Dear Secretary Buttigieg:
As the Federal Highway Administration (FHWA) implements the new clean charging and fueling programs created by the Infrastructure Investment and Jobs Act (IIJA), we write to urge you to prioritize investments in clean technologies that leverage existing state and local programs to significantly improve air quality in underserved communities.
If targeted appropriately, these "Clean Corridor" programs can make a significant difference in reducing greenhouse gas emissions and hazardous air pollutants, especially along the goods-movement corridors where the nearby communities face a disproportionate air pollution burden. We hope that you will consider the funding and guidance provided by the IIJA to be a floor, and not a ceiling, in that ambitious and important effort.
Specifically, we urge you to consider the following factors as you design and issue guidance:
Priority should be given to charging or fueling locations in goods-movement corridors, locations serving first- and last-mile freight near ports and freight hubs, and locations that optimize infrastructure networks and reduce hazardous air pollutants in communities disproportionately impacted by such pollutants. To inform that prioritization, FHWA should seek information on the following topics when requesting and reviewing proposals for charging and fueling locations:
Transportation activity (including commercial, port, and general transportation) that would be supported by the project proposal, including analysis in previously completed planning studies;
Estimated reductions in criteria pollutants, air toxics, and greenhouse gases;
Socioeconomic and pollution burden characteristics of communities in and around the proposed project;
Discussion of potential economic and health benefits in communities in and around the proposed project; and
The extent to which the proposed project supports local and regional air quality needs.
FHWA should reward proposals that leverage existing state and local programs and investment, and that reflect community participation and inclusion.
Preference should be given to projects located in, or supporting the transportation needs of, previously underserved and underinvested communities and in communities that suffer from a high pollution burden and/or are overexposed to toxic air pollution.
Preference should be given to applicants with previous experience in administering charging and fueling infrastructure projects or to those who partner with a more experienced provider. Experienced providers are best able to navigate project implementation and maintenance and deliver reliable operations to ensure quality, affordable, reliable, and easy-to-use infrastructure, which will be key to the ultimate success of these programs.
Projects should prioritize the cleanest technologies so as not to expand the use of extracted fossil fuels.
Thank you for your consideration of our comments, and we look forward to working with you as these programs are implemented.