Date: May 23, 2022
To:
The Honorable Jennifer Granholm
U.S. Secretary of Energy
The Honorable Pete Buttigieg
U.S. Secretary of Transportation
Dear Secretaries Granholm and Buttigieg,
The undersigned companies and organizations share a common goal: reducing greenhouse gas (GHG) and air emissions by electrifying our transportation system. We greatly appreciate President Biden's efforts to accelerate this process – especially given his leadership in passage of the Bipartisan Infrastructure Law (BIL). The BIL includes an historic investment in charging infrastructure that has the potential to advance this urgently necessary transition.
Much of the discussion around this investment has understandably focused on charging infrastructure for light-duty vehicles. After all, that’s the class of vehicles most Americans drive. But while heavy-duty vehicles make up only 10 percent of all vehicles on roads in the United States, they contribute 45 percent of the transportation sector’s nitrogen oxide pollution, 57 percent of its fine particulate matter pollution, and 28 percent of its global warming emissions.1 The pollution from these vehicles disproportionately impacts low-income and underserved communities.
Fortunately, electrifying medium- and heavy-duty vehicles (MHDV) is already economical in many cases, with the list of cost-effective use cases growing by the day. Access to charging, on the other hand, remains a significant barrier to adoption.
Most public EV charging infrastructure has been designed and built with passenger vehicles in mind. The size and location of spaces reflect an interest in servicing the driving public, not larger commercial vehicles.
If America’s MHDV fleet is to go electric, the charging infrastructure built under the BIL will need to take its unique needs into account. As the Biden Administration drafts guidelines, standards and requirements for EV infrastructure paid for by the BIL, we ask that they encourage states to develop charging infrastructure designed to service MHDVs. More specifically, we ask that at least ten percent of the funding included in the BIL’s Section 11401 Grants for Fueling and Infrastructure Program be spent on charging infrastructure designed to service MHDV – both along designated alternative fueling corridors and within communities. This includes public charging infrastructure to service vehicles and businesses located within and operating within disadvantaged and frontline communities, as appropriate.
We have heard stories from dozens of businesses large and small that charging is a major barrier to electrifying their fleets. Charging stations built and designed for larger vehicles and commercial customers will unlock electrification for vehicle classes that can disproportionately emit GHG emissions and harmful air pollutants in front-line communities. School districts will be able to expand the use of electric school buses funded by the BIL, and meet more needs for students, if charging for larger vehicle classes is found along routes for school events, like sports, music competitions, or field trips. These benefits are unlikely to be realized unless there is an intentional and concerted effort to bring them about in line with the President’s “Build Once” goals. We need to plan for MHDVs up front. Failure to do so will unnecessarily limit the impact of this historic infrastructure investment.
We applaud the President’s leadership in advancing the BIL and encourage the Departments of Energy (DOE) and Transportation (DOT) through the Joint Office of Energy and Transportation to make the most of the unprecedented investment in charging infrastructure that the BIL has made possible. Inherent in that goal is the need to fund infrastructure to serve all classes of vehicles.
Thank you for your thoughtful consideration of our requests. We will follow up with your staff directly to request a meeting to discuss these important topics.
Arrival
Amply Power
Environmental Defense Fund
CALSTART
Earthjustice
Elders Climate Coalition
Electrada
Environmental Law and Policy Center
Green Latinos
International Parking and Mobility Institute
Lightning eMotors
The Lion Electric Co. USA Inc.
Moms Clean Air Force
Panasonic North America
Proterra
Sierra Club
Tesla
Vicinity Motor Corp
1 https://www.ucsusa.org/sites/default/files/2019-12/ReadyforWorkFullReport.pdf