The weighted average of 13 percent will be used as the overhead threshold for the first ZEV Investment cycle and subsequent Investment cycles are subject to a 10% percent threshold. 4. For 2020, the overhead costs as a percentage of total creditable costs are within the annual target. The 2020 costs have been segregated between Cycle 1 and Cycle 2 activities. The Cycle 1 costs have been accumulated which allows for the assessment of overhead costs versus the stated target. The total overhead cost of Cycle 1 totaled $40,678,475 and that of Cycle 2 was $21,617,621 representing 8% and 7% of the total spending in the respective Cycles. Therefore, we claim all of the overhead costs for Cycle 1 and 2 as creditable without need to restate prior year amounts claimed as provisionally creditable. Further, the Cycle 2 planning demonstrates that the overhead costs in subsequent year will be below the threshold and the overall overhead costs for Cycle 2 are expected to be below the threshold. The 2020 overhead costs are claimed as provisionally creditable, subject to measurement and verification at the conclusion of Cycle 2, at the end of 2021. 5. "The cumulative Cycle 1 spending, including costs reported in the 2017, 2018 and 2019 Annual Reports, totals $300,000,000 for the National Investment Plan and $200,000,000 for the California Investment Plan. The Cycle 1 spending goal is $300,000,000 for the National Investment Plan and $200,000,000 for the California Investment Plan.

The National Investment plan goal was achieved within the specified Cycle 1 timeframe. Total spending on National Investment plan activities through June 30, 2019 totaled $300,000,000.

The California Investment plan goal was not achieved within the specified Cycle 1 timeframe. The unfinished Cycle 1 projects include L2 Workplace / MUD sites, DCFC charging sites, Battery Storage systems, and Green City initiatives. The activities for these specified Cycle 1 projects continued without pause after June 30, 2019 and the spending was discretely tracked and reported as Cycle 1 spending. At the end of December 31, 2020, the spending shortfall for Cycle 1 of $7,618,076 was completed and was reported as Cycle 1 spending. 6. The Service Level Agreement costs, reported in the Schedule of Creditable Costs, are Related Party Transactions between Electrify America, LLC and affiliated companies comprised of Volkswagen AG subsidiaries. For 2020, no Service Level Agreement costs have been claimed as creditable. 7. The COVID-19 Pandemic had far reaching impacts to U.S. communities and businesses. The efforts to reduce the spread of the COVID-19 virus, including Stay at Home mandates, introduced new restrictions on businesses in 2020. Electrify America was subject to these restrictions and introduced measures to accommodate the restrictions. Despite a temporary setback, the Cycle 2 projects continued to be developed and deployed in 2020. As of December 31, 2020, the cumulative Cycle 2 spending is on pace, based on the proportion of spending over the 30-month Cycle.

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Electrify America, LLC Schedule of Creditable Costs for Fiscal Year ending December 31, 2020 (in U.S. Dollars)

National National National Creditable Costs Cycle 1 Cycle 2 Total

Green City Expenses Car Share Infrastructure Marketing SMUD Storage Shares Subtotal - Green City Expenses

Education and Marketing Expenses Brand Neutral Education Branded Marketing Subtotal - Education and Marketing Expenses - 13,160,048 13,160,048

Total - Expenses - 61,433,248 61,433,248

Grand Total - Creditable Spending - 165,460,936 165,460,936 27 2020 National Annual Report to U.S. EPA

8. Supplemental Schedule of Creditable Costs In addition to the required schedule of creditable costs listed above, Electrify America is providing supplemental schedules which show the cumulative spend through calendar year 2020, including the previously reported costs from calendar years 2017-2019.

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Electrify America, LLC Supplemental - Cumulative Schedule of Creditable Costs for Cycle 1 and 2 for January 1, 2017 through December 31, 2020 (in U.S. Dollars)

Creditable Costs California National Total

Green City Expenses Car Share Infrastructure Marketing SMUD Storage Shares Subtotal - Green City Expenses 23,055,587 - 23,055,587

Education and Marketing Expenses Brand Neutral Education Branded Marketing Subtotal - Education and Marketing Expenses 37,986,910 49,591,199 87,578,110

Total - Expenses 117,667,181 156,690,952 274,358,133

Grand Total - Creditable Spending 309,549,437 512,198,087 821,747,525 29 2020 National Annual Report to U.S. EPA

Electrify America, LLC Supplemental - Cumulative Schedule of Creditable Costs for Cycle 1 and 2 for January 1, 2017 through December 31, 2020 (in U.S. Dollars) National National National Creditable Costs Cycle 1 Cycle 2 Total

Green City Expenses Car Share Infrastructure Marketing SMUD Storage Shares Subtotal - Green City Expenses - - -

Education and Marketing Expenses Brand Neutral Education Branded Marketing Subtotal - Education and Marketing Expenses 32,198,953 17,392,247 49,591,199

Total - Expenses 81,046,287 75,644,665 156,690,952

Grand Total - Creditable Spending 300,000,000 212,198,087 512,198,087 30 2020 National Annual Report to U.S. EPA

9. Attestation by Third-Party Reviewer

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