Revocable Consents for Battery Swapping and Charging Cabinets

Online comments: 9

• SolarBro

  Why can we get approval for charging cabinets but not for batteries to store energy from solar panels in our homes?

  Comment added July 30, 2024 11:40pm

• Richard Johns

  The Settlement Housing Fund sees battery swapping and charging cabinets as an effective tool for ensuring that our residents have access to micromobility devices in a cost-effective manner while reducing, if not eliminating, the risk of potentially catastrophic fires. Therefore, we strongly urge the New York City Department of Transportation to adopt the proposed rule.

  Comment attachment
  SHFLetterOfSupport-NYCDOT.pdf

  Comment added August 12, 2024 2:16pm

• Katherine O'Sullivan

  Another land grab from the public streets. This should not be allowed on public streets. Let charging stations be placed on private property at the will of the owner.

  Comment added August 14, 2024 6:36pm

• Holland Cathey

  Swobbee US Corp. designs, manufactures and operates a network of firesafe charging infrastructure (generally in the form of free standing kiosks on the sidewalk.) These kiosks allow ebike users to swap their discharged batteries for charged batteries, in a matter of minutes. Swobbee has just completed a successful pilot to test out the efficacy of the kiosk and infrastructure at selected locations in New York City.

  The kiosks stand roughly 7 feet 5 inches, and sometimes require a foundation or elevated base of a few inches. In addition, the roof of the station has built-in antennae to connect to the cloud, in order to ensure data transfer and connectivity to the internet.

  Thus, some clearance above the station is necessary. We are requesting that the maximum height allowed for the stations be increased from 8 feet to 8 feet 5 inches. Please see the attached technical spec sheet for more details. Limiting the height to 8 feet can, in some cases, slow down the swapping process for some users, and may also limit the kiosks’ ability to charge batteries fully and safely.

  Comment attachment
  SWOBBEE_US_LOCATIONPARTNER_INFO_8_14.pdf

  Comment added August 15, 2024 8:26am

• Michael Sutherland (Open Plans)

  Open Plans writes in regard to new proposed rules on expediting the installation of private e-bike charging cabinets on our sidewalks. The current landscape of illicit charging stations in bodegas and homes is a public hazard. We applaud the city’s efforts to safely and efficiently serve e-mobility users. However, we call for a more holistic approach to charging that doesn’t degrade vital sidewalk spaces. We call on DOT to preserve and improve the pedestrian experience. Detailed comments on this and more are in the attached testimony.

  Comment attachment
  Open-Plans-Testimony_-Sidewalk-E-Charging.pdf

  Comment added August 15, 2024 2:11pm

• Adam Roberts

  August 26, 2024

  CHIP Testimony on Revocable Consents for Battery Swapping and Charging Cabinets

  Thank you for holding this hearing today. I am Adam Roberts, Policy Director for the Community Housing Improvement Program (CHIP). We represent New York’s housing providers, including apartment building owners and managers. Our members operate New York’s one million units of rent-stabilized housing, which makes up 40% of its rental housing and the vast majority of its affordable housing.

  Lithium ion batteries are a significant danger to our members, their employees, and their tenants. Existing policies and laws limit the ability of building staff to act when a tenant is using their apartment illegally as an e-bike charging station or repair shop. Therefore, we appreciate the Mayor’s and DOT’s effort to provide programs for battery swapping and the installation of charging stations. However, as currently designed, this program would not have prevented the deadly fires that occurred in our members’ buildings.

  Critically, charging stations can only be installed, “adjacent to a property where the ground floor has a commercial or manufacturing use.” Therefore, residential buildings without commercial space cannot install charging stations. This leaves many, if not most, residential buildings unable to have a charging station.

  Furthermore, by limiting charging stations to being adjacent to commercial and industrial space, charging stations could negatively affect street visibility and loading zones. Commercial spaces rely on street visibility to garner customers and loading zones to keep their products stocked. We have seen the impact that unsightly sidewalk sheds have had on commercial activity for these storefronts. The council should explore the impact of charging stations as well.

  Lastly, the cost burden of charging stations is prohibitive. By choosing to implement charging stations through the city’s revocable consent system, owners will be required to pay for the installation, maintenance, and electrical for these stations. This adds up to tens of thousands of dollars, making it unaffordable. Rent-stabilized housing is facing a major financial crisis, meaning buildings do not have the income to cover the cost of these stations.

  As currently envisioned, this program would effectively allow for charging stations to be installed in front of residential buildings with ground floor commercial space, that do not already have obstacles blocking access to that commercial space, and are in highly profitable free market buildings. There are only a handful of buildings where this would seem possible. Tenants and workers in rent-stabilized buildings without commercial space would see little benefit from this program, putting them at continued risk from e-bike fires.

  We hope to work with the Administration and DOT to amend this program so that it can protect a greater number of New Yorkers. Thank you.

  Comment attachment
  8.26.2024-Ebike-Hearing-Testimony-CHIP.pdf

  Comment added August 22, 2024 9:09am

• Tom Scheiber

  Perch Mobility applauds New York City for the proactive approach in addressing the critical needs surrounding e-bike and scooter charging. The measures the city is considering align with broader climate and transportation goals, recognizing the significant role micromobility plays in reducing carbon emissions and shifting away from car-centric transportation. The development of a safe and reliable e-device infrastructure is not only essential for meeting the city and state’s climate objectives, but also imperative in tackling the ongoing crisis related to battery fires. By prioritizing safe charging solutions, the city is taking a vital step towards fostering a safer and more sustainable urban environment.

   

  We appreciate that the city is adopting an inclusive, ‘all of the above’ approach to enhance micromobility charging infrastructure and safety measures. This strategy including an expanded public bike parking with integrated charging facilities; establishing public charge and battery swap stations; requiring UL certification for e-bike batteries to ensure safety; launching initiatives like the e-bike trade-in program to replace unsafe devices with safer alternatives.

   

  Such multi-faceted strategies are essential in addressing the varied challenges associated with micromobility expanded, including safety, accessibility, and usability, while promoting widespread adoption. The recent initiatives highlighted in various reports, including the efforts to curb deadly e-bike fires, reflect the City’s commitment to innovative and effective solutions.

   

  While expanding micromobility infrastructure is crucial, we recognize the physical limitations of sidewalk space. The need for more charging and storage options is evident as micromobility adoption continues to grow. Drawing inspiration from community and advocacy groups such as Open Plans, we suggest that the city looks beyond sidewalks and considers utilizing curb lane spaces, which have already been successfully repurposed for outdoor dining, microhubs, and public spaces. 

   

  Curbside charging and parking can provide scalable solutions without further congesting pedestrian areas. Such measures would allow for the efficient use of public space, while supporting the citywide need for more comprehensive micromobility infrastructure.

   

  In addition to the use of revocable consent agreements, the City should explore ways to streamline the process for utilizing curbside (parking lane) space for e-bike parking and charging stations. Introducing modular solutions like those offered by Perch Mobility could significantly enhance community access to safe and reliable charging. Perch Mobility’s systems are designed to be easily deployed and adaptable, meeting the diverse and immediate needs of neighborhoods across the city. By leveraging such modular technology, the City can quickly and efficiently expand micromobility infrastructure.

   

  In addition, Perch strongly recommends when the UL 4900 standard for micromobility charging infrastructure safety becomes available, the city should require all public charging stations to comply with this standard. Ensuring adherence to comprehensive safety standards will further mitigate the risks associated with battery charging.  In considering future infrastructure, we encourage the city to explore diverse form factors for micromobility charging stations that do not solely rely on sidewalk installations. Alternatives can provide flexibility and reduce the impact on pedestrian traffic while still offering accessible charging options.

   

  Perch Mobility looks forward to supporting the City of New York and the expansion of micromobility infrastructure.  We are eager to contribute our expertise, technology, and product to help build a safer, more efficient last mile transit system.

   

  Comment attachment
  letterhead-NYC-Sidewalk-Comments-8-26-2024.pdf

  Comment added August 26, 2024 10:58am

• Tammy Meltzer

  Manhattan Community Board One submits the attached written testimony urging the Department of Transportation and NYC to not allow advertising on the cabinets as a revenue generating use on the sidewalks. As well as to create an end of life process and removal plan for the cabinets when this type of batteries are no longer needed, or the company has gone out of business, or the cabinet is abandoned or underutilized. Also urging the city to prioritize pedestrian safety on the sidewalks and work with businesses to identify alternative sites where businesses without adequate sidewalk space may locate and utilize charging cabinets and bike storage.

  Comment attachment
  MCB1-COMMENTS-ON-BATTERY-CHARGING-STATIONS_8.26.2024.pdf

  Comment added August 26, 2024 4:05pm

• Hayley Prim

  Please find the attached PDF with comments from Uber expressing our support for the proposed rule change regarding revocable consents for battery swapping and charging cabinets.

  Comment attachment
  NYC-DOT-Rules-_-Uber-Comment-on-Revocable-Consent.pdf

  Comment added August 26, 2024 4:39pm