Dear Ms. Londer,
Thank you for the detailed response and the EQC links. I appreciate the
transparency on process. My concern is not procedural, it is that the rate
structure as adopted is unlikely to achieve its stated cost-recovery goal,
and may undermine it.
The response rests on a premise worth re-examining: that a rate "set to
reflect actual costs" will recover those costs. That only holds if
utilization is fixed, and it isnt. EV charging is highly substitutable,
the next charger is minutes away and the price is posted before anyone
plugs in. Cost recovery is price multiplied by volume, not price alone. Set
the price above the local market and volume falls; spread the same fixed
costs (network subscriptions, utility demand charges, capital, maintenance)
across fewer kWh, and the per-kWh cost you must recover actually rises.
That is a downward spiral, not a path to break-even. You cannot recover
costs from a charger no one uses.
The EQC materials are where this shows most clearly. Staff modeled the new
rates by holding energy delivered constant (roughly 21.9 kWh for a Level 2
session and 41.6 kWh for Level 3) and simply showed the cost rising to
$8.97 and $21.22. There is no utilization data, no demand-response
assumption, and no revenue projection anywhere in the presentation. The
analysis assumes every kWh sold today will still be sold at nearly double
the price. That assumption is the whole question, and it went unexamined.
On the rates themselves, the right benchmark is what drivers actually pay,
not list pricing. Most regular users (and certainly the commercial,
rideshare, and gig drivers staff identified at Belle Haven) charge on a
membership. Electrify Americas Pass+ ($4/month) runs about $0.36/kWh for
genuine DC fast charging at 150–350 kW (charging rate at Bellhaven is half
that, at 40 kW and 80 kW). Against that real-world rate:
- The proposed $0.41 Level 2 rate is essentially more than what an
Electrify America member pays for DC fast charging, yet by the Citys own
slides, the Level 2 chargers deliver about 9.6 kW versus roughly 52 kW for
Level 3. Drivers would pay fast-charging prices for a fraction of the speed.
- The proposed $0.51 Level 3 rate sits above what a member pays for
actual fast charging in California. It is not the bargain the
regional-average comparison suggests once membership pricing is accounted
for.
The plan also moves in the wrong direction on demand management. It
eliminates time-of-use pricing entirely, yet time-of-use is exactly how the
major networks shift load to off-peak hours and reflect real grid costs,
and it is the precise tool for the resident-availability concern staff
raised. A flat rate high enough to deter heavy users doesnt reserve the
chargers for residents; it leaves them empty. Congestion is solved with
off-peak pricing, session limits, or idle fees, not with a price that
drives everyone away.
I am not asking the City to subsidize charging. I am asking it to price for
the volume that actually recovers cost. Specifically, I urge the Council
and staff to:
- Set the Level 2 and Level 3 rates within the competitive local band
rather than at the top of it, and in particular to revisit a Level 2 rate
priced at parity with commercial DC fast charging;
- Retain a time-of-use or off-peak discount to drive utilization into
lower-cost hours and ease the resident-availability concern; and
- Commit to reviewing actual utilization and net revenue 60–90 days
after implementation, with authority to adjust, before treating these rates
as settled.
Competitive pricing and cost recovery are not in tension, competitive
pricing is the only thing that makes cost recovery possible. I would
welcome the chance to review the utilization figures alongside staff.
Thank you again for your response!
Webster Lincoln
East Palo Alto, CA
On Fri, Jun 5, 2026 at 11:31 AM Rachael Londer
wrote:
> Dear Mr. Lincoln,
> Thank you for reaching out about the EV charging rate change starting July
> 1 across city chargers. The new rates were developed as part of the Citys
> broader Master Fee Schedule update, which was adopted by City Council on
> April 28, 2026. The rate structure was first presented publicly at the
> Environmental Quality Commission on February 26, 2026. The presentation
>
> , meeting minutes
> ,
> and recording
>
> from that
> EQC meeting are available by clicking the hyperlinks. The full Council
> agenda for the fee schedule adoption is available under Item I1 here
>
> .
> The rates were set to reflect the Citys actual costs for operating,
> maintaining, and administering the charging stations, including
> electricity, charger maintenance, and network services. The City also
> completed a regional comparison study, which was summarized for the EQC at
> that meeting.
> At the Belle Haven Community Campus, the DC fast chargers see heavy and
> sustained use, including use from commercial, rideshare and gig delivery
> drivers. These fast chargers were installed after the Citys existing rates
> had been adopted, so the fee schedule did not yet include a Level 3 rate,
> meaning fast charging was not priced to reflect its higher cost to the
> City. DC fast chargers are considerably more expensive to maintain and
> require frequent repairs, and without a rate that captured those costs, the
> heavy commercial use often left the chargers unavailable to the residents
> and campus visitors they are meant to serve. The new Level 3 rate reflects
> the true cost of operating these chargers, with the goal of keeping them
> available for residents and community members when they need them.
> Utilization matters to us and the feedback you have shared will be
> valuable as we continue to monitor how the rates are performing.
> Thank you,
> Rachael
>
>
>
> * Rachael Londer **(she/her)*
> Sustainability Manager
> City Hall - 2nd Floor
> 701 Laurel St.
> tel 650-330-6765
> menlopark.gov
> See www.pronouns.org to learn more about why I share my pronouns.
>
>
> ------------------------------
> *From:* Webster Lincoln
> *Sent:* Sunday, May 31, 2026 10:04 PM
> *To:* _CCIN
> *Subject:* Objection to Proposed EV Charging Rate Increase – July 1, 2026
>
>
> Dear Mayor and Council Members,
>
> I write to oppose the Citys proposed EV charging rate increases taking
> effect July 1, 2026.
>
> The proposed rates — $0.41/kWh for Level 2 and $0.51/kWh for DC fast
> charging — are not competitive with nearby alternatives. Neighboring Palo
> Alto offers Level 2 charging at just $0.25/kWh, fast chargers in the area
> range from $0.28 to $0.54 per kWh, and Metas chargers are available at
> $0.38/kWh. At $0.41/kWh, Menlo Parks proposed Level 2 rate is 64% more
> expensive than Palo Altos and exceeds what Meta charges for fast charging.
> The proposed Level 3 rate is nearly double what some nearby chargers offer.
>
> Cost recovery depends on utilization. If drivers can find cheaper charging
> nearby — and they can — they will. Uncompetitive pricing wont generate
> more revenue; it will strand the infrastructure while fixed operating costs
> remain.
>
> I urge the Council to price competitively, retain some form of off-peak
> discounting to drive utilization, and review actual utilization data before
> locking in rates that could undermine the very cost recovery goal the fee
> schedule is meant to achieve.
>
> Thank you for your consideration.
>
> Webster Lincoln
> East Palo Alto, CA
>
> Sent from my iPad
>
