Letter to Pete Buttigieg, Secretary of Transportation, Alan Davidson, Assistant Secretary of Commerce for Communications and Information, Jennifer Granholm, Secretary of Energy - Matsui, Eshoo Lead Effort to Co-locate Broadband and Ev Charging Infrastructure

Letter

Dear Secretary Buttigieg, Assistant Secretary Davidson, and Secretary Granholm,

The Infrastructure Investment and Jobs Act (IIJA) makes transformative investments in electric vehicle (EV) charging infrastructure and will help meet the Administration's critical goal of 500,000 chargers by 2030 to ensure that EVs are accessible to all Americans. As federal agencies, states, and relevant stakeholders develop plans for a robust electric vehicle (EV) charging network across the country, we urge you to consider the connectivity requirements for EV supply equipment (EVSE) as well as the benefits of co-locating EVSE with infrastructure that can also be utilized to deploy broadband.

EV charging access has long been lacking in underserved communities. In 2019, the Department of Energy (DOE) found that 80 percent of EV owners charge in their own homes. Although home chargers are the most used type of chargers in EV adoption, apartment residents are less likely to have access to at-home chargers. This disparity poses a particular challenge to lower-income households and communities of color, who are more likely to live in multi-unit housing. Similar challenges exist in rural areas, where limited electric distribution exacerbates range anxiety, the concern that vehicles will not be able to travel the distance needed. IIJA addresses these equity concerns by including $2.5 billion to support, among other things, rural charging and increase EV charging access in disadvantaged communities. Additionally, IIJA directs $5 billion to the National Electric Vehicle Infrastructure (NEVI) Formula Program, resulting in $7.5 billion to build a national electric vehicle charging network.

In its original guidance, the NEVI Formula Program requires state agencies deploying EVs to have a connected charger network to facilitate data collection, accessibility, and reliability. These connectivity requirements for EV charging infrastructure often require broadband access, which can be sparse in remote areas. To meet the 97 percent reporting standards of the NEVI Formula Program, stakeholders and agencies must address the broadband access challenges in rural and underserved communities.

Digital equity disparities exist in areas where access to broadband is non-existent or unaffordable and disproportionately affects rural areas and communities of color. A Pew Research Center report showed that 34 percent of Black households and 39 percent of Latino households do not have wired broadband connection. In addition to this, the Census Bureau found that 33 percent of Native Americans lack a broadband subscription, and 47 percent of those living on tribal lands lack broadband availability altogether. The IIJA acknowledged these disparities and provided $65 billion for broadband expansion, including grants for internet service expansion in unserved and underserved areas

In light of the national electric vehicle charging network's connectivity requirements, the persistent digital divide, and EV charging infrastructure disparities across the nation, we encourage you to coordinate IIJA broadband and EV charging infrastructure efforts to encourage co-location of EVSE with telecommunications infrastructure when and where appropriate. The IIJA also included strong prevailing wage protections and preferences to ensure federal funding supports high-skilled, well-paying jobs. We urge you to include and build upon these bedrock protections during deployment to maximize meaningful opportunities for American workers. This approach can address multiple national priorities simultaneously and avoid duplicative efforts, maximizing IIJA's wide-reaching equity mission.

We look forward to continuing working with you on IIJA funding implementation and finding holistic equity solutions for communities across the nation.