December 9, 2022
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The American Association of State Highway and Transportation Officials sent a five-page letter on September 29 to the Federal Highway Administration detailing concerns regarding the agency’s “Buy America” waiver proposed for electric vehicle or EV charging system materials at the end of August.

[Above photo by the Oregon DOT]

“States have significant concerns regarding the readiness of industry … and the tremendous potential near-term negative impact on the deployment of EV charging infrastructure across the country,” AASHTO said in its letter.

Image by AASHTO

“AASHTO asserts that it is in the public interest that EV infrastructure deployment not be delayed unnecessarily while industry makes good-faith efforts to integrate the new ‘Buy America’ requirements into their sourcing and manufacturing processes,” the organization said. “Given the desire to deploy EV infrastructure quickly and the anticipated significant increase in demand for EV chargers, an extension of the blanket waiver for manufactured products including EV charging equipment for a minimum of two years is needed.”

AASHTO said that the “practical ability” of the country’s domestic manufacturing industry to make changes to supply chains and to source American-made EV charger components would take longer than FHWA’s proposed 15-month transition period permits.

Photo by the Oregon DOT

“While the phased approach to compliance – starting with final assembly in the U.S. and progressing upward in the percentage of American-made components – appears to be reasonable, the proposed transition timeline is not achievable and will have detrimental impacts on the deployment of EV charging infrastructure,” the organization said.

“A rushed transition to the new requirements will exacerbate delays and increase costs if EV charging equipment providers are forced to abruptly shift component sourcing to domestic suppliers, who in turn may struggle with availability due to limited quantities and high demand,” AASHTO stressed.

That is why the organization is calling for a two-year delay to the implementation of “Buy America” rules for EV chargers and related infrastructure.  AASHTO also seeks FHWA’s help in conducting a “robust” market research effort to map out supply and demand issues at the national level, allowing for improved forecasting of the potential impact of new Buy America requirements on EV charger availability.

“AASHTO and the state DOTs greatly appreciate the opportunity to provide input on the implementation of new Buy America requirements on EV charging infrastructure,” the group concluded. “We encourage FHWA to carefully consider the input provided herein, as well as in the detailed comments submitted by individual states and industry members.”

editor@aashto.org

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