HomeMy WebLinkAboutStaff Report 4823
City of Palo Alto (ID # 4823)
City Council Staff Report
Report Type: Action Items Meeting Date: 6/16/2014
City of Palo Alto Page 1
Summary Title: EVSE Ordinance City Council
Title: Public Hearing: Recommend Adoption of an Ordinance Requiring All
New Multi -Family Residential and Non -Residential Construction to Provide
for Current or Future Installation of EV Chargers
From: City Manage r
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that the City Council adopt the attached local amendments to the California
Green Building Standards Code requiring that all new Multi-Family Residential and Non-
Residential construction provide for the current or future installation of Electric Vehicle
chargers.
Executive Summary
On December 9, 2013, the Palo Alto City Council, in its regular City Council meeting, adopted an
ordinance requiring all new single-family residential construction to provide the necessary
circuitry for EV chargers. At its December 9, 2013 meeting, the City Council also directed staff
to bring back to them for their review an ordinance that would create EV -friendly
requirements for all new construction of multi-family residential and non-residential
structures.
Staff convened the EVSE Task Force to develop recommendations for the current or future
provision of EV chargers in the following circumstances:
(1) New multi-family residential construction;
(2) New multi-family residential construction, with individual attached parking;
(3) New non-residential structures other than hotels;
(4) New hotels
There are two attachments to this report. “Attachment A” is a draft ordinance that illustrates
how the Task Force’s recommendations may be implemented as a local amendment to the
California Green Building Standards Code. “Attachment B” provides a detailed estimate of costs
for a typical construction project which could incur as a result of the Task Force’s
recommendations.
City of Palo Alto Page 2
On May 13th, 2014, the Policy and Services Committee met for a special meeting to review the
recommendations of the EVSE Task Force. The Committee directed staff to proceed with the
vast majority of the EVSE Task Force recommendations, with minor modifications. With one
exception discussed below, the Committee’s direction has been incorporated into the attached
ordinance.
Background
In response to City Council direction, staff convened the EVSE Task Force to develop
recommendations for new multi-family, non-residential, and hotel parking requirements that
will make Palo Alto a leader in promotion of electric vehicles.
Mobile sources account for well over half of the emissions that contribute to ozone and
particulate matter and nearly 40% of the greenhouse gas emissions in California. In order to
help meet California’s health-based air quality standards and greenhouse gas emission
reduction goals, significant gains are needed in the transportation sector in terms of reduced
petroleum usage.
Governor Brown's Executive Order of March 2012, directs state government to support and
facilitate the rapid commercialization of zero-emission vehicles (ZEVs), with a target of having
1.5 million ZEVs on California roadways by 2025. In order to meet this goal and in order for
electric vehicles to proliferate, it is important that early consumers have a positive experience
and that facilities be readily available to provide convenient charging stations for the electric
vehicles.
According to a 2012 study completed by the California Center for Sustainable Energy in
coordination with the Air Resources Board, approximately 1,000 new plug-in vehicles are being
sold in the state every month and, at that time, Californians owned more than 12,000 plug-in
electric vehicles (roughly 35% of all plug-in vehicles in the United States).
These recommendations are developed in response to numerous requests by stakeholders to
provide building standards that will meet current and future demands for Electric Vehicle
Supply Equipment (EVSE) in multi-family dwellings and commercial (non-residential) buildings.
These recommendations will encourage and support use of electric vehicles as an alternate
means of transportation. The provisions for EVSE for multi-family construction are intended to
provide low-cost strategies that offer choice and savings in design for multi-family unit
homeowners and multi-family tenants wishing to purchase an electric vehicle without
necessitating retroactive installation of higher capacity electrical wiring and supply equipment
for charging electrical vehicles. The provisions for EVSE for commercial construction are
intended to provide sufficient access to electric vehicle charging capabilities.
Staff has met multiple times with a group of stakeholders i ncluding EV owners, EVSE installers,
contractors, and other related parties to review the recommendations brought before the
City of Palo Alto Page 3
Policy and Services for review and the City Council for potential adoption. The
recommendations before you were vetted with the Development Center Advisory Group
(DCAG). During the first part of 2014, staff has continued the meetings with the EVSE Task
Force to draft recommendations for new multi-family, non-residential, and hotel construction.
In addition, staff has reviewed the EV permit fees and process to ensure it is cost neutral and EV
friendly.
Discussion
By adopting the attached ordinance, the City of Palo Alto will require a three-tier combination
of EVSE, EVSE ready outlets, and EVSE ready circuitry for new multi -family and commercial
construction.
The highest tier requires an “EVSE” parking space that contains installed electric vehicle supply
equipment capable of charging at 30A or higher at 208 or 240 volts. The second highest tier
requires an “EVSE-ready outlet,” such that little or no additional work is required to install an
EVSE. The third tier requires “conduit only” (also called “raceway only”) identical to the
requirement the City Council adopted for new single-family construction. A requirement to
provide conduit only may be met by providing an EVSE -ready outlet, and a requirement to
provide an EVSE-ready outlet may be met by providing an installed EVSE.
In an effort to help illustrate to council the impact of these requirements to construction, staff
has built two scenarios based on cost estimates for the purchase and installation of required
supplies and equipment provided in Figure 1-1 in Attachment B.
New Multi-family residential requirements
The ordinance requires the following for new multi -family residential structures:
1. For new multi-family residential construction, the ordinance requires one EVSE-Outlet
or EVSE Installed per unit.
2. For guest parking for new multi-family residential structures, the ordinance requires
Conduit Only, EVSE-Outlet, or EVSE Installed for at least 25% of guest parking spaces. At
least 5% of these spaces shall be EVSE Installed with a minimum of one EVSE Installed
space. A scenario has been provided in Figure 1 -3 in Attachment B.
3. For new multi-family construction with individual attached parking (i.e. tuck-under
garages), the ordinance requires one attached space with Conduit Only, EVSE -ready, or
EVSE Installed. This requirement is identical to the existing requirement for new single
family residences.
New Non-residential requirements
The ordinance requires the following for new non-residential (i.e. commercial) structures:
1. For new non-residential construction, other than hotels, the ordinance requires Conduit
Only, EVSE-Outlet, or EVSE Installed for at least 25% of parking spaces. At least 5% of
City of Palo Alto Page 4
these spaces shall be EVSE Installed with a minimum of one EVSE Installed space. A
scenario has been provided in Figure 1-2 in Attachment B.
2. For new hotels, the ordinance requires Conduit Only, EVSE-Outlet, or EVSE Installed for
at least 30% of parking spaces. At least 10% of these spaces shall be EVSE Installed with
a minimum of one EVSE Installed space.
General provisions
The ordinance further requires that:
1. Property owners provide minimum circuit capacity sufficient to ensure e lectrical service
will be able to accommodate future installation of EV chargers in all spaces where an
outlet or conduit are provided.
2. Conduit Only, EVSE-Outlet, or EVSE Installed be provided for accessible parking spaces,
with the condition that parking will not be restricted to electric vehicles in accessible
spaces with EV equipment or infrastructure.
3. The Conduit, Outlet or EVSE required by the ordinance be located to provide convenient
access, subject to guidelines to be established by the City.
Policy and Services Committee Recommendations
At its May 13, 2014 meeting, the Policy and Services Committee approved the EVSE Task Force
recommendations with three modifications.
First, the Committee directed staff to eliminate a distinction between multi -family residential
structures developed with a condominium map and those developed without a condominium
map. Upon implementing this change, staff found that an additional section dealing with mixed -
use development was redundant and eliminated that section to further simplify the ordinance.
In the event of mixed use development, the single-family and multi-family requirements will
apply to those parking spaces reserved exclusively for residents, the residential guest parking
requirements will apply to those spaces reserved exclusively for guests, and the non-residential
requirements will apply to all remaining parking spaces.
Second, the Committee directed staff to reevaluate the ordinance with the Council in three
years’ time. This will provide an opportunity for the Council to assess EV market conditions,
industry changes, and the practical impacts of the City’s cutting edge EVSE requirements.
Because the ordinance is structured as a local amendment to the Green Building Standards
Code, the Council will automatically be required to revisit the issue in 2016, when all California
Building Codes must be updated and adopted.
Third, the Committee directed staff to insert a requirement that the property owner bear the
cost of electricity for actual EVSE installed in guest parking and commercial development. At
this time, staff recommends returning the issue of payment to the Policy and Services
Committee and moving forward with the remainder of the ordinance. In attempting to
implement the Committee’s direction on this issue, staff encountered a number of detailed
City of Palo Alto Page 5
policy questions for which additional direction is required. In addition, staff is currently
exploring opportunities with the electric utility to develop an incentive and rebate program to
help offset the cost of installing and operating EVSE; staff hopes to bring these issues forward
on a coordinated, City-wide basis. Finally, there is some question regarding the legal ability of
the City to impose such a requirement. This is a developing area of the law, a nd there is a case
pending in the California Supreme Court that may shed light on these issues. To allow further
guidance on legal issues and additional policy direction from the Council, staff recommends
addressing questions of payment for EV chargers at a later date.
Resource Impact
Resource impacts from the adoption of this ordinance will be the additional staff time in plan
checking and inspections. As with the enforcement of all building standards by the City, these
costs are recovered through Building Permit fees.
Environmental Review
This action is exempt from the California Environmental Quality Act (CEQA) under Sections
15061, 15303, and 15311 of the CEQA Guidelines.
Attachments:
Attachment A: EVSE Ordinance for multi-family and commercial (PDF)
Attachment B: Cost Analysis (PDF)
ATTACHMENT A
NOT YET ADOPTED
140423 dm 0160077 1
Ordinance No. ______
Ordinance of the Council of the City of Palo Alto Adopting Section 16.14.380 of the Palo
Alto Municipal Code to Adopt Local Amendments to the California Green Building
Standards Code and Related Findings
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Findings and Declarations.
The adoption and amendment of Section A4.106.8 of the California Green Building
Standards Code is justified on the basis of local topographical and geographical conditions.
Failure to address and significantly reduce greenhouse gas emissions could result in rises to sea
level, including in San Francisco Bay, that could put at risk Palo Alto homes and businesses,
public facilities, and Highway 101 (Bayshore Freeway), particularly the mapped Flood Hazard
areas of the City. The aforementioned conditions create hazardous conditions for which
departure from California Green Building Standards Code is required.
SECTION 2. Section 16.14.370 of the Palo Alto Municipal Code is amended to read
as follows:
16.14.370 Section A4.106.8 Electric Vehicle (EV) Charging.
Section A4.106.8 of the California Green Building Standards Code is added and
amended to read:
A4.106.8 Electric Vehicle (EV) Charging for Residential Structures. Newly
constructed single family and multifamily residential structures, including residential structures
constructed as part of a mixed use development, shall comply with the following requirements
for electric vehicle supply equipment (EVSE). All parking space calculations under this section
shall be rounded up to the next full space. New detached single‐family dwellings shall comply
with the following requirements for electric vehicle supply equipment (EVSE):
A4.106.8.1 Definitions. For the purposes of this section, the following
definitions shall apply:
(a) Level 2 EVSE. “Level 2 EVSE” shall mean an EVSE capable of charging at 30
amperes or higher at 208 or 240 VAC. An EVSE capable of simultaneously
charging at 30 amperes for each of two vehicles shall be counted as two
Level 2 EVSE.
(b) Conduit Only. “Conduit Only” shall mean, at minimum: (1) a panel capable to
accommodate a dedicated branch circuit and service capacity to install a
208/240V, 50 amperes grounded AC outlet; and (2) raceway or wiring with
capacity to accommodate a 100 ampere circuit; terminating in (3) a listed
ATTACHMENT A
NOT YET ADOPTED
2
cabinet, box, enclosure, or NEMA receptacle. The raceway shall be installed
so that minimal removal of materials is necessary to complete the final
installation.
(c) EVSE‐Ready Outlet. “EVSE‐Ready Outlet” shall mean, at minimum: (1) a panel
capable to accommodate a dedicated branch circuit and service capacity to
install a 208/240V, 50 amperes grounded AC outlet; (2) a two‐pole circuit
breaker; (3) raceway with capacity to accommodate 100‐ampere circuit; (4)
50 ampere wiring; terminating in (5) a 50 ampere NEMA receptacle in a
covered outlet box.
(d) EVSE Installed. “EVSE Installed” shall mean an installed Level 2 EVSE.
A4.106.8.2 Single Family Residences. The following standards apply to newly
constructed detached and attached single family residences.
(a) In general. The property owner shall provide Conduit Only, EVSE‐Ready
Outlet, or EVSE Installed for each residence. as minimum a panel capable to
accommodate a dedicated branch circuit and service capacity to install at
least a 208/240V, 50 amperes grounded AC outlet. The raceway shall
terminate in close proximity to the proposed location of the charging
system into a listed cabinet, box, enclosure, or NEMA receptacle. The
raceway shall be installed so that minimal removal of materials is necessary
to complete the final installation. The raceway shall have capacity to
accommodate a 100‐ampere circuit.
(b) Location.Design. The proposed location of a charging station may be
internal or external to the dwelling, and shall be in close proximity to an on‐
site parking space consistent with City guidelines, rules, and regulations. The
proposed design must comply with all applicable design guidelines, setbacks
and other code requirements.
A4.106.8.3 Multi‐Family Residential Structures. The following standards apply
to newly constructed residences in a multi‐family residential structure, except as
provided in section A4.106.8.4.
(a) Resident parking. The property owner shall provide at least one EVSE‐Ready
Outlet or EVSE Installed for each residential unit in the structure.
(b) Guest parking. The property owner shall provide Conduit Only, EVSE‐Ready
Outlet, or EVSE Installed, for at least 25% of guest parking spaces, among
which at least 5% (and no fewer than one) shall be EVSE Installed.
ATTACHMENT A
NOT YET ADOPTED
3
(c) Accessible spaces. The percentage calculations and substantive
requirements imposed by this section shall be applied separately to
accessible parking spaces. Parking at accessible spaces where an EVSE is
installed shall not be limited to electric vehicles.
(d) Minimum total circuit capacity. The property owner shall ensure sufficient
circuit capacity, as determined by the Chief Building Official, to support a
Level 2 EVSE in every location where Circuit Only, EVSE‐Ready Outlet or
EVSE Installed is required.
(e) Location. The EVSE, receptacles, and/or raceway required by this section
shall be placed in locations allowing convenient installation of and access to
EVSE. In addition, if parking is deed‐restricted to individual residential units,
the EVSE or receptacles required by subsection (a) shall be located such that
each unit has access to its own EVSE or receptacle. Location of EVSE or
receptacles shall be consistent with all City guidelines, rules, and
regulations.
A4.106.8.4 Exception – Multi‐Family Residential Structures with Individual,
Attached Parking. The property owner shall provide Conduit Only, EVSE‐Ready
Outlet, or EVSE Installed for each newly constructed residence in a multi‐family
residential structure featuring: (1) a parking space attached to the residence; and
(2) a shared electrical panel between the residence and parking space (e.g., a
multi‐family structure with tuck‐under garages).
SECTION 3. Section 16.14.380 of the Palo Alto Municipal Code is amended to read
as follows:
16.14.380 Section A5.106.5.3 Electric Vehicle (EV) Charging for Non‐Residential Structures.
Section A5.106.5.3 of the California Green Building Standards Code is added and
amended to read:
A5.106.5.3 Electric Vehicle (EV) Charging for Non‐Residential Structures. New
non‐residential structures shall comply with the following requirements for electric vehicle
supply equipment (EVSE). All parking space calculations under this section shall be rounded up
to the next full space.
A5.106.5.3.1 Definitions. For the purposes of this section, the following
definitions shall apply:
(a) Level 2 EVSE. “Level 2 EVSE” shall mean an EVSE capable of charging at 30
amperes or higher at 208 or 240 VAC. An EVSE capable of simultaneously
ATTACHMENT A
NOT YET ADOPTED
4
charging at 30 amperes for each of two vehicles shall be counted as two
Level 2 EVSE.
(b) Conduit Only. “Conduit Only” shall mean, at minimum: (1) a panel capable to
accommodate a dedicated branch circuit and service capacity to install at
least a 208/240V, 50 amperes grounded AC outlet; and (2) raceway or wiring
with capacity to accommodate a 100 ampere circuit; terminating in (3) a
listed cabinet, box, enclosure, or NEMA receptacle. The raceway shall be
installed so that minimal removal of materials is necessary to complete the
final installation.
(c) EVSE‐Ready Outlet. “EVSE‐Ready Outlet” shall mean, at minimum: (1) a panel
capable to accommodate a dedicated branch circuit and service capacity to
install at least a 208/240V, 50 amperes grounded AC outlet; (2) a two‐pole
circuit breaker; (3) raceway with capacity to accommodate a 100‐ampere
circuit; (4) 50 ampere wiring; terminating in (5) a 50 ampere NEMA
receptacle in a covered outlet box.
(d) EVSE Installed. “EVSE Installed” shall mean an installed Level 2 EVSE.
A5.106.5.3.2 Non‐Residential Structures Other than Hotels. The following
standards apply newly constructed non‐residential structures other than hotels.
(a) In general. The property owner shall provide Conduit Only, EVSE‐Ready
Outlet, or EVSE Installed for at least 25% of parking spaces, among which at
least 5% (and no fewer than one) shall be EVSE Installed.
(b) Accessible spaces. The percentage calculations and substantive
requirements imposed by this section shall be applied separately to
accessible parking spaces. Parking at accessible spaces where an EVSE is
installed shall not be limited to electric vehicles.
(c) Minimum total circuit capacity. The property owner shall ensure sufficient
circuit capacity, as determined by the Chief Building Official, to support a
Level 2 EVSE in every location where Circuit Only, EVSE‐Ready Outlet or
EVSE Installed is required.
(d) Location. The EVSE, receptacles, and/or raceway required by this section
shall be placed in locations allowing convenient installation of and access to
EVSE. Location of EVSE or receptacles shall be consistent with all City
guidelines, rules, and regulations.
A5.106.5.3.3 Hotels. The following standards apply newly constructed hotels.
ATTACHMENT A
NOT YET ADOPTED
5
(a) In general. The property owner shall provide Conduit Only, EVSE‐Ready
Outlet, or EVSE Installed for at least 30% of parking spaces, among which at
least 10% (and no fewer than one) shall be EVSE Installed.
(b) Accessible spaces. The percentage calculations and substantive
requirements imposed by this section shall be applied separately to
accessible parking spaces. Parking at accessible spaces where an EVSE is
installed shall not be limited to electric vehicles.
(c) Minimum total circuit capacity. The property owner shall ensure sufficient
circuit capacity, as determined by the Chief Building Official, to support a
Level 2 EVSE in every location where Circuit Only, EVSE‐Ready Outlet or
EVSE Installed is required.
(d) Location. The EVSE, receptacles, and/or raceway required by this section
shall be placed in locations allowing convenient installation of and access to
EVSE. Location of EVSE or receptacles shall be consistent with all City
guidelines, rules, and regulations.
SECTION 4. If any section, subsection, clause or phrase of this Ordinance is for any
reason held to be invalid, such decision shall not affect the validity of the remaining portion or
sections of the Ordinance. The Council hereby declares that it should have adopted the
Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the
fact that any one or more sections, subsections, sentences, clauses or phrases be declared
invalid.
SECTION 5. The Council finds that this project is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA
Guidelines, because it can be seen with certainty that there is no possibility that the ordinance
will have a significant effect on the environment.
//
//
//
//
//
//
ATTACHMENT A
NOT YET ADOPTED
6
SECTION 6. This ordinance shall be effective on the thirty‐first day after the date of
its adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
City Attorney City Manager
____________________________
Director of Development Services
____________________________
Director of Administrative Services
1
Attachment
B:
EVSE
Cost
Analysis
The
EVSE
Task
Force
has
developed
a
cost
analysis
and
assumptions
for
the
application
of
the
proposed
ordinance.
The
cost
assumptions
include
basic
materials
and
installation
cost
as
provided
by
industry
experts
and
advocates
in
the
EVSE
Task
Force.
The
estimated
costs
for
typical
construction
activities
related
to
EVSE
installation
are
listed
in
Figure
1-‐1.
The
costs
listed
address
the
following
items;
conduit
material
(also
called
“raceway”),
wiring
material,
electric
panel
circuits,
protective
circuit
materials,
and
charger
technology.
The
cost
estimates
also
include
the
labor
associated
with
installation.
Figure
1-‐1:
EVSE
Cost
Analysis
A.
Estimated
costs B.
Economies-‐of-‐scale
for
co-‐located
parking
(Percent
Reduction
By
#
of
Installations)
Item Ave.Low High 2 5 20
Basic
Materials
100'
of
raceway
for
one
parking
spot
-‐
materials $214 $170 $235 0%10%20%
Installation
of
100'
of
raceway
only $646 $515 $710 0%0%0%
100'
of
240V/
50A
wiring
for
one
parking
spot
-‐
materials
only $186 $170 $205 0%10%20%
Installation
of
100'
of
wiring
only $450 $360 $495 0%0%0%
Installation
of
100'
of
raceway
&
wiring-‐
(material
and
install)$1,557 $1,401 $1,713 0%10%15%
Panel
capacity
supporting
one
240V/50A
circuit
(per
circuit)$400 $390 $440 0%10%20%
Protective
requirements
per
240V/50A
circuit
(disconnect)$450 $360 $500 0%10%20%
EVSE
Equipment
Basic
single-‐head
Level
2
charger
(Non-‐network
EVSE
single
head)$1,000 $800 $1,500
Fully
featured
single-‐head
Level
2
charger
(Networked
EVSE
single
head)$6,000 $5,000 $8,000
Basic
dual-‐head
Level
2
charger
(Non-‐network
EVSE
Double
Head)$2,000 $1,500 $3,000
Fully
featured
dual-‐head
Level
2
charger
(Networked
EVSE
Double
Head)$7,500 $5,500 $8,000
2
The
cost
estimation
from
Figure
1-‐1
has
been
applied
to
a
typical
commercial
construction
scenario
and
is
illustrated
in
Figure
1-‐2.
The
numbers
highlighted
with
a
bold
box
have
been
used
to
populate
the
cost
scenario.
The
example
new
commercial
office
building
is
shown
in
Figure
1-‐2.
This
scenario
assumes
a
30,000
square-‐foot
construction
scope.
For
this
scope,
the
electric
vehicle
requirement
includes
5
fully
functional
EVSE
spaces
and
20
conduit-‐only
spaces.
The
estimate
also
includes
the
city
permit
fees
for
installation.
The
overall
new
construction
cost
for
Figure
1-‐2
is
estimated
at
$250
per
square
foot
totaling
$7,500,000.
This
estimate
was
obtained
from
Reed
Construction
Data,
an
industry
standard
source
for
cost
estimating.
The
estimated
EV
cost
for
the
commercial
scenario
is
$57,817.
The
estimated
EV
cost
would
increase
the
overall
cost
to
the
project
by
0.8%.
Figure
1-‐2
New
Commercial
Construction
EVSE
Cost
Analysis
Scenario
3
The
cost
estimation
from
Figure
1-‐1
has
been
applied
to
typical
multi-‐family
construction
project
and
is
illustrated
in
Figure
1-‐3.
This
scenario
assumes
a
30-‐unit,
30,000
square-‐foot,
new
construction
project
with
55
resident
parking
spaces
and
10
guest
parking
spaces.
The
estimate
also
includes
the
city
permit
fees
for
installation.
The
overall
new
construction
cost
for
Figure
1-‐3
is
estimated
at
$300
per
square
foot
totaling
$9,000,000.
This
estimate
was
obtained
from
Reed
Construction
Data,
an
industry
standard
source
for
cost
estimating.
The
estimated
EV
cost
for
the
new
multi-‐family
scenario
is
$81,008.
The
estimated
EV
cost
would
increase
the
overall
cost
to
the
project
by
0.9%.
Figure
1-‐3
New
Multi-‐Family
Residential
-‐
EVSE
Cost
Analysis
Scenario
The
EV
Task
force
has
also
discussed
the
revenue
generation
associated
with
the
installation
of
EVSE.
In
the
case
of
EVSE
with
simple
technology,
the
charging
station
only
allows
for
no-‐cost
charging
by
the
EVSE
owner.
In
the
case
of
more
advanced
EVSE
technology,
the
equipment
owner
may
elect
to
require
a
fee
for
use
of
the
charging
station.
In
either
condition,
the
potential
revenue
created
from
EVSE
owners
should
be
considered
when
analyzing
the
cost
analysis
and
payback
period
of
EVSE.