Dear City Council Members,
We recommend that the city NOT pass the EV charging station ordinance at this time for the reasons described below.
The proposed ordinance is well intended but will have unintended consequences as it seeks to solve a problem that has not been
defined and we do not believe exists. Alternatively, we recommend that the city monitor the uses of existing EV charging stations
to ▒▒▒▒▒ the adequacy of supply and to act if and when needed to address any issues that will then have been defined.
We have studied this issue in great detail for our recently completed 195 unit apartment community at 777 Hamilton and Station
1300 a mixed use development currently under construction that will include nearly 1000 parking spaces. Like all building owners
we are focused on meeting the current demand for EV charging and having the infrastructure and appropriate technology to meet
future demand. To not do so would put us at a competitive disadvantage. We are highly motivated, like all building owners and
major employers, to get it right.
We will not be affected by this ordinance since Station 1300 building permit applications have all been deemed complete and our
garage is only 6 months from completion. Our comments are offered as members of the community with some knowledge of the issue and
who want to see the city get it right.
Salient points for your consideration are summarize, and explained in greater detail, below.
1.Justification for the ordinance has not been established.
2.Market forces, not regulatory guesses, should determine the provision of EV charging station.
3.An over supply of EV charging stations reduces parking for non-EV vehicles, which will not park in EV spaces.
4.The demand for charging stations at places of work is diminished because EV owners have a cost incentive to charge at night not
during business hours.
5.Demand for non residential charging stations will be dampened by the ever increasing driving range of EV’s.
6.The residential requirement for 100% of units to have charging station is excessive. (At 777 Hamilton 6% of residents own an
EV.)
7.Technology is changing rapidly in this embryonic industry. 2018 chargers will be obsolete by 2023; so why install now for a
guestimate of 2023+ demand.
8.Do not wire for future EV spaces. Wiring requirements will change over time. Install conduit, and pull wires when needed.
Justification---No where in the staff report or ordinance is there a statement of the problem and how the ordinance will address
that problem. Instead we are given the explanation that “several members [of the City Council] expressed interest in expanding the
regulations” (Staff Report 18-168-CC, pg 1) and the truism that “access to EV infrastructure is an important part of making EV a
success” (pg 2). It is not demonstrated that the EV charging needs in the city are not or will not be met under current Cal Green
regulations. We have an admirable desire that is not supported by any factual assessment of demand or the amount of supply
dictated by the proposed ordinance.
Current EV Charger Supply Greater than Demand—At 15% of commercial parking spaces, the number of EV charging spaces will be
substantially greater than demand, thereby leaving EV chargers spaces empty. Non-EV auto drivers are inclined not to park in an
“EV space”. Effectively, this City ordinance would reduce the number of available parking spaces in any development by requiring
more EV charger spaces than currently demanded.At our Hamilton apartment community of 195 apartment units, there are currently 12
EV autos (6% of the units ) owned by residents. The proposed requirement of one EV charger per unit is 15 times more than current
demand as shown by a new apartment community with a very tech oriented resident population. At Hamilton, we installed more EV
charger spaces than required because we knew our residents would demand more than the required number….we needed to meet market
demand for EV spaces or we would suffer from lower occupancy and rents. Do not artificially reduce parking supply by creating more
EV spaces than there is demand.
EV Auto Owners Charge at Night—As stated in your staff report, “most EV charging occurs overnight at homes” because the electric
rates are multiple times lower for EV owners who have a charging station at home. So EV auto owners will not charge their vehicles
at commercial locations during daytime hours that have higher rates.
EV Auto Range is Increasing--Tesla, which had the largest market share of EV autos in 2017 (about 1/3 of the EV only market), has
a vehicle range of 310 miles. The second highest market share (at about 20%) is the Chevy Bolt with a range of 240 miles and the
Nissan Leaf (third in market share at 15%) has a range of either 151 miles for the base model or 225 miles for the “Plus” version.
With these battery ranges and the average commute time to a Menlo Park employer being 22 minutes (about 10 miles), there is no
reason for a worker to charge an EV auto at a much higher electricity rate while at work or shopping. EV chargers at retail or
office locations are used at a significantly lower rate than the actual EV auto ownership (less than 5% in California in 2017).
EV Charging Technology is Changing—The Staff Report states:
A typical level 2 charger costs around $7,500 with additional cost for the installation and the costs for a level 3 charger would
be greater. The cost associated with the installation of the conduit and wiring typically includes the cost of materials and the
labor associated with the cutting of concrete and asphalt, trenching and the installation of the conduit and wiring, with the cost
increasing when the EV charging stall is further from the electrical supply equipment. A typical cost for a distance of less than
100 feet is approximately $25,000 for a single charger installation. There is some economy of scale for a multiple charger
installation, however, the cost does increase.
Installing EV chargers for office buildings, retail developments and multi-family projects is an expensive undertaking. Increasing
that percentage required from 5% to 15% of the parking spaces for commercial and to one per unit for residential developments of
more than 3 units will have a dramatic increase in the costs. As stated above in the City Staff report, if you use the low cost of
$7,500 per charger that would have increased the cost of our Hamilton apartments by over $1.3M with 90% + of those newly required
chargers not being used. The EV charger technology is changing rapidly so the EV chargers installed in 2018 may be obsolete in
2023 rendering many never used installed EV chargers useless or in need of an upgrade. Just a few years ago, no one thought that
cell phones would be charged wirelessly……when will that be the case for EV charging causing a revolutionary change in
infrastructure?
EV Ready Parking Spaces Should Not Include Wiring—As stated above, with technology changing rapidly including wiring in the EVSE
(Electric Vehicle Supply Equipment) ready spaces will most likely be a waste of money as different wiring or improved wiring will
be needed so owners will have to replace the wires in the conduit. Including conduit to the spaces is a good practice as conduit
can handle whatever technology improvements are made in the future.
We are all interested in facilitating EV’s and as building owners we are well incentivized to meet the demands of our tenants.
Let’s monitor the situation and develop an ordinance if and when needed. New development in the Willow corridor will offer ample
opportunity to test the provisions of what is being proposed city wide.
Respectfully,
Bob Burke and Steve Pierce
Greenheart Land Co.
