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EV Charging Needs to Include Micromobility

The Federal Highway Administration is currently seeking comments as they develop guidance on EV charging policy. The recently passed Bipartisan Infrastructure Law included $7.5 billion for EV charging and re:Charge-e recommends charging for electric micromobility be included. Our detailed comments are below:


re:Charge-e Recommendations for the Federal Highway Administration’s Electric Vehicle (EV) Charging Program (Docket FHWA-2021-0022) Submitted 1/13/22


Introduction

Combating climate change through the reduction of greenhouse gas emissions is the most important environmental challenge of our time. In the US nearly 30% of all greenhouse gas emissions, the key driver of a warming climate, come from the transportation sector. To reach the Biden Administration’s goal of net zero carbon emissions by 2050, the US needs to transform its transportation system away from the use of fossil fuels and towards electric vehicles powered by renewable energy sources. We believe the Infrastructure Investment and Jobs Act (IIJA) will accelerate the electrification of transportation by providing the resources necessary to build networks of electric vehicle charging stations throughout the US. To be successful, this effort must include all forms of electric vehicles, including bicycles, scooters and other types of micromobility. This would provide the infrastructure needed to equitably support a large-scale transformation to electric vehicles. We applaud the Biden Administration for these efforts.


However, at re:Charge-e we are increasingly concerned that an over-reliance on the electrification of exclusively cars, trucks and buses as a solution to the climate crisis is drawing attention, and funding, away from more energy-efficient and equitable modes of transportation such as walking, biking, and active mobility. While electric cars, trucks and buses indeed have some environmental benefits, they still possess many of the negative externalities associated with typical standard ICE vehicles, including impacts on roadway safety, contributions to sprawl development, inefficient allocation of the public right of way, lost productivity due to traffic congestion, and many more. And while greenhouse gas emissions from EV powertrains may be eliminated, the particulate matter generated by tire wear and vehicle braking may be greater in heavier EVs thus contributing to poorer air quality, especially in lower income communities which are more likely to be located closer to highways.


To be clear, re:Charge-e believes the electrification of cars, trucks and buses is critical to combating climate change. But we also firmly believe in the power of electric micromobility (both shared and privately owned) to transform cities, promote physical activity, and confront issues of equity, while addressing greenhouse gas emissions at the same time. For every electric car that is charged, more than 100 electric bicycles and scooters can be made available using the same amount of energy. We simply cannot afford to exclude all of those potential climate-friendly trips from the electrification of transportation because we didn't see this significant opportunity. It is essential that the infrastructure for charging micromobility vehicles such as e-bikes and e-scooters needs to be created alongside, and as a complement to, the charging infrastructure for cars, trucks and buses. This will be the focus of our comments below. Our recommendations for the FHWA EV charging program are as follows:


Expand Definition of Electric Vehicles to Include Electric Micromobility (Consideration #8)

We believe any interconnected network of charging infrastructure should be multimodal and also serve electric micromobility vehicles. While to our knowledge there is currently no all-in-one solution that charges both electric cars/trucks and micromobility, federal policy and funding could drive market innovation and thus accelerate the transition toward electric micromobility vehicles for transportation, recreation and last mile cargo delivery. It certainly should not exclude electric bicycles, scooters and other micromobility devices, and the best way to provide a level playing field is to include micromobility in the IIJA’s definition of electric vehicles.


Allow Community Grant Funding to Be Used to Electrify Micromobility (Consideration #4)

While charging stations for electric micromobility vehicles may not seem appropriate along the interstate highway system or along Alternative Fuel Corridors, the IIJA does allocate funding for community-based programs where such multimodal charging solutions might be a better fit. However, federal policy should recognize car ownership is frequently lower in communities of concern, and current electric vehicles cost more than their ICE counterparts, placing them out of reach to the less affluent. Already, lower income households spend a greater percentage of their income on transportation, so higher vehicle and fuel costs (public charging of EVs is more expensive than home charging) could exacerbate existing inequities. Funding through the community grant program of the IIJA, which allows EV charging infrastructure to be installed outside of designated Alternative Fuel Corridors, could be used to either provide charging infrastructure for ebikes and escooters, or to help electrify shared mobility programs already in place. FHWA should be clear that charging stations for electric micromobility stations are fundable projects and issue such guidance to the states.


Establish EV and LEV Charging Stations Along Multi-useTrails and in National Parks/Federal Public Lands (Consideration #s 3, 4) Under the IIJA, the Secretary of Transportation is granted authority to establish designated national electric vehicle charging corridors as recommended by the individual states, territories and districts. As multi-use trails are increasingly popular and frequently serve commuting purposes, re:Charge-e believes the FHWA should allow states to designate recreational trails Alternative Fuel Corridors. If necessary, the Administrator of the Environmental Protection Agency can designate ebikes and escooters as “alternative fuel vehicles” through authority granted in 49 USC 13211. This would allow EV and LEV charging stations to be installed at key trail access points. We also believe roads in the National Park system should receive a similar designation by the Secretary of the Interior to promote the use of electric transportation, including electric bikes and scooters, in parks.


Expand Definition of “Interconnected Networks” (Consideration #1)

It is clear that for the widespread adoption of electric vehicles to take hold, vehicle owners need to be certain of their ability to charge their vehicles when needed. Similar concerns over “range anxiety” exist for the users of electric micromobility, who currently rely on home- or work-based charging since there are no publicly available charging stations to charge their vehicles. Interconnected networks of EV charging stations for electric micromobility vehicles should be encouraged in more urban areas, where travel distances are comparatively short and commuting by electric bike or scooter is more common. As with our recommendation to broaden the electric vehicles to include electric bikes and scooters, so too should the definition of “network” evolve to encompass more dense and localized charging stations for electric micromobility.


Ensure the Interests of Electric Micromobility and Non-Motorized Modes are Represented on the Electric Vehicle Working Group (Consideration #11) The Electric Vehicle Working Group is established by section 25006 of the IIJA. Stakeholder slots designated for “an owner, operator, or manufacturer of electric vehicle charging equipment” should include representatives of companies which provide charging systems for electric micromobility. A new stakeholder representative should be created for representatives from the electric bicycle and scooter industry or its advocates (ebike sales were double electric car sales in 2020). While this group is not specified by the IIJA legislation, the Secretaries of Transportation and Energy are given the authority to add other stakeholders as they see fit. As many electric vehicles are larger, heavier and quieter than a similar ICE vehicle, concerns about safety for the non-motoring public are of paramount concern. This role could also ensure the safety interests of cyclists, pedestrians, and people with disabilities are given a voice in EV policy development.

Conclusion

re:Charge-e believes electric micromobility has the potential to significantly reduce the impact of transportation on climate change and equity and should be supported by the Administration’s EV charging policy. By incorporating electric micromobility charging infrastructure into the plans for EV charging along federal aid highways, along multi-use trails, in national parks, and as part of localized infrastructure efforts lower income areas, the FHWA can further encourage the use of a energy-efficient, equitable and climate-friendly mode of travel, while helping to build healthy communities. Thank you for the opportunity to comment on this important issue.

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