Washington Transportation Electrification Strategy — Full Report, February 2024 (Interagency Electric Vehicle Coordinating Council)

Issuer: Congressional materials
Document type: Report

Summary

The full report of the Washington Transportation Electrification Strategy, dated February 2024 and developed by Washington's Interagency Electric Vehicle Coordinating Council (EV Council), which adopted it at a public meeting on Nov. 30, 2023. A letter from the council's co-chairs at the Departments of Commerce and Transportation states that the strategy meets requirements in RCW 43.392.040 and provides a scoping plan under RCW 43.392.020 for the 2030 target that new passenger and light-duty vehicles be electric. The table of contents covers a summary and action plan, strategies on transportation inequities, the state's current transportation system, modeling scenarios, and priority policies on charging infrastructure, vehicles, micromobility and workforce development. The report closes with a policy table on equity outcomes and its source notes.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Washington Transportation Electrification Strategy — Full Report, February 2024 (Interagency Electric Vehicle Coordinating Council).” Original at app.leg.wa.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2024-final-rmi-us-wa-transportation-electrification-strategy-full-report-01/, SHA-256 ef652ce2f04517b3c85130dfa8cdf855aeadf0f46406b25c4f82e64ad849262f.

Full text

Washington Transportation
Electrification Strategy
Developed by the Interagency Electric Vehicle Coordinating Council

FULL REPORT | FEBRUARY 2024
Letter of Introduction
Dear Families and communities of Washington state:

Washington’s Interagency Electric Vehicle Coordinating Council (EV Council) is pleased to deliver to you the
Transportation Electrification Strategy (TES) for Washington adopted at a public meeting on Nov. 30, 2023.

The TES, its appendices and the attachments to this letter meet the requirements in RCW 43.392.040 to:

• Develop a statewide transportation electrification strategy to ensure market and infrastructure
readiness for all new vehicle sales.

• Develop a robust public and private outreach plan that includes engaging with community
organizers and the environmental justice council to develop community-driven programs to address
zero-emissions transportation needs and priorities in overburdened communities (see attached
Engagement Plan and Education Plan).

• Provide an annual report to the appropriate committees of the Legislature summarizing electric vehicle
implementation progress, gaps and resource needs (see attached Annual Report).

Further, per RCW 43.392.020, the TES adopted by the EV Council provides a scoping plan for achieving the
2030 target that all publicly owned and privately owned passenger and light-duty vehicles of model year
2030 or later that are sold, purchased or registered in Washington be electric vehicles.

Developing the statewide TES and implementing recommendations to equitably accelerate the transition
to electric vehicles required early and meaningful input from a wide variety of stakeholders, especially
in overburdened communities. The EV Council, co-chaired by the Departments of Commerce and
Transportation, sought input over the past year from the Washington Environmental Justice Council and
many other organizations listed in the TES. The EV Council also consulted with its 25-member Advisory
Committee — required in RCW 43.392.040(1)(e) — throughout the TES development process.

The EV Council developed the TES from the initial work in the 2021 State Energy Strategy, working
closely with the many agencies involved in aspects of electrification of transportation, and used the Joint
Transportation Committee’s June 2023 Report “Encouraging High-Consumption Fuel Users to Use
Electric Vehicles” to inform options considered in the TES. The EV Council ensured that the TES aligns with
and references several other related reports developed by WSDOT and Commerce, including:

• Washington State Transportation Carbon Reduction Strategy (2023).
• Green Electrolytic Hydrogen and Renewable Fuels: Recommendations for Deployment in Washington
(2024).

• Vehicle Miles Traveled (VMT) Targets – Final Report (2023).
The TES recommends adaptive management, encouraging the incorporation of new information during
implementation. Specific reports still in development on Nov. 30, 2023, that will be incorporated include the

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 2
Joint Transportation Committee’s expected report on medium- and heavy-duty vehicle incentive strategies
and the EV battery management report that the Department of Ecology will prepare by June of 2024.

The EV Council greatly appreciates the opportunity to assess and advance Washington’s progress
on transportation electrification. The TES provides a clear path forward, aligned with our climate
and environmental justice laws, to make our electric vehicle transition as fast and as equitable as
possible. We look forward to working with policymakers across state government to implement this
comprehensive strategy.

Respectfully,

Deborah Reynolds
Co-Chair, EV Council
Managing Director of Clean Transportation Alternative Fuels Program Manager
Washington State Department of Commerce Washington State Department of Transportation
Tonia Buell
Co-Chair, EV Council

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 3
Acknowledgments
EV Council agency representatives thank Governor Jay Inslee and the Washington State Legislature for their
vision and leadership.

The development of the Transportation Electrification Strategy would not have been possible without the
contributions of countless individuals within the executive branch.

EV Council Agencies and Governor’s Office

Department of Commerce Utilities and Transportation Commission
Deborah Reynolds**, Glenn Blackmon, Aaron Cahen*, Andrew Sellards
Steven Hershkowitz, Larry Mattson, Steven
Polunsky, Andrew Rector, Emma Wyma Department of Agriculture
Tahis McQueen*, Kelly McClain, Julia Terlinchamp
Department of Transportation
Tonia Buell**, Kevin Bartoy, Alon Bassok, Department of Ecology
Barb Chamberlain, Emily Geralds, Joshua Grandbouche*, Abbey Brown, Courtney
Celeste Gilman, Steve Holloway, Doris Cecale, Joel Creswell, Debebe Dererie, Sean
Karolczyk, Charlene Kay, Karin Landsberg, Lundblad, Caroline Mellor, Mehjabeen Rahman,
Justin Nawrocki, Jonathan Olds, Kara Adam Saul, Jill Schulte, Rebecca Sears, Molly
Symonds Spiller, Ron Stuart, Dustin Watson

State Efficiency and Environmental Department of Enterprise Services
Performance Office Courtney Speer*, Rick Bushnell, Ann Larson,
Hanna Waterstrat*, Angie Fitchner, Jonathan Lucas
Seth Kolodziejski
Department of Health
Office of Financial Management Kaitlyn Kelly*, Jeffrey Bryant, Julie Fox
Erik Hansen*, Tiff West
Governor’s Office
Office of Superintendent for Public Debbie Driver, Anna Lising
Instruction
Patti Enbody*, Chris Jose

*Primary EV Council members **EV Council Co-chairs

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 4
Acknowledgments
Additional thanks to the members of the 2023 EV Council Advisory Committee, who contributed their time
and expertise to informing and improving the Transportation Electrification Strategy; to the hundreds of
stakeholders who participated in meetings and task forces and who commented on the report; and to the
consulting team for their support of this process.

2023 EV Council Advisory Committee

Paula Sardinas* Steve Douglas Bryan Imai Julia Peacock Angela Song
Ryan Bradt* Mike Ennis Jay Kimball Matthew Pleasants Huoi Trieu
Kimberly Alejandro Maya Gillett Jason Lien Laura Ray Tracey Whitten
Susan Baird-Joshi Nicola Graham Leah Missik Amy Shatzkin Kyla Wilson
Dan Bowerson Darrell Herling Heather Mulligan Jeremy Smithson Monica Zazueta
Tanya Dion Sara Hetrick

*2023 Advisory Committee Co-Chairs

Consulting team

• RMI: Hannah Thonet, Ben Shapiro, Molly Freed, Hannah Lindsell, Anna Zetkulic, Jacob Corvidae,
Aradhana Gahlaut, Matt Miccioli, Dave Mullaney, Nick Pesta, Nocona Sanders, Drew Veysey, Gerard
Westhoff, Matt Wilde

• Cascadia Consulting Group, Inc.: Gretchen Muller, Laura Baetscher, Jasmine Beverly, Alexandra
Brown-Law

• NW Energy Coalition: Annabel Drayton, Lauren McCloy, Charlee Thompson
• Front and Centered: Aaron Fishbone, Deric Gruen, Paulo Nunes-Ueno, Rich Stolz
• Strategic Research Associates: Data Collection Team at Strategic Research Associates of Spokane

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 5
Table of Contents
Letter of Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

How to Read the Transportation Electrification Strategy . . . . . . . . . . . . 8

SUMMARY AND ACTION PLAN

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Key Takeaways . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Call to Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

MAIN REPORT

1. Introduction: Historical Context and Objectives . . . . . . . . . . . . . . . . 38

2. Strategy to Address Transportation Inequities . . . . . . . . . . . . . . . . . 42

3. Where Washington Is Today . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
Washington’s Current Transportation System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
Washington Residents’ Perceptions about Transportation Electrification . . . . . . . . . . . . . 55

4. Where Washington Needs to Go . . . . . . . . . . . . . . . . . . . . . . . . . . 57
Policy Context and Key Analytical Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
Policy Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
Key Analytical Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Recommendation: Focus Efforts on Achieving the S3 Strong Electrification Policy Scenario . . 61
2030 EV Target Scoping Plan – Scenario 3b . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Analysis Conducted to Support the TES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
Modeling Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
The Future Is Uncertain — Different Scenarios Explore Potential Outcomes . . . . . . . . . . . . 66
Scenario Output Comparison . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 6
5. How Washington Can Get There . . . . . . . . . . . . . . . . . . . . . . . . . . 89
Anticipated Barriers to Scaling EV Adoption . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
Technological Barriers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
Financial Barriers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
Institutional Barriers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94

Priority Policies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

Part I — Achieving the Strong Electrification Scenario . . . . . . . . . . . . . . . . . . . . . . 98
1. Consumer Education and Capacity Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98
2. Charging and Utility Infrastructure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101
3. Light-Duty Passenger Vehicles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 114
4. Medium- and Heavy-Duty Vehicles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119
5. Electrifying Micromobility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 122
6. Workforce Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 124

Part II — Closing the 2030 Transportation Greenhouse Gas Emissions Gap . . . . . . . . . .127
A. Reducing Vehicle Miles Traveled . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127
B. Reducing Vehicle Weight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129
C. Strategies to Reduce Gasoline and Diesel in Existing Vehicles . . . . . . . . . . . . . . . . . 130
D. Aviation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133
E. Marine and Ports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 134
F. Rail . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 136
G. Focus Planning and Implementation Efforts on Meeting the 2030 Emissions Limit . . . . 137

6. Implementation Roadmap . . . . . . . . . . . . . . . . . . . . . . . . . . . . 138

7. Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 149

Appendices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 150
Appendix A — Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .151

Appendix B — TES Engagement: Phase 1 and 2 Participants and Findings . . . . . . . . . . 158
Findings from Phase 1 Focus Groups and Interviews . . . . . . . . . . . . . . . . . . . . . . . . . 162
Findings from Phase 2 Focus Groups and Interviews . . . . . . . . . . . . . . . . . . . . . . . . . 170

Appendix C — Summary of Public Comment Feedback and Major Changes . . . . . . . . . .177

Appendix D — Technical Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .181
Transportation Electrification Strategy Modeling Overview . . . . . . . . . . . . . . . . . . . . . 181
Stock Rollover Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 181
Electric Vehicle Supply Equipment Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 191
Key Inputs and Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 196
Scenarios and Sensitivities Modeled . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199
Additional Scenario Analysis Comparisons and Commentary . . . . . . . . . . . . . . . . . . . 204

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 7
How to Read the
Transportation
Electrification Strategy
• Glossary: This report relies on a number of acronyms and technical terms to communicate nuance in
analytical findings and policy recommendations. Please refer to the glossary in Appendix A on pages
151–157 for support.

• With 10 minutes or less to read the Transportation Electrification Strategy: Review the key
takeaways on pages 11–13.

• With 30 minutes or less to read the Transportation Electrification Strategy: Review the TES
summary and action plan on pages 9–37.

• Legislative and agency actions: The Transportation Electrification Strategy implementation plan
on pages 138–148 provides a sequenced roadmap for maximizing electric vehicle adoption in an
equitable way. This is a shorter read for policymakers and the public who have limited time to review
recommended priority actions.

• Policy recommendations: A full list of policy recommendations can be found on pages 96-137 for
those who have more time — or who are looking for more context on implementation plan actions — to
review recommended strategies.

• Equity in transportation electrification: People interested in information about how the state
intends to address transportation inequities should read Chapter 2. The implementation plan on pages
138–148 also marks policy recommendations specifically focused on ensuring an equitable transition.

• Modeling and data analysis: Those wanting an overview of modeling results should read pages
66–88. This will provide helpful context for both policy recommendations and the implementation plan,
especially for readers interested in actions essential for emissions reduction. A more in-depth explanation
of the modeling inputs and outputs can be found in the technical appendix on pages 181–212.

• Development process: Readers interested in context on how the Transportation Electrification
Strategy was developed should read pages 38–41.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 8
Overview

A Chevrolet Bolt electric vehicle charges outside the Washington Department of Ecology’s Eastern Region Office.

Washington has adopted impressive and scientifically necessary requirements for reducing greenhouse
gases (GHGs) over the coming years, including limiting emissions to 45% below 1990 levels by 2030 and
achieving net-zero emissions by 2050.1 Representing 39% of Washington’s economy-wide emissions, the
transportation sector must play a critical role in the state’s decarbonization efforts.2 Electrifying on-
road transportation, which represents 24% of the state’s emissions, and for which electric vehicle (EV)
technology is most advanced, is a critical opportunity for the state to reduce GHG emissions.3

As a national leader on climate action, Washington is already taking actionable steps toward achieving
these goals. For example, the Washington State Legislature (Legislature) adopted, and the Department
of Ecology is implementing, California’s motor vehicle emissions standards rather than the federal
government’s standards.

• For new light-duty (i.e., passenger) vehicles (LDVs), the Advanced Clean Cars I and II (ACC I and ACC
II) regulations, which require a progressively stringent zero-emissions vehicle (ZEV) sales share,
culminate in a 100% sales requirement by 2035.

• For medium- and heavy-duty vehicles (MHDVs), the Advanced Clean Trucks (ACT) regulation requires
increasing new sales shares for larger vehicles, with 40%–75% ZEV sales required by 2035 depending
on weight class. These regulations are the driving force behind the recent acceleration in EV adoption
across the country and in Washington.

1 State of Washington Department of Ecology, “The Climate Commitment Act: Washington’s Path to Carbon Neutrality by
2050,” (n.d.).
2 State of Washington Department of Ecology, “Washington’s greenhouse gas inventory,” (n.d.).
3 State of Washington Department of Ecology, “Washington’s greenhouse gas inventory,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 9
The Legislature passed Move Ahead Washington (Chapter 182, Laws of 2022)4 in March 2022. This
monumental 16-year transportation package is known for its historic investments in transit, active
transportation, ferries, alternative fuels and rail, all intended to support mode shift, electrification of
these modes and reductions in vehicle miles traveled (VMT) along with their associated emissions. It also
established the Interagency Electric Vehicle Coordinating Council (EV Council) and a nonbinding statewide
target of reaching 100% new electric passenger vehicle sales by 2030 (2030 EV target) — five years earlier
than the 100% new ZEV sales requirement under ACC II.

The EV Council was tasked with aligning existing transportation electrification efforts across 10 state
agencies and offices and developing an equitable and inclusive statewide Transportation Electrification
Strategy (TES) pegged to the nonbinding 2030 EV target and aligned with the state’s 2030 emissions limit.
An annual report summarizing the transportation electrification–related activities and accomplishments
of the 10 agencies that make up the EV Council from July 1, 2022, through June 30, 2023, is available on the
TES website.

The TES addresses three critical questions:

• First, how can Washington meet the 2030 EV target established in Move Ahead Washington?
• Second, how can Washington ensure market and infrastructure readiness for all new LDV sales being
electric?

• And third, how can Washington decarbonize the majority of the transportation system, covering all
on-road vehicles (cars, trucks and buses) and non-road vehicles (planes, boats, trains and off-road
mobile equipment), while directly and equitably benefiting vulnerable populations and overburdened
communities?

4 Chapter 182, Laws of 2022.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 10
Key Takeaways

Washington Department of Commerce staff and community members open an EV charging station in White Pass in 2023.

Emissions Reductions

The 2021 State Energy Strategy (SES) is aligned with the state’s emissions limits and shows
transportation producing only 20 million metric tons (MMT) carbon dioxide equivalent (CO2e) in 2030.
Although Washington’s on-road vehicles accounted for roughly 58% of state transportation sector GHG
emissions in 2019, they are likely to contribute a smaller percentage of GHG emissions over time within
the transportation sector — roughly half by 2030 — because EV technology is more advanced in on-road
transportation modes than in non-road modes. Therefore, to meet the state’s 2030 limit, GHG emissions
from on-road vehicles likely need to decrease to fewer than 10 MMT CO2e annually. The TES is the state’s
implementation roadmap for how to get there in 2030 by maximizing transportation electrification in a way
that supports other clean transportation strategies, setting Washington up for the most equitable and cost-
effective zero-emissions future possible.

1. Washington’s recent transportation electrification policies will cut the state’s on-road emissions by
more than 70% in 11 years, from 23.5 MMT in 2019 to 14.1 MMT in 2030, if successfully implemented.
State policymakers in both the executive and legislative branches should now focus efforts on supporting
implementation of existing policies (e.g., ACC II, ACT) by (1) lowering up-front EV costs, (2) making charging
easy and accessible and (3) increasing consumer and fleet manager education and awareness.

2. The Advanced Clean Fleets (ACF) regulation, which has not been adopted in Washington, is the most
powerful tool available for accelerating medium- and heavy-duty (MHD) truck electrification, and
achieving its required adoption rates would further reduce on-road 2030 emissions to 13.9 MMT. Analysis
shows ACF adoption rates would increase the number of zero-emissions MHD trucks on Washington’s roads
in 2035 by approximately 14,000 vehicles (36%), creating significant demand for the vehicle supply produced
under ACT and covering approximately 40% of total MHD trucks in Washington today.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 11
3. Reaching the 2030 EV target would further reduce 2030 on-road emissions to 13.6 MMT, but will be
incredibly challenging and should not be counted on to get under the 2030 emissions limit. The state’s
recent adoption of ACC II is a critical component of transitioning to an EV future. Without ACC II, sales of
new electric passenger vehicles in Washington might account for only 59% of total new passenger vehicle
sales annually by 2030, compared with the 68% the state now expects to see with ACC II. Both broad-based
and additional targeted incentives are already necessary to achieve ACC II. Therefore, to further reach 100%
new electric LDV sales, the state would need to bring down EV costs substantially for all residents, likely at
the expense of more effective short-term emissions reduction strategies.

4. In addition to being essential — though insufficient — for short-term emissions reduction,
electrification remains the most effective long-term strategy for transportation decarbonization. The
climate benefits of electrification will accelerate in significance through 2050 as more gasoline and diesel
vehicles are retired and replaced by EVs powered by non-emitting electricity (due to the Clean Energy
Transformation Act [CETA]).

5. The state must also urgently pursue non-electrification policies to close the remaining gap in
expected 2030 on-road emissions. Such actions include (1) a strategic VMT-reduction policy (especially
more compact land use), (2) energy efficiency standards, (3) stronger clean fuels development and
deployment and (4) early retirement of the dirtiest MHDVs. Significant progress on each of these strategies
will likely be necessary to get under 10 MMT in on-road emissions by 2030.

Equity and Environmental Justice

Pursuant to the Move Ahead Washington legislation, the TES must ensure that “activities associated with
advancing transportation electrification benefit vulnerable populations and overburdened communities.”5
Public engagement work and consumer research during TES development confirmed that without state
action, significant inequities in the existing transportation system could continue, and in some cases
worsen, during electrification of the transportation system.

1. Survey research conducted as part of the TES shows clear adoption disparities by income and home
ownership for passenger EVs. The state must continue to measure adoption by socioeconomic factors
to ensure equitable access and awareness. The EV Council proposes the development of a Transportation
Equity Baseline across a variety of metrics, including equitable investments consistent with the Healthy
Environment for All Act of 2021 (HEAL Act). Refer to the Washington Transportation Electrification
Strategy EV Education Plan (Education Plan) for more information on the survey findings and Chapter 2
of the TES for details on equity definitions and metrics.

2. Targeted incentives are more effective than broad-based incentives, because they provide EV
adoption opportunities to vulnerable populations and consumers, organizations and businesses
operating in overburdened communities. Although broad-based LDV incentives will be important in
2024–27 for growing new EV sales before ACC II requirements ramp up, EV supply in Washington will soon
be constrained by limitations on “pooling” compliance credits among states. In other words, automakers
will need to prioritize sales in other ACC II states that trail Washington’s progress. This means incentives
starting in the late 2020s will have more of an effect on who has access to new EVs than on growing the
number of new EVs sold and increasing overall adoption.

5 Chapter 182, Laws of 2022.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 12
Since new battery electric trucks are increasingly economical on a total cost of ownership (TCO) basis due
to current generous federal incentives, vehicle availability and charging are the more significant adoption
obstacles. To address these obstacles, incentives should be directed toward agencies, organizations and
businesses operating MHDVs in overburdened communities or toward those without the financial capital to
take on higher up-front cost to access the post-sale fuel savings.

3. The new car market was inaccessible for the vast majority of drivers before EV adoption started to
accelerate. The state cannot change that reality through consumer subsidies alone, and must pursue
additional policies and programs to reduce prices through greater availability in the used vehicle
market. Between January 2022 and June 2023, about 80% of light- and medium-duty vehicle sales were for
used cars and trucks. That dynamic is flipped for battery electric vehicles (BEVs) due to the small number
of used EVs available. Without structural reforms to regulations outside Washington’s authority (e.g., ACC
II and federal motor vehicle emissions standards), new cars will remain out of reach for most, regardless
of fuel type. The state must prioritize strategies to grow the number of used BEVs on the market, in turn
driving down prices, or the transition to EVs will remain inequitable.

4. Maximizing access to charging for residents of multifamily and low-income single-family homes —
especially renters — will be essential to eliminating disparities already developing in the EV transition.
Charging at home is by far the most
affordable and convenient way to power
an EV, but is predominantly available
only to single-family homeowners. The
state must grow its charging investments
and carefully target programs toward
maximizing residential charging for those
who face financial or legal barriers. This
will also reduce overall system costs,
which are disproportionally borne by
lower-income taxpayers and ratepayers,
because residential charging installation
is much more affordable than public
chargers.

5. Strong transportation electrification
actions, if successfully implemented,
will cut current-day air pollution
caused by on-road vehicles by more
than half in 2035, leading to health
benefits in overburdened communities.
The decline in air pollution from MHDVs,
which disproportionally operate in
overburdened communities near
airports, marine ports and highways, is
especially important. The state should
An air quality monitoring station
increase its air quality monitoring
along transportation corridors and hubs,
especially in neighborhoods most at risk of cumulative adverse effects, and direct additional electrification
resources to areas near ports and highways until air quality and health benefits are equitable.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 13
In light of these findings, the EV Council developed 86 policy recommendations to enable the regulatory
and market environment needed for the strongest possible EV adoption through 2035. A companion
implementation roadmap lays out those suggested policies by priority year of action, as well as delineating
between those for legislative consideration and those for administrative action. The TES also highlights
additional strategies beyond the transportation electrification recommendations to achieve the 2030
emissions limit. The state must continue its clean transportation leadership and act urgently on all fronts to
build a cleaner, safer and more affordable transportation system for all Washington residents and businesses.

TES Implementation — 2024 Priorities

Washington has made tremendous strides in recent years to advance its climate leadership position. It
passed a landmark 100% clean electricity law, the nation’s first clean buildings standard and the nation’s
second cap-and-invest program. It also joined California, Oregon and British Columbia in the West Coast
clean fuel standard market and adopted California’s motor vehicle emissions standards. All of these
policies were built on a foundation of environmental justice through the HEAL Act and with strong labor
standards. And yet, as the TES modeling has made clear, Washington must do even more.
Given the high stakes and short time frame for closing the gap between current policy and the strongest
feasible electrification pathway, Washington must be highly focused on and organized in establishing
priorities. With this in mind, the following 2024 prioritization plan lays out a clear roadmap for 2024
legislative session recommendations and how agencies can work toward policy and program development
for the longer 2025 legislative session. Each policy includes a clearly identified agency lead and notes
expected transportation equity benefits and expected improvement in air quality in overburdened
communities.

The 2024 priorities are presented in Tables 1 and 2.

Table 1 lists new actions and emissions reductions, broken out by electrification and non-electrification
strategies, needed to close the 2030 on-road emissions gap left by current electrification and travel
efficiency policies. The table also shows estimated incremental GHG emissions reduction by strategy and
expected equity outcomes.

Achieving the additional 2030 emissions reductions in Table 1 is dependent on existing policies achieving
their full expected effect. The state should not take this for granted without further action. The EV Council
is prioritizing the recommendations in Table 1 for 2024 because urgent progress is essential to keep
Washington on pace to achieve existing policies.

Table 2 lists new and continued actions needed to successfully and equitably implement existing
transportation electrification policies, namely ACC I, ACC II and ACT.

It is challenging to isolate the effect on emissions of individual enabling actions that support existing
regulatory policies. Each of the priorities in Table 2 will be essential to achieving the modeled 9.4 MMT CO2e
reduction in 2030 on-road emissions from 2019 levels.

Readers can review Appendix D for an explanation of the emissions and equity determinations in Table 1
and Table 2.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 14
Table 1 2024 Priorities: New Actions and Emissions Reductions Needed
to Close 2030 Emissions Gap
Legislative Agency
Recommendations* actions actions Lead Agency GHG** Equity***

Transportation Electrification

Requirements and Fund staffing Work with Ecology and 230,000 Significant air
incentives for zero- needed to stakeholders to WSDOT quality
emissions MHDVs: pursue ACF consider improvement
adoptions rulemaking and
4.1 Pursue ACF rates through other policy Lower costs
adoption rates. stakeholder development
engagement needed to Increased EV
4.4 Fund and and possible achieve ACF access
implement an MHDV rulemaking. adoption rates.
incentive and
infrastructure Release Implement
program. appropriated MHDV
funding to the incentives and
Washington programs.
State
Department of
Transportation
(WSDOT) to
implement
Joint
Transportation
Committee–
recommended
program design.

Grow broad consumer Fund public Implement Commerce 20,000 Air quality
demand for passenger information public improvement
BEVs: campaign to information
increase campaign. Lower costs
3.8 Increase consumer awareness of
awareness of incentives and Increased EV
incentives. charging access
options.
3.7 Extend and expand
the state sales and use Pass legislation
tax exemptions for to extend and
BEVs. expand sales
tax exemption
for all BEVs.

4.5 Accelerate and Pass legislation Develop Ecology (with 10,000 Air quality
fund school bus and budget practical support from improvement
electrification to meet provisions implementation the office of
needed adoption developed timelines and Superintendent Lower costs
rates. with needed funding. of Public
stakeholders. Instruction Increased EV
[OSPI]) access

* Numbered items in the recommendations column correspond to the policy items detailed in Chapter 5, How Washington Can Get There,
in Part I and Part II.
** The GHG column reflects estimated incremental GHG emissions reduction in 2030 (metric tons CO2e).
*** The equity column reflects equity benefits, including air quality improvements in overburdened communities, and lower costs,
increased EV access and more non-driving options for vulnerable populations.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 15
Table 1 2024 Priorities: New Actions and Emissions Reductions Needed
to Close 2030 Emissions Gap, continued
Legislative Agency
Recommendations* actions actions Lead Agency GHG** Equity***

Clean Fuels, Vehicle Efficiency and Voluntary Early Retirement

Reduce carbon None Assess needed Ecology Expected Air quality
intensity of gasoline anticipated for program to be improvement
and diesel with clean 2024 changes to substantial,
drop-in fuels: increase but more
emissions analysis is
C.1.1 Add flexibility to reductions and needed.
the Clean Fuel consider
Standard’s carbon agency-
intensity schedule. requested
legislation for
C.1.2 Increase 2025.
stringency of Clean
Fuel Standard
program.

Diesel vehicle None Develop diesel Ecology ≈300,000– Significant air
efficiency standards anticipated for vehicle 700,000**** quality
2024 enforcement improvement
C.3 Enforce diesel and anti-idling
vehicle compliance. policy and Lower costs
consider
C.4 Explore an anti- introducing
idling law for ICE agency-
MHDVs. requested
legislation.

C.2 Improve vehicle Pass legislation Begin Commerce ≈600,000– Air quality
efficiency with to provide rulemaking. 700,000**** improvement
lower-resistance Commerce
replacement tires. rulemaking Lower costs
authority.

C.5 Focus on high- None Pursue state Ecology ≈110,000– Significant air
consumption gasoline anticipated for and federal 130,000**** quality
and diesel users. 2024 funding improvement
opportunities.

* Numbered items in the recommendations column correspond to the policy items detailed in Chapter 5, How Washington Can Get There, in
Part I and Part II.
** The GHG column reflects estimated incremental GHG emissions reduction in 2030 (metric tons CO2e).
*** The equity column reflects equity benefits, including air quality improvements in overburdened communities, and lower costs, increased EV
access and more non-driving options for vulnerable populations.
**** The emissions level or reduction is a preliminary estimate, not a model output, and requires additional analysis.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 16
Table 2 2024 Priorities: Actions Needed to Successfully and Equitably
Implement Current EV Policies
Legislative Agency Lead
Recommendations* actions actions Agency Equity**
Continue funding WSDOT zero-emission None in 2024 Assess programs WSDOT Significant air
vehicle and infrastructure programs: and develop quality
funding request improvement
2.24 Continue funding WSDOT’s ZEVIP for 2025-27
grant program to provide support for biennium. Lower costs
charging along state routes.
Increased
3.6 Continue funding WSDOT’s Zero-
EV access
emissions Access Program (ZAP).

4.8 Continue funding the WSDOT Green More non-
Transportation Capital grant program. driving options

5.1 Support and expand the e-bike rebate
and lending library programs.

D.3 Continue to invest in early-stage
development of electric and hydrogen
planes.

E.1.1 Vessel decarbonization (ferry vessel
and terminal electrification).
E.1 Port decarbonization (electrification).

Expand and accelerate funding None in 2024 Assess programs Commerce Air quality
Commerce community charging and EV and develop improvement
incentive programs for low-to-moderate funding request
income (LMI) consumers: for 2025-27 Lower costs
biennium.
2.9 Expand community charging Increased
programs through formula funding. EV access
3.4 Expedite funding for Commerce’s EV
incentive program.
3.2 Create a state-supported low-cost
leasing program with an EV equity
objective.

1.6 Provide block grants to increase CBO Fund program Implement Commerce Significant air
staff capacity. to help CBOs program. quality
design improvement
transportation
electrification Lower costs
projects.
Increased
EV access

More non-
driving options

* Numbered items in the recommendations column correspond to the policy items detailed in Chapter 5, How Washington Can Get There,
in Part I and Part II.
** The equity column reflects equity benefits, including air quality improvements in overburdened communities, and lower costs,
increased EV access and more non-driving options for vulnerable populations.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 17
Table 2 2024 Priorities: Actions Needed to Successfully and Equitably
Implement Current EV Policies, continued

Legislative Agency Lead
Recommendations* actions actions Agency Equity**
2.5 Support planning and building None in 2024 Finish cost Utilities and No ef fect
necessary utility-side charging assessment and Transportation
infrastructure. develop Commission
program as (UTC) and
funding request Commerce
or legislation.

3.14 Fund and support state agency Fund state Implement EO All state No ef fect
ef forts to implement EO 21-04. agency fleets 21-04. cabinet
to successfully agency fleets
implement EO
21-04.

Make charging access more equitable and None in 2024 Develop suite of Commerce Air quality
speed up project timelines: policy proposals (with support improvement
to improve from UTC)
Section 2: Charging and Utility consumer Lower costs
Infrastructure experience and
equitable Increased EV
access, and access
speed up
implementation
timelines.

1.7 Monitor equity indicators and None in 2024 Examine air- Ecology, Significant air
measure outcomes. monitoring Health and quality
needs near WSDOT improvement
highways,
estimate health Lower costs
benefits of the
TES and Increased EV
implement a access
transportation
equity More non-
assessment. driving options

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 18
Priorities for 2025 and Onward

The EV Council will implement the TES by immediately prioritizing the 14 sets of recommendations in
Table 2 above. Based on progress made, it will determine 2025 priorities in fall 2024. The EV Council will
then repeat the same annual prioritization process by identifying key actions for the year ahead. TES
recommendations not included in the 2024 list are important to the transition and will be considered for
prioritization in the EV Council’s work in 2025 and the years following.

TES Development Process

The EV Council oversaw development of the TES. The EV Council is an interagency effort co-led by the
Department of Commerce and the Washington State Department of Transportation (WSDOT), with
representation from the State Efficiency and Environmental Performance (SEEP) Office, the Office of Financial
Management, the Office of Superintendent of Public Instruction (OSPI), the Utilities and Transportation
Commission (UTC) and the Departments of Agriculture, Ecology, Enterprise Services and Health.

Through an open and competitive proposal process in the fall of 2022, the EV Council hired a consulting
team led by RMI and supported by Cascadia Consulting Group, NW Energy Coalition, Front and Centered
and Strategic Research Associates.

The EV Council drafted the TES with significant stakeholder engagement and recommendations, including:

• The EV Infrastructure and EV Adoption Working Group, an informal committee made up of state agency
staff with experience implementing transportation electrification policies and programs.

• The Advisory Committee, a formal stakeholder group with 25 members representing a diversity of
6

perspectives, in-state geographies and industries, and informed by issue-specific subcommittees.

• Wide-reaching and diverse stakeholder engagement in the form of 40 one-on-one interviews, eight
focus groups and a survey of 3,026 residents across the state, statistically representative by gender,
age and region, to explore opinions and perspectives on EVs. The survey consisted of 30 questions,
including quota and demographic questions, and aimed to understand Washington residents’ desires
for their personal vehicles and how they think about EVs, including information gaps and myths,
perceived barriers, trusted information sources and readiness to purchase an EV.

• In-depth modeling and analysis of different policy and economic scenarios influencing the potential
rate of transportation electrification in Washington.

• Eight targeted policy workshops and three equity-focused workshops.
• The application of an equity lens to all elements of the TES, developed in partnership with community-
based organizations (CBOs) representing low-income and Black, Indigenous and People of Color
(BIPOC) communities across Washington.

6 Washington State Department of Commerce, “Engrossed Substitute Senate Bill 5974,” Pub. L. No. Laws of 2022, 182
Chapter (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 19
Spokane City Line battery electric bus

Addressing Transportation Electrification Inequities

The TES fits within a broader statewide commitment to reduce carbon emissions and ensure equitable
benefits flow to vulnerable populations and overburdened communities, as established through
the Climate Commitment Act (CCA), HEAL Act and other legislation. Historically, the harmful effects
of transportation and energy policies have been concentrated on lower-income communities and
communities of color.7,8 Washington’s low-income and BIPOC communities, which have contributed
the least to climate change, experience the effects first and worst. These effects are compounded by a
transportation system that disproportionately exposes low-income and BIPOC communities to pollution,
vehicle crashes and the physical barriers created by roads, train tracks and airports.9

Although addressing these effects will require efforts beyond transportation electrification alone, a
forward-looking TES can be a significant step toward redressing the effects of these past and current
inequities by advancing meaningful security, safety and sustainability within the electrified transportation
system for overburdened communities and vulnerable populations. This system should unite
communities rather than divide them; provide individuals the tools to own, govern and benefit from the
energy and transportation assets in their community; and aim to deliver jobs, community wealth and
public health to overburdened communities throughout Washington.

The relationship between transportation electrification and overburdened communities is complex. At
the surface, transportation electrification will reduce adverse health effects caused by vehicle exhaust
in these communities. However, without state action, it is possible that overburdened communities and
vulnerable populations could be further marginalized by the siting of infrastructure and requirements

7 Thomas W. Sanchez, Rich Stolz and Jacinta Ma, “Inequitable Effects of Transportation Policies on Minorities,”
Transportation Research Record: Journal of the Transportation Research Board 1885, no. 1 (January 2004).
8 Thomas W. Sanchez, “Poverty, Policy, and Public Transportation,” Transportation Research Part A: Policy and Practice 42,
no. 5 (June 2008): 833–41.
9 Peter Huether et al., “2023 Transportation Electrification Scorecard,” ACEEE, (June 28, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 20
for technologies that do not directly benefit them. Additionally, BIPOC communities have traditionally
experienced higher energy burdens. Transportation electrification could risk worsening these inequities
through loss of financial equity from devalued gasoline-fueled vehicles and the higher cost of charging EVs
at public chargers versus at home.

The state bears an important responsibility to ensure that the imperative of achieving equitable outcomes
does not fall through the cracks. The TES’s recommendations include ways in which the state should use
its policy and regulatory authority to shape the market and put structures in place to ensure benefits for
overburdened communities and vulnerable populations. This means:

• Directly addressing the effects of higher costs of public charging on lower-income households that lack
access to EV charging at home. Options could include providing subsidies for lower-income EV owners,
extending rate protections to consumers at privately owned chargers and creating a system of public or
community-owned chargers.

• Codifying and enforcing consumer protections related to prices and price transparency, information
and signage, language access and alternative ways to pay (other than credit cards) to ensure that EV
charging is available to everyone. Ensuring that an equitable share of EV charging infrastructure and
its benefits is sited in overburdened communities. Options could include creating a system of public
or community-owned chargers or subsidies for companies to locate charging infrastructure in these
neighborhoods. Communities must be a part of this development to ensure solutions meet local needs.

• Requiring that chargers are regularly maintained and repaired in a timely manner, irrespective of
location, and that the siting of high-speed chargers takes into consideration the cascading effects of
lack of transportation on lower-income families and workers whose livelihoods depend on being able
to get to work on time.

• Designing and implementing robust community-based capacity building, education and outreach to
ensure equitable EV adoption.

• Prioritizing electrification of MHDVs that operate in overburdened communities, so that agencies target
the benefits of reduced air pollution from EVs to areas most at risk from current tailpipe emissions.

The TES also includes recommendations for (1) a transportation equity baseline, (2) an equitable
distribution process and (3) a clear model for adaptive management to help reach these goals.

Where Washington Is Today

Washington’s transportation system — composed of roads, ports, railways, sidewalks, bike lanes, transit
lines, vehicles small and large, and the people who operate and maintain the vehicles and infrastructure
— supports the movements of more than 7.7 million people and a $725 billion economy.10 Washington’s
transportation system is also the largest source of climate pollution in the state at 39% of total emissions,
according to Washington’s most recent official GHG inventory. Washington’s leadership in decarbonizing
transportation through electrification is critical for reducing overall emissions and driving market demand
and innovation.

10 Clifford Woodruff and Matthew von Kerczek, “Gross Domestic Product by State and Personal Income by State, 1st Quarter
2023,” Bureau of Economic Analysis, U.S. Department of Commerce, (June 30, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 21
In addition to GHGs, gasoline- and diesel-fueled transportation produces air pollution that can worsen
people’s health, including nitrogen oxides (NOx), particle pollution and other hazardous air pollutants
(HAPs). Air pollution can affect everyone, though some groups are especially sensitive, including children,
older adults, pregnant people and people with health conditions.11 Other groups, including people with
low income, people of color and tribal populations, have historically encountered increased and prolonged
exposures to air pollution. Traditional internal combustion engine (ICE) vehicles also create noise pollution,
which, although invisible, can cause increases in cardiovascular disease and mortality.12 Although EVs are
required by law to make a minimum amount of sound under certain speeds for pedestrian safety reasons,
they still result in a net reduction in noise pollution (especially at the MHD scale).

Table 3 Washington’s Current Clean Transportation Requirements and Targets
Year Goal(s)

2030 EV Target — 100% of new passenger vehicles sales are electric, per Revised
Code of Washington (RCW) 43.392.020* (non-binding target).
Emissions Limit — Economy-wide GHG emissions down to 50 MMT/year, 45%
below 1990 levels, per RCW 70A.45.020.**
By 2030
30% to 50% of new MHDVs must be zero emissions depending on vehicle class,
per ACT rule.

Carbon-neutral electricity, with a maximum of 20% offsets, per RCW 19.405.040.***

20% reduction in carbon intensity of on-road transportation fuels over 2017
By 2034
levels, per Chapter 173-424 Washington Administrative Code (WAC).****

By 2035 100% of new passenger vehicles must be electric, per ACC II rule.
Economy-wide GHG emissions down to 27 MMT/year, 70% below 1990 levels,
By 2040
per RCW 70A.45.020.

By 2045 Zero emissions electricity, per RCW 19.405.040.

Economy-wide GHG emissions down to 5 MMT/year, 95% below 1990 levels,
By 2050
per RCW 70A.45.020.

* RCW 43.392.020 – Interagency Electric Vehicle Coordinating Council – Target Established – Scoping Plan.

** RCW 70A.45.020 – Limiting Greenhouse Gas Emissions – Greenhouse gas emissions reductions – Reporting
Requirement.

*** RCW 19.405.040 – Washington Clean Energy Transformation Act – Greenhouse gas neutrality – Responsibilities
for electric utilities – Energy transformation project criteria – Penalties.

**** Chapter 173-424 WAC – Clean Fuels Program Rule.

11 U.S. Environmental Protection Agency, “Research on Health Effects from Air Pollution,” (n.d.).
12 Thomas Münzel, Mette Sørensen and Andreas Daiber, “Transportation Noise Pollution and Cardiovascular Disease,” Nature
Reviews Cardiology 18 (March 31, 2021): 619–36.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 22
Governor Jay Inslee attends the opening of new fast chargers.

Modeling for the TES suggests that the state’s current transportation policies and programs (Table 3) —
ambitious and critical as they are — will need additional scaling and an increased implementation pace
to meet the state’s electrification, climate, health and equity targets under today’s political and market
conditions. To understand how Washington’s transportation system will change, it helps to contextualize
what vehicle adoption, driving habits and on-road GHG emissions look like today.

By the Numbers

LDVs — cars, crossovers, vans, SUVs and pickup trucks — make up the vast majority of the more than 6.5
million on-road vehicles in Washington today. Notably, although gasoline-fueled vehicles are the vast
majority of vehicles in Washington, according to the U.S. Energy Information Administration (EIA), in 2021,
27% of on-road fuel consumption in Washington was by diesel vehicles, indicating proportionally greater
fuel consumption per vehicle among MHDVs.13

Passenger EV adoption is on the rise. Gasoline-fueled vehicles accounted for roughly 88% of new LDV
sales in Washington in 2022, but sales data from the first five months of 2023 suggest that approximately
16% of new LDVs sold in Washington were either BEVs or plug-in hybrid electric vehicles (PHEVs).14
However, negligible numbers of electric MHDVs were sold (not including buses). Approximately 1% and
3% of motorcycle and bus sales were electric, respectively. According to the U.S. Department of Energy’s
Alternative Fuel Data Center, Washington has 910 direct current fast chargers (DCFCs) at 240 locations, and
3,493 publicly accessible Level 2 (L2) EV chargers at 1,605 locations.15

Washington’s VMT has grown along with the state’s population, although at a much slower pace. Between
1996 and 2021, Washington’s VMT per capita has declined more than that of any other U.S. state.16 As

13 U.S. Energy Information Administration, “Washington State Profile and Energy Estimates,” (n.d.).
14 John Ryan, “Electric Vehicle Sales Accelerate in Washington State,” KUOW — NPR Network, (July 28, 2023).
15 U.S. Department of Energy — Energy Efficiency & Renewable Energy, “Electric Vehicle Charging Station Locations,” (n.d.).
16 Elizabeth Ridlington, “Less Driving Is Possible,” Frontier Group, (May 19, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 23
incredible as this progress has been, even larger reductions in per capita VMT, in alignment with WSDOT’s
2023 report recommending policy options at the state level and funding guidance for local jurisdictions,
will support Washington’s climate limits.17

The 2021 SES found that emissions from Washington’s transportation sector must decline from an
estimated 38 MMT CO2e in 2022 to 20 MMT CO2e or lower by 2030. On-road GHG emissions make up
approximately 58% of the state’s transportation sector emissions, suggesting that this subsector would
contribute 11.6 MMT CO2e in 2030 if this percentage stays the same. However, it is highly likely that
annual on-road emissions in 2030 must be less than 10 MMT CO2e to make up for harder-to-decarbonize
transportation subsectors, such as aviation and marine.

Washington Residents’ Perceptions about Transportation Electrification

For Washington to successfully meet its goals, it is essential to understand not only the current
transportation sector but also the barriers state residents face (or perceive they face) in the transition to
an electric transportation system. As part of the TES public engagement process, the consulting team
collected testimonials from a diverse group of Washingtonians on the kinds of barriers that exist for
transportation electrification, with a focus on overburdened communities and vulnerable populations.
Such discussions covered topics including:

• Public charger availability and accessibility
• The cost to purchase and charge EVs
• Supporting policies and funding at the local, state and national level
• Public understanding and excitement about EVs
• Demand on the power grid
• Inequities for overburdened communities in the electrification transition
Discussions with these diverse groups, covering the topics noted above and other aspects of transportation
electrification, have directly influenced policy development and implementation plan creation.

Where Washington Needs to Go

RMI conducted extensive modeling to explore how on-road EV adoption and charging needs in Washington
may progress over time. The analysis to support the TES included two stages: (1) an EV adoption model,
which estimates EV sales and overall vehicle population from 2023 through 2035 using a combination of
bottom-up economic analysis and top-down policy requirements such as the ACC II and ACT regulations
and (2) an assessment of anticipated EV charging needs, using the number of EVs estimated through the
adoption model combined with local trip data.

17 Roger Millar and Norene Pen, “Vehicle Miles Traveled (VMT) Targets - Final Report,” Washington State Department of
Transportation, (June 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 24
The modeling demonstrates the wide variety of potential outcomes that might be expected based on
different assumptions about future economic, policy and customer preferences. Several clear themes
emerged, ordered below by priority and potential impact:

1. The state’s adoption of ACC II is a critical component of transitioning to an EV future. However,
achieving the regulation’s sales requirements will happen only with additional actions to undergird
the policy, such as infrastructure build-out, consumer education and reduced purchase price. ACC
II requires light-duty ZEV sales in the state to account for 68% of new LDV sales in 2030 and 100%
of new LDV sales by 2035, while the separate 2030 EV target sets an accelerated goal of reaching
100% by 2030. Without ACC II, the state would otherwise expect sales of electric and plug-in hybrid
electric LDVs to represent only approximately 59% of new LDV sales in 2030 — far short of the
68% requirement and 100% goal (Figure 1). This finding underscores the need for supplementary
investments to ensure ACC II is successfully and equitably implemented.

Figure 1 Estimated Light-duty Vehicle Sales, ACC II and Economics Alone
EV PHEV ICE-Gasoline

LDV Sales Share Under ACC II LDV Sales Based on Economics Alone
100% 100%

80% 80%
2030: 68% 2030: 59%
ZEV Sales ZEV Sales
60% 60%

40% 40%

20% 20%

0% 0%
2023 2025 2030 2035 2023 2025 2030 2035

Note: The dip in EV sales share in the right-hand chart beginning in 2033 is due to anticipated expiration of federal tax credits extended and
modified by the Inflation Reduction Act.

2. The ACF regulation is one of the most powerful levers available to the state for accelerating
MHD truck electrification (Figure 2). By limiting usable lifetimes and setting purchase requirements
for specific market segments, ACF ensures that high-impact, electrifiable fleets replace their vehicles.
This purchase requirement creates significant demand for the vehicle supply produced under ACT.
Further, given that drayage trucks, state and local vehicles, and high-priority fleets — targeted under
ACF — comprise a significant number of vehicles (estimated at approximately 40% of total MHD
trucks in Washington in 2023), this regulation is uniquely positioned to encourage MHD electrification
broadly if adopted.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 25
Figure 2 Zero-Emissions Medium- and Heavy-Duty Truck Population
Under ACT and ACF
Strong
50,000 Electrification
Policy Scenario
(ACT + ACF)
40,000
Baseline
Scenario (ACT)

30,000

20,000

Additional Zero-
10,000 Emissions
Trucks Under
ACF
0
2023 2025 2027 2029 2031 2033 2035

Note: The S3 Strong Electrification Policy scenario (upper sales share line in chart) includes incentives for MHD truck
electrification in addition to those in the ACF regulation.

4. Supporting transportation options for people with lower incomes will be essential for attaining
state goals for electrification, climate and equity. The state will need to ensure that sufficient
incentives, charging infrastructure, education and outreach are provided to those least able to afford
to lease or purchase an EV and help make desirable EV adoption levels a reality.

5. Truck electrification is increasingly economical on a TCO basis, due in large part to the incentives
provided through the federal Inflation Reduction Act (IRA). Although up-front costs can still represent
a barrier, lifetime cost savings present opportunities to scale up electrification of these vehicles,
beyond the levels required in the ACT regulation. To ensure truck electrification can drive maximum
impact and scale up rapidly, Washington should focus on vehicles with strong potential to reduce local
air pollution, removing bottlenecks such as vehicle availability constraints and delays in deploying
EV supply equipment (EVSE – generally, charging stations) and providing education and technical
assistance to fleet managers.

6. The pace of installing charging infrastructure for LDVs and MHDVs needs to accelerate
significantly, indicating a clear role for supportive policies. In 2035 Washington will require more
than 20 times more EV charging plugs than the TES model suggests is needed today.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 26
7. Ensuring availability of home (or neighborhood) charging for multifamily homes meaningfully
reduces total public charging network requirements, providing both cost savings and equity
benefits. Figure 3 depicts the estimated number of residential charging ports for both single-family
and multifamily dwellings required to support LDVs in the Strong Electrification Policy scenario,
totaling more than 2.9 million by 2035. Supplementing direct on-site charging with neighborhood
charging options in close proximity to multifamily homes will be an important strategy for providing
this level of access for residents of multiunit dwellings.

Figure 3 Cumulative Residential Charging Ports Required,
Strong Electrification Policy Scenario
Single-Family Home, L2 Charging Ports Multifamily Home, L2 Charging Ports

2035 2.4M 565.5K
2034 2.1M 468.6K
2033 1.8M 384.3K
2032 1.6M 309.5K
2031 1.3M
2030 1.1M
2029 869.4K
2028 684.1K
2027 523.2K
2026 386.4K
2025 281.5K
2024
2023

8. Reducing VMT and total vehicle stock, while shifting new sales to lighter-weight vehicles, has
significant potential for reducing GHG and local air pollutant emissions, as well as total costs.

9. Bus electrification, especially school bus electrification, requires continued policy support to
increase market share. This support is needed from the state and local level, as well as through
flexible federal funding and continued dedicated federal funding such as the Low or No Emissions
grant and the Clean School Bus program.

10. Hydrogen fuel cell electric vehicles (FCEVs) are likely to eventually play a role in heavy-duty (HD)
truck and transit bus electrification. The market share these vehicles will obtain remains unclear,
but at present battery electric alternatives appear likely to be the primary technology for many
applications and duty cycles — especially for LDVs — based on TCO analysis. As both the state’s
hydrogen economy and FCEV technology mature through 2035, the role played by these vehicles
will become increasingly clear. The state should continue to monitor and track the development of

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 27
FCEV technology and costs, and over time consider how these vehicles can contribute to meeting
transportation sector emissions reduction targets. Per RCW 43.330.570,18 the Department of
Commerce’s Office of Hydrogen and Renewable Fuels delivered a Hydrogen and Renewable Fuels
2023 Legislative Report to the Legislature in December 2023, which should inform this assessment.
Additional analysis on FCEV cost outlooks is included in Appendix D.

11. Washington will need to take other actions for non-road vehicles, such as planes, boats
and trains, which represent approximately 42% of the state’s transportation-related emissions.
Accelerating electrification and emissions reduction policy measures addressing non-road vehicles
will be vital for meeting emissions targets.

A ferry crosses the Puget Sound. WSDOT aims to fully electrify the state’s ferry system by 2040.

Recommendation: Focus Efforts on Achieving the Strong Electrification Policy
Scenario

The state will need to focus on the levers it most readily has available to promote transportation
electrification, equity and alignment with climate goals. Accordingly, focusing on the Strong Electrification
Policy scenario (also referred to as Scenario 3 or S3, which is described in further detail in Chapter 4) is
likely to provide the best combination of attainable policy options and feasible programs to implement.

18 RCW 43.330.570 – Office of renewable fuels – Duties.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 28
For the state to align EV sales trajectories with the Strong Electrification Policy scenario, several key actions
will be required.

1. Providing enhanced state incentives for ZEVs and EV charging infrastructure. Examples include
extending and simplifying the EV sales tax exemption; providing a larger incentive value (e.g., $5,000) in
the Alternative Fuel Vehicle Incentive administered by the Department of Commerce, with a particular
focus on overburdened communities and vulnerable populations; increasing the charging and clean
fuels subsidies provided through the Department of Ecology’s Clean Fuel Standard through 2035;
and working with electric utilities to provide higher EVSE incentives for residential and commercial
customers (e.g., $800/residential EVSE through 2035 versus $400 through 2028 in the baseline scenario).

2. Ensuring that federal incentives are used to the greatest extent possible. Examples include
promoting the availability of the Clean Vehicle Credit and Qualified Commercial Clean Vehicle Credit
so that more EV sales in the state are subsidized primarily by the federal government, and promoting
adherence to the requirements for full rather than partial compliance with the Alternative Fuel
Refueling Property Credit, such as meeting prevailing wage requirements. The state should continue
to monitor and track applicable federal programs and share information with local government,
industry and residents to support effective utilization of federal incentives.

3. Achieving ACF adoption rates to complement the existing ACT regulation. Having adopted
California’s motor vehicle emissions standards under Section 177 of the Clean Air Act, Washington may
have the ability to adopt and implement the ACF rule or a policy that creates ACF-like adoption rates,
in addition to ACT. The Department of Ecology is currently monitoring California’s actions to finalize
ACF given its existing mandate from the Legislature. The accelerated purchase requirements for MHD
vehicles in ACF have a meaningful effect on electric and FCEV truck adoption in the state because
these requirements are applicable to an estimated 40% of the state’s MHD vehicles. The EV Council
anticipates ACF to provide commensurate levels of incremental GHG and local air pollutant emissions
reductions, beyond those associated with ACT.

4. Conducting education and awareness campaigns to promote the benefits of EVs, available EV
programs and increasing affordability of EVs. The Strong Electrification Policy scenario assumes
stronger consumer interest in EVs as a proxy for effective messaging and education about the benefits
of these vehicles. To make this assumption a reality, the state can invest in meaningful education and
engagement activities, beginning with the Education Plan and the Washington State Transportation
Electrification Engagement Plan (Engagement Plan) developed for the TES.

In addition to these key policies, the state should consider the strategies embedded within several of
the “exploratory” scenarios modeled, which rely heavily on VMT reduction and vehicle stock change
assumptions to achieve lower emissions rates than will be attainable through vehicle electrification alone.

How Washington Can Get There

In recognition of the challenge to meeting state goals identified within the modeling, the TES outlines
critical technological, financial and institutional barriers that the state will need to address to meet its
transportation electrification targets, briefly summarized in Table 4.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 29
Table 4 Technological, Financial and Institutional Barriers
Technological Financial Institutional

Product supply chain limitations Lack of cost parity between EVs and ICE Charging infrastructure
have led to both EV production vehicles can make it difficult or impossible development can face delays due
challenges and reduced availability for some consumers to transition. This to challenges caused by local
of fast-charging infrastructure. This barrier is worsened by the existence of a permitting processes, timelines,
has led to a mismatch between limited market for used EVs. Additionally, regulatory procedures for grid-
available EV stock and consumer not all EV models qualify for federal tax side utility upgrades and supply
preferences (e.g., affordable models credits, and historically, incentives have been chain constraints for electrical
like the Chevrolet Bolt, all-electric provided in the form of tax credits rather than equipment, among other
three-row SUVs, trucks, and vans) “on the hood” point-of-sale rebates. institutional barriers.
and a lack of available material for
fast-charging hardware, lithium, and Installation of EVSE can have high up- Lack of clear and consistent EV
other components (particularly front capital costs, including costs to signage creates difficulty locating
switchgear and transformers) critical upgrade grid infrastructure, and and subsequently using chargers.
to EVs and EVSE. challenging business models. Furthermore,
many individuals find it challenging to There is a lack of community
Current charging infrastructure is access federal, state, private and utility support and buy-in due to
generally decentralized, can be funding to defray the costs of charging perceived or real safety concerns;
unreliable, lacks interoperability infrastructure. insufficient data for personal and
and, due to slow speeds, can result business decision-making;
in queues for open chargers. Operating costs for public EV charging questions about range, weather
lack transparency, and significant price and towing capacity; and real or
Grid infrastructure is insufficient to variability between at-home and public perceived concerns regarding the
meet anticipated charging needs in charging disproportionately affects ethical and environmental
later years in many locations, and renters and residents of multifamily impacts of material extraction and
likely in the near term for areas homes. Additionally, fleet operators and recycling. These are worsened by a
with concentrations of MHDVs businesses are unaccustomed to negotiating confusing policy and incentive
which will require higher-power charging agreements and see it as complex landscape and information gaps for
charging. Additionally, Washington and full of risk. consumers shopping for a new
will need to increase investments in vehicle.
energy efficiency and demand Absent effective regulation, managed
management, and generate or import charging and other strategies to better use A limited workforce means a lack
sufficient renewable energy to ensure grid capacity, energy burdens could of technicians to service EVs, and
transportation electrification is increase for low-income households if of engineers, electricians and
powered by zero-carbon electricity. utility rates increase to support charging technicians to install and
infrastructure. maintain EVSE and related grid
Trip range can be limited by infrastructure. Additionally,
negative weather impacts on On average, existing passenger cars often increasing this limited workforce
battery capacity and can be stay on the road for approximately 15 needs to be balanced with job
worsened by lack of EVSE years, given the cost of replacing vehicles security for the existing workforce,
infrastructure. Specific vehicle and because older cars often move into the including those who currently work
types, such as electric buses, fleet used car market rather than being taken off with ICE vehicles.
vehicles and used EVs are likely to the road.
face higher barriers. Charging infrastructure,
especially for MHDVs, will require
significantly more real estate than
diesel fueling.

Slow turnover of existing vehicle
stock can limit implementation
timelines. Many cities limit the
number of electric buses they can
procure based on their current stock
of buses that are still in operation.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 30
To overcome these barriers, to enable a regulatory and market environment to facilitate EV adoption rates
at the pace envisioned in the Strong Electrification Policy scenario and to achieve Washington’s climate
and equity goals, the state will need to enact a collection of supplemental policies across six categories:
consumer education and capacity building, charging and utility infrastructure, LDVs, MHDVs, electrified
micromobility and workforce. This approach not only accounts for the need to transition vehicles, but
importantly, continues to develop the ecosystem needed to effectively and equitably transition to an
electrified transportation system.

A total of 86 policies are included across these six categories. Detailed descriptions can be found in Chapter
5, Part I – Achieving the Strong Electrification Scenario.

Additionally, to achieve the state’s 2030 GHG emissions limit, it is likely that on-road emissions must be
less than 10 MMT CO2e to make up for harder-to-decarbonize sectors and subsectors, including non-road
transportation.

RMI modeling shows that maximum feasible EV adoption still leaves an approximate 4 MMT CO2e gap
in emissions reductions in 2030 relative to the 10 MMT CO2e threshold. Given the state’s commitment to
reaching its 2030 emissions limit, it must consider significant new investments beyond the transportation
electrification recommendations laid out in this strategy (Table 5). Although EVs are part of a holistic
transportation landscape, they cannot be separated from land use, safety, transit, active transportation,
fuel economy and clean fuels. For this reason, the EV Council lays out additional policies in Chapter 5, Part
II – Closing the 2030 Transportation Greenhouse Gas Emissions Gap, because the state will need to consider
developing and implementing strategies to achieve the following objectives:

• Speed up retirement of the highest-emitting ICE vehicles
• Increase vehicle energy efficiency
• Decarbonize non-road vehicles (e.g., aviation, maritime)
• Reduce VMT by supplementing existing state efforts

Table 5 Strategies to Achieve 10 MMT CO2e in 2030 On-Road Emissions
2030 Incremental
Strategy emissions reduction

Successfully implement current EV and VMT policies 14.1 MMT 9.4 MMT
(from 2019 levels)

Take stronger electrification actions 13.9 MMT 0.2 MMT

Reduce VMT per capita by 17% instead of 6% ≈13.2 MMT* ≈0.7 MMT*

Require vehicle efficiencies and fund early ICE vehicle
≈12.0 MMT* ≈1.2 MMT*
retirement

Reduce carbon intensity of gasoline and diesel ≈10.0 MMT* ≈2.0 MMT*

* The emissions level or reduction is a preliminary estimate, not a model output, and requires additional analysis.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 31
2030 EV Target Is an Aspirational Stretch Goal, but Likely Infeasible

Revised Code of Washington (RCW) 43.392.02019 requires the EV Council complete a scoping plan for
achieving the 2030 EV target. The EV Council decided to complete this analysis within the TES, and it is
embedded throughout this report. The actions needed to achieve 100% new light-duty EV sales by 2030 are
also needed to achieve the 68% sales share projected by 2030 in the Strong Electrification Policy scenario
(S3). Therefore, the policy recommendations in Chapter 4 should be considered key elements of the
required scoping plan.

This divide raises the question: How could the state go from reaching 68% to 100% EV market share in
2030? The TES model uses a sensitivity analysis to assess the difference between these versions of the
future. For the preferred Strong Electrification Policy scenario (S3), that sensitivity analysis is labeled S3b
throughout the TES.

In addition to the recommended Strong Electrification Policy approach detailed throughout the rest of this
report, such a scenario (S3b) would require:

• Rebates amounting to $9,000 per sedan and $11,000 per light truck or SUV or more in 2030 above the
incentives required to reach the ACC II’s 2030 sales goal

• Approximately 185,000 additional charging ports by 2030 at an additional expense ranging from $200
million to $520 million

• Voluntary discontinuation of non-electric LDV production and sales by all automakers and dealers
Because S3b would likely be infeasibly expensive, would depend on factors largely outside the state’s
control (e.g., fossil fuel prices, automaker and dealership voluntary decision-making) and would result in a
relatively modest 0.3 MMT decline in 2030 emissions compared with Scenario 3, the EV Council selected the
more feasible and still very strong electrification pathway in Scenario 3 as the preferred scenario to use as
the TES foundation.

Recognizing the importance of bold targets to drive urgency in climate action, the EV Council and its
member agencies will continue to pursue the 2030 EV target set by the Legislature as an aspirational stretch
goal. It will also urge state policymakers to consider the cost per metric ton CO2e avoided when evaluating
different program investments to stay under the 2030 emissions limit.

Monitoring, Evaluation and Continuous Improvement

Successful implementation of Washington’s transition to an electric transportation system will be
measured in EVs on the road, EV chargers installed, air quality improvements and real and direct equitable
outcomes for overburdened communities and vulnerable populations. To that end, the state will publicly
track the key performance indicators listed below and publish an annual report.

19 RCW 43.392.020 – Interagency Electric Vehicle Coordinating Council – Target Established – Scoping Plan.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 32
in the face of a changing market and policy landscape. The annual report will assess progress, identify
roadblocks and recommend course corrections as necessary to achieve desired outcomes. Metrics will
include several indicators to assess changes to charging infrastructure, LDV and MHDV adoption, EV miles
traveled, GHG emissions and air pollutants, and equity and environmental justice indicators.
As a first step in successfully tracking relevant metrics, the EV Council, through the lead of each designated
agency, must:

• Establish methods of data collection and tracking for any new key performance indicators and set
baselines for any new information.

• Develop thresholds or goals by date for each indicator, if possible and if not already established.
• If too much uncertainty exists to establish a reliable threshold or goal, establish directional indicators
(positive, negative) for guidance.

As a reference, the Strong Electrification Policy scenario (S3) establishes guiding metrics that the state
can use to benchmark its progress (Figure 4). These metrics, as well as those from all modeled outcomes
of different scenarios and sensitivities tested as part of developing the TES, can be explored on the
Washington TES User-Interactive Dashboard, found on the TES website.20

Importantly, the metrics from the modeling should be considered directional and indicative, rather than
precise. State staff and interested stakeholders can use the metrics as general guidance when considering
Washington’s success in reaching state goals.

Figure 4 Washington EV Adoption and Infrastructure Milestones
Strong Electrification Policy Key + 2030 Electric LDV Sales Target

101k 101k Electric LDVs sold 284k 411k Electric LDVs sold 426k 426k Electric LDVs sold
3k 3k Electric MHDVs sold 5k 5k Electric MHDVs sold 7k 7k Electric MHDVs sold
223k 223k L2 chargers 1,291k 1,475k L2 chargers 2,989k 3,385k L2 chargers
2k 2k DCFCs 7k 8k DCFCs 11k 12k DCFCs
1k 1k MHDV and bus chargers 7k 7k MHDV and bus chargers 12k 12k MHDV and bus chargers
20.6 20.6 MMT GHG emissions 13.9 13.6 MMT GHG emissions 8.8 8.2 MMT GHG emissions

2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035

192k 192k Electric LDVs sold 363k 416k Electric LDVs sold
5k 5k Electric MHDVs sold 6k 6k Electric MHDVs sold
611k 613k L2 chargers 2,243k 2,610k L2 chargers
4k 4k DCFCs 9k 11k DCFCs
3k 3k MHDV and bus chargers 10k 10k MHDV and bus chargers
17.3 17.3 MMT GHG emissions 10.7 10.1 MMT GHG emissions

20 Washington TES User-Interactive Dashboard, found on the TES website.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 33
Building Awareness and Capacity

Although the state has existing programs and policies to bring down EV costs and build out charging
infrastructure, it has not yet taken action to provide good-quality public information so both consumers
and fleet managers can navigate a new, complex and quickly changing EV industry. If up-front cost and
charging are the first two legs of the EV transition stool, education and awareness is the third. Declining
prices and expanded charging infrastructure only drive adoption as far as people know about them.
Recognizing this gap, the EV Council hired Cascadia Consulting to develop an EV Education Plan to increase
awareness and a TES Engagement Plan to improve state-level decision-making with on-the-ground
information and input.

EV Education Plan

A crucial element for Washington’s success in meeting its goals is to ensure that Washington residents have
information and awareness regarding EVs. The EV Education Plan’s goal is to accelerate the adoption of
personal EVs in Washington. To that end, the EV Education Plan aims to serve as an evidence-based guide
for a short-term (one- to two-year) marketing campaign to provide Washingtonians with the information
they need to buy or lease EVs. This involves raising awareness of EVs, providing information and pointing
consumers to places where they can determine which EV is best for them and their lifestyle. The EV
Education Plan is a guide to overcoming Washingtonians’ barriers to and concerns about switching to EVs
to facilitate EV purchasing and leasing.

The plan draws from a literature review of existing EV Education Plans, a statewide EV market research
survey administered in the spring of 2023 and one-on-one interviews and focus groups conducted as part
of the TES’s formative engagement.

According to the market research survey, the top three barriers to EV adoption — whether perceived or real
— are universal across target audiences (Figure 5).

Figure 5 Top Three Barriers to EV Adoption

COST
The up-front cost of buying an EV
RANGE AND CHARGING
EVs do not have enough range and there are not enough charging stations
TECHNOLOGY WILL BECOME OUTDATED
Concern about EV technology changing fast and not wanting a vehicle that will be outdated

The statements in Figure 6 are perceptions (again, accurate or misconceptions) that survey respondents
reported with the most frequency as making them less enthusiastic about EVs. Although not explicitly
barriers, these statements can factor into individual decisions not to purchase or lease EVs or to delay
doing so, and therefore should be addressed through educational messaging and strategies.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 34
Figure 6 Survey Respondents’ Perceptions

The EV Education Plan includes messaging opportunities, trusted information channels, equity
considerations, strategies and monitoring and evaluation criteria.

TES Engagement Plan

The TES Engagement Plan’s goal is to provide a roadmap for engaging key audiences and Washington
communities on policies and programs that will be implemented under the umbrella of the TES. It is
complementary to the TES implementation plan and focuses on providing guidance regarding which
audiences need to be engaged on specific policy recommendations in the TES, and how to inform them,
seek their input, involve them in planning and implementation, and collaborate with them.

This engagement plan incorporates Washington audiences’ and community members’ input, priorities and
recommendations, and builds on extensive community feedback from several months of engagement and
a literature review.

The plan is divided into three parts (Table 6).

Table 6 TES Engagement Plan
Part One Part Two Part Three

Engagement Principles TES Engagement Strategies, A Guide to TES
and Methods Actions and Activities Implementation
Engagement
This section notes the This section outlines the
guiding principles for recommended ongoing This section lists key
engagement, including engagement strategies, actions audiences identified in
stages of engagement and associated activities. It also formative engagement,
and equity offers recommendations on provides specific guidance on
considerations. messaging to audiences whose which audiences and
input is sought. communities to engage, and
offers a matrix of engagement
and activities for each policy.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 35
The TES Engagement Plan identifies four key strategies for ongoing statewide engagement for the
implementation of TES programs and policies. These strategies are supported by actions, specific activities
and key performance indicators, and are as follows:

• Strategy 1: Cultivate an audience network
• Strategy 2: Establish an audience engagement framework
• Strategy 3: Engage key audiences and Washington communities
• Strategy 4: Conduct monitoring and evaluation
This document also serves as a guide to TES implementation engagement and serves as a complement to
other TES documents. The TES Engagement Plan identifies lead agencies and programs for specific policies
and programs in the TES, recommends integration into existing state infrastructure and funding streams,
and provides next steps for implementing those programs and policies. The TES Engagement Plan outlines
the ingredients for facilitating partnerships and engaging audiences that will support the advancement of
TES programs and policies.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 36
Call to Action

An electric vehicle
charges along
the West Coast
Electric Highway.

The EV Council designed the policy recommendations and implementation plan in this report to meet
Washington’s emissions limits through setting up the supportive infrastructure necessary for rapid
scaling, intentionally and proactively directing benefits to overburdened communities and vulnerable
populations, and ensuring that the electrification transition supports the state’s wider decarbonization
targets in 2030, 2040 and beyond.

Washington is among the first states to develop a truly holistic plan for equitably transitioning to a
predominantly electric transportation system. With this report, Washington commits to following up its
nation-leading policy obligations with actionable plans and impactful programs to achieve its climate
and equity goals.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 37
1. Introduction: Historical
Context and Objectives
Climate Imperative

People feel the effects of climate change across Washington. More extreme weather events, longer
droughts, increased wildfire risk and intensity and decreased snowpack are a result of climate change and
are impacting human health and the environment. Continuous action from Washington state government
is critical to protect the health and well-being of residents, and to eliminate the historical and cumulative
effects borne by overburdened communities and vulnerable populations. Mitigating the effects of climate
change is a paramount statewide priority. Washington has adopted aggressive requirements to limit GHG
emissions to 45% below 1990 levels by 2030, 70% below 1990 levels by 2040 and 95% below 1990 levels by
2050, and to achieve net-zero GHG emissions by 2050.

Achieving these GHG emissions reductions will require Washington to focus on the transportation sector,
which represents the state’s largest source of emissions at 39%. Electricity as a transportation fuel
offers one of the lowest carbon pathways to reduce transportation sector emissions, since Washington
has some of the cleanest electricity in the nation and is on a path to 100% clean electricity by 2045 as
mandated by CETA.21 CETA, coupled with Washington’s suite of clean transportation policies — including
the Clean Fuel Standard (CFS) and Clean Vehicles programs — as well as historic levels of federal support
for reducing emissions and fossil fuels through the IRA, positions Washington to rapidly decarbonize the
transportation sector.

Legislative Directive

In March 2022, the Legislature passed Move Ahead Washington (Chapter 182, Laws of 2022), a 16-
year transportation package. Included in Move Ahead Washington were several key elements to further
accelerate the transition to an electrified transportation system. Principally, Move Ahead Washington
established the EV Council to align existing transportation electrification efforts across state agencies. As
one of its first orders of business, the EV Council was directed to develop an equitable and inclusive TES.22

To complement this new interagency effort, Move Ahead Washington established a nonbinding target
that all publicly and privately owned passenger vehicles and light-duty vehicles of model year 2030 or
later that were sold, purchased or registered in Washington must be electric. Consistent with Move Ahead
Washington’s directives, the TES explores pathways to meet this 2030 EV target.

These directives have created a first-of-its-kind effort in Washington to strategically chart a holistic path
forward to a cleaner and more equitable transportation system.

21 Washington State Department of Commerce, “Clean Energy Transformation Act,” (n.d.).
22 A full report of the EV Council’s activities and accomplishments in 2022 and 2023 can be found in the Annual Report on the
TES website.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 38
RapidRide station in Downtown Seattle. Photo courtesy of Seattle Department of Transportation

Equity and Environmental Justice

The TES fits within a broader statewide commitment to reduce carbon emissions and ensure equitable
benefits flow to vulnerable populations and overburdened communities, as established through the CCA,
HEAL Act 23 and other legislation. Historically, the harmful effects of transportation and energy policies have
been concentrated on lower-income communities and communities of color.24,25 Washington’s low-income
and BIPOC communities, which have contributed the least to climate change, experience the effects first
and worst. These effects are compounded by a transportation system that disproportionately exposes
low-income and BIPOC communities to air and noise pollution, vehicle accidents and the physical barriers
created by roads, train tracks and airports.26

The TES presents an extraordinary opportunity to redress the effects of these past and current inequities
by advancing meaningful security, safety and sustainability within the electrified transportation system
for overburdened communities and vulnerable populations. This system should unite communities
rather than divide them; provide individuals the tools to own, govern and benefit from the energy and
transportation assets in their community; and aim to deliver jobs, community wealth and public health to
overburdened communities throughout Washington.

In response to this opportunity and with significant input from representatives of overburdened
communities from across the state, the TES includes recommendations for (1) a transportation equity
baseline, (2) an equitable distribution process and (3) a clear model for adaptive management to help
reach these goals, among other policy proposals.

23 Washington Department of Ecology, “Healthy Environment for All,” (2023).
24 Sanchez, Stolz and Ma, “Inequitable Effects of Transportation Policies on Minorities.”
25 Sanchez, “Poverty, Policy, and Public Transportation.”
26 Huether et al., “2023 Transportation Electrification Scorecard.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 39
Scope, Objectives, Goals

Maximizing the opportunity of electrifying the transportation system requires Washington to address the
inherent challenges in this transition. To achieve this, the TES seeks to address three key questions:

1. How can Washington meet the 2030 EV target established in Move Ahead Washington?

2. How can Washington ensure market and infrastructure readiness for all new LDV sales being electric?

3. How can Washington decarbonize the majority of the transportation system, covering all on-road
vehicles (cars, trucks and buses) and non-road vehicles (planes, boats, trains and off-road mobile
equipment), while directly and equitably benefiting vulnerable populations and overburdened
communities?

The EV Council developed seven TES objectives to help answer these questions:

1. Complete a statewide TES that can be delivered by the EV Council to the Legislature by January 2024.

2. Ensure the TES represents the preferences of and information from communities across Washington,
including perspectives gained from close coordination with the EV Council Advisory Committee.

3. Ensure the TES benefits vulnerable populations and overburdened communities.

4. Identify grant funding for EV infrastructure available to persons living in Washington, including
existing and future state, federal and other opportunities.

5. Create a detailed implementation roadmap through 2035 within the TES, including a scoping plan
benchmarked to the state’s 2030 EV target.

6. Create an engagement plan for effective public engagement through 2035 consistent with the HEAL Act.

7. Create an education plan detailing needed actions by the state to provide clear information and
education about EVs to ensure adoption in rapidly changing EV markets.

The five remaining chapters of the TES tie these objectives together:

• Chapter 2, Strategy to Address Transportation Inequities, describes transportation equity
expansively, anticipates how overburdened communities and vulnerable populations may be impacted
positively or negatively by electrification, and outlines key actions to support equitable outcomes.

• Chapter 3, Where Washington Is Today, outlines the current state of transportation electrification in
Washington, including policies, programs, vehicle stock trends and residents’ perspectives.

• Chapter 4, Where Washington Needs to Go, includes modeling and analysis of different scenarios
influencing the rate of transportation electrification for on-road vehicles and evaluates other factors,
including shifting and reducing VMT and HD mobility options.

• Chapter 5, How Washington Can Get There, outlines a detailed policy roadmap to meet Washington’s
transportation electrification targets and reduce transportation sector emissions consistent with the
statewide GHG limits.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 40
For the purposes of the TES, EVs exclude fossil fuel hybrids. The scenarios analyzed in Chapter 4 include
only on-road vehicles (light-, medium- and heavy-duty vehicles), and the recommendations in Part
I of Chapter 5 focus on supporting the electrification of these modes of travel, with the addition of
e-micromobility. The policies in Part II of Chapter 5 expand on the on-road recommendations to include
opportunities for non-road vehicle electrification and other strategies to reduce GHG emissions from the
transportation sector, consistent with the 2030 emissions limit.

TES Development Process

The EV Council spearheaded development of the TES. The EV Council is an interagency effort co-led by the
Department of Commerce and WSDOT and joined by the SEEP Office, the Office of Financial Management,
OSPI, UTC, and the Departments of Agriculture, Ecology, Enterprise Services and Health.

Meeting the objectives identified for the TES requires significant and meaningful stakeholder engagement.
Consequently, the TES is informed by recommendations from:

• The EV Infrastructure and Adoption Working Group, an informal committee made up of state agency
staff with experience implementing transportation electrification policies and programs.

• The EV Council Advisory Committee, a formal stakeholder group with 25 members representing
a diversity of perspectives, in-state geographies and industries, and informed by issue-specific
subcommittees.

• In-depth modeling and analysis of different policy and economic scenarios influencing the potential
rate of transportation electrification in Washington.

• Targeted policy and equity-focused workshops.
• The application of an equity lens to all elements of the TES, developed in partnership with CBOs
representing low-income and BIPOC communities across Washington.

Under the leadership of the EV Council, development of the TES was supported by a consulting team, led
by RMI and assisted by Cascadia Consulting Group, NW Energy Coalition, Front and Centered and Strategic
Research Associates.

Summary

The TES is the culmination of clear legislative leadership, critical oversight from the EV Council and robust
stakeholder input, and is designed to ease the path to an electrified transportation system that drives
meaningful reductions in GHG emissions and air pollutants. Equitable outcomes are prioritized throughout
and will be essential for the successful implementation of this strategy, as well as for the future health and
well-being of Washington’s residents.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 41
2. Strategy to Address
Transportation Inequities
Equity Chapter Overview

The TES fits within a broader statewide commitment to reduce carbon emissions and ensure equitable
benefits flow to vulnerable populations and overburdened communities. In addition to a reduction in
carbon emissions, the TES will be judged on its ability to deliver benefits to these residents.

Historically, the harmful effects of transportation and energy policies have been concentrated on lower-
income communities and communities of color.27,28 The transition to an electrified system will be the largest
transportation and energy evolution in our lifetimes. The TES is a pivotal step in imagining and planning for
that future in a way that leaves behind the inequities of the current system.29 This can be realized through
the adoption of (1) an equitable distribution process, (2) a transportation equity baseline and (3) a clear
model for adaptive management to help reach these goals, among other proposals.

The TES development process involved significant input from representatives of overburdened
communities from across the state. They included members of the Front and Centered Advisory Panel,
which was convened for the purpose of integrating equity principles in the TES and contributing
recommendations for this report.

Background and Statutory Guidance

The TES presents an extraordinary opportunity to set right the effects of past inequities by building on
federal and state policies. The Justice40 Initiative30 and CCA31 set targets for investing in communities that
have faced environmental injustice. CETA requires that equity become an explicit part of electric utility
planning. Move Ahead Washington and the HEAL Act establish specific environmental justice requirements.

RCW 43.392.01032 says “the legislature further finds that in order to meet the statewide greenhouse gas
emissions limits in the transportation sector of the economy, more resources must be directed toward
achieving zero emissions transportation and transit, while continuing to relieve energy burdens that exist
in overburdened communities.” RCW 43.392.040(1)(f)33 says the EV Council must “ensur[e] the statewide
transportation electrification strategy, grant distribution, programs, and activities associated with
advancing transportation electrification benefit vulnerable and overburdened communities.”

27 Sanchez, Stolz and Ma, “Inequitable Effects of Transportation Policies on Minorities.”
28 Sanchez, “Poverty, Policy, and Public Transportation.”
29 Huether et al., “2023 Transportation Electrification Scorecard.”
30 The White House, “Justice40,” (n.d.).
31 Washington Department of Ecology, “Climate Commitment Act,” (n.d.).
32 RCW 43.392.010 – Interagency Electric Vehicle Coordinating Council: Findings – Intent.
33 RCW 43.392.040 – Interagency Electric Vehicle Coordinating Council: Council responsibilities – Annual Report.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 42
Equity and Transportation Electrification

Over the life span of the TES, transportation electrification will deliver substantial economic and health
benefits to Washington residents, perhaps most clearly through reducing air pollution from vehicle exhaust
in all communities. But without careful policy design, these benefits may be provided predominantly
to the same neighborhoods and populations that have seen advantages from past policy and funding
decisions. Such an outcome would leave in place institutional racism, an economy stacked against those
with less generational wealth and obstacles to mobility for those without good credit or personal vehicles.
The federal and state governments are investing in a new age of clean transportation infrastructure and
have the opportunity to level the playing field for people all over the state and especially those facing
cumulative environmental, health-based, discriminatory and financial harms layered brick by brick by our
existing reliance on fossil fuels.

The EV Council is committed to building a new clean transportation system in an equitable way, which the
previous system never did. Transportation policy and practice have far-reaching implications for many
aspects of people’s lives, including their health, wealth, safety and fundamental dignity. BIPOC and low-
income communities, people with disabilities or language barriers and frontline transportation workers
at ports and on highways bear greater exposure to the harmful effects of the transportation system, such
as air and noise pollution and traffic collisions, and suffer from the division of their neighborhoods by
highways, train tracks and airports.34,35 Furthermore, they have limited access to essential resources, such
as public transit, sidewalks and safe bike paths, resulting in longer and more challenging commutes.36
Community members asked that the TES recognize these disparities and actively work to ensure the harms
and inequities of the current transportation system do not carry over into the new, electrified system.37,38

Simultaneously, BIPOC communities have consistently struggled to improve equity in the electricity system.
Energy burden and insecurity tend to be highest among Washington’s BIPOC and elderly communities.
People with larger energy burdens have long sought stronger consumer protections, improved community
engagement with respect to price transparency and accountability for how energy is sourced and where
facilities are sited. The intent of these efforts has been to enact policies that limit the catastrophic impact
of electricity disconnections and voltage disruptions on low-income communities, including BIPOC
communities. The TES recognizes these efforts as part of the system within which it must operate.

Transportation electrification, which intertwines the transportation and electricity systems, risks
continuing to entrench financial and mobility inequities in Washington if done without actively
counteracting these preexisting dynamics. For example, a recent survey from Front and Centered and the
NW Energy Coalition found that public EV charging rates in Washington were three to four times higher than
residential EV charging rates. Without purposeful policy intervention, this price differential means that in
the switch from gasoline and diesel fuel to electric charging systems, those who have access to charging
at a residential rate (primarily more affluent single-family home dwellers) will benefit from the savings of

34 American Lung Association, “Urban Air Pollution and Health Inequities: A Workshop Report,” Environmental Health Perspective
109, no. Suppl 3 (June 2001): 357–74.
35 Caitlin Cottrill and Piyushimita Thakuriah, “Evaluating Pedestrian Crashes in Areas with High Low-Income or Minority
Populations,” Accident Analysis & Prevention 42, no. 6 (November 2010): 1718–28.
36 Alexandra K. Murphy, Karina McDonald-Lopez and Alix Gould-Werth, “Transportation Insecurity in the United States: A
Descriptive Portrait,” Socius 8 (September 14, 2022).
37 TES Public Engagement feedback.
38 Front and Centered, “Just Movement Listening Sessions and Survey Findings,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 43
low-cost charging, whereas those who rely on public charging (including people who live in multifamily
housing, renters and high-mileage drivers) will see less in savings. What is more, those who cannot make
the switch in the first half of the transition — by 2035 — may face higher fuel costs and lower ICE vehicle
resale values as gasoline and diesel distributors see less demand and dirty vehicles become less desirable.
Equitable public investment will be required to ensure that all Washington residents can participate in the
transition, access its benefits and have upward mobility.

The TES should advance and support these efforts toward security, safety and sustainability in the
electrified transportation system. It should unite communities rather than divide them; provide
individuals the tools to own, govern and benefit from the energy and transportation assets in their
community; and aim to deliver jobs, community wealth and public health to overburdened communities
throughout Washington.39

To do so concretely, the following framework was developed.

Framework for Equity in Transportation Electrification

The EV Council identified a framework composed of three elements needed to equitably implement the TES:

• Define an equitable distribution process to guide the allocation of electrification funding and resources
to overburdened communities and vulnerable populations.

• Establish a statewide transportation equity baseline upon which the effects of electrification and other
transportation initiatives can be measured and outcomes tracked.

• Create an adaptive management process that Commerce and other state actors can use to “learn and
adapt,” to ensure the TES implementation improves equity outcomes.

Equitable Distribution Process

The TES prioritizes investments the market will not make on its own, targeting strategies and funding for
those who most need them and to whom they would be most beneficial. The federal government and
Washington have set a goal of distributing at least 40% of investments for transportation electrification
to overburdened communities and vulnerable populations. Agencies investing in transportation
electrification should consider the 40% goal as the minimum percentage of investment that will go to these
communities and populations, not the maximum.

The EV Council created a special equity task force — composed of representatives from the Departments
of Commerce, Ecology, Health (DOH), WSDOT and members of the Front and Centered Advisory Panel
— to identify the criteria that will be used for allocating funding to overburdened communities, listed
below. Note that this approach was developed to distribute funding in the short term. The state intends
to continue its work, in alignment with the Environmental Justice Council and HEAL Act agencies, to best
identify overburdened communities. Updated definitions should be developed with community input and
enable the incorporation of qualitative measures.40

39 Greenlining, “Achieving Electrification Equitably: Principles for Building EV Charging Infrastructure For Everyone,”
The Greenlining Institute, (October 20, 2022).
40 For an example of how qualitative feedback might be included, see Colorado Energy Office, Colorado EV Equity Study, (2022).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 44
In the interim, the state will prioritize transportation electrification funding to census tracts that are:

• Ranked 9 and 10 on the DOH’s Environmental Health Disparities Map
• Tribal lands
• In the 80th percentile and above for race and income in the U.S. Environmental Protection Agency’s
(EPA) EJScreen tool41

In addition, the state should consider vulnerable populations for prioritization as required by RCW
70A.02.010,42 including those who are low income, are linguistically isolated, are BIPOC, have disabilities,
work on the frontlines of transportation pollution (including highway workers, commercial drivers and
those who work at refineries and marine and aviation ports) and have been disadvantaged by historical or
institutional racism.

Part of equitable distribution is strategically investing dollars in programs, strategies and sectors that can
address long-standing inequity affecting overburdened and vulnerable communities. This includes:

• Making strategic electrification investments to convert light-, medium- and heavy-duty fleets that
disproportionally operate in or pollute overburdened communities.

• Ensuring electric charging infrastructure is established and maintained in overburdened communities,
especially where there are currently high ratios of people to EV chargers.

• Developing financing approaches that avoid debt traps and predatory lending.
• Electrifying school buses, public transit buses, owner-operated trucks and other vehicles for those who
drive for a living.

• Enabling community economic development through publicly owned charging and support for
community-controlled EV charging and revenue generation, investments in transitions for locally
owned gas stations, public or community-based EV sharing and leasing programs and alternative
career pathways for engine mechanics and other workers/community businesses in the gasoline and
diesel fuel and vehicle industry.

Transportation Equity Baseline

If Washington does not know where inequities exist in the current system, it will be impossible to measure
progress toward relieving them. To assess the impacts of transportation electrification, the state must
develop a baseline index and track its progress across variables on a regular basis.

Based on a literature review and discussions with the equity task force, the following metrics were put
forward as a starting point for the EV Council to gather and centralize ideas. Each EV and EVSE funding
program should evaluate which metrics are relevant for its program for tracking and annual reporting,
supplementing with additional data as appropriate.

41 U.S. Environmental Protection Agency, “EJScreen: Environmental Justice Screening and Mapping Tool,” (n.d.).
42 RCW 70A.02.010 – Environmental Justice – Definitions.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 45
• EV adoption disparities (percent compared with population) broken down by the list of
vulnerable communities included in the above definitions: Over time, the EV adoption disparity
between the general population and vulnerable populations should be reduced as outlined in the HEAL
Act. If the rate of EV adoption remains static or grows larger, then investment allocations, targets and
outreach efforts should be adjusted to ensure the desired equitable outcomes are achieved.

• State dollar allocation (dollars) in overburdened and vulnerable communities as a percentage of
overall funding for transportation electrification: Measure the dollars spent/invested in overburdened
communities to ensure that, at a minimum, the 40% threshold is being reached. If that target is not
being reached, adjust program investments. Also measure the dollars spent/invested in the vulnerable
populations listed above and in those further identified by the EV Council, to the extent data is available.

• Air quality, fine inhalable particulate matter with a diameter less than 2.5 micrometers
(PM2.5 [microgram/m³]), sulfur oxides (SOx), NOx and other applicable criteria and non-criteria
pollutants caused by transportation in overburdened communities: Measure air quality in these
communities to track that the investments being made are having the desired effect of reducing air
pollutants. If air quality is not improving, the state should investigate ways to identify specific vehicles
that travel through these communities and prioritize their electrification.

• Transportation energy burden (percent of income): Commerce tracks the percent of energy-
burdened households (defined as a household that spends more than 6% of its income on energy43),
as required by CETA.44 The EV Council should build on this work to track transportation energy burden,
especially for overburdened communities, which should decrease or stay static as a result of the TES.

• Crash-related injuries (number) by vehicle weight and severity tracked in overburdened
communities and by vulnerable populations: EVs tend to be heavier and quieter, and have faster
acceleration than their ICE equivalents. As the number of EVs increases, it will be important to assess
their effect on the safety of all road users, including pedestrians and cyclists. If crash-related injuries
increase as more EVs are driven on Washington’s roads, the state will need to address the issue by
exploring and enacting different measures. WSDOT should share crash-related data with the EV Council
to monitor this situation.45

• Impact of electrification on transit accessibility: WSDOT’s public transit division data, which is used
to populate the Washington State Transit Access Map,46 can be used to inform the state’s electrification
process. If transit access is worsening in the defined communities, the state will need to ensure that
transit service is not being negatively affected by electrification, and potentially revisit investments in
terms of actual outcomes.

• Transportation security: A biennial statewide Transportation Security Index survey is included in
47

the TES policy recommendations (monitor equity indicators and measure outcomes). Modeled on
the Food Security Index and hosted by the University of Michigan, the Transportation Security Index

43 Washington Utilities and Transportation Commission, “Issue Brief 3: Energy and Equity in Washington State,” (n.d.).
44 Kendrick Stewart, Low-Income Energy Assistance 2023 Legislative Report, Washington State Department of Commerce,
(March 6, 2023).
45 Washington State Department of Transportation, “Crash Data,” (n.d.).
46 Front and Centered, and Center for Neighborhood Technology, “Washington Transit Access Map,” (n.d).
47 University of Michigan, Poverty Solutions, “The Transportation Security Index,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 46
is a 16-question survey (which can be abbreviated to six questions if necessary) that asks respondents
about how their transportation situation affects their daily life. Survey results would help the EV Council
determine if the measures taken are improving people’s overall mobility situation or worsening it.

Adaptive Management Process

The following elements will be critical to the design and implementation of an adaptive management
process that advances equity:

• A structure and process for adjusting transportation electrification strategies to respond to
data trends affecting equity: It will be important for the state to have an iterative and adaptive
approach to the investments and initiatives outlined in the TES. To do this, the state should assess
overburdened communities across the metrics detailed above to establish baselines and measure
their change over time. If the relevant indicators are not moving in the right direction, the EV Council
and EV Council Advisory Committee should revisit each intervention and objective to assess how it
can be adapted. Review of these indicators for each covered program should be a regular part of EV
Council or relevant departmental meetings, and the EV Council should release an annual report with
a summary of this effort.

• A community engagement structure to assist the state in understanding data trends, including
how they play out in particular communities: Due to the magnitude of this transition and the
myriad effects it could have, it will be essential to hear directly from community members and use
their feedback to further evaluate the success of the state’s approach. This is especially important in
overburdened communities where quantitative data may be harder to gather. Qualitative feedback
can be equally important to understanding whether the TES is benefiting those communities, and
tracking the overall perception these communities have toward transportation electrification.

The concrete commitment from the EV Council to an equitable distribution strategy, coupled with the
transportation equity baseline and an effective adaptive management process, are critical to ensuring that
the TES outlines a path that meets the state’s decarbonization targets while also achieving its legislative
mandate of benefiting vulnerable populations and overburdened communities. This framework orients
toward a cleaner, more just transportation and energy future.

A hybrid electric bus sits ready to roll.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 47
Transportation Electrification Justice: In Our Own Voices

Members of the Front and Centered Advisory Panel provided the following quotes and calls to action. Their
contributions helped shape the TES’s recommendations.

Chiyo Crawford, Executive Director, Environmental Coalition of South Seattle (ECOSS):

“The state TES needs to be able to address policy that ensures cost of living will not be impacted by any
changes to building infrastructure, public infrastructure, modes of transportation and utility rates. Public
transit users are often unwilling to support or acknowledge public transportation electrification because of
beliefs that the cost of riding will increase, and routes/services will lessen in their neighborhoods, meaning
it will take more time and money to travel.”

Paul Tabayoyon, Executive Director, Asian Pacific Islander Coalition of Yakima:

“Electrification of transportation comes with many inequities in the rural areas of eastern Washington.
With limited access to property for placement of charging stations in public access spaces and easement
and zoning issues, community members are finding that many new EV chargers are being placed on private
property with limited or no public access.

“Many local governments, city and county, do not have additional staffing to properly analyze where zoning
needs to be changed, or are heavily resistant and continue to permit gas stations, as is the case with Yakima
County. This has the potential to end in abandoned chargers, investors who take money but do not use it
appropriately and the waste of placement of chargers in areas that do not have a need.

“Examination of grant funding needs to be done quickly to ensure that all charging stations installed using
public funds are placed where the general public will have access without worry of ticketing, towing or
additional costs placed upon the consumer by higher charge rates. Without uniformity, EV charging rates
will be different and exceptionally difficult to manage by consumers, creating a negative impact that
prevents EV purchasers.”

Krystal Monteros, Member, Empower Movement Washington:

“People with disabilities face numerous issues when it comes to electric vehicles. One example, for
wheelchair users and possibly those with low vision, is the cords at every charging station. They are
taking up the sidewalk space that was initially meant for people with disabilities to have independence,
accessibility and safety when in public.

“As of now, electric vehicles are silent. This is of major concern for people who are blind and low vision. The
fact that they only make noise when going below 18 miles per hour can put many lives in danger who have
learned to rely fully on sound for independence and safety. Aside from the sound concern, braille needs to
be on every charging station to comply with ADA regulations.

“Many people with disabilities fall in the category of low income. If they are able to afford an electric
vehicle, chances are they will rely on cash only. From the equity and accessibility perspective, it is best to
accept both cash and credit at each charging station.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 48
3. Where Washington Is Today
Washington’s Current Transportation System

Washington’s transportation system – composed of roads, ports, railways, sidewalks, bike lanes, transit
lines, vehicles small and large, and the people who operate and maintain the vehicles and infrastructure
– supports the movements of over 7.7 million people and a $725 billion economy.48 Washington’s
transportation system is also the largest source of climate pollution in the state at 39% of total emissions,
according to Washington’s most recent official GHG inventory (2019). Washington has long been a climate
leader, and recent progress in curbing GHG emissions places it among a small subset of front-running U.S.
states.49 Washington’s leadership in decarbonizing transportation through electrification is critical for
reducing overall emissions and driving market demand and innovation.

Table 7 Washington’s Current Clean Transportation Requirements and Targets
Year Goal(s)

2030 EV Target — 100% of new passenger vehicles sales are electric, per Revised
Code of Washington (RCW) 43.392.020* (non-binding target).
Emissions Limit — Economy-wide GHG emissions down to 50 MMT/year, 45%
below 1990 levels, per RCW 70A.45.020.**
By 2030 30% to 50% of new MHDVs must be zero emissions depending on vehicle class,
per ACT rule.
Carbon-neutral electricity, with a maximum of 20% offsets, per RCW 19.405.040.***

20% reduction in carbon intensity of on-road transportation fuels over 2017
By 2034
levels, per Chapter 173-424 Washington Administrative Code (WAC).****

By 2035 100% of new passenger vehicles must be electric, per ACC II rule.
Economy-wide GHG emissions down to 27 MMT/year, 70% below 1990 levels,
By 2040
per RCW 70A.45.020.

By 2045 Zero emissions electricity, per RCW 19.405.040.

Economy-wide GHG emissions down to 5 MMT/year, 95% below 1990 levels,
By 2050
per RCW 70A.45.020.

* RCW 43.392.020 – Interagency Electric Vehicle Coordinating Council – Target Established – Scoping Plan.
** RCW 70A.45.020 – Limiting Greenhouse Gas Emissions – Greenhouse gas emissions reductions – Reporting
Requirement.
*** RCW 19.405.040 – Washington Clean Energy Transformation Act – Greenhouse gas neutrality – Responsibili-
ties for electric utilities – Energy transformation project criteria – Penalties.
**** Chapter 173-424 WAC – Clean Fuels Program Rule.

48 Woodruff and von Kerczek, “Gross Domestic Product by State and Personal Income by State, 1st Quarter 2023.”
49 RMI, “Washington State Scorecard,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 49
An EV driver uses the control panel to adjust settings.

Washington’s clean transportation requirements and targets (Table 7), along with the state’s existing equity
goals, are intertwined. The pace of progress and degree of success in meeting one goal will affect others.
For example, early and robust decarbonization of the transportation system will make the state’s economy-
wide GHG emissions targets much easier to achieve. And urban design improvements to reduce VMT will
make the electrification transition easier by requiring less infrastructure build-out while providing a better
quality of life for overburdened communities.

Washington has already implemented some of the policies needed to meet these goals and is recognized as
a national leader in the work to electrify transportation. Some examples include:

• In addition to standing up the EV Council and authorizing the TES, the Move Ahead Washington
transportation package makes historic investments in public transportation, state ferry fleet
electrification, active transportation infrastructure and high-speed rail.

• As directed by the Legislature, the Department of Ecology has adopted multiple standards — ACC I and
II and ACT — from the California Air Resources Board (CARB), instead of less clean federal standards, to
drive future emissions reductions.

• Washington has reduced per capita VMT more than any other state since 1990. 50

• In the 2021 state building code, new single-family residences are required to have the electrical
infrastructure needed to support EV chargers, known as EV readiness.

• All three investor-owned utilities (IOUs) and at least seven consumer-owned electric utilities are
currently implementing plans for accelerating transportation electrification.

50 Ridlington, “Less Driving Is Possible.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 50
Modeling for the TES suggests the state’s current transportation policies and programs — ambitious and
critical as they are — will need additional scaling and an increased implementation pace to meet the
state’s electrification, climate, health and equity targets under today’s political and market conditions. To
understand how far the state will have to go to meet its goals, this chapter examines Washington’s current
vehicle stock, vehicle sales, VMT, transportation emissions and EV charging infrastructure.

2022 Total Vehicle Stock

LDVs — cars, crossovers, vans, SUVs and pickup trucks — make up the vast majority of the more than
6.5 million on-road vehicles in Washington today (Figure 7). Although gasoline-fueled LDVs are the vast
majority of vehicles in Washington, according to the EIA, in 2021, 27% of on-road fuel consumption
in Washington was by diesel vehicles, indicating proportionally greater fuel consumption per vehicle
among MHDVs.51

Figure 7 2022 Vehicle Stock by Type
Bus (0.2%) Motorcycle
Heavy-Duty (3.6%)
Truck (0.5%)
Medium-Duty
Truck (1.2%)

Light-Duty
Vehicle (94%)

Sources: Washington State Department of Licensing (DOL), Office of Superintendent for Public Instruction (OSPI),
Transit Agencies

51 U.S. Energy Information Administration, “Washington State Profile and Energy Estimates.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 51
Figure 8 2022 Light-Duty Vehicle Stock by Powertrain
Diesel (1.8%) Battery Electric
(1.4%)

Plug-in Hybrid
(0.4%)

Gasoline (96%)
Source: DOL

2022 New Vehicle Sales
The vast majority of new vehicles sold in Washington in 2022 were powered by gasoline, making up roughly
88% of new LDV sales in the state (Figure 9). Sales data from the first five months of 2023 suggests that
approximately 16% of new LDVs sold in Washington were either BEVs or PHEVs.52 Although this is excellent
progress, Figure 8 shows that BEVs account for only 1.4% of the entire vehicle stock. Compared with the
history of new technology adoption, light-duty EV adoption in Washington is still in the innovation stage,
meaning far more intervention is required to reach the state’s goals.53

Figure 9 2022 New Light-Duty Vehicle Sales by Powertrain
Gasoline Battery Electric Plug-in Hybrid

Plug-in Hybrid 2%
Battery Electric 10%
Gasoline 88%
0% 20% 40% 60% 80%
Source: DOL

52 Ryan, “Electric Vehicle Sales Accelerate in Washington State.”
53 Guru Mirthinti, “Technology Adoption Curve: 5 Stages of Adoption,” Whatfix (blog), (March 16, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 52
In 2022, negligible numbers of new electric MHDVs were sold (not including buses). Approximately 1% and
3% of new motorcycle and bus sales, respectively, were electric.

Vehicle Miles Traveled

Washington’s VMT has grown along with the state’s population, but not to the same degree (Figure 10).
In fact, over the past 25 years, Washington’s VMT per capita has declined more than that of any other U.S.
state (Figure 11), likely due to Washington’s long-standing policies on commuting and working from home,
investments in transit and improvements to walking and biking infrastructure.54 WSDOT released a report in
the summer of 2023 that outlines a process for establishing local VMT targets and recommends policy and
funding options for local jurisdictions to employ in meeting the targets.55 The majority of VMT driven in the
state comes from LDVs (Figure 12).

Figure 10 Washington Total Vehicle Miles Traveled, 1980–2021
60 Total
VMT
50 (billions)
40
30
20
10
0
1980 1985 1990 1995 2000 2005 2010 2015 2020
Source: WSDOT

Figure 11 Vehicle Miles Traveled per Capita, 1980–2021

9,000
8,000
Annual
7,000 VMT per
6,000 capita
5,000
4,000
3,000
2,000
1,000
0
1980 1985 1990 1995 2000 2005 2010 2015 2020
Source: WSDOT

54 Ridlington, “Less Driving Is Possible.”
55 Millar and Pen, “Vehicle Miles Traveled (VMT) Targets — Final Report.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 53
Figure 12 2022 Vehicle Miles Traveled by Vehicle Class
Bus (0.2%) Motorcycle (0.2%)
Heavy-Duty
Truck (6%)

Medium-Duty
Truck (3.9%)

Light-Duty
Source: WSDOT Vehicle (90%)

Transportation Emissions, All Vehicles

In 2020, Washington updated its GHG emissions limits and set a binding target for itself to reduce
economy-wide emissions to 50 MMT CO2e by 2030. As the state’s largest emitting sector (39% in 2019), the
transportation sector will need to play a central role in the state’s meeting its 2030 emissions target, and
subsequently its 2040 and 2050 emissions targets.

The 2021 SES found that Washington’s transportation sector must decline from roughly 38 MMT CO2e in
2022 (Figure 13) to 20 MMT CO2e or lower by 2030 to support the state’s economy-wide climate goals. Based
on the latest inventory, on-road GHG emissions make up approximately 58% of the state’s transportation
sector emissions, suggesting this subsector would contribute 11.6 MMT CO2e in 2030 if this percentage stays
the same. However, it is highly likely that annual on-road emissions in 2030 must be less than 10 MMT CO2e
to make up for harder-to-decarbonize sectors and subsectors, including non-road transportation, industrial
processes and commercial and industrial buildings.

Figure 13 Washington Transportation GHG Emissions, 1990–2022
40 Transportation
GHGs (MMT CO2e)
30

0
1990 1995 2000 2005 2010 2015 2019
Source: Ecology

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 54
EV Charging Infrastructure

According to the U.S. Department of Energy’s Alternative Fuel Data Center, Washington has 1,064 DCFCs at
280 locations, and 4,275 publicly accessible L2 EV chargers at 1,832 locations (Figure 14).56 Although EVs
can be charged using common 120 volt outlets, the slow speed of charging at those outlets can make it
an impractical option for certain situations and use cases. Faster charging using higher voltages requires
specialized infrastructure. As more EVs are deployed, more specialized charging infrastructure will have
to be built, as will supporting grid infrastructure such as demand-side management technologies; new
generation, transmission and distribution; and upgraded building panels.

Figure 14 Map of EV Charging Stations in Washington

Source: U.S. Department of Energy Alternative Fuel Data Center

Washington Residents’ Perceptions about Transportation Electrification

For Washington to successfully meet its goals, it is essential to understand not only the transportation sector
but also the barriers state residents face (or perceive they face) in the transition to electric transportation
systems. As part of the TES public engagement process, the consulting team interviewed a diverse group
of Washingtonians on the kinds of barriers that exist for transportation electrification, with a focus on
overburdened communities and vulnerable populations. The sample sentiments in Table 8 broadly reflect
interview findings. The full list of organizations and individuals interviewed can be found in Appendix B.

56 U.S. Department of Energy — Energy Efficiency & Renewable Energy, “Electric Vehicle Charging Station
Locations,” accessed December 18, 2023.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 55
Table 8 Sample Barriers to Transportation Electrification from Interviews

Barrier Samples from Public Outreach Interviews

There is a lack of publicly available charging infrastructure and charging
infrastructure for multifamily housing. It is expensive to install charging
Public Charger Availability infrastructure. The current lack of regulations or standards for charging
and Accessibility infrastructure makes charging stations difficult to use, unreliable and
unpredictable. Charging stations vary in cost, access and charging speed.

The high up-front cost for EVs — including e-bikes, personal cars and MHDVs —
Cost to Purchase EVs is a large barrier for many, particularly low-income communities and small
businesses.

Supportive Policies and Incentives and grants for EVs are fragmented, are incompatible with each other,
Funding at Local, State and have regulatory limits. Applications can be difficult to navigate, and existing
and National Levels incentives are not sufficient to make EVs affordable, especially for MHDVs.

There is a current lack of awareness about electrification. The state needs to
Public Understanding
and Excitement educate, inform and solicit feedback from community members, understanding
that many communities have other pressing priorities.

The state’s electrical grid needs to be updated to support the widespread and
Demand on Power Grid rapid deployment of EV infrastructure. EVs will increase overall electricity
and Increasing demand, which requires new generation, transmission and distribution resources
Renewable Generation to be quickly built. Coordination among utilities and EVSE/charging companies
needs to be dramatically improved. Without coordination, interconnection times
may increase, significantly delaying EVSE installations.

Communities of color and low-income communities often live closest to
Inequities for Overburdened transportation corridors and industrial facilities and are overburdened by the
Communities in the health impacts of noise pollution and poor air quality. But people living in
Electrification Transition overburdened communities do not feel included in decision-making and policy
prioritization within the electrification conversation.

Change Is Possible, but More Support Is Needed

Understanding the current state of Washington’s transportation system through data and interviews allows
for the state to chart a course for meeting its ambitious goals. Although the transportation electrification
transition has begun, reaching Washington’s near-term and long-term goals will require new policies and
programs to support electrification, drive market demand and inspire change.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 56
4. Where Washington
Needs to Go
Policy Context and Key Analytical Findings

Policy Context

In recent years, Washington has adopted strong policies that support on-road vehicle electrification. Paired
with revamped federal incentives that help reduce EV costs, these policies form the TES’s backdrop.

For new LDVs, the ACC I and ACC II regulation puts in place progressively stringent ZEV sales share
requirements, culminating in a 100% sales requirement by 2035. For new MHDVs, the ACT regulation also
requires increasing sales shares, albeit at considerably lower levels (40%–75% ZEV sales share required
by 2035, depending on vehicle weight class) (Figure 15). At the federal level, the IRA provides significant
incentives that help reduce the up-front cost of ZEVs and supporting infrastructure through restructured,
expanded and extended tax credits.57

Figure 15 Sales Requirements for New Zero-Emissions Vehicles by Model Year

100% Light-Duty
Vehicles

80%
Class 4-8 Trucks

60%
Class 2b-3 Pickup
Trucks and Vans

40% Class 7-8 Tractor
Trucks

20%

0%
2026 2028 2030 2032 2034

57 For example, the Clean Vehicle Credit, Commercial Clean Vehicle Credit and Alternative Fuel Vehicle Refueling Property Credit.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 57
This policy baseline — and especially the ACC II rule — plays a critical role in setting Washington on a path
toward increasing sales of new EVs. If the state had not adopted ACC II, light-duty EV adoption based on
economics alone would be unlikely to result in the state realizing adoption rates needed to meet either the
2035 or the accelerated 2030 EV target of 100% electric LDV sales. This indicates a clear need for additional
policy support to ensure these targets can be attained — and attained equitably. For MHDVs, ACT plays a
role in spurring vehicle electrification, although its considerably less stringent sales share requirements
lessen its impact compared with the influence of ACC II on LDV sales.

The ACF regulation — a companion policy adopted in California that imposes purchase requirements
on certain fleets of MHD trucks — has significant potential to bolster ACT and spur considerable truck
electrification, should the state adopt it or a similar regulation.

Key Analytical Findings

The modeling conducted for the TES demonstrates the wide variety of potential outcomes that might
be expected based on different assumptions about future economic, policy and consumer preferences.
Several clear themes emerge from this modeling, which help inform the policy recommendations and
implementation guidance detailed in subsequent sections of this strategy.

1. The state’s adoption of ACC II is a critical component of transitioning to an EV future. The strong
and essential effect of ACC II is clear in all but the most optimistic exploratory scenarios. However,
achieving the regulation’s sales requirements will necessitate additional policies and incentives to
undergird the policy’s top-line requirements, such as infrastructure build-out, consumer education
and reduced purchase price. Absent further intervention and policy support, economics-based
adoption of EVs is unlikely to enable the state to attain the ACC II’s requirement that light-duty ZEV
sales account for 100% of new LDV sales by 2035, nor the accelerated goal of reaching this milestone
by 2030. Based on anticipated economics alone, the state can expect sales of electric and plug-in
hybrid electric LDVs to represent only approximately 59% of new LDV sales in 2030 — far short of the
68% required under ACC II and the 100% required under the 2030 EV target.

2. The ACF regulation is one of the most powerful levers available to the state for accelerating MHD
truck electrification (Figure 16). By limiting usable lifetimes and setting purchase requirements for
specific market segments, ACF ensures that high-impact, electrifiable fleets replace their vehicles.
This purchase requirement creates significant demand for the vehicle supply produced under ACT.
Further, given that drayage trucks, state and local vehicles, and high-priority fleets — targeted under
ACF — comprise a significant number of vehicles (estimated at approximately 40% of total MHD
trucks in Washington in 2023), this regulation is uniquely positioned to encourage MHD electrification
broadly if adopted.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 58
Figure 16 Zero-Emissions Medium- and Heavy-Duty Truck Population
Under ACT and ACF
Strong
50,000 Electrification
Policy Scenario
(ACT + ACF)
40,000
Baseline
Scenario (ACT)

30,000

20,000

Additional Zero-
10,000 Emissions
Trucks Under
ACF
0
2023 2025 2027 2029 2031 2033 2035

Note: The S3 Strong Electrification Policy scenario (upper sales share line in chart) includes incentives for MHD truck
electrification in addition to those in the ACF regulation.

3. Ensuring EV purchase prices are affordable is a key strategy for getting closer to sales and
emissions goals, especially for lower-income residents. Focusing on reducing costs in the near term
drives higher adoption rates before the ACC II sales requirements begin to take effect in model year
2026. This supports faster electrification and thereby larger retirements of polluting ICE vehicles.
Electric sedans and crossovers have sufficiently strong economics in most years to meet ACC II sales
requirements. Pickups and SUVs, in contrast, are likely to require more significant support beginning
in 2026 as ACC II requirements ramp up. However, providing higher levels of incentives directly to all
potential buyers of larger LDVs is neither feasible nor advisable. This reiterates the importance of
ensuring that incentives are targeted to have maximum effect for minimum public cost, as well as
capturing the financial and climate benefits of prioritizing and promoting sales of smaller vehicles to
the extent possible.

4. Supporting transportation options for people with lower incomes will be essential for attaining
state goals for electrification, climate and equity. The TES modeling did not explore the influence
of socioeconomic or demographic factors on EV adoption. Accordingly, the assessment of how
technology costs and policy incentives influence an individual’s vehicle purchase or lease decisions
does not distinguish between residents who are more or less able to afford EVs. The state will need
to ensure that sufficient incentives, charging infrastructure, education and outreach are provided to
those least able to help make the necessary EV adoption levels from the modeling a reality.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 59
5. Truck electrification is increasingly economical on a TCO basis, due in large part to the incentives
provided through the federal IRA. Although up-front costs can still represent a barrier, lifetime cost
savings present opportunities to scale up electrification of these vehicles, beyond the levels required
in the ACT regulation. To ensure truck electrification can drive maximum impact and scale up rapidly,
Washington should focus on vehicles with strong potential to reduce local air pollution, removing
bottlenecks such as vehicle availability constraints and delays in deploying EVSE and providing
education and technical assistance to fleet managers.

6. The pace of installing charging infrastructure for LDVs and MHDVs needs to accelerate
significantly, indicating a clear role for supportive policies. In 2035 Washington will require more than
20 times more EV charging plugs than the TES model suggests is needed today.

7. Ensuring availability of home (or neighborhood) charging for multifamily homes meaningfully
reduces total public charging network requirements, providing both cost savings and equity
benefits. Figure 17 depicts the estimated number of residential charging ports for both single-
family and multifamily dwellings required to support electric LDVs in the S3 Strong Electrification
Policy scenario, totaling more than 2.9 million by 2035. Supplementing direct on-site charging with
neighborhood charging options in close proximity to multifamily homes will be an important strategy
for providing this level of access for residents of multiunit dwellings.

Figure 17 Cumulative Residential Charging Ports Required,
S3 Strong Electrification Policy Scenario
Single-Family Home, L2 Charging Ports Multifamily Home, L2 Charging Ports

2035 2.4M 565.5K

2034 2.1M 468.6K

2033 1.8M 384.3K

2032 1.6M 309.5K

2031 1.3M

2030 1.1M

2029 869.4K

2028 684.1K

2027 523.2K

2026 386.4K

2025 281.5K

2024

2023

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 60
8. Reducing VMT and total vehicle stock, while shifting new sales to lighter-weight vehicles, has
significant potential for reducing GHG and local air pollutant emissions, as well as total costs.
However, the deep societal and behavioral changes required to realize the optimistic level of these
efficiency changes included in two of the three exploratory scenarios (S4 Strong VMT Policy and
S6 Best Case Climate Aligned, but not the S5 Worst Case scenario) indicate that, although these
strategies would be helpful for meeting state goals, they should be considered supplementary to
rather than replacements for meaningful focus on transportation electrification because they are
unlikely to occur. These exploratory scenarios assume the state achieves 5,700 LDV VMT per capita
in 2035, whereas the core scenarios (S1 Baseline, S2 Strong Electrification Technology, S3 Strong
Electrification Policy) assume 6,400 LDV VMT per capita in that year.

9. Bus electrification requires continued policy support to increase market share. This support
is needed from the state and local level, as well as through flexible federal funding and continued
dedicated federal funding such as the Low or No Emissions grant and the Clean School Bus program.
The S3 Strong Electrification Policy scenario estimates approximately 8,800 battery electric school
buses and 3,500 battery or fuel cell electric transit buses on Washington’s roads by 2035, respectively
representing 66% and 56% of the state’s projected total school and transit bus fleet in that year. This
represents a significant increase in electrification over today’s estimated 1% and 14% electric school
and transit bus fleets in Washington.

10. Hydrogen FCEVs are likely to eventually play a role in HD truck and transit bus electrification. The
market share these vehicles will obtain remains unclear, but at present battery electric alternatives
appear likely to be the primary technology for many applications and duty cycles — especially for
LDVs — based on TCO analysis. As both the state’s hydrogen economy and FCEV technology mature
through 2035, the role played by these vehicles will become increasingly clear. The state should
continue to monitor and track the development of FCEV technology and costs, and over time consider
how these vehicles can contribute to meeting transportation sector emissions reduction targets. Per
RCW 43.330.570,58 the Department of Commerce’s Office of Hydrogen and Renewable Fuels delivered
a Hydrogen and Renewable Fuels 2023 Legislative Report to the Legislature in December 2023, which
should inform this assessment. Additional analysis on FCEV cost outlooks is included in Appendix D.

11. Washington will need to take other actions for non-road vehicles, such as aircraft, watercraft and
locomotives, to accelerate their electrification and emissions reduction. Although not a part of this
modeling effort, planning and policy measures for addressing non-road vehicles, which represent
approximately 42% of the state’s transportation emissions, will be vital for meeting emissions targets.

Recommendation: Focus Efforts on Achieving the S3 Strong
Electrification Policy Scenario
The state will need to focus on the levers it most readily has available to promote transportation
electrification, equity and alignment with climate goals. Accordingly, focusing on the S3 Strong
Electrification Policy scenario described in further detail throughout this chapter, while striving for the
S3b sensitivity that explores attaining the 2030 EV target of 100% electric LDV sales, is likely to provide the
best combination of attainable policy options and feasible programs to implement. The state has the most
control over the factors that shape that scenario given its emphasis on policy, whereas it does not have

58 RCW 43.330.570 – Office of renewable fuels – Duties.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 61
direct control over some other factors modeled in other scenarios, such as the pace of improvements in EV
technology (S2 Strong Electrification Technology) or global fossil fuel prices (sensitivities d and e).

As shown in Figure 18, the S3 Strong Electrification Policy scenario projects on-road transportation
emissions in Washington to decrease to approximately 13.9 MMT CO2e by 2030, and to 8.8 MMT CO2e by
2035, due in large part to supporting successful implementation of existing state and federal policies,
including the ACC II and ACT regulations. Achieving the 2030 EV target provides a further 300,000 metric ton
reduction in 2030 emissions. These S3 emissions figures represent a large improvement over the S5a Worst
Case scenario where ACC II and ACT are not met (16.8 and 13.9 MMT in 2030 and 2035, respectively).

However, a significant gap remains between anticipated 2030 emissions under the S3 Strong Electrification
Policy scenario and the approximate threshold of 10 MMT CO2e the EV Council uses in this report for
achieving the state’s 2030 emissions limit for on-road transportation. Accordingly, targeting some of
the strategies embedded within the exploratory S4 Strong VMT Policy and S6 Best Case Climate Aligned
scenarios can help further close this gap, even if reaching the full levels of complementary VMT reduction
and vehicle stock changes included in those modeling runs is limited in feasibility (for example, land use
policies would have to be enacted and implemented fast enough to affect 2030 emissions) or are largely
outside the state’s control (for example, requiring lighter vehicles to be sold).

Figure 18 On-Road Transportation Sector GHG Emissions, Select Scenarios
(MMT CO2e)

18
S5a Worst Case
16 without ACC II or ACT
S2 Strong
Electrification
14 Technology
S3 Strong
Electrification Policy
12
S1 Baseline

10 S3b Strong Electrification
Policy with 2030 Target Met
8
S4c Strong VMT
S6b Best Case with
6 Policy
2030 Target Met

0
2023 2025 2027 2029 2031 2033 2035

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 62
Key Components of the S3 Strong Electrification Policy Scenario

Relative to the S1 Baseline scenario, the S3 Strong Electrification Policy scenario includes larger state
and federal incentives for ZEVs and charging infrastructure, assumes stronger consumer interest in ZEVs,
and assumes the ACF rule or a similar policy is adopted, requiring considerably faster adoption of zero-
emissions trucks by fleets subject to this regulation (drayage trucks as well as “high-priority” and public
fleets).59 Sensitivity S3b — in which the 2030 LDV sales goal is met — does not include specific additional
policies or incentives beyond the core S3 Strong Electrification Policy scenario, but rather assumes that the
ACC II LDV sales trajectory increases substantially from 2027 through 2030 to reach the accelerated goal.

For the state to align EV sales trajectories with the S3 Strong Electrification Policy scenario or the S3b
sensitivity (where the 2030 LDV sales target is met), several key actions will be required.60

1. Providing enhanced state incentives for ZEVs and EV charging infrastructure. Examples include
extending and simplifying the EV sales tax credit through 2035, rather than through 2025 (baseline
expiration year); providing a larger incentive value (e.g., $5,000) in the Alternative Fuel Vehicle
Incentive administered by the Department of Commerce, with a particular focus on overburdened
communities and vulnerable populations;61 increasing hydrogen subsidies provided through the
Department of Ecology’s CFS through 2035; and working with electric utilities to provide higher EVSE
incentives for residential and commercial customers (e.g., $800 per residential EVSE through 2035
versus $400 through 2028 in the baseline). The following section provides additional context on what
levels of funding may be required for different vehicle segments.

2. Ensuring that federal incentives are used to the greatest extent possible. One example is
promoting the availability of the Clean Vehicle Credit and Commercial Clean Vehicle Credit so
that more EV sales in the state are subsidized primarily by the federal government (e.g., S3 Strong
Electrification Policy assumes an average credit of 75% of the maximum $7,500 for LDVs, whereas the
S1 Baseline scenario assumes an average credit of 50%). Another example is promoting adherence
to the requirements for full rather than partial compliance with the Alternative Fuel Refueling
Property Credit, such as meeting prevailing wage requirements. The state should continue to monitor
applicable federal programs and share information widely to support effective utilization of federal
incentives.

3. Achieving ACF adoption rates to complement the existing ACT regulation. Having adopted
California’s motor vehicle emissions standards under Section 177 of the Clean Air Act, Washington
may have the ability to adopt and implement the ACF rule or a policy that creates ACF-like adoption
rates, in addition to ACT. The Department of Ecology is currently monitoring California’s actions to
finalize ACF given its existing mandate from the Legislature. As highlighted earlier in this section, the
accelerated purchase requirements for MHD vehicles in ACF have a meaningful impact on electric
and FCEV truck adoption in the state because these requirements are applicable to an estimated
40% of the state’s MHD vehicles. The EV Council anticipates ACF to provide commensurate levels of
incremental GHG and local air pollutant emissions reductions, beyond those associated with ACT.

59 The ACF regulation defines high-priority fleets as fleets with more than 50 trucks or belonging to private companies that make
more than $50 million in annual revenue.
60 Please see Appendix D for additional details on scenario assumptions, including policy and incentive differences between
Scenarios 1 and 3.
61 The S3 Strong Electrification Policy scenario assumes this incentive provides an additional $2,000 per vehicle, relative to the S1
Baseline scenario.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 63
4. Conducting education and awareness campaigns to promote the benefits of EVs, available EV
programs and increasing affordability of EVs. The S3 Strong Electrification Policy scenario and the
S3b sensitivity, which meets the 2030 electric LDV sales goal, assume stronger consumer interest in
EVs as a proxy for effective messaging and education about the benefits of these vehicles.62 To make
this assumption a reality, the state can invest in meaningful education and engagement activities,
beginning with the Education Plan and Engagement Plan developed for the TES.

To achieve the 100% electric LDV sales goal, the state will need to invest significantly in the policy areas
highlighted above, going beyond the support levels assumed in the core S3 Strong Electrification Policy
scenario to enable the accelerated sales trajectory from 2027 to 2030. The state would also likely have
to consider additional policies that discourage the sale of new ICE LDVs in the late 2020s to complement
additional support for EVs. Realistically, achieving the 100% electric LDV sales goal will also involve favorable
conditions outside of the state’s control, such as the price of EV technology, federal policy, automaker
decision-making, supply chains and rapid and deep shifts in consumer preferences across the population.

In addition to these key policies, the state should consider the strategies embedded within exploratory
scenarios S4 Strong VMT Policy and S6 Best Case Climate Aligned, which rely heavily on VMT reduction and
vehicle stock change assumptions to achieve lower emissions rates. Both the policy categories described
above for the S3 Strong Electrification Policy scenario and the VMT reduction levers within the exploratory
scenarios are discussed in further detail in Chapter 5.

2030 EV Target Scoping Plan – Scenario 3b

RCW 43.392.020 63 requires the EV Council to complete a scoping plan for achieving the 2030 EV target. The
EV Council decided to complete this analysis within the TES, and it is embedded throughout this report. As
one might imagine, the actions needed to achieve 100% new light-duty EV sales by 2030 are also needed to
achieve the 68% sales share projected by 2030 in the S3 Strong Electrification Policy scenario. Therefore,
the policy recommendations in Chapter 5 should be considered key elements of the required scoping plan.

This divide raises the question: How could the state go from reaching 68% to 100% EV market share in
2030? The TES model uses a sensitivity analysis to assess the difference between these versions of the
future. For the preferred S3 Strong Electrification Policy scenario, that sensitivity analysis is labeled S3b
throughout the TES.

In addition to the recommended S3 Strong Electrification Policy approach detailed throughout the rest of
this report, S3b would require:

• Rebates in 2030 amounting to at least $9,000 per sedan and $11,000 per light truck or SUV above the
incentives required to reach the ACC II’s sales goal.64

62 Stronger consumer interest is embedded by adjusting the parameters that determine the shape of the adoption S-curve,
effectively making modeled consumers and businesses more responsive to TCO.
63 RCW 43.392.020 – Interagency Electric Vehicle Coordinating Council – Target established – Scoping plan.
64 These estimated incentive levels are based on reaching approximately 95% electric LDV sales share in 2030, beyond which
modeled incentive values become exceedingly large. This is due to the S-curve modeling framework, which assumes that
achieving the final percentage sales (e.g., the last 5%) require exponentially increasing monetary incentives as a way of
conveying that the “last few” consumers put a very high value on buying an ICE vehicle.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 64
• Approximately 185,000 additional
charging ports by 2030 at an additional
expense ranging from $200 million to
$520 million.65

• Voluntary discontinuation of non-
electric LDV production and sales by all
automakers and dealers.

The TES model uses an S-curve to
represent the projected shape of EV
adoption. Sales start slowly at first before
overall cost parity is reached, with only
early adopters purchasing EVs. Then,
as cost parity is reached and exceeded,
adoption accelerates rapidly. However,
an S-curve is symmetrical. When it comes
to getting the last 5% or so of adoption,
the pace slows down significantly, and
incremental sales require increasingly
higher consumer benefits to reach near
100% adoption. The required incentive
value therefore increases exponentially
as EV sales get closer to 100%, which
reflects the reality that for the small tail of
last adopters, there really is no price that
would make them want to adopt an EV if a A worker digs a trench for EV charging infrastructure at a Jefferson
gasoline or diesel alternative still exists. Transit Authority station in Jefferson County.

The model therefore finds that the rebate amount needed to reach 100% new light-duty EV sales would be
more than the price of the vehicle itself — clearly an unsustainable level of public funding. This highlights
the importance of targeting incentives to influence incremental sales most cost-effectively. Providing
exceedingly large incentives for each and every vehicle — including to individuals who do not require that
level of monetary support — would be well beyond cost prohibitive for the state.

Because S3b would require an exponential cost for each additional EV sale, would depend on factors
largely outside the state’s control (e.g., fossil fuel prices, automaker and dealership voluntary decision-
making) and would result in a relatively modest 0.3 MMT decline in 2030 emissions compared with S3, the
EV Council selected the more feasible and still very strong electrification pathway in S3 as the preferred
scenario to use as the TES foundation.

Recognizing the importance of bold targets to drive urgency in climate action, the EV Council and its
member agencies will continue to pursue the 2030 EV target set by the Legislature as an aspirational stretch
goal, and also urge state policymakers to consider the cost per metric ton CO2e avoided when weighing
different program investments to stay under the 2030 emissions limit.

65 Cost range due to low and high EVSE and installation unit cost estimates, from the National Renewable Energy Laboratory,
2023.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 65
Analysis Conducted to Support the TES

Modeling Overview

To explore how on-road EV adoption and charging needs in Washington may progress over time, RMI
developed a two-stage modeling approach (Figure 19). The first stage uses a vehicle stock rollover model,
which assesses potential EV adoption from 2023 through 2035, by vehicle segment and by county, using
a combination of bottom-up economic analysis based on estimated TCO for different powertrains, and
top-down policy requirements such as the ACC II and ACT regulations. The second stage of the modeling
assesses anticipated EV charging needs, using the number of EVs estimated through the stock rollover
model combined with local trip data or average daily VMT.

Figure 19 Two-Stage Modeling Approach

• Vehicle stock rollover model
Stage 1 • Explores various policy and economic scenarios and sensitivities
EV Adoption

• Estimates EVSE required to charge given number of EVs
Stage 2 • Explores required home, workplace, depot and public charging needs
EV Charging Needs

The Future Is Uncertain – Different Scenarios Explore Potential Outcomes

EV adoption and associated charging needs in Washington will depend on a variety of factors, including
market dynamics, such as the cost of EVs and charging infrastructure relative to conventional vehicles;
public policy choices, including EV incentives and requirements, support for deployment of EV charging
stations and the prioritization of public transit; and consumer preferences, among other influences.

To explore a wide range of potential EV adoption outcomes, RMI considered six scenarios with varied
assumptions about market and economic factors, policy support and consumer preferences, as well
as several sensitivities applied to one or more of the modeled scenarios. Table 9 provides an overview
of the modeled scenarios. Three are core scenarios of interest (S1, S2 and S3), whereas three are
exploratory scenarios (S4, S5 and S6) that are less probable, but nevertheless helpful for understanding
the potential range of outcomes should certain dynamics (e.g., VMT reduction) occur more or less rapidly
than anticipated.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 66
Table 9 Scenarios Modeled
Characteristics
Type # Scenario Key Questions Explored
(Relative to Baseline)

What might EV adoption
look like under current
Core 1 Baseline N/A policy and middle-of-
the-road outlooks on
cost trajectories?

How much greater
External technological shifts electrification and lower
Strong
work in Washington’s favor, costs would Washington
Core 2 Electrification
including lower ZEV, EVSE, get if technology
Technology
electricity and hydrogen costs. develops faster than
expected?

Washington enacts additional
policy to support eletrification
such as higher incentives for How much greater
Strong ZEVs and EVSE, inclusion of electrification and lower
Core 3 Electrification the ACF rule’s adoption rates costs would Washington
Policy and education and outreach get with more
to encourage strong consumer supportive policies?
interest in ZEVs.

Washington enacts policy to How much greater
reduce per capita VMT more adoption, lower costs
than is currently legislated. and additional social
Strong
Exploratory 4 Policies also encourage less car benefits would
VMT
ownership and a shift to more Washington get with
Policy
efficient, lighter vehicles (e.g., successful VMT-limiting
more sedans). policies and actions?

Combination of factors that
would together constitute the What is the worst case
worst case, such as higher ZEV for electrification and
Exploratory 5 Worst Case costs, lack of electrification costs if the technology
policy and lack of VMT policy and policy environments
(i.e., inverse inputs from those are unfavorable?
used for Scenarios 2, 3 and 4).

Achieves the most on-road
What is the best case for
emissions reduction through
electrification and costs
Best Case an optimistic combination of
if all input variables
Exploratory 6 Climate external factors (from
support greater EV
Aligned Scenario 2) and policy
adoption and VMT
implementation (from
reduction?
Scenarios 3 and 4).

Exploring key sensitivities helps identify the effect of different policy and economic factors embedded in
the scenarios described above. Table 10 provides an overview of the five different sensitivities tested, two
of which (“major”) were applied to all six of the scenarios and three of which (“minor”) were applied to a
subset of scenarios.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 67
Table 10 Sensitivities Tested
Scenarios
Type # Sensitivity Applied To Key Questions Explored

How much do ACC II and ACT influence
outcomes? What might EV adoption
Remove Effects look like without the top-down
Major a of Policy 1–6 influence of those policies, and what
Requirements does that suggest about additional
policies that may be required to
support these regulations?

How close does each modeled
2030 LDV Sales scenario get to the 2030 target? What
Major b 1–6
Target Met supportive policies may be required to
enable this goal?

VMT Reduction What benefits are achieved by
Minor c without Stock or 4 reducing VMT but not reducing vehicle
Freight Change size and fleet size?

High Fossil Fuel How do relatively high petroleum
Minor d 1, 2
Prices prices affect outcomes?

Low Fossil Fuel How do relatively low petroleum
Minor e 1, 2
Prices prices affect outcomes?

Comparing across and between these scenarios and sensitivities allows for an estimation of how
Washington’s transportation sector may evolve over time under different combinations of economic and
policy influences. Sensitivities further enable isolation of the effect that different factors may have on EV
adoption over time.

These scenarios and sensitivities suggest which levers the state (and other stakeholders) might prioritize
to ensure equitable and efficient attainment of transportation electrification goals. Some aspects of the
scenarios and their sensitivities, such as EV technology progress, fossil fuel prices and ACC II or ACT being
struck down in federal court, are beyond the state’s control. Yet other aspects of the scenarios and their
sensitivities, such as electrification policy and approaches to VMT reduction, are within Washington’s control.

Scenario Output Comparison

Combining the scenarios and sensitivities results in 23 distinct sets of outputs, including EV and PHEV
adoption by vehicle segment, EVSE needs by vehicle segment and location type, and GHG emissions and
local air pollutants.

The remainder of this chapter provides an overview of how these outputs vary across scenarios and
sensitivities, as well as a discussion of the primary drivers of this variation and the implications for the policy
recommendations and implementation guidance detailed in subsequent chapters of the TES, including
considerations related to state control (or lack thereof) over certain dynamics explored in the modeling.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 68
Outputs from all modeled scenarios and sensitivities are available in more detail (e.g., by vehicle
subsegment) on the Washington TES User-Interactive Dashboard.66

Light-Duty Vehicle Outputs

Light-Duty Vehicle Sales

No modeled scenario reaches 100% electric LDV sales by 2030 or 2035 based on economics alone,
highlighting the key role of policy support in attaining this level of EV uptake. Figure 20 shows anticipated
LDV sales share by powertrain for the S1 Baseline scenario with and without the influence of the ACC II
regulation, indicating both that the 2030 goal is unlikely to be met without substantial additional support
and that ACC II bolsters the ZEV sales share significantly more than expected based on economics alone.67

Figure 20 Estimated Light-duty Vehicle Sales, ACC II and Economics Alone
EV PHEV ICE-Gasoline

LDV Sales Share Under ACC II LDV Sales Based on Economics Alone
100% 100%

80% 80%
2030: 68% 2030: 59%
ZEV Sales ZEV Sales
60% 60%

40% 40%

20% 20%

0% 0%
2023 2025 2030 2035 2023 2025 2030 2035

Note: The dip in EV sales share in the right-hand chart beginning in 2033 is due to anticipated expiration of federal tax credits extended and
modified by the Inflation Reduction Act.

Other scenarios help close the gap between the economics-based adoption in the S1 Baseline scenario and
the 2030 target and 2035 requirement of 100% electric LDV sales. When viewed without the influence of ACC
II to isolate scenario impacts (Figure 21), the most impactful scenarios include S2a Strong Electrification
Technology and S6a Best Case Climate Aligned, which increase economics-based EV sales share in 2030 by

66 Washington TES User-Interactive Dashboard, found on the TES website.
67 RMI initially included FCEVs as an option in the LDV analysis. However, the consistently and significantly higher costs of these
vehicles on a TCO basis resulted in insignificant levels of light-duty FCEVs across all scenarios modeled. To simplify the LDV
analysis, FCEVs were therefore removed; they remain present in the HD vehicle results described in the following section. TCO
comparisons between battery electric, plug-in hybrid electric, fuel cell electric, and conventional ICE vehicles are shown in
Appendix D.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 69
8 and 11 percentage points, respectively, relative to the S1a Baseline scenario (59% sales share), and by 10
percentage points in 2035. The S3a Strong Electrification Policy also increases sales shares relative to the
baseline, albeit to a smaller extent (2 and 1 percentage points in 2030 and 2035, respectively), indicating
that the level of incentives embedded in that scenario have a smaller impact on reducing EV TCO than the
cost declines embedded in S2a Strong Electrification Technology. However, increasing the magnitude of
incentives included in S3a to levels commensurate with the assumed cost declines in S2a would equalize
the effect of these two scenarios.

Figure 21 Light-Duty Vehicle Sales Share, BEV + PHEV
(Baseline, 2030 Target Met and Economics-Based Adoption)
100% S1b Baseline with
2030 Target Met

90% S1 Baseline

80% S6a Best Case Climate
Aligned without ACC II

70% S2a Strong Electrification Technology
without ACC II
60%

50%
S1a Baseline
without ACC II S3a Strong Electrification
40% Policy without ACC II

30% S5a Worst Case
S4a Strong VMT Policy
20% without ACC II

10%

0%
2024 2026 2028 2030 2032 2034

Light-Duty Electric Vehicle Stock Growth

The total population of EVs, including BEVs and PHEVs, in Washington by 2035 varies significantly across
scenarios, as shown in Figure 22. The scenarios that result in the largest number of EVs by 2035 are S2b
Strong Electrification Technology with the 2030 LDV target met, and S3b Strong Electrification Policy with
the 2030 LDV target met (with ~3.8 million and ~3.7 million EVs, respectively). Both scenarios build on the
ACC II regulation by assuming EV sales must increase to 100% by 2030, which drives a greater number of EVs
into the vehicle stock by 2035.

It is worth noting that the exploratory S4 Strong VMT Policy and S6 Best Case Climate Aligned scenarios result
in lower total numbers of light-duty EVs primarily because they assume an overall reduced vehicle stock.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 70
Of the scenarios that do not assume vehicle stock reductions, S5a Worst Case without the Effect of ACC
II results in the lowest number of light-duty EVs in Washington by 2035 (~2.3 million EVs). This result
highlights both the important effect ACC II has on supporting EV sales and therefore stock, and the
significant decrease in economics-based adoption that might be expected if EV technology costs are
relatively high while policy support is relatively low (the dominant input variables to that scenario).

Figure 22 Statewide EV Population Variation
S2b Strong Electrification
Technology with 2030 Target Met
3,500,000
S3b Strong Electrification Policy
with 2030 Target Met

3,000,000 S3 Strong
Electrification Policy
S1 Baseline
2,500,000

2,000,000

1,500,000 S5a Worst Case without
S6b Best Case Climate ACC II
Climate Aligned
with 2030 Target Met
1,000,000
S4b Strong VMT Policy
with 2030 Target Met

500,000

0
2023 2025 2027 2029 2031 2033 2035

Differences in EV population across the scenarios are lessened by the requirement to reach ACC II annual
sales shares, which, as noted in the beginning of this chapter, plays an outsized role in driving EV sales
beyond what economics-based adoption alone might produce. Removing the effect of ACC II to explore
how various scenarios compare shows larger variation. The sensitivity versions of S6 Best Case (S6a), S2
Strong Electrification Technology (S2a) and S3 Strong Electrification Policy (S3a), which remove the effect
of ACC II, have the largest EV share in the baseline population, indicating they produce the most favorable
economics for EVs.

Notably, achieving the 2030 100% electric LDV sales target results in relatively modest effects on the overall
share of EVs in the vehicle stock by 2035. This is due to the relatively long time frame over which changes in
new sales have meaningful effects on the total vehicle stock (i.e., vehicles are fairly long-lived assets).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 71
Light-Duty EV Charging Needs

EV charging needs for LDVs vary across scenarios and sensitivities in proportion to the total number of EVs
and PHEVs estimated by the stock rollover model. In the S3 Strong Electrification Policy scenario, the number
of needed L2 residential charging ports grows from a 2025 estimate of 280,000 at single-family homes and
32,000 at multifamily homes to a 2035 estimate of 2.38 million and 570,000, respectively (Figure 23).68

The growing share of residential chargers at multifamily homes is based on the assumption that charging
access at these residences will grow over time (from 20% of multifamily homes having access in 2022 to
60% in 2035). However, it is important to note that this growth in charging access — which would support
both lower infrastructure costs and a more equitable transition to EVs69 — is far from guaranteed. To ensure
these monetary and equity benefits are realized, Washington will need to focus on enabling charging access
for residents of multifamily homes, whether directly on-site or nearby at neighborhood charging sites, to
closely replicate the convenience home charging offers to residents of single-family homes.

Level 1 (L1) charging at residences was not modeled given limited infrastructure development needs to
support this form of charging. Additionally, L1 charging’s slow recharging speeds limit its viability for
residents who regularly drive moderate distances (e.g., relatively longer daily commutes without workplace
charging access). However, the state is very supportive of leveraging L1 charging as a useful option for EV
drivers whose travel patterns do accommodate these slower charging speeds, to reduce costs and expand
access to charging options.

Figure 23 Cumulative Residential Charging Ports Required,
S3 Strong Electrification Policy Scenario
Single-Family Home, L2 Charging Ports Multifamily Home, L2 Charging Ports

2035 2.4M 565.5K
2034 2.1M 468.6K
2033 1.8M 384.3K
2032 1.6M 309.5K
2031 1.3M
2030 1.1M
2029 869.4K
2028 684.1K
2027 523.2K
2026 386.4K
2025 281.5K
2024
2023

68 Residential L2 chargers are assumed to have a capacity of 7.2 kW.
69 Logan Pierce and Peter Slowik, “Home Charging Access and the Implications for Charging Infrastructure Costs in the
United States,” The International Council on Clean Transportation, (March 9, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 72
In addition to the growing number of residential charging ports required, a significant increase in L2 chargers
at workplaces and public destinations will be required, as will public DCFCs (also known as Level 3 chargers).70
Figure 24 depicts the anticipated number of each type of charging port required over time in the S3 Strong
Electrification Policy scenario, increasing from approximately 7,000 workplace L2, 3,900 public L2 and 3,000
public DCFCs in 2025 to approximately 31,000, 13,000 and 10,500 ports by 2035, respectively.

Figure 24 Cumulative Nonresidential Charging Ports Required,
S3 Strong Electrification Policy Scenario
Workplace, L2 Charging Ports Public, L2 Charging Ports Public, DCFC Ports

2035 31.2K 13.1K 10.5K
2034 28.6K 12.2K 9.9K
2033 26.3K 11.4K 9.3K
2032 23.5K 10.6K 8.5K
2031 20.7K 9.6K 7.8K
2030 17.9K 8.7K 6.9K
2029 15.6K 7.7K 6.1K
2028 13K 6.5K 5.3K
2027 10.7K 5.7K 4.4K
2026 8.7K 4.9K
2025 7K 3K
2024 5.5K
2023 4.2K

These estimated nonresidential charging port requirements are lower than some other analyses of required
EVSE, relative to the number of light-duty EVs anticipated based on the stock rollover modeling. This result
is driven by several factors: the relatively high levels of residential charging assumed to be available, as
noted above; an assumption that public L2 chargers are 19 kilowatts (kW) (faster and more powerful than
is often the case today, because it is assumed that is what drivers will demand as the charging network
matures); and an assumption that the utilization rate of nonresidential chargers will increase over time
(e.g., public DCFC growing from 6% in 2023 to 15% by 2035, on average).71

70 Workplace L2 chargers are assumed to have a capacity of 7.2 kW, whereas public L2 and public DCFCs are assumed to have a
capacity of 19 kW and 150 kW, respectively.
71 The relatively low utilization rate (especially in the early years of the modeling period) is also intended to reflect the reality
that EVSE does not typically provide 100% of its nameplate capacity. An analogous treatment would be to assume that each
port’s nameplate capacity (e.g., 150 kW DC) is in reality only delivering a lower average power output, such as 120 kW. Higher
utilization rates and lower delivered power rates would result in a similar number of total required ports.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 73
Governor Inslee inspects a Kenworth electric truck in Pierce County.

If the nonresidential charging network developed in the state is not used as efficiently as the modeling
assumptions suggest, a larger number of nonresidential charging ports would be required, increasing total
infrastructure costs. Accordingly, focusing efforts on deploying nonresidential EVSE at locations that can
both meet the needs of EV drivers and support relatively high levels of asset utilization will be an important
component of developing a charging network that is both useful for drivers and cost-effective.

EVSE needs estimates for all modeled scenarios, by location type and by county or census block group, can
be found on the Washington TES User-Interactive Dashboard.72

Medium- and Heavy-Duty Vehicle Outputs

Several types of MHD vehicles were considered in the TES analysis, including medium-duty (MD) trucks, HD
trucks, school buses and transit buses.

Medium- and Heavy-Duty Vehicle Sales and Stock

Medium- and Heavy-Duty Trucks

Figure 25 depicts MHD truck sales and total vehicle population, by powertrain, for the S3 Strong
Electrification Policy scenario.73 In this scenario, electric MD truck sales share reaches approximately 65%
in 2030, and grows to 90% by 2035, and their share of total MD truck stock nearly doubles from 25% in 2030
to 48% by 2035. Electric HD truck sales share reaches 77% in 2030, and grows to 81% by 2035, and their
share of total HD stock reaches 23% by 2030 before growing to 41% by 2035. In addition to these battery
electric trucks, a small but growing number of FCEV HD trucks are adopted beginning in the early 2030s.

72 Washington TES User-Interactive Dashboard, found on the TES website.
73 For this analysis, Class 2b vehicles were included in the LDV pickup/SUV category, whereas Class 3 vehicles were included in
the MD truck category.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 74
Figure 25 Medium- and Heavy-Duty Truck Sales and Total Vehicle Population
by Powertrain, S3 Strong Electrification Policy Scenario
EV HD EV MD ICE-Diesel FCEV ICE-Diesel
Truck Truck HD Truck HD Truck MD Truck

Annual Sales Total Vehicle Stock

110K
8,000
100K

90K

80K
6,000
70K

60K
4,000 50K

40K

30K
2,000
20K

10K
0
2023 2027 2031 2035 2023 2027 2031 2035

As with the LDVs described above, the total population of electric MHD trucks in Washington varies
considerably across scenarios. Figure 26 provides this range over time, highlighting that the S3 Strong
Electrification Policy and S6 Best Case Climate Aligned scenarios result in the largest number of electric
trucks by 2035. A large component of this result is the inclusion of the ACF’s adoption rates in these
scenarios. ACF, which is currently being considered for adoption in Washington, is a more stringent
companion policy to the existing ACT rule. RMI estimates that ACF would apply to approximately 40% of
MHD trucks in Washington.

Unlike the analogous comparison of electric LDV stock over time, the scenario with the lowest number of
electric trucks — S5a Worst Case without ACT — is a clear outlier, demonstrating that under other scenarios
exposed to the sensitivity of removing the ACT requirement, truck electrification remains relatively
strong. This is due to the combination of significant federal tax credits and the more responsive nature
of commercial players to TCO advantages (compared with individual consumers), indicating there is
significant opportunity for cost-effective electrification among the state’s MHD trucks.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 75
Figure 26 Statewide Medium- and Heavy-Duty EV and FCEV Truck Population
Variation
S6 Best Case
50,000 S3 Strong
Electrification
Policy
45,000

40,000

35,000

30,000

25,000
S1 Baseline
20,000

15,000

10,000
S5a Worst Case
without ACT
5,000

0
2023 2025 2027 2029 2031 2033 2035

In contrast to the LDV results, which are dominated by the effect of ACC II, for MHD trucks S2 Strong
Electrification Technology, S3 Strong Electrification Policy and S6 Best Case Climate Aligned all show fairly
large increases over the S1 Baseline in terms of 2035 EV population. S2 Strong Electrification Technology
promotes higher adoption through lower vehicle and operating costs, S3 Strong Electrification Policy
through both larger incentives and the purchase requirements from the ACF rule and S6 Best Case through
a combination of S2 and S3.

Notably, these three scenarios show similar incremental levels of truck electrification over the S1 Baseline
even in the absence of the ACT regulation (sensitivities S2a, S3a and S6a). This indicates that decreasing the
cost of electric trucks relative to ICE trucks enables electrification beyond the minimum levels required by
top-down policy — a distinct finding compared with the analogous analysis of electric LDV stock with and
without the ACC II regulation.

The sensitivities that explore higher and lower fossil fuel costs show larger effects on MHD trucks than the
application of these sensitivities to the LDV scenarios, due to both the higher responsiveness of commercial
truck operators to TCO, and the larger share of total costs that operating expenses make up for trucks
relative to cars (making truck operators more sensitive to fuel price changes, all else being equal).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 76
School and Transit Buses

Unlike LDVs and MHD trucks, bus electrification was modeled based primarily on assumptions about grant
funding availability and forecasted price parity rather than TCO analysis due to the historic reliance of these
vehicle types on public funding, including for electrification.

Three electric sales trajectory projections were created for both school and transit buses: a baseline, a
high-adoption scenario and a low-adoption scenario. For transit buses, the sales trend was influenced
by the availability of federal funds such as the low- or no-emissions grant offered by the Federal Highway
Administration (FHWA), which covers up to 90% of the purchase price of electric transit buses. For school
buses, the sales trajectories were differentiated based on anticipated years that price parity is achieved
between ICE and battery electric school buses, according to the World Resources Institute (WRI).74

Figure 27 depicts school and transit bus sales and total vehicle population, by powertrain, for the S3
Strong Electrification Policy scenario. In this scenario, electric school bus sales increase exponentially to
100% by 2029. Electric transit buses reach an approximately 54% sales share by 2030, increasing to 80%
by 2035. Additionally, FCEV transit buses start to gain a small portion of market share in 2029, reaching
approximately 10% of statewide sales by 2035.

Figure 27 School and Transit Bus Sales and Total Vehicle Population,
by Powertrain, S3 Strong Electrification Policy Scenario
EV School EV Transit FCEV Transit ICE-Diesel School ICE-Diesel Transit

Annual Sales Total Vehicle Stock

18,000
1,500 16,000
14,000
12,000
1,000
10,000
8,000
6,000
500
4,000
2,000
0
2023 2027 2031 2035 2023 2027 2031 2035

74 According to WRI (“Which Electric School Bus Business Model Is Right for Your District?”), electric school buses are
projected to reach lifetime TCO parity with diesel buses by 2029, and upfront price parity by 2033.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 77
Alternate bus electrification scenarios assume more or less funding is available for these vehicles, with
commensurate increases or decreases, respectively, for sales and stock share. Table 11 provides the sales
and stock share for battery electric school and transit buses and for FCEV transit buses for the three bus
electrification scenarios modeled.

Table 11 Bus Electrification Sales and Stock Share by Year
Sales Share Stock Share

2030 2035 2030 2035

BEV School Buses (Base) 38% 100% 11% 45%

High 100% 100% 30% 66%

Low 14% 37% 5% 16%

BEV Transit Buses (Base) 50% 68% 32% 47%

High 53% 90% 35% 55%

Low 22% 18% 25% 23%

FCEV Transit Buses (Base) <1% 8% <1% 1.50%

High <1% 10% <1% 2%

Low <1% 2% <1% <1%

Medium- and Heavy-Duty EV Charging Needs

As with the LDVs, charging requirements for electric trucks and buses grow quickly, as depicted for the S3
Strong Electrification Policy scenario in Figures 28 and 29. As shown in Figure 28, charging for both MD and
HD trucks is anticipated to come primarily from depots, especially in the near term as the routes that can best
accommodate reliance solely on depot charging are electrified. Areas with significant trucking activity such as
ports and warehouse districts are likely to be key locations within which to develop charging infrastructure.
The concentration of the relatively large power needs of MHD trucks in such areas will require thoughtful
advance planning to accommodate the electric grid upgrades necessary to accommodate charging of these
vehicles. As additional trucking routes are electrified over time, an increasing share of charging is expected to
come from on-road public DCFCs.75 However, in these projections, even though the total amount of charging
from public DCFCs grows, the share of public charging ports decreases compared with depot charging ports as
utilization rates of the public charging network increase.76

75 Depot chargers for MD trucks are assumed to have a capacity of 50 kW DC, whereas depot chargers for HD trucks are assumed
to be 350 kW DC. Public DCFCs for medium- and heavy-duty trucks are assumed to be 150 kW DC and 350 kW DC, respectively.
76 As with LDVs, utilization rates for MHDVs are intended to both encompass the proportion of time the charging ports are used in
a given day and serve as a proxy for the difference between nameplate capacity of the EVSE and the average delivered power.
Actual port count requirements, especially for MHDV public charging ports in the later years of the modeling period (where
the utilization rate is assumed to be relatively high), may be larger than these estimates suggest due to both average power
delivered versus nameplate capacity differences and relatively strong assumptions about the efficiency of charger utilization.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 78
Figure 28. Cumulative Charging Ports Required to Support Electric Medium-
and Heavy-Duty Trucks, S3 Strong Electrification Policy Scenario
HD Depot Charging Ports HD Public Charging Ports MD Depot Charging Ports
MD Public Charging Ports

2035 1.1K 7.7K
2034 1.1K 7K
2033 974 6.3K
2032 884 5.7K
2031 788 4.9K
2030 679 4.2K
2029 3.5K
2028 2.8K
2027 2.2K
2026 1.5K
2025 1K
2024
2023

The stock rollover model used to determine the number of electric trucks in Washington over time and
the associated EVSE needs is based on vehicle registration data from the Department of Licensing (DOL).
Although that data provides a good approximation of the LDVs operating in the state, a larger share of
MD and especially HD trucks that operate on Washington’s roads and highways are registered out of
state. As these out-of-state trucks electrify, they will also require charging infrastructure when they are
driven within Washington.

Data from the FHWA indicates that, on average, approximately 30% of MHD truck miles in the United
States are driven outside of a truck’s home state.77 Separately, RMI analysis of FHWA data suggests that in
Washington, the percentage of total state highway miles driven by vehicles registered outside the state
is approximately 18% for MD trucks and potentially as high as 50% for HD trucks. Table 12 applies these
shares (18% to 30% for MD trucks, and 30% to 50% for HD trucks) to the EVSE needs estimated for the S3
Strong Electrification Policy scenario to estimate the range of potential incremental charging required by
out-of-state trucks (assuming for simplicity that those trucks are electrified on a similar trajectory as those
within Washington). These out-of-state electric trucks would likely skew toward public rather than depot
charging, although some would also charge at depots within the state.

77 U.S. Department of Transportation – Federal Highway Administration, “Freight Facts and Figures 2010,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 79
Table 12 Estimated Additional EVSE Required to Support Out-of-State MHD
Trucks
Charger Type MD Depot* MD Public* HD Depot** HD Public**

2025 188 – 314 18 – 29 56 – 93 31 – 51

2030 759 – 1,264 51 – 85 204 – 340 77 – 129

2035 1,389 – 2,315 90 – 150 342 - 570 115 - 192

*Note: MD ranges represent number of chargers needed for an out-of-state share of MD trucks between 18% and 30%
** Note: HD ranges represent number of chargers needed for an out-of-state share of HD trucks between 30% and 50%

In this analysis, electric buses are assumed to exclusively use depot charging, as shown in Figure 29.78 In the
S3 Strong Electrification Policy scenario, school bus depot chargers begin with a relatively small number in
the first few years as bus electrification ramps up, reaching approximately 2,200 19 kW L2 chargers statewide
by 2035. A larger number of higher-power transit bus depot chargers (350 kW direct current [DC]) are required
sooner as these vehicles electrify, whereas the growth of chargers needed over time is anticipated to be more
moderate based on a somewhat slower pace of bus electrification, combined with an assumed increase in the
efficiency of charger utilization as transit agencies learn how to optimize larger electric fleet operations.

Figure 29 Cumulative Charging Ports Required to Support Electric School
and Transit Buses, S3 Strong Electrification Policy Scenario
School Bus Depot Charging Ports Transit Bus Depot Charging Ports

2035 2.2K 502
2034 2K 455
2033 1.8K 409
2032 1.5K 365
2031 1.3K 331
2030 1K 309
2029 729 278
2028 439 256
2027 266 218
2026 238
2025 217
2024 177
2023

78 School bus depot chargers are assumed to be 19 kW AC given the relatively long dwell times these buses have during the
school day and overnight, whereas transit bus depot chargers are assumed to be 350 kW DC to accommodate their duty cycles.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 80
Anticipated EV Charging Costs

Based on the EVSE needs analysis described above, Washington can expect to require significant public
and private funding to develop sufficient charging infrastructure to support the anticipated number of EVs.
Figure 30 depicts cumulative estimated EVSE costs — including equipment and installation but not utility-
side grid upgrades — by 2035 for both the S1 Baseline and S3 Strong Electrification Policy scenarios.79 Note
the different axis scales between the LDV (left) and MHDV (right) charts.

Figure 30 2035 Cumulative EVSE Equipment and Installation Cost Estimates,
Scenarios S1 and S3 ($2023, billions)

LDV Residential Charging MHD Depot Charging
LDV Nonresidential Charging MHD Public Charging

S1 Baseline Scenario S3 Strong S1 Baseline Scenario S3 Strong
Electrification Electrification
Policy Scenario Policy Scenario
7.3B 7.4B 972.9M

148.2M
1.6B 1.7B
6B 723.8M
750M
105.1M
571.5M

4B 89.1M
500M
423.3M
2.7B 2.7B 62.9M 824.7M
5.7B 5.7B
901.1M 918.3M 618.7M
2B 250M 482.3M
360.5M
1.8B 1.8B

S1 Low S1 High S3 Low S3 High S1 Low S1 High S3 Low S3 High

Note: For the S3 Strong Electrification Policy scenario, additional costs to support out-of-state MHD trucks are estimated at between $157 million
and $263 million cumulatively by 2035. This assumes the average of the scaling factors outlined earlier in this section, by vehicle segment, to
determine incremental miles from out-of-state trucks, i.e., 24% and 40% for MD and HD trucks, respectively.

79 Estimates do not include the value of tax credits available through the IRA.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 81
Table 13 provides estimates of annual EV charging costs for EVSE and installation, broken into four categories.

Table 13 Estimated Annual Cost of EV Charging Equipment and Installation,
S3 Strong Electrification Policy Scenario ($2023, millions)
LDV LDV MHD MHD
Residential Nonresidential Depot Public Total

2023 149–446 202–367 27–47 9–15 387–875

2024 61–198 64–116 43–74 11–18 180–406

2025 75–242 64–117 33–57 6–10 179–425

2026 87–281 59–108 35–59 7–12 188–460

2027 109–351 70–127 40–67 8–14 227–559

2028 123–396 71–130 41–70 7–12 242–608

2029 136–438 69–125 40–69 6–10 251–642

2030 147–475 62–113 40–69 7–11 256–668

2031 164–530 63–115 40–69 6–10 273–723

2032 173–559 56–103 40–68 6–10 275–739

2033 180–579 55–101 34–58 5–9 274–747

2034 186–598 43–80 34–59 5–8 268–745

2035 193–622 40–74 35–59 6–10 274–766

Across all scenarios, the cost of EVSE for LDVs at residences is the primary driver of total costs, followed
by nonresidential charging for LDVs (including workplace and public charging). Residential charging costs
will be borne largely by private citizens, although ensuring EVSE costs are not a deterrent to EV adoption
will be critical, especially for lower-income households (e.g., through state or utility incentive programs).
Nonresidential light-duty EVSE costs will be borne by a combination of players, including developers of
public charging stations (both L2 and DCFC) and employers developing EVSE for their employees.

Public funding for these nonresidential charging options will also be important to ensure they are deployed
equitably, with access provided to all drivers in Washington. The state should prioritize L2 installation
locations based on their connection to non-driving modes and their ability to maximize utilization to
improve consumer experience, limit disruption to traffic patterns and bring significant savings to the state.
Examples of locations that were requested during the public engagement period include park-and-rides,
libraries, airports, parks and municipal buildings.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 82
MHD charging costs will be borne largely by fleet operators developing private charging stations for their
vehicles at depot locations. Public funding will, however, be important for ensuring that fleet electrification
progresses quickly, in line with state goals, by providing incentives to reduce the up-front costs associated
with deploying EVSE. Additionally, as trucks that cannot easily rely solely on depot charging electrify over
time, public funding to support high-powered public DCFC suitable for MHD vehicles will be essential for
ensuring larger portions of these vehicles are able to transition to electric options.

The cost estimates described above do not include utility electric grid upgrades that will be required to
accommodate EV charging. Although those costs will be an important component of the total expense
necessary to electrify the transportation sector, conducting estimates of utility-side costs was not part
of the scope of this analysis. However, the Department of Commerce is conducting a study of utility-side
costs in 2024 to better understand the total expense that will be required to prepare the state’s electric
grid for transportation electrification, the results of which should prove informative for additional
planning efforts.

Electric Sector Impacts from Transportation Electrification

The total amount of electricity required to support transportation electrification will grow significantly
this decade and beyond. In the S1 Baseline scenario, light-, medium- and heavy-duty EVs are
estimated to require 1.4 terawatt-hours (TWh) of electricity by 2025, increasing tenfold to 14 TWh by
2035. This represents 1.6% and 16%, respectively, of the state’s current annual electricity
consumption of approximately 88 TWh.80 The S3 Strong Electrification Policy scenario estimates that
EV charging would require 1.7 TWh by 2025 and 15 TWh by 2035 (1.9% and 17% of the state’s current
consumption, respectively).

In terms of power demand, the growing number of EVs has the potential to materially increase peak
loads, but also presents an opportunity to flatten out existing load profiles, thereby increasing the
overall utilization of grid infrastructure and reducing average costs for all consumers. The modeling
conducted for the TES did not explore the potential for managed charging, on-site generation or other
peak demand reduction opportunities. Nonetheless, the magnitude of the opportunity presented by
load shifting and distributed generation and storage resources is clear from the anticipated scale of
load growth.

As transportation electrification progresses in Washington, it will be imperative to manage as much of
this new load as possible, shifting charging to off-peak times that maximize utilization of both grid assets
and renewable electricity generation. Figure 31 presents a statewide load shape for the S1 Baseline and
S3 Strong Electrification Policy scenarios on a typical weekday in 2035, not including managed charging.
Accordingly, the sizable evening peak — 3.2 gigawatts (GW) and 3.4 GW, respectively — can be considered a
worst case outcome should the state, electric utilities and other stakeholders fail to take advantage of load
shifting and demand mitigation through on-site resources such as renewable generation and stationary
battery storage.81

80 U.S. Energy Information Administration, “Washington Electricity Profile 2021,” (November 10, 2022).
81 Including estimates of MHD truck charging load from out-of-state vehicles operating in Washington, total unmanaged peak
load in 2035 could increase by approximately an additional 120 MW or 170 MW for Scenario S1 and Scenario S3, respectively,
representing an incremental 4%–5% of total peak demand across all vehicle segments.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 83
Figure 31 Statewide Time-of-Day EV Load Without Demand Management,
2035 S1 Baseline and S3 Strong Electrification Policy Scenarios
S1 Baseline
Electricity Load (GW)
3.0
Public DCFC

2.5 Public Level 2

2.0 MHD Trucks
Multifamily
Residential Level 2
1.5
Bus Depots
Workplace
1.0 Level 2
Single-Family
Residential Level 2
0.5

0.0
0 2 4 6 8 10 12 14 16 18 20 22
Hour of Day

S3 Strong Electrification Policy
Electricity Load (GW)
3.0
Public DCFC

2.5 Public Level 2

2.0 MHD Trucks Multifamily
Residential Level 2

1.5 Bus Depots Workplace
Level 2

1.0
Single-Family
Residential Level 2
0.5

0.0
0 2 4 6 8 10 12 14 16 18 20 22
Hour of Day

Emissions Reduction Potential from Transportation Electrification

A primary benefit of transportation electrification is the reduction of both GHG and local air pollutant
emissions. The following section briefly discusses modeled GHG and air pollutant outcomes; further details
can be found on the Washington TES User-Interactive Dashboard, found on the TES website.82

82 For a scenario comparison of GHG and local air pollutants from both ICE tailpipes and electric power generation for EV
charging — including PM2.5, PM10, NOX, N2O, CO, SOX and VOCs — please see the Washington TES User-Interactive Dashboard,
found on the TES website.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 84
Greenhouse Gas Emissions

Modeling conducted for the TES suggests that current GHG emissions from the on-road transportation
sector — approximately 22 MMT — may fall to between a worst case level of 16.8 MMT and a best case level
of 12.0 MMT by 2030, and between 13.9 MMT and 6.7 MMT by 2035 (Figure 32).

Figure 32 Estimated Range of Statewide GHG Emissions from On-Road
Transportation, By Scenario (MMT CO2e)
22

20
S5a Worst Case without
18 ACC II or ACT

14
S1 Baseline
12
Approximate 2030
Emissions Limit
10
S3 Strong
Electrification
8 Policy

6
S6b Best Case with
2030 Target Met
4

0
2023 2025 2027 2029 2031 2033 2035

Compared with the analogous figures shown for light-duty and MHD EV population variation across
scenarios (Figure 22 and Figure 26, respectively), the range of emissions reduction outputs is somewhat
narrower due to the continued effect of the remaining ICE vehicles (which keep emitting from tailpipes).
The largest factors driving this range of outcomes include different assumptions about VMT reductions
and vehicle stock changes (exploratory scenarios S4 Strong VMT Policy and S6 Best Case Climate Aligned,
and the sensitivities applied to them), as well as the presence or absence of existing regulations (ACC II,
ACT) and the 2030 EV target in the modeling. It is important to note that although the largest emissions
reductions are desirable from a climate and public health perspective, they are based on aggressive VMT
reductions and vehicle stock changes, which may not be feasible to fully attain in the short term (i.e., by
2030) because of their reliance on challenging structural changes such as land use reform.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 85
Rush hour traffic in Seattle

The 2021 SES83 found that Washington’s transportation sector must reach 20 MMT CO2e or lower by 2030 to
support the state’s economy-wide climate goals. On-road GHG emissions (those modeled directly for the TES)
made up approximately 58% of the state’s transportation sector emissions based on the latest inventory,
suggesting that the approximate 2030 GHG emissions this subsector could contribute would be 11.6 MMT.
However, electrification technology and commercialization status suggest that the on-road subsector is better
positioned than non-road vehicles (e.g., marine, aviation, construction, agricultural) to achieve near-term
decarbonization progress, indicating that a lower on-road target such as 10 MMT is better calibrated to the
emissions reductions that will be required from these vehicles to support state goals.

Unfortunately, none of the modeled scenarios meet this 2030 emissions limit. Additionally, the emissions
reductions estimated in the scenarios that achieve the largest emissions reductions (exploratory scenarios
S4 Strong VMT Policy and S6 Best Case Climate Aligned, and the sensitivities applied to them) are likely
to be fully unattainable because of the combination of external factors they include (e.g., high fossil fuel
prices, low EV costs) and the challenges inherent in achieving the steep VMT and vehicle stock change
reductions embedded in them. Nonetheless, these exploratory scenarios indicate the significant range of
potential emissions reductions beyond those spurred by electrification alone. Accordingly, the state should
focus on achieving the transportation electrification targets and goals it has established (ACC II, ACT, 2030
100% electric LDV sales) while also attempting to at least partially close the gap between expected and
desired 2030 on-road vehicle GHG emissions.

Local Air Pollutants

Gasoline- and diesel-powered transportation produces air pollution that can affect people’s health, in
addition to emitting GHGs that contribute to climate change. These mobile sources of air pollution emit
NOx, particle pollution and other HAPs. NOx is a respiratory irritant associated with asthma attacks,

83 Lisa Brown et al., “Washington State Energy Strategy, 2021,” Washington Department of Commerce, (December 2022).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 86
symptoms such as coughing and increased hospital visits for respiratory conditions. NOx also reacts with
sunlight to create ground-level ozone, another pollutant, which can cause wheezing, shortness of breath
and chest pain; aggravate existing lung conditions; and increase the risk of respiratory infections. Particle
pollution can cause eye, nose and throat irritation and coughing or asthma attacks, or aggravate existing
lung and heart conditions. HAPs include a wide variety of toxins, including benzene, and are known
or suspected to cause cancer or other serious health conditions such as reproductive issues and birth
defects. Air pollution can affect everyone, though some groups are especially sensitive or at risk, including
people 18 and younger and older than 65, pregnant people, people with health conditions, people with
low income, people of color, and tribal and Indigenous populations. People who live near busy roads, truck
routes or goods movement centers are also at increased risk of adverse health effects from air pollution.

Reductions in local air pollutant emissions are a significant benefit of transportation electrification, often
felt more tangibly in communities than reductions in GHG emissions. Recognizing this opportunity, the
American Lung Association released a series of reports in recent years documenting the meaningful health
benefits expected from vehicle electrification and the associated reduction in tailpipe emissions.84

Figure 33 depicts estimated local air pollutants from both ICE vehicles and EVs in the S3 Strong
Electrification Policy scenario. Table 14 shows the percentage change in each pollutant relative to
estimated 2023 levels. As an increasing proportion of the state’s vehicles are electrified, significant
decreases in local air pollution will be attained, leading to improved public health outcomes such as
reductions in asthma, respiratory-related hospitalizations and premature deaths.

Figure 33 Local Air Pollutants, S3 Strong Electrification Policy Scenario
(Metric Tons)
CH 4 CO N2 O NO X PM10 PM 2.5 SO X VOC

40,000

30,000

20,000

10,000

0
2023 2025 2027 2029 2031 2033 2035

84 American Lung Association, “Electric Vehicle Reports,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 87
Table 14 Change in Local Air Pollutants Relative to 2023 Levels,
S3 Strong Electrification Policy Scenario
CH 4 CO N2 O NOx PM 10 PM 2.5 SOx VOC

2024 −2% −4% −6% −4% −3% 3% 86% −5%

2025 −3% −8% −10% −9% −4% 6% 175% −10%

2026 −8% −12% −14% −14% −5% −3% 224% −15%

2027 −9% −17% −19% −19% −13% −3% 237% −20%

2028 −20% −22% −23% −25% −16% −2% 260% −25%

2029 −23% −26% −27% −31% −18% −1% 166% −30%

2030 −40% −31% −32% −38% −35% −33% 114% −35%

2031 −45% −36% −36% −43% −40% −38% 26% −40%

2032 −49% −41% −41% −48% −44% −43% 46% −45%

2033 −54% −45% −45% −53% −48% −47% 66% −49%

2034 −58% −50% −49% −57% −53% −52% −100% −54%

2035 −62% −55% −54% −63% −57% −56% −100% −58%

Note: Definitions for the abbreviations at the top of the table can be found in the glossary. Sulfur emissions from ICE
vehicles are not included in the MOVES3 database from which emissions factors were sourced, because they are a
relatively minor and nonuniform source of tailpipe pollution. They are, however, included in electric power sector
emissions, driving the increase shown in this table. However, as the table shows, these are a relatively small source of
local air pollution compared with other pollutants such as carbon monoxide (CO), nitrogen oxides (NOx) and volatile
organic compounds (VOCs).

Chapter 5 includes high-level recommendations for how to reduce both GHG and local air pollutant
emissions from VMT reductions, vehicle stock changes, vehicle energy efficiency, clean non-electricity
fuels, early retirement of gasoline and diesel vehicles, and reducing emissions from non-road
transportation. The chapter also includes core policy recommendations and implementation guidance for
achieving transportation electrification targets.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 88
5. How Washington
Can Get There
Anticipated Barriers to Scaling EV Adoption

Note: Barriers are applicable to all transportation electrification strategies (personal vehicle,
micromobility, fleets, public transportation) unless otherwise specified.

Washington has taken a wide variety of critical actions to support transportation electrification, which
has helped improve air quality and reduce GHG emissions. These actions include adopting ACC II and
ACT, which analysis in the previous chapter shows will drive overall uptake of EVs by ensuring a growing
percentage of vehicles sold in the state are electric. However, supporting the state’s residents, companies
and industries to adapt to EVs smoothly, equitably and affordably will require additional state action and
capacity in the form of supporting technological, financial and institutional infrastructure.

The transition from predominately fossil fuel–based modes of transportation to a predominantly electric
transportation system is likely to face barriers. This chapter begins by reviewing those barriers and then
discusses how the policy recommendations and implementation plan are designed to address them.

Technological Barriers

Product supply chain limitations have led to both EV production challenges and limited availability
of fast-charging infrastructure. The availability of EVs and charging equipment is a key component in
ensuring people and companies have access to and are comfortable with the transition to EVs. Feedback
from fleet operators noted that it is difficult to access electric vans, trucks and other EVs at a rate needed
to achieve their EV procurement goals and requirements. Availability constraints are driven by demand
outpacing available product, likely due to market factors such as rapidly declining capital costs or TCO and
increasing gas prices. It could also be due to customer experience, such as improved driving experience or
consumer preference. Similarly, government regulations or incentives at the federal or state level may also
increase demand faster than supply.

Paradoxically, both real and perceived limitations in vehicle options, especially affordable models (e.g., Chevy
Bolt) and other model types (e.g., electric three-row SUVs, trucks and vans) may limit consumer interest as
auto manufacturers rush to adapt to evolving consumer preferences. As an example, in 2023 there were about
29 fully electric consumer vehicle models in North America (of which 18 were eligible for federal tax credits),85
compared with over 400 models of fossil fuel–based models. Similarly, electrified versions of niche MHDVs,
such as refrigerated trucks or long-haul capacity vehicles, are not yet available at scale.

Finally, pandemic-related delays in the supply chain for vehicle computer chips was a huge factor in
the doubling of raw material costs for EVs since 2020.86 Production capacity for fast-charging hardware,

85 Scooter Doll, “Here’s Every Electric Vehicle That Currently Qualifies for the US Federal Tax Credit,” Electrek, (August 8,
2023).
86 AlixPartners, “Auto Industry Needs to Adopt the ‘Ruthless Prioritization’ Demonstrated by Chinese Automakers to Avoid
a Repeat of China’s Domestic Electric-Vehicle Dominance Globally,” (June 26, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 89
A Chevrolet Bolt electric vehicle charges outside the Washington Department of Ecology’s Eastern Region Office.

semiconductors, switch gears, transformers, lithium and other components could similarly affect
production and availability of EVs and EVSE.

Charging infrastructure is generally decentralized, can be unreliable, lacks interoperability and can
result in queues for open chargers due to slow speeds. Charging an EV is inherently different than filling
up a gas tank and will require both a different infrastructure model and a different user mindset. Currently,
charging speeds, even for DCFC, are slower than filling up a gas tank, and there is a risk of long queues if
drivers need to wait for an open charger. This risk is compounded by reliability challenges among existing
chargers, which may be broken or vandalized.

Charger accessibility will also be a determining factor in easing the transition to EVs. For those who can
charge at home, charging an EV will be far more convenient than filling up an ICE vehicle at a gas station.
Although 72% of Washingtonians have parking within 20 feet of an electrical outlet,87 those who cannot
upgrade the outlet to 240 volts, lack access to personal off-street parking, or cannot charge sufficiently
at work will need additional support from the state to gain reliable and affordable residential or
neighborhood charging access.

Even with the vast majority of charging expected to happen at home, the public charging experience must
be drastically improved, especially for those without residential charging access. As charging infrastructure
is built out, the lack of a centralized platform to locate and compare nearby charging locations may
frustrate would-be users. Similarly, challenges in interoperability among charging companies — for
example, different apps and payment options, the need for credit cards and even varying charging
connector ports — will complicate the ability to charge without standardization. Washington is funding
both Combined Charging Systems (CCS) and North American Charging Systems (NACS) through charging
investment programs and is waiting for federal action to move forward with one standard. NACS is still
going through the SAE International (SAE) certification process and Commerce is working with the National
Association of State Energy Officials to urge action at the federal level.

87 Office of Energy Efficiency & Renewable Energy, “FOTW #1308, September 18, 2023: Sixty-Seven Percent of All Housing
Units in the United States Have Vehicle Parking Within 20 Feet of an Electrical Outlet,” (September 18, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 90
Two people admire an electric vehicle charging in a parking garage.

Of specific note, those using electric cars that rely on CHAdeMO chargers (including Washington’s 13,000
Nissan Leaf drivers) will face unique challenges finding charging access. Washington agencies must prioritize
more common connectors like NACS and CCS to make most effective use of limited resources and should urge
Nissan to address this issue, caused by the company’s decision to limit consumer interoperability.

Grid infrastructure is insufficient to meet anticipated long-term charging needs in many locations,
and likely in the near term for areas with high concentrations of MHDVs, which require higher-power
charging. To support LDV adoption, fleet charging and MHDV charging in line with Washington’s goals requires
investments in and deployment of sufficient grid infrastructure to meet the charging demand. Nationally,
transmission infrastructure needs to grow at least 2% per year (twice the annual national average growth
rate) just to keep up with the electrification demand from the IRA’s renewables and electrification incentives.88
Utilities will need to deploy additional resources and enable electricity resource management to smooth
and shape the demand of additional load throughout each day, such as through use of distributed energy
resources (DERs), demand management and possibly vehicle-to-grid (V2G) capability.

Washington’s electricity sector is already considerably low carbon and will become more so as utilities meet
CETA’s carbon neutrality requirement by 2030 and 100% clean energy requirement by 2045. However, as
charging demand grows, Washington will need to increase investments in energy efficiency and demand
management, and generate or import sufficient renewable energy to ensure transportation electrification is
powered by zero-carbon electricity.

Trip range can be limited by negative weather impacts on battery capacity and can be worsened by
lack of EVSE infrastructure. Range anxiety among drivers has and will continue to diminish as vehicle
performance improves and the public charging network is built out. At the start of 2023, the average range

88 Jesse D. Jenkins et al., “Electricity Transmission Is Key to Unlock the Full Potential of the Inflation Reduction Act,” REPEAT
Project, Princeton, (September 22, 2022).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 91
for a new electric LDV on a single charge was 216 miles (348 kilometers),89 and the average car owner
nationally drives 37 miles per day, according to the FHWA. In Washington, only about 10% of commuters
have one-way travel times exceeding one hour, and even these commutes should not affect those with
access to home charging. Used EVs, however, are often sold with smaller, older batteries that have a more
limited range. This compounds equity implications for low-income drivers who are more likely to own used
EVs and be impacted by these challenges.

Battery range is a more prominent issue among fleets and MHDVs, especially with respect to electric bus
performance, which under the best circumstances may need to incorporate midday charging requirements,
especially on hilly routes or in cold weather. Range limitations that constrain electric fleet vehicles to
specific routes and schedules reduce their operational flexibility.90,91 Many school districts have their buses
in operation the better part of the day with drivers’ downtime spent outside the depot. Cross-county trips
for recreational games and field trips need to be made, sometimes with minimal planning. Drivers whose
trip length dictates their income, such as couriers and transportation network company (TNC) drivers like
Uber and Lyft, many of whom share their vehicle with other drivers and lack downtime to charge, will also
struggle to transition without additional support.

Financial Barriers

The lack of cost parity between EVs and ICE vehicles can make it difficult or impossible for some
consumers to transition. Although a variety of EV models have begun to enter the market, new electric
LDVs on average are still considerably more expensive than their ICE counterparts.92 This also remains
the case for MHDVs. Additionally, Washington’s used EV market is still limited. Current federal and state
incentives for purchasing new and used EVs have been a deciding factor for the majority of consumers.
Analysis from RMI suggests light-duty EVs will eventually reach TCO superiority and purchase price
parity with ICE vehicles, but not until 2030–32.93 This is dependent on current projection for states’ ACC II
adoption. This suggests up-front incentives still have a strong role to play in decisions to purchase an EV
over an ICE vehicle for the next few years, especially for LMI consumers.

Up-front vehicle costs impact LMI consumer options disproportionately compared with higher income
consumers, even given the long-term operational savings EVs offer. Fortunately, the federal EV incentive is
changing from a tax credit, wherein purchasers did not see the benefit until after they provided the up-
front capital, to a point-of-sale rebate, requiring no tax liability for the consumer. The Washington sales tax
exemption is also functionally an “on the hood” benefit, though it would be more impactful for consumers
if it were aligned with the federal incentive.

Installation of EVSE can have high up-front capital costs, including costs to upgrade grid
infrastructure, and challenging business models. Despite many federal, utility, private and other funding
options to deliver charging infrastructure, EVSE equipment is still a substantial expenditure. Hardware,

89 Electric Vehicle Database, “Range of Full Electric Vehicles,” (n.d.).
90 Ryan Sclar et al., “Barriers to Adopting Electric Busses,” World Resources Institute, (May 21, 2019).
91 Due to limited data on routes, the TES modeling assumed all transit and school bus charging takes place at depots. As these
buses electrify, however, the state should work with transit agencies and school districts and OSPI to determine where on-
route charging may be required, and incorporate these planning considerations into broader EVSE deployment strategies.
92 IEA, “Global EV Outlook 2022,” (May 2022).
93 Drew Veysey and Marie McNamara, “Advanced Clean Cars II: Cutting Pollution While Strengthening Local Economies,” RMI,
(April 5, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 92
An electric vehicle charging along the West Coast Electric Highway.

installation, site preparation, permits and inspections bring the up-front cost of an average DCFC EV
charging station to more than $100,000.94 The window to apply for a rebate or other incentive can fluctuate,
and consumers are not always aware they qualify. Charging installations can trigger both building electrical
upgrades and grid infrastructure upgrades. Moreover, because the EVSE market is still relatively new,
modeling the return on investment of an EVSE installation varies widely across Washington.

Operating costs for public EV charging lacks transparency, and significant variability in costs between
at-home and public charging disproportionately affects renters and residents of multifamily homes.
For drivers without access to home charging, the cost of operating an EV can be a significant deterrent
to adoption. At the start of 2023, EV owners paid on average $4 more for every 100 miles to charge at
commercial charging stations compared with those who charged at home.95 In some cases, the cost of
charging at publicly accessible chargers is set by EVSE providers or property owners. These extra costs add
up and are experienced disproportionately by renters and residents of multifamily homes, who tend to be
low-income households.

Additionally, fleet operators and businesses are unaccustomed to negotiating charging agreements with
their utility provider and see negotiations as complex and full of risk. Fleet operators, which typically have
a strong sense of fuel costs when operating ICE vehicles, can feel that they have less control of prices when
charging EVs and that there is overall less predictability.96

Absent effective regulation, managed charging and other strategies to better use grid capacity,
energy burdens could increase for low-income households if utility rates increase to support charging
infrastructure.

94 Chris Nelder and Emily Rogers, “Reducing EV Charging Infrastructure Costs,” RMI, (2019).
95 Institute for Energy Research, “Operating Costs of Electric Vehicles Are Catching Up, and in Some Cases Overtaking Gas-
Powered Autos,” (February 7, 2023).
96 “Challenges and Solutions in EV Fleet Electrification,” TruckingDive, (March 27, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 93
On average, existing passenger cars often stay on the road for approximately 15 years, given the cost
of replacing vehicles. The vehicle stock turnover rate is even longer for MHDVs. This will ultimately limit
the rate at which vehicles in Washington more widely transition to EVs.

One concern heard during public engagement was from EV drivers who pay a $225 fee to cover what
they would otherwise pay in gasoline tax, which helps fund roadway maintenance. The TES’s TCO and
S-curve model indicate that annual registration fees have little impact on consumer behavior. Based on
this finding, the TES recommends other more effective strategies for lowering EV purchase prices without
worsening roadway preservation. That being said, EV Council agencies will continue to support the
administration’s efforts to evaluate road usage charge proposals by ensuring fair fees for EV drivers.

Institutional Barriers

Charging infrastructure development can face delays due to challenges caused by local permitting
processes, timelines, supply chain constraints for electrical equipment and regulatory procedures
for grid-side utility upgrades, among other institutional barriers. Significant coordinated institutional
efforts are needed to reduce barriers to developing accessible charging infrastructure. State and local
efforts to develop EVSE need to be complementary and not duplicative, ensuring transparency and
coordinated planning efforts. Securing permits to build chargers, construct sites and connect to the grid
can require months (sometimes years) of planning, making it difficult to execute projects in a timely
manner. Additionally, protocols for fleet electrification are lacking, specifically policies regarding take-
home vehicles, charging on the clock, right-to-charge and a hierarchy of charging rights, which can cause
confusion for employees.

Lack of clear and consistent EV signage creates difficulty locating and subsequently using chargers.
Real or perceived lack of cost transparency to charge, in comparison to high-visibility gas station signage,
also deters widespread EV adoption, as do perceptions that electricity costs on average exceed gas prices
(though these assumptions are inaccurate in Washington97).

There is a lack of community support and buy-in due to perceived or real safety concerns; insufficient
data for personal, consumer and business decision-making; questions about range, weather and towing
capacity; and real or perceived concerns regarding the ethical and environmental impacts of material
and extraction recycling. Tackling the “FUD” principle (fear, uncertainty, doubt) when it comes to EVs means
assuaging safety concerns, articulating the benefits of EVs and addressing both real and perceived biases.
Some pedestrians and bicyclists have safety concerns regarding sharing roadways with EVs, which can be
heavier than their ICE counterparts due to the large batteries. Maintenance workers will need to learn to work
with new technology, and fire response personnel will need to learn how to safely deal with EV fires. Previous
hasty, uncoordinated rollouts by technology companies of e-bikes and e-scooters have led to persistent
negative perceptions of e-micromobility sharing programs and battery safety.98

Lack of data also contributes to the FUD principle for decision-making for both consumers and businesses.
As mentioned in other barriers listed in this section, there is concern regarding battery range during
different weather conditions and under various towing capacities. Data gaps regarding charging access and
costs can also make it difficult for consumers and businesses to support the transition to EVs.

97 Michael J. Coren, “Is It Cheaper to Refuel Your EV Battery or Gas Tank? We Did the Math in All 50 States,” Washington Post,
(August 14, 2023).
98 Nikolaus Lang et al., “Putting Micromobility at the Center of Urban Mobility,” Boston Consulting Group, (May 20, 2022).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 94
Infrastructure is installed in a transit bus depot in preparation for high-powered electric bus chargers.

Additionally, consumers have both real and perceived concerns regarding ethical and environmental
impacts of material extraction necessary for the manufacturing of EVs.99 The need to establish
infrastructure to support battery recycling could create additional challenges.

This overarching dynamic is worsened by a confusing policy and incentive landscape, and significant
information gaps at the primary point of sale (dealerships).

A limited workforce means a lack of technicians to service EVs, and of engineers, electricians and
technicians to install and maintain EVSE and related grid infrastructure. The EV and EVSE workforce,
although growing in Washington, does not meet the number of technicians in demand for EV maintenance,
EVSE installation and maintenance, and grid infrastructure upgrades. As fleets electrify, the skills needed
to service EVs will likely require new training for existing maintenance staff, additional staff generally, and
external contracting.100 Ensuring an inclusive and just transition for Washington’s ICE mechanics and wider
workforce is also critical.

Charging infrastructure, especially for MHDVs, will require significantly more real estate than diesel
fueling. Chargers, especially MHDV chargers, take up a significant amount of real estate, and their needs must
be balanced with competing state interests such as habitat preservation and housing. Charger sizes typically
increase with the size of the vehicles they power. Electric buses, for example, demand considerably larger
charging equipment and more space, and can require depot expansion by as much as 40%.101

99 Alessandra Carreon, “The EV Battery Supply Chain Explained,” RMI, (May 5, 2023).
100 Sclar et al., “Barriers to Adopting Electric Busses.”
101 Sclar et al., “Barriers to Adopting Electric Busses.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 95
Priority Policies

In 2022, the Legislature directed the EV Council to determine how Washington could meet its 2030 EV target,
ensure market and infrastructure readiness for an electric transportation system, and ensure the TES
benefits vulnerable populations and overburdened communities. The Annual Report contains an annual
report that shows the progress state agencies have made since the Legislature created the EV Council. The
report shows that Washington has already adopted some critical policy levers, such as ACC II and ACT, that
will benefit from supporting policies to ease the path to EV adoption. Other policies need to be established
or modified to ensure equitable distribution of benefits.

The EV Council must additionally consider its role in advancing strategies to reduce the transportation sector’s
GHG emissions. Washington will need to take a number of actions to reach its ambitious goals of reducing
transportation sector GHG emissions from 40.3 MMT CO2e annually in 2019 to roughly 20 MMT CO2e or below
annually by 2030, in keeping with the state’s 2030 emissions limit. Electrifying on-road vehicles, which today
account for 58% of Washington’s transportation sector emissions, is a key opportunity that can be pursued
swiftly and equitably and will further benefit from Washington’s low-carbon electric grid. This is especially
true for LDVs, which were responsible for 40% of transportation sector emissions in 2019 and are further
ahead in EV technological advancement than heavier on-road vehicles.

Notably, reaching Washington’s mandate of 100% electric LDV adoption by 2035 is critical but
insufficient to reduce enough GHG emissions attributed to the transportation sector by 2030, and
the state would benefit from considering opportunities beyond on-road vehicle electrification. Policy
recommendations are therefore divided into two sections.

Cars drive through downtown Seattle at dusk.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 96
Policies in Part I, Achieving the Strong Electrification Scenario, are designed to enable the assumptions
built into the S3 Strong Electrification Policy scenario described in Chapter 4, which assumes the state
adopts a suite of supporting policies to encourage adoption of on-road EVs, and additionally includes
policies to ensure this scenario can be met equitably. The policy recommendations span six areas:

• Consumer Education and Capacity Building explores state actions to ensure residents and
businesses have the information and resources they need to make this transition easily and
confidently, and that local and state government, as well as CBOs, have the resources to support
their constituents.

• Charging and Utility Infrastructure considers how to scale deployment of EVSE and ensure people
have the means to charge their vehicles when they need to at a convenient, safe and accessible
location; costs and benefits of charging are distributed equitably; charging is reliable and resilient; and
the grid is prepared to handle the increased demand.

• Light-Duty Passenger Vehicles reviews opportunities to accelerate electric passenger vehicle
adoption through financial support, state leadership and other strategies.

• Medium- and Heavy-Duty Vehicles examines strategies to accelerate electric MHDV adoption through
targeted policies that ease financial barriers to getting more EVs on the road.

• Electrifying Micromobility considers how to expand affordable access to e-bikes and integrate them
with electrified public transit.

• Workforce Development details actions the state can take to ensure Washington’s workforce develops
the skills and training necessary to support work on EVs, charging infrastructure and the grid; requisite
training includes strong labor standards; and that the transition to a low-carbon transportation sector
fuels the growth of Washington’s clean industrial economy.

Policies in Part II, Closing the 2030 Transportation Greenhouse Gas Emissions Gap, detail additional
strategies the state should consider beyond on-road vehicle electrification to reduce GHG emissions from
the transportation sector in alignment with the state’s 2030 emissions limit. Such opportunities include:

• Reducing VMT and vehicle weight.
• Additional on-road vehicle strategies, targeted specifically to reducing GHG emissions.
• Non-road transportation strategies, including aviation, marine and ports.
• Focusing state planning and implementation efforts on meeting the 2030 emissions limit.
Collectively, Washington can take action on several fronts to ensure its residents, businesses and workforce
are supported in swiftly adopting EVs and deploying charging infrastructure at scale. The state can also
pursue additional strategies to steepen the curve of GHG emissions reductions.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 97
Part I – Achieving the Strong Electrification Scenario

1. Consumer Education and Capacity Building

• Educate and engage Washington residents and businesses about the opportunities and benefits
of transportation electrification. As shown in the TES analysis, and specifically the S3 Strong
Electrification Policy scenario, a comprehensive education and engagement strategy is essential to
ensure the general public is aware of the transportation electrification resources and opportunities
available and takes action. This should build on the Education Plan and the Engagement Plan102
and integrate existing local resources, such as the Municipal Research and Services Center and the
Washington State University (WSU) Green Transportation program.

○ (1.1) Develop a Transportation Electrification Education and Resource Center: In coordination
with relevant agencies, Commerce should develop and manage the Resource Center, starting with a
centralized Transportation Electrification website to provide clear information on incentives, grants
and programs offered by the federal, state and local governments; electric utilities; and community
organizations. This one-stop shop of incentives, including consolidated program requirements
and application processes, will increase ease of access and support enhanced understanding of
opportunities for Washington drivers, fleet managers and state funding applicants and recipients.
The website should also provide educational materials, resources and best practices for consumers,
dealers, auto and other original equipment manufacturers (OEMs), fleet managers and local
implementers. This could include guidance for consumers regarding at-home charging and one-
on-one technical assistance for local implementers. This could also include something similar to
CARB’s Cal Fleet Advisor program, which provides funding assistance, resources, planning and other
support for fleet operators that are working to purchase ZEVs.103 Commerce is currently considering
developing a website to help users navigate available energy rebates for the clean buildings
programs, and could consider expanding the website to also include information on transportation
rebates, thereby establishing a clean energy clearinghouse website. The Resource Center should be
developed by leveraging existing resources such as WSU Energy Office, where possible.

Once a central website is built, the Resource Center should have staff or consultants in relevant
funding programs, electric utility planning and operations, or transportation planning organizations
assigned to each region in the state. This is a similar structure to ReCharge Colorado within
Colorado’s Energy Office.104 Commerce should request preliminary funding to establish the Resource
Center, and more funding will be needed from the Legislature to staff and maintain the Resource
Center in the future. Resources should be available in the languages spoken in those regions.

○ (1.2) Promote public information campaigns about financial incentives for and the benefits
of getting an EV: Federal funding for IRA tax credits105 is unlimited, meaning a state can access
consumer- and commercial-facing incentives to the extent it can get its residents and businesses to
use them. Accessing incentives will become easier starting in 2024 when dealers will begin providing
the Clean Vehicle tax credit at the point of sale, regardless of a consumer’s tax liability. Commerce

102 Additional education and engagement strategies are to be further developed in the Education Plan and the Engagement Plan.
103 California Air Resources Board, “Medium- and Heavy-Duty Fleet Zero-Emission Vehicle Purchasing Support (SB 372),”
(n.d.).
104 Colorado Energy Office, ReCharge Colorado, (n.d.).
105 IRS, “Credits and Deductions Under the Inflation Reduction Act of 2022,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 98
Prospective EV drivers inspect an electric vehicle at a "ride and drive" event.

should invest in a robust marketing campaign directed at consumers and dealers in order to
increase Washington’s share of federal dollars and make EVs more affordable. Public information
campaigns should include facts about the efficiency of available EVs and should rely on hyperlocal
messaging and messengers to the maximum extent possible.

In addition, the Legislature should pass a bill authorizing the DOL, as an extension of its oversight
of dealerships, to create and enforce rules requiring dealers to display tax credit and incentive
information and to provide it to potential buyers.

○ (1.3) Support ride-and-drive events: The previously described Resource Center within Commerce
should support ride-and-drive events that anyone can attend and test drive an EV to facilitate an
increase in business and consumer awareness and understanding of EV technology. These events
are an important tool for providing people hands-on opportunities to experience EVs. This support
can take the form of leveraging efforts from private entities already hosting such events in order to
reduce public costs, along with partnering with CBOs to host events in the communities they serve.

• Increase government capacity to coordinate and streamline program design, assess equity
outcomes and equity-oriented initiatives, and support municipal capacity for grant funding
distribution for EVs, EVSE and complementary programs. To ensure the equitable transition to
transportation electrification and to support its residents, businesses and municipalities, the state can
provide additional guidance, resources and internal capacity to simplify and encourage EV adoption,
build out associated supporting physical and operational infrastructure, and measure success.

○ (1.4) Standardize and streamline government EV and EVSE program applications: Commerce
staff assigned to EV Council responsibilities should work together with other agencies to
simplify access to government funding in support of EV and EVSE adoption by standardizing and
streamlining program applications and program design administered by different agencies as

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 99
applicable. For applications, this would ideally take the form of a universal application in which
applicants could upload supporting material once for all relevant state programs. In lieu of proof of
qualification at the point of sale, Commerce should consider self-attestation of LMI eligibility with
sample audits, following the lead of other state agencies and electric utilities.

To streamline reporting and data collection requirements for EVSE, the EV Council should coordinate
across agencies, municipalities, private entities and stakeholders with respect to technical-,
industry- and consumer-facing requirements for EVSE (refer to the Charging and Utility Infrastructure
section). It should also coordinate and streamline data collection, reporting and standardization.

○ (1.5) Fully fund agency staffing needs to implement the TES: The Legislature should direct full
appropriate funding to agencies for staffing to carry out the responsibilities identified in the TES.
Agencies should work with urgency to recruit and fill positions as funding allows.

○ (1.6) Provide block grants to increase CBO staff capacity: Commerce should provide new funding
specifically to support low-income service provider and CBO staff capacity for transportation
electrification project planning and site design, potentially as part of a broader neighborhood-
led decarbonization program. This funding is essential to (1) create better access to increasingly
large climate funding programs for overburdened communities and vulnerable populations, and
(2) establish an information feedback loop between community leaders and state agencies to
better inform large program design decision-making. The feedback loop will also provide agencies
a channel to inform communities about funding opportunities, and for communities to inform
agencies about clean energy siting priorities. Consider designing the grants similarly to the EPA’s
Climate Pollution Reduction Grants, such as providing guaranteed funding for planning and
assessment and competitive grants for implementing specific programs.

○ (1.7) Monitor equity indicators and measure outcomes: WSDOT should be funded to implement
a transportation equity measurement tool, starting with a baseline assessment. The tool should
include a Transportation Security Index (similar to the Food Security Index, which identifies food
deserts) to assess how people’s access to and utilization of transportation modes changes over time
as the state begins to implement the TES.

The Legislature should fund the DOH to estimate and model health benefits for inclusion in TES
metrics. Estimates should be based on TES modeled air pollutants reductions.

In Seattle and Tacoma, two existing air-monitoring locations adjacent to I-5 use EPA-approved air
monitors and establish a benchmark for high-quality air monitoring near highways. The information
from these locations can be used to accurately characterize air quality improvements that result
from fleet electrification.

As noted both during TES engagement efforts and through current work at Ecology to expand
the existing air quality monitoring network in overburdened communities highly impacted by air
pollution, there is a desire for a greater understanding of air quality in such neighborhoods. Ecology
should evaluate how to best obtain information on traffic-related air pollutants along additional
high-traffic road segments, particularly those in overburdened communities highly impacted by air
pollution. Ecology should consider community input in this evaluation and any potential expansion
of its existing air-monitoring network. These outcomes may be achieved through Ecology’s existing
efforts to conduct outreach and engagement and to characterize air quality in overburdened

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 100
A family crosses the street in Seattle Department of Transportation gear.

communities highly impacted by air pollution. Ecology should bring a budget proposal to the
Governor’s Office if funding needs are demonstrated by the review, including for expanded
engagement with overburdened communities.

Commerce’s staff should coordinate with the other EV Council agencies to track these and other
equitable electrification-related metrics, such as EV adoption rates by race, income and geography,
to assess the effects of transportation electrification–related projects, programs and opportunities
on overburdened communities and on equity outcomes moving forward.

2. Charging and Utility Infrastructure

• Prepare the grid to handle the increase in EV charging demand.
○ (2.1) Require utilities to develop public-facing electric capacity maps: The state should pass
legislation requiring consumer-owned electric utilities — and the UTC should require IOUs — to
post public-facing grid “hosting” capacity maps on their websites and provide the underlying data
layers to WSDOT, Commerce and UTC so they can be added to existing tools (such as WSDOT’s
ZEV Mapping and Forecasting Tool) without compromising data security. Although this action
is important for helping project planners identify sites for EV charging, maps should also show
capacity for other DERs. Commerce may need to adopt rules to implement this legislation.

Maps should show electrical capacity to power EV charging at the distribution feeder level. This
initiative could be a challenge for under-resourced consumer-owned utilities and will likely require
state funding in order to be implemented. The Legislature should include funding for public
power associations or a similar entity to do this work on behalf of their member utilities or utility
customers below a certain size threshold. Maps must be updated at least once a year and include
clear contact information and responsive technical assistance to allow EVSE implementers to verify
accuracy. Commerce and the UTC should work with the Attorney General’s Office Public Counsel
Unit and other ratepayer advocates to ensure mapping requirements are as cost-effective as

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 101
possible so planning benefits outweigh costs to ratepayers. Complementary policies should be
evaluated to ensure available capacity benefits all users, not just early adopters.

○ (2.2) Replace the statutory rate impact cap with ratepayer benefits and affordability
protections: Repeal the annual rate impact cap under RCW 35.92.450,106 RCW 54.16.430107
and RCW 80.28.360108 that limits how much electric utilities can spend on transportation
electrification programs using ratepayer dollars. The cap was originally intended to protect
ratepayers from broadly covering programs that only benefited early adopters. However, with
EVs now making up close to 20% of all new vehicle sales, the cap is too restrictive to allow
utilities to meet the needs of their customers. Instead of a broad cap, the Legislature should:

■ Require utilities to designate a minimum percentage of their transportation electrification
portfolio to provide direct benefits to low-income customers.

■ Replace the incentive rate of return for IOUs with performance incentives currently under
development in Docket U-210590 to support equitable outcomes.

■ Consider additional measures, as necessary, to promote affordability. This is consistent
with concerns expressed by stakeholders regarding rising electricity prices, especially for
overburdened communities and vulnerable populations.

■ Provide the additional funding necessary for agencies to implement changes to RCW
35.92.450,109 RCW 54.16.430110 and RCW 80.28.360.111

○ (2.3) Identify areas for increased grid investment: The Energy Resilience and Emergency
Management Office (EREMO) within Commerce should cross-reference utility outages of
significant duration in overburdened communities and incorporate the energy risk and
vulnerability information from the state energy security plan. This analysis should also
determine the unique grid upgrades needed for rural communities to transition to electrified
transportation. This assessment can also support digitalization via smart grid investments,
time-variant charging (i.e., reducing charging prices at certain times of day), managed charging
and other load management strategies. Both of these investments should enhance the utility
system’s resilience as EV adoption reaches critical mass in future years.

This analysis should actively involve consumers and provide fair compensation to them for
supporting grid management needs. The UTC has led on requiring such work with several IOUs
incorporating analysis into their clean energy implementation plans (CEIPs) and settlement
agreements. This initial progress should be scaled up for all utilities through integrated resource
plans (IRPs) and CEIPs.

106 RCW 35.92.450 – Municipal Utilities – Electrification of transportation plan – Considerations – Incentive programs
107 RCW 54.16.430 – Powers – Electrification of transportation plan – Considerations – Incentive programs.
108 RCW 80.28.360 – Gas, Electrical, and Water Companies – Electric vehicle supply equipment – Capital expenditures –
Incentive rate of return on investment.
109 RCW 35.92.450 – Municipal Utilities – Electrification of transportation plan – Considerations – Incentive programs.
110 RCW 54.16.430 – Powers – Electrification of transportation plan – Considerations – Incentive programs.
111 RCW 80.28.360 – Gas, Electrical, and Water Companies – Electric vehicle supply equipment – Capital expenditures –
Incentive rate of return on investment.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 102
○ (2.4) Evaluate time-variant electricity pricing and EV charging management: IOUs and a few
consumer-owned utilities have started using time-variant electricity pricing for EV charging and
voluntary managed charging programs. The Legislature should require that all consumer-owned
electric utilities with more than a specified number of customers develop and offer managed
charging programs. The UTC should continue to require IOUs to do the same. Managed charging
programs should be technology and hardware agnostic to offer flexibility to develop the best
solution for affected communities. As part of these efforts, the state should monitor developments
in both V2G and battery storage technology and opportunities and consider if they could be
leveraged as an extension of managed charging strategies, for example, through the use of virtual
power plants (VPPs), which aggregate multiple DERs to provide energy, capacity and other grid
services. Commerce should compile best practices from initial programs to inform a statewide
requirement for managed charging programs and time-variant pricing. These programs may be
included in demand response targets in utility CEIPs for compliance with the CETA. Reducing
impacts on the power system is complementary to the state’s commitments to restoring salmon
populations and improving salmon migration.

• Offer and explore additional tools for rapid EVSE deployment.
○ (2.5) Support planning and building necessary utility-side charging infrastructure: UTC and
Commerce should enable utilities to develop “make-ready” infrastructure programs, which cover
partial or full costs of electrical infrastructure, assessments and equipment to accommodate EV
charging. UTC and Commerce should also enable utilities to own and operate EVSE in circumstances
where the private EV service provider (EVSP) market is unlikely to meet customer needs. This may
include incorporating on-site DERs in appropriate locations. Make-ready investments for customers
need to ensure that customers benefit from the investment, and that there is no cross subsidization
between residential and commercial customers.

This should include passing legislation requiring and ensuring equitable funding for proactive grid
planning to help utilities scale transportation electrification. Industry leaders believe one of the
greatest risks to the EV transition will be utility-side infrastructure bottlenecks. Consumer and fleet

Workers prepare to install EV charging infrastructure in a parking lot.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 103
demand for EVs is increasing, OEMs are working on increasing supply, and EVSPs and other EVSE
implementers are anticipating where charging demand will be. To meet this new demand, distribution
and transmission upgrades will be necessary in certain locations, as indicated by modeling results.
This need for upgrades is an especially large concern for MHD charging sites, such as fleet depots
and along freight corridors. Because Washington’s drayage truck industry is predominantly
owned by small enterprises, cost-effective charging infrastructure that meets their needs should
be prioritized. The state should identify and recommend sites where publicly available charging
should be developed and recommend proactive grid development to accommodate it. According
to the baseline modeling for the TES (S1 Baseline scenario), demand for MHD charging is
forecasted to grow exponentially from 2023 to 2035, from fewer than 250 ports to over 7,500. MHD
deployment to meet the ACT rule (and possibly ACF) levels will simply not occur without adequate
new charging infrastructure.

Building on Commerce’s current utility-side EVSE cost assessment, which is due in November
2024, the state should give clear authority to utilities for planning and building infrastructure in
accordance with anticipated EV charging demand. To the extent possible, Ecology could share
nonproprietary fleet data to best equip the utilities to plan accordingly. Guidance should be
developed to allow proactive infrastructure investments to support transportation electrification
in areas where EV adoption and EVSE analyses highlight impending needs. Alternative financing
mechanisms to offset costs to customers should be considered, such as leveraging the U.S.
Department of Energy’s Loan Programs Office programs. In tandem, WSDOT and Ecology should
develop a process for updating the list of eligible expenditures by utilities with CFS revenue.

○ (2.6) Explore expanding public utility line extension allowances for public EVSE charging:
IOUs may provide allowances to commercial customers that require line extensions to serve EVSE.
However, consumer-owned utilities do not currently offer line extension allowances, making it
harder for commercial customers to afford the up-front capital costs for projects. Commerce should
convene consumer-owned utilities to discuss opportunities to better enable their customers to
implement EVSE projects, and subsequently work with the Legislature to clarify or authorize, as
appropriate, such measures to support EVSE build-out.

○ (2.7) Explore the development of a publicly backed financing entity to provide innovative
financing mechanisms: Green banks in other parts of the country support a variety of different
initiatives and projects, including providing financing mechanisms for EV charging infrastructure.
A regional financing entity established through the IRA’s Greenhouse Gas Reduction Fund that
serves Washington businesses and organizations could, for example, provide support for a zero-
emissions trucker co-op, including low- or no-interest loans for electric trucks and associated EVSE.
As an example, Canada’s Infrastructure Bank recently made a CAD 220 million commitment to
finance more than 2,000 public fast-charging ports across Canada by 2027.112 A green bank or similar
publicly backed financing entity can assist in mitigating uncertainty in the rate of EV adoption and
subsequent charger utilization.

○ (2.8) Amend Clean Fuel Standard rules to allow capacity credits for private fleet depots: In order
to be eligible under this change from Ecology, projects would need to demonstrate a public benefit
(for example, improving air quality in overburdened communities) and serve two or more fleets.

112 “Canada Infrastructure Bank Marks Its First EV Charging Investment with a $220 Million Commitment to FLO,” FLO, (April
26, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 104
A row of electric vehicle chargers ready for use.

• Ensure benefits and costs of charging infrastructure are passed on equitably.
○ (2.9) Expand community charging programs through formula funding: Commerce is using the
first $69 million in community charging grants to fund chargers at multifamily buildings, in rural
and tribal communities, in underserved urban and suburban areas, at workplaces and for depot
charging. These have been identified as priority areas that require funding to add chargers. The
funding is being allocated through a competitive process that will take at least six months from
application development to contract negotiation. RMI analysis shows that in the preferred S3
Strong Electrification Policy scenario, the state will need to build approximately 1.3 million charging
ports by 2030, increasing to 3 million by 2035. If the state intends to distribute the funding required
to support the amount of EVSE installations indicated by RMI’s modeling, the state will need to
expedite its process for awarding funding.

Furthermore, Commerce currently receives funding through operating appropriations, which
require new appropriations when spanning biennia — an inevitable need for fast-charging projects
that take more than one year to complete. Formula grants would allow Commerce the flexibility
needed to award funding annually. Instead, Commerce should develop an equitable funding
formula that delivers the state’s share of funding based on (1) likely local public and private
investments, determined through factors such as area median income or county median household
income, current and projected EV adoption by county and existing EVSE; and (2) the approximate
range of funding needed as estimated in the preferred S3 Strong Electrification Policy scenario.

Feedback collected during the public engagement period noted that EVSE locations should be
prioritized based on their connection to non-driving modes and their ability to maximize utilization
to improve consumer experience (especially for TNC and rideshare drivers), limit disruption to
traffic patterns and bring significant savings to the state. Example locations include park-and-rides,
airports, transportation hubs, parks, libraries, hospitals and municipal buildings. This could also
include installing infrastructure to support a bring-your-own-cable structure, as appropriate.113
It is essential that charging infrastructure meets the unique needs of the local community (i.e.,
different solutions for rural populations) and that the level of charging meets the charging location’s
anticipated timing and demand.

113 EVBox, “5 Biggest Differences of EV Driving in the US,” (February 22, 2018).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 105
The formula funding structure and program design should be evaluated on a regular basis to
ensure it is having the intended effects and is not unintentionally skewing funding to areas with
minimal need. Applications for multifamily charging should specifically be assessed to ensure
residents benefit from lower-cost at-home charging (as opposed to being used to create paid
charging at the same rates as public charging or EV parking spots for high monthly fees). The EV
Council will discuss whether to expand this and other EVSE incentive programs to include private
entity applicants. Included in this discussion will be an analysis of how eligibility for different
incentive programs might differ based on their funding sources, and the state’s need to balance
public interest with ease of implementation.

○ (2.10) Ensure community partnerships are in place for charging infrastructure in
overburdened communities: Community benefit agreements114 with ongoing project assessments
should be required for publicly funded charging infrastructure above a specified size installed in
overburdened communities, as defined within the TES. Community benefit agreements should be
developed between the grantee (for example, an EVSP) and the local community and submitted to
the state as a stipulation for receiving funding. Community benefit agreements should be used to
ensure EV charging is holistically serving overburdened communities and vulnerable populations,
consistent with community input.

○ (2.11) Develop charging consumer protections and price transparency: Typically, residential
charging rates are lower than public charging prices, which could worsen inequities between those
who can charge at home and those who cannot. As a result, Washington residents are at risk of
experiencing price disparities that would predominantly impact overburdened and vulnerable
communities absent policy solutions. To better understand the extent of this issue and begin to
ensure equitable charging access, a suite of policy development actions are recommended.

■ The UTC should review and consider the application of RCW 80.28.320115 to require IOUs to
include caps for reasonable public charging rates in utility contracts with EVSPs while also
ensuring the economic viability of public charging projects.

■ Commerce and UTC, in consultation with the Attorney General’s Office, should periodically
assess prices for electricity as a transportation fuel for all residents, and, as necessary, pursue
actions to protect customers and eliminate financial disparities. Policies should, at a minimum,
seek to mitigate cost disparities between those who do not have access to home charging
(residential rates) and those who rely on public charging.

■ Commerce should explore the viability of alternative EV charging ownership models that
maximize economic benefits for overburdened communities and vulnerable populations.
Alternative ownership models should consider regional and utility partnerships that promote
administrative efficiencies and equitable outcomes.

○ (2.12) Relieve demand charges through alternative rates for EV charging: Commerce and
UTC, working with COUs and IOUs respectively, should develop model rate structures and conduct
outreach to support widespread adoption of EV charging rates across Washington. A demand

114 Community benefit agreements are contracts between community groups and private entities that require, in the case of EVSE,
that a certain percent of the proceeds generated from charging are funneled back into the local community or neighborhood.
115 RCW 80.28.320 – Gas, Electrical, and Water Companies – Regulation of battery charging facilities.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 106
A ribbon-cutting ceremony for a new EV charger, attended by WSDOT representatives.

charge is a charge paid by electricity customers on the basis of metered demand (i.e., required
electric power), typically for the highest hour or 15-minute interval during a billing period. Because
EV charging, particularly DCFC, can have low utilization but intervals of high demand, demand
charges can make it difficult to cost-effectively operate EV charging. Time-variant electricity rates
provide an alternative to demand charges that help shift charging to off-peak periods while ensuring
utilities can recover costs through rates without disincentivizing EV charging and also adhering to
the principles of cost causation. Alternatively, the state could explore rate design relief models that
scale with utilization, such as those in place in New York and Massachusetts.

○ (2.13) Carefully consider electricity rates: The Legislature, UTC and Commerce should carefully
consider how to sequence the implementation recommendations in this section of the TES to avoid
spikes to electricity rates. Complementary programs may be useful to reduce system costs, and
partnerships between Commerce, UTC, Bonneville Power Administration, Northwest Power and
Conservation Council, and utilities should be explored to evaluate energy efficiency opportunities.

• Ensure the EVSE build-out process is informed by communities, streamlined and consistent.
○ (2.14) Community-informed EVSE siting: In coordination with HEAL Act staff, agencies with
charging funding programs should co-develop guidance for community-centered siting for EVSE
infrastructure and require that utilities and EVSPs use the guidance through contract language. The
guidance should include best practices for collaboration and co-development between utilities/
EVSPs and community entities, including through information loops developed by CBO block grants
recommended in Consumer Education and Capacity Building. Agencies should work together with
utilities and EVSPs when making community-level requests for input to avoid burdensome and
duplicative requests.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 107
○ (2.15) Develop model site designs: Commerce should pull together industry and accessibility
experts and local planners to develop statewide model site designs for different types of EVSE
deployments that can be used by local implementers. The use of model site designs does not need
to be a requirement but could aid in speeding up site design and permitting processes.

○ (2.16) Analyze and reduce grid interconnection timelines for EVSE: In anticipation of a
significant uptick in EVSE development, Commerce and UTC should conduct a study of how long
it takes on average for EVSE installations to complete the utility service and local government
permitting process, as well as the steps necessary to obtain project approval. The study should
also consider interconnection timelines for bidirectional charging (or V2G). This study will help
streamline the project approval process and identify bottlenecks so the state can work to address
them accordingly. With this insight, the state can set required turnaround times for utility service
and local government permit approvals. Utility service approvals should consider existing service
approval requirements and practices such as for rooftop solar and residential service. Turnaround
times should account for technical requirements for service at the site for the utility to approve
service in a specified number of days. There may be additional factors (e.g., grid capacity,
environmental justice) to consider in developing an extension request process. Recent work on
these topics published by the Sustainable Energy Action Committee, the Interstate Renewable
Energy Council and RMI can serve as best practices.

As part of this analysis, Commerce and the UTC should learn from implementation of California’s
recently passed SB 410, 116 which requires by September 30, 2024, that the California Public Utilities
Commission set reasonable average and maximum target times for connecting new customers to the
grid and has corresponding reporting requirements. Findings from California should inform whether
Washington adopts similar policies.

○ (2.17) Develop recommendations for building codes and corresponding parking and
charging requirements: Commerce, in coordination with the Department of Enterprise Services
(DES), the Labor & Industries Department (LNI), WSDOT and other agencies, should review current
building code EV charging requirements and develop a 2024 building code cycle proposal for EV
charging requirements for all relevant codes, including technical requirements in alignment with
the National Electrical Code. The proposal should cover new buildings and renovations, include
requirements for MHDV charging at appropriate locations, allow flexibility for the type of charging
required at large parking areas, and align with TES modeling. The agencies should assess possible
improvements to requirements for Americans with Disabilities Act (ADA)–compliant EV charging
and include requirements for secure parking with adequate access to charging outlets for a
variety of e-bike models.

○ (2.18) Increase ability to install EV chargers in public rights-of-way: Where possible, electric
utilities and local jurisdictions should identify barriers to and encourage the installation of EV
chargers in public rights-of-way, including the dual use of light poles, utility poles and other existing
electrified infrastructure. Careful consideration will be needed to ensure charging at light poles
does not contribute to or create ADA accessibility issues for pedestrians or individuals accessing
chargers, or create visual obstacles at street corners. Commerce’s local government division should
support the development of model ordinances to support this initiative.

116 SB 410 – Powering Up Californians Act.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 108
• Ensure EVSE are reliable and resilient.
○ (2.19) Establish standards for EVSE reliability: It is essential that EVSE are reliable and resilient
and composed of quality chargers. To achieve this, Commerce, in partnership with WSDOT, should
adopt statewide publicly accessible EVSE reliability standards, including uptime standards and
charging power rates, that help improve the customer experience, which could include requiring
preventive maintenance and field monitoring. Commerce should evaluate existing reporting
requirements and modify as necessary to ensure data is being tracked by the appropriate state
agencies for all publicly accessible charging ports. When feasible, reporting requirements, such
as tracking uptime, should be aligned with federal minimum standards, state agency standards
adopted by DES and SEEP, and other programs that have similar requirements to measure and
report these metrics. EVSE operators should implement effective systems for consumers to report
problems with chargers, and individual chargers should have a unique identifier number or code
so problems can be reported more effectively and tracked over time. Commerce should also set a
standard (including a time frame) for how quickly chargers will be repaired. Reliability standards
should measure incidents of vandalism and other physical damage to inform best-practice EVSE
security measures.

○ (2.20) Establish ongoing maintenance agreements for publicly funded projects: Commerce,
WSDOT and other applicable agencies should require all new projects that use public funds, including
any projects in which state or local agencies or public utilities play an administrative role in funding
deployment, have either ongoing maintenance agreements or retainer contracts with a local or
regional contractor to meet the maintenance demand. Possible accountability structures include
(1) partial clawback of public funds used to finance the charger, (2) disqualification from future
public EVSE funding, (3) financial penalty written into the contract and (4) an incentive retainage
awarded annually based on achievement of minimum uptime standards. WSDOT, in partnership with
Commerce, may also consider reserving a pool of funds to bring down costs of multiyear maintenance
contracts, and the establishment of a list of qualified maintenance providers.

Electric vehicles are displayed at an EV charger.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 109
○ (2.21) Plan for EVSE disaster readiness: Commerce’s EREMO, in partnership with other key
stakeholders, should develop an emergency response action plan for the prioritization of EV
charging during an energy supply disruption, in line with current planning for fuel supply disruptions
at gas stations.

○ (2.22) Co-locate renewable energy and battery storage with charging: Agencies with EVSE
funding programs and regulatory authority should encourage the deployment of renewable
infrastructure and batteries together with EV chargers when connection to the electric grid is
either infeasible or less cost-effective, or when charging from battery storage is essential for load
management. Although co-location should not be required for all charging infrastructure, the state
should list renewables and batteries as an allowable expense under all grant funding opportunities.
Charging locations where load shifting or managed charging are less feasible may be better for
the co-location of renewables and battery storage, given their ability to help offset peak demand.
Renewable energy system co-ops and localized governance and ownership models should be
encouraged where feasible, especially in overburdened communities.

○ (2.23) Evaluate cybersecurity threats to drivers and their EVs: EREMO should evaluate threats
that could disrupt transportation operations or compromise personally identifiable information,
including threats related to EVs, charging infrastructure, network companies and utilities.

• Continue to fund and implement highway fast charging.
○ (2.24) Continue funding WSDOT’s ZEVIP grant program to provide support for charging
along state routes: This program provides funds to nonprofit organizations, tribes and other
governmental organizations in cooperation with private-sector partners for EVSE along state routes
in Washington. In the 2023–25 biennium, ZEVIP awarded 14 grants for 32 EVSE sites, totaling $30.2
million. The program received applications for $49.1 million, leaving almost $20 million in viable
projects unfunded.

○ (2.25) Use the National Electric Vehicle Infrastructure (NEVI) Formula Program to fund EVSE
along interstates and highways: FHWA has approved Washington’s Electric Vehicle Infrastructure
Deployment Plan and its first annual update. The EV Council oversees development of this program.
WSDOT will administer approximately $71 million in federal NEVI funding over five years. NEVI funds
must meet federal requirements, including:

■ Minimum of four 150 kW combo charging system DCFCs per site

■ Site power capability no less than 600 kW

■ 50 miles between sites along designated alternative fuel corridors within one mile of the highway

• Ensure that all Washington residents can access charging easily.
○ (2.26) Publish and maintain the ZEV Mapping and Forecasting Tool to provide information
to support utility and EVSE investment decisions: WSDOT is developing the ZEV Mapping and
Forecasting Tool in close coordination with Ecology, Commerce and the Office of Equity. The tool
will be available in 2024. Census tract–level data will include EV registration numbers by vehicle
class, EVSE stations, road networks, and traffic levels, and population, employment, health,
environmental and socioeconomic data. The tool will use, and if needed build on, TES modeling to
forecast vehicle populations and derive associated charging infrastructure and electricity needs.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 110
○ (2.27) Develop and implement reporting requirements to assess charging installation progress
and provide better information to drivers: The Legislature should provide rulemaking authority
to Commerce to, in coordination with California and other states, require owners, operators and
infrastructure developers of public charging and electric utilities that develop private charging to
report information needed for the state to assess progress on charging build-out and to support
WSDOT’s ZEV Mapping and Forecasting Tool.

○ This authority should also include the ability to require EVSPs to share real-time data free of charge
with each other and with third-party application developers so the public can conveniently access
availability information in mobile navigation apps. Requirements for shared real-time data should
be limited to information drivers need to find and use chargers (for example, number of charging
plugs available, power level, price and parking restrictions).

○ (2.28) Standardize EVSE signage: The Legislature, based on recommendations from WSDOT and
Commerce, should modify RCW 46.08.185 117 to increase EVSE visibility and require installation of
consistent signage. Consistent FHWA signage should be installed on Washington state roads and
rights-of-way. Road users should be able to locate major charging hubs along highways by using
consistent wayfinding signage and not need to use an app, although the state should work with
mobile navigation apps to ensure drivers can easily use them to find charging.

○ (2.29) Electrify truck parking at ports: Commerce, Ecology and WSDOT should work with ports
to locate truck parking in industrial areas away from residential zones to minimize the effects of
trucking activities on neighboring communities. Allocating parking will require coordination with
local jurisdictions. These locations should provide overnight truck parking that is secure and access

The Port of Seattle is shown from an aerial view.

117 RCW 46.08.185 – General Provisions – Electric vehicle charging stations—Signage—Penalty.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 111
to L2 and DCFC charging stations for different charging needs. Electrifying truck parking at ports will
be expensive, and because parking is already limited, it is likely that additional parking will need to
be added at ports to achieve electrification. The state should conduct additional assessments to
ensure that charging infrastructure is designated and designed to meet port needs effectively.

○ (2.30) Develop increased public charging for MHDVs: The state should fund increased public
charging for MHDVs through NEVI, ZEVIP and other programs to increase the potential range for MHDVs
and decrease range anxiety. Depot charging will be funded in conjunction with incentives for MHDVs.

• Ensure that all Washington residents can access charging equitably.
○ (2.31) Make EVSE accessible: Agencies with EVSE funding programs and regulatory authority
should evaluate EVSE standards under WAC 16-662-200,118 16-662-210,119 16-662-215120 and 16-662-
220,121 and amend as necessary to expand financial services, increase access to affordable charging
and increase physical access to charging.

State agencies should evaluate complementary efforts to expand financial services and increase
access to affordable charging. For example, Commerce should work with the Washington
Department of Social and Health Services to explore opportunities to use Electronic Benefits
Transfer (EBT) cards that support EV charging at discounted rates and work with utilities to extend
bill discount rates to EV charging rates. The Department of Agriculture has an open rulemaking
on payment methods for EVSE, and the EV Council will ensure the outcome of that rulemaking is
incorporated into future policies and programs.

Additionally, the state should adopt statewide accessibility standards for new publicly accessible
EV charging to improve physical access to EVSE. Such standards could include establishing an
adjoining access aisle of 5 feet between spaces, ensuring charging infrastructure is not obstructed
by a curb and that the surrounding ground is clear and prohibiting unsecured cables on sidewalks
(which could pose a hazard for wheelchair users, pedestrians, people using walkers and so on).
Design recommendations from the U.S. Access Board122 and final Department of Justice accessibility
requirements can be used to inform standards for accessible EV charging.

○ (2.32) Encourage deployment of EV charging in multifamily housing: Commerce should
identify and recommend, and the Legislature should codify, consumer protections associated
with communal EV charging access at multifamily residences (e.g., price transparency, accessible
payment methods and language access) and establish enforcement mechanisms for charging
station operators, as contracted by the building owner and management. Commerce should ensure
EV infrastructure requirements do not mandate more parking than would otherwise be required for
the site. Commerce should also identify funding mechanisms that can be stacked to help offset the
cost of EV infrastructure built and maintained at affordable housing developments. Commerce and

118 WAC 16-662-200 – Agriculture marking and fair practices – Electric vehicle supply equipment compliance dates.
119 WAC 16-662-210 – Agriculture marketing and fair practices – Electric vehicle supply equipment payment method and fee
disclosure requirements.
120 WAC 16-662-215 – Agriculture marketing and fair practices – Electric vehicle supply equipment language requirements.
121 WAC 16-662-220 – Agriculture marketing and fair practices – Interoperability requirements related to electric vehicle
supply equipment.
122 “Design Recommendations for Accessible Electric Vehicle Charging Stations,” U.S. Access Board, (July 17, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 112
Electric vehicles charge under a canopy of solar panels.

UTC should engage utilities to prioritize their EVSE incentives for multifamily units in overburdened
and vulnerable communities.

○ (2.33) Develop renter protections regarding EV charging: The Legislature should pass right-to-
charge legislation to ensure that renters have a means of gaining access to charging infrastructure
at their residence or can add charging infrastructure at their residence, without the threat of penalty
or eviction. Right-to-charge legislation from other states123 and Washington’s HB 1793 (2022)124
should be evaluated to inform policy design. Affordability agreements should be considered when
allocating public funding to install EVSE at rental housing. As shown in TES analysis, ensuring that
an increasing share of multifamily homes — many of which are rental units — have access to home
charging has significant benefits in terms of both equitable outcomes and cost savings, by reducing
the size of the public charging network required.

○ (2.34) Enforce EVSE standards: To enforce all standards and program requirements, including
consumer protections, the Department of Agriculture should establish additional fees, using
existing statutory authority, in order to fund field visits and analyze data reported as part of funding
programs. Field visits and data collection will be essential to ensure EVSE meets standards and
reliability thresholds, and is accessible for Washington residents.

123 States that have right-to-charge legislation include California, Colorado, Florida, Hawaii, Maryland, New Jersey, New York,
Oregon and Virginia.
124 HB 1793 (2022) – Concerning EV charging stations in common interest communities.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 113
3. Light-Duty Passenger Vehicles

• Provide financial support for passenger vehicle drivers who are currently priced out of EVs.
Providing incentives and rebates for the transition to EVs will ease the burden of those who would
otherwise face challenges affording an EV while increasing the number of both new and used EVs in
the state, further driving down purchase prices.

○ (3.1) Launch Commerce’s targeted, up-front point-of-sale EV rebate program: Up-front rebates
have proven more effective than tax incentives for influencing EV purchases, and RMI’s modeling
shows that incentives are required to achieve necessary rates of passenger EV adoption. Up-front
rebates are necessary to ensure access for customers who do not have the capital to cover the
purchase cost of an EV and then wait for rebates through their tax return. Commerce is in the
process of developing a new, targeted point-of-sale rebate program with the intent to ensure
rebates are reaching people in communities that need them the most.

LMI residents should be specifically supported by point-of-sale light-duty EV rebates. In lieu of proof
of qualification at the point of sale, Commerce should consider self-attestation of LMI eligibility with
sample audits, following the lead of other state agencies and electric utilities.

Furthermore, the state should consider allowing low-income service providers to access this
rebate to subsidize EVs they use to serve the LMI community. Low-income service providers could
be defined as organizations that provide health, dental, social, transportation, financial, energy
conservation or other assistive services to LMI households, and the state could consider using an
existing program to verify eligibility, such as the Washington State Community Action Partnership.

Commerce should engage with TNCs and rideshare drivers to discern how to best support drivers to
transition to EVs through incentives and other support systems, if they do not qualify for incentives
under the parameters described above.

The state should also consider including additional restrictions, parameters, down payment
assistance and bonus incentives in the creation of this rebate. This could include, for example,
additional financial support for LMI drivers and qualifying high-mileage drivers to purchase
wheelchair-accessible vans and for small businesses in rural communities. The state could also
include caps on rebates for qualifying vehicles tied to cost or weight limits, in alignment with the
federal Clean Vehicle Credit. Additionally, Commerce should explore implementing a loan loss
reserve fund to make it possible for consumers without access to credit to participate. Similar
programs in California and other states have found very limited instances of defaults.

Finally, Commerce should consider offering comprehensive solutions that stack— rather than just one
of these possible design options — to increase affordability and reduce burdens for LMI residents.

○ (3.2) Create a state-supported low-cost leasing program with an EV equity objective: To provide
additional support for LMI communities — which make up a disproportionate 75% of Washington
drivers who buy used vehicles — Commerce is considering a social leasing program, wherein
individuals below an income threshold can lease EVs at an affordable monthly rate. Although low-cost
leases may be included as part of the point-of-sale rebate program, Commerce should explore an
expanded program if new vehicle leases prove effective at driving down used EV prices.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 114
An electric vehicle drives with a mascot on board.

○ (3.3) Establish financing and charging incentives supporting affordability: Commerce is
considering offering corresponding rebates to LMI residents for residential or discounted public EV
charging, and offering state-backed, low-interest-rate financing for the purchase or lease of both
the EV and charger. This could be paired with financial counseling and case management provided
by nonprofits.

○ (3.4) Expedite funding for Commerce’s EV incentive program: In the 2025–27 biennium, the next
governor should propose, and the Legislature should appropriate, the remaining funding in the
Electric Vehicle Incentive Account for Commerce’s EV incentive program. Commerce should obtain
an independent evaluation of the program to inform recommendations for continued funding for
equity-focused EV incentives beyond the 2025–27 biennium.

○ (3.5) Facilitate a used EV work group: Commerce should work with automakers and dealerships
to identify strategies that make the state the highest per capita net importer of used EVs and make
recommendations to the governor and Legislature for additional incentives beyond the existing
program.

○ (3.6) Continue funding WSDOT’s Zero-emissions Access Program (ZAP): WSDOT’s ZAP grants
provide funding for zero-emissions car-share pilot programs in underserved and LMI communities
that have limited access to public transportation. By making vehicles available to people who may
not be able to afford one, this program provides another way for people to access the places, goods
and services they need. Ensuring that car-sharing vehicles are electric means the communities using
these vehicles receive the benefits of electrified transportation. In addition, this program introduces
drivers to EVs. The pilot program is funded through 2023–25. The Legislature should work with
WSDOT on extending, refining and expanding ZAP from a pilot to a funded program.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 115
• Leverage the unlimited federal Clean Vehicle Credit with a broad-based expanded sales tax
exemption to signal consumer demand to automakers, incentivizing increased new vehicle
supply in Washington and further driving down prices.

○ (3.7) Extend and expand the state sales and use tax exemptions for BEVs: To maximize EV
adoption, the state needs to attract vehicle adopters across all incomes, geographies and use cases.
Sales and use tax exemptions are administratively more efficient than rebates, serve as a helpful
incentive for all EV adopters, and can be used in combination with IRA incentives to substantially
reduce up-front capital costs of vehicles. The Legislature should extend the exemptions’ effective
date, narrow eligibility to BEVs, and align its purchase price requirements with federal limits.
Additionally, DOL should work with dealerships to ensure they are providing information about EV
incentives to consumers.

○ (3.8) Increase consumer awareness of incentives: Commerce should make broad-based
incentives, especially the federal rebate, one of the key messages of the public information
campaign recommended in Consumer Education and Capacity Building. Every dollar spent on
increased awareness will be matched by significantly more in federal dollars and consumer cost
savings. A number of audiences should receive specific outreach, including LMI residents, small
businesses, rural communities and MHDV fleet owners.

• Pursue additional policy strategies to accelerate LDV adoption rates.
○ (3.9) Update ACC II to make EVs more affordable while also accelerating adoption rates.
Ecology, with consultation from Commerce, should work with CARB and other ACC II states to
change the ACC II credit structure to incentivize automakers to sell more affordable vehicles without
lowering overall ZEV sales percentages. For example, instead of an EV sale being worth one credit,
the EV sale itself would be worth 0.75 in isolation, with the vehicle’s specific price or efficiency
determining the rest of the credit. Alternately, the state could consider a standards-based credit
system where vehicle price standards are set and EVs that are more affordable than the standards
get additional credits and those that are less affordable get fewer. Additional topics for discussion
should include requirements for vehicles to have the technical ability to initiate a managed charging
session or send signals to incentivize managed charging, lower credit values for hydrogen FCEVs to
reflect their increased risk of power sector natural gas emissions because they need three to four
times more electricity than BEVs, and lower credit values for eligible PHEVs to reflect their higher
associated emissions.

○ (3.10) Work with CARB to explore further actions that can be taken to support equitable
and lower-cost access to EVs. California and states that have adopted California’s motor vehicle
emissions standards have considerable automobile market power. The state should discuss regional
approaches with CARB and Section 177 states to support equitable and lower-cost access to EVs for
LMI households and retain used EVs in California and Section 177 states.

○ (3.11) Develop a Clean Miles Standard for large employers: WSDOT, in consultation with Ecology
and Commerce, should work with the Commute Trip Reduction Board to examine strengthening
RCW 70A.15.4060125 and associated WSDOT rules to create a Clean Miles Standard for large
employers that reduces gasoline consumed by their employees for commutes.

125 RCW 70A.15.4060 – Washington Clean Air Act – Transportation demand management – Commute trip reduction board.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 116
A group of people share a ride.

Additionally, using California’s Clean Miles Standard as a model, Ecology should convene TNC
companies, taxicab companies, rideshare drivers and cab drivers to develop a recommended policy
for reducing emissions from those companies. Facilitating electrification of rideshare vehicles is
both an equity and an emissions reduction priority for the state. The Clean Miles Standard should
have specific targets for companies, such as GHG emissions reduction targets, and financial support
for high-mileage drivers so they can meet these parameters without undue financial burden,
especially because many of the drivers for these companies are from LMI and other overburdened
communities. It is essential that charging infrastructure is developed to effectively support drivers
impacted by the Clean Miles Standard, by installing sufficient charging at park-and-rides, airports,
transportation hubs, parks, libraries, hospitals and municipal buildings. In addition, it is crucial that
the charging level meets the charging location’s anticipated timing and demand.

Ecology’s GHG inventory team, in consultation with Commerce, should set targets for on-road
gasoline and diesel usage aligned with the state’s climate goals, 2021 SES and the TES by driver
segment and by vehicle segment to track progress on prioritizing high-fuel-consumption users.

○ (3.12) Allow automakers to sell direct to consumers for all ZEVs: The Legislature should pass
legislation allowing consumers to purchase any ZEV (LDV or MHDV) directly from automakers
without having to purchase through a dealership. Currently, Tesla is the only OEM allowed to
sell directly to consumers in Washington. Based on research by Atlas Public Policy126 and public
engagement findings by the RMI consulting team, the EV Council has determined this market
inconsistency creates an unnecessary barrier to EV adoption. The TES modeling shows the state can
no longer leave any policy option untapped to increase EV adoption, let alone one that comes with
only relatively minor administrative cost to implement.

126 “Estimating the Impacts of Direct-to-Consumer Electric Vehicle Sales,” Atlas Public Policy, (September 2022).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 117
The EV Council recognizes that franchise dealerships oppose this change and agency representatives
listened carefully to their perspectives throughout the engagement process. Dealerships are
important members of their communities and essential partners in the EV transition. Ultimately, this
recommendation comes down to empowering consumer choice and creating fair competition in the
automaker market.

• Provide state agencies with the commitment and resources they need to lead by example and
implement Executive Order (EO) 21-04, which calls for the electrification of state executive and
small-cabinet agency fleets. Reform state standards for local public fleet electrification and use
state procurement to make the transition more affordable.

○ (3.13) The next governor should reaffirm commitment to EO 21-04:127 Some specialty vehicles
without electric alternatives may require separate timelines, though gaps are rapidly being filled by
new models.

○ (3.14) Fund and support state agency efforts to implement EO 21-04: The Legislature should
ensure Washington is able to lead by example through codifying EO 21-04 and allocating funding
for ongoing staffing at state agencies to plan and implement strategies needed to achieve EO 21-04
targets. Additionally, the Legislature should provide funding for staff training on fleet electrification,
model availability and use of TCO models. The Breaking Barriers Collaborative128 cohort model
can be used as a reference for a program in a new state Electric Vehicle Resource Center within
Commerce.

DES and fleet managers should also continue to prioritize purchasing vehicles that qualify for 100%
of the federal Commercial Clean Vehicle Tax Credit when cost-effective and feasible from a vehicle
availability and deliverability standpoint.

○ (3.15) Provide charging for state fleets: Provide EV charging for the state’s fleet, state staff’s
personal vehicles and visitor vehicles at state properties. Leverage the recently completed DES
study129 on EVSE needs for cabinet-level state agency fleet electrification. The Legislature should
provide adequate funding for DES, SEEP and state agencies to complete this work and meet
requirements set in EO 21-04.

○ (3.16) Convene a local public fleet work group: The work group, led by the WSU Energy Office in
collaboration with Ecology, Commerce, DES and SEEP, should assess amending RCW 43.19.648130 to
align the statute with Ecology’s motor vehicle emissions standards (ACC II, ACT and, if adopted, ACF
or a similar policy). The statute should also support bulk purchasing of BEVs by the state on behalf
of local public fleets, similar to how WSDOT procures transit buses on behalf of transit agencies. The
state should continue to consider bulk purchasing for both state and local fleets to increase vehicle
model availability and affordability for specific duty cycles when appropriate.

127 EO 21-04 – Zero Emission Vehicles.
128 “Breaking Barriers Collaborative,” (n.d.).
129 Washington State Department of Enterprise Services, “Washington State Cabinet Agency Vehicle Fleet Electrification
Forecast,” (n.d.).
130 RCW 43.19.648 – Department of Enterprise Services – Publicly owned vehicles, vessels, and construction equipment –
Fuel usage – Advisory committee – Tires.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 118
High-powered electric bus chargers shown at a bus depot.

4. Medium- and Heavy-Duty Vehicles

• Adopt California’s motor vehicle emissions standards under the Clean Vehicles Program (ACC
I, ACC II and ACT). The Department of Ecology is required to do this through RCW 70A.30.010, 131
and therefore should continue to update existing standards and adopt any additional regulations by
reference considered by the agency to be motor vehicle emissions standards. These standards should
be used independently or in tandem with other existing state policies to accelerate the transportation
electrification transition.

○ (4.1) Pursue ACF adoption rates: Modeling for the TES shows a significant difference in electric
MHDV deployment and emissions impacts when ACF-required adoption rates are included, making
ACF the single largest emissions reduction electrification policy the state has yet to adopt. Ecology is
monitoring California’s actions to finalize ACF and will continue to update Washington’s motor vehicle
emissions standards as required by RCW 70A.30.010. Design and production of electric fleet vehicles
across all categories are still developing. Although fleet electrification is rapidly expanding, some use
cases may not yet have an electrified version on the market. Ecology should maintain a list of vehicle
use cases where electrification is not yet available to facilitate exemption processes as needed.

○ (4.2) Advocate for and support development of a successor policy to ACT: TES modeling
indicates the need for a policy more robust than ACT to help bridge the gap between ACT and
ACF automaker sales mandates, which increase significantly between model year 2035 and
2036. Therefore, Ecology should advocate for, support and provide input on any potential CARB
development of a successor policy to ACT, as well as updates to ACT. Supporting both will further
accelerate electrification in the MHDV sector.

131 RCW 70A.30.010 – Motor Vehicle Emission Standards – Department of ecology to adopt rules to implement California
motor vehicle emission standards.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 119
○ (4.3) Consider adopting other MHDV emissions policies and updating existing standards:
California has adopted, is working on developing, or is updating the following standards: ACT,
Innovative Clean Transit, ACC I and its amendments (ACC II), Zero Emissions Forklifts policy, In-Use
Off-Road Diesel-Fueled Fleets Regulation, Ocean-Going Vessels At Berth policy, Commercial Harbor
Craft policy, In Use Locomotive Regulation, Zero Emission Airport Shuttle policy and Zero Emission
Motorcycles. Ecology should continue to assess the impact of adopting additional MHDV emissions
policies and act accordingly.

• Incentivize electrification of privately owned MHDVs.
○ (4.4) Fund and implement a MHDV incentive and infrastructure program: The Legislature
should allocate necessary funding to support zero-emissions MHDV adoption beyond the initial
$130 million–plus in the 2023–25 biennium. The EV Council recommends one large voucher program
with set-asides for all on-ground vehicle types except public school and transit buses (rather than
many different programs spread across agencies and different program administrators), with carve
outs at least for public fleets. The program should include a dedicated increased incentive and set
aside funding for MHDVs operating in overburdened communities historically exposed to higher
levels of air pollution, as well as for businesses that cannot afford the up-front cost of these vehicles.
However, the base level incentive should otherwise be applicable statewide and have no minimum
number of vehicles requirement. Additionally, this voucher program should also include strong
incentives for corresponding EVSE infrastructure, such as depot charging, to serve the funded
vehicles. Private-sector investment companies should be engaged to finance further electrification
of the commercial fleet sector and achieve economies of scale. Finally, the voucher program should
consider design options that promote the secondary market for MHDVs in the state, as many users
(e.g., drayage) have historically purchased used MHDVs.

○ (4.5) Accelerate and fund school bus electrification to meet needed adoption rates: To
transition Washington’s school bus fleet as quickly as the state’s GHG targets demand and to
significantly improve health outcomes for students and bus drivers, easy-to-access funding must be
provided for school districts and for student transportation service contractors to purchase electric
school buses on an urgent timeline. Utilizing its expertise from the existing Clean Diesel school bus
program, Ecology should work with OSPI and Commerce to:

■ Identify target years for requiring that all new public school bus purchases be battery electric
(or fuel cell if electric is not feasible) and that all public school buses in operation be battery
electric (or fuel cell if electric is not feasible), considering the TES modeling and other cost
analyses and bus availability projections (e.g., WRI132).

■ Calculate the amount of funding necessary for school districts to cover higher purchase prices
prior to cost parity, bus route planning, facility upgrades, charging infrastructure and training
for technicians and drivers.

■ Develop a funding process that does not require school districts to apply for state competitive
grants separate from other direct funding streams, and that ensures a seamless transition from
Ecology’s Clean Diesel school bus program.

132 Lydia Freehafer, Leah Lazer and Brian Zepka, “The State of Electric School Bus Adoption in the US,” World Resources
Institute, (September 21, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 120
■ Develop an exemptions request and approval process that can be made for FCEVs or other
ZEVs, if a district can demonstrate they are required by the route.

■ Coordinate with school districts via regional transportation coordinators on the above
decision points.

○ (4.6) Expand the Clean Diesel program’s focus and funding: Currently, Ecology’s Clean Diesel
program is entirely focused on diesel-powered vehicles. The state should expand the program
to address all fossil fuel–powered equipment transitioning to zero-emissions technology. The
Legislature should also provide funding via the Clean Diesel program for innovative projects in
sectors that need more support or are showing a promising innovative approach. As an example,
this could include funding for comprehensive demonstration projects for more complex sectors that
have environmental justice benefits, such as electrifying the refrigerated food delivery trucks of
local food banks.

○ (4.7) Establish port priority access for EVs: State ports should develop opportunities to prioritize
access for EVs, without creating undue burdens on small fleets or owner-operated vehicles or
creating new traffic congestion, which would worsen air quality impacts. This could take the form
of creating priority lanes, priority hours or a fee structure that could be aimed at large fleets and
initially waived for small operators. Because of the complex operations and competing demands
that take place on port property, implementation of this recommendation must be completed in
close alignment with ports and other stakeholders to avoid unintended consequences and operate
within the federal and international legal constraints.

○ (4.8) Continue funding the WSDOT Green Transportation Capital grant program: This program
provides funding to transit agencies for zero-emissions buses and infrastructure capital projects
that reduce the carbon intensity of the Washington transportation system. Nearly $50.5 million was
awarded to nine transit agencies for 11 projects for the 2023–25 biennium, including both battery
electric and hydrogen fuel cell technologies. The program is expected to receive $39.4 million each
of the next two biennia based on transportation budget funding projections.

A cargo ship awaits unloading in port.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 121
• Leverage federal funding for the electrification of MHDVs.
○ (4.9) Apply for a Clean Heavy-Duty Vehicles grant from the IRA: Washington can use IRA funding
to electrify its own fleet vehicles, and establish a grant to support localities, tribal nations and
school districts to do the same. SEEP should take the lead on pursuing federal funding for the state
fleet, and WSDOT and Ecology should work together on supporting other applications. Washington
should explore the potential to contribute local matching funds.

○ (4.10) Explore bulk purchase financing through the U.S. Department of Energy Loan Programs
Office: Commerce, Ecology and WSDOT should work together to explore financing bulk purchases of
electric trucks and buses, and charging infrastructure, through the U.S. Department of Energy Loan
Programs Office’s IRA funding.

5. Electrifying Micromobility

• Expand affordable access to e-bikes and integrate it with electrified public transit.
○ (5.1) Support and expand the e-bike rebate and lending library programs: The Legislature
should establish the new programs in statute, expand future funding to meet LMI resident needs,
and provide flexibility to modify the programs based on lessons learned through the early
implementation phases. Based on strong demand for such programs in other states, the Legislature
should fund programs in line with emissions reduction and transportation equity objectives.

■ Provide rebates for e-bikes and e-trikes: The rebates should include electric cargo bikes and
family bikes, adaptive e-bikes and e-trikes for use by people with disabilities, as well as related
equipment, including equipment designed for transporting children such as child bike seats
and trailers. The state should reserve at least 75%–80% of the rebate for LMI residents.

■ Fund the scaling or introduction of affordable e-bikes and e-scooters that connect to
other forms of public transportation: Providing access to and increasing first- and last-mile
transportation options in locations where transit services are not available is essential for
non-drivers. Explore opportunities to create “one card” access across these shared mobility
platforms and transit services.

• Adequately fund bike infrastructure, including charging access for e-bikes.
○ (5.2) Implement the Active Transportation Plan’s remaining recommendations: The Legislature
and other state decision-makers should implement any remaining recommendations not yet
acted on in WSDOT’s award-winning Active Transportation Plan related to e-micromobility,
including providing safe bicycling paths. Similar to WSDOT’s highway corridor charging programs
for passenger vehicles, the Legislature should create an e-bike charging program administered by
WSDOT to ensure sufficient recharging access to make commutes and other longer trips possible.

○ (5.3) Expand public access to secure bike parking, including access to charging outlets
for e-bikes: WSDOT’s Active Transportation Division, in consultation with Commerce’s Local
Government Division, should enable e-bike parking to count toward parking requirements, provided
minimum requirements are in place to encourage conversion of traditional parking spots into
secure storage for different types and sizes of electric and non-electric bikes. Where feasible, e-bike

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 122
A pair of electric bikes await riders on their daily commute.

parking should integrate with solar-powered facilities. WSDOT and Commerce staff supporting
local governments should prioritize these parking and charging stations at transit centers, state
government buildings including colleges and universities, libraries, schools, local government
buildings, community centers, public gathering places such as parks and providers of essential
goods and services such as health care and groceries.

○ (5.4) As communities develop their curb management strategies, ensure that electrification
and micromobility safety is considered: Support communities in establishing a curb management
strategy that balances priority access to the curb for pedestrians, cyclists and shared transit users
with short-term pick-up and drop-off access and charging infrastructure for electric modes of
transportation, particularly e-micromobility. Commerce’s Growth Management Services team
should work with local governments to work this strategy into its comprehensive plans to ensure
significant build-out of protected bike lanes and infrastructure. The strategy should include
guidance on:

■ Accommodating standard cargo and e-cargo bikes (e.g., lane widths, loading zones and on-
street charging zones).

■ Utilizing space at intersections to provide parking for e-bikes and other e-micromobility
devices, potentially with charging and/or docking stations, while also providing improved line of
sight for drivers so they can see pedestrians crossing streets and other movements.

■ Ensuring capital improvements to the curb include preparing for or implementing EVSE for
e-micromobility and for some electric LDVs and MDVs.

■ Ensuring curbside EV charging does not deter conversions of or plans to convert on-street
parking to public space for recreational and commercial use.

■ Ensuring access for people with disabilities.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 123
6. Workforce Development

• Support early career development and career transitioning for the industry and industry access
for underrepresented individuals while meeting Washington’s transportation electrification
workforce demand.

○ (6.1) Invest in targeted workforce training: Fund workforce training programs across Washington,
in rural, suburban and urban areas, that provide education about the mechanics, operation,
safety and maintenance of ZEVs, EV charging, hydrogen fueling stations, and tools involved in the
implementation of alternative fuel technologies. This should include funding to create accessible
career pathways, including registered pre-apprenticeship and apprenticeship programs with a focus
on joint labor-contractor programs and labor-led workforce development. Certification programs
should be scaled and delivered in partnership with technical colleges and CBOs. Additionally, this
should include training for incumbent manufacturing employees and ICE vehicle mechanics on new
technologies to minimize worker displacement — using federal funding where available. This should
be specifically designed to ease barriers to entry for BIPOC, women, tribal citizens, low-income
residents and veterans. Additionally, this should include wraparound services for individuals in
these communities.

Agency staff involved in the EV Council’s work should get on the Clean Energy Technology Workforce
Advisory Committee’s agenda early in its formation to present the TES findings and the feedback
received from workforce stakeholders in the TES development process, and to urge the committee
to prioritize transportation electrification jobs in their recommendations.

• Ensure the existing workforce has adequate access to the certifications necessary to participate
in the shifting industry.

○ (6.2) Require certifications for the electrical components of EV charger installations: Require
Electric Vehicle Infrastructure Training Program (EVITP) or similar accredited program certification
for the installation of the electrical system of EV chargers to ensure safety and effectiveness, and
to address inconsistencies in labor standards. This requirement should be rolled out in phases,
starting in 2025 as a requirement for publicly funded projects, and later for privately funded
projects. EVITP certification should only apply to electricians required to work on-site on solely
electrical components and should not apply to other construction workers necessary for the
installation of EV charging infrastructure (including but not limited to charging stations, parking
spots and bus and other fleet depots) and all other processes involving EVSE installation. EVITP
certification typically requires 20 hours of instruction and costs $275 for the online course (and
typically less for in-person apprenticeship continuing education programs). The state should set up
a fund to offset the cost of certification for Minority or Women’s Business Enterprises entities. LNI
should review the EVITP curriculum to ensure it stays current with changing EV charger technology.
As this policy recommendation is implemented, additional consideration should be given to the
findings from the Clean Energy Technology Workforce Advisory Committee (HB 1176). 133

133 Clean Energy Workforce Advisory Committee (HB 1176) – An act relating to developing opportunities for service and
workforce programs to support climate-ready communities.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 124
A maintenance technician works on an EV charger.

○ (6.3) Explore training and certification requirements for EV charging maintenance
technicians: Support maintenance providers in receiving appropriate instruction for maintenance
and repair of EVSE, including manufacturer-approved training. For example, SAE International has a
specifically developed Electric Vehicle Supply Equipment (EVSE) Technician Certification.134

○ (6.4) Require EV technician training for fleets: Agencies with ZEV funding programs should work
with LNI, transit agencies and labor unions to ensure training and proper equipment for technicians
working on EVs, including electrical safety best practices. Legislators, agencies and stakeholders
should determine whether this is best implemented through legislative or regulatory workplace
safety standards, guidance that must be adopted to receive ZEV funding or collective bargaining
contract language.

○ (6.5) Require training and certification for EV technicians: Ensure a lead mechanic is present
when an OEM gives instructions on servicing their vehicle models and require annual re-trainings to
keep technicians up to date on new technologies.

○ (6.6) Create a training grant program for first responders addressing EV battery fires: Although
EV battery fires are significantly less frequent than gasoline vehicle fires, they burn differently and
require new vehicle firefighting methods. Washington State Patrol, in their authority on fire safety
training, should develop guidance on responding to EV battery fires and request funding for a grant
program to support local training for first responders.

• Enact strong labor standards and agreements for the existing and growing electrification workforce.
○ (6.7) Set standards for government-funded EVSE projects: Ensure all EVSE projects funded in
whole or in part with state or federal funds, including projects supported with grants, loans and tax
incentives, pay the prevailing wage and adhere to Apprentice Utilization Requirements. Apply the

134 SAE International, “SAE International Electric Vehicle Supply Equipment (EVSE) Technician Certification,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 125
labor standards attached to federal funding to projects funded in whole or in part by the state through
project installation. Require high-road labor standards for manufacturing assembly, and operations
and maintenance jobs at facilities funded in part by public funds (including tax incentives).

○ (6.8) Develop labor and workforce standards and require labor agreements for large public
installation projects: Develop labor and workforce standards for transportation electrification
projects and require project labor agreements or community workforce agreements (for laborers,
operators and electricians) for all public installation projects larger than 25 DCFCs, 100 L2 chargers
and/or $1 million in total cost. Require project labor agreements or community workforce
agreements for the construction of new or retrofitting of existing manufacturing plants.

○ (6.9) Establish clear objectives for participation by overburdened communities and
vulnerable populations in the electrification workforce: Building on experience with priority
hiring programs in Washington, establish clear goals for the recruitment, participation, hiring and
retention of women, BIPOC community members and individuals from overburdened communities
and vulnerable populations in pre-apprenticeship programs, apprenticeship programs and
employment. Require data collection and submission to the LNI so that trends can be monitored
and corrective actions can be taken if necessary to reach these goals. Contractors and training
organizations that successfully meet goals should receive additional points in future contracting
and procurement opportunities with the state.

• Identify opportunities created through the transportation electrification transition to grow
Washington’s clean industrial economy.

○ (6.10) Build EV manufacturing in Washington: Commerce’s Office of Economic Development and
Competitiveness should identify manufacturing sites statewide and support site development for
EV components and assembly. It should either prioritize areas where workforce and training centers
are currently located or support the creation of new workforce development centers in identified
areas. Leverage all available federal funds (namely the 48C Advanced Manufacturing Tax Credit and
the Domestic Manufacturing Conversion Grants Program) to expand in-state manufacturing of EV
components and EV assembly. As an example, in 2023 it was announced that a factory is being built
to manufacture and deliver silicon battery technology in Moses Lake, Washington, and production
lines are projected to be online by 2024.135

○ (6.11) Support local markets for battery reuse and recycling: There is a focus on developing a
circular economy for battery recycling in the United States to reduce reliance on minerals sourced
overseas. As directed by Chapter 434, Laws of 2023, Ecology is currently studying EV battery
management in Washington and will be making recommendations to the Legislature via a legislative
report in spring 2024. Part of that study is examining reuse markets. The Legislature should take
action to financially support the development of a program to reuse or retire EV batteries.
In addition, Commerce’s Office of Economic Development and Competitiveness should apply for
federal funding (namely the 45X Advanced Manufacturing Production Tax Credit) for the creation
of a battery recycling plant using direct disassembly or hydrometallurgy. In consultation with
Commerce, Ecology should examine what obstacles prevent the siting of a battery recycling facility
in Washington and identify what steps can be taken to address them. Any recycling plants need to
meet workforce standards for both construction and operations.

135 PR Newswire, “Group14 Technologies Begins Construction of the World’s Largest Commercial Factory for Advanced
Silicon Battery Materials,” (April 4, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 126
Part II – Closing the 2030 Transportation Greenhouse Gas Emissions Gap

TES modeling shows that even the most ambitious, yet still feasible EV adoption rates reflected in the S3
Strong Electrification Policy scenario leave an approximate 3.9 MMT CO2e gap in emissions in 2030. As
explained in Chapter 4, even if insufficient, maximizing transportation electrification is necessary to stay
under the 2030 emissions limit, and it is essential to staying under 2040 and 2050 limits.

Meeting the state’s 2030 emissions limit will require actions beyond the transportation electrification
recommendations in this strategy. The Legislature cited the 2030 emissions limit in its language creating
the EV Council, embedding it in this report’s purpose. This legislative intent was mirrored by stakeholders
and community leaders who requested recommendations beyond EVs be included in this strategy.

For these reasons, staff representing the agencies on the EV Council will support efforts by colleagues, local
and regional public agencies, private-sector and nonprofit partners, and communities to make progress on
additional clean transportation strategies.

On-Road Vehicle Strategies

A. Reducing Vehicle Miles Traveled

The 2021 SES identified two prongs to address transportation GHGs: switching to EVs and clean fuels, and
moving people and goods more efficiently and equitably. The TES focuses on transportation electrification.
However, because electrification will leave a significant emissions gap in 2030, additional strategies are
needed. Investments that move people and goods more efficiently will reduce per capita VMT and bring the
state closer to meeting GHG limits.

Drivers commute home through the dusky Seattle night.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 127
In addition to directly lowering vehicle energy use and associated emissions, improved travel efficiency
reduces the amount of energy infrastructure needed, which also supports transportation electrification
efforts. Requiring less electricity for travel will make the transition to EVs easier and less costly, because it
will require less additional generation, transmission and charging infrastructure.

As described in Chapter 4, VMT-related scenarios identify the additional emissions reductions from
transportation efficiency strategies. Modeling included several exploratory scenarios to evaluate how
maximizing reductions in VMT would affect 2030 emissions. Analysis compared a 17% per capita reduction
by 2035 with the 6% reduction expected under current policies and showed that a high level of VMT
reduction could narrow but not fully close the remaining 2030 emissions gap. Although meeting the
underlying assumptions in these illustrative scenarios will be very challenging — due to long timelines
for infrastructure build-out and housing density changes — they must be pursued in tandem with
electrification and clean fuels strategies.

In November 2023, WSDOT submitted the Transportation Carbon Reduction Strategy (TCRS).136 The
TCRS uses the SES’s two-pronged approach to describe the transportation carbon reduction policies and
strategies currently in place across the state. In the section on moving people and goods more efficiently,
the TCRS identifies a number of current policies and strategies, including land use strategies, active
transportation investments, transit and rideshare incentives and strategies (including intercity transit),
using the internet to reduce travel needs, operating the system efficiently, and improvements in user fees,
fleet operations management and vehicle efficiency.

• (A.1) WSDOT – 2023 VMT Report
In 2021, the Legislature directed WSDOT, in partnership with Commerce, to complete a report on
VMT reduction targets. WSDOT’s Vehicle Miles Traveled (VMT) Targets – Final Report137 provides
recommendations on legislative and rules changes that would improve travel efficiency and reduce the
need to drive alone, setting sub-state per capita VMT targets and identifying the need for future equity
analysis and community-led planning and engagement.

The report chapter “What Works – A Menu of VMT Strategies” highlights the effectiveness of various VMT
reduction strategies, as shown in Table 15, and notes the importance of land use changes and pricing:

○ “Reducing per capita VMT requires smart transportation investments aligned with strong land use
planning. A study by Smart Growth America and the State Smart Transportation Initiative in 2021 for
Washington State identified the potential VMT impact of land use and transportation strategies.

○ “Land use patterns are clearly one of the most effective changes a jurisdiction can make, but
the resulting development (and therefore VMT reduction benefits) will take time. It is crucial to
address land use changes as soon as possible to accelerate the realization of future benefits. Land
use provides the foundation, then active transportation and transit facilities and services enable
people to enjoy the benefits of shorter travel distances. Pricing is also effective as witnessed by
behavior changes related to gas prices; however, it can be politically challenging to implement.
For these reasons, a combination of all these strategies should be implemented in communities
across the state.”

136 WSDOT, “Transportation Carbon Reduction Strategy.”
137 Millar and Pen, “Vehicle Miles Traveled (VMT) Targets - Final Report.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 128
Table 15 VMT Reduction-Management Strategies and Their Potential
Average Effect

Note: Each dot represents a 5% average reduction in VMT.
Source: WSDOT “Vehicle Miles Traveled (VMT) Targets – Final report.”

• (A.2) Commerce – Local Land Use Support
The state is supporting the land use VMT strategy by providing early guidance for local governments on
improving transportation efficiency (among other climate planning issues)138 developed by Commerce’s
Growth Management Services team, working in close coordination with WSDOT.

In the 2023 legislative session, Chapter 228, Laws of 2023 added a climate element to comprehensive
planning requirements for counties and cities with more than 6,000 people.139 For the state’s 11 largest
counties and the cities within those counties, a required sub-element must include goals and policies
to reduce emissions and VMT. To support this planning, Commerce is awarding $30 million in grants
statewide for the 2023–25 biennium.

Historic Investments in Transit and Active Transportation

Efforts to create denser communities are supported by significant new investments in public transit
and active transportation. These two transportation options will receive 80% of CCA carbon emissions
reduction account funding per RCW 46.68.490140 and RCW 46.68.500.141

B. Reducing Vehicle Weight

Reducing vehicle weight can have significant effects on fuel economy and energy consumption, therefore
reducing emissions. The national trend toward larger passenger vehicles142 such as pickup trucks and SUVs

138 Washington State Department of Commerce — Growth Management Services, “Climate Element Planning Guidance,” (June
2023).
139 Washington State Department of Commerce, “Climate Program,” (n.d.).
140 RCW 46.68.490 – Climate active transportation account.
141 RCW 46.68.500 – Climate transit programs account.
142 Andrew Van Dam, “The Real Reason Trucks Have Taken over U.S. Roadways,” Washington Post, (April 7, 2023).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 129
makes emissions reduction more difficult, transportation fuel costs more expensive and traffic collisions
more likely to be fatal or to cause serious injury. However, achieving vehicle weight reductions at the state
level is difficult, as automaker marketing has an outsized effect on consumer preferences.

Although options are limited, the Legislature and state agencies should consider a variety of possible
actions to make progress on reducing average passenger vehicle weight:

• (B.1) Explore increasing registration fees for noncommercial vehicles that weigh more than 4,000
pounds. RCW 46.17.355143 sets increased registration fees for vehicles starting at 4,000 pounds to
reflect increased wear on roads, ranging from $53 for 4,000 pounds to $93 for 10,000 pounds. The state
could assess the impact these fees have on consumer decision-making and consider increasing fees or
shifting to a more visible point-of-purchase sales tax surcharge. California’s Legislature is considering a
bill to conduct a similar analysis.144

• (B.2) Support federal efforts to apply consistent emissions standards for larger vehicles. The
state should comment on relevant rulemakings related to the EPA’s emissions standards, the National
Highway Transportation Safety Administration’s Corporate Average Fuel Economy (CAFE) standards,
and the U.S. Department of Energy’s fuel efficiency standards to encourage the consistent application
of emissions standards to larger passenger and commuter vehicles. Historically, these standards have
incentivized automakers to produce vehicles with larger physical footprints, which have relatively
higher traffic safety concerns and emissions but are required to have less costly emissions controls
systems. The state should also work with Washington’s federal congressional delegation to support
changes that incentivize smaller new passenger and commuter vehicles.

C. Strategies to Reduce Gasoline and Diesel in Existing Vehicles

The modeled electrification strategies leave a 2030 emissions gap largely because they primarily address
new vehicle sales and not the gasoline or diesel vehicles already on Washington roads. The state can close
this gap by pursuing the following strategies:

• (C.1) Increase use of clean drop-in fuels through the Clean Fuel Standard: The 2021 SES was tied
to the state’s emissions reduction limits and modeled scenarios that stay under the 2030 emissions
limit by assuming a dramatic increase in clean drop-in fuels, including biofuels, renewable diesel and
electrofuels (carbon-neutral fuels created by combining green electrolytic or renewable hydrogen
and CO2 or carbon monoxide), which reduce the carbon intensity of gasoline and diesel when blended
with fossil fuels. The state’s primary policy instrument to increase the use of these drop-in fuels is the
Clean Fuel Standard (CFS), which is currently set to decrease carbon intensity by 20% by 2034 through a
credit-deficit market system. Ecology should coordinate with Commerce’s Office of Renewable Fuels to
assess whether the CFS is driving enough drop-in fuel deployment to meet the SES and other relevant
modeling and pursue two actions:

○ (C.1.1) Add flexibility to the Clean Fuel Standard’s carbon intensity schedule: The Legislature
currently retains authority, through RCW 70A.535.025,145 to set carbon intensity reduction

143 RCW 46.17.355 – Vehicle Fees – License fees by weight.
144 AB-251 California Transportation Commission: vehicle weight safety study, (2023–24).
145 RCW 70A.535.025 – Carbon intensity in transportation fuels – Standards to reduce carbon intensity – Adoption of rules –
Monthly Calculation.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 130
A lone 18-wheel truck traverses a Washington highway.

schedules for Washington’s CFS. The Legislature should transfer that authority to Ecology so
Ecology can adjust schedules via rulemaking. This effects the program’s flexibility to respond
to changes in the transportation sector and the Washington CFS market, the state’s emissions
reduction needs and price stability in the market for CFS credits. This would align with two other
states’ low-carbon fuel standards, as the CARB and the Oregon Department of Environmental
Quality both control their respective state’s carbon intensity schedules.

○ (C.1.2) Increase the stringency of the Clean Fuel Standard program: Where appropriate, the
state should consider for inclusion in Washington’s CFS both the suite of proposed updates to
California’s Low Carbon Fuel Standard146 and updates implemented by Oregon’s CFS since the
passage of Washington’s CFS statute. This includes increasing the stringency of the carbon intensity
reduction schedule by 2030 and extending the carbon intensity targets into later years. Further
reductions in fuel carbon intensity are not included in the TES modeling results and will be an
important part of bridging the emissions gap identified above for 2030. This includes increasing
the stringency of the carbon intensity reduction schedule by 2030 and extending the carbon
intensity targets into later years. Further reductions in fuel carbon intensity are not included in
the TES modeling results and will be an important part of bridging the emissions gap identified
above for 2030.

• (C.2) Improve vehicle efficiency with lower-resistance replacement tires: According to the
U.S. Department of Energy, “20% to 30% of a vehicle’s fuel consumption and 24% of road vehicle
CO2 emissions are tire-related.”147 In fact, only 12% to 30% of gasoline used in an ICE vehicle goes
to propelling motion. More than 70% of energy is lost in engine operations and wheel resistance.
Commerce’s Energy Policy Office estimates that efficiency standards for replacement tires and
associated consumer awareness and labeling efforts could save about 618 million gallons of gasoline,
1,396 gigawatt-hours of electricity, and 5.4 MMT CO2e between 2026 and 2035. They further find that
Washington drivers would save an average of $714 per set of four replacement tires over the life of the
tires through increased efficiency savings. States can adopt efficiency standards because the federal

146 State of California Air Resources Board, ”Low Carbon Fuel Standard 2023 Amendments,” (September 8, 2023).
147 U.S. Department of Energy, “Tires and Fuel Economy,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 131
government has not acted and therefore no preemption exists. Commerce plans to pursue such
standards, which are similar to other energy efficiency standards enacted through Commerce rules.148

• (C.3) Enforce diesel vehicle compliance: Many diesel engines are out of compliance. Due to EPA
inaction on this issue, a diesel anti-tampering law is needed to stop the sale of aftermarket defective
devices, which should include a scrap-and-swap element for electrification. Additionally, the
Legislature should authorize Ecology to develop penalties for shops that illegally retrofit or bypass
emissions systems. This effort could be combined with the proposed anti-idling legislation below.

• (C.4) Explore an anti-idling law for ICE MHDVs: Ecology should consider developing an anti-idling
agency request bill for MHD ICE vehicles, specifically targeting long idling times, thus incentivizing
a shift to EVs while reducing pollution in overburdened communities. The legislation or resulting
implementation could provide incentives for drivers to invest in technologies that reduce idling,
including electrifying internal cabin operations to ease the transition to anti-idling. HD truck idle
reduction technologies exist, which enable truck drivers to maintain climate control and power.149 In
places like New York City, a Citizens Air Complaint Program enables citizens to file a complaint when
vehicles are idling for more than one to three minutes and potentially receive payment.150

• (C.5) Focus on high-consumption gasoline and diesel users: Building on findings from the Joint
Transportation Committee’s June 2023 report the state should focus electrification efforts on
“superusers” to maximize emissions reductions through electrification investments. Strategies
include:151

○ Developing a Clean Miles Standard

○ Specifically identifying LMI residents who drive long distances for work as vulnerable populations
within incentive program prioritization

○ Targeting high-consumption fuel users in the Education Plan’s outreach

○ Creating a scrap-and-replace incentive program for high-emissions MHDVs with viable battery
electric alternatives

This scrap-and-replace program should aim to accelerate the adoption of electric MHDVs by providing
incentives to purchase new electric MHDVs in exchange for scrapping inefficient ICE trucks and
construction equipment. This program would not be structured as a requirement, but instead as an
incentive, and would be stackable with other incentive programs. This incentive should be designed
specifically to support small fleets and owner-operators through a Disadvantaged Business Enterprise
program. Funding amounts would need to be significant — hundreds of millions of dollars annually —
to make a sizeable contribution to emissions reduction considering the sheer number of existing ICE
vehicles and high administrative cost for scrappage verification.

148 Chapter 19.260 RCW – Energy Efficiency.
149 U.S. Department of Energy – Energy Efficiency & Renewable Energy, “Heavy-Duty Truck Idle Reduction Technologies,” (n.d.).
150 NYC Environmental Protection, “Citizens Air Complain Program,” (n.d.).
151 Washington State Joint Transportation Committee, “Encouraging High-Consumption Fuel Users To Use Electric Vehicles,”
June 2023.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 132
• (C.6) Continue to assess fossil-fuel-to-electric conversions: Conversions that change existing ICE
vehicles to battery or plug-in hybrid electric have long been a potential way to achieve faster emissions
reductions, but despite decades of research and development they have not reached scale. The state
must focus on scaling up proven technology to meet its emissions limits, but will monitor conversion
technology developments and reassess prioritization during TES implementation.

Non-Road Vehicle Strategies

Electrification of non-road vehicles is explored below, although it was not designed to be a significant focus
of the TES. As the state continues to explore non-road vehicle strategies, it will further engage and involve
non-road transportation stakeholders.

SeaTac airport is shown from above.

D. Aviation

At 6.3 MMT, aviation emissions — primarily from jet fuel — made up 16% of the state’s transportation
emissions in 2019 and 6% of economy-wide emissions. For perspective, that is more than the emissions
created from burning natural gas to generate electricity. In recent years, aviation emissions have been as
high as 9% of all emissions — more than natural gas used to heat residential and commercial buildings
combined.

Pollution from jet fuel and aviation gasoline, especially nitrogen dioxide (NO2), has negative effects on
health outcomes for residents living near airports and downwind of flight paths, and for workers at airports.
In a 2019 University of Washington School of Public Health study funded by the Legislature, researchers
found “communities under the flight paths near the airport are exposed to higher proportions of smaller-
sized, ‘ultra-ultrafine’ pollution particles and over a larger area compared to pollution particles associated
with roadways.”152 Smaller pollution particles are more dangerous to health because they are more easily
inhaled, as noted in a 2019 DOH literature review on ultrafine particles.153

152 “Communities around Sea-Tac Airport Exposed to a Unique Mix of Air Pollution Associated with Aircraft,” UW News,
(December 3, 2019).
153 Elmer Diaz et al., “Summary of Health Research on Ultrafine Particles,” Washington State Department of Health, (November
2019).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 133
Zip codes containing SeaTac Airport (10), Paine Field (9), Boeing Field (10) and Grant County International
Airport (9) all have either a 9 or 10 on DOH’s Environmental Health Disparities Map, identifying them as
overburdened communities. Spokane International Airport is ranked as an 8 overall, though it is ranked as
a 10 for the ozone concentration factor (which is correlated to NO2). In order to reduce GHG emissions and
pollution associated with the aviation sector, the state should consider the following actions:

• (D.1) Encourage increased uptake of sustainable aviation fuel (SAF) and establish interim targets
through 2030: Building on the agreements negotiated by the Port of Seattle, Commerce’s Office of
Renewable Fuels should push for ambitious targets and corresponding policy recommendations with
the WSU Alternative Jet Fuels Work Group continued by Chapter 232, Laws of 2023. The IRA includes
sustainable aviation tax credits, which are $1.25–$1.75 per gallon of SAF in a mixture through 2027.
Incentives from Chapter 232, Laws of 2023 will augment the IRA incentives, including the creation of
a tax credit of $1–$2 per gallon for SAF produced in Washington and allowing more favorable carbon
accounting to make SAF be included in the Washington CFS.

• (D.2) Implement market mechanisms to speed up the use of SAF: Revise the CFS via WAC 173-424-130
to include jet fuel as an obligated fuel for intrastate flights. This will help improve the economics of SAF
while also putting jet fuel on an even playing field with other transportation fuels used in Washington. A
commercial facility to produce SAF using electricity recently broke ground in Moses Lake, Washington.154

• (D.3) Continue to invest in early-stage development of electric and hydrogen planes: Washington
has continued to build on its longtime position as a global aviation leader by investing in research
development and deployment of early-stage electric and hydrogen plane technology.155 Commerce should
continue to fund private-sector technologies, while WSDOT continues to make investments in airport
infrastructure needed to test emerging electric and hydrogen planes for shorter regional flights.156

E. Marine and Ports

Marine vessels were responsible for even more GHG emissions than aviation in the 2019 inventory,
making up 18% of the transportation sector’s climate pollution — the same share as HD on-road vehicles.
Many of those emissions are connected to the state’s many marine ports, which serve as vital engines of
Washington’s economy. A number of options are available for the state to reduce emissions within the
marine sector.

• (E.1) Port decarbonization (electrification): The Legislature should allocate funding to Commerce to
create a holistic maritime electrification strategy, informed by the 2019 Blue Economy Strategy.157 The
maritime electrification strategy should be developed with ports, industry, longshoremen, frontline
communities residing near ports, freight and drayage drivers, utilities and other stakeholders. The
strategy should include vessel decarbonization, port decarbonization (specifically shore power) and the
creation of green corridors.

154 Washington Governor Jay Inslee, “Twelve Announces Plans to Scale Production of Sustainable Aviation Fuel Made from
CO2 in Washington State,” (June 19, 2023).
155 Washington State Department of Commerce, “ZeroAvia Announces Expansion of Electric Propulsion R&D Facility at Paine
Field,” (June 19, 2023).
156 Washington State Department of Transportation – Aviation Division, “Washington Electric Aircraft Feasibility Study,”
(November 2020).
157 Washington Maritime Blue, “Washington State’s Strategy for the Blue Economy,” (January 2019).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 134
A group of cars await loading onto one of Washington's ferries in Seattle. WSDOT aims to fully electrify the state's ferry
system by 2040.

○ (E.1.1) Vessel decarbonization (ferry vessel and terminal electrification): Effective vessel
decarbonization will require a variety of alternative fuel technologies to address a variety of
use cases. More research, demonstration projects and policy guidance are needed to increase
information availability, decrease investment risk, and ultimately lead to fuel switching.

Electric and hybrid electric propulsion systems are replacing traditional fueling systems in limited
use cases, such as intracoastal ferry routes. The Washington State Ferry System is working on three
key elements to transition to a hybrid electric fleet: building new vessels, converting vessels and
electrifying the terminals. The first hybrid electric conversion is planned to be complete in the fall
of 2024. Work is also under way on terminal electrification and contracting for new electric hybrid
vessels. Challenges to these types of projects can include the cost and complexity of designing and
building new vessels (or rebuilding them in the case of conversions), the cost and complexity of
installing charging infrastructure, and limitations in vessel operations (e.g., limited routes) due to
vessel charging requirements.

Clean alternative fuels such as green electrolytic hydrogen, electrofuels (e.g., e-methane,
e-ammonia, e-diesel), renewable diesel and biofuels (e.g., bio-methane, bio-methanol, bio-oils)
hold promise, particularly for transoceanic use cases. When coupled with renewable electricity for
production, the life-cycle GHG emissions of these fuels can be significantly lower compared with
those of traditional marine fuels. From a regional perspective, Washington’s relatively low-cost
and low-carbon electricity presents an economic opportunity to support the local production of
emerging clean maritime fuels. Tacoma Power created the nation’s first pilot electricity rate to
support the production of electrofuels in 2021.158

158 Tacoma Public Utilities, “Tacoma Power Announces the Nation’s First Electrofuel Tariff,” (March 4, 2021).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 135
○ (E.1.2) To create better certainty, Washington should support development and partnerships
for clean maritime fuels. Modeling in Commerce’s green hydrogen legislative report indicates
Washington will see demand for sustainable maritime fuels, including hydrogen-derived Fischer-
Tropsch liquid fuels and ammonia, beginning to take off by 2025–30. Entities including Washington
Maritime Blue are conducting research regarding the most appropriate sustainable maritime fuels,
vessel types and corridors. The state should use these findings to support rapid deployment of
these fuels in maritime operations. This should include establishing strong targets and new market
incentives for maritime fuels, as well as support for multi-stakeholder efforts that will elevate this
policy area in similar ways to the Alternative Jet Fuels Work Group.

○ (E.1.3) Port decarbonization: A wide variety of infrastructure upgrades will be necessary
to sustain ongoing port operations with reduced carbon intensity. These activities include
refueling vessels, providing shore power to sustain vessel operations at berth (e.g., cold ironing),
cargo handling and drayage. The state now has shore power active in the Port of Seattle,
and the Legislature recently invested nearly $50 million for the 2023–25 biennium. Many of
the technologies will be electrically powered and will significantly increase demand on the
electrical grid, requiring close coordination with electric utilities. Replacing traditional port and
ship technologies could require additional job training and adjustments to the long-standing
operational status quo, which must be accounted for in transition planning. The state could look
to the Port of Los Angeles’s Technology Advancement Program,159 Zero Emission Freight Advanced
Infrastructure Demonstration (AID) Program, and Zero Emission Tech Demonstration Projects160
as examples. In addition to infrastructure upgrades, the state should explore adopting California’s
2020 Ocean-Going Vessels At Berth regulation to ensure that shipping companies utilize the shore
power being added to the ports.

○ (E.1.4) Green corridors: Washington ports have recently gained notoriety for the announcement
of two green corridors, currently under development. They include a green cargo shipping corridor
between the Northwest Seaport Alliance and the Republic of Korea161 and a green cruise corridor
from the Pacific Northwest to Alaska.162 These corridors are designed to overcome technology
adoption barriers by ensuring vessels will have access to required fuels and infrastructure at each
port, and to demonstrate feasibility in support of future expanded routes.

F. Rail

The EV Council also recognizes that rail emissions make up 300,000 metric tons CO2e in the 2019 emissions
inventory, but they are not addressed in the TES. Ecology’s latest Volkswagen Settlement program included
zero-emissions freight switcher locomotives. The current transportation budget also includes $5 million for
a Tacoma rail facility to add zero-emissions battery electric switchers. Representatives of member agencies
will explore the EV Council’s role in supporting rail electrification during implementation of the TES,
including reviewing other zero-emissions projects in the country.

159 Clean Air Action Plan, “Ports Technology Advancement Program,” (n.d.).
160 Port of Los Angeles, “Zero-Emissions Technologies,” (n.d.).
161 Northwest Seaport Alliance, Seattle + Tacoma, “The Northwest Seaport Alliance Announces Partnership with Busan Port
Authority to Further Decarbonization of Ports at United Nations Climate Conference,” (November 7, 2022).
162 Port of Seattle, “Exploring the World’s First Green Corridor for Cruise,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 136
G. Focus Planning and Implementation Efforts on Meeting the 2030 Emissions Limit

The TES provides the clearest indicator yet that Washington needs increased focus on the 2030 emissions
limit if state leaders hope to stay under the scientifically necessary threshold. As part of the Pacific Coast
Collaborative and U.S. Climate Alliance, Washington is a key partner in a group of states and provinces
in the United States and Canada that can show the rest of the world how to decarbonize equitably while
creating good jobs and affordable electricity, transportation and heating and cooling.

The state has several planning efforts that can bring even more focus to Washington’s short-term emissions
limit, identify key strategies to actualize existing policies, and move forward on new actions to meet the
2030 emissions limit.

• (G.1) Carbon Pollution Reduction Grants: Through the IRA, Congress provided several funding
opportunities for states to pursue GHG pollution reductions, including the Climate Pollution Reduction
Grants program administered by the EPA. The Climate Pollution Reduction Grants program has two
phases. Phase 1 is the planning phase, and the IRA has appropriated $250 million for planning grants
that the EPA will award noncompetitively to states, metropolitan statistical areas, tribes and territories.
Phase 2 will issue implementation grants, and the IRA has appropriated $4.6 billion under this phase to
carry out the plans that are developed under Phase 1 of the program.

○ Commerce and Ecology are leading development of Phase 1 for the state and plan to include TES
recommendations as part of the Priority Climate Action Plan, which is due March 1, 2024. This is
essential, because climate mitigation measures must be included in the Priority Climate Action Plan
to be eligible for funding in Phase 2.

○ EV Council agencies should work through the (to-be-designated) lead agency for the Climate
Pollution Reduction Grants program to prioritize TES recommendations in the state’s competitive
application in Phase 2. The lead agency should identify gaps in progress on the TES implementation
plan to determine the most urgent funding requests.

○ Commerce and Ecology should also support Seattle-Tacoma-Bellevue metro area and tribal
planning and competitive applications by sharing TES modeling outputs and policy guidance.

• (G.2) Move up the next SES: During the 2025 session, the next governor should include a budget
proviso funding Commerce’s Energy Division to move up its next SES to be completed in mid-2026 with
a special focus on immediate actions within the power, transportation, buildings and industrial sectors
needed to hit the 2030 emissions limit. The 2026 SES should be delivered to the governor’s office for
inclusion in the 2027 session budget and legislative proposals.

○ For the transportation sector, the 2026 SES should update TES modeling to assess implementation
progress and focus on the trade-offs of more aggressive emissions reduction options, such as early
ICE vehicle retirement through a robust scrap-and-replace program.

○ The 2026 SES should establish clear sector and subsector targets that must be achieved to stay
under the 2030 emissions limit, while recommending the governor and Legislature take immediate
action in the 2027 legislative session on 2026 SES proposed strategies.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 137
6. Implementation Roadmap
Washington has made tremendous strides in recent years to achieve its climate leadership position. It
passed a landmark 100% clean electricity law, the nation’s first clean buildings standard and the nation’s
second economy-wide cap-and-invest program. It also joined California, Oregon and British Columbia in
the West Coast clean fuel standard market and adopted California’s motor vehicle emissions standards.
All of these policies were on a foundation of environmental justice through the HEAL Act and strong labor
standards. And yet, as the TES modeling has made clear, Washington must do even more.

Given the high stakes and short time frame for closing the gap between current policy and the S3 Strong
Electrification Policy scenario, Washington must be highly focused on and organized in establishing
priorities. With this in mind, the following 2024 prioritization plan lays out a clear roadmap for 2024
legislative session recommendations and how agencies can work toward policy and program development
for the longer 2025 legislative session. Each policy includes a clearly identified agency lead and notes
expected transportation equity benefits and expected improvement in air quality in overburdened
communities.

The 2024 priorities are presented in Tables 16 and 17.

Table 16 lists new actions and emissions reductions, broken out by electrification and non-electrification
strategies, needed to close the 2030 on-road emissions gap left by current electrification and travel
efficiency policies. The table also shows estimated incremental GHG emissions reduction by strategy and
expected equity outcomes.

Achieving the additional 2030 emissions reductions in Table 16 is dependent on existing policies achieving
their full expected effect. The state should not take this for granted without further action. The EV Council
is prioritizing the recommendations in Table 16 for 2024 because urgent progress is essential to keep
Washington on pace to achieve existing policies.

Table 17 lists new and continued actions needed to successfully and equitably implement existing
transportation electrification policies, namely ACC I, ACC II and ACT.

It is challenging to isolate the effect on emissions of individual enabling actions that support existing
regulatory policies. Each of the priorities in Table 17 will be essential to achieving the modeled 9.4 MMT
CO2e reduction in 2030 on-road emissions from 2019 levels.

Readers can review Table 38 in Appendix D for an explanation of the emissions and equity determinations
in Table 16 and Table 17.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 138
Table 16 2024 Priorities: New Actions and Emissions Reductions Needed
to Close 2030 Emissions Gap
Legislative Agency
Recommendations* actions actions Lead Agency GHG** Equity***

Transportation Electrification

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 139
Table 16 2024 Priorities: New Actions and Emissions Reductions Needed
to Close 2030 Emissions Gap, continued
Legislative Agency
Recommendations* actions actions Lead Agency GHG** Equity***

Clean Fuels, Vehicle Efficiency and Voluntary Early Retirement

* Numbered items in the recommendations column correspond to the policy items detailed in Chapter 5, How Washington Can Get There, in
Part I and Part II.
** The GHG column reflects estimated incremental GHG emissions reduction in 2030 (metric tons CO2e).
*** The equity column reflects equity benefits, including air quality improvements in overburdened communities, and lower costs, increased EV
access and more non-driving options for vulnerable populations.
**** The emissions level or reduction is a preliminary estimate, not a model output, and requires additional analysis.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 140
Table 17 2024 Priorities: Actions Needed to Successfully and Equitably
Implement Current EV Policies
Legislative Agency Lead
Recommendations* actions actions Agency Equity**
Continue funding WSDOT zero-emission None in 2024 Assess programs WSDOT Significant air
vehicle and infrastructure programs: and develop quality
funding request improvement
2.24 Continue funding WSDOT’s ZEVIP for 2025-27
grant program to provide support for biennium. Lower costs
charging along state routes.
Increased
3.6 Continue funding WSDOT’s Zero-
EV access
emissions Access Program (ZAP).

4.8 Continue funding the WSDOT Green More non-
Transportation Capital grant program. driving options

5.1 Support and expand the e-bike rebate
and lending library programs.

D.3 Continue to invest in early-stage
development of electric and hydrogen
planes.

E.1.1 Vessel decarbonization (ferry vessel
and terminal electrification).
E.1 Port decarbonization (electrification).

More non-
driving options

* Numbered items in the recommendations column correspond to the policy items detailed in Chapter 5, How Washington Can Get
There, in Part I and Part II.
** The equity column reflects equity benefits, including air quality improvements in overburdened communities, and lower costs,
increased EV access and more non-driving options for vulnerable populations.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 141
Table 17 2024 Priorities: Actions Needed to Successfully and Equitably
Implement Current EV Policies, continued
Legislative Agency Lead
Recommendations* actions actions Agency Equity**
2.5 Support planning and building None in 2024 Finish cost Utilities and No ef fect
necessary utility-side charging assessment and Transportation
infrastructure. develop Commission
program as (UTC) and
funding request Commerce
or legislation.

3.14 Fund and support state agency Fund state Implement EO All state No ef fect
ef forts to implement EO 21-04. agency fleets 21-04. cabinet
to successfully agency fleets
implement EO
21-04.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 142
An Amtrak Cascades train zips toward its destination.

Priorities for 2025 and Onward

The EV Council will implement the TES by immediately prioritizing these 14 sets of recommendations.
Based on progress made, it will determine 2025 priorities in fall 2024. The EV Council will then repeat the
same annual prioritization process by identifying key action for the year ahead. TES recommendations not
included in the 2024 list are important to the transition and will be considered for prioritization in the EV
Council’s work in 2025 and the years following.

Monitoring, Evaluation and Continuous Improvement

Successful implementation of Washington’s transition to an electric transportation system will be
measured in EVs on the road, EV chargers installed, air quality improvements, and real and direct equitable
outcomes for overburdened communities and vulnerable populations. To that end, the state will publicly
track the key performance indicators listed below and publish an annual report.

In addition, the EV Council is committed to an adaptive management process to ensure that policies and
programs are having their intended effects and that policies and programs remain flexible and iterative
in the face of a changing market and policy landscape. Given Washington’s position as a first mover in
pursuing an electric future, the historic amount of federal support for clean energy and technology and a
growing embrace of transportation electrification nationwide, significant uncertainty exists in the near- and
long-term implementation of the TES. Metrics should be monitored and evaluated annually. The EV Council
should publish an annual report that assesses progress, identifies roadblocks, and recommends course
corrections as necessary to achieve desired outcomes.

Table 18 details key performance indicators that the EV Council should monitor and evaluate annually,
across the following categories: GHG emission reduced, equity and environmental justice, light-duty EV
adoption, medium- and heavy-duty EV adoption, VMT reduced and charging infrastructure.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 143
Table 18 Metrics and Key Performance Indicators for Tracking Transportation
Electrification Progress
Impact Metric Description Lead Agency

GHG EMISSIONS REDUCED

Estimated gasoline and diesel avoided by (1)
Avoided fossil fuels Gallons changes in gasoline consumption and (2) number Ecology
of EV miles driven

GHG reduction, Metric tons CO2e Estimated GHG emissions reduction attributable to
Ecology
overall EV adoption and reduced VMT

Estimated GHG emissions reduction, attributed to
GHG reduction, Metric tons CO2e electrification of on-road travel, non-road travel Ecology
by sector
and reduction in VMT

Cost-effectiveness Metric tons CO2e Estimated reduction in GHG emissions per dollar
Ecology
/$ spent by the state

EQUITY AND ENVIRONMENTAL JUSTICE

For each vulnerable population (as defined in the
EV adoption
% HEAL Act), compare % EV drivers with % state Commerce, DOL
disparities
population

Total state dollars invested in overburdened
All agencies with
State allocation $, % communities as a percentage of overall funding for
programs
transportation electrification (must be 40%+)

PM2.5, SOx, NOx and other applicable criteria and
Air quality µg/m3 non-criteria pollutants caused by transportation in Ecology
overburdened communities

Measure of percent of a household’s income spent
Transportation energy
% on transportation energy. Evaluate across all Commerce
burden
vulnerable populations

Correlation of crash-
Tracked statewide and in overburdened
related injuries with R-squared
communities, and evaluated across all vulnerable WSDOT
vehicle weight over coefficient
populations
time

Impact of Number of high-frequency routes (under 15-
electrification on # minute headways) within overburdened WSDOT
transit accessibility communities (via Washington Transit Access Map)

Charger reliability in
Frequency and duration of uptime for EV charging
overburdened % Commerce
in overburdened communities
communities

Charger availability in
Percentage of EV chargers in overburdened
overburdened % Commerce
communities, broken out by use case
communities

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 144
Table 18 Metrics and Key Performance Indicators for Tracking Transportation
Electrification Progress, continued
Impact Metric Description Lead Agency

LIGHT-DUTY EV ADOPTION

Electric miles driven Miles Miles driven by light-duty EVs WSDOT

Total light-duty EV registrations in Washington, by
EV registrations # Commerce, DOL
type (BEV, PHEV)

Light-duty EV registrations in Washington, by year
New vs. used EVs # Commerce, DOL
first registered

Year-over-year EV Annual growth in light-duty EV registrations in
% Commerce, DOL
growth Washington, by type

Percent of state cabinet agency light-duty fleets State cabinet
EV share of fleet %
made up by EVs agency fleets

MEDIUM- AND HEAVY-DUTY EV ADOPTION

Electric miles driven Miles Miles driven by MHD EVs WSDOT

ZEV MHD truck Total MHD EV registrations in Washington, by type
# Commerce, DOL
registrations (BEV, FCEV)

Total number of electric and FCEV bus (school and
ZEB registrations # transit) registrations in Washington, by type (BEV, DOL, OSPI
PHEV, FCEV)

MHD EV registrations in Washington, by year first
New vs. used EVs # Commerce, DOL
registered

Year-over-year EV Annual growth in MHD EV registrations in
% Commerce, DOL
growth Washington, by type

Percent of state cabinet agency MHD fleets made State cabinet
EV share of fleet %
up by EVs agency fleets

VMT REDUCED

Year-over-year change in total miles driven
Miles driven Miles WSDOT
(gas/diesel or EV)

Year-over-year change in number of vehicle
Vehicle registrations # Commerce, DOL
registrations (gas/diesel, EV, total)

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 145
Table 18 Metrics and Key Performance Indicators for Tracking Transportation
Electrification Progress, continued
Impact Metric Description Lead Agency

CHARGING INFRASTRUCTURE

# and # per Number of L2 home ports (Single Family Homes
Residential EVSE capita by and Multifamily Homes) deployed in Washington, Commerce
geography assessed in total and per capita by geography

# and # per Number of workplace and public L2 ports
Nonresidential L2
capita by deployed in Washington, assessed in total and per Commerce
EVSE
geography capita by geography

# and # per Number of public DCFCs deployed in Washington,
WSDOT,
Public DCFC capita by assessed in total, per capita and per capita by
Commerce
geography geography

# and # per Number of depot and non-depot EVSE deployed to
MHD EVSE capita by support MHD trucks and buses, assessed in total Commerce
geography and per capita by geography

Average capital investment and operating support,
Average costs $/station, $/port Commerce
by station and by port

Average utilization Percent of time a charger is providing electricity to
% Commerce
rate a vehicle

Charger reliability % Percentage uptime of individual EVSE and stations Commerce

Customer satisfaction surveys issued to
Survey
Customer satisfaction understand consumer experience and any areas for Commerce
responses
improvement and issue resolution

Total charging events # Discrete charging events Commerce

Unique visitors # Unique visitors (drivers) Commerce

Events held to solicit input for station siting,
Public engagement
# promote the program, or other engagement Commerce
events
purposes

Number of EV charging ports installed with primary
State cabinet
State fleet EVSE # purpose of charging state cabinet agency fleet
agency fleets
vehicles

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 146
As a first step in successfully tracking relevant metrics, the EV Council, through the lead of each designated
agency, must:

• Establish methods of data collection and tracking for any new key performance indicators and set
baselines for any new information.

As a reference, the S3 Strong Electrification Policy scenario, which assumes strong policy support to meet
the ACC II mandate among other goals, and sensitivity S3b, which additionally assumes the 2030 goal of
100% electric LDVs is met, establishes guiding metrics the state can use to benchmark its progress and
remain on track to achieve required outcomes (Figure 34).

These metrics are for electrification and efficiency because those are the ways to decarbonize
transportation. They prevent transportation pollution by reducing the use of gasoline and diesel, which
must be tracked and measured to ultimately understand progress on the state’s climate objectives.
Ecology, in coordination with other member agencies, will explore how to best track all transportation fuels
during strategy implementation.

Figure 34 Washington EV Adoption and Infrastructure Milestones
Strong Electrification Policy Key + 2030 Electric LDV Sales Target

2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 147
State staff and interested stakeholders can explore these metrics, as well as those from all the modeled
outcomes of different scenarios and sensitivities tested as part of developing the TES, on the Washington
TES User-Interactive Dashboard.163 These outputs include annual sales, sales share, total vehicle
population, EV charging requirements, GHG emissions and local air pollutants. Most outputs are segmented
by different dimensions across the different pages, including vehicle segment (e.g., LDVs, MD trucks),
county, census block group and year (2023–35).

163 Washington TES User-Interactive Dashboard, found on the TES website.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 148
7. Conclusion

An electric vehicle gets a charge with Washington's evergreens in the background.

Washington’s TES builds on years of state leadership and recent historic federal investment in
transportation decarbonization. Against this backdrop, the state’s focus is to ensure the transition
to an electrified transportation system is as efficient, equitable and effective as possible. The policy
recommendations contained in this report are designed to meet these objectives, by setting up the
supportive infrastructure necessary for rapid scaling, intentionally and proactively directing benefits
to overburdened communities and vulnerable populations, and ensuring the electrification transition
supports the state’s wider decarbonization targets in 2030, 2040 and beyond. Because of the lagging nature
of vehicle stock turnover, analysis from this report shows that the next five years, and even the next two
years, are critical for the state to meet its ambitious climate goals. The implementation plan included in the
TES outlines a strategic path for state policymakers and agencies to do just that.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 149
Appendices
A. Glossary

B. TES Engagement: Phase 1 and 2 Participants and Findings

C. Summary of Public Comment Feedback and Major Changes

D. Technical Appendix

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 150
Appendix A — Glossary

2021 State Energy Strategy (SES) – The Department of Commerce produced the 2021 State Energy
Strategy to provide a roadmap for meeting the state’s greenhouse gas emission limits.

Advanced Clean Cars II (ACC II) – A regulation originally established in California and implemented in
Washington by the Department of Ecology, ACC II requires a progressively stringent zero-emissions vehicle
sales share, culminating in a 100% sales requirement of zero-emissions LDVs by 2035.

Advanced Clean Fleets (ACF) – A California regulation requiring fleets to adopt an increasing percentage
of ZEVs beginning in 2024 and culminating with a 100% ZEV sales requirement by model year 2036. ACF is
designed to be complementary to ACT.

Advanced Clean Trucks (ACT) – Set in California and implemented in Washington by the Department
of Ecology, this regulation establishes a manufacturer’s ZEV sales requirement and includes a one-time
reporting requirement for large entities and fleets.

Battery electric vehicles (BEV) – BEVs are vehicles that can be powered by an electric motor that draws
electricity from a battery and is charged through an external source. These vehicles do not produce
tailpipe emissions.

Black, Indigenous and People of Color (BIPOC) – A term used to refer to people of color, with specific
emphasis on Black and Indigenous communities.

California Air Resources Board (CARB) – A California agency that protects public health from the harmful
effects of air pollution, and develops programs to fight climate change.164

Carbon dioxide equivalent (CO2e) – The number of metric tons of CO2 emissions with the same global
warming potential as one metric ton of another greenhouse gas.

Clean Energy Transformation Act (CETA) – Signed into law on May 7, 2019, by Governor Jay Inslee, CETA
commits Washington to an electricity supply free of GHG emissions by 2045.165

Clean Fuel Standard (CFS) – Washington’s Clean Fuel Standard law requires fuel suppliers to gradually
reduce the carbon intensity of transportation fuels to 20% below 2017 levels by 2034. This could be through
improving the efficiency of their fuel production processes, producing or blending low-carbon biofuels into
the fuel and purchasing low-carbon fuel credits.166

Climate Commitment Act (CCA) – The CCA caps and reduces GHG emissions from Washington’s largest
emitting sources and industries, allowing businesses to find the most efficient path to lower carbon
emissions. This powerful program works alongside other critical climate policies to help Washington
achieve its commitment to reduce GHG emissions by 95% by 2050.167

164 CARB.
165 “Clean Energy Transformation Act.”
166 State of Washington Department of Ecology, “Clean Fuel Standard,” (n.d.).
167 “Climate Commitment Act.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 151
Combined Charging Systems (CCS) – An open international standard for connectors used to rapid-charge
electric vehicles.

Community-based organization (CBO) – An organization that is driven by community residents, and
typically provides a bottom-up approach for participation in development efforts.

Cost parity – Total cost of ownership cost parity refers to equivalent lifetime costs for an EV and an ICE
vehicle of similar types (e.g., sedans), when considering the all-in cost of not only purchasing the vehicle,
but also the operating costs over its lifetime, including maintenance and fuel or charging costs. Purchase
cost parity refers to equivalent purchase costs for an EV and an ICE vehicle of similar types, based solely on
the up-front cost of the vehicle.

Department of Enterprise Services (DES) (Washington state) – DES provides centralized business
services to state government agencies, to other public entities such as cities and counties, to tribal
governments and to Washington residents.

Department of Health (DOH) (Washington state) – DOH works with others to protect and improve the
health of all people in Washington.

Department of Licensing (DOL) (Washington state) – DOL provides driver’s licenses, identification cards,
license plates and vehicle and boat registrations. DOL also provides licenses for some professions.

Department of Revenue (Washington state) – DOR is Washington’s primary tax agency, overseeing 60
categories of taxes, which provide funds for important state services.

Direct current fast charger (DCFC) – Rapid charging infrastructure designed to charge a BEV to 80%
in 20 minutes to one hour. DCFC charging ranges from 400 to 1,000 volts direct current and provides a
typical power output of 50 to 350 kW, providing an estimated 180 to 240 miles of electric range per hour of
charging.168 DCFCs are also referred to as L3 chargers.

Distributed energy resources (DERs) – Small, modular energy-generation resources that sometimes also
include storage technologies, DERs can either be connected to the local electric grid or be a stand-alone
system.169

Electric vehicle (EV) – An EV is a vehicle that can be powered by an electric motor that draws electricity
from a battery and is charged through an external source. These vehicles do not produce tailpipe
emissions.

Electric Vehicle Infrastructure Training Program (EVITP) – EVITP is a program that certifies electricians
in the United States and Canada. Some places require at least one electrician working on an EV charging
installation project to be EVITP certified.

Electric vehicle service provider (EVSP) – The EVSP delivers end-to-end EV charging and is responsible
for managing, controlling and optimizing the EV charging station operations and experience.

168 U.S. Department of Transportation, “Charger Types and Speeds,” (n.d.).
169 National Renewable Energy Lab, “Using Distributed Energy Resources,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 152
Electric vehicle supply equipment (EVSE) – A more complete term used for EV charging infrastructure and
its component parts, EVSE includes both hardware and software, such as charging chords, charging stands
or enclosures, plugs and software.

Energy Resilience and Emergency Management Office (EREMO) – Housed in the Energy Division of the
Department of Commerce, EREMO is focused on energy assurance planning.

Environmental Health Disparities Map – An interactive mapping tool that compares communities across the
state for environmental health disparities. It shows pollution measures such as diesel emissions, ozone and
proximity to hazardous waste sites, and other metrics such as poverty and cardiovascular disease rates.

Environmental justice (EJ) – EJ is the meaningful involvement and fair treatment of all people
regardless of race, color, national origin or income, with respect to the development, implementation
and enforcement of environmental laws, regulations and policies. This should lead to the same degree of
protection from environmental and health hazards, and equal access to the decision-making process to
have a healthy environment.170

Federal Highway Administration (FHWA) – The Federal Highway Administration (FHWA) is an agency
within the U.S. Department of Transportation that supports State and local governments in the design,
construction and maintenance of the Nation’s highway system.

Fuel cell electric vehicle (FCEV) – A FCEV is a vehicle that is powered by a hydrogen fuel cell. Hydrogen is
converted to electricity by the fuel cell, which is used to power the vehicle. FCEVs do not produce harmful
tailpipe emissions, only water vapor and warm air.

Greenhouse gas (GHG) – GHGs are gases that trap heat in the atmosphere, including carbon dioxide (CO2),
methane (CH4), nitrous oxide (N2O) and fluorinated gases. As GHGs build up in the atmosphere, they trap
the sun’s heat and alter the earth’s climate.

Hazardous air pollutants (HAPs) – Hazardous air pollutants, also known as toxic air pollutants or air
toxics, are pollutants that are known or suspected to cause cancer or other serious health effects, such as
reproductive effects or birth defects, or adverse environmental effects.

Healthy Environment for All Act of 2021 (HEAL Act) – The HEAL Act works toward eliminating
environmental and health disparities among communities of color and low-income households. The
HEAL Act covers seven Washington state agencies: Health, Agriculture, Commerce, Ecology, Natural
Resources, Transportation and Puget Sound Partnership. The HEAL Act builds on recommendations from
the Environmental Justice Task Force, including incorporating environmental justice into agency work,
promoting the equitable sharing of environmental benefits, investing in communities that have experience
significant environmental and health burdens and supporting evaluation tools and processes.171

Heavy-duty (HD) vehicle – Vehicles that have a gross vehicle weight rating greater than 26,000 pounds.
This includes weight classes 7 and 8.172

170 EPA, “Environmental Justice,” (n.d.).
171 DOH, “Environmental Justice,” (Washington State Department of Health), n.d.
172 FHWA, “Traffic Monitoring Guide — Appendix C. Vehicle Types,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 153
Inflation Reduction Act (IRA) – Signed on August 16, 2022, the IRA is a significant piece of federal
legislation designed to help the United States meet its climate goals, strengthen energy security, create
good-paying jobs and reduce energy and health care costs. It includes, for example, tax incentives for EVs
and has spurred investment in the EV supply chain.173

Interagency Electric Vehicle Coordinating Council (EV Council) – Move Ahead Washington established
the EV Council to align existing transportation electrification efforts across state agencies.

Internal combustion engine (ICE) – A vehicle that uses gasoline, diesel or alternative fuels such as natural
gas, propane, biodiesel or ethanol to power its engine. ICE vehicles directly produce harmful tailpipe
emissions.

Investor-owned utilities (IOUs) – IOUs are private, monopoly utilities that generate and distribute power
to electric customers within their defined service territory.

Joint Transportation Committee – The JTC is a bipartisan, bicameral legislative agency that conducts
transportation-related studies and other related activities to inform state and local government
policymakers and legislators.174

Justice40 – A goal set by the federal government that 40% of the overall benefits of certain federal
investments need to flow to disadvantaged communities that are marginalized, underserved and
overburdened by pollution.

Kilowatt-hour (kWh) – A measure of electricity, measured as 1,000 watts of power expended over one hour.

Labor & Industries Department (LNI) (Washington state) – A state agency that focuses on the safety,
health and security of Washington’s workers. The agency helps employers meet health and safety
standards and inspects workplaces when informed of hazards.

Level 1 EV charger (L1) – L1 chargers provide charging through a common residential 120-volt alternating
current (AC) outlet. It can take 40 to 50-plus hours to charge a BEV to 80% on an L1 charger. The typical power
output of an L1 charger is about 1 kW, which can provide 2 to 5 miles of electric range per hour of charging.175

Level 2 EV charger (L2) – L2 chargers provide higher-rate alternate current (AC) charging through 240- or
208-volt residential or commercial electrical service. It can take 4 to 10 hours to charge an EV from empty to
80% on an L2 charger. The typical power output of an L2 charger is 7 to 19 kW, which can provide 10 to 20
miles of electric range per hour of charging.176

Level 3 EV charger (L3) – Refer to the definition of DCFC.

Light-duty vehicle (LDV) – Vehicles that have a gross vehicle weight rating less than 10,000 pounds. This
includes weight classes 1 and 2.177 LDVs are generally considered passenger vehicles.

173 The White House, “FACT SHEET: One Year In, President Biden’s Inflation Reduction Act Is Driving Historic Climate Action
and Investing in America to Create Good Paying Jobs and Reduce Costs,” (n.d.).
174 Washington State Legislature, “Joint Transportation Committee,” (n.d.).
175 “Charger Types and Speeds.”
176 “Charger Types and Speeds.”
177 “Traffic Monitoring Guide — Appendix C. Vehicle Types.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 154
Low-to-moderate income (LMI) – A low-income community is one with a median family income of less
than 50% of the area median income. A moderate-income community means the median family income is
between 50% and 80% of the area median income.

Medium- and heavy-duty vehicle (MHDV) – An umbrella term that refers to medium-duty and heavy-duty
vehicles collectively.

Medium-duty (MD) vehicle – Vehicles that have a gross vehicle weight rating between 10,001 and 26,000
pounds. This includes weight classes 3, 4, 5 and 6.178

Minority and Women’s Business Enterprises (M/WBE) – M/WBE businesses can be certified by
Washington to enhance their procurement opportunities for certified businesses participating in state-
funded projects or working with state agencies, local governments, school districts and public universities.
To be M/WBE certified, a business must be for profit, be licensed in Washington, be able to fulfill a contract
in the business’s area of expertise, be a small business and have an eligible owner. An eligible owner
meets the criteria of being a minority or a woman, owns at least 51% of the company, controls day-to-day
operations and is economically disadvantaged.179

National Electric Vehicle Infrastructure (NEVI) Formula Program – This FHWA program provides
funding to states to deploy strategic EV charging stations to develop an interconnected network. Funding
is available for up to 80% of eligible project costs, including acquisition, installation, network connection,
operations and maintenance of charging stations, and data sharing.180

National Highway Transportation Safety Administration Corporate Average Fuel Economy (CAFE)
standards – Mandated by Congress since 1975, the CAFE standards regulate how far vehicles must travel on
one gallon of fuel.181

Nitrogen oxides (NOx) – A combination of the gases nitrogen and oxygen, NOx are released in tailpipe
emissions from ICE vehicles and more generally from the burning of coal, oil and natural gas.

North American Charging Systems (NACS) – The North American Charging Standard (NACS) is a charging
connector interface standard for electric vehicles that Tesla Inc. developed and has made available for use
by other charging network operators and automakers.

Office of Equity (Washington state) – The Office of Equity was created by the Legislature and signed into
law April 2020, with the mission to promote access to equitable opportunities and resources that reduce
disparities and improve outcomes statewide across government.

Office of Financial Management (OFM) (Washington state) – OFM provides information, fiscal services
and policy support to the governor, Legislature and state agencies.

Office of Superintendent of Public Instruction (OSPI) (Washington state) – OSPI oversees public K–12
education in the state, including allocating funding and providing tools, resources and technical assistance.
It is also responsible for the safe and efficient transport of students, including school bus procurement.

178 “Traffic Monitoring Guide — Appendix C. Vehicle Types.”
179 Washington State Office of Minority & Women’s Business Enterprises, “State Certification,” (n.d.).
180 U.S. Department of Energy, Energy Efficiency & Renewable Energy, “National Electric Vehicle Infrastructure (NEVI) Formula
Program.”
181 U.S. Department of Transportation, “Corporate Average Fuel Economy (CAFE),” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 155
Original equipment manufacturer (OEM) – An original producer of vehicle components.

Overburdened community – A geographic area where vulnerable populations face multiple environmental
harms and health impacts or risks due to exposure to environmental pollutants or contaminants through
multiple pathways, which may result in significant disparate adverse health outcomes or effects.

Plug-in hybrid electric vehicle (PHEV) – A PHEV is a vehicle that is powered by both an electric motor that
draws electricity from a battery and by an ICE. The ICE element produces tailpipe emissions.

PM2.5 – Fine inhalable particulate matter with a diameter less than 2.5 micrometers.

PM10 – Inhalable particulate matter with a diameter less than 10 micrometers.

State Efficiency and Environmental Performance (SEEP) (Washington state) – SEEP works with state
agencies to achieve reductions in GHG emissions and eliminate toxic materials from state agency operations.

State Transportation Carbon Reduction Strategy (TCRS) – Building on the 2021 SES, the TCRS will
identify and summarize the strategies for reducing transportation carbon emissions that are being
developed and implemented by state agencies, tribes, freight, aviation, ports and regional and local
jurisdiction partners. It was submitted to FHWA in November 2023.182

Sulfur oxides (SOx) – SOx are made from sulfur and oxygen and contribute to acid rain and particulate
pollution. They can be created by burning coal, oil and gas.183

Sustainable aviation fuel (SAF) – A biofuel that has similar properties to conventional jet fuel, but with a
smaller carbon footprint. SAF can be used to power aircraft and can be made with renewable biomass and
waste resources.

Total cost of ownership (TCO) – The TCO of an asset is calculated by adding the up-front cost of purchase
and the operating costs over the asset’s lifetime, including maintenance and fuel or charging costs.

Transportation electrification – Transportation electrification is the process of developing the
infrastructure, systems and policies needed to transition all forms of transportation — public, private,
commercial, etc. — to be electrically powered.

Transportation Electrification Strategy (TES) – A strategy initiated by the EV Council to align existing
transportation electrification efforts across 10 state agencies and offices and develop an equitable and
inclusive statewide strategy pegged to the nonbinding 2030 EV target and aligned with the state’s 2030
emissions limit.

Transportation network company (TNC) – Also known as ridesharing companies, TNCs provide
prearranged transportation services for compensation, usually through an online-enabled application to
connect drivers with passengers.184

182 Washington State Department of Transportation, “Washington State Transportation Carbon Reduction Strategy,” (n.d.).
183 UCAR Center for Science Education, “Sulfur Oxides,” (n.d.).
184 California Public Utilities Commission, “Transportation Network Companies,” (n.d.)

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 156
Utilities and Transportation Commission (UTC) (Washington state) – A three-member commission
appointed by the governor and confirmed by the state senate, designed to protect the people of Washington
by ensuring that IOU and transportation services are safe, equitable, reliable and fairly priced.185

Vehicle miles traveled (VMT) – The measurement of the number of miles traveled by a vehicle.

Vehicle-to-grid (V2G) – V2G is when unused power is drawn from an EV battery to provide more energy to
the grid, especially during peak electricity hours or extreme conditions.186

Virtual power plants (VPPs) – VPPs are an aggregation of small-scale DERs that together, in coordination
with grid operations, can offer additional energy and capacity to the grid similar to traditional power
plants, providing increased reliability. Components of a VPP can include EVs, home appliances, batteries
and heat pumps.187

Volatile organic compounds (VOCs) – Compounds that have high vapor pressure and low water solubility,
VOCs are often components of petroleum fuels, hydraulic fluids, paint thinners and dry-cleaning agents.
They are common groundwater contaminants and can have short- and long-term health effects.188

Vulnerable populations – As defined in the HEAL Act, vulnerable populations include racial or ethnic
minorities, low-income populations, populations disproportionately impacted by environmental harms
and populations of workers experiencing environmental harms.

Washington State Department of Transportation (WSDOT) – WSDOT provides safe, reliable and cost-
effective transportation options to improve communities and economic vitality for people and businesses.189

Washington State University (WSU) – WSU is a public research university dedicated to improving lives by
serving the public good. The university has six campuses, 11 academic colleges, extension offices in all 39
Washington counties and four research and extension centers.190

Zero-emissions Access Program (ZAP) – A WSDOT program that offers grant funding for zero-emissions
car-share pilot programs in underserved and LMI communities.191

Zero-emissions vehicle (ZEV) – The EPA categorizes all-electric vehicles as ZEVs because they do not
generate direct exhaust or tailpipe emissions. ZEVs include fuel cell EVs.192

Zero-emission Vehicle Infrastructure Partnerships (ZEVIP) – A WSDOT program that offers grant
funding for the installation of new EV charging equipment and hydrogen fueling infrastructure located on
priority corridors.193

185 Washington Utilities and Transportation Commission, “About the Commission,” (n.d.).
186 IEEE, “Vehicle to Grid (V2G) Technology,” (n.d.).
187 Liza Martin and Kevin Brehm, “Clean Energy 101: Virtual Power Plants,” (January 10, 2023).
188 EPA, “What are Volatile Organic Compounds (VOCs)?” (n.d.).
189 Washington State Department of Transportation, “Strategic Plan,” (n.d.).
190 Washington State University, “About Washington State University,” (n.d.).
191 WSDOT, “Zero-Emissions Access Program Grant,” (n.d.).
192 U.S. Department of Energy, Energy Efficiency & Renewable Energy, “All Electric Vehicles,” (n.d.).
193 WSDOT, “Zero-emission Vehicle Infrastructure Partnerships Grant,” (n.d.).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 157
Appendix B — TES Engagement: Phase 1 and 2 Participants and Findings

Tables 19 to 22 summarize all participants from Phase 1 and 2 engagement. The tables list participants by
group and organization. “Group” refers to categories into which the TES project team sorted participants
based on the overarching audience or interest they represented. “Group” does not represent organizational
affiliation. A summary of findings from each engagement effort can be found below the participant tables.

Table 19 Phase 1 —One-on-One Interview Participants
# Group Organization/Affiliation
1 Community leader HomeSight

2 Community leader Former Yakima City Council Member; Washington State Labor Council

3 Community leader Transit Riders Union

4 Community leader Washington Tenants Union

5 Community leader Asian American Pacific Islander (AAPI) Senior; Community Leader

6 Labor Drivers Union

7 Labor Northwest Laborers’-Employers Cooperation & Education Team (LECET)

8 Labor Teamsters Local 117

9 Local jurisdiction Port of Seattle

10 Multimodal transit users Cascade Bicycle Club

11 Multimodal transit users Seattle Neighborhood Greenways

12 Organizations Sierra Club

13 Organizations Transportation Choices Coalition

14 Overburdened communities African Chamber of Commerce

15 Overburdened communities BIPOC Mobility Action Coalition

16 Overburdened communities Environmental Coalition of South Seattle (ECOSS)

17 Overburdened communities Gather Together, Grow Together

18 Overburdened communities Puget Sound Advocates for Retirement Action (PSARA)

19 Overburdened communities Puget Sound Sage

20 Overburdened communities Spokane Neighborhood Action Partners (SNAP)

21 Overburdened communities WA Build Back Black Alliance

22 Overburdened communities Washington State Community Action Partnership

23 Overburdened communities Yakima Pacific Islander Coalition

24 Overburdened communities Asian Pacific Islander Coalition (APIC) Spokane

25 Overburdened communities People’s Economy Lab

26 Overburdened communities WA African Community Leaders

27 Overburdened communities Earth Ministry; Washington Interfaith Power and Light

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 158
Table 20 Phase 2 — One-on-One Interview Participants
# Group Organization/Affiliation

1 EVSE contractors Puget Sound Solar, LLC

2 Organizations Transit Riders Union

3 Local jurisdictions City of Mount Vernon

4 Local jurisdictions Association of Washington Cities

Association of Western Pulp and Paper Workers (Commerce
5 Manufacturing and distributing
Manufacturing Council)

Multifamily housing property
6 Washington Multifamily Housing Association
managers/owners

7 Organizations Methow Valley Citizens Council

8 Organizations America Walks

9 Overburdened communities Tri-Cities Hispanic Chamber of Commerce

10 Overburdened communities Firelands Workers Action

11 School Walla Walla Public Schools

12 Towing fleet Towing & Recovery Association of Washington

13 Towing fleet Airport Towing

Tribes and sovereign government
14 Columbia River Inter-Tribal Fish Commission
partners

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 159
Table 21 Phase 1 — Focus Group Participants

# Group Organization/Affiliation
1 EV Driver Private Citizen

2 EV Driver Private Citizen

3 EV Driver Private Citizen

4 EV Driver Coltura; Seattle Electric Vehicle Association

5 EV infrastructure manufacturers and distributors Blink Charging

6 EV infrastructure manufacturers and distributors ChargePoint

7 EV infrastructure manufacturers and distributors Electrify America

8 EV infrastructure manufacturers and distributors EV Support, Puget Sound Solar

9 EV infrastructure manufacturers and distributors Tesla

10 EV infrastructure manufacturers and distributors Mobility House

11 EV infrastructure manufacturers and distributors Hubject

12 EV manufacturer/dealer Alliance for Automotive Innovation

13 EV manufacturer/dealer Daimler

14 EV manufacturer/dealer GM

15 EV manufacturer/dealer Tesla

16 EV manufacturer/dealer Toyota Motor North America

17 EV manufacturer/dealer Volvo Group North America

18 Organizations Drive Electric WA

19 Organizations Seattle Electric Vehicle Association

20 Organizations AAA Washington

21 Organizations Climate Solutions

22 Organizations Coltura

23 Organizations Union of Concerned Scientists

24 Organizations Zero Emission Transportation Association (ZETA)

25 Utility Clark Public Utilities

26 Utility PacifiCorp

27 Utility Seattle City Light

28 Utility Snohomish PUD

29 Utility WA Public Utilities Districts Association (WPUDA)

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 160
Table 22 Phase 2 — Focus Groups Participants

# Group Organization/Affiliation

1 Labor The International Brotherhood of Electrical Workers (IBEW) 46

Washington State Building & Construction Trades Council,
2 Labor
AFL-CIO

3 Labor Amalgamated Transit Union (ATU)

4 Labor Blue Green Alliance

5 Labor ATU 843

6 Mobility Equity Cabinet Nakani Native Program; Consultant/Facilitator/DEI Trainer

7 Mobility Equity Cabinet Para los Ninos

8 Mobility Equity Cabinet University of Washington

9 Mobility Equity Cabinet Community Leader

10 Mobility Equity Cabinet Community Leader

11 Mobility Equity Cabinet White Center Community Development Association

The National Association for the Advancement of Colored
12 Mobility Equity Cabinet
People (NAACP)

13 Mobility Equity Cabinet Community Leader

14 Mobility Equity Cabinet King County Metro

15 Mobility Equity Cabinet King County Metro

Multifamily housing property
16 Washington Multifamily Housing Association
managers/owners

Multifamily housing property
17 Fourth Ave Capital
managers/owners

Multifamily housing property
18 Equity Residential Properties
managers/owners

Multifamily housing property
19 Greystar
managers/owners

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 161
Findings from Phase 1 Focus Groups and Interviews

This section summarizes findings from focus groups and one-on-one interviews. To analyze the feedback
from participants, the project team coded all responses to each discussion question into key themes. The
project team then synthesized those initial themes into higher-level themes, which are reported below.

The themes in this section are presented in the following categories:

• General Views of Electrification
• Community Understanding of Electrification
• Barriers to Adoption and Use of EVs
• Barriers to Installation of Charging Infrastructure
• Suggested State Actions to Increase Access to and Feasibility of EVs
• EV Infrastructure Needs in Washington
• Recommendations for Electrification Incentives
• Preferred Methods for Information Sharing
• Implementing an Equitable Electrification Transition
General Views of Electrification

The following themes represent how participants understand and think about transportation
electrification in general.

General Perceptions of Electrification

• Electrification is necessary for Washington to reduce GHG emissions, address climate change and
mitigate adverse impacts from transportation pollution in overburdened communities.

• Although necessary, electrification is not the only solution to the climate crisis. Washington must
consider the entire transportation system and invest in transit, active transportation (biking, walking
and rolling) and multimodal options.

Critical Needs

• To achieve a just transition, electrification must be implemented equitably and keep environmental
and racial justice at the forefront.

• There is a current lack of education about electrification, and the state needs to educate, inform,
and solicit feedback from community members, understanding that many communities have other
pressing priorities.

• Industry stakeholders noted that the transition is already happening, but MHDV electrification will
require significant state policy intervention to make the transition.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 162
Concerns about Electrification

• There are economic challenges, namely high up-front costs for EVs and budget limits that restrict the
ability of utilities and government agencies to implement this transition.

• There are concerns about workforce changes, the use of natural resources to produce batteries and
increasing vehicle weight due to batteries.

• There are also concerns about limited reliable and accessible charging infrastructure, and
technological and electrical grid limitations.

• Rural, suburban and agricultural communities, particularly in Central and Eastern Washington, need
tailored solutions and assistance to make the transition.

Community Understanding of Electrification

The following themes synthesize participants’ characterization of their community’s understanding of
electrification. These themes are from the interviews alone, not focus groups. Since interviewees were mainly
community leaders, they were asked specific questions about the community they serve.

Inequitable Access to Electric Transportation

• Communities of color and low-income communities often live closest to transportation corridors and
industrial facilities and are overburdened by the health impacts of pollution and poor air quality. These
overburdened communities have been largely excluded from decision-making and policy prioritization
within the electrification conversation.

• For many, electrification is not as immediate a priority as basic needs such as neighborhood safety,
affordable transportation, employment, food and housing.

• There is a lack of accurate, accessible information about transportation electrification within
Washington communities.

• EVs are still too expensive for many people to transition. This exacerbates existing inequities within the
transition, such as the decreasing value of assets for those who cannot afford to buy EVs.

Electrification Beyond Personal Vehicles

• Overwhelmingly, interviewees discussed the need to electrify more than just personal cars and LDVs.
Interviewees emphasized the importance of electrifying transit, MHDVs, bikes and scooters.

Challenges to Electrification

• Rural communities have different needs within the electrification transition than communities in cities
and urban areas.

• There is limited availability of charging stations at homes (particularly apartments and multifamily
housing) and workplaces.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 163
• Community members are concerned about workforce transitions and job security during the transition.
• Transportation electrification could exacerbate issues related to accessing infrastructure and
transportation options for people with disabilities, such as EV charging cables crossing sidewalks.

Barriers to Adoption and Use of EVs

The following themes summarize the barriers participants shared that hinder the adoption and use of EVs
in their community or industry.

Cost and Incentives

• High cost of EVs: The high up-front cost for EVs — from e-bikes and personal cars to MHDVs — is a large
barrier for many, particularly low-income communities and small businesses.

• Fragmented, limited and confusing incentives and grants: Incentives and grants for EVs are
fragmented, incompatible with each other, and have regulatory limits. Applications can be difficult to
navigate, and existing incentives are not sufficient to make EVs affordable, especially for MHDVs.

Charging

• Insufficient charging infrastructure and lack of standardization: There is a lack of publicly available
charging infrastructure and charging infrastructure for multifamily housing. It is expensive to install
charging infrastructure. Current lack of regulations and standards for charging infrastructure makes
charging stations difficult to use, unreliable and unpredictable. Charging stations vary in cost, access
and charging speed.

• Grid supply and utility capacity: The electrical grid needs to be updated to support the widespread
and rapid deployment of EV infrastructure, such as charging. EVs will increase overall electricity
demand, which requires that new generation, transmission and distribution resources be quickly built.
Coordination among utilities and EVSE and charging companies needs to be dramatically improved.
Without coordination, concerns that interconnection times will significantly delay EVSE installations
may become a reality.

Public Awareness and Opinion

• Misinformation and lack of education: Communities have limited exposure to and education about
EVs. Information can be inaccessible, particularly for non-English speakers and people with limited
access to technology. Education and outreach are needed to combat misconceptions about EVs.

• Cultural resistance: People who do not currently own or drive a vehicle may remain resistant to the
transition to EVs.

• Mistrust of government: Overburdened communities continue to be excluded from decision-making
and need to be heard and engaged to ensure their priorities guide the electrification transition.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 164
Vehicle Technology

• Lagging MHDV technology: Technology for electric MHDVs, particularly long-haul trucking, is not as
comprehensive as technology for electric LDVs.

• Limited vehicle range: Both actual and perceived range limits keep many community members and
industries from adopting EVs.

Procedure and Process

• Long wait times for both EVSE and EVs: Long permitting timelines delay infrastructure installation.
Limited availability of EVs themselves, as well as infrastructure and equipment, cause long wait times.

Barriers to Installation of Charging Infrastructure

The following themes represent barriers to installing and energizing charging infrastructure, as identified
by participants in the utilities and EVSP focus groups.

Equipment and Infrastructure

• Installation and charging equipment (particularly switch gears and transformers) are experiencing
supply chain delays and limited availability.

• It is difficult to find contractors to install charging equipment.
• There is resistance from landlords and homeowner associations, especially for renters.
Procedure and Process

• Insufficient supporting infrastructure and building codes: Existing building and electrical
infrastructure may not support EV infrastructure or electrical upgrades and may need retrofitting.

• Insufficient building codes: Building codes are insufficient to support infrastructure development and
charging placement.

Utilities

• There is a lack of easements allowing utilities and EVSPs to access public light poles.
Suggested State Actions to Increase Access to and Feasibility of EVs

The following themes synthesize participant suggestions for actions Washington can take to make EVs more
feasible for their community or industry.

Incentives and Benefits

• Provide funding for incentives, rebates and low-income loans to increase access to EVs, reduce total EV
costs and achieve cost parity with ICE vehicles.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 165
• Create targeted incentives for electrifying vehicles in overburdened communities. Additionally, create
targeted incentives for MHDVs. Consider pairing regulations and incentives.

• Consider policies that pair electrification with the adoption of solar.
Infrastructure

• Increase and improve charging infrastructure, particularly publicly accessible and multifamily
residential charging stations.

• Improve and design street infrastructure for multimodal transportation options. Streets need to
have comprehensive bike facilities that are safe for e-bikes and should encourage transit and active
transportation.

Education and Engagement

• Develop and implement consistent, clear educational campaigns about all aspects of EVs, including
incentives, charging and regulations and requirements.

• Let community voices develop campaigns so they are authentic and resonant with their communities.
• Beyond education, reach out to, engage with, and hear feedback from community members.
• Support workforce development to ensure job and economic security for workers during the transition.
• Host EV car-share programs to increase exposure and awareness within communities.
State Fleets

• Lead by example and model EV adoption by electrifying Washington’s fleets.
EV Infrastructure Needs in Washington

The following themes encapsulate how participants characterize infrastructure needs and their suggested
infrastructure changes to facilitate the transition to EVs.

Charging Infrastructure

• Need for an easily accessible public charging network, with charging stations co-located at community
hubs (like grocery and retail) and protected from vandalism or destruction.

• Need for secure charging stations and storage for EVs, including e-bikes.
• Charging infrastructure needs to support charging for MHDVs.
• Permitting and insurance timelines need to be shortened.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 166
Street Infrastructure

• Create safer streets that facilitate multimodal transportation, including transit, biking, walking and
rolling.

Electric Infrastructure

• Upgrade existing electric infrastructure, particularly utility lines, to enhance grid capacity, reliability
and resilience.

Engagement and Training

• Engage and educate community members about EV charging and technology, so they can more easily
access and use charging infrastructure.

• Support or provide job training for EV repair and encourage more EV service shops.
• Coordinate with fleet owners and local municipalities to implement fleet electrification or help electrify
service vehicles.

Recommendations for Electrification Incentives

The following themes represent participants’ recommendations for incentives and benefits that will help
Washington achieve a faster transition to EVs.

Ease and Accessibility

• Incentives need to be simple, streamlined and understandable. Education and training should
accompany incentive programs and incentives should be “stackable,” so people can apply for multiple
programs and incentives with one application.

• Participants emphasized the importance and ease of point-of-sale incentives. They generally preferred
rebates over tax incentives, although a few participants preferred tax incentives. Participants also
mentioned stipends, grants, trade-in programs, subsidies and lowered insurance rates.

Charging Benefits

• Charging-based incentives, including access to low-cost charging stations or workplace and public
charging stations, are beneficial.

Equitable Incentives

• Incentives should support vulnerable and overburdened communities. Incentives should be designed
to prevent predatory financing, such as high-interest loans.

• Infrastructure improvements should have an anti-displacement focus to ensure that upgraded or newly
built infrastructure does not displace residents by increasing property costs.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 167
Preferred Methods for Information Sharing

The following themes summarize effective methods for sharing information, educating people, and
increasing awareness about electrification and EVs, as recommended by participants.

Hands-on Experience

• Provide hands-on educational opportunities, such as in-person ride-and-drive events.
Partnerships

• Partner with CBOs and trusted local community members to spread the word about electrification.
• Partner with rideshares, schools and driving schools to expand EV visibility and education in
communities.

• Partner with trusted community media sources and influencers for advertising, earned media and
social media campaigns.

Communication Channels

• Send large, widespread digital communications through traditional methods, such as email blasts and
newsletters.

• Utilize conventional media sources for advertising and earned media.
• Meet people where they are, such as CBOs, churches, unions and other community gathering spaces.
• Share information through government-based sources (e.g., departments of transportation, OEMs,
utilities).

Accessible Engagement

• Ensure materials are accessible and inclusive, including providing materials in multiple languages.
• Lean on digital media, such as podcasts and digital workshops and trainings.
• Use a multipronged approach that includes several methods of outreach and education to ensure
reaching as many community members as possible.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 168
Implementing an Equitable Electrification Transition

The following themes synthesize actions and priorities that participants recommend be included in the TES
to ensure that electric transportation equitably serves Washington communities.

Holistic Transformation for Transportation

• Design a reliable and inclusive transportation system because many will not be able to afford a
personal EV. This includes expanding and investing incentives and supportive infrastructure for other
transportation modes, particularly transit and e-bikes.

• Prioritize electrifying HD trucks and buses where they cause disproportionate air quality impacts,
especially on overburdened communities.

• Enhance safety investments to create walkable, bikeable neighborhoods.
• Create protections against rising electricity prices, especially for the energy insecure.
Increased Access to Electric Vehicles

• Provide equitable access to low-cost EVs and low-cost electricity for charging.
• Create reliable, fast-charging infrastructure that is equitably accessible to community members. This
includes charging infrastructure specific to multifamily buildings and in other public gathering places
and destinations.

• Create programs that benefit rural areas, small towns and suburban areas.
• Conduct research on funding and grant opportunities for community members.
Engagement and Education

• Engage and collect input from community members to create and implement equitable programs.
• Ensure equitable and accessible education for community members. This includes EV pilot programs
and job training for workforce development.

Local Policy, Housing and Land Use

• Work with local jurisdictions to update codes and policies to ensure efficient implementation.
• Approach this topic more holistically, going beyond transportation to include affordable housing,
housing displacement and land use. Decreasing emissions could be more efficient by tackling the
climate crisis with a multipronged approach.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 169
Findings from Phase 2 Focus Groups and Interviews

This section summarizes findings from focus groups and one-on-one interviews. To analyze the feedback
from participants, the project team coded all responses to each discussion question into themes.
The findings in this section are presented in the following categories:

• General Views of and Existing Reactions to Transportation Electrification
• Barriers to Adoption and Use of EVs
• Suggested State Actions to Increase Access to and Feasibility of EVs
• EV Infrastructure Needs in Washington
• Preferred Methods for Information Sharing
• Implementing an Equitable Electrification Transition
• Audience-Specific Findings

General Views of and Existing Reactions to Transportation Electrification

The following themes represent how participants understand and think about transportation electrification
in general, as well as how the industries, communities and organizations they represent have responded to
electrification thus far.

General Perceptions of Electrification

• There are barriers to electrification: Electrification implementation is starting (through adoption of
EVs or through installing infrastructure), but communities are running into a variety of barriers.

• It is important for the environment: Electrification is important to reduce emissions and to achieve
goals beyond climate.

• It has infrastructure needs and costs: Electrification will require infrastructure installation and
increased grid capacity and infrastructure installation costs can be a barrier for the transition to EVs.

• Markets will change: Electrification will change the transportation and housing markets. Participants
are interested in how these changes will be implemented.

Electrification Needs

• Grid capacity: Electrification transition needs higher power grid capacity and access to renewable
products.

• Electrification planning: The transition to electrification needs better planning.
• Barriers: There is interest in electrification, but costs and barriers need to be reduced for EVs to be
more widely adopted.

• EV education: Communities need more education and engagement about the transition to EVs.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 170
Perceptions of Transit Electrification

• Concerns about electrifying bus fleets
○ Participants specifically mentioned concerns about overhead electric wiring.

○ There are concerns about the ethical production of batteries for the transition to EVs.

○ Electrification of buses in rural areas is not as feasible or a high priority due to the limits of public
transit in those areas.

• Support for more reliable transit before electrification: Multimodal transit users are worried that
efforts to electrify transportation will be prioritized over those to make transit service more reliable.
Participants noted that transit reliability is a high priority, particularly in rural areas.

Barriers to Adoption and Use of EVs

The following themes summarize the barriers participants shared that hinder the adoption and use of EVs
in their community or industry.

Cost

• High cost of EVs: Participants named the up-front cost of purchasing and the cost to maintain EVs as
barriers to adopting EVs in their communities.

• Insufficient access to funding: Existing EV car subsidies and rebates are insufficient and qualifying for
funding can be complicated. There are also few existing subsidies for e-bikes and scooters.

• Inequitable access to funding: The high cost to purchase EVs and limited access to funding leaves
lower-income communities out of the transition.

Infrastructure

• Safe routes for electric bikes and scooters are needed: There is an overall need for EV infrastructure
and facilities, particularly for electric bikes and scooters. This will lead to safety improvements for
people walking, biking and rolling.

• Infrastructure is expensive: Participants identified that infrastructure needs for the transition to EVs
are expensive.

• Charging infrastructure is needed: There is a lack of charging infrastructure for public use along
transportation corridors.

Public Perception

• Lower buy-in in rural/suburban areas: In rural areas, community buy-in is a barrier to electrification;
there are concerns around range anxiety, battery safety and cost.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 171
• Range anxiety: EV range is too short for typical trips.
• Skepticism around benefits: There is community skepticism regarding the benefits of EVs.
• Support for a shift away from cars: We need to prioritize modal shift, moving away from cars and
moving toward public transit, walking, biking and rolling.

• Environmental safety: Concerns exist about the environmental impacts of lithium batteries (mining)
and grid capacity for EV charging stations.

Barriers for Rural/Suburban Communities

• Lack of charging infrastructure: There is a lack of charging infrastructure for public use along
transportation corridors in rural areas. At the same time, there is also a concern about grid capacity for
charging infrastructure for rural/suburban utilities.

• Infrastructure cost: The up-front cost of creating new charging infrastructure and retrofitting existing
structures for public and at-home chargers is a barrier for rural/suburban communities.

• Insufficient funding: There is a lack of financial incentives to transition to EVs.
• Range anxiety: People are worried their EVs will not get them where they need to go since trips are
typically longer than in urban areas.

• Change public perception: There is a need to change cultural perceptions regarding who benefits
from electrification and who does not.

• High cost of EVs: The up-front cost of purchasing EVs and the cost to maintain them are barriers to
adopting EVs in rural/suburban communities.

Suggested State Actions to Increase Access to and Feasibility of EVs

The following themes synthesize participant suggestions for actions Washington can take to make EVs more
feasible for their community or industry.

Access to EVs and EV Infrastructure

• Improve charging access: Increase convenient public charging and charging along travel corridors and
improve charging accessibility.

• Prioritize reliability: Build a reliable electrification system for community members where charging
stations are maintained and easily accessible.

Funding for EVs

• Incentives for up-front costs: Create easily accessible incentive programs that make EVs easier to own
and use than gas-powered vehicles. Reduce up-front costs for EVs (including school buses).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 172
• Charging infrastructure: Incentivize charging infrastructure construction through grants.
• Tax system reform: Create a more progressive and equitable tax system to incentivize EV
transportation.

Public Perception and Education

• Education programs: Create education and engagement programs that prioritize investments in
BIPOC communities and people in need. Include programs on EV servicing and maintenance.

• Financial education for EVs: Educate the public about financial support.
• Multimodal solutions: Shift cultural perspectives and normalize transit-friendly, walkable and
bikeable communities, rather than car-dependent communities. Communities should have housing
close to jobs and increased micromobility options.

EV Infrastructure Needs in Washington

The following themes encapsulate participants’ characterization of infrastructure needs and their
suggested infrastructure changes to facilitate the transition to EVs.

Charging

• Increase public charging availability: Improve charging accessibility and reliability. Put charging
stations at places people need to go or already park, such as grocery stores, coffee shops, libraries and
banks.

• Install fast chargers and L2 chargers: Focus not only on DCFC but also L2 charging for e-bikes,
scooters, etc.

Infrastructure Installation

• Provide EV training: Increase training and educational programs for EV technicians.
• Add new building requirements: Require and incentivize charging stations in new construction and
apartment buildings.

Preferred Methods for Information Sharing

The following themes summarize effective methods for sharing information, educating people, and
increasing awareness about electrification and EVs, as recommended by participants.

Communication Channels

• Conventional media: Utilize conventional media sources for advertising and earned media.
• Multimedia and in-language approaches: Utilize social media, WhatsApp, interviews with experts
and commercials to engage with non-English-speaking communities.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 173
• Gathering places: Conduct in-person outreach that meets people where they are (e.g., at CBOs and
community gathering locations).

○ Partner with CBOs that have built long, trust-based relationships with communities.

○ Coordinate word-of-mouth efforts and conversations, such as talks at local organizations.

• Word of mouth: Word of mouth is most effective for non-English-speaking communities because the
message is coming from trusted community members.

Community Messaging

• Unified messaging: Unify the state’s message about EV and EV infrastructure to create a cohesive
narrative. State agencies need to communicate to reinforce each other’s communications efforts and
make messaging consistent and clear.

• Jurisdictional roundtables: Develop recurrent roundtables with representation of cities across the
state (not just those in the Puget Sound).

• Account for government distrust: There is distrust of government and politicians; think through this
lens when developing messaging about EVs for communities.

Implementing an Equitable Electrification Transition

The following themes synthesize actions and priorities that participants recommend be included in the TES
to ensure that electric transportation equitably serves Washington communities.

Engagement and Education

• Equitable implementation: Incorporate equity through every step of the process to ensure that
communities are centered in the conversation about the transition to EVs.

Partnerships

• Collaboration with EV partners: Do not reinvent the wheel when it comes to transportation and
electrification equity. Lean on the expertise of partners that have already done electrification work.

• Existing transportation equity frameworks: Lean on existing transportation equity frameworks
(such as the King County Metro Mobility Framework).

Electrification system

• Prioritize reliable transit: Prioritize a cohesive statewide public transit system over electric bus fleets.
The main priority is to ensure public transit is reliable.

• Used EV affordability: Create a more affordable used EV market.
• Multimodal transition: Focus on a greater shift in the transportation system, rather than just
switching all ICE vehicles to EVs.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 174
Audience-Specific Findings

The following themes each synthesize key findings that arose from particular audience groups.

Multifamily Housing

• Transition is tenant dependent: Electrification for multifamily housing properties will depend on the
demand from tenants. If there is little demand, it does not make sense for property managers to invest
in the cost of installing charging equipment. The state should focus on developing and encouraging
demand from customers.

• Barriers to installation: Permitting can be a barrier for property managers of multifamily housing to
install EV infrastructure.

Multimodal Transit Users (King County Mobility Equity Cabinet)

• Community-centered systems: Create community-centered transportation systems that are
designed for people.

• Engagement for a multimodal solution: Engage community members in the design of a system
that supports active transportation (walking, biking or rolling) and public transit, prioritizing
community mobility.

• Good transit service over electrification: For transit agencies, it is more effective to provide good
transit services that disincentivize using cars, rather than electrifying transit fleets, to meet climate goals.

• Paratransit challenges: Electrifying paratransit vehicles may be a challenge due to vehicle weight.
Ensure the priority is to provide paratransit services to those in need over electrifying the
paratransit fleet.

Labor

• Training and apprenticeships: Training and apprenticeship opportunities to account for the changing
labor market are needed for workers. Ensure apprentices working on electrification have enough work.

• Maintenance responsibility clarity: Responsibility for maintenance seems unclear. Clarity is needed
about what gets maintained and who does that maintenance.

• Funding for fleet electrification: Provide state funding for electrifying bigger fleets — transit
agencies, local jurisdictions, etc. — to ensure the proper workforce is available for the transition.

• Access for underrepresented groups: Create support programs to provide access to apprenticeships
for populations underrepresented in the workforce, including people of color, women, tribal citizens
and low-income residents.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 175
Towing and Recovery Fleets

• Safety concerns about batteries: There are major concerns about safety risk from battery and
electrical fires. In parking lots, EVs require a wide radius to protect their surroundings from fire, which
decreases area available to store cars.

• Concerns about the cost of transitioning to EV fleets: There are major concerns about the effects of
both costs and new regulations on small towing businesses in the state. The biggest worry is that fleet
transition and the associated costs will be mandated by the state.

• Conflict between state and insurance requirements: Towing companies feel the conflict between
changing state requirements to move toward electrification and changing insurance requirements,
which respond negatively to the risks of electrification, including fires.

• Prioritize electrification of fixed-route services: Fixed-route services should be electrified first
because their vehicles have more reliable schedules and thus more predictable charging needs.

Manufacturing

• Define the benefits: The state needs to define the benefit of the transition to EVs beyond reducing
carbon emissions.

• Define and align standards: There need to be equal standards and requirements for EV
manufacturing across each industry.

• Ensure the transition is widespread to maintain cost competitiveness: If the transition to EVs
happens in some places but not all, competitors that do not transition will have a cheaper product
and consumers will be less likely to buy an EV. Manufacturers would like to electrify, but if this is not a
complete transition, they will go out of business.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 176
Appendix C — Summary of Public Comment Feedback and Major Changes

The EV Council posted the draft TES to its website for public comment on October 2, 2023. Organizations
and individuals were able to submit their feedback through a form available through October 30, 2023.
The public comment period was announced through the EV Council listserv, as well as Commerce and
WSDOT social media channels. EV Council Advisory Committee members shared the link with their
communities, and the comment form was also distributed to each person who was previously involved in
the engagement process throughout the year.

In total, 283 suggested changes were made during the public comment window from:

• 86 sets of comments* through the public engagement form. Together, they represent a broad array of
perspectives, from industry implementation partners to local governments and utilities to advocates
and CBOs (Table 23).

• 19 verbal comments from the October 11 EV Council meeting, which was dedicated to hearing public
feedback.

• 19 sets of comments* sent to the EV Council email inbox.
*The phrase “sets of comments” is used to include coalition letters, which are only counted as 1 in these
numbers.

Table 23 Comments Received through Public Engagement

Organization/Company/Entity Count

Unaffiliated 18

Other 16

CBOs/advocate groups 14

Private-sector interest 6

EV manufacturers 5

EVSE providers 5

EV consumer advocate 5

Rural Washington residents 5

Auto dealers 4

Public transit agency 4

State/local government 3

Public utility 1

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 177
Once the comment period closed, each suggestion was compiled in a spreadsheet, separated into
individual recommendations and coded according to theme or topic (e.g., “charging infrastructure”).
The consultant team reviewed each comment individually and synthesized the feedback, noting where
organizations or individuals had made similar or conflicting comments. For each suggestion, the consultant
team submitted a recommendation to the EV Council: whether to make a substantive change to the draft
TES, add clarifying language but no change in substance to the draft TES or move forward with no changes.
Each individual EV Council representative provided their preferred responses and then agency staff
compiled decisions to be reflected in the final TES.

Out of the 283 suggested changes, the EV Council incorporated more than half. Out of the 146 changes
made, 75 included substantive edits or wholesale changes. For example, comments suggested that the
draft Implementation Plan included too many of the recommendations and did not clearly identify realistic
priorities for immediate action by the Legislature and agencies. In response, the EV Council completely
revamped the implementation approach.

Major changes suggested through the public feedback process had a high threshold for inclusion because
significant additions or deletions would not have the same opportunity to go through the stakeholder
review process as previous TES content. The EV Council has been committed throughout the development
process to ensuring that the TES reflects information and preferences representative of communities across
Washington. The TES draft that was reviewed during the formal public engagement period was the result of
an eight-month multilayered engagement process. As a result, major changes were included only where it
was possible to do so without losing the intent of previous input.

Major themes submitted during the public comment period are listed below, along with the EV Council’s
response. Minor clarifying edits and corrections made to the TES in response to the public comment period
are not included below. In general, comments regarding granular details for specific policies were not
included because they will be addressed during program design processes at specific agencies and are out
of scope for the TES.

• Hydrogen fuel cell vehicles: The TES was updated to further clarify where and how this technology
was considered throughout the TES development process, and to highlight that Washington will
continue monitoring this technology, its costs and its potential role in reducing emissions from the
state’s transportation sector. New language was also included to acknowledge the new development
of the Pacific Northwest receiving $1 billion for a hydrogen hub and analysis from a report on hydrogen
uses developed by Commerce’s Office of Renewable Fuels.

• Incentives for other fuel and vehicle types: The TES was updated to include a recommendation
that the state continue to monitor the market for alternative vehicle types (e.g., gasoline-to-electric
conversions and FCEVs). The TES continues to recommend that incentives focus on BEVs because they
are currently more cost-effective.

• Direct sales: Language was added to the direct sales policy recommendation acknowledging concerns
from franchise auto dealerships, but ultimately the recommendation was still included in order to
empower consumer choice and create fair market competition.

• Domestic critical minerals and battery component provisions: The EV Council added more
context about the intention to create a circular battery recycling-to-manufacturing economy to
reduce dependence on overseas mining. This addition included an example of ongoing research and

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 178
development work in Moses Lake, Washington. However, the EV Council ultimately decided not to add
“Buy America” requirements to the recommended incentive programs because the restrictions would
likely limit the vehicle and charging supply chains needed to meet the state’s ambitious climate targets
without influencing the behavior of companies that largely operate on a national and international
scale. Federal clean vehicle credits already come with an influential North America assembly
requirement that is far more effective in creating American or Washington jobs.

• Priority charging: A number of specific locations were called out as priorities for public charging
investment, especially for TNC and rideshare drivers, including park-and-rides, airports, transportation
hubs, parks, libraries and municipal buildings. Ports were also highlighted as a critical location for
truck charging. References were added throughout the report.

• Purchase requirements and niche vehicle uses: Language was added to acknowledge the existence
of unique vehicle use cases that do not currently have an electrified version on the market and create
exemptions as needed.

• New recommendations added:
○ Continue funding for WSDOT’s ZEVIP.

○ Continue funding for WSDOT’s ZAP.

○ Clarified guidance about the use of NEVI funds and an increase in public charging for MHDVs using
NEVI and ZEVIP.

○ Update Clean Fuel Standard rules to allow capacity credits for private fleet depots.

○ Evaluate cybersecurity and physical security threats to drivers and their EVs.

○ Publish and maintain the ZEV Mapping and Forecasting tool.

○ Continue funding the WSDOT Green Transportation Capital grant program (replaces “Increase
funding for electrification of transit buses”).

○ Explore training and certification requirements for EV charging maintenance technicians.

• Implementation plan priorities: Narrowed the list of regulatory and legislative priorities for 2024 to
further emphasize critical actions, with an acknowledgment that an annual prioritization process will
need to take place each future year.

• Policy Recommendations, Part II: Clarified the role of additional clean transportation strategies
(beyond electrification) in meeting the state’s emissions targets.

• Maritime: Added details to the maritime section, including a recommendation that the state support
the development of clean maritime fuels such as green hydrogen.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 179
• Rail: Added a section acknowledging that the EV Council did not have capacity to address rail
electrification in the TES, and agency representatives will explore possible strategies during
implementation.

• MHDV costs: Clarified that MHDV electrification is economical on a TCO basis, but that up-front costs
can remain an important barrier, especially for smaller fleets and independent owner-operators.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 180
Appendix D — Technical Appendix

Transportation Electrification Strategy Modeling Overview

To explore how on-road EV adoption and charging needs in Washington may progress over time, RMI
developed a two-stage modeling approach (Figure 35). The first stage uses a vehicle stock rollover model,
which assesses potential EV adoption from 2023 through 2035, by vehicle segment and by county, using
a combination of bottom-up economic analysis based on estimated TCO for different powertrains, and
top-down policy requirements such as the ACC II and ACT regulations. The second stage of the modeling
assesses anticipated EV charging needs, using the number of EVs estimated through the stock rollover
model combined with local trip data or average daily VMT.

Figure 35 Two-Stage Modeling Approach

• Vehicle stock rollover model
Stage 1 • Explores various policy and economic scenarios and sensitivities
EV Adoption

• Estimates EVSE required to charge given number of EVs
Stage 2 • Explores required home, workplace, depot and public charging needs
EV Charging Needs

Stock Rollover Model

Overview

The Stock Rollover model was built in Python to estimate ZEV adoption in each of the 39 counties in
Washington through 2035 for multiple categories of on-road vehicles, under both economic-based
adoption and the state’s sales mandate targets (ACC II, ACT). Figure 36 shows the general process, from
inputs through two types of calculations to the resulting outputs.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 181
Figure 36 Stock Rollover Model Flow
Vehicle adoption Stock rollover
Inputs calculations calculations Outputs

Vehicle Additional cost Costs and
assumptions and emissions emissions
and VMT

Total cost of Adoption
ownership function
Policy
incentives Stock rollover
and function
mandates

Sales and
stock

Baseline
vehicle stock

Table 24 describes the specific vehicle types considered in the stock rollover model. For LDVs other than
motorcycles, several additional categories were modeled, including personal single-family home (SFH),
personal multifamily home (MFH), commercial (fleet) SFH domiciled and commercial (fleet) MFH domiciled.

Table 24 Vehicle Segments Modeled
Vehicle Type Powertrains

Passenger Vehicles

Motorcycle Gasoline ICE, EV

Light-Duty Sedan* Gasoline ICE, EV, PHEV

Light-Duty Crossover* Gasoline ICE, EV, PHEV

Light-Duty Pickup/SUV* Gasoline ICE, EV, PHEV

Buses

School Bus Diesel ICE, EV, FCEV

Transit Bus Diesel ICE, EV, FCEV

Commercial Trucks

Medium-Duty Truck Diesel ICE, EV, FCEV

Heavy-Duty Truck Diesel ICE, EV, FCEV

*Note: These vehicle types have subsegments of personal SFH and MFH, and commercial (fleet) SFH and MFH.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 182
The stock rollover model calculates the base year stock of vehicles and projected future demand using
state data, and then models a retirement distribution of vehicles over time, to calculate the number of sales
required for each vehicle segment by year. In each modeled year, for each vehicle segment and powertrain
combination, the TCO is calculated over the average lifetime of that vehicle type. This calculation includes
purchase costs, fuel, maintenance, refueling infrastructure costs (where relevant) and policy incentives.

The TCO for each powertrain within a vehicle segment is then compared in a logistic function, which uses
an S-curve based on historic EV adoption for that segment to calculate the adoption probability for each
powertrain in a given year. This probability is then translated into sales using the demand forecast and
retirement calculation before constraints and sales mandates are applied to adjust total ZEV sales to meet
state targets, where relevant. Vehicles are “aged” and “retired” over the modeling timeline in the stock
rollover function. This then outputs the sales and vehicle stock for each segment, powertrain and county by
year through 2035.

Stock Rollover and New Sales

Baseline Stock

The baseline stock in the model for 2022 was calculated from DOL vehicle registration data. This data
indicated whether a car was a new registration or renewal, which county it was registered in, whether it
was owned by a business and the specific vehicle model and category or weight class. These last three
categories were used to define higher-level vehicle segments for the analysis, into which the registration
data was then sorted. See the Vehicle Stock section later in this appendix for additional detail on baseline
stock estimates by vehicle segment.

Stock Projection

The total stock forecast was determined from the DOL transportation revenue forecast from 2022. To
match this forecasted data to baseline segment mapping, each segment in this data was converted to a
percentage increase of the base year, which was then applied to the baseline. Additionally, because this
data set only went to 2033, the trend was extrapolated to 2035.

Retirement Curve

Retirement of vehicles was modeled using a Weibull distribution. This is a mathematical function that takes
the average retirement of a vehicle as an input, and then has retirement rates increasing as vehicle age
increases and gets nearer to that average retirement age, before increasing even faster after the average
age has been reached. This retirement distribution was tuned to a combination of national vehicle average
lifetime data and the Washington state registration data, which skewed slightly older than the national
average for some vehicle segments. For example, Figure 37 shows the “survival curve” output by this
distribution for a personal sedan.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 183
Figure 37 Survival Curve for Personal Sedans

100%

80%

60%

40%

20%

0%
5 10 15 20 25 30 35 40
Vehicle Age (Years)

Stock Rollover and Sales

At the end of each modeled year, each existing vehicle is aged by one year. The vehicle segment–specific
survival curve value for this new age is then applied to determine the number of vehicles that should
retire in that year, and the number of vehicles that will roll over to the next year. Total new sales in each
subsequent year are then equal to the total stock projection for a year, less the vehicles that would survive
the retirement curve at the end of the previous year (i.e., total population for a given year equals vehicles
not retired in the previous year plus new sales).

Vehicle Adoption

To calculate the powertrain makeup of the sales for each vehicle segment each year, a bottom-up TCO
approach is used, before applying any top-down policy mandates.

Total Cost of Ownership

Each TCO component is calculated in 2022 prices as a net present value (NPV) with a discount rate of 6.5%.

Vehicle cost, infrastructure and efficiency assumptions come from a variety of external sources, including
the International Council on Clean Transportation (ICCT) and CARB, in addition to RMI analysis (see the Key
Inputs and Sources section below).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 184
VMT is calculated for each segment, for each county. This is determined using a combination of statewide
FHWA data for total miles traveled by each vehicle type, and Replica, a commercially available source
of travel demand data, for county splits. VMT is then used alongside efficiency inputs to calculate fuel
usage for each vehicle and year, with operations and maintenance (O&M) scaling with VMT. Average VMT
within a county was derived as detailed above given the scope of this analysis. Given that some vehicles
will travel more (and some less) than this average VMT figure, the economic and technical feasibility of
electrification will vary depending on specific use cases, driving patterns and driver needs. Accordingly,
electrification may occur at different paces based on these driving patterns (among other factors, such
as consumer preferences).

Charging infrastructure sizing, utilization and costs vary by vehicle type, and by whether a vehicle is located
at a SFH or MFH, and whether it is a personal or commercial vehicle. Commercial vehicles and those
located at MFHs are assumed to more heavily use public versus home charging.

Fuel costs come from the EIA’s analysis of the Pacific U.S. region, with electricity prices varying between
home charging and public charging.

Policy incentives are input into the model from federal, state and utility programs. These include purchase
and charging/refueling infrastructure capital incentives and fuel tax credits.

All NPV components of the TCO are summed up, and then those outputs are sent to the adoption function.

Figures 38 through 42 provide examples of the TCO outputs. The first three plots compare TCO by
powertrain for vehicles purchased in different years (2023–35) to demonstrate how the relative cost of
different vehicles changes over time. The following two sets of plots show the TCO by component in two
snapshot years — 2023 and 2030 — for two different example vehicles: a personal light-duty sedan and a
HD truck.

As can be seen in these charts, current outlooks on ZEV costs — both in terms of purchase price and TCO —
suggest that BEVs are anticipated to be considerably more cost-effective than FCEVs in the light-duty sector
(Table 26 includes details on cost sources and assumptions). FCEV purchase costs and fuel costs would
need to come down significantly to become cost-competitive with BEVs and PHEVs, and based on these
TCO comparison findings, the primary LDV analysis focused on BEVs and PHEVs as the near-term light-duty
ZEV options. Although several automakers have recently announced plans to explore or produce light-duty
FCEVs, these plans appear focused on the back half of this decade, and therefore should be considered
further if and when they materialize. In general, Washington will need to monitor developments in the FCEV
market, and potentially further explore this powertrain option if and as it becomes more competitive.

Note that the temporary increase in TCO for all of the ZEVs (BEVs, PHEVs and FCEVs) after 2032 is due to
the expectation that incentives provided for these vehicles through the IRA will no longer be available
after that year.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 185
Figure 38 TCO by Powertrain, Personal Light-Duty Sedans Domiciled at SFHs
in Clark County ($2023)
$100K

$80K

$60K FCEV
PHEV

$40K
ICE-Gasoline

EV
$20K

$0
2023 2025 2027 2029 2031 2033 2035

Figure 39 TCO by Powertrain, Personal Pickups/SUVs Domiciled at SFHs
in Clark County ($2023)

$100K

FCEV
$80K
PHEV
$60K
ICE- Gasoline

$40K EV

$20K

$0
2023 2025 2027 2029 2031 2033 2035

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 186
Currently, FCEV cost outlooks for MHDVs are also considerably higher than those for both conventional
diesel engines (“ICE-Diesel” in Figure 40) and battery electric options. However, the S-curve–based TES
analysis does project small numbers of FCEV HD trucks being adopted in the early 2030s, when costs
are expected to be somewhat more competitive with BEV and diesel options. Given uncertainty about
how this technology and the associated costs develop (including uncertainty about hydrogen refueling
infrastructure, which has yet to be developed at scale), Washington will continue to monitor FCEV
options in the coming years, especially for MHDVs. Per Chapter 292, Laws of 2022,194 the Department of
Commerce’s Office of Hydrogen and Renewable Fuels delivered a Hydrogen and Renewable Fuels 2023
Legislative Report to the Legislature on December 1, 2023, which should be used to inform this assessment.

Figure 40. TCO by Powertrain for Heavy-Duty Trucks Domiciled
in Kitsap County

$900K

$800K

$700K

$600K

$500K
FCEV
$400K
ICE-Diesel
$300K
EV
$200K

$100K

$0
2023 2025 2027 2029 2031 2033 2035

Note that in Figures 41 and 42, FCEV infrastructure is included as the “EVSE Cost” for the HD trucks.
Infrastructure costs for light-duty FCEVs were not directly included in this assessment, and if included (as
part of fueling costs) they would make FCEVs even less competitive for that vehicle segment.

194 SB 5910 – Accelerating the availability and use of renewable hydrogen in Washington state.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 187
Figure 41 TCO by Powertrain and Component, Personal Light-duty Sedans
in Clark County, 2023 and 2030
ICE-
2023 EV PHEV Gasoline FCEV

Purchase Cost +$44K +$43K +$35K +$76K
Purchase Incentive −$7K −$7K ±$0 −$7K
EVSE Cost +$1K +$596 ±$0 ±$0
EVSE Incentive −$22 ±$0 ±$0 ±$0
Operations & Maintenance +$1K +$1K +$3K ±$0
Fuel Cost +$1K +$2K +$4K +$2K
Fuel Incentive −$25 ±$0 ±$0 −$169
Total +$40K +$41K +$42K +$72K

ICE-
2030 EV PHEV Gasoline FCEV

Purchase Cost +$35K +$42K +$36K +$67K
Purchase Incentive −$6K −$6K ±$0 −$6K
EVSE Cost +$1K +$596 ±$0 ±$0
EVSE Incentive −$22 ±$0 ±$0 ±$0
Operations & Maintenance +$1K +$1K +$3K ±$0
Fuel Cost +$1K +$2K +$3K +$2K
Fuel Incentive −$14 ±$0 ±$0 −$96
Total +$32K +$40K +$42K +$63K

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 188
Figure 42 TCO by Powertrain and Component, Heavy-duty Trucks Domiciled
in Kitsap County, 2023 and 2030

2023 EV ICE-Diesel FCEV
Purchase Cost +$313K +$156K +$512K
Purchase Incentive −$40K ±$0 −$40K
EVSE Cost +$193K ±$0 +$323K
EVSE Incentive −$96K ±$0 ±$0
Operations & Maintenance +$24K +$47K +$30K
Fuel Cost +$68K +$159K +$167K
Fuel Incentive −$17K ±$0 ±$0
Total +$443K +$362K +$991K

2030 EV ICE-Diesel FCEV
Purchase Cost +$219K +$158K +$275K
Purchase Incentive −$40K ±$0 −$40K
EVSE Cost +$115K ±$0 +$143K
EVSE Incentive −$58K ±$0 ±$0
Operations & Maintenance +$24K +$47K +$30K
Fuel Cost +$57K +$142K +$116K
Fuel Incentive −$8K ±$0 ±$0
Total +$310K +$347K +$523K

Adoption Function

The adoption function is based on the S-curve theory of innovation and growth. Adoption of a new
technology occurs slowly at first, then exponentially, before slowing down as the last few percentage points
of adoption are approached.

S-curve inputs were calibrated to historical EV sales figures as a proportion of total sales for each vehicle
segment, in addition to past EV and ICE prices, to determine the link between TCO and S-curve position.
Different future S-curve shapes (i.e., speed of adoption and sensitivity to economics) were used for the S1
Baseline scenario and other modeled scenarios that assume either more or less consumer and business
interest in EVs and responsiveness to underlying economics. These different S-curve shapes are also
intended to reflect other noneconomic factors, such as relatively more or less EV charging availability or the
extent of education and outreach programs to promote vehicle electrification, and the associated effect
these may have on EV uptake (these different S-curve treatments are reflected as “EV Adoption Demand
Rate” in Table 33).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 189
A logistic function (mathematical representation of the S-curve) is used to model the purchase decision-
making process for an individual or fleet operator at each sale decision point. For each vehicle type, the
TCO for each powertrain option is fed into a logistic function in a two-step process, with two decisions or
comparisons made:

1. Will the adopted vehicle be an ICE or a ZEV?

2. If the vehicle will be a ZEV, which type of ZEV will it be?

At each step, the logistic function outputs a probability of adoption. Combined, this two-step process
outputs the probability of what new sales of a particular vehicle type will be (i.e., ICE vehicles, EVs, PHEVs
or FCEVs).

Final Sales

These probabilities are not yet final sales. For some segments, sales constraints are applied (based on
RMI analysis of potential supply chain and manufacturing constraints, for both vehicle supply and electric
grid capacity availability) to slow their growth in sales to a particular rate. Additionally, vehicle sales are
compared against policy mandates (e.g., ACC II, ACT) to determine whether TCO-based sales shares meet
the required level for a given year.

Policy Mandates

ACC II and ACT are both relatively straightforward regulations to implement in the stock rollover model,
with both setting a minimum sales share trajectory implemented for their target vehicle segments. Where
economic-based sales are below the target level, sales are increased proportionally across the state with
a method that increases sales in counties where the economics are stronger first. For LDVs this is done
across all segments combined rather than for each individual segment, and so certain segments with more
favorable TCOs may reach higher EV shares first (e.g., personal sedans).

Advanced Clean Fleets

ACF-applicable MHDV populations are derived from a combination of bottom-up calculations and high-
level estimates. ACF is a complex policy, with different phase-in dates for different types of MHDVs,
including drayage trucks, high-priority fleets and state fleets. In addition, implementation of this policy in
Washington may differ in some respects from what happens in California (which developed this regulation).

For state fleets, additional county-level data was provided by Washington. For drayage fleet port
volumes, California’s drayage inventory was scaled to the port volumes of Washington, and checked for
soundness against some public Washington drayage registries because there is no single drayage truck
inventory for Washington.

High-priority fleets are the most difficult to accurately determine without detailed data on the makeup and
revenue of fleets operating in Washington. Accordingly, CARB estimates for California were scaled down to
Washington’s number of residents. To eliminate some double counting, approximately 50% of the drayage
truck population from this high-priority fleets estimate was then subtracted for those counties in which
drayage fleets operate.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 190
With this total number of ACF-applicable fleets, a minimum sales mandate share for each county was
calculated, inclusive of ACT as well as ACF, and used in the modeled scenarios that include ACF as an active
policy (using the same method described above for ACT and ACC II).

Emissions and Air Quality

Emissions and air quality are calculated from the fuel usage determined during the TCO steps, and the
overall stock by vehicle type and powertrain determined in the stock rollover step. Emissions and air
quality factors for grid electricity used to charge EVs and tailpipe emissions for ICE vehicles were derived
from Argonne National Laboratory’s GREET model database. The modeling does not assume increased
usage of alternative liquid fuels such as renewable diesel or biofuels in ICE vehicles over time.

This approach excludes some air quality emissions due to tire and brakes wear and tear.

Electric Vehicle Supply Equipment Model

The EVSE model calculates the charging infrastructure needed to satisfy the charging demand of the
number of EVs determined by the stock rollover model. LDV, MHD truck and bus EVSE needs are simulated
separately. The total number of required charging ports represents the final output of the model, whereas
the intermediate steps produce insight into hourly load shape and (unmanaged) peak electricity demands.

Light-Duty Vehicle Modeling

The process for modeling LDV EVSE requirements begins with aggregating daily trips for a given geography
from Replica, based on a combination of different data sources aggregated to create a robust data set. The
Replica data set contains vehicle travel simulations for each day of the week for the entire population of
the state. Trips can be aggregated at the census block group, county or state level. Each trip indicates start/
stop location, start/stop time, vehicle type, travel purpose and demographic information about the driver.
A unique driver identification is used to link all the stops and trips across the day made by the same person.

After all trips in the geography are collected, calculating total charging demand is the next step. All vehicles
are assumed to start fully charged at the beginning of the day. The mileage of each trip is converted to
electrical demand via unique efficiency scalars (kWh/mile) for each type of LDV (e.g., sedans operate at a
different average efficiency than pickup trucks). Vehicles must recharge the load they have used by the end
of the day.

The charging logic aspires to capture driver behavior by accounting for stop duration and charger
availability. Stops over the course of a day are ranked by duration, and charging is assigned in order from
longest to shortest duration stop until the total demand is satisfied. Load for a given geography (e.g.,
county) is distributed across five charger types: Single-Family Home L2, Multifamily Home L2, Workplace L2,
Public L2 and Public DCFC.

If charging at home is available, demand is usually met there. All single-family home residents are assumed
to have access to home L2 charging. A variable fraction of multifamily home residents (increasing with
time) is assumed to have access to home L2 charging. Work charging access is assumed to increase over
time in a similar fashion (Table 25). Public charging stops shorter than one hour are assumed to be met
with DCFC and longer stops with L2.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 191
Table 25 Assumed EVSE Access Rates
Access Rate 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035

SFH L2 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100%

MFH L2 23% 26% 29% 32% 35% 38% 42% 45% 48% 51% 54% 57% 60%

Office Work 23% 26% 29% 32% 35% 38% 42% 45% 48% 51% 54% 57% 60%

Non-office Work 10% 10% 10% 10% 10% 10% 10% 10% 10% 10% 10% 10% 10%

Port counts of each charger type are then calculated based on the power level of the charger, the quantity
of the load and a charger utilization rate that represents the total time in a day the unit is assumed to be
providing power (Table 26). To derive estimated LDV charging ports at the census block group level, Replica
data by trip purpose (e.g., return to home, commute) for each block group is used to allocate chargers from
the county level to individual census block groups.

Table 26 Assumed EVSE Utilization Rates
Utilization
Rate 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035

Work L2 4% 5% 6% 7% 8% 9% 9% 10% 11% 12% 13% 14% 15%
Public L2 4% 4% 5% 5% 6% 6% 7% 7% 8% 8% 9% 9% 10%
Public DCFC 6% 7% 7% 8% 9% 10% 10% 11% 12% 13% 14% 14% 15%
MHD Depot 30% 30% 30% 30% 30% 30% 30% 30% 30% 30% 30% 30% 30%
MHD Highway 10% 13% 15% 18% 20% 23% 25% 28% 30% 33% 35% 38% 40%

Medium- and Heavy-Duty Vehicles

As with LDVs, the process for modeling MHDV EVSE requirements begins with collecting daily Replica trips
for a given geography (county or statewide). Unlike with LDVs, truck trips are anonymized and cannot be
linked to distinct drivers or vehicles. Trip attributes are limited to start/stop time, start/stop coordinates,
distance and truck type.

Since individual vehicle driving patterns cannot be analyzed, charging load is allocated in the aggregate
across the total active truck population of the region. Desired charging times are assumed to be
inversely proportional to driving times. For example, if the population of trucks drives 25% more than
average from 3:00 to 4:00 PM, the charging load delivered to the population in the same time frame
will be 25% less than mean hourly charging. As with LDVs, trucks must satisfy all demand (refill their
batteries) in each 24-hour period.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 192
Once a curve of charging needs by hour in each county is obtained, the shape of this curve is used to scale
average daily mileage data. Average vehicle efficiency (kWh/mile) is then used to calculate total daily
load for the region. The number of ports needed to satisfy this load is then calculated in the same way
as described above for LDVs, as a function of charger power level and charger utilization (access rate — a
factor in the calculation of LDV EVSE ports — is not a factor for the analogous MHD truck calculation).

Buses

The Replica data set does not contain trip data on transit or school buses, so the bus EVSE modeling process
is distinct. This alternative method takes the annual statewide school and transit bus VMT totals from WDOT
and assumes the baseline scenario of the stock rollover model corresponds with the most recent WSDOT
VMT data. Annual VMT from the baseline year is scaled by the annual growth projected in each stock rollover
scenario, and vehicle driving efficiency (kWh/mile) is then used to convert mileage into bus electricity needs.
The number of charging ports needed to satisfy daily loads is then calculated as a function of charger power
levels and available charging hours. School buses are assumed to operate an average of 200 days per year,
whereas transit buses are assumed to operate 280 days per year. School buses are assumed to have eight
stationary hours per day available for charging and transit buses are assumed to have four.

Table 27 EVSE Power Levels
School Transit
EVSE SFH MFH Work Public Public MD MD HD HD Bus Bus
Type L2 L2 L2 L2 DCFC Depot Highway Depot Highway Depot Depot

Power
7.2 7.2 7.2 19 150 50 150 350 350 19 350
(kW)

Estimating TCO Surplus and Deficit Relative to Attainment of Desired EV Sales Shares

To reach state goals, the gap between estimated EV adoption levels based on economics alone and EV sales
trajectories required for compliance with enacted (or contemplated) state regulations must be bridged.
To provide a sense of the gap’s magnitude, the TES model was used to estimate the associated gap in TCO
between economics-based adoption and policy-mandated sales shares.

It is important to clarify that the TES stock rollover model was not developed to be a subsidy calculation
tool, and instead is intended to estimate adoption levels based on average costs and expectations of
technology uptake. Estimating potential TCO shortfalls using this tool can help assess whether and to
what extent compliance with policy goals may be at risk due to insufficient economics for ZEV technology.
However, the results shown in Figure 43 should be understood as directional estimates, rather than precise
forecasts; there is sufficient uncertainty in this modeling to merit caution in interpreting these results. This
is especially true given the importance of use cases (duty cycles) in determining the physical and economic
feasibility of transportation electrification, perhaps most notably for MHDVs.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 193
Figure 43 indicates the estimated average “missing money” — on a TCO basis — to produce sales shares
in line with the regulations embedded in the S1 Baseline scenario (ACC II and ACT) and the S3 Strong
Electrification Policy scenario (ACF). This is based on the S-curve methodology described earlier in this
section, which assumes that as economics improve for a new technology, sales share also increases,
with relatively slow adoption in the initial years, rapid adoption once economics are competitive with
alternative options and then slower adoption as the market saturates. Importantly, this method produces
a phased adoption of alternative technologies, rather than a binary adoption function where 100% of
the less expensive vehicle would be adopted each year. Fundamentally, this assumes that as the TCO of
different vehicle types (e.g., EV and ICE) gets closer, there will be adoption of both vehicle types, with the
relative share based on the TCO comparison between the two.

Understanding the implications of Figure 43 requires considering the interaction of this S-curve
methodology and the level of EV adoption required for compliance with state goals. In the early years,
ZEV sales targets are relatively low (e.g., 7% for class 7 and 8 tractors in 2025). Although the TCO for
electric class 7 and 8 vehicles is not estimated to be less expensive than comparable diesel tractors
in that year, the values are sufficiently close that a small share of electric tractors are estimated to be
adopted. Additionally, given that the compliance level is also relatively low for these vehicles in that
year (7% ZEV sales share), these charts therefore tell us that based on estimated TCO and adoption,
economics-based EV adoption (which includes significant federal incentives) should support sufficient
compliance levels for those vehicles.

In Figure 43, positive values indicate that the TCO advantage of EVs is sufficiently strong in that year that,
as modeled, economics-based adoption surpasses required sales targets. Negative values, in contrast,
indicate the additional value required per vehicle — on a TCO basis — to produce EV adoption aligned
with that year’s sales share target for a given vehicle type (i.e., ACC II requirements for LDVs and ACT or ACF
requirements for MHDVs). Note that the $0 axis in these plots does not indicate TCO parity between EV and
ICE options, but rather indicates the level of EV TCO advantage estimated to be required to reach a given
year’s sales goals for the different vehicle segments. The significantly smaller surplus TCO values for MHDVs
in the S3 Strong Electrification Policy chart are due to the inclusion of ACF in addition to ACT, which has
higher ZEV sales share requirements, offsetting the higher incentive levels assumed in that scenario.

The positive values for the next several years indicate that TCO (inclusive of all available incentives)
appears to be sufficient to enable compliance with state policy goals. In short, this analysis suggests that
TCO should not be a barrier to accomplishing near-term policy goals. It is critical to reemphasize that
these results assume vehicles take advantage of all available incentives, which are critical to producing
TCO-based adoption in line with required targets. Additionally, duty cycles and specific operational
needs, especially for MHDVs, will play a key role in determining both the economic and physical feasibility
of electrification, suggesting the need for continued focus on enabling larger portions of the market to
electrify. This analysis uses county-level average VMT to assess TCO, but VMT will vary by vehicle use case.
The state should continue to monitor EV adoption rates, incentive program participation and consumer
perspectives over the coming years to best calibrate the needed levels of support to produce desired EV
sales penetrations.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 194
Figure 43 Average TCO Surplus or Deficit Relative to EV Adoption Compliance
Requirements

HD Truck MD Truck Crossover Sedan Pickup/SUV

S1 Baseline Scenario

100K

80K

60K

40K

20K

−20K

−40K
2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035

S1 Baseline Scenario
100K

80K

60K

40K

20K

−20K

−40K
2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 195
Key Inputs and Sources

Table 28 describes the sources and modifications used to develop the key inputs for the EV stock rollover
and EVSE models. RMI can answer additional questions regarding inputs and sources.

Table 28 Key Inputs and Sources
Category Input Description Modifications Source
End-use sectors: residential,
commercial and industrial
Annual $/kWh energy
Forecast scenarios: reference
Commodity (Fuel) prices for electricity used Annual Energy
Electricity case, low uptake of IRA, low
Costs in transportation in the Outlook 2023, U.S. EIA
oil and gas supply, and low
Pacific region
macro and low zero-carbon
technology cost

Annual $/gallon energy
prices for motor gasoline and Forecast scenarios: reference
Commodity (Fuel) Annual Energy
Diesel and Gasoline diesel used in transportation case, low oil price, and high oil
Costs Outlook 2023, U.S. EIA
in the Pacific region price

Making Zero-
Commodity (Fuel) Annual $/kg prices for Forecast scenarios: high and
Hydrogen Emissions Trucking
Costs hydrogen fuel average cost
Possible, MPP/RMI

Vehicle types: sedan,
crossover, SUV/pickup
International Council
Fuel types: ICE, BEV, PHEV
on Clean
Vehicle Upfront Annual purchase price per Forecast scenarios: baseline,
LDVs Transportation (ICCT);
Costs vehicle conservative, and optimistic,
EV Outlook 2023,
created based on ICCT source
BloombergNEF
and BloombergNEF EV
Outlook 2023 trajectories

Vehicle types: school bus,
transit bus
Vehicle Upfront Annual purchase price per Fuel types: ICE, BEV, PHEV,
Buses Market research
Costs vehicle FCEV.
Forecast scenarios: baseline,
conservative and optimistic

Vehicle types: MD trucks, HD
trucks
Fuel types: ICE, BEV, FCEV Making Zero-
Vehicle Upfront Annual purchase price per
MD and HD Trucks Forecast scenarios: baseline, Emissions Trucking
Costs vehicle
conservative, and optimistic, Possible, MPP/RMI
created based on RMI and
MPP analysis

Fuel types: ICE, BEV
Vehicle Upfront Annual purchase price per
Motorcycles Forecast scenarios: baseline, Market research
Costs vehicle
conservative and optimistic

Sources: Mission Impossible Partnership and RMI, “Making Zero-Emissions Trucking Possible”; International Council on Clean Transportation (ICCT),
“Assessment of Light-Duty Electric Vehicle Costs and Consumer Benefits in the United States in the 2022-2035 Time Frame”; BloombergNEF, “Electric
Vehicle Outlook 2023”; Consumer Reports, “Electric Vehicle Ownership Costs: Today’s Electric Vehicles Offer Big Savings for Consumers”; NREL, “Foothill
Transit Battery Electric Bus Evaluation: Final Report”; NREL, “Orange County Transportation Authority Fuel Cell Electric Bus Progress Report”; California
Energy Commission, “GFO-17-607 Cost Effectiveness Model Battery Electric School Buses”; CARB, “Appendix G, Literature Review on Transit Bus
Maintenance Cost”; J.D. Power, “Don’t Get Ripped Off by Excessive Motorcycle Servicing Costs”; ConEdison, “Con Edison and Partners Go To School with
Findings from E-School Bus Contract”; WSDOT, “Annual mileage and travel information”; EIA, “Annual Energy Outlook 2023”; NREL, “The 2030 National
Charging Network: Estimating U.S. Light-Duty Demand for Electric Vehicle Charging Infrastructure.”

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 196
Table 28 Key Inputs and Sources, continued
Category Input Description Modifications Source

Powertrains: ICE, EV, PHEV
Annual $/mile
Vehicle O&M Costs LDVs Vehicle types: sedan, Consumer Reports
maintenance cost.
crossover, SUV/pickup

Foothills Transit
Study, NREL; Orange
Powertrains: ICE, EV, FCEV
Annual $/mile County FC Bus Report,
Vehicle O&M Costs Buses Vehicle types: school bus,
maintenance cost. NREL; California Energy
transit bus
Commission, CARB

Powertrains: ICE, BEV, FCEV Making Zero-
Annual $/mile
Vehicle O&M Costs MD and HD Trucks Vehicle types: MD trucks, HD Emissions Trucking
maintenance cost.
trucks Possible, MPP/RMI

Annual $/mile
Vehicle O&M Costs Motorcycles Powertrains: ICE, BEV J. D. Power
maintenance cost.

Powertrains: ICE, EV, PHEV Annual Energy
Annual mpg and Outlook 2023, U.S.
Vehicle Efficiencies LDVs Vehicle types: sedan,
kwh/mile fuel efficiencies EIA; EV Outlook 2023,
crossover, SUV/pickup
BloombergNEF

Foothills Transit
Annual mpg, kwh/mile Powertrains: ICE, EV, FCEV.
Study, NREL; Electric
Vehicle Efficiencies Buses and kg/mile fuel Vehicle types: school bus,
School Bus Report,
efficiencies transit bus
Con Edison

Annual mpg, kwh/mile Powertrains: ICE, BEV, FCEV Making Zero-
Vehicle Efficiencies MD and HD Trucks and kg/mile fuel Vehicle types: MD trucks, MD Emissions Trucking
efficiencies trucks Possible, MPP/RMI

Annual mpg, kwh/mile Market research – CT
Vehicle Efficiencies Motorcycles Powertrains: ICE, BEV
and kg/mile fuel efficiencies Ridge Guide, Electrek

VMT is calculated for each vehicle
type from the total statewide VMT
using the share of each vehicle type
of the total statewide vehicle stock.
Scenarios: base, low, high
Scenarios are calculated according
Annual Vehicle Miles
VMT VMT to modeled change in per capita VMT WSDOT
Traveled (VMT)
required to meet baseline growth
from current state data, MOVE Ahead
scenario and other recent work.

Charging types and levels:
Installation and single-family L2, multifamily
EVSE EVSE Costs NREL
equipment costs per port L2, public L2, workplace L2,
public DCFC

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 197
Economic Policy Inputs

Table 29 describes the policy inputs that directly influence the economics in the model, which determine
TCO-based adoption.

Table 29 Economic Policy Inputs
Lead Modeling Vehicle Time Baseline High/Low
Policy Jurisdiction Agency Detail Segments Frame Values Scenario

High: $7,000/
Alternative Fuel Department Reduction in up-front $5,000/
State Electric LDVs 2024–28 personal crossover
Vehicle Incentives of Commerce cost for electric LDVs personal
Low: $3,000/personal
crossover personal crossover

Removal of state sales High: Extend through
EV Sales Tax State Department $1,000 off sales price
tax from up-front cost for All electric LDVs 2023–25 2035
Exemption of Revenue
alternative fuel vehicles Low: Remove after 2025

Escalating minimum All LDV cars
Advanced State Department Annual sales N/A (removed
annual sales (motorcycles 2026–35
Clean Cars II of Ecology requirements in one sensitivity)
percentage (LDVs) excluded)

Advanced Department Escalating minimum Annual sales N/A (removed
State annual sales All MHDVs 2024–35
Clean Trucks of Ecology requirements in one sensitivity)
percentage (MHDVs)

Downward adjustment High: Extend through
Clean State Department All EVs, all
to $/kWh rates for 2023–33 Varies 2035
Fuel Standard of Ecology segments
public charging Low: Remove after 2026

High: $5,625
Clean Reduction in up-front Electric and $3,750 average credit
Federal U.S. Treasury cost for alternative 2023–32 (75% of $7,500)
Vehicle Credit PHEV LDVs (50% of $7,500) Low: $1,875
fuel vehicles
(25% of $7,500)

<14k lb: High/Low 100%
Qualified Reduction in up-front <14k lb: $5,625 (75% of
and 50% of $7,500,
Commercial Federal U.S. Treasury cost for alternative All EVs, PHEVs 2023–32 $7,500)
respectively.
Clean Vehicles fuel vehicles and FCEVs >14k lb: $30,000 average >14k lb: High: $40,000;
credit (75% of $40,000) Low: $20,000

Reduction in up-front High: Increase to $800,
All electric LDV
Residential EVSE Utility extend through 2035
Various cost for electric LDVs cars (motorcycles 2023–28 $400
Incentive (utility) Low: Decrease to $0
(reducing EVSE cost) excluded)
beginning 2025

All EVs, all High: Increase to cover
Reduction in up-front 50% of costs, extend
Commercial EVSE segments
Utility Various cost for EVs 2023–28 25% of EVSE costs through 2035
Incentive (utility) (motorcycles
(reducing EVSE cost) Low: Decrease to $0
excluded) beginning 2025

Residential: 30% max of High: Residential: no
$1,000 change; commercial:
Alternative Fuel Commercial: 6% up to increase to 25%
U.S. All EVs, all
Refueling Property U.S. Treasury Reduction in up-front 2023–32 $100,000, only in eligible
segments average credit value
Credit cost for EVSE census tracts (using 10% Low: Residential: drop
for baseline, assuming an to $0; commercial:
average of some projects decrease to 0%
that do use prevailing wages)

Clean School Bus Environmental Reduction in up-front cost Electric
$20,000 average credit
High: $40,000
U.S. Protection of electric school bus and 2023–26 (rounding to $18,750 for
Program school buses Low: $0
Agency charging infrastructure buses + $1,000 for EVSE)

Source: Chapter 297, Laws of 2022; RCW 82.12.999 – Exemptions – Vehicles using clean alternative fuels and electric vehicles (Expires August 1, 2028);
Advanced Clean Cars II; Advanced Clean Trucks; Clean Fuel Standard; Clean Vehicle Credit; Commercial Clean Vehicle Credit; Alternative Fuels Data Center;
Clean School Bus Program Rebates.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 198
Vehicle Stock

The vehicle stock input is a CSV file detailing the vehicle stock composition for the base year of the stock
rollover model. Every subsequent year in the model is built in relation to this base stock input. The stock
input file describes, for every county in Washington, the number of vehicles in each vehicle type category
(personal/commercial sedan, crossover, or pickup/SUV; MD or HD trucks; school bus; transit bus; and
motorcycle), powertrain (ICE or EV) and vintage (age of operation up to 30 years old).

Table 30 Vehicle Stock Estimation
Source Information Gathered Key Assumptions or Modification

Count, age and powertrain
information for: Base year data based on 2022 registrations,
• Personal/commercial sedans, the most recent complete year.
Washington DOL, crossovers or pickups/SUVs
Registration Database* Off-road and ATV vehicle types were
• MD and HD trucks
excluded from the stock.
• Motorcycles

Count, age and powertrain
Washington OSPI, information for:
None
School Bus Database
• School buses

Transit agencies were assigned to counties
based on operating territory. In case of
cross-county operations, buses were
Federal Transit Count and age for: assigned to the county with the majority of
Administration, National • Transit buses territory.
Transit Database
Vehicles counted toward the bus type of
interest, and excluded other vehicles in the
National Transit Database, such as light rail
and trams.

Respective Transit Most recent transit agency development
Development Plans for Powertrain information for: plans were used, usually the 2021–26 plan.
each Washington transit • Transit buses
EV counts were determined from stock and
agency
investment information in plans.

*Note: Multiple Department of Licensing data fields used to create vehicle categories modeled for TES.

Scenarios and Sensitivities Modeled

Tables 31 and 32 describe the scenarios and sensitivities modeled. Table 33 describes the combination of
inputs used to define each scenario.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 199
Table 31 Scenarios Modeled
Characteristics
Type # Scenario Key Questions Explored
(Relative to Baseline)

What might EV adoption
look like under current
Core 1 Baseline N/A policy and middle-of-
the-road outlooks on
cost trajectories?

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 200
Table 32 Sensitivities Tested
Scenarios
Type # Sensitivity Applied To Key Questions Explored

How close does each modeled
2030 LDV Sales scenario get to the 2030 target? What
Major b 1–6
Target Met supportive policies may be required to
enable this goal?

VMT Reduction What benefits are achieved by
Minor c without Stock or 4 reducing VMT but not reducing vehicle
Freight Change size and fleet size?

High Fossil Fuel How do relatively high petroleum
Minor d 1, 2
Prices prices affect outcomes?

Low Fossil Fuel How do relatively low petroleum
Minor e 1, 2
Prices prices affect outcomes?

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 201
Table 33 Scenario and Sensitivity Inputs
Scenarios Sensitivities

1 2 3 4 5 6 a (1–6) b (1–6) c (4) d,e (1–2)

VMT
Best Reduction
Strong Strong Strong Worst Remove Effect 2030 High/Low
Case without
Category Baseline Electrification Electrification VMT Case Target Fossil
Climate of Requirements Stock,
Tecnology Policy Policy Met Costs
Aligned Freight
Change

EV and PHEV
Vehicle Low High Low Varied Varied
Costs

Vehicle FCEV Costs Low High Low Varied Varied

Energy Electricity Low High Low Varied Varied

Energy Fossil Costs Low High Varied Varied High/Low

Hydrogen
Energy Low High Low Varied Varied
Costs

Infrastructure EVSE Costs Low High Low Varied Varied

Hydrogen
Infrastructure Infrastructure Low High Low Varied Varied
Costs

EVSE
Infrastructure High Low High Varied Varied
Availability

Requirements
ACC II Yes No Varied
and Targets

Requirements ACT Yes No Varied
and Targets

Requirements ACF No Yes Yes No Varied
and Targets

Requirements 2030 LDV
No No Yes
and Targets Target

Incentive Utility
High Low High Varied Varied
Policies Incentives

Incentive State
High Low High Varied Varied
Policies Incentives

Incentive Federal
High Low High Varied Varied
Policies Incentives

LDV VMT
VMT Portfolio High Low High Varied Varied High
Reduction

LDV Stock
VMT Portfolio High Low High Varied Varied
Reduction

LDV
Composition:
Shift to High Low High Varied Varied
Lighter
Vehicles

Increase in
VMT Portfolio Bus VMT High Low High Varied Varied High
and/or Stock

Reduction in
VMT Portfolio Freight VMT High Low High Varied Varied
and/or Stock

EV Adoption
Cross-cutting High Low High Varied Varied
Demand Rate

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 202
VMT Scenario Assumptions

Table 34 provides VMT assumptions used in the different scenarios.

Table 34 VMT Scenario Assumptions
Scenario Units
Input (Reported for 2035) Scenario Value Source/Assumption

LDV VMT % per capita
Baseline 6% State forecast
Reduction decrease relative to 2019

State Smart Transportation
LDV VMT % per capita
High 17% Initiative-Smart Growth America
Reduction decrease relative to 2019
Washington report

LDV VMT % per capita
Low −10% Reverse progress since 2005
Reduction decrease relative to 2019

LDV Stock % reduction relative to
High 17% Proportional to VMT reduction
Reduction baseline

LDV Stock % reduction relative to
Low −5% 50% of VMT increase
Reduction baseline

LDV Shift to
% sedan share of LDV sales Baseline 20% Conservative trend extrapolation
Lighter Vehicles

LDV Shift to
% sedan share of LDV sales Low 5% Worst case extrapolation
Lighter Vehicles

LDV Shift to
% sedan share of LDV sales High 50% Return to 2000s share
Lighter Vehicles

Washington Energy Policy
Increase in Bus % increase relative to Simulator; Institute for
High 59%
VMT and Stock baseline Transportation and Development
Policy

Increase in Bus % increase relative to
Low −10% Partial post-COVID19 recovery
VMT and Stock baseline

Freight VMT and % reduction relative to State Energy Plan (~50% of LDV
High 6%
Stock Reduction baseline potential)

Freight VMT and % reduction relative to
Low −20% Double LDV worst case
Stock Reduction baseline

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 203
Bus Electrification Scenarios

The baseline scenario assumes that the growth in funding availability from 2020 to 2023 would continue
through 2035. The “low” scenarios assume annual funding availability to stay constant from 2023 through
2035, with an increasing number of electric buses becoming eligible for purchase due to a decrease in bus
purchase costs. The “high” scenarios follow the sales trajectory required to achieve 100% electric transit
bus sales in the state by 2035.

For school buses, the sales trajectories are differentiated based on anticipated years that price parity
is achieved between ICE and electric school buses, according to WRI. The baseline sales trajectory is
projected to meet a target of 100% electric school bus sales by 2033, the year electric school buses are
expected to reach up-front price parity with their ICE counterparts. Similarly, the “high” sales trajectory is
projected to meet 100% sales in 2029, the year in which the electric school buses reach TCO parity with ICE
buses, according to WRI. The “low” sales trajectory is aligned with a longer-term goal of 100% sales by 2040.

Additional Scenario Analysis Comparisons and Commentary

LDV Comparison Across Scenarios and Sensitivities: Plug-in EV Share of Total 2035 Light-Duty
Vehicle Stock

Table 35 provides a comprehensive comparison of the different scenarios and sensitivities based on their
resulting light-duty plug-in EV share of total stock in 2035 (shown as percentage point change in EV stock
share, relative to the S1 Baseline scenario).

Table 35 Effect of Scenarios and Sensitivities on 2035 Light-duty Plug-in EV
Share of Vehicle Stock

−14% 9% a) b) c) VMT d) e)
Remove 2030 Reduction High Low
Percentage Point Effect LDV without Fossil Fossil
Change Relative to S1 No of ACC Target Stock Fuel Fuel
Baseline Scenario Sensitivities II Met Change Prices Prices

S1 Baseline −9% 7% 3% −1%

S2 Strong Electrification
3% −3% 9% 6% 1%
Technology

S3 Strong Electrification
2% −8% 8%
Policy

S4 Strong VMT Policy −2% −14% 5% −1%

S5 Worst Case* −1% −13% 6%

S6 Best Case Climate
2% −3% 8%
Aligned
* S5b (6%) is a counterintuitive scenario with somewhat limited value for interpretation because it includes high EV technology costs
and low levels of supportive policy incentives, while also adhering to the top-down 100% electric LDV sales by 2030 goal.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 204
As shown in the No Sensitivities column, differences across scenarios are muted by the requirement
to reach ACC II annual sales shares. S4 Strong VMT Policy has fewer EVs because it has many fewer
LDVs overall, as well as lower VMT per vehicle (making EVs relatively less economic through minimized
opportunity to save on operating costs). S6 Best Case Climate Aligned has a similar dynamic, although the
EV economics in that scenario — based on a combination of technology cost declines and policy support
— are strong enough that it counteracts the effect of lower VMT, resulting in a modest EV stock increase
relative to the S1 Baseline scenario.

Removing the effect of ACC II to explore how various scenarios compare (third column) shows larger
variation. S6 Best Case, S2 Strong Electrification Technology and S3 Strong Electrification Policy maintain
the largest EV share of baseline population, indicating they produce the most favorable economics for EVs.

The fourth column shows relatively modest impacts on the overall share of EVs by 2035 from including a
firm 2030 100% electric LDVs sales requirement. This is due to the relatively long time frame over which
changes in new sales have meaningful impacts on the total vehicle stock (i.e., vehicles are fairly long-lived
assets).

The fifth column highlights the scenario in which VMT reduction takes place without there also being a
reduction in vehicle stock and a shift to lighter vehicles. Although reducing VMT will decrease the cost
savings for EVs and would therefore decrease their sales and stock share, the inclusion of the ACC II
requirement mutes this dynamic, producing minimal changes relative to the baseline. S4c does, however,
have a much larger impact on GHG and local air pollutant emissions reduction. The final two columns show
a similar effect, with relatively small changes to 2035 EV stock share due to the strong influence of ACC II on
EV sales and ultimately stock.

MHD Truck Comparison Across Scenarios and Sensitivities: ZEV Share of Total 2035 MHD Truck Stock

Table 36 provides a comprehensive comparison of the different scenarios and sensitivities based on their
resulting electric share of total truck stock in 2035 (shown as percentage point change in EV stock share,
relative to the S1 Baseline scenario).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 205
Table 36 Effect of Scenarios and Sensitivities on 2035 Zero-Emissions Share of
MHD Truck Stock
b)
−31% 14% 2030
LDV
Percentage Target
Point Met c) VMT d) e)
Change a) (N/A Reduction High Low
relative to Remove for without Fossil Fossil
S1 Baseline No Effect MHD Stock Fuel Fuel
Scenario Sensitivities of ACT trucks) Change Prices Prices

Core S1 Baseline −3% 7% −4%

S2 Strong
Core Electrification 8% 8% 9% 4%
Technology

S3 Strong
Core Electrification 12% 11%
Policy*

S4 Strong
Exploratory −1% −6% −1%
VMT Policy

S5 Worst
Exploratory −5% −31%
Case

S6 Best Case
Exploratory Climate 14% 14%
Aligned

* S3a (11%) is a counterintuitive scenario with somewhat limited value for interpretation regarding MHDs because it removes the effect
of the ACT regulation, yet includes the effect of the more stringent ACF regulation.

The No Sensitivities column shows fairly large increases over the S1 Baseline 2035 electric truck population
for S2 Strong Electrification Technology (due to lower vehicle and operating costs), S3 Strong Electrification
Policy (due to larger incentives) and S6 Best Case Climate Aligned (due to a combination of lower costs
and higher incentives). The Remove Effect of ACT column shows similar deviations from baseline levels of
electric truck adoption, even in the absence of the ACT regulation, for S2a, S3a and S6a. This indicates that
decreasing the cost of electric trucks relative to ICE trucks enables electrification beyond the minimum
levels required by top-down policy, a distinct finding from the analogous comparison of electric LDV stock
with and without the ACC II regulation.

S4a Strong VMT Policy without the Effect of ACT hurts the economic case for electric trucks by reducing
operating cost savings, thereby reducing electric truck adoption relative to the baseline. S5a Worst Case
without the Effect of ACT significantly reduces the economics for electric trucks, resulting in far lower sales
and stock when ACT is not serving as a backstop.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 206
The VMT Reduction without Stock Change column shows a marginal change in 2035 electric truck
population from reducing VMT while holding vehicle stock constant. The final two columns — which
explore the sensitivity of higher and lower petroleum prices, relative to the baseline — show larger impacts
than the application of these sensitivities to the LDV scenarios, due both to the higher responsiveness of
commercial truck operators to TCO, and the larger share of total costs that operating expenses make up
for trucks relative to cars (making truck operators more sensitive to fuel price changes, all else equal).
Interestingly, S2e Strong Electrification Technology with Low Fossil Fuel Prices results in a larger number of
electric trucks in 2035 than the S1 Baseline scenario, indicating that the economic advantage provided by
lower electrification technology costs is sufficient to offset the disadvantage of lower diesel prices.

Table 37 provides a comprehensive comparison across scenarios and sensitivities of the estimated on-road
GHG emissions in 2035, shown as percent change relative to the S1 Baseline scenario.

Table 37 Effect of Scenarios and Sensitivities on 2035 On-road Transportation
GHG Emissions
b) c) VMT d) e)
−36% 34% a) 2030 Reduction High Low
Remove LDV without Fossil Fossil
No Effect of Target Stock Fuel Fuel
Sensitivities ACC II Met Change Prices Prices

S1 Baseline 10% −7% −5% 3%

S2 Strong Electrification
−4% 3% −11% −8% 0%
Technology

S3 Strong Electrification
−4% 6% −12%
Policy*

S4 Strong VMT Policy −20% −8% −26% −11%

S5 Worst Case 21% 34% 15%

S6 Best Case Climate
−30% −24% −36%
Aligned
* S3a (6%) is a counterintuitive scenario with somewhat limited value for interpretation because it removes the effect of the ACT
regulation, yet includes the effect of the more stringent ACF regulation.

For additional details on both GHG and local air pollutant emissions, by scenario, vehicle segment and
powertrain, please see the online Washington TES User-Interactive Dashboard.195

Explanation of Emissions and Equity Determinations in Tables 1 and 2

Table 38 provides an explanation of how the EV Council determined estimates for potential emissions
reduction and equity effects in identifying 2024 priorities.

195 Washington TES User-Interactive Dashboard, found on the TES website.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 207
Table 38 Explanation of Emissions and Equity Determination in Prioritization
Tables 1 and 2

Strategy Emissions Reduced Transportation Equity Air Quality Equity

There is a strong overlap
Achieving ACF adoption rates with
Requiring and incentivizing the between overburdened
support from incentives is one of
purchase of MD and HD ZEVs communities and those most
the assumptions made in
will increase access to EVs by affected by diesel pollution.
modeling S3 but not in S1.
accelerating the supply of ZEV Therefore, reducing truck
Requirements and
trucks in Washington. pollution through
incentives for zero- The determination of 230,000
electrification will have a
emissions MHDVs. MMT is found by taking the
The CARB found in a cost larger positive effect on air
difference between GHG
assessment of ACF that fleets quality in the average
emissions in S3 and S1 for MD and
save $48 billion through 2050 overburdened community
HD vehicle segments in 2030 and
as a result of the policy.* than the average Census
rounding to the nearest 10,000.
tract.

Growing consumer demand for
EVs will result in automakers
delivering more EVs to
Washington, especially prior to
Modeling for S3 assumes There is an overlap between
model year 2026.
increased incentives and overburdened communities
consumer awareness needed to and those most impacted by
Increased sales tax exemption
achieve increased EV sales prior to heavy-traffic roadways.
and awareness of incentives
model year 2026. Therefore, reducing LDV
Grow broad consumer and charging will have a larger
pollution through
demand for passenger positive impact for those who
The determination of 20,000 MMT electrification will have a
BEVs. currently cannot afford the up-
is found by taking the difference larger positive effect on air
front purchase price
between GHG emissions in S3 and quality in the average
differential of EVs to access the
S1 for LDV and motorcycle overburdened community
TCO savings.
segments in 2030 and rounding to than the average Census
the nearest 10,000. tract.
Recent consumer research
shows that Black and Hispanic
Americans are less likely to be
aware of federal EV credits.**

*CARB, “Public Hearing to Consider the Advanced Clean Fleets Regulations - Final Statement of Reasons for Rulemaking, Including Summary of Comments
and Agency Response,” (April 27, 2023).
** Ben German, “Exclusive: 40% of Americans Say They’ve Never Heard of Biden’s EV Tax Credits,” Axios, (October 30, 2023).
***Freehafer, Lazer and Zepka, “The State of Electric School Bus Adoption in the US.”
**** EPA, “Making School Buses Cleaner,” (n.d.).
***** Washington Department of Ecology, “Clean Fuel Standard Cost Benefit Analysis Report,” (May 12, 2022).

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 208
Table 38 Explanation of Emissions and Equity Determination in Prioritization
Tables 1 and 2, continued
Strategy Emissions Reduced Transportation Equity Air Quality Equity

Modeling for S3 assumes 100% of
school bus purchases are electric
starting in 2029, four years earlier
than in S1.
According to the World
According to the EPA,
The determination of 10,000 MMT Resources Institute, “Students
“Children are more
is found by taking the difference from low-income families are
susceptible to air pollution
between GHG emissions in S3 and particularly exposed to the
than healthy adults because
S1 for the school bus segment dangers of diesel exhaust
their respiratory systems are
(6,800) and rounding to the pollution: 60% ride the bus to
still developing and they
Accelerate and fund school nearest 10,000. school, compared to 45% of
have faster breathing
bus electrification to meet students from families with
rates.”****
needed adoption rates. The modeling assumptions should higher incomes. In addition,
not be considered a Black students and children
State funding will be needed
recommendation of the EV with disabilities rely on school
by all districts, especially
Council and were used to explore buses more than their peers,
those with lower access to
possible scenarios. Any purchase meaning they’re more likely to
local funding, to transition to
requirements should be be exposed to diesel
electric school buses.
developed with school districts exhaust.”***
and stakeholders. Refer to
Recommendation 4.5 for
suggested actions toward policy
development.

Reducing the carbon intensity
of liquid fuels powering ICE
vehicles does not increase
access to EVs or non-driving
transportation options.
The TES modeling did not assume There is an overlap between
According to Ecology’s cost-
a reduction in carbon intensity for overburdened communities
benefit analysis for the CFS,
gasoline and diesel emissions, and those most impacted by
the current policy is estimated
making it possible to isolate the heavy-traffic roadways.
to affect gasoline prices
program’s impact separate from Therefore, reducing vehicle
Reduce carbon intensity of between $0.00 and $0.19 per
transportation electrification pollution through reduced
gasoline and diesel with gallon and diesel prices
policies. carbon intensity will have a
clean drop-in fuels. between –$.02 and $0.17 per
larger positive effect on air
gallon, while driving down
Ecology staff will assess the quality in the average
costs of all other major fuel
isolated impacts of the current overburdened community
types by much larger
CFS and an acceleration in carbon than the average Census
amounts.*****
intensity reduction schedule. tract.
More analysis is needed to
determine the impact of an
accelerated carbon intensity
reduction on transportation
costs.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 209
Table 38 Explanation of Emissions and Equity Determination in Prioritization
Tables 1 and 2, continued
Strategy Emissions Reduced Transportation Equity Air Quality Equity
Anti-idling measures reduce
costs for fleets by changing There is a strong overlap
behavior that reduces fuel between overburdened
usage well beyond the amount communities and those most
Ecology staff have provided of fines paid for violations. impacted by diesel pollution.
preliminary estimates of 300,000– Therefore, reducing truck
Pursue diesel vehicle 700,000 metric tons of CO2e The measures do not have an pollution through less idling
efficiency standards. effect on overall EV adoption, and engine tampering will
reductions in 2030 from an anti- though may result in some have a larger positive effect
idling policy. electric anti-idling on air quality in the average
technologies. overburdened community
than the average Census
They also do not have an tract.
impact on mobility options.

Efficiency standards for
There is an overlap between
replacement tires will save
overburdened communities
RMI estimated that if Commerce drivers hundreds of dollars in
and those most impacted by
were to implement a replacement fuel costs for each set of tires,
heavy-traffic roadways.
tire efficiency standard similar to a far more than the expected
Improve vehicle efficiency Therefore, reducing vehicle
draft regulation published by the marginal increase in cost for
with lower-resistance pollution through better fuel
California Energy Commission, more efficient tires.
replacement tires. efficiency will have a larger
Washington LDV emissions would
positive effect on air quality
decline by an additional 360,000 The standards will have no
in the average overburdened
metric tons in 2030. impact on EV or multimodal
community than the average
options.
Census tract.

A scrap-and-replace program
for the heaviest medium- and
heavy-duty vehicle fuel users
may steer EV incentives toward
independent owner-operators,
but more analysis is needed.
Scrappage can also have the There is a strong overlap
negative effect of reducing the between overburdened
number of used diesel trucks communities and those most
Ecology staff have provided available, which could increase impacted by diesel pollution.
preliminary estimates of 110,000– used diesel truck prices. But Therefore, reducing truck
Focus on high-
130,000 metric tons of CO2e the state could structure a pollution through
consumption gasoline and
scrap-and-replace program to electrification will have a
diesel users. reductions in 2030 from early mitigate these effects by, for larger positive effect on air
retirement of heavy diesel users. example, requiring incentive quality in the average
recipients to trade their newer, overburdened community
more efficient diesel trucks at than the average Census
no or low cost to smaller fleets tract.
or owner-operators and
require scrappage of the older,
less efficient model.

There is no expected impact on
multimodal options.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 210
Table 38 Explanation of Emissions and Equity Determination in Prioritization
Tables 1 and 2, continued

Strategy Emissions Reduced Transportation Equity Air Quality Equity

WSDOT’s programs, especially
WSDOT programs focused on
Programs are considered essential those focused on zero-
airports, marine ports and
to successful and equitable emissions transit, electric
Continue funding WSDOT buses have a strong positive
implementation of existing bikes and car shares, have an
zero-emission vehicle and effect on the air quality of
policies, but no emissions outsized positive impact on
infrastructure programs. overburdened communities
reduction is attributed to this lowering costs and increasing
and those most impacted by
specific strategy. EV and multimodal options for
diesel pollution.
vulnerable populations.

Commerce programs are
specifically focused on
There is an overlap between
improving equitable access to
overburdened communities
lower-cost EVs, multifamily
and those most impacted by
residential charging and public
Expand and accelerate Programs are considered essential heavy-traffic roadways.
charging. As a result, they will
funding for Commerce to successful and equitable Therefore, reducing vehicle
lower transportation fuel costs
community charging and implementation of existing pollution through more
for low-income communities.
EV incentive programs for policies, but no emissions equitable EV adoption will
low-to-moderate income reduction is attributed to this have a larger positive effect
They are not expected to have
(LMI) consumers. specific strategy. on air quality in the average
an impact on multimodal
overburdened community
options, although public
than the average Census
charging near transit access
tract.
points and fleet depots may be
funded.

Grants to CBOs to plan and
design projects will allow for
more equitable participation in
Program is considered essential to Block grants to CBOs for
available programs, including
successful and equitable projects that benefit their
Provide block grants to the WSDOT and Commerce
implementation of existing neighborhoods will improve
increase CBO staff opportunities listed above.
policies, but no emissions air quality by increasing
capacity.
reduction is attributed to this electrification that displaces
This will result in more
specific strategy. polluting fuels.
electrified multimodal options
at lower costs in overburdened
communities.

Similar to the emissions
Although utility-side make-
Policy is considered essential to reduction and transportation
ready infrastructure is an
Support planning and successful and equitable benefits, this policy is a
essential component of the
building necessary utility- implementation of existing structural component of the
electrification transition, it
side charging policies, but no emissions transition but is not
does not on its own lower
infrastructure. reduction is attributed to this expected to have an outsized
costs, increase EV options or
specific strategy. impact in overburdened
increase multimodal options.
communities.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 211
Table 38 Explanation of Emissions and Equity Determination in Prioritization
Tables 1 and 2, continued

Strategy Emissions Reduced Transportation Equity Air Quality Equity

EO 21-04 applies to state
EO 21-04 applies to state
cabinet agency fleets.
Policy is considered essential to cabinet agency fleets. More
Although it will have positive
successful and equitable analysis is needed to identify
Fund and support state transportation benefits for
implementation of existing positive air quality impacts
agency efforts to state agencies, the
policies, but no emissions of agency electrification for
implement EO 21-04. transportation equity
reduction is attributed to this overburdened communities
determinations are intended
specific strategy. compared to other Census
for the broader public and
tracts.
vulnerable communities.

Policies are likely to result in There is an overlap between
improved price transparency, overburdened communities
better access to charging and those most impacted by
Policies are considered essential information, improved heavy-traffic roadways.
to successful and equitable reliability and quicker build Therefore, reducing vehicle
Make charging access more
implementation of existing out of the public charging pollution through
equitable and speed up
policies, but no emissions network. These outcomes will electrification will have a
project timelines.
reduction is attributed to this lead to more equitable access larger positive effect on air
specific strategy. to EVs and lower charging quality in the average
prices, especially for those overburdened community
without access to home than the average Census
charging. tract.

Working with communities
Policy is considered essential to Assessing transportation
to put in place more air
successful and equitable equity outcomes will improve
monitors near highways will
Monitor equity indicators implementation of existing understanding of program
improve understanding of
and measure outcomes. policies, but no emissions impacts and drive more
program impacts and drive
reduction is attributed to this effective investments and
more effective investments
specific strategy. policies.
and policies.

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 212
© 2023 Interagency Electric Vehicle Coordinating Council

Washington Transportation Electrification Strategy Interagency Electric Vehicle Coordinating Council 213

File and source

File: 2024_final-rmi-us-wa-transportation-electrification-strategy-full-report-01.pdf
Size: 19,629,797 bytes
SHA-256: ef652ce2f04517b3c85130dfa8cdf855aeadf0f46406b25c4f82e64ad849262f
Our copy: 2024_final-rmi-us-wa-transportation-electrification-strategy-full-report-01.pdf
Original: app.leg.wa.gov

Washington Transportation Electrification Strategy — Full Report, February 2024 (Interagency Electric Vehicle Coordinating Council)

Summary

Cite this document

Full text

File and source

Related records