NAFA Urges States to Consider Public Fleets in EVSE Plans

The Ceres Corporate Electric Vehicle Alliance and NAFA Fleet Management Association teamed up to send a letter to state departments of transportation, urging officials to strongly consider commercial and public fleets in their plans for electric vehicle supply equipment (EVSE) in their respective states.

In February, the Federal Highway Administration (FHWA) issued the final minimum standards for the National Electric Vehicle Infrastructure (NEVI) Formula Program that will provide funding and guidance to states for the build-out of cost-effective, equitable, and reliable electric vehicle (EV) infrastructure.

'Merely a Baseline for Success'

Together, the Ceres and NAFA coalition is made up of 32 major companies and fleet operators that represent over $1.1 trillion in annual revenue and collectively own, lease, or operate more than 2.5 million fleet or networked vehicles. The April 20 letter is a follow-up to Ceres and NAFA's July 2022 letter. In the new letter, the organizations reminded states that the final NEVI standards are, "merely a baseline for success," for both publicly- and privately-funded infrastructure.

The Ceres Corporate Electric Vehicle Alliance members plan to collectively procure more than 330,000 zero emission vehicles (ZEVs) in the U.S. market. Additionally, the letter states that NAFA members support the accelerated transition to EVs as a critical part of the strategy for sustainability and the reduction of vehicle emissions.

What the Organizations Are Asking For

A Ceres Alliance survey found that the majority of vehicle charging for the 330,000+ ZEVs will take place at private locations — 26% at fleet depots and 42% at employee homes. However, on-road charging will account for the remaining 32% of charging needs. The organizations wrote that the on-road charging is critical for regional and long-haul freight movement, and fleet movement within urban, suburban and rural areas.

The organizations called the NEVI Formula Program charging stations a "promising step towards widespread charging availability in the U.S.," but said there is much more to be done to create a cost-effective, equitable, and resilient charging network for commercial and public fleets.

The organizations pointed to NAFA's 2022 Charging Infrastructure Recommendations as a source of guidance for states as they work to invest funding from the NEVI Formula Program. They also encouraged eligible public and tribal governments within states to take advantage of funding opportunities offered under the Charging and Fueling Infrastructure (CFI) Discretionary Grant Program, which provides $700 million in the current round of funding to help public and tribal entitites address regional EV charging system gaps and deploy charging infrastructure in communities and along corridors most impacted by transportation emissions.

Don't Forget About Medium- and Heavy-Duty Vehicles

The final NEVI standards don't include specific requirements to support the charging of medium- and heavy-duty vehicles (MHDVs). However, while these vehicles represent only 5% of the vehicles on the road, they currently account for 21% of transportation greenhouse gas emissions and are, "therefore critical levers in improving public health and reducing transportation emissions," the organizations wrote.

They also pointed out that MHDVs typically run on diesel fuel, which is the top source for criteria pollutants like nitrogen oxides (NOx) and PM2.5 that are threatening to human health.

"These emissions disproportionally impact the health of traditionally low-income and BIPOC communities situated near fleet depots, major transportation corridors, distribution centers, and ports," the letter stated.

CERES and NAFA are calling for states to incorporate provisions that support the charging of MHDVs in future NEVI State Deployment Plans and in all other siting plans for new charging infrastructure.

According to the American Lung Association’s 2022 State of the Air report, a national shift to 100% zero-emission passenger vehicles by 2035 and 100% medium- and heavy-duty trucks by 2040 would generate over $1.2 trillion in public health benefits between 2020 and 2050.