Industry players are making their voices heard as a Federal Highway Administration (FHWA) program aims to speed up the country’s transition to electric vehicles as part of last fall's Infrastructure Investment and Jobs Act.
A notice of proposed rulemaking was posted to the Federal Register to gather public comments on the National Electric Vehicle Infrastructure (NEVI) Formula Program’s planned regulations and minimum standards for a nationwide electric vehicle charging network.
The federal government, under the Infrastructure Investment and Jobs Act, which President Biden signed into law in November, is allocating $5 billion among the states to build electric vehicle (EV) charging stations. An additional $2.5 billion is being allocated to states via discretionary grants that can be applied to build EV charging infrastructure and hydrogen, propane, and natural gas fueling infrastructure, focusing on rural areas and disadvantaged communities.
Under the current proposed rule, the FHWA would require publicly available EV charging stations to be built every 50 miles and no more than one mile from the interstate. States may, in their applications, request an exception to the distance rules under what the NEVI program guidance called “very limited circumstances” that will be “granted sparingly.”
The stations would need to support at least four combined charging system (CCS) ports, each with the capability of providing at least 150 kW simultaneously, allowing no less than 600 kW of charging capability per charge station. Stations should be designed to be able to accommodate future expansions needed to meet the power demands of medium- and heavy-duty trucks. All stations must use direct-current fast chargers (DCFC).
Charging requirements for electric trucks
In their comment on the proposed rulemaking, American Trucking Associations (ATA) said the 50-mile requirement was unnecessary and highlighted the much higher energy needs for electric trucks over passenger vehicles.
“Given the current market penetration rates of EV freight trucks, installing truck charging infrastructure every 50 miles along designated Alternative Fuel Corridors is not currently warranted nor economically practical,” ATA commented. ATA stated that most commercial electric vehicles (CEVs) are for urban and regional applications, and because they charge “behind-the-fence” do not venture far from their domicile.
“The energy demands for one electric car pales in comparison to the needs for one Class 8 electric truck,” ATA commented. “As an illustration, the energy demands for 44 Tesla electric cars traveling the national average of 13,500 miles per year equates to the electricity needed for one Class 8 truck traveling 100,000 miles per year.”
ATA acknowledged the much higher amount of light-duty battery-electric vehicles (BEVs) on the roads, but emphasized the importance of future-proofing infrastructure to accommodate the rapidly increasing number of medium- and heavy-duty CEVs that will operate on the nation’s highways, especially if the White House is to meet its target of half of all new vehicles sold being zero-emissions by 2030. ATA stated that, as of June, there were 1.45 million light-duty BEVs in the U.S., but as of December 2021, only 1,214 medium- and heavy-duty zero-emission vehicles (ZEVs). However, there are currently 140,000 pending orders for commercial ZEVs, “which will be fulfilled across different time scales depending on manufacturer capacity, supply chain constraints, and order size.”
The fastest DC fast chargers, according to ATA’s comment, can power up a light-duty EV battery up to 80% in 10 minutes. By comparison, a 600-KWh electric truck needs six hours to charge using a 100 kW DC fast charger. While current NEVI program guidelines state that ports should have a minimum charge power of 150 kW and should be designed to accommodate 350kW or greater outputs in future upgrades, ATA stated the trucking industry will need EV chargers rated over 1 MW to charge commercial vehicles in a timely manner.
Grid capacity for electric vehicles
There is, however, concern over the electrical grid’s capacity to support such high wattages. Ford Motor Co., in its comment, recommended allowing a minimum of two 350kW and two 150kW ports, but acknowledged the design flexibility that would be needed to achieve this.
“It may be necessary to balance investment expense and the grid's ability to support power delivery with the desire for 350kW charging hardware,” Ford commented. “The stations should be designed with flexible architecture starting with a minimum of 150kW and load-sharing within the stations to achieve 350kW on half the plugs when the other half of the plugs are not in use. When existing grid infrastructure supports greater than 1 MW of power delivery, two 350kW charging stations should be installed. Where infrastructure power delivery is limited, hardware should be future proofed to support 350kW power delivery once available.”
ChargeNet Stations suggested the charging stations be coupled with solar panel canopies and battery storage, with the batteries being able to divert stored electricity back to the grid at night to reduce strain. In its comments, ChargeNet Stations underscored the importance of electricity used in EV charging to be obtained via renewable sources.
On electrical grid capacity, ATA suggested that the program require states to consult with utility companies as to their ability to meet demand. ATA commented that NEVI guidance states the importance of and suggests “that consultation should occur, the guidance does not indicate when consultation should occur. ATA recommends that as a precondition of NEVI funding, DOT require states to undertake analysis in coordination with relevant utilities to affirm their ability to serve additional charging loads well into the future.”
Both Ford and ATA urged the FHWA to include specifications for stations to be designed with commercial vehicles in mind, including heavy-duty trucks’ turning radius needs in the stations and minimum height clearance requirements for tractor-trailers.
Private investment in EV charging
The funds from the NEVI program will be allocated from the federal government to the states, but some industry players assert that the government is not doing enough to encourage private investment in EV charging.
NATSO, a trade organization representing truck stops, travel centers, and fuel retailers, argued in their Federal Register comment that charging stations not be regulated as a utility, saying, “states that encourage regulated utilities to supplement grant dollars with ratepayer money in a risk-free, guaranteed rate of return environment, will discourage private investment and engender a faulty market structure” and discourage competition between private entities that would foster innovation and lower prices for consumers.
NATSO and its partners also stated the FHWA should omit the requirement that stations be placed every 50 miles. The comment was a joint statement issued alongside the National Association of Convenience Stores and fuel marketing trade association SIGMA.
