Con Ed Cripples its NYC SmartCharge Off-Peak Charging Incentive Program by Excluding TOU Clients

The Electrical Utility is “Enhancing” a Profitable Managed Charging Program By Excluding its Major Advocates

Like many main cities, New York Metropolis has set forth aggressive objectives for encouraging EV adoption as a way to enhance air high quality and mitigate the widescale harm of local weather change. New York Metropolis’s Earlier Commissioner of the Division of Transportation, Hank Gutman introduced a plan in 2021 to construct at the least 40,000 public Stage 2 charging stations and 6,000 DC quick chargers within the metropolis by 2030. The DOT felt that this variety of chargers can be essential to help the town’s objective of switching 400,000 fossil gas vehicles within the metropolis over to zero emission autos by 2030. The Governor of New York State, Kathy Hochul additionally introduced a plan to remove the sale of fossil fuel-powered autos in the whole state by 2035. And to get there, the EV charging infrastructure goes to want to evolve as will client behaviors.

Whereas public charging stations are helpful for condominium dwellers who could not have entry to a storage or driveway, nicely over 1,000,000 residents of New York Metropolis and Westchester County do have entry to a driveway or storage and these people will largely be charging their EVs at dwelling. As a way to stop pressure on {the electrical} grid, Con Edison (aka “Con Ed”), the electrical utility for New York Metropolis and Westchester, beforehand carried out an incentive program known as “SmartCharge Rewards.” (I’ve written about this  beforehand – Arms-On with ConEd’s SmartCharge Reward Program).

The SmartCharge incentive system, also called a “managed charging program” was fairly easy: cost your automotive throughout off-peak hours and also you’d get a money rebate for every kWh charged throughout off-peak hours. The rebate quantity wasn’t large (5 cents per kWh), nevertheless it may add up over time, significantly if you happen to drove your automotive incessantly and often charged it at dwelling at night time. As well as, individuals in this system may earn a flat reward every Summer time month ($20/month) in the event that they prevented charging their automotive throughout tremendous peak hours altogether and $5/month the remainder of the 12 months only for staying in this system and charging your automotive inside the service space at the least as soon as each 30 days. Members may additionally earn a $25 bounty for referring new prospects to this system in addition to $25 for infrequent surveys. The system had a level of “gamification” in that prospects may monitor their progress in an internet portal and earn badges for sure charging behaviors.

If It Ain’t Broke…

Apparently the SmartCharge New York program was pretty profitable as Con Ed lately disclosed to us that this system noticed over 20,000 buyer registrations, which represents over 20% of eligible EVs registered in ConEd’s service space, as of 2022. However regardless of that success, Con Ed introduced in late 2022 that the SmartCharge New York program was being suspended, pending a “redesign.” The brand new model of the SmartCharge NY program is predicted to go dwell in April, 2023. Some incentives are growing: individuals will get 10 cents per kWh when charging an EV off peak (midnight to eight AM). For those who can keep away from charging your EV throughout “tremendous peak” instances in the course of the Summer time months (2:00 PM to six:00 PM June to September), you’ll earn $35/month, with a further bonus of $35 if you happen to keep away from tremendous peak charging for the entire summer time. However the largest change to this system is the worst one: Con Ed prospects on a TOU (Time of Use) billing plan are not eligible for this system.

TOU packages are standard with shoppers who personal solar energy techniques, as a result of these prospects can generate energy in the course of the day when charges are larger, however then use energy at night time when charges are decrease. And if the photo voltaic buyer has dwelling battery storage like a Tesla PowerWall as a part of their system, then they don’t even have to shift their electrical utilization to off-peak hours. Batteries may be charged from the photo voltaic panels in the course of the day and from the grid at night time, then energy may be drawn from these batteries at any time, with out tapping into the grid throughout peak hours. In brief, prospects who’ve invested in solar energy and signed up for a TOU plan are precisely those most definitely to buy electrical autos and perceive the necessity to cost their vehicles off-peak. By eliminating these prospects from the motivation program, Con Ed is successfully alienating their core viewers, thereby undermining the objective of this system.

Once we enquired in regards to the reasoning behind this modification, a Con Ed spokesperson informed us, “SmartCharge New York was redesigned to succeed in the most individuals and embrace as many autos and applied sciences as attainable. The primary objective of this system continues to be to shift charging to off-peak hours. The New York State Public Service Fee mentioned in its order for Approving Managed Charging Packages with Modifications, that residential and small enterprise time-of-use (TOU) prospects are ineligible to take part in SmartCharge. That’s to keep away from incenting the identical charging conduct twice, as each this system and the TOU fee present a financial profit for shifting charging to off-peak hours.”

When in Doubt, Cross the Buck

The New York Public Service Fee (PSC) is the federal government physique which regulates utilities in New York state. I’ve learn their “Order for Approving Managed Charging Packages for Modifications” (which may be discovered right here) and there’s no direct reference to TOU prospects being ineligible for any incentive or managed charging program. The primary reference I can discover to Con Ed eradicating TOU prospects from eligibility is available in Con Ed’s personal MCIP (Managed Charging Implementation Plan) for the revised SmartCharge program, which you’ll find right here. That is what Con Ed submitted to the PSC for approval of the revised program.

Whereas I can perceive the will to not present further incentives as a cost-saving measure, the corporate’s declare that this redesign permits this system to “attain the most individuals” is categorically false. The brand new program penalizes those that have already proven the willingness to put money into solar energy techniques and shift their electrical energy utilization to off-peak hours by stopping them from collaborating in this system in any respect: no per-kWh rewards for off-peak EV charging, no month-to-month incentives for off-peak charging, no capacity to earn further rewards by referring new customers to this system. And with Con Ed’s electrical energy charges in New York Metropolis already 40% above the nationwide common (23.1 cents/kWh vs. 16.1 cents/kWh), the corporate may actually afford to proceed to supply these incentives to TOU prospects so long as its helps to additional this system objectives. Why shouldn’t TOU prospects be eligible to earn these incentives so long as they meet the phrases and objectives of this system?

Following up additional, the Con Ed rep informed us that the proscribing issue is predicated on the PSC’s pointers for incentivization. The rep informed us: “The Order states that ‘participation incentives paid to prospects should be cost-based, and are to not exceed the distinction between the default volumetric fee and a Fee authorised time-varying or dynamic fee.’  Since prospects who’re on TOU charges are on the most degree already, we aren’t capable of supply them any further incentives with out further approval.”

However there’s a drawback with this logic. ConEd’s present electrical energy charges for TOU prospects are roughly 35.3 cents/kWh for peak utilization and about 16.2 cents/kWh off-peak (based mostly alone most up-to-date Con Ed invoice). Con Ed additionally costs a penalty to prospects with solar energy techniques of about .5 cents per kWh, which I received’t even get into right here (don’t get me began!). These electrical energy charges are even larger throughout Summer time months. With Con Ed’s present common non-TOU fee at 23.1 cents/kWh, non-TOU prospects might be paying solely 13.1 cents/kWh for off-peak charging, plus they are going to be eligible for as much as $175 in further rewards in the event that they keep away from super-peak charging for the whole summer time. So the revised SmartCharge program is already offering a bigger off-peak incentive to non-TOU prospects than TOU off-peak charges. And but, this plan was authorised by the PSC. Continued inclusion of TOU prospects within the plan would merely require approval from the PSC (which Con Ed didn’t search).

ConEd prospects who’re enrolled in a TOU (time of use) service plan at the moment are excluded from collaborating within the firm’s SmartCharge off-peak EV charging incentive program.

So it seems that Con Ed itself (not the Public Service Fee) has determined that they are going to exclude TOU prospects from the SmartCharge managed charging program shifting ahead. I’d speculate that the corporate believes that TOU customers are already “hooked” and have sufficient incentive to cost their vehicles after hours.  To me, this appears to be “penny smart, pound silly” as many former advocates of this system or “SmartCharge Ambassadors” as they (we) had been known as, will not be eligible to take part, nor to refer new prospects to take part in this system. And that’s certain to place a damper on this system’s proliferation and enlargement. In the end this implies fewer individuals might be charging their vehicles throughout off-peak hours – which is the precise objective of this system.

For me personally, I plan to modify again off the TOU plan to a typical plan as soon as the brand new SmartCharge program goes dwell. Our electrical energy utilization isn’t excessive sufficient to justify the meager low cost that Con Ed gives for off-peak utilization and the incentives of the SmartCharge plan would exceed the financial savings we’d see on a TOU plan. And I’d suggest that different Con Ed prospects take into account doing the identical. For many who usually are not TOU prospects, or who usually are not ConEd prospects in any respect, however who do cost their vehicles in New York Metropolis or Westchester throughout off-peak hours, the Sensible Cost program is price wanting into.

Received an opinion on Con Ed’s transfer or on Managed Charging packages basically? Tell us within the feedback.

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