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Well-known member
May 3, 2014
California Energy Commission
Fuels and Transportation Division
1516 Ninth Street, MS-27
Sacramento, CA 95814

16 February 2015


Dear California Energy Commission Members,

I was the first person to drive an all-electric vehicle (EV) from Mexico to Canada, and first to travel across both Oregon and Washington using only DC quick charging along the newly opened West Coast Electric Highway in June 2012. Since that time, travel along intra-state corridors within California is nearly as non-existent as it was then (except for Tesla cars).

What follows are my suggestions for our state's financing of a true "California West Coast Electric Highway" that should be BETTER than what Oregon and Washington state have already done now, almost three years previously, with great success. California has been a signatory partner to the venture since 2009, along with Oregon, Washington state, and the province of British Columbia.

For the purposes of my discussion, an “electric vehicle” is one that is solely “refueled” with electricity that comes from a charging station into the vehicle. Vehicles that are primarily refueled with electricity, but can also be refueled from bio-fuel, alcohol, gasoline, diesel, natural gas or hydrogen are “hybrids” for my discussion. Because hydrogen fuel cell vehicles are considered by some to be “electric vehicles” too, I want to be clear that I am referring to the refueling infrastructure in the following comments, and therefore a hydrogen fuel cell vehicle is not an electric vehicle for my discussion, but it may be a hybrid.

I propose that our state fund a logical California West Coast Electric Highway system comprised of 40 multi-charger (2 minimum) “Plazas” that are powered by onsite batteries, and the batteries are replenished with solar, wind power where applicable, and “single” phase sub-20kW grid power to mitigate or eliminate “demand charges”. These sites would cost approximately $250,000 per site and be placed at 60-100 miles apart along the major corridors that already have freeways:

1) Los Angeles to Sacramento, via 5 and 99
2) Los Angeles to Las Vegas, via 15
3) Los Angeles to Phoenix, via 10
4) Los Angeles to San Francisco via 101
5) San Francisco to Reno via 80
6) San Francisco to Oregon via 101
7) Sacramento to Oregon via 99 and 5
8) San Diego to Yuma via 8

These are the logical routes the Californians actually drive to already. With numerous 100-200 mile electric cars on the horizon from major auto manufacturers like General Motors and Nissan, and also premium auto makers like Tesla and Jaguar, these routes must be planned for the near future, but made capable with existing cars that have sub-100 miles ranges. For those cars, I recommend placing small 20kW DC chargers in between each Plaza site, which will not need batteries or infrastructure to eliminate demand charges.

For just half the amount of money devoted to hydrogen cars for just one year (just $10 million) by our state, California could have the premier EV infrastructure that is the envy of any place outside of Japan (Japan is heavily promoting hydrogen, yet they also have a VERY robust EV quick charge infrastructure; literally THOUSANDS of DC quick chargers, and it's growing by one thousand or more per year!). An addition $2.5 million would fund the 50 additional low powered (20kW) sites at $50,000 per site.

People who live in small towns in California deserve the same proportional level of EV infrastructure as those in metro areas. All Californians need to be able to drive their EV's anywhere along heavily traveled routes with high confidence, like they currently do in Japan, Washington, Oregon, and large parts of Europe. It's embarrassing how far behind we are, and that we're now debating whether it should be done properly (while also considering diverting those state resources to more at-work charging).

Building that critical corridor EV charging infrastructure will not only allow mobility without CO2 emissions, but also gain confidence for the next wave of EV purchasers who have never had an EV, and might not own one were it were not capable of driving to "drive to Vegas / Reno / Tahoe / Yosemite / ski slope / etc.

With the aforementioned 200 mile range cars from GM, plus our own California company Tesla and, of course, Nissan (it has been announced that GM is only 20 months away from production of their 200 mile Chevy Bolt, for instance, with plans for 25,000 - 30,000 annual production), BMW and VW are certainly likely to make their EVs longer range, sooner than later.

The folks who want to travel in their EV (or any car) may not be those "rich" homeowners with multiple cars sitting around, one specific for each type of drive. A singular EV may be their only car. They may be retired, unemployed, student, traveling sales person, airline pilot, stay at home mom, and lots of other personal situations where more at-work charging doesn't help them. 200-300 mile EV's don't need at-work charging anyway.

Folks who currently own 75 mile range cars can still use this proposed EV highway. Just because one of the corridors might go from Sacramento to Ashland, Oregon (southern most build out of current West Coast Electric Highway) doesn't mean that all people would drive that whole length (that seems to be a common thought... nobody will drive a 75 mile car that whole route, so don't build it).

One 75 mile range car may only want to go from Sacramento to Red Bluff (131 miles of flat terrain) and another 75 mile car may go from Redding to Yreka (99 miles in the mountains). A third may do the entire route to visit their family in Medford, Oregon for the holidays.

Yes, a 75 mile EV is bit of a pain in comparison to those new 200-300 mile EV's coming (or any gasoline car), but this might be the only option... drive the 75 mile EV, or don't go. That corridor made all this possible.

Without the corridor, even the driver of the 200 mile range car isn't likely to want to make the trip to Medford. Heck, you wouldn't drive your gasoline or hydrogen car there if there wasn't infrastructure!

Much like putting in Coke machines, California companies are fully capable of putting in low powered charging for their employees at the work place. If we want to promote at-work charging, give them a tax credit or state sponsored education promoting the virtues of EV charging at work. This view may not excite charging equipment companies (of which I am one) who are lobbying for state money, but it's the tough love our industry needs.

Our nation didn't build its interstate highway system only to major metro areas and at work places. It is the same high quality roadway in eastern Nevada or Montana (where nobody lives), and even Yreka, California as it is in any major metro area.

The California West Coast Electric Highway should be that same high standard everywhere in our state. It will help all people in California with an electric car, not just a select privileged few with employment in major metro areas. It brings jobs and business to rural areas.

It promotes EV emission free driving and EV sales. It connects us to the existing West Coast Electric Highway that our state has been a signatory of since 2009. It entices neighboring Nevada and Arizona to build their infrastructure, at least connecting Reno, Las Vegas, Phoenix and Tucson to California, places that Californians drive to every day.

It puts California on the forefront of demonstrating to other states and the world how it should be done. It will ensure we attain the millions of Zero Emission Vehicles that the governor wants on the road. Our infrastructure can be the gold plated standard and inspiration that our state's Air Resources Board rules are to a multitude of states, including Washington and Oregon.

Toyota, the world's largest auto manufacturer and biggest proponent or hydrogen refueled cars (and public opponent to EV's) has publically stated that they will only build "up to" 3000 hydrogen cars for California in the near term and "hope" to have as many as 6000 in Japan by the 2020 Olympics in Japan.

Hydrogen cars won't be the driving force that puts millions of cars in California displacing fossil fuel cars any time soon, and certainly not by 2020-2025.

Soichiro Okudaira, chief officer of Toyota’s research and development group, told Automotive News Europe said that, "fuel cell vehicles won't be priced to compete with battery electrics before 2030." If hydrogen cars are our state's future, according to Toyota, we have at least 15 years to have the best EV infrastructure in the world.

Then, if that hydrogen future doesn't quite work out by 2030, we were not sitting on our hands just waiting for what has always been the "fuel of the future" while everybody burned gasoline to go to Las Vegas and Reno. I predict that 200-300 mile cars will be the norm by then, and refueling times will be double or triple the existing speed, adding 150 miles of range in 10-15 minutes or less while on the road.

Hydrogen really has a significant number of hurdles to overcome, and EV's really only have a few simple ones. Range, refueling time and refueling infrastructure. The first two will be smartly addressed in the coming decade, and the last one is something our state needs to bootstrap to make the first two worthwhile.

We should never be falling behind in any technology, but our state is woefully being other states and countries in this venture, including those that are "sold" on hydrogen and have work place charging. Hopefully, today is the turning point.



Tony Williams
R&D Manager
Quick Charge Power LLC
SUBJECT: Comments on DC Fast Charger Installations for CALIFORNIA West Coast Electric Highway

FROM: Electric Auto Association, Electric Vehicle Corridor Charging Group

DATE: March 16, 2015

Introduction and Purpose

What follows is the our input for the completion of the West Coast Electric Highway (WCEH) in California with DC Fast Charger (DCFC) along corridors. We are addressing the following questions:

1. What is the order of the roll out by corridor and why?
2. Is a spacing of 40 miles between DCFCs acceptable?
3. Is starting with one CHAdeMO / SAE unit with conduit for additional chargers acceptable?
4. What are the minimum requirements for a site?

We believe a statewide Electric Vehicle (EV) infrastructure plan should be based on the following principles, and we used these criteria in making our corridor recommendations:

● Connect existing EV metro areas with corridors and complete the WCEH.
● Meet our state’s obligation to the WCEH.
● Maximize population areas served.
● Provide leadership by investing in important corridors with locations that may not be attractive to private industry for economic or logistical reasons.
● Maximize benefits to Environmental Justice Communities.
● Maximize exposure to communities with low EV adoption with access to charging infrastructure that currently only exists in large metro areas.

A patchwork network of DCFC stations already exists in parts of California. Existing stations should be included in the WCEH if they meet the standards discussed in this proposal. To foster this, the state should consider providing grants to existing station responsible parties along the proposed WCEH route if they agree to the proposed California WCEH standards.

In applying these criteria, we have considered the needs of current EVs with driving ranges of 80 miles in addition to the potential 150-200 mile range cars that are expected in calendar year 2017 and beyond. Furthermore, older, lower range cars with long lifespans will also be available for modest sums in this period; opening up EV travel to a wider range of economic classes.

Corridor Roll Out Order Recommendations:

1. Our highest priority recommendation is to develop a charging corridor from the Oregon border at the town of Yreka, then south on Interstate 5 (I-5) to Red Bluff, then State Highway 99 (CA-99) through the Central Valley to connect to I-5 again south of Bakersfield, and finally to the US / Mexico border in San Diego. In considering the routing of the WCEH and evaluating the choice between the I-5 and CA-99 corridors, we strongly urge the selection of the CA-99 corridor. This route serves the heart of the Central Valley with its current population of 5.7 million. These counties combined had a faster population growth rate than other regions of California. CA-99 connects the largest number of metro areas, can provide fast charging within these underserved communities, and supports air quality improvements in regions needing it most. The Valley’s air quality remains at non-attainment levels throughout. The Valley has the most people at risk for asthma, bronchitis and emphysema.

State support for the CA-99 corridor creates the opportunity for EV ownership for those who currently can't participate in the EV community. This will maximize the long-term investment the public has made in these vehicles by allowing the use of used EVs the ability to serve a wider geographic area where they are needed the most. Also, it opens up these routes for users who do not have the economic means to purchase new EVs. The per capita income of the Valley is significantly below the state average. While the cost of new EVs may make them beyond the reach of these residents, the used car market for EVs is showing these vehicles will likely be affordable if there is adequate public charging support to deal with the reduced range.

2. After the I-5 / CA-99 / I-5 North-South corridor is completed, then we recommend installing DCFCs on US Highway 101 (US-101) between Los Angeles and San Jose as the next highest priority. This will connect the San Francisco Bay Area and Santa Barbara / Santa Ynez regions with the Salinas Valley, Monterey, and the Central Coast (population 2.3 million). There will be approximately a 200 mile gap once the Sunspeed Network DCFCs are completed in San Luis Obispo later in 2015, and this gap could be filled with only 4 charging stations separated by approximately 40 miles. For example, these locations could be in Gilroy, Gonzales, San Lucas, and Paso Robles. The Gonzales and San Lucas stations are located in relatively remote regions of the Salinas Valley so it is important for the state to develop these locations than may not be attractive to private industry. This corridor could connect the Central Valley to the Central Coast.

Is a spacing of 40 miles between DCFCs acceptable?

We are concerned about ensuring that a failed station does not strand a driver. A 40 mile distance means a failed station requires an 80 mile range. This exceeds the range of the most common short range EVs such as the Nissan LEAF. The EPA range on these cars of 80 to 85 does not cover freeway speeds, or travel with significant heater or air conditioning use, or a reduced range expected after a few years of operation from “battery degradation”, and / or the 80% maximum charge limit with some DCFCs.

The backbone of the Central Valley corridor should have stations in larger existing communities to maximize the overall goals of the program. Placing stations at Yreka, Weed, Dunsmuir, Redding, Red Bluff, Chico, Oroville, Yuba City, Sacramento, Lodi, Stockton, Modesto, Turlock, Merced, Madera Fresno, Selma, Tulare, Delano, Bakersfield, Lebec, Castaic serves these communities and provides a spacing between 14 and 40 miles. This will also provide service to the large number of Environmental Justice Communities identified in this corridor. In the rural areas north of Redding, it may be necessary for stations to be placed outside of a town.

A 40 mile separation can work if there are several L2 backing up failures of the DCFC. In the case of a DCFC failure, a limited range vehicle would have to take time to add additional miles with the L2 charge station. Assuming 1 hour of incremental L2 charge is necessary to reach the next station, two backup L2 chargers would handle an arrival rate of one per 30 minutes, and four would handle one per 15 minutes. In addition, L2 can serve local needs as well as a backup to a failed DCFC.

Shorter than 40 miles spacing will be required for corridors with significant elevation gain and / or cold climates. Approximately 6 miles of range are lost for every 1000 foot increase in elevation for a typical EV. This will affect the northern part of I-5 between Redding and Yreka and over the “Grapevine” between Bakersfield and Los Angeles.

Is starting with one CHAdeMO / SAE unit with conduit for additional chargers acceptable at each location?

Yes, a single station with both CHAdeMO and SAE charging standards should be the minimum. We recommend alternating 50 kW and 100 kW units to provide a network that is adequate for both the current short-range EVs (charge at 50 kW every 40 miles) and support the longer range EVs to be introduced in 2017 and later (charge at 100 kW every 80 miles).

As stated above, there needs to be at least two L2 charging stations at each location (with infrastructure to add more if needed) to serve as backup for failure as well as overflow capacity. More than two may be required for higher traffic areas and local needs.

Since no current 100 kW DCFC units are currently available, we recommend that these alternating sites have transformers and other infrastructure capable of 100 kW operation. All sites should have conduit installed to meet this future eventuality.

What are the minimum requirements for a site?

Sites should provide (in descending order):

● 24 hour / 7 day availability (not locked in a parking garage or limited access private area)
● Safety / security & comfort (lighting, adjacent to some services, etc)
● Highway exit signage that conforms to existing WCEH standards set by Oregon, Washington and British Columbia
● Parking lot signage with logical and easy to follow directions
● Parking stalls marked with California Vehicle Code (CVC) 22511 language

Highly valued criteria (in descending order):

● Restrooms
● Food service
● Shading from sun, possibly with solar PV panels

Additional Remarks

The DCFCs will have to be easy to use and be well maintained for long distance corridor charging networks to be successful. It would be ideal if all corridor DCFCs could accept at least one common form of payment, e.g., a credit card and optionally the addition of a common network card. Second, locating them close to the corridor highways (within 5 minute drive time). The stations need to be publically available at all times (24 x 7 x 365) to all compatible vehicles.

Reliability / Uptime

The CEC provided significant leadership in prior years to support the rollout of charging stations with significant value enabling EV sales growth. Unfortunately, we are seeing that several brands of DCFCs have shown high mortality rates and are undergoing expensive repairs and / or have long lead times to repair. Certainly, a downed charger increases costs, but beyond that, a downed station may create a break in the chain that prevents many EVs from transiting the corridor. Just as important, it takes away confidence in the use of public charging stations.

We recommend three actions:

● With respect to failure rates, require 10 year warranties on all equipment. The warranty might have two components, a 5 year base warranty by the DCFC manufacturer and / or distributor of that equipment, and an extended warranty which might be funded by the station owner. The warranty should cover parts and labor.

● A target of 99% uptime should be required. Each proposal for a station should have a manufacturer’s preventive maintenance plan supported and implemented. The uptime requirement would be exclusive of rare preventive maintenance with published down times at late night. Lack of preventive maintenance is a high source of failures, particularly with high amperage equipment in hot locations, as is with much of WCEH.

● Reliability issues often arise from the payment and networking components. The individual DCFCs must be capable of operating when the network, card reader or fob reader doesn’t work. In other words, the default setting is that it ALWAYS works, and that the networking and payment methods are additions. This is a significant change from the status quo. Care should be given to avoid solutions that increase station failure rate. It’s not uncommon for us to see failures with credit card readers at gas stations. In that case, a gas car driver can switch to another reader or go inside a station to pay, ensuring they won’t be stranded. We need a level of dependability and driver confidence on the same level as gas stations.

Maintaining the DCFCs in operational status with infrequent faults is essential for providing a reliable network. Status information (vacant / non-operational / in-use) must also be available via the internet (for instance, on the CalTrans site) or a mobile app (ideally in real time).

To win the struggle of our current and future transportation needs, we must decide to accept the challenges and move forward with funding and action. Let’s demonstrate strong leadership for EV adoption through completion of the WCEH.

Thank you again for providing this opportunity to comment, and please do not hesitate to contact us in the future.


Ron Freund,
San Francisco Bay Area Chairman EAA
Randal Friedman Sacramento
EAA Member

Guy Hall
President SacEV
EAA Board Member

Randal Friedman
EAA Member

Tony Williams
San Diego
Quick Charge Power LLC
BC2BC Rally Organizer

Tom Greene
Redwood City
EAA Member

Paul Gipe
Author, Renewable Energy Industry Analyst
EAA Member
CHAdeMO stations are great (who uses SAE??) - especially if you mod your Be to get a JdeMO ; but I'd also like to encourage high-amperage L2 (haL2) installations with more frequency; cost per station is lower and it can be easier to arrange with quasi-destination charging (hotels, lunch, parks, etc)

I refer to the following which is something in the pacific northwest - where we have a dense CHAdeMO coverage on I5 and other highways but a great low-density area sprinkled with 72A J1772 EVSEs. Of course not all cars are suited to A complimentary strategy to many CHAdeMOs that may help increase coverage ROI.


Plug-In North Central Washington is a 501 (c) 3 registered non-profit organized for the purpose of encouraging EV adoption and tourism in north central Washington. The high amperage L2 (haL2) project is focused on placing Clipper Creek CS-90 (240V 72A) EVSE in our area of operations. We are using the Sun Country Highway model. We raise money to purchase the the CS-90, seek host business/proprietors who operate sites that meet our requirements then execute a 36 month agreement with them to maintain and manage the equipment. Plug-In NCW also promotes the host location by planning EVents and other activities that gain the host site visibility in the community and expose residents to EVs. These are our intended sites:
We could probably cut you the deal of a lifetime on future units.

Our future JAMP SR will be available in 48, 64, 72 and 80 amp ratings.

It will come with our mega flexible 80 amp rated cable,

Available Fall 2015.

We are an eastern Washington based company in Kennewick.