Arizona Department of Transportation
1655 W. Jackson Street
Phoenix, AZ 85007
Director Halikowski and ADOT Staff,
On behalf of the Arizona Solar Energy Industries Association (AriSEIA), Solar United Neighbors (SUN), and Vote Solar, we write to thank ADOT for crafting and submitting the National Electric Vehicle Infrastructure (NEVI) Formula Program plan for Arizona.
Our organizations would like to express our enthusiastic support for the NEVI program. Electrification of the energy sector, including electric vehicles (EVs), is critical to maximize the benefits of clean energy technologies, reduce pollution, and build a more reliable and affordable grid. Each of our organizations have been thoroughly engaged in developing electrification policy. AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. AriSEIA also advocates for sustainable job creation and encourages utilization of Arizona’s greatest natural resource, the sun. SUN represents solar homeowners, many of whom are also electric vehicle owners or enthusiasts, as they endeavor to install rooftop solar. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar is also working to remove regulatory barriers and implement key policies needed to bring solar to scale.
We applaud your department for its vision and for seizing this opportunity to secure $76.5 million in funding for Arizona to build out electric vehicle infrastructure in the state. It is critical to develop Electric Vehicle Supply Equipment (EVSE) along interstate corridors over the next five years for Arizona to reach a clean energy future and to promote quality of life for our residents and businesses. Expanding a strategic network of alternative fuel and charging infrastructure and increasing EV accessibility will accelerate the adoption of electric vehicles, making them more convenient, affordable, and reliable for Arizonans. Building out EV infrastructure will result in a number of significant economic and environmental benefits for Arizona. This includes reducing air pollution from the transportation sector, creating new family-sustaining jobs, boosting the economy, and lowering costs at the fuel pump for Arizonans across the state. In sum, we are grateful to see how the NEVI plan will support the building of a resilient, equitable, accessible, and reliable charging network for Arizonans.
Going forward, we provide the following recommendations for ADOT’s consideration to improve the affordability and accessibility of Arizona's transition to clean energy vehicles. The growth of EV charging infrastructure will increase electricity usage, and so it is important to simultaneously invest in distributed energy resources in order to mitigate the need to build additional energy infrastructure. Investments in locally sited solar and storage not only contribute to meeting local energy needs, but improve the resiliency of the grid. It is important that ADOT encourages EVSE owners to set price structures that incentivize the charging of vehicles during off-peak hours. Charging during times when electricity is less expensive will reduce overall costs. We would like to see ADOT require EVSE owners to establish a communication system that allows drivers to opt-in and notify the EVSE owner when a system is down so that issues can be fixed with little to no delay. Lastly, ADOT should prioritize the needs of current EV drivers and traditionally underserved communities when making decisions about where EVSE should be sited. We encourage ADOT to continue engaging stakeholders and the public in regular conversations and outreach available in both English and Spanish throughout the implementation of the plan.
Now more than ever, Arizona should take significant steps to capitalize on the momentum behind the growth of electric vehicles. Each of our organizations are eager to see the swift implementation of ADOT’s NEVI Plan.
Arizona Solar Energy Industries Association (AriSEIA)
Western Region Director
Solar United Neighbors (SUN)
Interior West Regulatory Director
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