New Jersey’s march toward electric trucks and buses has picked up speed in the last few years. This summer, the New Jersey Board of Public Utilities released a preliminary proposal outlining the development of charging infrastructure for medium- and heavy-duty vehicles throughout the state, inviting stakeholders to participate in public discussions and provide written comments. This straw proposal has incredible potential to ready New Jersey for the coming wave of electric buses and trucks and to accelerate and build on existing progress.
Environmental Defense Fund filed written comments on this proposal yesterday. The takeaway? Though it sets the stage for some progress, the straw proposal has some gaps that suggest the BPU’s vision for electrifying trucks and buses misses key public benefits and some fundamental realities of how the transformation will occur. As written, it limits the potential and power of a well-calibrated BPU framework for electrifying the sector and risks undermining New Jersey’s climate, clean energy, equity and economic goals.
New Jersey’s steady progress
New Jersey’s 2019 Energy Master Plan calls for electrification of the state’s transit fleet; industry partnerships to develop electrification incentives; and expansion of clean transportation options in low- and moderate-income communities that are disproportionately impacted by diesel pollution. The state’s 2020 Plug-In Vehicle Law requires transit electrification on a set schedule and directs agencies to establish other goals for truck and bus electrification and associated infrastructure development.
New Jersey also signed on to a multi-state agreement committing to transition trucks and buses in the state entirely to zero-emission, starting with 30% of vehicle sales by 2030.The state has taken positive steps toward achieving these goals by committing Regional Greenhouse Gas Initiative and Volkswagen settlement funds to electrifying medium- and heavy-duty vehicles and establishing a new program, NJ ZIP, to support the purchase of new Class 2b-6 trucks.
Support for private charging is essential
EDF and other transportation electrification advocates have been working with fleet owners for years, advocating for the need to electrify trucks and buses and listening carefully to understand the logistical and financial roadblocks they face during this transition. Upfront cost is paramount – not just the cost of new vehicles and the charging hardware required for operation, but also the electric infrastructure upgrades that will ready depots for charging.
Unfortunately, the straw proposal excludes these on-site make-ready costs from ratepayer support at private charging facilities — imposing millions of dollars of additional costs on the fleets New Jersey has said it wants to electrify. And this is over and above the expense of buying cutting-edge vehicles and chargers. Early-adopter electric truck fleets need guaranteed access to charging. Because public charging infrastructure does not provide guaranteed access, fleets rely overwhelmingly on private charging equipment. Moreover, most companies will not be able to open up their private charging to the public because it will interfere with their logistical operations.
But that doesn’t mean that their charging infrastructure benefits only themselves. Early adopting fleets can bring a wide range of public benefits, including advancing the EV marketplace in the state, improving the efficiency and resiliency of the entire electric system and its ability to integrate intermittent renewable generation through thoughtful vehicle-grid integration, and rapid air pollution reduction benefits in the locations where their vehicles operate.
We strongly encourage the BPU to authorize some funding of make-ready infrastructure at the depots of electrifying fleets as an essential element to jumpstart fleet electrification on the timeline and scale envisioned by the state.
Equity is a core benefit
The straw proposal rightly explains that electrification of New Jersey’s buses and trucks will improve air quality. But it fails to recognize this benefit is more than an incidental consequence. Harmful pollution from diesel medium- and heavy-duty vehicles disproportionately affects already overburdened communities.
In the context of the energy transition, equity isn’t just about spreading the benefits of electrification equally. It includes deploying clean solutions like electric trucks and buses in a way that addresses the health inequity imposed upon generations of New Jerseyans. Beyond the long-term climate benefit of removing millions of tons of diesel pollution, cleaning the air in New Jersey’s overburdened communities is a core benefit of transportation electrification and should be a core principle of how the BPU develops its long-term plan.
The BPU’s ultimate order in this proceeding should require utilities to work with community groups to address barriers to truck and bus electrification in overburdened communities, recognize health benefits associated with reduced diesel emissions, and evaluate the success of charging infrastructure deployments partly based on success at obtaining these benefits in locations with the highest air pollution burdens.
Goals and long-term planning drive success
Despite truck and bus electrification goals emanating from various parts of New Jersey government, from the NJ Transit bus electrification mandate in the Plug-In Vehicle Law to the sales goals embodied in the multi-state agreement, the straw proposal does not target any medium- and heavy-duty electrification goals. The lack of goals not only makes it impossible to judge success, it makes it very hard to understand what the BPU is actually shooting for.
This lack of direction is reinforced by the failure to task utilities with the responsibility of planning for the electric transportation future. Instead, the BPU envisions utilities giving other companies tools for anticipating affordable places to site charging — a useful tactic if customers have flexibility as to where they charge, but non-responsive to the needs of most fleets with existing depots that inevitably will need upgrading. Even more importantly, no non-utility party can reasonably anticipate or plan for system-level needs that full-scale electrification will trigger — only utilities themselves can do that. And if no one plans for these system-level upgrades, the result will be massive medium- and heavy-duty electrification delays and higher costs when the need for those upgrades materializes in the form of an unforeseen crisis.
We strongly recommend the BPU’s final order be designed to achieve clear electrification goals that are consistent with other New Jersey programs and policies, and that it direct utilities to do their part to plan for that level of achievement.
It is a positive sign that the BPU released its first draft to key stakeholders for robust discussion, public review and comment. But as drafted, the straw proposal won’t get us where we need to be, and New Jersey’s efforts to electrify its bus and truck fleets will fall far short. By adding elements such as those recommended here and in our public comments, the BPU can set the stage for New Jersey to meet its truck and bus electrification goals on schedule and in the most affordable and beneficial way.