Docket No. FHWA-2025-0070 RE: International Council on Clean Transportation (ICCT) comments on the Federal Highway Administration (FHWA) Proposed Modification of the 2023 Waiver of Buy America Requirements for Electric Vehicle (EV) Chargers Dear Administrator McMaster, The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the Federal Highway Administration (FHWA)’s Proposed Modification of the 2023 Waiver of Buy America Requirements for Electric Vehicle (EV) Chargers. The ICCT is an independent, nonprofit organization founded to provide world-class research and technical analysis to governments in major vehicle markets worldwide. Our mission is to improve the environmental performance and energy efficiency of road, marine, and air transportation in order to benefit public health and mitigate climate change.
We are concerned with the proposed modifications to the Waiver of Buy America Requirements for Electric Vehicle (EV) Chargers. The proposal risks undermining federal-aid highway projects, specifically the National Electric Vehicle Infrastructure (NEVI) Formula Program, which aims to support a reliable, interconnected, and equitable nationwide EV charging network, as well as the Charging and Fueling Infrastructure (CFI) Grant Program, which prioritizes charging deployment in low-income, underserved, rural, and high-density neighborhoods. Both programs are designed to support the strategic expansion of publicly accessible EV charging across the United States
.1 While strengthening domestic charger manufacturing is a widely supported goal, the proposed abrupt and significant tightening domestic content requirements from 55% to 100% of the cost of all components is inconsistent with the objectives of the NEVI and CFI programs and would negatively impact U.S. consumers, state governments, and industry. At a time when states are scaling implementation, immediate changes without similar immediate investment in (....)