APPA Weighs In On National Electric Vehicle Infrastructure Formula Program

August 23, 2022

by Paul Ciampoli
APPA News Director
August 23, 2022

The American Public Power Association (APPA) recently responded to a request for comments from the Federal Highway Administration (FHA) on a notice of proposed rulemaking for the National Electric Vehicle Infrastructure (NEVI) Formula Program. Among other things, APPA commented on the need for flexibility on the number of ports and charging capacity for Electric Vehicle Supply Equipment (EVSE).

A section of the proposed rule includes requirements for the installation, operation, and maintenance of NEVI Formula Program funded chargers. Specifically, this section proposes to require four Combined Charging System charging ports capable of simultaneously charging four electric vehicles, with each port being capable of charging at least 150 kW. This means a NEVI-compliant charging station would be required to serve at least 600 kW at any given time. 

APPA noted in its Aug. 22 comments that public power utilities are already actively working with their communities to advance transportation electrification. However, “this level of new load could be a challenge depending on the unique circumstances of the local utility and grid. For some APPA members this additional load could double their current overall load and, even for utilities serving a larger load, charging stations at this capacity level will still require significant and costly utility upgrades to support.”

To address this challenge, APPA offered two recommendations. 

First, APPA recommended providing the maximum possible flexibility in implementing the requirement that NEVI-compliant charging stations include four, 150 kW minimum, charging ports.

It noted that in certain areas with low utilization levels, EV drivers may be fully served by two 150 kW ports in the near-term and additional ports could be added subsequently during the five-year NEVI program. “Additionally, states should be strongly encouraged to include the cost of necessary electric infrastructure upgrades when providing grants to fund NEVI stations.”

Additionally, grant recipients should also be able to futureproof stations and upsize design (lot sizes, transformers, conduit, wire/cable/etc.) to enable rapid deployments of additional chargers at the sites as demand grows, APPA said.

APPA also recommended that stakeholders, including NEVI station owners, operators, and site hosts, talk to utilities early about connecting to the grid. “This engagement will allow public power utilities to plan for future load and any upgrades as well as provide crucial advice on how to deploy this infrastructure.”

The program also that “states must ensure that EVSE is maintained in compliance with NEVI standards for a period of not less than 5 years from the date of installation.” 

APPA “encourages states to require clear, comprehensive, and detailed contractual agreements for any maintenance and operation requirements. For example, contracts should specify turnaround timeframes for maintenance and describe if the scope includes maintenance for operational issues due to theft and vandalism. This is vital to ensuring a positive customer experience, but ongoing and proactive maintenance is also needed to support charger reliability.”  

The FHA also proposes requirements for the workforce installing, maintaining, and operating NEVI-funded EV charging stations, including requirements that all electricians be either certified through the Electric Vehicle Infrastructure Training Program or a graduate from a Registered Apprenticeship Program that includes EVSE-specific training and is developed as part of a national guideline standard approved by the Department of Labor in consultation with the Department of Transportation. 

APPA voiced concerns about this requirement, particularly given the size and scope of the NEVI Formula Program, which aims to deploy 500,000 EV chargers around the country. “This effort will absolutely require an appropriately trained and qualified workforce; however, additional flexibility regarding training specifics will allow more workers to qualify in a timely manner.”

Meanwhile, APPA also expressed concerns about the program’s proposal that NEVI-funding charging stations be required to display and base the price for charging in $/kWh. 

“APPA has concerns with this requirement, particularly that it will limit innovation in pricing from site hosts and other stakeholders. For example, public power utilities have already utilized a variety of billing techniques including price per kWh, price per minute, subscription fees, and connection or idling fees that may be in combination with other fee types.”

APPA noted that an idling fee would encourage responsible EV charging practices and allow for the most efficient use of chargers by the most consumers. Some public power utilities are using time-of-use structures within these billing techniques. “This can help incentivize off-peak charging as well as provide drivers with a more accurate price signal for the cost to charge their vehicle. As not-for-profit entities, the main goal of public power utility rate design is to recover the cost of providing service. It is important that pricing structures for charging infrastructure allow flexibility for owners to recover costs such as installation, maintenance, and make-ready infrastructure upgrades.”

APPA also addressed the question of whether there are factors that could be considered to avoid an instance of charging the consumer too high a price for electric vehicle charging, particularly when demand is high, and supply is low.  

“APPA strongly believes that electric rate design is a state and local decision. Ratemaking at public power utilities is conducted in an open and transparent manner and is subject to approval by the utility’s governing body.”

Supply Chain And The Need For Flexibility

APPA also used its comments to highlight ongoing supply chain challenges facing the electric utility sector.

If supply chain issues persist into the long-term, “they could impact the ability for electric utilities to deploy the infrastructure necessary for the EV charging network envisioned by the NEVI program, as well as many of the other electric infrastructure projects that will be supported by the Infrastructure Investment and Jobs Act (IIJA).”

Implementing federal and state agencies “should consider what tools they can deploy to help the electric industry ensure the supplies and materials, as well as the necessary workforce, are in place to efficiently and effectively make this significant and needed infrastructure investment.”

APPA also said that NEVI grant programs should be designed with flexibility in mind, noting that every community is different and project needs will vary. “Technology is evolving and EV and charging infrastructure usage will change with higher adoption. One-size-fits-all programs will be inaccessible or unworkable for many public power utilities.”