TERC EV METHODOLOGY

OPEN FOR PUBLIC COMMENT

The TERC EV Methodology is now open for public comment. We encourage stakeholders to review the complete methodology, available below, and share their feedback by submitting comments in the accompanying form or send to info@terc-energy.com. All comments must be submitted by November 4th, 2025.

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Now Available for Public Comment

TERC EV Methodology

Program Scope & Eligibility

Consistent with the TERC Program Framework, the geographical boundary under the current methodology is limited to the United States and excludes EV charging activity occurring in jurisdictions with active low carbon fuel compliance programs (e.g. California, Oregon, Washington). ● What considerations should guide whether participation in TERC EV can occur alongside other compliance and voluntary crediting programs (e.g. LCFS, RFS)? ● What considerations should guide whether and how to expand TERC EV geographical boundaries beyond the United States?

Attribute Ownership and Incentive Alignment

Under the current methodology, the environmental attribute owner (i.e. the party eligible to generate TERC EVs) is the charging station owner for non-residential EV charging and the EV charging network operator for residential EV charging. In both cases, rights to environmental attributes may be assigned to other parties via written agreement. ● Do these ownership rules sufficiently address potential for double-counting or multiple attribute claims? ● Are there other ownership structures or situations that should be taken into account? ● How should rights to environmental attributes be handled in cases where multiple parties (e.g., OEMs, utilities, fleet owners, site hosts) are involved? ● Does the methodology sufficiently align incentives with investments?

Carbon Intensity

The current methodology references EPA eGRID state-level emissions data to determine the carbon intensity of electricity and lifecycle emissions analysis from the EPA RFS program to determine the CI of baseline fuels (diesel and gasoline). The TERC program will update CI data upon the publication of updated emissions data from both of these sources. ● What is your perspective on the use of EPA eGRID state-level emissions data to determine the emissions of electricity from EV charging? ● What considerations should guide the development of mechanisms to lower the CI of electricity (e.g. REC book-and-claim, hourly emissions data, etc.) ● What alternative data sources or calculation approaches, if any, might be considered?

Registration, Reporting & Verification

The Xpansiv Digital Fuels Registry will be the exclusive interface for registering EV charging equipment and submitting verified data for TERC generation through the TERC Program. Registration and reporting requirements for TERC EV align closely with the CA LCFS. Following the initial reporting period covering EV charging activity in 2024-2025, reporting periods will be quarterly. ● How practical is the proposed registration and reporting framework, and is the alignment with CA LCFS appropriate? ● How effective is the proposed verification framework in ensuring reductions represented by TERCs are reasonably attributed to quantities of electricity dispensed for EV charging?

Market Integrity & Claims

This section seeks input on how buyers of TERC EVs can credibly use them in corporate climate disclosures. ● What information must be included with TERC EVs (e.g., charging location, equipment type, baseline fuel, residential vs. commercial use) to make them useful and credible in disclosures? ● For your organization, would TERC EVs be applied toward Scope 1 (direct fuel use in your own vehicles), Scope 3 (value chain emissions, vehicles owned by others), or both? ● Would you prefer to use TERC EVs as evidence of direct emission reductions (avoided gasoline/diesel) or as indirect, market-based reductions (book-and-claim attributes, like RECs)? ● What additional safeguards or documentation would you need to be confident that no other party (OEMs, fleets, utilities, site hosts) is making overlapping claims on the same activity? ● Should the program provide standardized claim language or disclosure guidance to make it easier for buyers to communicate their use of TERC EVs without risk of greenwashing

Do you have any additional comments?

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