BILL ANALYSIS                                                                                                                                                                                                    �






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: SB 730
          SENATOR MARK DESAULNIER, CHAIRMAN              AUTHOR:  kehoe
                                                         VERSION: 3/22/11
          Analysis by:  Mark Stivers                     FISCAL:  yes
          Hearing date:  March 29, 2011



          SUBJECT:

          Electric vehicle charging equipment

          DESCRIPTION:

          This bill requires local building inspectors to make available 
          an online permit application for the installation of electric 
          vehicle charging equipment, issue such a permit within 24 hours 
          of receipt, and conduct an inspection within seven days of 
          completion of the work.  The bill also makes local governments 
          that comply with the above requirements eligible for funding 
          from the Alternative and Renewable Fuel and Vehicle Technology 
          (AB 118) Program. 

          ANALYSIS:

          Current law authorizes but does not mandate cities and counties 
          to require building permits for the construction, alteration, 
          improvement, demolition, or repair of any building or structure. 
           If a city or county does require such building permits, current 
          law requires them to use a statutory form for permit 
          applications.  Current law also allows cities and counties to 
          charge fees of applicants to cover the costs of the permit and 
          inspection program.

          AB 118 (N��ez), Chapter 750, Statutes of 2007, created the 
          Alternative and Renewable Fuel and Vehicle Technology Program, 
          which the California Energy Commission (CEC) administers, to 
          provide grants, revolving loans, loan guarantees, loans, or 
          other appropriate funding measures to public agencies, vehicle 
          consortia, businesses, consumers, recreational boaters, and 
          academic institutions to develop and deploy innovative 
          technologies that transform California fuel and vehicle types to 
          help attain the state's climate change policies. 

          Funding of approximately $100 million annually for this program 
          comes from additional fees on vehicle registrations, special 




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          identification plates for various vehicles, and vessel 
          registrations, plus $10 million annually from the Public 
          Interest Research, Development, and Demonstration Fund, which is 
          derived from a portion of electric utility rates.

          Existing law makes the following projects eligible for funding 
          under the Alternative and Renewable Fuel and Vehicle Technology 
          Program: 

               Alternative and renewable fuel infrastructure, fueling 
              stations, and equipment.
               Projects to develop and improve vehicle technology that 
              provide for better fuel efficiency and lower greenhouse gas 
              emissions.
               Alternative and renewable fuel projects to develop, 
              improve, demonstrate, deploy, produce, and commercialize 
              alternative and renewable fuels, plus reduce the overall 
              carbon footprint of these fuels.
               Vehicle retrofit projects to create higher fuel 
              efficiencies.
               Infrastructure projects that promote alternative and 
              renewable fuel infrastructure development for existing 
              fleets, public transit, and existing transportation 
              corridors. 
               Workforce training programs related to alternative fuels 
              and vehicle technology.
               Block grants administered by not-for-profit technology 
              consortia for specified purposes.
               Analyses and assessments performed by state agencies to 
              determine the impacts of increasing the use of low-carbon 
              transportation fuels and technologies.
               Programs to provide funding for homeowners who purchase a 
              plug-in electric vehicle to offset costs associated with 
              modifying electrical sources to include a residential 
              plug-in electric vehicle charging station.

          The CEC, through a competitive process, allocates these funds to 
          alternative fuel and vehicle technology projects.  To set 
          priorities for the allocation of funds, the CEC must develop an 
          investment plan in consultation with a wide array of 
          stakeholders.  In February of this year the CEC released a draft 
          of its plan for the 2011-12 fiscal year.  The draft plan 
          proposes allocating $8 million for plug-in electric vehicle 
          charging infrastructure, including $1 million for "projects that 
          will support the streamlining of permitting, installation, and 
          inspection of residential charging infrastructure."  According 




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          to the draft plan:

               The permitting, installation, and inspection of residential 
               charging infrastructure needs to be seamless.  The process 
               will vary for each community and for each installation, but 
               on the whole, it is complex, costly, and protracted.  The 
               average residential installation time between ordering and 
               installing charging equipment can be more than four weeks.  
               Although the actual charging panels may take only a few 
               hours to install, the entire process depends on a series of 
               site visits including the utility company, licensed 
               electrician, city permitting office, and city building 
               inspector.  Regions are currently brainstorming to find 
               ways to streamline the process and reduce the time for 
               installation. It is also important to provide education to 
               local government jurisdictions that often lack knowledge 
               about the permitting process for PEV charging 
               infrastructure and provide assistance to permit and 
               inspection offices facing workforce reductions.

           This bill  requires local building inspectors to make available 
          an online permit application for the installation of vehicle 
          charging equipment, issue such a permit within 24 hours of 
          receipt, and conduct an inspection within seven days of 
          completion of the work.  The bill also makes local governments 
          that comply with the above requirements eligible for funding 
          from the Alternative and Renewable Fuel and Vehicle Technology 
          (AB 118) Program.
          
          COMMENTS:

           1.Purpose of the bill  .  According to the author, electric 
            vehicle manufacturers and service providers have identified a 
            serious delay between the time someone purchases an electrical 
            vehicle and when the necessary permit, installation, and 
            inspection of electric vehicle charging equipment is complete. 
             These delays range between 20 and 40 days.  Lengthy delays in 
            this process have the potential to dissuade perspective EV 
            purchasers from that purchase.  In order to promote the market 
            penetration of zero-emission electric vehicles, the author 
            asserts that it is in the state's best interest to ensure 
            there is a process in place at the local government level that 
            enables the smooth deployment of electric vehicle charging 
            infrastructure.
          
           2.More complicated than it may appear  .  As the CEC's draft AB 




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            118 investment plan for 2011-12 describes, permitting electric 
            vehicle charging stations is complex.  One reason for this 
            complexity is that, unlike most building permits, and electric 
            vehicle charger essentially requires sign off from two 
            entities: the local building permit department and the 
            electric utility.  This is because obtaining a permit is not 
            just a matter of having the correct building plans.  If an 
            electric panel upgrade is required, as will probably be the 
            case with an EV charger, the electric utility must certify 
            that the power lines to the home have sufficient capacity to 
            handle the increased demand, which may not always be the case. 
             In most areas, the building department and the utility are 
            entirely unrelated, so streamlining the timing of a permit 
            requires efficient communication.  

            The City of Los Angeles recently announced an initiative to 
            reduce permitting, inspection, and meter installation times 
            for home electric vehicle chargers to less than seven days.  
            Under the initiative, the city's Department of Water and Power 
            (LADWP) will be available to conduct home pre-inspections to 
            identify potential issues with an installation and assist 
            customers who may have problems.  Vehicle owners may then 
            obtain permits instantly online, and the city will inspect the 
            installation within 24 hours of request.  Once installation of 
            the charger is complete, LADWP will expedite a new meter.  In 
            addition, LADWP has upgraded 1,223 distribution transformers 
            and replaced 479 poles in its vast power grid to address 
            potential system impacts related to EV charging.  This 
            initiative is possible in part because of the proactive grid 
            upgrades and the fact that the building department and the 
            utility are under the same city umbrella.  Especially 
            considering that the bill does not require utilities to 
            fulfill their obligations in any specific timeframe, it is not 
            clear that 24 hours will be sufficient to approve permit 
            applications even when a city and county has sufficient staff 
            for the workload.  
           
          3.Local fee authority  .  This bill on the one hand requires local 
            governments to streamline their permitting processes for 
            electric vehicle chargers and on the other hand offers them 
            funding to do so.  Traditionally, incentive funding has been 
            used to motivate behaviors not already required by law.  This 
            bill takes the opposite approach of paying local governments 
            for an activity that the bill requires anyway.  To the extent 
            that only some cities and counties will be able to secure AB 
            118 grants, this could lead to inequities in which all have to 




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            streamline their processes and only some are paid for it.  
            Moreover, local governments have and use the authority to 
            charge fees of all building permit applicants to cover their 
            building permit programs.  The committee may wish to consider 
            whether incentive funds should be used to pay for a required 
            activity.
          
           4.Already an envisioned use of AB 118 funds  .  Under current law, 
            the CEC staff is proposing to allocate $1 million of AB 118 
            funds for projects that will support the streamlining of 
            permitting, installation, and inspection of residential 
            charging infrastructure.  It is therefore unclear how this 
            bill affects the AB 118 program because it simply declares 
            such expenditures as eligible, not required.  

           5.Arguments in opposition  .  The League of California Cities 
            states that the vast majority of cities do not have any form 
            of on-line building permit system and that creating an online 
            portal from scratch for one fairly infrequent type of permit 
            will be costly.  Moreover, an online application may actually 
            delay issuance of a permit because the building inspector will 
            not be able to ask questions of and interact with the 
            contractor, as would be possible at the counter.  The 24-hour 
            turnaround requirement will not be possible in many 
            jurisdictions, especially smaller cities that may only have 
            one staff person for all permits.  Lastly, the League argues 
            that it is improper to give priority status to one type of 
            permit because other types of permits, such as rehabilitation 
            of a substandard home, will have to be delayed.  

           6.Possible alternative approaches  .  To address the various 
            issues described above, the committee may wish to consider one 
            of the following two alternative approaches to promote the 
            streamlining of permits for electrical vehicle chargers:

                 Delete the requirement for online applications and delay 
               the effective date of the 24-hour permit issuance 
               requirement by six months.  Deleting the online requirement 
               would significantly reduce the cost of the mandate, lessen 
               the nature of the preferential treatment for EV charger 
               permits, and continue to allow for interaction between the 
               building inspector and the contractor.  Cities and counties 
               could still develop online systems if they so choose.  
               Delaying the effective date would give cities and counties 
               more time to staff up and put systems in place to meet the 
               24-hour mandate, as well as synchronize implementation with 




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               the beginning of most cities' and counties' fiscal year.

                 Delete the mandate entirely but limit the availability 
               of AB 118 funding to those cities and counties that do 
               choose to implement online applications with a 24-hour 
               turnaround.  This approach would provide an incentive for 
               cities and counties to meet the goals of the bill without 
               requiring all jurisdictions to assume the costs of the 
               mandate.
          
          RELATED LEGISLATION:

          SB 209 (Corbett) provides that a prohibition or restriction on 
          the installation or use of an electrical vehicle charging 
          station in any of the governing documents of a common interest 
          development is void and unenforceable.  This bill will be heard 
          in the Senate Transportation and Housing Committee on March 29, 
          2011.

          POSITIONS:  (Communicated to the Committee before noon on 
          Wednesday,                                             March 23, 
          2011)

               SUPPORT:  Plug In America

          
               OPPOSED:  League of California Cities