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Document Notes:

• Quarterly data submissions (p.7 and p.43/44; Section 680.112(b))
  • Charging station use
    • Charging session metrics
    • Energy dispensed per port
  • Reliability, maintenance, and installation cost 
    • Charging station uptime
    • Total monthly cost of electricity paid to operate the station
      • Demand charges
      • Energy charges ($/kWh)
      • Fixed charges
      • Taxes
      • Other fees
    • Monthly maintenance and repair costs per port
  • Construction and installation data
    • Detailed costs such as:
      • Installation costs
      • Distributed energy resource acquisition and installation
      • Grid connection and upgrade costs (paid for by charger operator)
• Annual data submissions (p.7 and p.44/45; Section 680.112(c))
  • Identifying information about organizations operating, maintaining, or installing EVSE
    • Whether these organizations participate in State or local business opportunity certification programs such as programs for minority-owned businesses, Veteran-owned businesses, woman-owned businesses, and/or businesses owned by economically disadvantaged individuals for private entities
  • Information about any certifications of these entities
• Annual report (p.7 and p.45; Section 680.112(d))
  • Description of community engagement activities conducted in accordance with their approved State EV Infrastructure Deployment Plans
• With regard to data requirements: Will this data collection place undue burden on states? (p.7/8)
• Charging station networking requirements (p.8; p.46/47/48; Section 680.114)
  • Must be able to communicate through the Open Charge Point Protocol (OCPP) in tandem with ISO 15118
    • This is meant to help with cybersecurity concerns and;
    • Reduce the risk of stranded assets in the event that an operator abandons a station
  • Must be capable of “Plug and Charge”
  • Must be capable of “smart charge management”
  • FHWA recognizes that these requirements (Plug and Charge; smart charge management) are fairly new, hence the requirement of OPCC communications instead of requiring the use of those capabilities outright
  • Chargers don’t need to use those capabilities, but they must be capable of it
  • “FHWA proposes to include a requirement in Section 680.114(b) that, where credential-based electric charge initiation or payment is implemented, charging networks be capable of communicating with other charging networks to enable customers to use a single credential regardless of the charging network responsible for a charging station.” (p. 48)
  • Charging networks must be capable of communication with electric utilities and energy providers, or local energy management systems (p.48)
• Charging stations need to provide real-time status information through a freely accessible API to all third-party software developers (p.8)
  • Location
  • Connector type
  • Power level
  • Status
    • Number of ports accessible to persons with disabilities (p.51; Section 680.116)
  • Pricing
  • Chargers would be required to display the price of charging in $/kWh
    • In states where “charge for charge” is not allowed, FHWA requests comment on how to best require the display of price on these chargers
    • Should it be $/mi, $/minute, or some other metric?
• Price transparency (p.27/28)
  • Public disclosure for the documents concerning the operations of the EV charging stations where price setting is involved, including the procurement process used, the number of bids received, the identification of the awardee, the proposed contract with the awardee, and, in accordance with State law, the financial summary of contract payments (including the price and cost data), and any information describing how prices for EV charging are to be set under the contract.
• States are subject to 23 U.S.C. 112 and any State procurement policies and procedures per 2 CFR 200.217 (p.28)
• Level 2 chargers may be eligible for NEVI funds after corridors are fully built out (p.31)
  • J1772 would be the required connector for a Level 2 charger
• Non-CCS plugs at DCFC sites (p.31)
  • “Section 680.106(c) would further provide for additional flexibility for the provision of charging ports after the aforementioned CCS requirement has been met. This includes adding permanently attached proprietary connectors to DCFCs. In addition, specific to the use of FY22 NEVI Formula Program funds, DCFCs may include permanently attached CHAdeMO connectors for one or more DCFC charging port.”
    • It is not clear to me if “CCS requirement has been met” refers to “fully built-out” or just the 4 plugs per site requirement.
• Station power level (p.32)
  • Chargers with higher power levels are encouraged “where appropriate to support industry efforts to ensure a consumer’s time to charge is at least comparable to filling a gas tank”.
  • “The inclusion of a requirement that each DCFC charging port must be at or above 150kW would benefit the charging industry primarily in communicating standards with individual utilities that may not be accustomed to EV industry preferences.”
  • Level 2 chargers (if funded) would need to deliver at least 6kW per port simultaneously across all ports.
• Charger availability (p.32 and p.50; Section 680.116(b))
  • Stations must be available for public use 24/7 with minor exception
  • Isolated or temporary interruption due to maintenance or repairs would not violate this requirement
  • Stations must have an uptime greater than 97%
  • Uptime must be submitted quarterly and retained for quarterly review
    • Uptime calculation:
    • Mu = ((8760 – (T_outage – T_excluded))/8760) X 100
    • Mu = port uptime percentage
    • T_outage = total hours of outage in previous year
    • T_ excluded = total hours of outage in previous year for reasons outside operator’s control
  • The FHWA requests specific comment on what additional considerations should be contemplated to ensure EVSE resilience/reliability in floodplains and during natural disasters
• Payment systems (p.34)
  • Stations cannot require memberships for access
  • Payment options must include contactless payment methods from all major debit/credit card providers
  • Access cannot be limited by payment type
  • Plug and Charge payment capabilities are required
  • Credit card is not required to be the only payment method to be mindful of the underbanked.
  • FHWA requires multilingual access and access for people with disabilities
• Efficiency certifications (p.35)
  • For Level 2 chargers, ENERGY STAR certification is required
  • For DCFC, ENERGY STAR certification is not currently required due to a lack of widespread availability
• Physical and Cybersecurity measures (p.35/36)
  • “Section 680.106(h) would require States to implement physical and cybersecurity strategies consistent with their State EV Infrastructure Deployment Plans. This section also includes options for both physical security, such as lighting, siting, driver and vehicle safety, fire prevention, tampering, charger locks, and illegal surveillance of payment devices, and cybersecurity strategies that may be addressed in order to mitigate charging infrastructure, grid, and consumer vulnerability associated with the operation of charging stations. The FHWA encourages States to implement policies to safeguard consumer privacy and requests comments on best practices available in the industry.”
• Operational period (p.36)
  • Charging infrastructure must operate for at least 5 years (Section 680.106(i))
  • 5 years was chosen to provide a reasonable useful life while providing sensitivity to the changing landscape of charging standards/expectations and tech developments
• Workforce concerns (p.36/37/38)
  • Installation and maintenance must be done safely by a skilled workforce with appropriate licensing, certification, and training.
  • Workforce used should be diverse.
  • With exception of apprentices, all electricians installing, maintaining, and operating EVSE must be certified through the Electric Vehicle Infrastructure Training Program (EVITP)
    • The participant in the program must provide documentation of a minimum of 8,000 hours of hands-on electric construction experience
    • https://evitp.org/
    • FHWA is aware of industry concerns with EVITP:
      • It being the sole provider might serve to privatize the licensing process or impose a hurdle to obtaining electricians
      • To address this, States can meet this requirement through another Registered Electrical Apprenticeship program that includes EVSE-specific training
    • For projects with more than one electrician, at least one must be an apprentice in a registered electrical apprenticeship program – Section 680.106(j)
  • “FHWA recommends that States take proactive steps to work with training providers, workforce boards, labor unions, and other worker organizations, community-based organizations, and non-profits to build a local workforce that will support the EV network”
  • Funding sources for such programs can be found at https://www.fhwa.dot.gov/environment/alternative_fuel_corridors/resources/ev_funding_report_2021.pdf
  • States should also consider how disadvantaged communities will benefit from added job growth
• Station customer feedback requirements (p.39)
  • Stations must allow for customers to report outages, malfunctions, and other issues
  • These reporting mechanisms must be accessible and equitable in accordance with ADA
  • FHWA requests comments on customer service strategies to enter issues as part of the real-time status data outlined in Section 680.116(c)
• Traffic control devices and signage (p.42)
  • Requirements are set by existing regulations in 23 CFR part 655 and 23 CFR part 750 for NEVI Formula Program projects
  • Manual on Uniform Traffic Control Devices (MUTCD) is currently being updated (updates due in September, 2022?)
  • Section 680.110