New FHWA standards for EV charging funds

[Autolycus]

For the super nerdy people in the room, here's the FHWA minimum standard rule for NEVI and other federal funds:

https://www.fhwa.dot.gov/environment/nevi/resources/ev_charging_min_std_rule_fr.pdf

And here are some news stories from the Joint Office, including the one about the new rule as well as some related announcements about efforts from different charging networks:

https://driveelectric.gov/news/#private-investment

The partnerships with Travel Centers of America and Pilot-Flying J with EA and EVGo are the ones I'm really excited to see. They show a very clear shift in thinking by major gas-oriented businesses.

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[Marchin_MTB]

For the super nerdy people in the room, here's the FHWA minimum standard rule for NEVI and other federal funds:

https://www.fhwa.dot.gov/environment/nevi/resources/ev_charging_min_std_rule_fr.pdf

And here are some news stories from the Joint Office, including the one about the new rule as well as some related announcements about efforts from different charging networks:

https://driveelectric.gov/news/#private-investment

The partnerships with Travel Centers of America and Pilot-Flying J with EA and EVGo are the ones I'm really excited to see. They show a very clear shift in thinking by major gas-oriented businesses.

thanks! I’ll take a look tonight. Anything in there about how uptime has to be defined?

 

[Autolycus]

thanks! I’ll take a look tonight. Anything in there about how uptime has to be defined?

Haven't gotten there yet. The summary of the requirements starts on page 18. Dog walk is going to intervene before I read those and the actual textual requirements. Will probably try to mention my highlights later tonight.

Edit to add: Final Rule itself begins on page 122, for those who like to read the actual regulatory requirement instead of proposals, explanations, summaries, and public comments on the NPRM.

 

[Autolycus]

thanks! I’ll take a look tonight. Anything in there about how uptime has to be defined?

Ugg... I'm a nerd. Dog has to wait...

680.116(b) (emphasis added):

(b) Minimum Uptime. States or other direct recipients must ensure that each charging port has an average annual uptime of greater than 97%.
(1) A charging port is considered “up” when its hardware and software are both online and available for use, or in use, and the charging port successfully dispenses electricity in accordance with requirements for minimum power level (see § 680.106(d)).
(2) Charging port uptime must be calculated on a monthly basis for the previous twelve months.
(3) Charging port uptime percentage must be calculated using the following equation:
μ= ((525,600 - (T_outage - T_excluded ))/525,600) X 100
where:
μ = port uptime percentage,
T_outage = total minutes of outage in previous year, and
T_excluded = total minutes of outage in previous year caused by the following reasons outside the charging station operator’s control, provided that the charging station operator can demonstrate that the charging port would otherwise be operational: electric utility service interruptions, failure to charge or meet the EV charging customer’s expectation for power delivery due to the fault of the vehicle, scheduled maintenance, vandalism, or natural disasters. Also excluded are hours outside of the identified hours of operation of the charging station.

(b)(1) is a critical requirement!!! So if it doesn't dispense at least 150kW (at 250-920V), it isn't "up".

 

[Marchin_MTB]

Ugg... I'm a nerd. Dog has to wait...

680.116(b) (emphasis added):

(b)(1) is a critical requirement!!! So if it doesn't dispense at least 150kW (at 250-920V), it isn't "up".

Thank you for digging that up! That is big step in the right direction. Of course, companies can still play games with the T_excluded variable by blaming downtime on the utility but at least they can’t report the station as up if it’s not dispensing power (that’s my interpretation anyway).

 

[MrMetlHed]

I also like this bit

§ 680.116 Information on publicly available electric vehicle charging infrastructure
locations, pricing, real time availability, and accessibility through mapping.

on page 139. A lot of info about the charger needs to be made publicly available via API. Including things like geolocation, real-time status, pricing, whether or not a vehicle with a trailer can access it, and more.

Will make it much easier for 3rd party apps to include all charging station info.

 

[zefram47]

Very interesting and thanks for posting! A big one that concerns everyone with a 400V class vehicle is how they define 150 kW minimum power spec. On page 59 they specify 375A minimum over 250-920V, yielding 150 kW at 400V. So that's good news.

Now we shouldn't see any new chargers like the ChargePoint CPE250 only coming with 200A cables. In those units you'll see all over Colorado and Utah (many others) they're labeled as 125 kW Shared, but a lone 400V class vehicle will only be able to get around 80 kW from one because of the current limitation.

 

[NY_Rob]

thanks! I’ll take a look tonight. Anything in there about how uptime has to be defined?

That particular metric will be very difficult to monitor.. remember when Kyle visited all those brand new EA chargers during a recent cold spell in CO? Every one of the new chargers at multiple sites he visited that night errored out at the physical locations yet the EA app showed them as up.

 

[Autolycus]

Very interesting and thanks for posting! A big one that concerns everyone with a 400V class vehicle is how they define 150 kW minimum power spec. On page 59 they specify 375A minimum over 250-920V, yielding 150 kW at 400V. So that's good news.

375A-rated connections is a suggestion, not a requirement. The enforceable requirements are only the text of the final regulation, which starts on page 122.

 

[Autolycus]

Some highlights as I read the actual reg itself, as opposed to all the APA requirements published alongside it.

Some definitions with good information:

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Contactless Payment Methods means a secure method for consumers to purchase services using a debit card, credit card, smartcard, mobile application, or another payment device by using radio frequency identification (RFID) technology and near-field communication (NFC).​

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Important that "mobile application" is an acceptable form of contactless payment. Tesla's got to be happy about that, since their stations have no screen or payment method.

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Plug and Charge means a method of initiating charging, whereby an EV charging customer plugs a connector into their vehicle and their identity is authenticated through digital certificates defined by ISO-15118, a charging session initiates, and a payment is transacted automatically, without any other customer actions required at the point of use.​

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ISO-15118 is the obvious choice, but it's good that it's written into the definition of plug and charge.

§ 680.106 Installation, operation, and maintenance by qualified technicians of electric vehicle charging infrastructure.

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(b) Number of Charging Ports. (1) When including DCFCs located along and​

designed to serve users of designated AFCs, charging stations must have at least four network-connected DCFC charging ports and be capable of simultaneously charging at least four EVs. (2) In other locations, EV charging stations must have at least four network-connected (either DCFC or AC Level 2 or a combination of DCFC and AC Level 2) charging ports and be capable of simultaneously charging at least four EVs.​

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Anything in an Alternative Fuel Corridor must have 5 DCFC ports. No surprise here. That was the rule before as well.

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(c) Connector Type. All charging connectors must meet applicable industry standards. Each DCFC charging port must be capable of charging any CCS-compliant vehicle and each DCFC charging port must have at least one permanently attached CCS Type 1 connector. In addition, permanently attached CHAdeMO (CHAdeMO) connectors can be provided using only FY2022 NEVI Funds. Each AC Level 2 charging port must have a permanently attached J1772 connector and must charge any J1772- compliant vehicle.​

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CCS is required for any DCFC. Chademo is being ended as a requirement immediately and not eligible for funds after FY2022 funds are spent. J1772 required for any L2 sites that get federal funding from sources other than BIL/NEVI funds. Again, no surprise. Tesla was NEVER going to get funds for its connectors.

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(d) Power Level.​

129​

(1) DCFC charging ports must support output voltages between 250 volts DC and 920 volts DC. DCFCs located along and designed to serve users of designated AFCs must have a continuous power delivery rating of at least 150 kilowatt (kW) and supply power according to an EV’s power delivery request up to 150 kW, simultaneously from each charging port at a charging station. These corridor-serving DCFC charging stations may conduct power sharing so long as each charging port continues to meet an EV’s request for power up to 150 kW.​

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Again, no surprises here. 150kW was the prior requirement. Power sharing is allowed so long as each port always gets at least 150kW. It's a reasonable minimum standard.

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(e) Availability. Charging stations located along and designed to serve users of designated Alternative Fuel Corridors must be available for use and sited at locations physically accessible to the public 24 hours per day, 7 days per week, year-round.​

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Kind of a duh requirement here.

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(f) Payment Methods. Unless charging is permanently provided free of charge to customers, charging stations must:​

(1) Provide for secure payment methods, accessible to persons with disabilities, which at a minimum shall include a contactless payment method that accepts major debit and credit cards, and either an automated toll-free phone number or a short message/messaging system (SMS) that provides the EV charging customer with the option to initiate a charging session and submit payment;​

(2) Not require a membership for use;​

(3) Not delay, limit, or curtail power flow to vehicles on the basis of payment method or membership; and​

(4) Provide access for users that are limited English proficient and accessibility for people with disabilities. Automated toll-free phone numbers and SMS payment options must clearly identify payment access for these populations.​

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A lot in here that's worth reading. Can't have a closed network. Can charge less with a membership, but can't throttle charge rate based on it. So Tesla can't favor Tesla vehicles for charging rate, but can for cost.
"Contactless payment method that accepts major debit and credit cards"... see definition of "contactless payment method" above. I read this as saying an app is fine but it has to take VISA/MC/Amex for payment.

There are some physical and data security requirements. Sites should be well lit, etc.

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(i) Long-Term Stewardship. States or other direct recipients must ensure that chargers are maintained in compliance with this part for a period of not less than 5 years from the initial date of operation.​

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Sites have to meet all of these requirements for at least 5 years.

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(k) Customer Service. States or other direct recipients must ensure that EV charging customers have mechanisms to report outages, malfunctions, and other issues with charging infrastructure. Charging station operators must enable access to accessible platforms that provide multilingual services. States or other direct recipients must comply with the American with Disabilities Act of 1990 requirements and multilingual access when creating reporting mechanisms.​

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Gotta have customer service available to report outages and problems. I think all of the networks have those already, but maybe there are some that don't? There aren't any specific requirements, which might be a shame. 24/7 should be required.

§ 680.108 Interoperability of electric vehicle charging infrastructure.

Some others might want to look at this more closely than I will now. It starts on page 134 at the bottom.

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(a) Charger-to-EV Communication. Chargers must conform to ISO 15118-3 and must have hardware capable of implementing both ISO 15118-2 and ISO 15118-20. By [INSERT DATE ONE YEAR AFTER DATE OF PUBLICATION IN THE FEDERAL​

134​

REGISTER], charger software must conform to ISO 15118-2 and be capable of Plug and Charge. Conformance testing for charger software and hardware should follow ISO 15118-4 and ISO 15118-5, respectively.​

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Again, no surprise that the ISO standard is required for charger-to-EV comms, including plug and charge.

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(d) Network Switching Capability. Chargers must be designed to securely switch charging network providers without any changes to hardware.​

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This one is interesting. So if Travel Centers of America buy EA chargers and their deal with EA for maintenance, etc. runs out, their EA charger must be capable of being switched to EVGo, for instance?

§ 680.112 Data submittal.
Starts on bottom of page 135. Lots of specific quarterly and annual reporting.

§ 680.114 Charging network connectivity of electric vehicle charging infrastructure.
Some more requirements for connectivity and communications.

§ 680.116 Information on publicly available electric vehicle charging infrastructure locations, pricing, real time availability, and accessibility through mapping

Price has to be given before a charge session and cannot change during a session.

Minimum uptime requirements posted earlier in this thread.

Data sharing with other apps through an API mentioned above in thread. Starts on p. 141. Plugshare and ABRP will really appreciate this data, but so will all of the vehicle manufacturers. Rivian, Tesla, GM, etc. should eventually all be able to route to any charger out there. I hope they're smart about allowing a variety of user filters, prioritizing charge rate/price/etc..

 

[Marchin_MTB]

I still need to look through this but I hope they specify something for enforcement and fines and I also hope that this has teeth.


The problem (one of the problems?) with most public DCFC providers is that their business model seems half-baked. Hoping for continued investment from automakers and/or the government may not be sufficient. Consequently the product/service provided isn’t good. I haven't been stranded by a DCFC station yet (though some came pretty close) but I also wouldn’t describe most of those as “good experiences”.

For most people, 95% or so of all charging should be happening on L2 and we should be building out that (affordable) capability for apartments and condos and continue to encourage folks to install L2 at home.

For the small remainder of trips that require long distance, I would be willing to pay 50-100% more than the current DCFC $/kWh rates provided that (a) the reliability is MUCH better meaning I get the charging rate that my vehicle requests and I don’t need to reposition twice in the middle of a packed Sam’s parking lot, and (b) the location makes sense and is well lit, safe, with some kind of amenity (shade and a playground for the kids would be nice, also not being in the middle of a busy Sam’s parking lot). and (c) there are more than two to four stalls so any wait time, if it occurs, is reasonable.

I know that increasing costs is not a popular stance. “Aha!”, say the click bait crew, “charging EVs is more expensive per mile than gasoline, see?”. No, a small portion of charging may be more expensive. The vast majority of charging that anyone does (L2) is still less expensive. The point I’m arguing is that DCFC probably needs to be more expensive so that it can grow into an actual business.

Also, enforcement of these uptime and performance requirements needs to step up. The regulations and incentives are a step in the right direction for sure. They are a necessary but not sufficient part of the bigger picture though.

 

[Marchin_MTB]

Sounds to me like they don’t have it all quite figured out yet:

“The FHWA also acknowledges that enforcement of the uptime requirement will be complex; however, in contrast to a recommendation in the comments, FHWA does not see sufficient benefit in delaying the uptime requirement as uptime is a key complaint received regarding those chargers existing prior to the implementation of this final rule. The FHWA would prefer to immediately implement this important regulation, acknowledging that enforcement techniques will evolve over time”

Also interesting to see that uptime is defined per port, not per station (p 111). Which is the right way to go.

 

[Autolycus]

Sounds to me like they don’t have it all quite figured out yet:

“The FHWA also acknowledges that enforcement of the uptime requirement will be complex; however, in contrast to a recommendation in the comments, FHWA does not see sufficient benefit in delaying the uptime requirement as uptime is a key complaint received regarding those chargers existing prior to the implementation of this final rule. The FHWA would prefer to immediately implement this important regulation, acknowledging that enforcement techniques will evolve over time”

Also interesting to see that uptime is defined per port, not per station (p 111). Which is the right way to go.

Yeah, I think they had the right approach here. Getting into the specific enforcement mechanisms in the reg could have delayed the reg.

Absolutely agree that per port average uptime is the right standard. That means a 4-port station can have a total of just 44 days downtime across all ports per 365 days.

 

[atebit]

So roughly, a port must suffer less than 11 days of downtime/year (< 263 hours). Would be nice if there was an additional requirement/penalty around an entire location being down. Having to queue up for a port because n of m are down is an inconvenience; getting stranded at a location because all m are down is dangerous.

 

[Dark-Fx]

This one is interesting. So if Travel Centers of America buy EA chargers and their deal with EA for maintenance, etc. runs out, their EA charger must be capable of being switched to EVGo, for instance?

This argument makes sense from a political perspective, but from a technical perspective it's a disaster. I suspect it's trying to protect against the fear of a particular provider going under and still being able to manage the site without them.

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