Way back at the beginning of 2023, we reported on the approval by the Massachusetts Department of Public Utilities (DPU) of new electric vehicle (EV) programs by the electric utilities National Grid, Eversource, and Unitil. Together, the utilities got the OK to spend more than $400 million on helping to build out EV charging infrastructure over the next four years. We are now halfway through that program, and the utilities have just filed “Mid-Term Modification Proposals” with the DPU. You have the right to weigh in at the DPU – here's everything you need to know.

Why is this important? 

Every major EV-related study or poll makes it clear that a lack of access to charging, whether at home or when traveling, is a primary barrier holding people back from ditching their old gas-powered cars in favor of EVs. Our Electric Vehicle Infrastructure Coordinating Council (EVICC) has found that to meet our 2030 emissions reduction mandate of 50%, we will need 10,000 public DC Fast Charging ports, 35,000 public Level 2 charging ports, and 700,000 workplace and residential charging ports. Right now, we’ve got 1,069 DC ports and 7,456 Level 2 ports per the Alternative Fuels Data Center. (The number of workplace and residential ports is not easily tracked.) Clearly, we’ve got a long way to go in a short number of years. The programs offered by our utilities are one of the main public policy tools at our disposal to support this build-out and are therefore crucial to maintain. 

Reminder: What are the programs? 

National Grid and Eversource, the two utilities we focus on, offer financial support to residential and commercial customers who want to install EV charging. The funding can support both “Make Ready” investments (in other words, wiring upgrades) and the purchase of the actual EV charging station hardware. The amount available in each category depends on the type of customer and the location, particularly if the site is in an environmental justice community. We lay out all the details here for residential consumers (including renters!) and here for commercial entities. 

The original order from the DPU sets budgets for different categories of work – residential vs workplace and public charging vs fleets, etc. The programs have been very popular. In fact, both National Grid and Eversource have run out of funding in some segments. National Grid has run out of funding for public and workplace charging (both DC Fast Charging and Level 2) but still has some funding available in residential, multifamily, and fleet segments. Eversource only has funding left for residential and multifamily segments, and only for Level 2 charging. 

What are the utilities proposing now? 

The mid-term modification proposals allow the utilities to adjust course, based on their experience so far. Here are their proposals. (For those of you who want to dive deep into the DPU’s virtual filing room, Eversource’s docket number is 24-195 and National Grid’s is 24-196.) 

Allowing Third-Party Funding (Both Utilities) 

When the DPU issued its order back at the end of 2022, it required that: 

1. Any participating site hosts apply for any “available” and “aligned” third-party funding (including, but not limited to, MassEVIP funds);
2. And that the utility subtract whatever third-party funding is awarded from the utility award.  

We’re all for not double-paying for the same costs, but the DPU order effectively prohibits site hosts from stacking different incentive programs. For example, a municipality that wants to use utility Make Ready funds for wiring upgrades and MassEVIP funds for the actual charging hardware cannot combine these incentives, even though they pay for different pieces of the pie. We’ve heard from many site hosts – particularly municipalities – that this has stopped them from moving forward with installations. The utilities’ mid-term modification proposals call for changing this rule, so that site hosts can stack incentives, as long as they don’t end up getting reimbursed twice for the same costs. We strongly support this proposal. 

Budget Shifting & Reducing DC Incentives (Both Utilities) 

Both Eversource and National Grid propose to shift some funds from segments that are undersubscribed so far (mostly the residential segment) to segments that are oversubscribed or new. Eversource’s proposed budget shifts are under the limit where they don’t need to explicitly ask for permission (15%); National Grid is asking to exceed that percentage. And both utilities are proposing to reduce the incentives available for DC Fast Charging installations so that more of the available dollars can go towards Level 2 installations. We support these proposed changes, as they attempt to make the most of limited dollars. 

Changes Proposed By Eversource Only 

1. Supporting medium- and heavy-duty (MHDV) fleets. In its original filing, Eversource proposed a pilot program to offer incentives for infrastructure upgrades for MHDV with Make Ready incentives. That pilot was quickly fully subscribed, and now the utility is requesting to scale it up, with $5 million in new funding to cover infrastructure upgrades for public and private fleets and tiered incentives for the chargers themselves for government fleets. 
2. Bi-directional charging pilot. Eversource is proposing to shift $500,000 from the residential make-ready program funds to support a pilot investigating bidirectional charging to enable vehicle-to-grid (V2G) charging for MHDVs. We’re super excited about this, as unlocking the ability for stationary vehicles like electric school buses to discharge electricity back onto the grid has huge potential for helping us shave the peak and manage electricity costs for all of us, overall. 
3. Residential managed charging program. We have been calling on Eversource to offer a managed charging program to drivers all the way back to 2021, when they first proposed the plan that became the EV program approved by the DPU in 2023. So, we’re glad to see them rolling something out. The proposed Off-Peak Rewards program will offer customers $10 a month if 90% of their charging occurs off-peak (after 9 pm and before 1 pm), with a $50 enrollment incentive. Eversource hopes to enroll 9,000 EVs by the end of 2026. To pay for the program, they’re proposing moving $3 million from the residential bucket of funding. In our public comments, we will question why the program requires this level of funding, as shifting load from peak to off-peak moments results in lower costs in terms of both supply and delivery. 

Eversource’s proposed changes (specifically, the creation of the MHDV program) would result in an increase to the EV program surcharge Eversource customers see on their electric bills. Their filing states that an average residential customer would see an increase of only about 60 cents annually. 

Change Proposed By National Grid Only 

Expanding the off-peak charging rebate program. We have written many times about the need for off-peak charging rebates and similar programs to shift EV demand off-peak – and the fact that we think National Grid’s program should be designed to better align with the real cost benefits of shifting charging off-peak. In its mid-term modification proposal, National Grid is proposing to extend the program through 2026, remove a cap on participation (currently set at 11,000 customers, with 6,000 participating so far), and extend off-peak periods to weekends and holidays. We support all three changes. (In fact, National Grid quotes us in their official testimony as calling for these changes way back in the original 2021 proceeding.) To do so, National Grid is proposing to shift $5 million from the residential sector. Here, again, we will ask the DPU to question why the program requires this level of funding when shifting load off-peak lowers costs. 

National Grid’s proposed changes would increase the electricity bill of an average residential customer by somewhere between $0.70 and $1.70 annually.

How will Green Energy Consumers comment? 

At the public hearing next week, we will urge the DPU to take the following steps: 

1. Approve the proposals to allow for the stacking of third-party funding, so long as total reimbursement does not exceed 100% of installation costs.
2. Request a status update on all program segments, in which the electric utilities report on:
   1. Original allocated funding and funding spent;
   2. Original goal for the number of chargers to be supported, and number of chargers installed through utility programming;
   3. Number of chargers installed in each segment without utility funding;
   4. Expected EV adoption and actual EV adoption.
3. Justify the need for a budget for managed charging incentives when shifting demand off-peak lowers costs. 

Ultimately, we think the proposed changes are reasonable, but we do think the DPU needs to do its due diligence to pull together a comprehensive progress report. 

An Overarching Point on Electricity Rates 

We fully support the existence of utility Make Ready programs because we need such programs to build out the charging infrastructure we need to reach our climate requirements, and because of the documented downward pressure increased EV adoption has on rates for everyone. With all of that said, societally, we need to think about how we fund clean energy programs, from Make Ready to Mass Save. The more we tack additional charges onto volumetric (per-kilowatt-hour) charges, the more we raise the operating costs of the electric technology we need to shift to cut out fossil fuels, like heat pumps and EVs. Not to mention, the more we raise electricity costs in a region where they are already disproportionately high. In Massachusetts, we have an Interagency Rates Working Group that has been tackling this very issue. There are lots of ideas on the table, from shifting costs from volumetric charges to fixed charges, adjusting the utility’s rate of return (basically, how much the utilities get paid per dollar they spend maintaining the system), and increasing support for low-income ratepayers. Our point here is that this issue is much larger than just these mid-term modification proposals and something we all need to work on. 

Take Action 

To submit written comments on these proposals, follow these steps by 5 pm on Monday, February 10. 

Write your comments.

We recommend the following template. (Please note that whatever comments you send in will be posted to the DPU website without redacting personal information.)

1. Approve the utilities’ proposal to allow site hosts to stack available and aligned third-party funding, provided that overall incentives do not exceed 100% of the installation costs.
2. Ask the utilities to justify the budget requested for managed charging programs when shifting load off-peak reduces costs.
3. Build a comprehensive report of status for each program segment to compare progress compared to utility projections and needs according to the first report of the Electric Vehicle Infrastructure Coordinating Council, considering

• • Original allocated funding and funding spent;
  • Original goal for the number of chargers to be supported, and number of chargers installed through utility programming;
  • Number of chargers installed in each segment without utility funding;
  • Expected EV adoption and actual EV adoption. 

Thank you for this opportunity to provide comment. 

Sincerely,

[Your name]

Create a PDF of your comments.

Make sure that the document includes the docket number of the proceeding (DPU 24-195 for Eversource and DPU 24-196 for National Grid).

Send the PDF in by email.

The text of the email must list your name, the docket number of the proceeding, and a “brief descriptive title of the document.” It should be sent to: 

Email the comments to the following addresses:

• Hearing Officer Scott Seigal at scott.seigal@mass.gov and dpu.efiling@mass.gov
• The utilities’ attorneys, John Habib, Esq. and Michael Hershberg, Esq. at jhabib@keeganwerlin.com and mhershberg@keeganwerlin.com
• CC us at drivegreen@greenenergyconsumers.org, so we can keep track of how many comments were sent in! 

Thank you for taking action! With your help, we can make sure these important EV programs are in place through 2027, the end of the original program term.