Electric and Hybrid Vehicle Battery Management Act
Description
Each year, producers will be required to submit an annual report. At least once every five years, or more as needed, producers will be required to submit a battery management plan and pay a fee. Alternatives include requiring producers to email all their documents for staff to manually import to an Access database for storing the data associated with the program. This would be a very disorganized approach, leaving room for human error. Access is also limited in functionality and is not a central location, making it difficult to share with Enforcement once requirements take effect. Furthermore, there is no other alternative for billing producers.
This project will support program implementation by providing the regulated community with a centralized place for submitting required forms and paying their fees all in one place. The DEP benefits from having a central location to bill producers and store all the data associated with battery management plans and annual reports.
Problem Statement
On January 8, 2024, Governor Murphy signed N.J.S.A. 13:1E-99.81 et seq., the Electric and Hybrid Vehicle Battery Management Act. The law requires producers to develop and implement a battery management plan that provides for the management of propulsion batteries at their end-of-life. Producers are also required to submit annual reports to the DEP. This project is necessary to compile and store producer data from battery management plans and annual reports and to collect fees associated with reviewing producer submissions. The division requires a centralized location for incoming data to facilitate submission and review of management plans and annual reports, to collect associated fees, and to communicate with enforcement once the requirements of the law take effect.
Project Justification
The DEP is anticipating approximately thirty producers will be submitting battery management plans at least once every five years and an annual report each year. With the projected number of producers affected by this law, the division does not have the staff to manually enter the data and separately bill each producer. Additionally, collection of associated fees requires an established payment system, which is only available through the use of RSP.
Estimated Transactions
30 initial plans, 30 reports per year.
Target Rollout Date Reason
None
Attachments
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FILE
IT Project Sheet - EV Batteries.docx
2025-04-02 13:00
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Activity
IPTD-533
From meeting today with Jim Bridgewater
Christopher Mikulewicz
Michele Zola
Michael Gerchman
Kyle McHenry
Victor Aboh
Jill Aspinwall
Nita Mishra
Generated by AI. Be sure to check for accuracy.
Meeting notes:
Evaluation of Data Submission Solutions for Battery Management Reporting: Michele, Jim, Michael, Christopher, Victor, Kyle, and others discussed various options for submitting and managing battery management data, including the Facility Submittal Service (FSS), full RSP service, and Simply Gov, with Christopher providing details on the reporting requirements and data structure, and the group weighing cost, technical feasibility, and data accessibility.
FSS Capabilities and Limitations: Michele and Jim explained that the Facility Submittal Service (FSS) can be built in-house to allow online submission of required documents, which are then attached to ngems and tracked as activities. FSS supports billing and payment, but does not parse or store data in a way that enables direct database reporting; manual data entry would be required for more granular data access.
Full RSP Service and Cost Considerations: Jim and Michael discussed the possibility of building a full RSP service, which would automate data parsing and validation, but noted that the cost for such a solution—estimated at $200K to $300K for 30 facilities—was not justifiable given the frequency and volume of submissions. Jim highlighted contract ceiling limitations and the need for prioritization based on available funding and organizational priorities.
Simply Gov as an Alternative: Kyle described Simply Gov as an online portal for data submission, currently used for CPCN, which allows for fillable forms, electronic signatures, and some billing functionality. Data submitted through Simply Gov is stored in its own database and can be exported to Tableau, Access, Excel, or SQL, but does not integrate directly with ngems, requiring additional manual or technical steps for full data migration.
Reporting Requirements and Data Structure: Christopher outlined the annual and five-year reporting requirements for battery management, including the need to track propulsion batteries sold, returned, remanufactured, repurposed, recycled, and disposed of, along with justifications and outcomes. The data is complex, involving multiple fields and attachments, and must be parsed by disposal method and brand, with deadlines set for annual and five-year submissions.
Decision-Making and Next Steps: Michele, Jim, and Christopher agreed that the team should discuss internally which solution best meets their needs, considering the trade-offs between cost, data accessibility, and technical feasibility. They decided to wait for further input before proceeding, emphasizing the importance of not starting down a path that may later need to be reversed.
Manual Data Entry and Staffing Implications: Jim, Victor, and Christopher discussed the need for manual data entry if FSS is used, as data submitted as attachments would require staff to enter details into ngems, raising questions about staffing and project scope.
Manual Entry Requirements: Jim explained that if FSS is used and data is submitted as attachments, staff would need to manually enter information into subject item detail windows in ngems to make the data accessible for reporting, which would require additional staffing and project planning.
Annual and Five-Year Battery Management Reporting Deadlines: Christopher clarified the deadlines for annual battery management reporting and five-year management plan submissions, noting the current and future requirements and the extension of the annual reporting deadline.
Reporting Deadlines: Christopher stated that annual reporting for battery management is required as of January 8, 2026, with the deadline extended to April 30th, and that the five-year management plan submission is a separate requirement pending completion of a needs assessment and future rulemaking.
Funding and Billing Components for Data Submission: Christopher and Jim discussed the funding and billing aspects of the battery management reporting process, including the need to establish fees through rulemaking and the configurability of billing within FSS and ngems.
Fee Establishment and Billing: Christopher explained that the law requires producers to pay a fee, which will be determined through future rulemaking, while Jim noted that billing functionality can be configured within FSS and ngems as needed.
Follow-up tasks:
Internal Review of Data Submission Options: Conduct an internal discussion to determine which data submission route (FSS, RSP, SimplyGov, or spreadsheet via email) best meets program needs, including considerations for staffing and data entry requirements. (Christopher, Michael, Jill, Kyle)
Spreadsheet Submission Evaluation: Evaluate the first year of spreadsheet submissions via email to assess the quality and completeness of data received and identify any necessary tweaks for future system builds. (Christopher)
Follow-up Communication to Project Team: Notify Michele, Jim, Victor, and Nita of the decision regarding the preferred data submission route once internal discussions are complete. (Christopher, Michael)
Hi Nicole,
I saw this and wanted to clarify if you had conversations with Jim about this moving to #1 and whether he can act on it or if you want any help getting time set up.
Knute Jensen
IT Project Coordinator | Division of Information Technology
knute.jensen@dep.nj.gov<knute.jensen@dep.nj.gov>
609 940-5526
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Despite the pending submission deadlines, this project at a priority 5 (with many duplicate 1-4 higher priorities in AEMS) it is unlikely to be taken up any time soon. Nicole to consider competing demands and priority with program. Possibly this would get into conversations on CGI work lining up in July 2026 with a new contract year.