In March 2022, the Indiana Department of Transportation (INDOT) started a process to plan how the state will spend $100 million in funds allocated for a new public network of Level 3 DC Fast Charge charging stations across the state. Hoosier EVA joined with Solar United Neighbors (SUN), a nonprofit dedicated to helping Hoosiers build a clean, just, and equitable energy system, to submit the following comments in response to INDOT’s initial request for information that will inform their plan on April 29, 2022.
Thank you for this opportunity to provide public input on the Indiana Department of Transportation’s (INDOT) plans for the development of electric vehicle (EV) charging networks within the State of Indiana. On behalf of Solar United Neighbors (SUN), Hoosier Electric Vehicle Association (Hoosier EVA), and more than 4,500 supporters of our two organizations around the state, we are writing to ensure that current and future EV owners who will benefit from this foundational infrastructure investment have a voice in the planning process.
As EV owners and supporters, we wish to provide the following principles for your consideration in the development of our State’s broad EV charging infrastructure plan and in the specific deployment of National Electric Vehicle Infrastructure Formula Program funds available from the Bipartisan Infrastructure Law:
- EV charging is an inherently competitive and innovative market and Indiana’s plan for deploying these valuable public funds should foster an environment that enables and incentivizes continued innovation in the future as the marketplace and technologies continue to develop.
- We support the guidelines for EV charging criteria outlined for alternative fuel corridors as proposed by the Federal Highway Administration. To ensure the EV charging stations supported by these public funds are best located for public use, we suggest the following additional criteria for ideal placement:
-Charging locations should have adequate space and the underlying infrastructure to meet future demand by adding capacity and / or adopting new technologies as EV charging evolves and the EV market continues to grow.
– All locations should be safe, well-lit, and include safe walking paths to nearby shops, restaurants, and other amenities, including clean and well maintained 24/7 restrooms large enough to accommodate extra traffic from EV owners.
- Charging infrastructure should be distributed widely and early investments especially should be placed strategically to ensure that all communities have equal access. Prioritizing planned corridors for early investments should be balanced with clear plans designed to meet the needs of underserved communities in both urban and rural settings.
- Public dollars should only go to infrastructure providers whose networks can cooperate and be accessible to other companies’ networks, ideally those whose networks use the “Open Charge Point Protocol” standards.
- Open payment systems should be required so that a consumer can use a common credit card reader that accepts all payment cards, an agreement to accept another company’s payment card, or a similar solution.
- Charging costs at public stations should be reasonable, transparent, and available in per kWh terms.
- Charging companies and systems should be required to share real-time information about the location of chargers, their availability, and price terms. The public should be able to access this information easily and conveniently.
- Charging station uptime and reliability are critical to the success of the network and should be incentivized. Reliability targets should be set to a high but achievable level, based on what the top performing charging providers, including Tesla, have achieved in the past.
- Charging infrastructure deployment plans should support the use of distributed solar, energy efficiency, and other non-wires alternatives such as battery storage co-located with EV charging infrastructure to minimize overall costs and reduce system-wide burdens from increased electricity demand.
- INDOT and other regulators (including the Indiana Utility Regulatory Commission) should ensure that federal dollars be utilized for EV charger-related power grid upgrades rather than allowing utilities to raise electricity rates on general customers for these purposes.
Thank you again for the opportunity to provide public input into this critical process for planning Indiana’s transportation future. We look forward to further participation in the public input process as appropriate.
| Zach Schalk|
Indiana Program Director
Solar United Neighbors
Hoosier Electric Vehicle Association