NATSO filed comments on Aug. 22 on the Federal Highway Administration’s (FHWA) Notice of Proposed Rulemaking to set proposed minimum standards and requirements for projects funded under the National Electric Vehicle Infrastructure (NEVI) Formula Program.
The agency announced the NPRM in early June to address “wide disparities” among EV charging stations in key components, such as operational practices, payment methods, site organization, price, speed and power of chargers, and information communicated about the availability and functioning of each charging station.
NATSO was joined in submitting the comments by SIGMA: America’s Leading Fuel Marketers and the National Association of Convenience Stores (NACS).
Existing fuel retail locations represent the best opportunity for building out a nationwide network of EV charging stations. The associations, which collectively represent more than 150,000 fuel retailers, called for a series of market and policy reforms that focused on the need for the private sector to be able to earn a profit from EV charging as well as a uniform pricing structure for consumers. Other policy reforms focused on the need for flexibility in the requirement that EV chargers be located every 50 miles along designated corridors and the need to focus on driver safety and convenience at site locations.
NATSO said that fuel retailers support proposals to establish a transparent and uniform pricing structure across the charging station network, requiring NEVI-funded charging operators to display and base the price of electrical charge in dollars per kilowatt hour. A uniform, transparent pricing structure would allow consumers to compare offerings throughout the country.
Notably, NATSO urged U.S. DOT to:
Flexibly administer the requirement that states locate electric vehicle charging stations every 50 miles along designated corridors. Rather than forcing states to meet an arbitrary 50-mile requirement where it isn’t feasible, U.S. DOT should ensure that states can administer the program in accordance with their specific needs, especially in rural states, working with the private sector as required by law.
Refrain from regulating or capping revenue earned from private sector operation of a NEVI-subsidized EV charging station. Regulated utilities should be precluded from imposing exorbitant rate hikes on their monthly customers to underwrite NEVI-funded charging station investments that the private sector is willing to make.
Establish a transparent and uniform pricing structure across the charging station network, requiring NEVI-funded charging operators to display and base the price of electrical charge in dollars per kilowatt hour. A uniform, transparent pricing structure would allow consumers to compare offerings throughout the country.
Encourage states to allow EV charging station operators to sell electricity to EV drivers without being regulated as a utility. In many states, utilities are opposing efforts by prospective charging station operators to generate their own electricity to power their charging stations. This opposition reflects an effort by regulated utilities to undermine the case for private investment in charging stations and inhibits EV penetration.
Require states to consider driver safety and convenience by locating chargers at sites that have on-site employees to call emergency personnel when needed and offer amenities that attract other highway travelers. Co-locating charging stations with 24/7 amenities will invariably make consumers more comfortable purchasing an EV without concern for undue safety risks when refueling.
Avoid bureaucratic hurdles that would inadvertently depress the market for electric vehicle charging. The “Buy America” provision, for example, requires charging station equipment to be manufactured in the United States yet virtually no equipment on the market today meets the "Buy America standards." Such requirements would significantly delay charging projects.
The NEVI Formula Program was enacted as part of the Infrastructure Investment and Jobs Act of 2021 and oversees funding to states to deploy EV charging stations across the country. FHWA will now review the comments before publishing a Final Rule in 2023.
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