Comments to the Federal Highway Administration on EV Charging Deployment

The Bipartisan Infrastructure Law (BIL) will invest approximately $7.5 billion for the deployment of electric vehicle charging infrastructure in the US. The Department of Transportation (DOT), in coordination with the Department of Energy (DOE), is required to develop guidance for States and localities to deploy electric vehicle charging. A Request for Information (RFI) was published under Docket No. FHWA-2021-0022 to invite public comments to inform the development of the Guidance for an Electric Vehicle Charging Program.

I submitted the following comments:

Docket No. FHWA-2021-0022
January 27, 2022

As an electric vehicle driver of nearly ten years, I appreciate this opportunity to provide comments on the Development of Guidance for Electric Vehicle Charging Infrastructure Deployment from an EV driver’s point of view. The consumer experience at public EV charging stations can have a profound effect on the success of charging infrastructure deployment.

Comments are directed at the EV Charging Program statutory considerations as indicated by their corresponding numbers below.

Statutory Consideration 1

50 miles is a reasonable distance between publicly available EV charging stations. This is especially critical for colder climates where the winter temperatures can reduce the range on battery electric vehicles.

Statutory Consideration 3

Priority should be given to EV charging infrastructure that is located at or near locations that have 24-hour amenities such as off-highway travel centers, fuel retailers, convenience stores, and local small businesses.

Statutory Consideration 4

Publicly available EV charging stations in rural corridors and other underserved communities should be given high priority because they are often unattractive to the existing commercial EV charging service providers. Serving rural areas can encourage people who live in those areas to use electric vehicles. This will create a larger benefit for the individuals as well as the public as a whole.

Statutory Consideration 5

Poor reliability is one of the biggest problems that current EV drivers face. It is not “range anxiety” but “charger anxiety” that concerns us. It is important to enforce operational uptime requirements to ensure the continuous availability and long-term operation of publicly-funded EV charging infrastructure.

Grant recipients should be required to submit an operations and maintenance plan and adhere to a quick repair schedule when problems are reported. There should be a third party assigned to evaluate the percentage of time that individual charging stations are inoperable and that information should be made publicly available.

Statutory Consideration 8

The Program should encourage, but not necessarily mandate, higher-powered Level 2 charging stations in order to meet the anticipated demand for vehicles that have faster onboard AC charging capabilities such as pickup trucks. Additional funding could be considered for Level 2 AC charging equipment that can deliver between 10 and 19 kilowatts.

Statutory Consideration 9

Another factor that I suggest the Secretary consider in developing the EV Charging Program guidance is to expand and enhance the data reporting in the Department of Energy Alternative Fuels Data Center (AFDC). I would suggest that each charging station funded under the Program have more detailed information made available in the AFDC. This would include listing the cost per kWh where applicable, the power rating of each connector, and the current live status/availability via a public API for all DC Fast Chargers.

General service and wayfinding signs should be considered to help EV drivers navigate from the highway to the particular location of the charging stations. Prominent signage can also help “advertise” to the public that the electric vehicle charging infrastructure is becoming ubiquitous.

The next revision to the FHWA Manual on Uniform Traffic Control Devices (MUTCD) should contain sign standards to discourage non-electric vehicles from blocking charging station spaces and to remind electric vehicle drivers to only use the spaces for charging.

Consideration should be given to charging hubs in urban centers to support charging for Uber/Lyft/Taxi drivers.

Continued support should be provided for the CHAdeMO connector standard. There are still many electric cars that use this connector that are affordable to more people on the used vehicle market.

Sincerely,
Lanny Hartmann

See also: Comments to Maryland PSC on Reliability of Public Charging