Agenda Item # 11.4 - Dan Donovan | Received 08/02/2022From:
To: City C er ; A Council Members
Subject: EXTERNAL - August 1st Public Comment
Date: Monday, August 1, 2022 9:22:19 PM
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My comments on item 11.4 regarding REACH codes.
- I generally agree with retention of Option 1 to continue mixed use (NG + electric) utilities.
That said, requiring electric heat pumps versus electric AC compressors is a better long term
option for building owners. Installing the support infrastructure for heat pumps during original
construction is much less expensive and disruptive than doing it as a retrofit.
- On the topic of EVCSs: I am the owner of a late first generation serial hybrid EV (BMW i3
w/range extender). Electric range is somewhat limited (-80 miles when new), but sufficient
for commuting to San Jose and charging at work.
I found that Level 1 or 120 volt AC, 20 AMP charging was barely acceptable with my vehicle
because the recharge time exceed 8 hours. As a result, I had a 240 volt AC, 40 AMP circuit
installed to support an L2 charger. With this solution, I cut my recharge time to about 3 1/2
hours, allowing scheduled recharging after 11:00 PM (lowest electricity cost).
With wider availability of pure BEVs that have much higher capacity battery capacities (Ford
Mach-E, F150 Lightning, Rivian RT1/RS1, Tesla's, etc.) and range, L1 charging is no longer
remotely practical as it would take 24-48 hours to fully charge a vehicle. L2 charging is a
requirement. The charging station that Ford has introduced requires a 100 AMP, 240 volt
circuit to achieve a sub-8 hour recharge time.
While this comment is long, it explains why I believe 120 volt or L1 charging is largely
useless for anything other than an electrically assisted bicycle. If the City is going to adopt a
REACH code for EVCSs, it should be to require a dedicated 100 AMP, 240 volt circuit to
support high capacity L2 charging at each vehicle stall. If it's a long cable run, there should be
a sub -panel at the stall. Due to the high voltage and amperage, all cabling should be installed
in rigid, metal conduit.
Dan Donovan