Plug In America 6380 Wilshire Blvd Suite 1000 Los Angeles, CA 90048 323-372-1236 June 19, 2020 Nevada Legislative Committee on Energy 401 S. Carson Street Carson City, NV 89701-4747 Submitted via email to Assemblywoman Daniele Monroe-Moreno ([email protected]); Senator Chris Brooks ([email protected]); and Marjorie Paslov-Thomas ([email protected]) Re: SCR 3 Transportation Funding Solutions Dear Chair Monroe-Moreno and Vice-Chair Brooks: On behalf of the electric vehicle (EV) drivers in Nevada that we represent, Plug In America would like to thank you for your leadership with the Senate Concurrent Resolution 3 (SCR3) process, particularly given these challenging times. EVs provide significant benefits to all Nevadans, and we urge you to take these benefits into account as you finalize the report on alternative solutions for transportation funding in Nevada, including what fees – if any – should be assessed to EV drivers in Nevada. Plug In America is the nation’s leading independent consumer voice for accelerating the use of EVs in the United States to consumers, policymakers, auto manufacturers and others. Formed as a non-profit in 2008, Plug In America provides practical, objective information collected from our coalition of plug-in vehicle drivers through public outreach and education, policy work and a range of technical advisory services. Our expertise represents the world’s deepest pool of experience of driving and living with plug­ in vehicles.1 The solutions to solving the immediate transportation funding shortfalls in Nevada – and also nationwide – require major shifts in how the funding has historically been implemented. New solutions require time to bring all stakeholders on board and to inform all drivers of the changes. Therefore, in the interim before any final solution is adopted, we urge you not to adopt a short-term and shortsighted approach of placing punitive fees on EV drivers. While EV drivers should pay their fair share for using the roads, EV drivers already pay a registration fee of $33 in Nevada.2 In addition, EV drivers pay local electricity taxes, and plug-in hybrid EV drivers already pay gas taxes. The Committee should not impose any additional fee that would be punitive to the point of disincentivizing the purchase of an EV or negating any fuel cost savings to the EV driver. We have divided our comments into the following three sections: 1. A detailed list of the benefits EVs provide to Nevadans. a. The SCR3 legislation specifically instructs that the interim study must include an examination of the benefits of the use of EVs and the costs of transportation related pollution, including greenhouse gas emissions in Nevada. 1 More information available at: www.pluginamerica.org 2 https://dmvnv.com/regfees.htm 1 Plug In America 6380 Wilshire Blvd Suite 1000 Los Angeles, CA 90048 323-372-1236 2. Plug In America’s recommended solution to transportation funding in Nevada. 3. A detailed whitepaper examining the transportation funding shortfall issue, the role of EVs and additional options. 1. A detailed list of the benefits EVs provide to Nevadans. a. Benefits to the Nevada EV driver: i. EVs are cheaper to fuel and maintain than gasoline-powered vehicles. On average, fueling a car with electricity is roughly the same as gasoline at $1.09 per gallon in Nevada, thanks to an EV’s performance efficiency and the lower cost of electricity.3 Electricity prices are also far more stable than gasoline prices, allowing drivers to avoid the risk of future price spikes. On average, EVs save consumers about $770 a year in fuel costs.4 Combined with the low maintenance costs, EVs save consumers far more money than gas vehicles.5 Plug-in hybrid EVs (PHEVs) require fewer oil changes, while battery EVs (BEVs) require none. BEVs also have 10 times fewer moving parts than gasoline vehicles; there is no engine, transmission, spark plugs, valves, fuel tank, tailpipe, distributor, starter, clutch, muffler, or catalytic converter. ii. EVs are convenient. With no trips to the gas station, the battery can be charged overnight and be ready to go first thing in the morning.6 b. Benefits to all Nevadans: i. EVs are significantly better for local economies and the Nevada economy. EVs are fueled by electricity from the local grid, which is cheaper for all consumers. Money not spent on gas and maintenance can be invested back into the local economy.7 Nevada imports virtually all of its petroleum fuels, sending over $4.2 billion out of state in 2017.8 With a transition to transportation electrification, this $4.2 billion could be kept in the state of Nevada, particularly as Nevada aims to have at least 50% of its electricity generated from renewable energy. ii. EVs produce little to zero tailpipe emissions, improving air quality and reducing health care costs, especially for low-income and disadvantaged communities. The most recent State of the Air report for Nevada shows that the majority of Nevadans live in areas where the air is unhealthy to breathe.9 In addition, the report gave Clark and Washoe Counties an F grade for ozone pollution (smog). The Las Vegas valley was ranked as the 9th most polluted in the country for 3 http://energy.gov/eere/eveverywhere/ev-everywhere-saving-fuel-and-vehicle-costs 4 https://www.ucsusa.org/resources/going-pump-plug 5 https://www.energy.gov/eere/electricvehicles/saving-fuel-and-vehicle-costs 6 https://afdc.energy.gov/fuels/electricity_infrastructure.html 7 Roland-Holst, David. 2012. Plug-in Electric Vehicle Deployment in California: An Economic Assessment https://are.berkeley.edu/~dwrh/CERES_Web/Docs/ETC_PEV_RH_Final120920.pdf and Stroo, Hans. 2015. Bills to Advance Electric Vehicles Make Good Economic and Environmental Sense http://planwashington.org/blog/archive/bills-to-advance-electric-vehicles-make-good- economic-and-environmental-sense/ 8 https://www.eia.gov/state/data.php?sid=NV#ConsumptionExpenditures . 9 http://www.stateoftheair.org/city-rankings/states/nevada/ 2 Plug In America 6380 Wilshire Blvd Suite 1000 Los Angeles, CA 90048 323-372-1236 ozone, with vehicle emissions being a primary contributor to ozone formation. Low-income neighborhoods and communities of color have been disproportionately impacted by health issues related to vehicle emissions and ozone, as these communities are often located next to high-traffic corridors and industrial facilities that are major sources of pollution. BEVs have no tailpipe and therefore no tailpipe emissions, while PHEVs produce far fewer tailpipe emissions than a standard gasoline-powered vehicle. With more EVs on the roads, public and private health care costs can be greatly reduced.10 iii. EVs significantly reduce carbon emissions. EVs powered by electricity from the local grid currently produce 54 percent less (lifetime) carbon pollution than gasoline cars, which could grow to 71 percent by 2050 as our power supply gets cleaner.11 EVs also have the lowest total lifecycle carbon footprints for all light­ duty vehicles on the road.12 To meet the carbon emission reduction goals that Nevada has, Nevada must accelerate the transition to a transportation electrification future. iv. EVs help achieve national security. These clean vehicles reduce our dependence on imported oil as they are fueled by electricity, which can be domestically produced from multiple resources, including renewable energy generated in Nevada.13 As mentioned above, Nevada imports virtually all of its petroleum fuels.14 1516 v. The EV market is creating good jobs in Nevada. According to data from the Blue Green Alliance Foundation, Nevada is home to at least eleven businesses involved in manufacturing components for EVs.15,16 These businesses and the jobs they provide offer job security for Nevadans employed with these businesses, as the entire global auto market is moving towards full electrification. vi. With little to zero tailpipe byproduct and no oil leakage on to roadways, EVs reduce the public and private sector costs spent on mitigating the pollution from roadway runoff. The polluted runoff from highways is nonpoint source pollution, and can impact local surface and ground water quality as well as aquatic habitat. BEVs are cleaner than gas-powered vehicles and have no oil leakage or drips of pollution from the tailpipe. c. Benefits to the electric grid, ratepayers and grid operators: i. Investment in EVs and charging infrastructure can result in more off-peak energy sold, and therefore reduced rates for ratepayers. Additional load from 10 https://www.ucsusa.org/clean-vehicles/vehicles-air-pollution-and-human-health 11 https://www.nrdc.org/experts/luke-tonachel/study-electric-vehicles-can-dramatically-reduce-carbon-pollution 12 http://carboncounter.com/ 13 https://www.energy.gov/eere/vehicles/articles/fotw-1081-may-13-2019-plug-vehicles-united-states-displaced-323-million 14 https://www.eia.gov/state/data.php?sid=NV#ConsumptionExpenditures . 15 https://www.bgafoundation.org/programs/visualizing-the-clean-economy-autos/ 16 https://www.bls.gov/green/electric_vehicles/ 3 Plug In America 6380 Wilshire Blvd Suite 1000 Los Angeles, CA 90048 323-372-1236 EVs can make more efficient use of existing utility assets, which – especially through off-peak charging – puts downward pressure on electricity rates.17; 18; 1917 18 ii. EVs can be a source of potential load control. Many EV owners are open to load control programs, such as letting the utility or a third party turn EV charging on and off as needed, as long as it does not prevent the charge from finishing by a specified time.20 Going a step farther than load control is pulling energy from idle EVs at peak load times via “vehicle-to-grid.”21 iii. EVs can make the integration of renewables easier. EV loads are generally during low demand times (and can be moved around with TOU rates and other tools), making it easier to justify the addition of renewable power sources that cannot be ramped.22 2.