State of Arizona

Electric Vehicle
State Plan/State Plan Update for Electric
Vehicle (EV) Infrastructure Deployment Plan
September 27, 2023
Table of Contents
Table of Contents ..................................................................................................................................... i
Revision History....................................................................................................................................... ii
List of Figures .......................................................................................................................................... ii
List of Tables .......................................................................................................................................... iii
Introduction ............................................................................................................................................ 1
State Agency Coordination ...................................................................................................................... 6
Public Engagement .................................................................................................................................. 8
Community Engagement Outcomes Report ........................................................................................... 16
Plan Vision and Goals ............................................................................................................................ 27
Contracting ........................................................................................................................................... 29
Civil Rights ............................................................................................................................................. 34
Existing and Future Conditions Analysis ................................................................................................. 36
Implementation..................................................................................................................................... 94
Equity Considerations .......................................................................................................................... 100
Labor and Workforce Considerations................................................................................................... 105
Physical Security & Cybersecurity ........................................................................................................ 107
Program Evaluation ............................................................................................................................. 109
Appendix A Arizona EV Deployment Plan Exception Request ............................................................A-1
Appendix B Supporting Materials ..................................................................................................... B-1
Appendix C Utility Capacity .............................................................................................................. C-1
Appendix D Cybersecurity Specifications ......................................................................................... D-1
Appendix E Supporting Materials ..................................................................................................... E-1
Endnotes ............................................................................................................................................. 113

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Revision History
Version History Date Revisions
Version 1 8/01/2022 Original
Version 2 9/01/2022 Appendix E: Cyber Security
Specifications added
Version 3 2/07/2023 Appendix C: Utility Capacity,
Appendix D: EV Charging Costs,
and Appendix F: Phase 2 Public
Engagement Summary added
Version 4 8/1/2023 2023 Plan Update
Version 5 9/27/2023 2023 Plan Update with FHWA
Feedback

List of Figures
Figure 1: Arizona National Highway System ........................................................................................... 40
Figure 2: EV Adoption Forecast Methodology Flow Diagram .................................................................. 44
Figure 3: EV Model Availability Forecast ................................................................................................ 45
Figure 4: Expected EV Adoption in Arizona, 2020-2040 Total Registrations ............................................ 48
Figure 5: Expected EV Adoption in Arizona, 2020-2040 by New Sales..................................................... 49
Figure 6: Forecast of EV Battery Energy Consumption............................................................................ 53
Figure 7: Forecasted EV Energy Consumption ........................................................................................ 54
Figure 8: Arizona Alternative Fuel Corridors........................................................................................... 61
Figure 9: Existing Charging Stations on Alternative Fuel Corridors in Arizona ......................................... 72
Figure 10: NEVI Creditable EVSE Stations, Arizona, 2022 - 2023 ............................................................. 78
Figure 11: Discretionary Exemption Requests, 2022-2023...................................................................... 79
Figure 12: Proposed Charging Network, 2022 -2023 .............................................................................. 87
Figure 13: Proposed New AFC Candidates, 2024-2025 ........................................................................... 89

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 List of Tables
Table 1: Invitees to Agency Coordination Meetings, 2023 Plan ................................................................ 6
Table 2: Stakeholder and Public Involvement Activities............................................................................ 9
Table 3: Stakeholders Involved in Plan Development ............................................................................. 10
Table 4: Online Survey Self-ID Results .................................................................................................... 17
Table 5: In-Person Survey Self-ID Results ............................................................................................... 17
Table 6: Descriptor Question Responses ................................................................................................ 17
Table 7: Prioritization Criteria Question Responses ................................................................................ 18
Table 8: Payment Methods Question Responses.................................................................................... 19
Table 9: Online Information Question Responses................................................................................... 19
Table 10: Potential New Additions to the Charging Network .................................................................. 19
Table 11: Advertising Publications, 2023 ................................................................................................ 23
Table 12: 2022 Plan Service Area by Utility ............................................................................................ 25
Table 13: 2023 Plan Service Area by Utility ............................................................................................ 25
Table 14: Contracting Timeline .............................................................................................................. 29
Table 15: Typical EV Technical Specifications ......................................................................................... 36
Table 16: Common EV Connector Types ................................................................................................ 37
Table 17: 2021 AFCs VMT Data .............................................................................................................. 42
Table 18: Arizona Vehicle Registrations by Year ..................................................................................... 43
Table 19: Arizona State Characteristics that Influence EV Adoption ....................................................... 46
Table 20: EV Market Model Growth Scenarios ....................................................................................... 48
Table 21: Expected In-State EV Adoption ............................................................................................... 49
Table 22: AADT of EVs in Arizona, 2021 ................................................................................................. 52
Table 23: Known Risks and Challenges ................................................................................................... 54
Table 24: Arizona AFC ............................................................................................................................ 59
Table 25: Locations of Existing Charging Infrastructure Along AFCs (as of 6/29/2023) ............................ 62
Table 26: Potential Funding Sources ...................................................................................................... 73
Table 27: NEVI Creditable* EVSE Stations, 2022 - 2023 .......................................................................... 76
Table 28: Potential Upgrades and New EVSE Station Locations, 2022 – 2023 ......................................... 81
Table 29: Preliminary List of Proposed New AFC Candidates, 2024-2025 ............................................... 88
Table 30: Arizona EV Policies and Plans.................................................................................................. 91
Table 31: Metrics to Measure Impacts and Benefits to DACs ............................................................... 103
Table 32: Program Evaluation Metrics ................................................................................................. 109

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Introduction
Adopting electric vehicles (EVs) improves air quality and contributes to meeting state and federal
carbon-reduction goals. Because more Arizonans and visitors to the state are driving EVs, the State
is working to incorporate federal funding opportunities into development of infrastructure needed
to support EV drivers. The Arizona Department of Transportation (ADOT), as tasked by the
Bipartisan Infrastructure Law (BIL) and the National Electric Vehicle Infrastructure (NEVI) Formula
Program, has developed Arizona's EV Infrastructure Deployment Plan (Plan), which seeks to increase
the long-range mobility of EV drivers by reducing gaps in electric vehicle supply equipment
infrastructure (EVSE; i.e., an EV charging station) and contributing to an equitable, reliable, resilient,
and accessible national EVSE network.

Funding to support this work was secured in March 2022, and the development of the 2022
Deployment Plan (2022 Plan) commenced in May 2022. This updated 2023 Deployment Plan (2023
Plan) is based on finalized NEVI Formula Program Guidance and the National Electric Vehicle
Infrastructure Standards and Requirements (23 CFR 680) released in February 2023.

Development Process
The Plan was developed in response to the provision of funding for EV adoption that was included in
the BIL, which was enacted as the Infrastructure Investment Jobs Act, Public Law 117-58 (November
15, 2021). The NEVI Formula Program is a $5 billion program established in the BIL to serve as a
catalyst for the construction and implementation of a national network of 500,000 EVSE by 2030.

State departments of transportation can nominate corridors along the national highway system
within their states to become Alternative Fuel Corridors (AFCs)1, which are eligible for funding of
EVSE installations and upgrades under the BIL.

Study Area
The 2022 Plan addressed Arizona’s designated AFCs, which are all part of the Interstate Highway
System. In 2022, the Arizona State Highway System had 7,767 total centerline miles, including 1,168
centerline miles of Interstate highway. Arizona’s entire roadway network (including local roads) had
74,606 centerline miles. While Interstate highways make up less than two percent of the state’s
total roadway network, they account for 21.4% of the vehicle miles traveled (VMT) on Arizona
roads.2

In 2023 ADOT nominated seven additional highways for AFC status. These routes are the focus of
this 2023 Plan update.

Plan Development
The 2022 Plan and the 2023 Plan update were developed in accordance with federal law, NEVI
Formula Program guidance, Arizona law and ADOT policies. ADOT has hosted and will continue to
host engagement activities with the public, community-based organizations, federal, state, local
and tribal representatives, as well as other impacted groups, in order to develop a Plan that is
equitable and beneficial to the entire state. The state agencies included the Arizona Department of
Environmental Quality, Arizona Commerce Authority, Arizona Corporation Commission, Arizona
Department of Administration, Arizona State Parks, and Arizona Residential Utility Consumer Office.

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Plan Vision and Goals
The vision of the Plan is to aid in the deployment of a national EVSE network and make EV driving
accessible and reliable in the state of Arizona.

ADOT has six goals for an interconnected EVSE network:

1. Reduce range anxiety by closing gaps in the EVSE network along Arizona's AFCs.
2. Support the development of an EVSE network that is resilient, equitable, accessible, and
reliable.
3. Engage stakeholders and the public in the planning, development, and installation of EVSE.
4. Identify potential new AFC locations during the outreach process.
5. Utilize efficient contracting and procurement mechanisms to maximize the amount of
infrastructure that can be built; consider future needs; and reduce current risk(s) to support the
EVSE network’s long-term viability.
6. Use data and performance metrics to evaluate charger installation and operations to inform the
development of program improvements.

Plan Milestones
Major milestones and anticipated dates of EVSE deployment include:

2022 Goals

The following goals have been completed at the time of submitting this plan:

1. Completed and submitted the 2022 Plan.

2. Solicited public and stakeholder input on potential new AFCs to be considered for nomination.

2023 Goals

The following goals have been completed at the time of submitting this plan:

1. Began the solicitation process for new/upgraded EVSE stations.

2. Nominated new AFCs through the federal process.
3. Updated the EV Infrastructure Deployment Plan to include the newly nominated AFCs.

The following goals are anticipated:

2024 Goals

1. Nominate new AFCs through the federal process.

2. Prepare the 2024 Plan update.
3. Award contract(s) to upgrade existing stations and/or construct new stations, as identified in the
2022 Plan.
4. Begin the process to solicit and award contracts to upgrade existing stations and/or construct
new EVSE stations on AFCs identified in the 2023 Plan, with available funding.

2025 – 2026 Goals

1. Nominate new AFCs through the federal process.

2. Prepare the 2025 and 2026 Plan updates.

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3. Solicit and award remaining funding for EVSE construction.
4. Install EVSE.
5. Evaluate the performance of NEVI Formula Program implementation.

Updates from Prior Plan

The following changes and updates have been made in the 2023 Plan:

 Overall
o Plan update set in calendar years, rather than federal fiscal years (October 1 –
September 1)
o Financial information remains in federal fiscal years
o Some technical information is based on the Arizona state fiscal year (July 1 – June 30)
 Agency Coordination
o Meetings were held with state, federal, and tribal leaders on July 7 and July 12, 2023.
 Public Engagement

o Information and updates from engagement events held from August 2022 to July 2023
has been added, including details on:
o A statewide series of open-house format in-person public meetings in late 2022.
o A public survey and associated public responses which accompanied the open house
meetings in late 2022.
o A statewide virtual public meeting held on July 18, 2023, to present the 2023 plan
update.

 Plan Vision and Goals

The following goals listed in the 2022 Plan have been completed:

o Completed and submitted the 2022 Plan.

o Began the solicitation process for new/upgraded EVSE stations.
o Solicited public and stakeholder input on potential new AFCs to be considered for
nomination.
o Nominated new AFCs through the federal process.
o Updated the EV Infrastructure Deployment Plan to include the new AFCs.

 Contracting

o ADOT has released a request for information (RFI) in June 2023 to gather perspectives
from industry members in to inform development of the anticipated request for
proposals (RFP).
o ADOT intends to release an RFP through single-step procurement at the end of 2023.
The RFP will solicit contractors who will construct and potentially upgrade charging
stations.

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 Civil Rights

o Per finalized NEVI guidance, ADOT has added that an automated toll-free phone number
and short messaging service (SMS) will be included as payment options for chargers to
enhance accessibility.

 Existing and Future Conditions Analysis

o Risks and mitigations were updated to reflect current conditions.

o All statistics were updated to reflect the most current data available.

 Infrastructure Deployment

o Two stations, at Payson and Show Low, were added to the list of NEVI creditable
stations. Both are owned by Electrify America.
o Seven new AFCs were added.
o Eleven new proposed stations and two new candidates for station upgrades were
added.
o New funding sources, including the Electric Vehicle Charging Station Rebate, the Electric
Vehicle Charging Station Pilot Program, and the Charging and Fueling Infrastructure
Discretionary Grant Program, were added to this section.
o Flexibility was added to the siting of new stations so that more than one interchange
considered for deployment.
o All updates necessary to comply with final NEVI guidance were included.

 Implementation

o Per finalized NEVI guidance ADOT will require that chargers are capable of using Open
Charge Point Interface (OCPI) for interoperability.

 Equity

o Updates have been made to the frequency and content of equity metrics in order to
streamline processes and comply with finalized NEVI guidance.

 Labor and Workforce Development

o These policies were reviewed to ensure compliance with finalized NEVI guidance.

 Cyber and Physical Security

o All necessary updates were made to ensure compliance with updated NEVI guidance.
o ADOT will require site owners to enact physical security strategies to address lighting,
siting, driver and vehicle safety, fire prevention, tampering, charger locks, and illegal
surveillance of payment devices, as well as siting and station design to ensure visibility
from onlookers, video surveillance, or emergency call boxes.

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 Program Evaluation

o The Program Evaluation section was revised to reflect the updated metrics and
disclosure requirements from the NEVI guidance, as well as the updated timelines for
disclosure and data collection.

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 State Agency Coordination
ADOT recognizes the importance of coordinating with state, federal, and tribal agencies in the
development of this Plan.

ADOT initially met with state agency partners on June 16, 2022, to gather input to inform the
development of the 2022 Plan. The following agencies were identified as key stakeholders and
invited to the 2022 meeting:

 Arizona Department of Environmental Quality

 Arizona Commerce Authority

 Arizona Corporation Commission

 Arizona Department of Administration

 Arizona Residential Utility Consumer Office

 Arizona Governor’s Office

The department also distributed a stakeholder survey to the agencies, contacted certain agencies
for additional information, and notified the agencies of virtual and in-person public meetings and
public surveys.

ADOT also met with staff of Grand Canyon National Park during the development of the 2022 Plan.

In preparing the 2023 Plan, ADOT held separate meetings with state, federal, and tribal
organizations on July 7, 2023, and July 12, 2023, to share progress made since the 2022 Plan and to
gather feedback on draft recommendations developed for the update. Representatives of the
entities listed in Table 1 were invited to the meetings.

Table 1: Invitees to Agency Coordination Meetings, 2023 Plan

Entity Government Entity Type

Arizona State Parks State

Residential Utility Consumer Office State
Arizona Department of Environmental Quality State
Arizona Commerce Authority State economic development organization
Navajo Nation Tribal
Inter Tribal Council of Arizona Tribal
Hopi Tribe Tribal
San Juan Southern Paiute Tribe Tribal
Fort McDowell Yavapai Nation Tribal

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Entity Government Entity Type

Colorado River Indian Community Tribal

Ak-Chin Indian Community Tribal
Tonto Apache Tribe Tribal
Gila River Indian Community Tribal
Salt River Pima-Maricopa Indian Community Tribal
Hualapai Tribe Tribal
Fort Mohave Tribe Tribal
U.S. Bureau of Reclamation Federal
U. S. National Park Service Federal
Grand Canyon National Park Federal
Federal Highway Administration Federal
U. S. Bureau of Indian Affairs Federal
U.S. Forest Service Federal

Memoranda of Understanding with Other Agencies

ADOT has not entered into any memoranda of understanding at the time of writing of this report.

Interagency Working Group(s)

ADOT did not establish any interagency working groups at the time of writing of this report.

Plans to Utilize Domestic EVSE

ADOT will act in accordance with the NEVI Formula Program rulemaking to maximize opportunities
to utilize EVSE made in the United States. ADOT recognizes that the Buy America requirements of 23
U.S.C. 313 and the Build America, Buy America Act apply to the use of NEVI Formula Program funds,
and that it is the intent of the FHWA to maximize, consistent with the law, the use of goods,
products, and materials produced in the United States. ADOT will ensure that EVSE station owners
comply with all relevant regulations. When appropriate, ADOT may seek waivers from these
provisions as provided by law and Executive Order 14005 (“Ensuring the Future is Made in All of
America by All of America’s Workers”).

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Public Engagement
Stakeholder Engagement and Public Involvement Goals
ADOT has been and continues to be committed to effective stakeholder engagement and inclusive
public involvement processes throughout the development of ADOT’s EV plan. To achieve these
goals, a Public Involvement Plan was developed as part of the 2022 Deployment Plan to identify
public involvement goals, methods to inform and engage key stakeholders and the public, and to
ensure equitable access for underserved and Disadvantaged Communities (DACs) in engagement
activities. The Public Involvement Plan supports equitable statewide reach and encourages
participation through virtual methods, as well as in-person methods at a local level.

This year’s activities are a continuation of the initial Public Involvement Plan and included multiple
methods for the public and key stakeholders to learn about and provide input on the 2023 Plan prior
to submission.

Outreach was modeled after the International Association for Public Participation’s Spectrum of
Public Participation3 process, a globally recognized system for designing intentional engagement
activities that best suit the public’s role in the planning process. ADOT’s overall public participation
goal is to consult the public and key stakeholders in the Plan's development.

Throughout public engagement, ADOT has and will continue to advance these engagement goals:

 Keep the public and stakeholders informed.

 Obtain feedback on the Plan analysis, alternatives and/or decisions.

 Listen to and acknowledge concerns and aspirations from the public and key
stakeholders.

 Provide feedback on how public and key stakeholder input influenced the Plan
recommendations.

Specific sub-goals of this process include to:

 Provide information about and facilitate informed public and stakeholder input on:
Plan objectives; EVSE types and their charging speeds; federal requirements;
guidelines for implementing the EVSE network; and the timeline for Plan submission
and implementation.

 Secure participation from a broad cross-section of the community, as well as key

stakeholders with an interest in EVSE development, with an emphasis on reaching
DACs as identified in the Justice40 mapping tool.

 Raise awareness of ADOT’s efforts to secure federal funding to improve

infrastructure and transportation resiliency.

 Gain insight to supplement the data available on existing and future conditions.

 Gain insight into Arizona residents’ propensity for, and barriers to, use of EVs.

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  Understand the public’s desires and priorities related to siting EVSE and prioritizing
EVSE corridors, particularly in relation to how equity is evaluated and integrated
into the prioritization process.

 Determine the community’s perceptions and concerns regarding the EVSE network
and inform future outreach efforts.

Stakeholder and Public Involvement Activities

Public involvement is critical to the Plan’s development and successful implementation. Table 2
provides a description and status of stakeholder and public involvement activities conducted
between August 2022 and July 2023. Initial results, based on activities conducted through July 2022
were previously reported in the revised 2022 Plan, dated February 9, 2023.

Table 2: Stakeholder and Public Involvement Activities

Activity Status

In-person public meetings in an open-house format, held in

Completed November 2022
Tucson, Yuma, Kingman, Flagstaff, and Phoenix.
Second online public survey in English and Spanish to seek
Completed November 2022
input on the Plan recommendations and implementation.
State agency coordination meetings with federal, state, and
Completed July 7 and 12, 2023
tribal entities.
Statewide virtual public meeting to discuss the 2023 Updated
Plan. Meeting presentation and recording posted to website Completed July 18, 2023
for those unable to attend.
Coordination meeting with utilities across the state for
collaboration on both the planning and deployment stages of Completed July 20, 2023
the Plan.
Public comment period on 2023 plan update. July 11- July 25, 2023

Stakeholders Involved in Plan Development

An extensive and diverse list of key stakeholders for the Plan was developed. It includes:

 City and county staff in communities along the AFCs

 Representatives from every Metropolitan Planning Organization/Council of

Governments in Arizona

 Governor’s office

 Various state agencies

 The tribal communities with land along the AFCs

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  EV industry representatives (including EVSE operators, EV automobile
manufacturers, other EV suppliers, and EV advocacy organizations)

 Utility companies

 Chambers of commerce

 Other business or commerce organizations

 Large employers

 Others with interests in the Plan’s development

Roadway users, including current EV users, are also stakeholders in the Plan.

Table 3 lists the organizations that were invited to participate in the Plan's development.
Stakeholder organizations that address the goals of the Justice40 Initiative, identified in Executive
Order 14008, are shown in italic text.

Table 3: Stakeholders Involved in Plan Development

Organization Category Organizations Targeted for Engagement

Transportation planning  Central Arizona Governments

organizations  Central Yavapai Metropolitan Planning Organization
 Lake Havasu Metropolitan Planning Organization
 Maricopa Association of Governments
 MetroPlan Metropolitan Planning Organization for Greater Flagstaff
 Northern Arizona Council of Governments
 Pima Association of Governments
 Sierra Vista Metropolitan Planning Organization
 Southeastern Arizona Governments Organization
 Sun Corridor Metropolitan Planning Organization
 Western Arizona Council of Governments
 Yuma Metropolitan Planning Organization

Counties and cities  Apache County

 Coconino County
 Gila County
 Graham County
 La Paz County
 Maricopa County
 Mohave County
 Navajo County
 Pima County
 Pinal County
 Santa Cruz County
 Yavapai County

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Organization Category Organizations Targeted for Engagement

 Yuma County
 Avondale
 Benson
 Black Canyon City
 Buckeye
 Bowie
 Camp Verde
 Casa Grande
 Chambers
 Chandler
 Cochise
 Coolidge
 Cordes Junction
 Eloy
 Flagstaff
 Gila Bend
 Holbrook
 Joseph City
 Kingman
 Marana
 Maricopa
 Nogales
 Phoenix
 Quartzsite
 Sahuarita
 San Luis
 San Simon
 Sanders
 Seligman
 Tempe
 Tucson
 Welton
 Willcox
 Williams
 Winslow
 Yuma

State Department of  Arizona Department of Administration

Energy  Arizona Governor’s Office

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Organization Category Organizations Targeted for Engagement

Environmental protection  Arizona Department of Environmental Quality

agencies  U.S. Environmental Protection Agency

State economic  Arizona Commerce Authority

development agencies  Economics Collaborative of Northern Arizona
 Greater Phoenix Economic Council
 Mohave County Economic Department
 City of Sahuarita Economic Development Department

Public transportation  City of Phoenix Public Transit

agencies  Arizona Transit Authority
 Mountain Line

Tribal governments  Ak-Chin Indian Community

 Cocopah Indian Tribe
 Colorado River Indian Tribes
 Fort McDowell Yavapai Nation
 Fort Mohave Indian Tribe
 Fort Yuma Quechan Indian Tribe
 Gila River Indian Community
 Havasupai Tribe
 Hopi Tribe
 Hualapai Tribe
 Kaibab Band of Paiute Indians
 Navajo Nation
 Pascua Yaqui Tribe
 Pueblo of Zuni
 Salt River Pima-Maricopa Indian Community
 San Carlos Apache Tribe
 San Juan Southern Paiute Tribe
 Tohono O’odham Nation
 Tonto Apache Indian Tribe
 White Mountain Apache Tribe
 Yavapai Apache Nation
 Yavapai-Prescott Indian Tribe

Electric utilities;  Aha Macav Power Service

transmission and  Anza Electric Cooperative
distribution owners and  Arizona Corporation Commission
regulators  Arizona Electric Power Co-Op
 Arizona G&T Cooperatives

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Organization Category Organizations Targeted for Engagement

 Arizona Public Service

 Arizona Residential Utility Consumer Office
 CLEAResult
 Duncan Valley Electric Cooperative
 Garkane Energy Cooperative
 Graham County Electric Cooperative
 Grand Canyon State Cooperatives
 Mohave Electric Cooperative
 Pinnacle West
 Salt River Project
 Sierra Southwest Cooperative
 Southwestern Power Group
 Sulphur Springs Valley Electric Cooperative
 Trico Electric Cooperative
 Tucson Electric Power (TEP) and UniSource Energy Services

Community-based  Arizona Chamber of Commerce

organizations, small  Arizona Hispanic Chamber of Commerce
business associations,  Arizona League of Cities and Towns
chambers of commerce,  Arizona Small Business Association
labor organizations, and
 Asian Corporate and Entrepreneur Leaders
private entities
 Black Chamber Arizona
 Chinese Chamber of Arizona
 Economics Collaborative of Northern Arizona
 Flagstaff Chamber of Commerce
 Fortis Networks
 Greater Flagstaff Chamber of Commerce/Northern Arizona Chamber
Organization
 Greater Phoenix Chamber
 Kingman Chamber of Commerce
 Tucson Metro Chamber
 Valley Partnership

Private-sector EVSE  Blink Charging

owners and network  Charge Point
operators  Charge Zero
 Electrify America
 EVgo
 Francis Energy
 Tesla

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Organization Category Organizations Targeted for Engagement

Vehicle manufacturers  Atlis Motor Vehicles

 Audi
 BMW
 Cruise
 DeMenna (representing Avis)
 FCA Group
 General Motors
 Goodyear
 Lucid Motors
 Nikola Motor / Nikola Defense
 Toyota
 Proterra
 Tesla
 Waymo

Minority- and women-  Arizona Minority Contractors Association

based organizations  Chicanos Por La Causa
 Greater Phoenix Urban League
 NAACP Maricopa County Branch

Freight industry  Arizona Trucking Association

Environmental and other  Arizona Forward

community advocacy  Ceres
organizations with an  Southwest Energy Efficiency Project (SWEEP)
interest in EVSE  The Nature Conservancy
 Valley of the Sun Clean Cities Coalition
 Western Resource Advocates

EV industry organizations  Alliance for Automotive Innovation

and EV advocacy groups  Alliance for Transportation Electrification
 Arizona Technology Council
 EV Noire
 EV Transportation Alliance
 Fourth Mobility
 Phoenix Electric Automotive Association
 Plug In America
 Tucson Electric Vehicle Association (TEVA)
 Zero EV

Gas station owners and  Circle K

operators  Flying J
 Love's

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Organization Category Organizations Targeted for Engagement

 Shell Recharge Solutions

Ride-share drivers/taxi  Lyft

drivers  Uber

Emergency management  Arizona Governor’s Office

and public safety agencies
Other parties  Atlas Public Policy
 Electric Power Research Institute
 Triadvocates
 Generation Seven Strategic Partners
 Phoenix IDA
 QCM Technologies
 Verdek

Stakeholder organizations that address the goals of the Justice40 Initiative, identified in Executive
Order 14008, are shown in italic text

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Community Engagement Outcomes Report
Public Outreach and Notification
ADOT utilized various methods for promoting awareness of the EV plan, its development process,
draft recommendations, and planned engagement events for the public at each phase of outreach.
The methods used in 2022 and 2023 are summarized below:

 ADOT EV website with information about the plan and how to participate and
provide comments.

 Notification to the public via multiple methods, including news releases, mass email
alerts to the EV subscriber list (more than 3,000 subscribers) and ADOT social media
platforms.

 Paid advertising in print and online news media statewide in English- and Spanish-
language and tribal publications. The open house meetings in late 2022 were
promoted in 13 publications, with web advertisements promoting the
accompanying online survey viewed over 446,000 times. The summer 2023
statewide meeting was promoted in 11 different local publications.

 Collaboration with stakeholders to reach their constituents and audiences.

 Earned news media coverage of the Plan and public engagement activities, including
outlets such as news radio station KTAR in Glendale, National Public Radio member
station KJZZ in Tempe, television station KTVK in Phoenix, and television station
KGUN in Tucson.

Late 2022 Public Involvement Outcomes

As an addendum to initial engagements captured in the 2022 Plan, five in-person open house
meetings were held throughout the state from late October 2022 through early November 2022.
These meetings were supplemented by informational materials posted on the project website and a
public survey that was available both in person and online from mid-October through the end of
November.

Engagement included five in-person open house events geographically distributed across the state.
These engagements provided an opportunity to learn about the EV Plan, in many instances for the
first time. It also provided an opportunity for members of the public who were unaware of or unable
to participate in the July 2022 Virtual Public Meeting to participate in engagement efforts conducted
as a part of this work, while also updating those who had attended prior meetings with new
information about the EV Plan.

Meetings were held in Tucson, Yuma, Kingsman, Flagstaff, and Phoenix; venues were chosen to
ensure optimal convenience, accessibility, and ease of parking and navigation. These meetings were
attended by a total of 178 people.

The public survey received 1,423 responses. The survey was also accompanied by an additional,
optional, one-question Self-ID survey to allow respondents to indicate their racial/ethnic identity;
results are shown in Table 4 and Table 5. This aids ADOT in evaluating the effectiveness of public

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 outreach activities in reaching all communities in the state. 1,011 (73%) of respondents to the main
survey also completed this additional survey.

Table 4: Online Survey Self-ID Results

American Native
African Indian/ Hawaiian/
American/ Alaskan Pacific Hispanic/
Options White Black Native Islander Asian Latino

Responses 883 (87.3%) 36 (3.6%) 39 (3.9%) 14 (1.4%) 44 (4.4%) 96 (9.5%)

Table 5: In-Person Survey Self-ID Results

American Native
African Indian/ Hawaiian/
American/ Alaskan Pacific Hispanic/
City White Black Native Islander Asian Latino

Tucson 3 (60.0%) 1 (20%) 1 (20%) 1 (20%)

Yuma 4 (66.7%) 1 (16.7%) 1 (16.7%)
Kingman 9 (81.8%) 1 (9.1%) 1 (9.1%)
Flagstaff 12 (100%) 1 (8.3%)
Phoenix 23 (85.2%) 1 (3.7%) 3 (11.1%)
Total 51 (85.0%) 4 (6.7%) 0 (0%) 1 (1.7%) 1 (1.7%) 7 (11.7%)

The survey asked respondents to describe themselves using a provided list of descriptors (presented
in Table 6). For this question, 1,421 respondents (99.9%) indicated that at least one descriptor
applied, and 744 (52.3%) selected multiple options.

Table 6: Descriptor Question Responses

Descriptor Responses

Arizona resident (full- or part-time) 1,349 (94.8%)

Non-Arizona resident 50 (3.5%)
Live in urban/suburban area 436 (30.6%)
Live in rural area 294 (20.7%)
Electric vehicle industry representative 22 (1.5%)
Construction contractor, subcontractor, or supplier 25 (1.8%)

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Local municipality, regional, state, or federal agency 49 (3.4%)
Tribal member 17 (1.2%)
Other (please specify) 88 (6.2%)
The first question discussed the criteria that should be used for prioritizing the nomination of non-
Interstate roadways as AFCs, qualifying them for NEVI-funded EV charging stations. Respondents
were asked to score the importance of seven different criteria on a scale of 1 to 5, with 1 being
‘least important’ and 5 being ‘most important.’ There was little deviation in the average scores
among the seven criteria, suggesting the public believes each of these criteria are of equal
importance in prioritizing future AFCs.

Table 7: Prioritization Criteria Question Responses

Proposed Criteria Average Rating

Providing connectivity between Arizona and other states 3.56

Availability of existing services (convenience stores, restaurants, etc.) on route 3.55
Accessing major parks and tourist attractions/destinations 3.51
Connecting the Phoenix and Tucson metro regions with other AZ communities 3.47
Amount of vehicle traffic currently using the roadway 3.43
How feasible and cost-effective implementation would be 3.41
Connecting rural and tribal areas 3.16
Respondents were also able to suggest additional criteria for determining which additional highways
should be added to the electric vehicle charging network. Written answers were received for this
question totaling to 462 received responses, though some responses reiterated the listed criteria or
discussed matters unrelated to the question. Common suggestions included:

 Connecting to communities projected for significant future growth

 Routes that can maintain station access during detours and constructions

 Heat, topography, and other factors that impact vehicle power consumption

 Presence of, or feasibility for, future green energy infrastructure

 Current and projected EV ownership concentration and infill opportunities between

busy stations

 Spurring new tourism and economic growth

 Placing charging infrastructure near communities without fast charging options for
local use, particularly in underserved areas and areas with high percentages of
rental housing

The third question asked respondents to identify the payment methods they believed should be
provided at EV charging stations. Respondents were asked to rate the importance of five different

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 payment methods on a scale of 1 to 5, with 1 being ‘least important’ and 5 being ‘most important.’
Table 8 displays the average ratings, showing a preference for traditional, widely adopted payment
methods.

Table 8: Payment Methods Question Responses

Proposed Payment Method Average Rating

Chip-and-pin credit and debit cards 3.93

Contactless payment (tap-to-pay cards) 3.63
Phone-based payment like Apple Pay or Samsung Wallet 3.23
App-based payment method through charger network operator 2.98
Vehicle-based payment 2.93
The final topical question addressed which information about the stations and chargers should be
available online. Respondents were asked to rate the importance of five different pieces of
information on a scale of 1 to 5, with 1 being ‘least important’ and 5 being ‘most important.’ While
the average ratings do show a stronger preference for some options, all five scored relatively high
on the scale, suggesting that any information that can be provided is helpful as shown in Table 9.

Table 9: Online Information Question Responses

Proposed Online Information Average Rating

Availability and hours of operation at location 4.23

Number/type of chargers currently available 4.23
Number/type of chargers currently installed at location 4.07
Charging pricing 3.72
Availability of services near the location 3.56
Respondents were presented with a list and a map of 23 roadways in the state and were asked to
select five that they would most like to see added to the electric vehicle charging network. Table 10
lists these roadways by number of responses.

Table 10: Potential New Additions to the Charging Network

Roadway Selections Selection Rate

SR 64: I-40 to Grand Canyon National Park 409 40.0%

SR 87: Phoenix to Payson 382 37.3%
SR 69: I-17 to Prescott 373 36.5%
SR 179: I-17 to Sedona 365 35.7%
US 89: Flagstaff to Utah 353 34.5%
US 60: Phoenix to Wickenburg 275 26.9%

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Roadway Selections Selection Rate

US 60: Phoenix to Globe 248 24.2%

US 93: Wickenburg to I-40 245 23.9%
US 93: Kingman to Hoover Dam 241 23.6%
SR 260: Payson to Show Low 238 23.3%
SR 85: I-8 to I-10 195 19.1%
US 160: US 89 to Four Corners 193 18.9%
SR 89/89A: SR 69/169 to north end of route 164 16.0%
SR 77: Tucson to Pinal County 161 15.7%
US 60: Show Low to New Mexico 160 15.6%
SR 260: Camp Verde to Sedona 154 15.1%
SR 90: I-10 to Bisbee 149 14.6%
SR 347: Maricopa to I-10 137 13.4%
SR 287: Casa Grande to I-10 115 11.2%
SR 68: US 93 to Bullhead City 99 9.7%
US 95/SR 95: San Luis to Bullhead City 96 9.4%
SR 77: SR 260 to I-40 89 8.7%
SR 80: Bisbee to Douglas 71 6.9%

2023 Public Engagement

Following ADOT’s identification of recommended future EV corridors, ADOT conducted additional
public engagement in summer 2023. The focus of the 2023 EV Plan update public engagement was
to:

 Inform the public and key stakeholders of the additional state highway corridors on
the National Highway System identified as alternative fuel corridors as part of the
next phase of ADOT EV plan implementation, following the interstate corridors
identified in the 2022 Plan.

 Provide an opportunity to comment on the draft 2023 Plan for the study team’s
consideration prior to submission.

This engagement focused on the following activities:

 Conducting a statewide virtual public meeting.

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  Meeting with state agencies, MPOs/COGs and tribal communities located along the
additional alternative fuel corridors identified, as well as utility company
coordination.

 Holding a public comment period.

 Broadly notifying the public and stakeholders about the EV plan update and
opportunities to provide input.

Statewide Virtual Public Meeting

To share progress and gather input on the 2023 Plan, ADOT hosted a statewide virtual public
meeting on July 18, 2023, from 6:00 p.m. to 7:30 p.m. The meeting was held via the Zoom online
meeting platform and attended by 366 people. The meeting consisted of a presentation followed by
a question-and-answer session between the public and a panel of technical and public engagement
staff working on the Plan. ADOT provided live interpretation in Spanish and Navajo and allowed
participants to call in to the meeting, rather than only join by Zoom, to facilitate access for residents
who do not have reliable internet service.

The purpose of the meeting was to share information about the 2023 Plan Update, including a
review of the NEVI program and ADOT’s role in administration and implementation and an update
of the status of 2022 Plan implementation. The meeting addressed the new routes and stations
proposed in the 2023 plan, as well as routes to be potentially added in future updates identified
using both technical analysis and input from the public and key stakeholders.

The question-and-answer session followed the presentation. Attendees online were able to submit
their questions through the Zoom “Q&A” feature, while a portion of the session was set aside to
receive questions and comments verbally from attendees joining by phone. Participants entered 217
questions and comments into the Q&A feature, and two questions were asked by telephone.
Questions on similar topics were aggregated and verbally presented to the panelists. The most
common themes discussed in the question-and-answer session included:

 Charging Technology - Recent announcements in the EV industry about charging

connector standards; the potential for installing chargers with higher wattages than
150kW; charging compatibility with vehicles that use different connector types;
impacts of extreme heat on vehicles and charging infrastructure.

 Station Features and Amenities - Potential for charging larger EVs such as medium-
and heavy-duty trucks and buses at planned stations; inclusion of the network in
charging station locator apps and maps; inclusion of shade structures and pull-
through charging at stations; placing stations at locations with food and drink
options and restrooms.

 Station Operations - Charging prices, and the ability to regulate prices; station
maintenance, and the ability to ensure minimal station downtime, particularly
during holidays and peak travel days/times; power availability and impacts to the
electrical grid; safety considerations, including fire prevention, electrical hazards,
and the security of equipment and of users.

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  Planning and Implementation - Routes and station locations in the northern and
western parts of the state, particularly near tribal lands; timeline for station
construction and charger installation; number of chargers and stations ADOT
anticipates can be funded through NEVI; consideration of local and wider
environmental impacts.

 Stakeholder and Public Engagement - Public involvement in the planning process;

stakeholder, government, and agency coordination; coordination with neighboring
states; suggestions for partnering with various businesses and industries for station
hosting.

ADOT requested that attendees complete a self-identification survey for Title VI reporting purposes,
which asks participants to list their race/ethnicity. The results are shown below. A total of 130
people completed the self-ID survey. Of the 130 self-identification survey responses, 110 identified
as White, 14 participants identified as Hispanic/Latino, nine identified as African American/Black, six
identified as Asian, three identified as American Indian/Alaskan Native and two as Native
Hawaiian/Other Pacific Islander.

ADOT also offered the opportunity to provide comments via a one-question online comment form,
email, phone, or mail with the comment period open through July 25, 2023. Final public comments
will be added prior to final approval of the 2023 Plan update.

Public Meeting Notification

The July 18 virtual public meeting was publicized through the ADOT project website, ADOT
GovDelivery email alerts, print ads, ADOT social media posts and a news release.

Project Website
ADOT hosts a project website at https://azdot.gov/EVPlan. The project website is intended to
increase accessibility by serving as a resource that provides a project overview, including
information about the 2022 plan and 2023 plan update along with meeting presentations and
recordings. A link to an online survey/comment form was also included through July 25, 2023.

GovDelivery Emails
Information on how to participate in the virtual public meeting and provide comments on the 2023
Plan update were distributed by ADOT on June 27, July 5, July 17, July 20, and July 24, 2023, to the
EV subscriber list in GovDelivery. Each notice included over 3,000 contacts and on average had a
53% open rate. Copies of the GovDelivery notices can be found in the Appendices.

Print Ads
The virtual public meeting and comment period were advertised in the publications listed in Table
11.

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 Table 11: Advertising Publications, 2023
Publication(s) Run Date(s) Includes Coverage
Spanish Includes Tribal
Placement Communities

Arizona Daily Star July 5, 9, 12, 16 ✔ ✔

Arizona Republic July 3, 7, 9, 12, 14, 16 ✔
AZ Daily Sun July 11, 13, 15 ✔
Kingman Daily Miner July 12, 16 ✔
La Voz Arizona July 14 ✔
Navajo Hopi Observer & Williams July 12 ✔
Grand Canyon News
Navajo Times July 13 ✔
O’odham Action News July 6 ✔
Payson Roundup July 7, 14 ✔ ✔
The Tribune July 5, 12 ✔

Copies of the ads can be found in the Appendices.

News Release
ADOT Public Information staff distributed a news release to media outlets on July 12, 2023. The
news release can be found in the Appendices.

Social Media
ADOT Digital Communications staff posted to ADOT’s Facebook, Twitter, and NextDoor accounts
multiple times, providing information about the public meeting and commenting opportunities.
Social media posts can be found in the Appendices.

Tribal Engagement
Tribes potentially impacted by the 2023 Plan update, as well as agencies relevant to tribes, were
invited to a coordination meeting held on July 12, 2023. ADOT shared progress on the 2022 Plan and
presented draft recommendations developed for the 2023 Plan update. Attendees communicated
overall support for the program and their questions focused on the schedule for implementation,
the selection of alternative fuel corridors, and station locations.

The following entities were invited to the tribal coordination meeting:

 Colorado River Indian Tribe

 Hopi Tribe

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  Ak-Chin Indian Community

 Fort Mohave Indian Community

 Fort McDowell Indian Community

 Gila River Indian Community

 Hualapai Tribe

 Tonto Apache Tribe

 Navajo Department of Transportation

 Salt River Pima Indian Community

 Mazatzal Casino

 Bureau of Indian Affairs

 FHWA Tribal Coordinator

 Inter Tribal Council of Arizona

ADOT also presented an overview of the 2023 Plan update at the ADOT-Navajo Partnership meeting
in Window Rock on June 15, 2023. This presentation informed attendees of the newly identified
alternative fuel corridors and the upcoming events related to the 2023 Plan.

As previously mentioned, ADOT targeted advertising about the July 18, 2023, statewide virtual
public meeting to tribes potentially impacted by the 2023 Plan update.

Utility Engagement
Utility coordination and engagement is vital to developing an effective charging infrastructure
network. To support the implementation of the 2022 Plan and the 2023 Plan update, a survey was
distributed each year to the state’s utilities to gather information. The survey presented new
proposed charger locations, including nearest route and exit number, and questions on the
following topics:

 The nearest substation location at the town level

 The proposed stations’ charger load impact on the electric grid

 Whether 600 kilowatts of power would overload the existing substation, would
nearly reach full load, or would not overload the substation during peak hours

 Whether three-phase service is available at each proposed station location

The survey relevant to the 2022 Plan was sent in 2022 to the following utilities:

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 Table 12: 2022 Plan Service Area by Utility
Utility Service Area

APS Flagstaff, Prescott, Phoenix, Yuma

TEP/Trico Tucson
Mohave Electric Cooperative Mohave, Yavapai, and Coconino Counties
Unisource Mohave and Santa Cruz Counties
Sulphur Springs Valley Electric Cooperative Cochise, Graham, Pima, and Santa Cruz Counties
Navopache Electric Cooperative Apache, Greenlee, Gila, and Navajo Counties

For the 2023 Plan, surveys were also conducted to understand grid capacity at the planned
deployments, utilities included:

Table 13: 2023 Plan Service Area by Utility

Utility Service Area

Unisource Energy Services Mohave and Santa Cruz Counties

Arizona Public Service (APS) Flagstaff, Prescott, Phoenix, Yuma
Electrical District No. 3 Maricopa and Stanfield
Salt River Project (SRP) Phoenix
Navopache Electric Cooperative Apache, Greenlee, Gila, and Navajo Counties
Navajo Tribal Utility Authority (NTUA) Navajo Nation
Page Utility Enterprises The Greater Page Area

2023 Plan Update Coordination Meeting

On July 20, 2023, ADOT held a coordination meeting with all utilities listed above. The Department
presented an overview of the 2023 Plan update and requested input from attendees regarding grid
capacity and coordination with potential contractors.

Metropolitan Planning Organization / Council of Government Engagement

ADOT presented an overview of the draft 2023 Plan update to an Arizona’s metropolitan planning
organizations (MPOs) and councils of governments (COGs, i.e., rural planning organizations) to a
statewide planners’ meeting on June 9, 2023. The following MPOs and COGs were invited to the
meeting:

 Central Arizona Governments

 Central Yavapai Metropolitan Planning Organization

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  Lake Havasu Metropolitan Planning Organization

 Maricopa Association of Governments

 MetroPlan Metropolitan Planning Organization for Greater Flagstaff

 Northern Arizona Council of Governments

 Pima Association of Governments

 Sierra Vista Metropolitan Planning Organization

 Southeastern Arizona Governments Organization

 Sun Corridor Metropolitan Planning Organization

 Western Arizona Council of Governments

 Yuma Metropolitan Planning Organization

Site-Specific Public Engagement

ADOT is developing an RFP for the implementation of charging stations along the Interstate
highways, per the 2022 Plan. The RFP and the awarded contracts will contain requirements for
public engagement during the implementation of charging stations.

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Plan Vision and Goals
To create a framework for the successful implementation of a statewide charging infrastructure
network, ADOT developed the following vision and goals for the Plan. These goals will provide a
baseline for program evaluation that will monitor three key areas to determine success: data
collection, equitable access, and network reliability.

Vision
The Plan seeks to increase long-range mobility for EV drivers by closing the current gaps in the
availability of charging station infrastructure along Arizona's AFCs, and supporting the development
of an equitable, accessible, and reliable nationwide network of fast EV chargers.

Goals
ADOT has set six goals that an interconnected EVSE network must achieve to realize the agency’s
vision. ADOT’s Plan and associated commitments will:

1. Reduce range anxiety by closing gaps in the EVSE network along Arizona's AFCs.
2. Support the development of an EVSE network that is resilient, equitable, accessible, and
reliable.
3. Engage stakeholders and the public in the planning, development, and installation of EVSE.
4. Identify potential new AFC locations during the outreach process.
5. Utilize efficient contracting and procurement mechanisms. This will: maximize the amount of
infrastructure that can be built, consider future needs, and reduce risk(s) to support the EVSE
network’s long-term viability.
6. Use data and performance metrics to evaluate EVSE installation and operations to inform
program improvements.

Annual Goals
The following five-year program identifies specific goals for each year through 2026:

Completed Goals
The following goals have already been completed at the time of this publication:

2022 Goals

The following goals have been completed at the time of submitting this plan:

 Completed and submitted the 2022 Plan.

 Solicited public and stakeholder input on potential new AFCs to be considered for nomination.

2023 Goals

The following goals have been completed at the time of submitting this plan:

 Began the solicitation process for new/upgraded EVSE stations.

 Nominated new AFCs through the federal process.
 Updated the EV Infrastructure Deployment Plan to include the newly nominated AFCs.

27
The following goals are anticipated:

2024 Goals

 Nominate new AFCs through the federal process.

 Prepare the 2024 Plan update.
 Award contract(s) to upgrade existing stations and/or construct new stations, as identified in the
2022 Plan.
 Begin the process to solicit and award contracts to upgrade existing stations and/or construct
new EVSE stations on AFCs identified in the 2023 Plan, with available funding.

2025 – 2026 Goals

 Nominate new AFCs through the federal process.

 Prepare the 2025 and 2026 Plan updates.
 Solicit and award remaining funding for EVSE construction.
 Install EVSE.
 Evaluate the performance of NEVI Formula Program implementation.

Five-Year Goal
The five-year program culminates in the following five-year goal:
 Use NEVI funds to complete the charging network on Arizona’s AFCs.

The Plan will be updated annually to reflect the addition of new AFCs and station locations, based on
available funding for the upcoming year.

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 Contracting
Status of Contracting Process
ADOT is using a public-private partnership (P3) contracting process to support this work and
developing a single request for proposals (RFP) to select a contractor who will design, build, own,
operate, and maintain the charging stations (which may include upgrades) identified in the 2022
Plan. The contractor will also provide the required 20% match, with the remaining 80% covered by
NEVI formula funds. All awards will be reimbursement-based; no advances of funds will be provided.

If a charging station identified in the Plan is installed on public land, such as a national park, funds
may be awarded directly to public agencies.

To help inform RFP development, ADOT issued a request for information (RFI) on June 29, 2023, to
gather industry feedback. ADOT received written responses that were due by July 28, 2023 and will
meet one-on-one with prospective proposers on August 8-9, 2023. The following timeline is a
preliminary schedule for the remainder of the contracting process.

Table 14: Contracting Timeline

Milestone Anticipated Timeline

Public hearing for P3 procurement 4th quarter of 2023

Release RFP 4th quarter of 2023

RFP responses due 1st quarter of 2024 (anticipated 90-day response

period)

Selection of preferred proposers 1st quarter of 2024

ADOT is authorized to enter into agreements with public or private entities for the purposes of this
program under Title 28, Chapter 22 (“Public-Private Partnerships in Transportation”) of the Arizona
Revised Statutes (A.R.S.). All contracting and procurement activities will be subject to the applicable
requirements of 2 CFR Section 200 et seq. and 2 CFR Section 1200 et seq.

Awarded Contracts
ADOT has not awarded any contracts as of the submittal of this plan.

Scoring Methodologies Utilized

ADOT will issue a single RFP in 2023 to select a contractor to design, build, own, operate, and
maintain the charging stations (may include upgrades) identified in the 2022 Plan. The Department
is developing the scoring methodology it will use to evaluate proposals, but this has not been
finalized to date.

The methodology will be based on a range of factors that may include:

 Compliance with the issuance of the NEVI Standards and Requirements

29
  Eligibility

 Ability to further program goals

 Experience and expertise in EVSE station installation, ownership, operation, and

maintenance

 Demonstrated record of providing reliable and safe EV charging services meeting

industry standards

 Security, cybersecurity, emergency, and resilience plans

 Operations and maintenance plans

 Technical, managerial, and financial capacity

 Community engagement plan

 Budget/independent cost estimate

To identify information that that may inform the development of the RFP, ADOT requested
suggestions from industry respondents in the RFI released in 2023.

Strategies Leading to Efficient and Effective Deployment Against Plan Goals

ADOT will consider using NEVI Formula Program funds for new EVSE station operations and
maintenance costs.

ADOT will require, via contract terms, that infrastructure be maintained and operated at the same
location for a period of no less than five years from the installation date with the consideration of
providing service beyond the use of NEVI Formula Program funds. Contract terms may require that
awardees for new stations post a performance bond to guarantee that the EVSE remains operational
for the five-year performance period.

Community Engagement During Station Implementation

NEVI Standards and Requirements state that contractors who will implement the 2022 plan must
engage with the community where EVSE infrastructure will be installed to help ensure the locations
are in line with the community’s needs, barriers to implementation are identified upfront, and the
station will ultimately be used by the community. Community engagement requirements will be
included in all contracts. ADOT will require that potential contractors describe their community
engagement strategies as part of their proposal to ADOT, and the strength of their strategies will be
considered during the selection process. Community engagement activities shall comply with civil
rights requirements, the ADOT Public Involvement Plan, and the NEVI Standards and Requirements.

Compliance with State and Federal Requirements

Solicitations will comply with all applicable federal and state procurement requirements. They will
be advertised and made available to potential awardees through appropriate distribution channels.
ADOT will hold a pre-proposal meeting or other meetings, as appropriate, with potential proposers
to discuss program goals, selection criteria, and other topics.

30
Solicitation documents will provide detailed information on submittal requirements, eligibility,
program goals, and standards for station upgrade, installation, operation, and maintenance, as
applicable. Administrative and other applicable requirements including NEVI Formula Program
requirements, applicable state requirements, and applicant responsibilities relating thereto, and
other relevant information will also be included.

ADOT will ensure that solicitation documents and contracts executed with all parties awarded NEVI
Formula Program funding comply with Title 23 U.S.C., CFR 680; or FHWA Special Experimental
Project No. 14; and all applicable requirements under 2 CFR 200. Contract provisions will require
that all applicable federal requirements are met by the awardee, and appropriate monitoring will be
conducted to verify compliance.

Public Disclosure Requirements

ADOT intends to comply with the NEVI Standards and Requirements relating to contracting with
private entities. The following strategies are based on the Standards and Requirements.

 ADOT will comply with the FHWA’s public disclosure requirements, as published in
the NEVI Standards and Requirements, for the documents concerning the
operations of EVSE including the procurement process used, price of award, the
number of bids received, the identification of the awardee, the proposed contract
with the awardee and, in accordance with State law and the financial summary of
contract payments. ADOT will ensure these items are made publicly available
whether through an announcement, public comment period, or other means.

 Any agreements for the operation and maintenance of an EVSE will be subject to
A.R.S. Title 28 (Transportation), Chapter 22 (Transportation Public-Private
Partnerships), 2 CFR 200 et seq. and 2 CFR 1200 et seq.

Additional Public Disclosure Considerations

ADOT will encourage station owners to consider electricity rates in the surrounding community
when setting a pricing structure to confirm users are being reasonably charged for use. The rate
should offset the lifetime cost of the charging station, including:

 Need to recover fixed operating costs

 Need to recover usage-based or other variable operating costs

 Management of vehicles left in EVSE parking spaces for extended periods or other
misuse patterns

 Incentivizing charging during lower-cost off-peak hours

 Ability of targeted users to access or enable the EVSE

 Ability of targeted users to pay for and afford charging rates

 Need for networked versus non-network stations to apply charges and process
payment

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Station owners will be encouraged to take advantage of offerings from local utilities to minimize
upfront and operational costs. Additionally, electric utility providers may offer electricity rates that
encourage the recharging of vehicles during off-peak, overnight times that may be much lower than
on-peak, midday times.

Prior to finalizing the RFP that will solicit prospective contractors to implement the 2022 plan, ADOT
is required by A.R.S. Section 28-7704(I) to hold a public hearing on charging station usage costs.

Environmental Compliance
Projects that require federal approval and are funded by FHWA must meet the requirements of the
National Environmental Policy Act (NEPA). Development of the statewide EV Plan qualifies as a
Categorical Exclusion (CE) under 23 CFR 771.117I(1) because it is a planning activity.

The installation of EV charging infrastructure is a separate activity that will require an additional
environmental approval. ADOT anticipates performing the environmental review and approval of
the awarded EV charging sites. A vast majority of federal-aid projects have no significant
environmental impacts and can be determined to be a CE. It is anticipated that EV charging sites
would meet the definition of a CE under 23 CFR 771.117(c)(21). Pursuant to 23 U.S.C. 326, the FHWA
Arizona Division and ADOT have entered into a Memorandum of Understanding (MOU) for the State
Assumption of Responsibility for CEs. The CE Assignment MOU (326 MOU) was signed by FHWA and
ADOT on January 3, 2018. CEs listed under 23 CFR 771.117(c) are approved by ADOT under the 326
MOU.

All CE determinations follow documentation requirements, proper CE determination under 23 CFR

771.117 (c) and (d), environmental analysis, re-evaluation under 23 CFR 771.129, evaluation of
“unusual circumstances,” inclusion of environmental commitments, and exercise of proper approval
authority under the aforementioned 326 MOU. Utilizing an ADOT CE Checklist, supported by
cultural, biology, hazardous materials, air quality, and noise, among other technical evaluation
criteria, assesses project impacts. The environmental review and required documentation would be
appropriate to the scope of each project and specific conditions at each site. Upgrade sites located
at existing charging sites that require minimal or no ground disturbance may be covered by a CE
type that reflects minimal cultural, biology, and hazardous materials investigations. Sites where new
charging stations are installed may experience more ground disturbance and would require a higher
level of environmental study and documentation. If project activities have the potential to impact
cultural resources, these sites may require cultural resources investigations and consultation under
Section 106 of the National Historic Preservation Act. Land ownership of the site will also be
considered. Any sites on Tribal land may require additional approvals or outreach to the affected
Native American Tribes.

The timeline for CE approval is dependent upon project-specific circumstances and approvals. CEs
for upgrades to existing charging sites with minimal ground disturbance can be expected to take
approximately three months to complete and obtain approval. CEs for new build sites with more
ground-disturbing activities, or those requiring cultural resources survey and/or Section 106
consultation, may take up to six months to complete and obtain approval. In addition, certain
technical studies such as hazardous materials or biological surveys may need to be updated if
extensive time has transpired between conclusion of the environmental process and the start of

32
construction. Any subsequent environmental field work is often completed prior to the start of
construction and execution time should be considered in site location scheduling.

33
Civil Rights
ADOT will comply with NEVI Standards and Requirements as they relate to civil rights. To ensure all
EVSE customers and participants are provided with equitable opportunities to engage in EVSE
offerings, the Plan complies with State and Federal civil rights laws and regulations, including Title VI
of the Civil Rights Act of 1964 (Title VI), the ADA of 1990, Section 504 of the Rehabilitation Act of
1973, Executive Order 12898 on Environmental Justice, and Executive Order 13166 on Limited
English Proficient (LEP) Persons.

Title VI prohibits discrimination on the basis of race, color, or national origin, either directly or
indirectly in the types; quantity, quality, or timeliness of program services; aids; or benefits that they
provide or in the manner in which they provide them, in any program that receives Federal funds or
other Federal financial assistance. Executive Order 13166 for Limited English Proficiency requires
recipients of Federal financial assistance to take reasonable steps to provide Limited English
Proficient individuals with language services (oral or written) to ensure meaningful access to the
agency’s programs, activities, and services. Identification of LEP persons is required to ensure access
to language services pursuant to this Executive Order. To ensure nondiscriminatory practices based
on Title VI, ADOT will:

 Ensure public outreach materials, including handouts, posters, and other

communications, are accessible to all persons in alternative language formats and
provide vital documents in English and Spanish.

 Ensure EVSE stations provide information, instructions, and other communications

in English and Spanish by including these requirements in future contracting and
procurement mechanisms.

 Ensure that automated toll-free phone numbers and short messaging service (SMS)
payment options are accessible to all persons in alternative language formats.

ADA prohibits discrimination and guarantees that people with disabilities have the same
opportunities as everyone else to participate in the mainstream of American life, including
employment opportunities, purchasing goods and services, and participating in state and local
government services. The following efforts will be instituted to comply with the statutory
requirements of the ADA and the NEVI Standards and Requirements:

 Ensure EVSE stations include accessible parking spaces and are developed in
accordance with ADA and Architectural Barriers Act Disability Guidelines for
transportation facilities, including but not limited to the Public Right-of-Way
Accessibility Guide.

 Follow procedures outlined in ADOT’s Transition Plan for Public Rights-of-Way,

including Title II: Public Services and Transportation.

 Maintain EVSE station signage that clearly designates all available facilities and
accessible entrances and exits from those facilities.

34
  Ensure that access for people with disabilities be provided in the creation of
payment instructions, SMS payment options, and toll-free phone numbers.

 Ensure that public meetings and outreach efforts are ADA-compliant. This includes,
among other efforts, ensuring that public meetings are accessible to everyone,
including those with disabilities, that venues are accessible by ADA-compliant
transportation options, and information provided is in accessible formats for
persons with vision or hearing disabilities.

Section 504 of the Rehabilitation Act protects qualified individuals from discrimination based on
their disability by forbidding organizations and employers from excluding or denying individuals with
disabilities an equal opportunity to receive program benefits and services. To ensure
nondiscriminatory practices based on Section 504, ADOT will:

 Provide Notice of Reasonable Accommodations language at EV charging stations in

English and Spanish.

Executive Order 12898 on EJ requires “the fair treatment and meaningful involvement of all people,
particularly minority and low-income populations, in the environmental decision-making process.”
The United States Department of Transportation (USDOT) Order 5610.2(a) and FHWA Order
6640.23A require compliance with Executive Order 12898. This includes the “full and fair
participation by all potentially affected communities in the transportation decision-making process.”

Executive Order 14008 on Tackling the Climate Crisis (Justice40) states that “40 percent of the
overall benefits” of federal investments from covered programs should flow to DACs. To respond to
the Justice40 directive, ADOT will adhere to and comply with the NEVI Standards and Requirements.

To ensure nondiscriminatory practices based on EJ, ADOT will:

 Identify and engage low-income and minority populations in the Plan development.

 Identify and consider low-income and minority populations in siting EVSE stations.

 Follow the plan outlined in the Equity section of this Plan.

 Follow the other mandates of Justice40 as they evolve.

Nondiscrimination practices will be implemented and enforced in compliance with NEVI Standards
and Requirements.

35
 Existing and Future Conditions Analysis
This analysis summarizes current EV and associated equipment technologies; Arizona’s geography
and travel patterns; existing and planned EVSE infrastructure; a forecast on EV adoption; and a
charging demand analysis for Arizona through 2040. This section has been updated to include the
latest data on existing conditions and new AFC designations for the 2023 plan.

Electric Vehicle Basics

EVs are powered by electric motors, while internal combustion engine (ICE) vehicles are powered by
fossil fuels. Current specifications for a typical EV are shown in Table 15.

Table 15: Typical EV Technical Specifications

Specification Description Value

Vehicle Size Types of EV available on the Commonly sedans. Beginning

market to develop SUVs and trucks.
Range The distance that a battery in an 150-300 miles4
EV vehicle can travel before
needing to be recharged
Efficiency The mileage of an EV per unit 3.46 mi/kilowatt hour (kWh)5
capacity of the battery
Battery Size The battery capacity of an EV 54-108 kWh6
Battery Pack Cost The cost of an EV battery per $153/kWh7
unit capacity

Charger Types
EV chargers come with different connector types and power outputs, which directly affect the
charging time of the vehicle. The higher the power output, the shorter the charging time required.
There are three classifications for charger power levels.

Level 1 chargers utilize standard 20-ampere, 120-volt outlets commonly found in homes. Charging
speeds are slow, providing a rate of 2-5 miles of range per hour. These chargers are suitable for
home and overnight charging locations. However, Level 1 charging is becoming less common as
battery capacity increases, and they are now primarily used as emergency chargers.

Level 2 chargers require higher-voltage outlets, specifically 220 volts, the same as the voltage
outlets used by a clothes dryer. The higher voltage enables a faster charging rate of 10-30 miles of
range per hour. Level 2 chargers are typically found in EV charging stations at workplaces, curbside
parking spots, hotels, parks, and other public destinations and are most beneficial at locations
where longer dwell times are expected.

Level 3 chargers, also known as DCFC chargers, allow for even higher speed charging but necessitate
commercial-grade power levels. Power output levels vary from 50kW to 350kW, with NEVI requiring

36
 a minimum of 150kW per charging port. Charging times are generally less than a half-hour. Installing
Level 3 chargers requires close collaboration with the local electric utility because these chargers
demand higher power capacity and quality than Levels 1 or 2 chargers.

For DCFC chargers, the NEVI program requires that each charger use the J1772 Combined Charging
System (CCS) connector. NEVI formula funds may be used for the installation of other proprietary
and nonproprietary connectors in addition to CCS. This includes the North American Charging
Standard (NACS) connectors that have been used in Tesla charging stations and are expected to be
increasingly used by other auto manufacturers.

Table 16: Common EV Connector Types

EV Connector Type Charger Description

The primary connector type used for Level 1

and Level 2 charging.

A CCS is a J1772 connector with additional

ports to enable DCFC.

Used on some US cars for DCFC only. Vehicles

with CHAdeMO will have a second inlet
(usually J1772) for Level 1 and Level 2 charging.
Used by Tesla (for Level 1, Level 2, and DCFC)
but are becoming the standard for numerous
other manufacturers.

Public Charging Infrastructure

The availability of a publicly accessible charging network plays a critical role in promoting the
adoption of EVs in an equitable and inclusive manner. A network of widely available public charging
infrastructure offers several important benefits such as:

 Providing alternatives to at-home EVSE installation: Many individuals encounter

obstacles when attempting to install EVSE at their residences. Factors such as high
installation costs or the complexities associated with rental units and multi-family
dwellings can make it challenging. By having a comprehensive public EVSE network
in place, people may consider purchasing an EV even if they lack access to an EVSE
at home. Additionally, at-home charging may not be the most convenient charging
location for EV owners. Workplace and public charging stations provide flexible
recharging options for owners’ daily use.

 Reducing driver range anxiety: One of the most common reasons cited by drivers in
not choosing to drive an EV is the fear of running out of battery charge before
reaching the desired destination or a charging location. This fear is commonly

37
 referred to as range anxiety. A robust network of public EVSE infrastructure can
alleviate this concern by providing convenient charging options.

 Facilitating inter- and intra-state travel: To enable long-distance EV travel across the
United States, it is necessary to establish an EVSE network along major highway
corridors. The USDOT has collaborated with states to develop the Alternative Fuel
Corridors (AFC) program, which aims to identify roads on the National Highway
System as corridors for the development of infrastructure for a range of alternative
fuels, including a national network of EV chargers. NEVI formula funds can only be
spent on EVSE infrastructure on AFCs. These chargers will be fully accessible to the
public and strategically placed with sufficient density to support long distance travel
within states and across the country.

Existing State Characteristics

State Geography, Terrain, Climate, and Land Use Patterns
Geography and Terrain
Arizona is located in the southwestern part of the United States and shares borders with California,
Nevada, Utah, Colorado, and New Mexico. To the south, it borders Mexico. The western border of
Arizona is formed by the Colorado River, which flows from the Grand Canyon in the north through
Lake Mead, and passes along Bullhead City, Lake Havasu City, Parker, and Yuma in the southwestern
corner of the state.

Arizona has vast stretches of arid desert land, mainly in the central, southern, and western parts,
including the Sonoran, Chihuahuan, and Mohave deserts. Despite having extensive low-lying desert
landscapes, over half of the state’s area lies above an elevation of 4,000 feet above sea level. As you
move north and east, the elevation increases, leading to more mountainous regions characterized
by the Mogollon Rim, which diagonally cuts across the state’s higher-elevation mountainous area,
and the Colorado Plateau, where the Navajo and Hopi Tribal lands are located. Arizona boasts
internationally recognized natural landmarks such as the Grand Canyon, Painted Desert, Petrified
Forest, Chiricahua National Monument, and Monument Valley.

Geographically, Arizona can be divided into three regions: the Colorado Plateau, the Basin and
Range Province, and the Central Highlands. The northeastern part of the state is known as the
Colorado Plateau, which also extends into Utah, Colorado, and New Mexico. In Arizona, this area
consists mostly of tablelands occasionally interrupted by mesas and plateaus, exemplified by
Monument Valley. The highest peaks in the state, Humphrey’s Peak (12,633 feet) in the San
Francisco Mountains and Baldy Mountain (11,403 feet) in the White Mountains, are situated in the
southern part of the Colorado Plateau. This region then transitions into the Central Highlands,
characterized by plateaus, rugged mountain peaks, and rolling hills. The Basin and Range Province
occupies a significant portion of the Sonoran Desert, where vast open valleys provide the
environment for the expansive urban growth of major cities like Phoenix and Tucson.

Arizona possesses a diverse range of natural and built landscapes, including large urban
metropolitan areas, snow-capped volcanic peaks in the San Francisco Mountains, the sprawling
Sonoran Desert, extensive tribal lands, and the lush Coconino National Forest. These landscapes

38
offer both opportunities and limitations for efficient transportation of goods and people. Most of
Arizona’s built environments were developed after World War II and have been influenced by the
construction of faster transportation options, particularly Interstate highways. The Phoenix
metropolitan area, the fifth largest in the country, serves as the primary hub of development and
economic opportunities. The region has experienced accelerated growth, partly due to the efficient
vehicular transportation systems in place, also including Interstate highways, a modern freeway
system, and a well-developed urban arterial grid-based network.

Climate
Arizona experiences a diverse range of weather patterns that vary depending on the season and
region of the state. The weather in Arizona can be broadly categorized into two climates: The
southern and western parts of the state, including Maricopa, Yuma, Pima, La Paz, Mohave, Santa
Cruz, Pinal, Cochise, and Graham Counties, consist mainly of arid lands. Conversely, the northern
and eastern regions, including Coconino, Yavapai, Gila, Greenlee, Navajo, and Apache Counties, have
a more alpine climate.

During summer, temperatures in Arizona generally reach their peak, with daytime highs frequently
ranging from 90°F to 110°F. The hottest areas are located in the Sonoran Desert in the south,
central, and southwest regions. Summer nights typically bring temperatures between 50°F and 90°F.
These significant fluctuations between high and low temperatures contribute to a high potential for
dust storms and monsoon storms. Coupled with the dry terrain, these weather phenomena can lead
to flash floods and unsafe travel conditions.

Winters in Arizona are comparatively milder than summers, with average highs around 70°F in
lower-elevation areas. However, nighttime temperatures regularly dip below freezing. The northern
highlands, including Flagstaff, the largest city in northern Arizona, experience the most severe
winter conditions, with an average annual low temperature of 32°F.

In terms of rainfall, Arizona receives an average of 13 inches per year, with the majority occurring
during late summer and fall. The northern high elevations can experience greater rainfall, reaching
up to 20 inches annually, while the southern desert regions receive less frequent rainfall but have
late summer monsoon seasons that contribute significantly to the total yearly rainfall. Areas with
the highest annual rainfall include Payson (20 inches), Coronado National Monument (21 inches),
Flagstaff (21 inches), and Williams (22 inches). Conversely, the lowest annual rainfall is concentrated
in Western Arizona, including Parker (4.6 inches), Lake Havasu City (4.2 inches), and Yuma (3.3
inches). Snowfall is more common in the northern and eastern parts of the state, occurring between
November and March. Locations with the highest annual snowfall include Show Low (19 inches),
Grand Canyon Village (43 inches), Williams (65 inches), and Flagstaff (90 inches). Despite some of
these snowy areas having fewer inhabitants, Arizona is home to numerous popular recreational
areas that attract significant traffic even during adverse weather conditions.

Land Use
The development patterns in Arizona are closely intertwined with land use and transportation. In
the early history of the state, towns initially sprouted around and in proximity to train stops. Over
time, as technology advanced, land use patterns continued to align with transportation trends,
particularly with the rise of automobiles and, more significantly, the Interstate highway system. This
period coincided with Arizona's most prominent growth phase.

39
Land in Arizona is categorized into private, public, and state property. Approximately 18% of the
land is privately owned. The federal government owns 42% (30.3 million acres out of 72.9 million
acres) of land in Arizona, primarily allocated among the Forest Service, National Park Service, Fish
and Wildlife Service, Bureau of Land Management, Bureau of Reclamation, and the Department of
Defense. The State of Arizona itself possesses an additional 13% of land (9.6 million acres) through
the state trust, resulting in just over 51% of Arizona's land being under government control.

Moreover, Arizona encompasses extensive tribal lands, with the largest being the Navajo Nation,
spanning 17.28 million acres across northeastern Arizona, Utah, and New Mexico. Overall, 27% of
the land in Arizona (equivalent to 20.1 million acres) is occupied by 22 different tribes.

State Travel Patterns, Public Transportation Needs, Freight and Other Supply Chain Needs
In 2021, the Arizona State Highway System totaled 7,767 centerline miles, including 1,168 centerline
miles of Interstate highway. A map of the National Highway System, the road system important to
the nation’s economy, defense, and mobility, in Arizona is shown in Figure 1. Arizona’s entire
roadway network (including local roads) had 74,606 centerline miles.8
Figure 1: Arizona National Highway System

40
As EVs are increasingly adopted for private use, they are also increasingly being adopted by public
transit agencies and fleet operators. Many public transit agencies across the state have already
begun to plan for electrification of their fleets or are already in implementation phases. The Cities of
Phoenix and Tempe have begun converting their bus fleets to low-emission and zero-emission fuel
sources, with the goal of achieving a zero-emission bus fleet by 2040. 9 The City of Phoenix officially
procured the electric buses at the beginning of 2023. Phoenix and Valley Metro, the agency that
operates transit systems in the Phoenix metropolitan area, have also received a $16.3 million grant
from the Federal Transit Administration (FTA) to help fund the purchase of electric buses and
construct charging infrastructure.10 Additionally, the Phoenix Union High School District began using
electric buses in 2020 and is continuing efforts to fully transition the fleet to EVs.11 Using funds from
the FTA’s Low-No Emission Grant Program, the Sun Tran bus system and the City of Tucson have
been introducing electric buses to their already 100% clean fuel fleet.12 Mountain Line, the transit
agency in the Flagstaff area, has completed a Zero Emissions Bus Plan, and will transition their bus
fleet by 2034.13

Table 17 shows the vehicle miles traveled (VMT) along each of the NHS routes that have been
identified as AFCs.14 Approximately 17% of VMT in Arizona along the designated AFCs are attributed
to truck traffic, with significant contributions from major ports in California for cross-country
transportation on Interstate highways. The movement of goods into and within Arizona poses
additional considerations for the implementation of electric trucking statewide and the provision of
charging infrastructure along the AFCs, as these trucks will require charging as fleets transition to
electric. In 2018, freight flow in and out of the state amounted to 98 billion ton-miles (the
transportation of one ton of freight over a distance of one mile).

41
 Table 17: 2021 AFCs VMT Data
VMT per Day
Corridors
(million miles)

I-8 1.9
I-10 19.4
I-15 0.6
I-17 7.5
I-19 1.8
I-40 6.5
US 93 2.9
SR 95 2.1
SR 347 0.7
US 89 1.4
SR 87 3.0
SR 260 2.4
SR 64 0.6
Total 50.9

EV Industry and Market Conditions

The global EV market has grown over the past decade, largely attributed to increased availability,
improved vehicle range, cost competitiveness with internal combustion engine vehicles due to
maturing battery technology, and the wide availability of tax rebates and other incentives. Emission
reduction targets set by government agencies have also led to an increased focus on expanding EV
usage.

Overview and Purpose

To support Arizona’s EV market analysis, an assessment of the existing number of registered light-
duty EVs in Arizona was conducted based on current vehicle registration data, existing market
information, and EV adoption projections.

EV Ownership
ADOT reports the number of vehicles registered within Arizona, as shown in Table 18, for the
previous three fiscal years (FY20-FY23). There were 71,512 EVs registered in Arizona as of May 16,
2023, which accounts for 0.92% of all registered vehicles.

42
 Alternative fuel vehicles include those that run on electricity or other sources of energy. Arizona
Revised Statute §1-215.4 defines an alternative fuel as one of the following:

 Electric

 Natural gas/CNG or liquified petroleum gas

 Hydrogen

 Blend of 70% alternative fuels with 30% gasoline (unavailable in Arizona)

 Solar15

Vehicle sales and historical EV adoption data provide insight into future EV adoption at the localized
level.

Table 18: Arizona Vehicle Registrations by Year

2020 2021 2022 2023
 Vehicles Registered 7,828,255 7,444,032 7,764,367 TBD
o Alternative Fuel Vehicles Registered 37,477 63,147 102,793 TBD
 Electric Vehicles Registered 34,898 40,964 58,219 71,51216

To date, EVs do not represent a significant market share in Arizona, although Arizona’s share of
nationwide EV sales is greater than the national average.17 Barriers to the aggressive adoption of EVs
are likely attributed to:

 Initial capital costs: While studies show that operations and maintenance costs
throughout the lifecycle of an EV are significantly lower than those of traditional ICE
vehicles, EVs have a higher purchase cost which can be a barrier.

 Weather concerns: Extreme hot and cold temperatures can reduce EV range. In the
case of Arizona, the majority of the state’s population lives in areas that experience
mild winters, but the summers present very hot temperatures. Higher temperatures
can reduce EV range—the electricity needed for heating and cooling systems is
diverted away from the drivetrain and thus reduces the amount of onboard energy.
Given that Arizona experiences extremely hot temperatures throughout the
summer, drivers have indicated concern about range limitations.

 Range anxiety: Research has indicated that a primary barrier to EV adoption is

concern around range anxiety, the fear that their vehicle will not have sufficient
battery capacity and/or that they will not be able to easily access an EV charger to
cover their desired driving distance or reach their intended destination.

These barriers may eventually be lowered through incentives to make initial purchases of EVs more
affordable, improvements to battery capacity and vehicle range, and the expansion of the DCFC
network.

43
EV Adoption Forecast
Methodology
Industry trends, localized EV adoption factors, and historical vehicle trends in Arizona were used to
build the EV adoption forecast to estimate the anticipated rate of EV adoption and the percent of
Arizona’s anticipated passenger EV market over the next 20 years as shown in Figure 2. For each
future year modeled, the adoption forecast is recalculated based on projected changes in the EV
market of preceding years.

Figure 2: EV Adoption Forecast Methodology Flow Diagram

Annual Vehicle Adoption

Sales Traits

Historical EV EV Tech
Adoption Trends
EV
Adoption
Forecast

EV Adoption Forecast Factors

For each year modeled, an EV adoption factor was calculated representing the percentage of annual
total vehicle sales that is anticipated to be EVs. The calculation itself was developed based on two
input categories correlated to EV adoption: industry trends and state characteristics. The calculation
was also tested and refined to verify that the forecasted results aligned with both historical data and
other industry projections.

EV Tech Trends – Industry Trends

Battery technology improvements reduced upfront vehicle costs, and the development of a public
charging network are all changing the EV industry by lowering barriers to entry and further
encouraging current and future EV purchases. These trends are prerequisite to providing potential
vehicle buyers with the evidence needed to be confident that EVs are becoming as capable,
affordable, and accessible as ICEs. The projection model uses industry trends as input factors for EV
adoption, by examining model availability and initial EV capital cost when compared to an ICE
vehicle. The density of the public charging network is also utilized in the model.
EV Tech Trends - Model Availability
The expanded availability of EV options on the market gives drivers enough flexibility to select EVs
that fit within their preferences, budget, lifestyles, and preferred manufacturer. Model availability

44
was estimated using the number of currently available EV models on the market; projections
through 2040 for model availability are based on announcements and electrification commitments
from major vehicle manufacturers. Both industry trends, due to public preference as well as federal
targets and commitments to reduce emissions, suggest that manufacturers will continue progressing
toward fully electrified fleets by 2040. Figure 3 displays the model availability projections for some
of the major vehicle manufacturers.

Figure 3: EV Model Availability Forecast

450
400
350
300
EV Models

250
200
150
100
50
0
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Year

BMW Ford GM Honda Hyundai

Kia Mazda Mercedes Nissan Subaru
Tesla Toyota Volkswagen Other

EV Tech Trends – Costs

One of the primary barriers to EV adoption is the higher upfront cost of an EV when compared to an
ICE vehicle. According to Kelly Blue Book, in June 2023 the average price to purchase a new EV was
$53,438, compared to a new ICE vehicle at an average of $48,808. Despite the higher purchase
price, the current disparity between ICEs and EVs is expected to decrease and lead to increased EV
adoption. The adoption model utilizes a projected cost reduction of EVs through 2040, due to
declining battery prices, as an input. Anticipated cost competitiveness between EVs and ICEs is
expected to occur in 2025 based on the projection.

Adoption Traits – Arizona Characteristics

EV adoption varies significantly depending on numerous indicators, such as the potential
purchaser’s income, educational attainment, environmental concern, home ownership, and the
number of vehicles already owned. For example, drivers with higher levels of household income or
higher concern for the environment are more likely to purchase an EV than those with lower income
or less concern for the environment.18 These factors can vary geographically, thus they were
assessed on a localized level to yield the EV adoption outputs for Arizona.

In Arizona, the average gallon of gasoline costs $3.76 as of July 24, 2023 (higher than the national
average of $3.60).19 Due to global and national macroeconomic factors, gas prices are expected to
continue to increase or to stay elevated for the near future, which could make purchasing an EV

45
 more attractive to consumers as the difference in operating costs between EVs and ICE vehicles
continues to grow.

For EV adoption in Arizona, state level data for residents were assembled from publicly available
sources. Each factor is presented in Table 19 along with the applicable data source.

Table 19: Arizona State Characteristics that Influence EV Adoption

State Characteristic Factor Measurement Arizona Value Source

Median Household Household income $61,529 2020 US Census

Income

Environmental Election results 49% voted for a platform 2020 Federal

Concern that supported Election Results
environmental policies,
including EV infrastructure
development
3+ Car Households Number of households with 590,173 2020 Automobile
three or more cars Consumer Services
(ACS) 5-Year
Estimates
Total Households Households 2,643,430 2020 ACS 5-Year
Estimates
College Education Percentage of residents with a 30.3% 2020 US Census
Attained bachelor’s degree or higher
Homeowner Percentage of single unit 65.3% 2020 US Census
Percentage detached households in
Arizona
Vehicle Count Number of registered 4,818,711 ADOT
passenger vehicles
Existing Level 2 Ports Number of Level 2 charging 1810 Alternative Fuels
ports installed Data Center
Existing DCFC Ports Number of DCFC charging ports 459 Alternative Fuels
installed Data Center
EV Policies Policies that drive EV adoption, 19% American Council
including charging for an Energy-
infrastructure plans, Efficient Economy
emission/adoption goals,
building codes, and incentives.
Arizona value based on EV
programs available compared

46
State Characteristic Factor Measurement Arizona Value Source

to other states as detailed in

the source.
Annual Vehicle Sales Arizona share of new vehicle 2.19% National
registrations in the United Automobile
States Dealers Association
Historical EV Number of registered EVs in 2019: 28,770 ADOT
Adoption Arizona
2020: 34,898
2021: 40,964
2022: 58,219
2023: 71,512

EV Adoption Forecast Assumptions

The following key assumptions were made to forecast EV adoption through the year 2040:

● Between 2035 and 2040, car manufacturers will exceed current EV commitments by electrifying
their full fleet, including all sedans, SUVs, and trucks.

● Operational and maintenance costs are not included as consumers are typically more concerned
with the initial price (rather than full life-cycle costs) when determining which vehicle type to
purchase, although it should be noted that the recent significant surge in gas prices has begun to
shift this consumer mindset.

● Battery technology will mature by 2030, leading to upfront cost declines of EVs. Beyond 2030,
costs are assumed to be constant.

● An optimal amount of charging infrastructure will be developed to meet the estimated increase
in adoption (e.g., 4 DCFCs per 1,000 EVs, 60 public Level 2 chargers per 1,000 EVs, and at-home
charging is available for homeowners).20 Each year, the expanded charging network
infrastructure is used as the input factor for adoption for the subsequent year being modeled as
an iterative process.

● Vehicle sales are constant throughout 2040 as total new vehicles sales have remained generally
constant in the United States between 2015-2019; however, impacts from COVID-19 and policy
pressure to further encourage EV adoption may impact this assumption in the future.21

EV Adoption Scenarios
Three scenarios were analyzed to identify the potential magnitude of growth in EV adoption due to
economic and policy trends. The scenarios are defined in Table 20. These scenarios were applied to
the EV adoption forecasts to quantify the range of potential EV adoption in Arizona. Due to the
current economic factors and supply chain shortages, the low-growth scenario describes current

47
 circumstances; however, recent EV policy direction and the long-term outlook for widespread EV
adoption required the analysis of medium- and high-growth scenarios as well.

Table 20: EV Market Model Growth Scenarios

Growth Scenario Description

Low Reduce model availability by 25% compared to the medium projection. This
scenario accounts for supply shortages of EV components.

Medium Scale high-growth scenario to better align with historical EV adoption trends. This
scenario accounts for the unique EV adoption factors in Arizona and projections
of the EV market into the future.

High Increase in the cost parity of an EV compared to an ICE vehicle by 25% compared
to the medium projection to reflect rising gas prices. This scenario reflects other
policies and infrastructure deployment to meet a high-growth projection of 1.5
million EVs on the road in 2038.22

Findings
The model generated estimates for Arizona’s EV adoption based on the three growth scenarios (as
shown in Figure 4. EV adoption estimates for 2030 range between 6%–14% of the total Arizona
passenger vehicle market being electric, with 11%–25% of new sales being EVs. For comparison,
forecasts predict 9% of the country’s fleet will be electric in the same time period, with 36% of new
sales being EVs; this is driven by recent federal government targets of 50% of all vehicle sales to be
EVs by 2030.23, 24

Figure 4: Expected EV Adoption in Arizona, 2020-2040 Total Registrations

2,500
EVs Registered (thousands)

2,000
Scenarios:
1,500
High Adoption
1,000 Med Adoption
Low Adoption
500

0
2015 2020 2025 2030 2035 2040 2045
Year

48
 Figure 5: Expected EV Adoption in Arizona, 2020-2040 by New Sales
100%
90%
80%
70%
Scenarios:
60%
EVs Sold

50% High Adoption

40% Med Adoption
30%
Low Adoption
20%
10%
0%
2015 2020 2025 2030 2035 2040 2045
Year

Table 21: Expected In-State EV Adoption

EV Estimate 2030 EV Estimate 2040

Growth Scenario EVs Registered In-state EV EVs Registered In-state EV

Market % Market %

Low 307,897 6.4% 864,991 18.0%

Medium 402,293 8.3% 1,145,084 23.8%

High 678,920 14.1% 1,944,045 40.3%

Understanding of factors driving EV adoption are key when comparing the different growth
scenarios.

 EV models are directly correlated with the number of EVs registered. The low-
growth scenario assumes a 25% reduction in EV models available compared to the
medium-growth scenario, resulting in only three-quarters as many EVs on the road.
EV model availability is a primary factor in any adoption increases, as ICE models are
expected to become rare if manufacturers begin to offer only EVs.

 As the initial price of EVs continues to reach parity with ICE vehicles, new EV sales
continue to rise in the near-term. The rate of growth of EV sales will begin to slow,
though still continue to increase if EVs become the more economical option;
modeling indicates that this period of slower growth is mostly due to an anticipated
lack of new EV models being introduced between 2026 and 2035, and the modeling
assumption that rapid EV model development does not begin until 2035.

 While new EV sales are expected to continue to rise annually, growth will be
tempered since vehicle fleet stock takes a significant amount of time to turn over

49
 (even in the most aggressive scenario). For example, ICEs have an average vehicle
life of approximately ten years.

The most likely growth scenario for Arizona over the analysis period is the medium forecast.
Continued deployment of EV charging infrastructure, education on the benefits of EVs, federal and
local government policy support, and financial assistance will support the forecasted adoption rate.

Recommendations and Considerations

Based on the existing and future conditions assessment, recommendations and considerations are
as follows:

 By the year 2030, the medium-growth scenario predicts 402,293 vehicles (8.3%) on
Arizona roadways to be EVs. This is expected to be the most likely forecast scenario,
as it aligns with historical adoption data and is reflective of federal policies and local
governments’ trends to encourage EV adoption. However, due to lingering COVID-
19 impacts and current supply chain storages, this trend may start as a low-growth
scenario in the near-term, then develop into the medium-growth scenario. To
achieve the high-growth scenario, aggressive state and federal policies would need
to be enacted to further encourage EV adoption.

 Despite Arizona currently having a small number of EVs on the road, all growth
scenarios predict that the number of EVs will at least double between 2021 and
2023. The active participation of the Arizona state government, including its
coordination with local jurisdictions and electric utilities, is critical to supporting this
transition by following best practices to plan for and accelerate EV adoption.
Potential initiatives include developing EV readiness plans, providing educational
materials, hosting workshops to facilitate cross-stakeholder collaboration (to share
best practices and help streamline efforts across the state), or adopting state EV-
adoption targets.

 Policy levers may be utilized to accelerate adoption rates and turn over existing
vehicle stock more quickly, and they could include early vehicle retirement
programs or incentives on new vehicle purchases.

 The long-term COVID-19 pandemic impacts may hinder EV adoption due to

economic constraints on individual households and the global automobile market.
These impacts should be considered along with any additional EV adoption barriers
that may be faced, particularly by disadvantaged or vulnerable populations.
Comprehensive electrification considerations—such as incentives for the purchase
of EVs, expanded funding sources, partnerships, and streamlined permitting
processes—can all support reducing barriers to electrification. The overall EV
adoption trends are expected to remain fairly consistent based on current
projections, and the trends point toward an increasingly aggressive nationwide
electrification trajectory to reduce emissions and promote public health.

50
Arizona Charging Demand Analysis
To properly plan for future EV needs, it is important to understand and forecast anticipated charging
infrastructure demands.

Widespread EV adoption can bring benefits to both individuals and the environment, but there is
also a significant challenge in ensuring the availability of an adequate network of public charging
infrastructure to meet the growing charging demand. Meeting this demand also poses the issue of
ensuring local electric utilities can continue to provide reliable service even with the added load of
transportation electrification. If not properly planned for, the impacts resulting from increased
electrification on the charging network and impacts to electricity demand can lead to rising
electricity prices, grid constraints, and blackouts.

Charging Demand Methodology

The charging demand analysis was conducted using traffic data relevant to the AFCs, taking into
account the results from the EV market analysis. The analysis calculated the expected annual
electricity consumption of EVs traveling on the AFCs through the year 2040 and accounted for traffic
pattern changes, anticipated improvements to battery economy, and the impacts of Arizona
weather conditions on EV performance. The calculation steps were:

 Utilize the EV adoption forecast to estimate statewide EV traffic using existing

average annual daily traffic (AADT) data and applying an annual average growth
rate.

 Calculate the AADT of EVs traveling on each individual AFC to understand charging
demand needs.

 Calculate the yearly energy consumption factor by multiplying the mileage by the
estimated fuel efficiency (in kWh/mile).

EV Traffic and Mileage

ADOT records daily passenger vehicular traffic and mileage data for each highway corridor, as shown
in Table 22. Daily VMT were calculated by multiplying the corridor segments’ length (in miles) by the
AADT. To account for increases in traffic resulting from population and economic growth, a 2.1%
average annual growth rate was assigned to both the AADT and VMT.25

51
 Table 22: AADT of EVs in Arizona, 2021
Length of
Forecast 2040 AADT
Corridor Corridor 2021 AADT (miles)
(miles)
(miles)

I-8 178.3 11,130 16,950

I-10 391.2 49,730 75,740
I-15 29.4 23,270 35,450
I-17 146.5 51,710 78,760
I-19 63.1 29,020 44,210
I-40 359.6 18,190 27,700
US 93 199.4 14,760 21,906
SR 95 116.5 18,101 26,865
SR 347 28.7 25,455 37,779
US 89 136.5 10,445 15,503
SR 87 272.7 11,177 16,589
SR 260 217.8 10,919 16,206
SR 64 108.3 5,143 7,633

To determine the future EV AADT, forecasted totals of passenger EVs traveling in Arizona by the year
2040 was used. It should be noted that values are anticipated to change annually due to changes in
EV adoption. For this analysis, it was assumed that the percentage of EVs in Arizona’s vehicle fleet is
equal to EV AADT as a percentage of statewide AADT.

Annual EV energy consumption was calculated by applying an average battery capacity (in
kWh/mile) for passenger EV vehicles to the known AADT on the routes.26 The resulting value
represents the amount of electricity an EV is estimated to consume on each designated travel
corridor; additional mileage is accumulated traveling to and from the corridor.

Figure 6 displays the expected average battery energy consumption of light-duty passenger vehicles
(e.g., sedans, SUVs, and trucks) and are based on current EV specifications and forecasted future
improvements. Battery fuel economy is assumed constant after 2030 due to limitations on our
knowledge of standards and technology improvements past that point.

52
 Figure 6: Forecast of EV Battery Energy Consumption
450.00
Average Battery Energy Consmption
400.00
350.00
300.00
(mi/kWh)

250.00
200.00
150.00
100.00
50.00
0.00
2015 2020 2025 2030 2035 2040 2045
Year

Localized Weather Impacts

As weather impacts can affect battery range, it is important to account for localized weather
patterns. Arizona experiences a broad range of temperatures throughout the state, throughout the
year, and between day and night. EV performance can be affected by weather due to energy from
the vehicle’s battery being used to support cooling and heating systems (to condition both the
vehicle cabin and to maintain battery temperature) in addition to standard propulsion, which leads
to decreased travel range. Studies show that an ambient temperature of 20° F results in a 41%
reduction in driving range, while a temperature of 95° F results in a 17% reduction (both results
compared to testing at 75° F). 27 Other factors, such as elevation, wind, and precipitation affect
vehicle range; however, these other factors are taken into consideration in the annual fuel efficiency
metric.

Charging Demand Results

The charging demand analysis estimates that EVs will account for between 3.0 million and 6.6
million miles of interstate travel daily in Arizona by the year 2030. A significant amount of electricity
would be required to recharge the vehicles under assumed vehicle efficiencies, estimated to be
between 684 gigawatt hours (GWh) and 1,509 GWh as seen in Figure 7. Much of this electricity will
be consumed through home or workplace charging; however, this underlies the importance of
deploying a public DCFC network capable of supporting EV growth.

53
 Figure 7: Forecasted EV Energy Consumption

Electric Grid Capacity

The high-power output of DCFC requires adequate capacity on the electrical grid and specific
electrical service conditions such as three-phase power. An understanding of where three-phase
service and adequate electrical capacity exists will play a critical role in identifying sites for proposed
charging stations. Sites that do not have adequate electrical conditions will need to be upgraded,
adding to the cost and timeline of deployment. ADOT currently lacks data on available grid capacity
but plans to collaborate with Arizona electric utilities to understand grid conditions at the proposed
sites. A utility capacity survey was issued to each utility in July 2022 and 2023 to identify if charger
sites identified for upgrade or construction can accommodate the added power capacity for
charging infrastructure. Coordination with utilities on substation capacity is still ongoing; Appendix C
provides latest responses on newly proposed charging stations. Following engagement, ADOT may
revise the proposed sites if constraints are identified. Additionally, a meeting was held on July 20,
2023, to coordinate with utilities. ADOT will continue to collaborate with utilities throughout the
planning and deployment stages of the NEVI program.

Known Risks and Challenges

Table 23 lists the risks and challenges identified in Arizona regarding the deployment of EV charging
infrastructure.

Table 23: Known Risks and Challenges

Risk/Challenge Description Mitigation

Staffing The Plan implementation will require a Continue to develop a

significant number of ADOT staff, including contracting mechanism that
environmental, cybersecurity, contracts, enables effective
legal, and project management, as well as implementation of the Plan
staff to monitor contractor performance, with existing staff.
collect data, and prepare federal reports.
NEVI funds cannot be used to create and fill

54
Risk/Challenge Description Mitigation

new staff positions and ADOT is unlikely to

have the resources to create new positions
specifically for this program.

Stranded Assets To close gaps and help to meet needs of Develop contracting
underserved communities, some stations will mechanisms that require
be placed in rural, tribal, and/or low-income private companies to own the
communities; these areas might initially have stations and keep them
low station utilization and may be running long-term.
unprofitable for some time, but their
installation is required for sufficient
infrastructure coverage. Private businesses
selected to implement the EV Plans may
abandon stations if they prove unprofitable.

Equity The stations that are most profitable and Bundle several stations, entire
easiest to develop have already been built by corridors, and/or geographic
private companies. Many proposed EV areas into a single contract to
station locations are in rural, tribal, and make development more
underserved areas that have not attracted attractive.
private developers.

Cybersecurity Cyber-attacks are a risk to customers' Develop and maintain a robust

financial transaction data, personal data, and cybersecurity plan throughout
vehicle-connected devices. Any identified the lifetime of the
EVSE vulnerabilities can introduce the infrastructure. Include
potential of malware installation and requirements from the plan in
propagation to vehicles, charging all applicable contracts.
infrastructure, and other connected
technologies. Exposing equipment to
breaches in cybersecurity can put payment
data and personal information of the
customer at risk, and also present risks to the
charging network and electrical grid.

Location Viability and Some proposed infrastructure locations Prepare permits and
Permitting might be space-constrained and/or on agreements in clear language
private/leased property. and streamline permitting
processes. Consider space
constraints during the

55
Risk/Challenge Description Mitigation

selection and design of

potential EV station sites.. All
real property acquisitions must
comply with The Uniform
Relocation Assistance and Real
Property Acquisition Act per
NEVI guidance. These projects
are considered construction
projects, so Title 23
requirements apply, including
acquiring adequate property
interests.

Charger Types Multiple connector types exist for DCFC Consider connectors and/or
charging. Inclusion of only one type might adapters that can be used by
exclude certain vehicles from being able to different vehicles. Consider
utilize the charging infrastructure. including NACS connectors, if
feasible.

Communication All chargers will be networked, and any loss Include up-time performance
Reliability of connection would result in the charger(s) metrics of charging
going out of service. infrastructure in operating
contracts to maintain a very
high level of reliability, which
could include redundancies of
different networks if the
primary network goes down.

Unbanked Not everyone has access to a credit/debit Consider the feasibility and
Population card as some of the population remains utility of alternative payment
unbanked. methods, such as prepaid
debit cards. Require charging
stations to accept payment
through an automated toll-
free phone number or a short
messaging service (SMS), per
NEVI requirements.

Demand Charges During peak period usage, it is more costly to Consider software at charging
provide electricity. Utility providers may add stations to allow for variable
additional demand charges on top of pricing. This would help to
manage peak demand and

56
Risk/Challenge Description Mitigation

standard electricity prices to compensate for minimize operating costs while

the increased delivery costs. still providing adequate levels
of charging.

Vandalism and Charging stations could be vandalized if not Implement security features
Damage properly secured or damaged from improper such as protective bollards,
use (e.g., vehicle crash, driving over charging retractable cords, vandal-proof
cords). chargers, closed circuit
television.

Supply Chain All 50 states are simultaneously procuring Actively plan for and
Shortages and deploying NEVI-compliant infrastructure, incorporate longer than
which could further exacerbate existing expected lead times for the
supply chain issues. procurement of materials
when developing schedules.

Extreme Weather During the extreme heat of the summer Require contractors to
and Battery Fires months, EVs are more susceptible to lithium- establish mitigation strategies,
ion battery fires. These fires are difficult to such as adequate fire
extinguish. During extreme heat or cold, EV suppression. Build station
range declines as the vehicle uses battery locations to provide sufficient
power for heating or cooling, rather than availability of chargers.
propulsion.

Changing Technology EV technology is rapidly evolving and could Futureproof new station
quickly outpace currently available EV locations by adding larger
infrastructure. conduits and other cost-
effective improvements to
enable future upgrades.
Consider requiring chargers
that operate at 400 and 800
volts.

Incentives
Arizona offers a variety of incentives (both monetary and policy oriented) to encourage low and
zero-emission vehicle adoption. They are typically stated in relation to AFVs to be more
encompassing than just EVs, but in some cases include hybrid vehicles.

57
State
ADOT issues special license plates dedicated to AFVs that are powered by propane, compressed
natural gas (CNG), electricity, or hydrogen. The plates provide eligible drivers with incentives for
driving AFVs, including the ability to park without penalty in parking areas designated for carpool
operators and in spaces designed for EV charging.28,29 Similarly, Arizona Revised Statute 28-2416
allows qualified AFVs to use high-occupancy vehicle lanes, regardless of the number of occupants,
although this exemption will expire in September 2025.30 Owners of qualified AFVs that are
registered in Arizona for the first time are not required to complete emissions testing in their first
year only, unless they are used for commuting into Phoenix or Tucson.31
A financial incentive is also currently provided. Alternative fuel vehicles purchased in 2022 or earlier
have a reduced annual vehicle license tax assessment based on a percent of the suggested retail
price.32
Private Incentives
Utility providers within Arizona offer various incentives and rebates to encourage development of
the charging infrastructure network. APS operates the Take Charge AZ pilot program which offers
free EV infrastructure and services.33 APS does not pay for the energy used, but does help
businesses, fleets, and multi-family complexes access EV charging infrastructure by installing
charging stations and cables, establishing services, educating staff, and conducting check-ups on
equipment.
Salt River Project and Navopache Electric Cooperative offer residential customers who operate an
EV or plug-in hybrid vehicle the opportunity to use time-of-use electricity rates for at-home charging
during super off-peak hours (11pm to 5am, year-round) and additional off-peak hours (non-peak
hours that vary by season) on weekends, holidays, and some weekday hours. A separate smart
submeter is required for EV charger usage and is provided by SRP.34 SRP also has rebates for
commercial users and offers funding to trained vendors who study electrification. These
opportunities can be for commercial non-road equipment through the Electric Qualified Service
Provider Assessment Program and on-road electrification opportunities for fleets under the Fleet
Advisory Services Program.35
On the infrastructure side, SRP provides rebates for installing charging infrastructure. SRP has a
marketplace for individuals to purchase Level 2 chargers with instant rebates applied at the time of
purchase. Businesses can receive $1,500 per networked Level 2 charging station port. Government,
non-profit, and school customers can receive $4,000 per Level 2 port. The amount increases to
$15,000 per DCFC port for businesses and $20,000 per DCFC port for government, non-profits and
school customers. Rebates are limited to three DCFC ports per customer per program year. Electrical
District No. 3 is also providing a $250 rebate to commercial and residential customers for purchase
of Level 2 charging equipment.
In February 2023, Unisource Electrical Service approved its three-year plan to provide at-home EV
charger incentives for its residential customers. These include a $500 rebate on home charger
installation, and up to $800 for lower-income customers. They are also introducing residential and

58
 commercial EV rates similar to SRP, allowing customers lower rates during off-peak hours when
energy demand is lower.36 At the time of writing of this Plan, Navajo Tribal Utility Authority (NTUA)
and Page Utility had yet to offer electric vehicle-based incentives.

Compliances
ADOT is working to meet federal requirements. Under the Code of Federal Regulations, Title 23 Part
680 – NEVI Standards and Requirements (23 CFR § 680), specifications are described to ensure safe
public access to EV charging infrastructure. These regulations include:

- Charging stations must provide secure payment methods;

- Implementation of cybersecurity strategies to safeguard user identities and access

management;

- Mechanisms for customers to report charging station issues;

- Up-to-date charger hardware;

- Periodic data reports; and

- Secure communication between charging networks, electric utilities, and energy

providers.

Alternative Fuel Corridor Designations

Since 2016, FHWA has accepted nominations from state departments of transportation, including
ADOT, for AFCs. Those considered “corridor ready” contain enough fueling facilities to enable travel
with the designated alternative fuel; those considered “corridor pending” lack sufficient existing
facilities to support alternative fuel vehicle (AFV) travel. Arizona’s AFCs are presented in list format
in Table 24 and in map format in Figure 8.

Table 24: Arizona AFC

Status Corridor Name Location

2023: Nominated but not yet approved by FHWA

US 93 Kingman to the Nevada border
SR 95 I-40 to Quartzsite
SR 347 Maricopa to I-10
Corridor Pending US 89 Flagstaff to Utah
SR 87 Phoenix to Payson
SR 260 Payson to Show Low
SR 64 I-40 to Grand Canyon National Park
2022: Designated as AFCs by FHWA

59
Status Corridor Name Location

AZ/Mexico border to I-19/I-10 interchange in

Corridor Pending I-19
Tucson (includes all of I-19))
I-10 Buckeye to Benson
West Anthem Way in Phoenix to Camelback
Corridor Ready I-17
Road in Phoenix
I-40 I-40/I-17 interchange in Flagstaff to Winslow
AZ/CA border to the I-8/1-10 interchange in Casa
I-8
Grande
AZ/CA border to Buckeye and between the
I-10
AZ/NM border and Benson

Corridor Pending I-17/I-10 interchange in Phoenix to Camelback

I-17 Road in Phoenix; and from Camelback Road in
Phoenix to the I-17/I-40 interchange in Flagstaff
AZ/CA border and I-40/I-17 interchange in
I-40 Flagstaff; and between the AZ/NM border and
Winslow
Corridor Ready I-15 AZ/Nevada border to the AZ/UT border
Corridor Ready I-10 Tucson to Phoenix
AZ/NM border to Tucson and from the AZ/CA
I-10
Corridor Pending border to Phoenix
I-17 Phoenix to Flagstaff
Source: https://www.fhwa.dot.gov/environment/alternative_fuel_corridors/

60
 Figure 8: Arizona Alternative Fuel Corridors

Existing Charging Stations

Table 25 presents the existing locations of Level 2 and DCFC (Level 3) charging infrastructure along
the AFCs as of June 29, 2023. Figure 9 displays Interstate charging locations on a map of Arizona.
Although the Plan is focused on the deployment of DCFC, Level 2 chargers are also listed in Table 25
because they support the EV charging network.

61
 Table 25: Locations of Existing Charging Infrastructure Along AFCs (as of 6/29/2023)
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

Existing Stations Identified Along 2023 AFCs

ChargePoint TBD No
612 L2 US 89 Flagstaff 2
Network
ChargePoint TBD No
173230 L2 US 89 Flagstaff 2
Network
212778 L2 US 89 Flagstaff 4 Non-Networked TBD No
254406 DCFC US 89 Flagstaff 24 Tesla TBD Yes
Grand TBD No
Canyon
103563 L2 SR 64 2 Non-Networked
National
Park
Grand TBD No
Canyon
103565 L2 SR 64 2 Non-Networked
National
Park
Grand TBD No
Canyon
150677 L2 SR 64 6 Tesla Destination
National
Park
Grand TBD No
Canyon
190528 L2 SR 64 2 Non-Networked
National
Park
Grand TBD No
Canyon SemaCharge
194725 L2 SR 64 2
National Network
Park
Grand TBD No
Canyon
227697 L2 SR 64 2 Non-Networked
National
Park
187213 L2 US 93 White Hills 2 Blink Network TBD No

62
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

39855 L2 SR 95 Parker 1 Non-Networked TBD No

112778 L2 SR 95 Parker 3 Tesla Destination TBD No
ChargePoint TBD No
189253 L2 SR 95 Parker 2
Network
112779 L2 SR 260 Payson 1 Tesla Destination TBD No
117722 DCFC SR 260 Payson 12 Tesla TBD Yes
237677 L2 SR 260 Show Low 1 CHARGELAB TBD No
Existing Stations Identified Along 2022 AFCs
39853 Level 2 I-10 Avondale 1 Non-Networked TBD No
2 each TBD No
39861 Both I-10/I-17 Phoenix Non-Networked
(4 total)
1 each TBD No
39863 Both I-10 Tempe Non-Networked
(2 total)
ChargePoint TBD No
61294 Level 2 I-10 Chandler 2
Network
ChargePoint TBD No
61295 Level 2 I-10 Chandler 2
Network
ChargePoint TBD No
66290 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
66794 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
76160 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
76161 Level 2 I-10 Phoenix 2
Network
76907 Level 2 I-40 Flagstaff 2 AmpUp TBD No
ChargePoint TBD No
79956 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
80014 Level 2 I-10 Phoenix 2
Network

63
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

ChargePoint TBD No
85633 Level 2 I-10 Phoenix 2
Network
95292 Level 2 I-10 Phoenix 4 Blink Network TBD No
95412 Level 2 I-10 Phoenix 1 Blink Network TBD No
95568 Level 2 I-17 Phoenix 2 Blink Network TBD No
95706 Level 2 I-10 Phoenix 7 Blink Network TBD No
95707 Level 2 I-10 Phoenix 2 Blink Network TBD No
95738 Level 2 I-10 Phoenix 1 Blink Network TBD No
95880 Level 2 I-10 Tucson 1 Blink Network TBD No
95964 Level 2 I-10 Phoenix 2 Blink Network TBD No
96019 Level 2 I-10 Phoenix 4 Blink Network TBD No
96059 Level 2 I-10 Phoenix 2 Blink Network TBD No
96060 Level 2 I-17 Phoenix 1 Blink Network TBD No
96100 Level 2 I-17 Phoenix 2 Blink Network TBD No
96383 Level 2 I-10 Tempe 1 Blink Network TBD No
101980 DCFC I-10 Buckeye 8 Tesla TBD No
101981 DCFC I-10 Casa Grande 6 Tesla TBD No
101982 DCFC I-40 Flagstaff 12 Tesla TBD No
101984 DCFC I-40 Holbrook 12 Tesla TBD No
101985 DCFC I-40 Kingman 10 Tesla TBD No
101986 DCFC I-17 Mayer 8 Tesla TBD No
101989 DCFC I-17 Phoenix 16 Tesla TBD No
101990 DCFC I-10 Quartzsite 36 Tesla TBD No
101994 DCFC I-10 Tucson 10 Tesla TBD No
101996 DCFC I-10 Willcox 8 Tesla TBD No
101997 DCFC I-8 Yuma 8 Tesla TBD No
ChargePoint TBD No
104200 Level 2 I-17 Phoenix 1
Network

64
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

112761 Level 2 I-40 Flagstaff 3 Tesla Destination TBD No

112762 Level 2 I-40 Flagstaff 1 Tesla Destination TBD No
112763 Level 2 I-40 Flagstaff 1 Tesla Destination TBD No
112764 Level 2 I-40 Flagstaff 3 Tesla Destination TBD No
112765 Level 2 I-40 Flagstaff 2 Tesla Destination TBD No
112770 Level 2 I-40 Kingman 2 Tesla Destination TBD No
112783 Level 2 I-10 Phoenix 2 Tesla Destination TBD No
112831 Level 2 I-10 Tucson 3 Tesla Destination TBD No
112832 Level 2 I-40 Winslow 1 Tesla Destination TBD No
114851 Level 2 I-15 Mesquite 3 Tesla Destination TBD No
ChargePoint TBD No
118886 DCFC I-40 Flagstaff 1
Network
121828 DCFC I-10 Buckeye 4 Electrify America TBD Yes
121833 DCFC I-8 Yuma 4 Electrify America TBD No
Petrified ChargePoint TBD No
122218 Level 2 I-40 2
Forest Network
122249 DCFC I-8 Gila Bend 8 Tesla TBD No
122359 Level 2 I-10 Phoenix 6 Tesla Destination TBD No
123009 DCFC I-40 Williams 1 Non-Networked TBD No
123483 DCFC I-10 Benson 4 Electrify America TBD Yes
124348 DCFC I-17 Anthem 4 Electrify America TBD Yes
127934 DCFC I-40 Flagstaff 4 Electrify America TBD Yes
135874 DCFC I-40 Winslow 4 Electrify America TBD Yes
145281 Level 2 I-10 Phoenix 2 Volta TBD No
ChargePoint TBD No
145653 Level 2 I-10 Phoenix 2
Network
145749 DCFC I-10 Tucson 10 Electrify America TBD Yes

65
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

ChargePoint TBD No
146891 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
146892 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
147040 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
147041 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
147083 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
147118 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
147121 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
147458 Level 2 I-10 Phoenix 2
Network
149194 DCFC I-10 Tempe 8 Electrify America TBD Yes
2 each TBD No
150334 Both I-10 Phoenix Blink Network
(4 total)
151953 DCFC I-17 New River 10 Tesla TBD No
153411 DCFC I-10 Ehrenberg 8 Tesla TBD No
154797 DCFC I-8 Tacna 8 Tesla TBD No
ChargePoint TBD No
156367 Level 2 I-10 Goodyear 2
Network
SemaConnect TBD No
164142 Level 2 I-10 Chandler 2
Network
164254 Level 2 I-10 Phoenix 3 Blink Network TBD No
SemaConnect TBD No
164351 Level 2 I-40 Williams 2
Network
SemaConnect TBD No
164414 Level 2 I-10 Tucson 4
Network

66
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

ChargePoint TBD No
164787 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
165214 Level 2 I-10 Buckeye 2
Network
ChargePoint TBD No
166787 Level 2 I-10 Goodyear 2
Network
ChargePoint TBD No
167342 Level 2 I-40 Flagstaff 2
Network
ChargePoint TBD No
167343 Level 2 I-40 Flagstaff 2
Network
168622 Level 2 I-40 Kingman 2 Tesla Destination TBD No
168689 Level 2 I-10 Phoenix 4 Tesla Destination TBD No
168691 Level 2 I-40 Flagstaff 2 Tesla Destination TBD No
168702 Level 2 I-10 Chandler 2 Tesla Destination TBD No
168741 Level 2 I-8 Gila Bend 4 Tesla Destination TBD No
168852 Level 2 I-40 Williams 5 Tesla Destination TBD No
169028 Level 2 I-10 Phoenix 1 Tesla Destination TBD No
169228 Level 2 I-10 Phoenix 4 Tesla Destination TBD No
169240 Level 2 I-10 Phoenix 3 Tesla Destination TBD No
169411 DCFC I-8 Dateland 4 Electrify America TBD Yes
170168 Level 2 I-10 Phoenix 3 Blink Network TBD No
ChargePoint TBD No
171760 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
171771 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
171772 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
171839 Level 2 I-10 Phoenix 2
Network

67
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

ChargePoint TBD No
171845 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
171846 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
171928 Level 2 I-10 Phoenix 1
Network
ChargePoint TBD No
173956 DCFC I-10 Chandler 1
Network
ChargePoint TBD No
174635 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
175685 Level 2 I-10 Goodyear 2
Network
ChargePoint TBD No
182918 Level 2 I-10 Tucson 1
Network
ChargePoint TBD No
182919 Level 2 I-10 Tucson 1
Network
ChargePoint TBD No
182920 Level 2 I-10 Tucson 1
Network
ChargePoint TBD No
182921 Level 2 I-10 Tucson 1
Network
184916 DCFC I-40 Williams 4 Electrify America TBD Yes
185095 Level 2 I-40 Flagstaff 2 Non-Networked TBD No
185098 DCFC I-17 Phoenix 1 Non-Networked TBD No
ChargePoint TBD No
186033 Level 2 I-17 Phoenix 2
Network
ChargePoint TBD No
186034 Level 2 I-17 Phoenix 2
Network
186193 Level 2 I-10 Goodyear 1 Non-Networked TBD No
186198 Level 2 I-17 Phoenix 2 Non-Networked TBD No
186348 Level 2 I-10 Phoenix 3 Non-Networked TBD No
186349 Level 2 I-10 Tempe 1 Non-Networked TBD No

68
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

186350 Level 2 I-10 Chandler 2 Non-Networked TBD No

186351 Level 2 I-10 Chandler 1 Non-Networked TBD No
ChargePoint TBD No
187569 Level 2 I-10 Phoenix 2
Network
187879 DCFC I-40 Kingman 4 Electrify America TBD Yes
187884 Level 2 I-10 Phoenix 4 Blink Network TBD No
187948 DCFC I-10 Quartzsite 4 Electrify America TBD Yes
189037 Level 2 I-10 Tucson 2 Blink Network TBD No
189311 Level 2 I-8 Yuma 2 Blink Network TBD No
1 each TBD No
189658 Both I-10 Phoenix Blink Network
(2 total)
189685 DCFC I-10 Tucson 4 Non-Networked TBD No
ChargePoint TBD No
190647 Level 2 I-10 Phoenix 2
Network
191561 DCFC I-10 Chandler 4 Electrify America TBD Yes
ChargePoint TBD No
193276 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
193277 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
193278 Level 2 I-10 Phoenix 2
Network
ChargePoint TBD No
193279 Level 2 I-10 Phoenix 2
Network
195717 Level 2 I-10 Phoenix 2 Blink Network TBD No
195718 Level 2 I-17 Phoenix 4 Blink Network TBD No
195719 Level 2 I-17 Phoenix 2 Blink Network TBD No
195724 Level 2 I-10 Phoenix 2 Blink Network TBD No
ChargePoint TBD No
195733 Level 2 I-10 Tucson 2
Network

69
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

ChargePoint TBD No
195734 Level 2 I-10 Tucson 2
Network
ChargePoint TBD No
196011 Level 2 I-40 Flagstaff 2
Network
ChargePoint TBD No
196012 Level 2 I-40 Flagstaff 2
Network
SemaConnect TBD No
198039 Level 2 I-10 Tucson 2
Network
198261 DCFC I-10 Tempe 1 EVgo Network TBD Yes
198884 DCFC I-10 Casa Grande 1 EVgo Network TBD Yes
ChargePoint TBD No
201449 Level 2 I-40 Flagstaff 2
Network
ChargePoint TBD No
201450 Level 2 I-40 Flagstaff 2
Network
201865 Level 2 I-40 Holbrook 2 Blink Network TBD No
202355 Level 2 I-8 Yuma 4 Non-Networked TBD No
202359 Level 2 I-10 Phoenix 4 Non-Networked TBD No
202365 Level 2 I-40 Flagstaff 4 Non-Networked TBD No
202369 Level 2 I-40 Holbrook 4 Non-Networked TBD No
202371 Level 2 I-10 Goodyear 4 Non-Networked TBD No
202372 Level 2 I-17 Phoenix 4 Non-Networked TBD No
202374 Level 2 I-17 Phoenix 4 Non-Networked TBD No
202383 Level 2 I-10 Phoenix 4 Non-Networked TBD No
202395 Level 2 I-10 Casa Grande 2 Volta TBD No
ChargePoint TBD No
205051 Level 2 I-10 Avondale 2
Network
ChargePoint TBD No
205372 DCFC I-19 Green Valley 1
Network
205566 DCFC I-40 Kingman 14 Tesla TBD No

70
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

ChargePoint TBD No
205762 Level 2 I-10 Avondale 2
Network
ChargePoint TBD No
206318 Level 2 I-8 Yuma 2
Network
ChargePoint TBD No
206319 Level 2 I-8 Yuma 2
Network
ChargePoint TBD No
206479 Level 2 I-10 Tucson 2
Network
206610 DCFC I-10 Tucson 16 Tesla TBD No
ChargePoint TBD No
207198 DCFC I-10 Avondale 1
Network
ChargePoint TBD No
207199 DCFC I-10 Avondale 1
Network
ChargePoint TBD No
207804 Level 2 I-10 Tempe 1
Network
ChargePoint TBD No
207805 Level 2 I-10 Tempe 1
Network
ChargePoint TBD No
207806 Level 2 I-10 Tempe 1
Network
ChargePoint TBD No
207807 Level 2 I-10 Tempe 1
Network
ChargePoint TBD No
211831 Level 2 I-19 Green Valley 1
Network
ChargePoint TBD No
211832 DCFC I-19 Green Valley 1
Network
212779 Level 2 I-40 Winslow 4 Non-Networked TBD No
212782 Level 2 I-10 Goodyear 4 Non-Networked TBD No
213154 Level 2 I-17 Phoenix 8 Non-Networked TBD No
ChargePoint TBD No
217183 Level 2 I-40 Flagstaff 2
Network

71
State EV Meets all Intent to
Charger Number of
Charging relevant count towards
Level (DCFC, Route Location EV EV Network
Location requirements Fully Built Out
L2) Connectors determination?
Unique ID in 23 CFR 680?

ChargePoint TBD No
217184 Level 2 I-40 Flagstaff 2
Network
All State EV Charging Location Unique IDs are defined by the state and are found in the State’s applicable GIS
databases.

Figure 9: Existing Charging Stations on Alternative Fuel Corridors in Arizona

EV Charging Infrastructure Deployment

Developing a nationwide public EVSE network is key to creating a convenient, affordable, reliable,
and equitable charging network. To achieve this goal, the NEVI Formula Program designates that a
state may receive funding to deploy EVSE that meet NEVI Standards and Requirements along its
AFCs. The requirements include, but are not limited to, the following:

72
  Publicly accessible EVSEs must be within 50 miles of each other. Discretionary
exceptions may be granted.

 EVSE must be less than one driving mile from a highway exit.

 Site power capability must be at least 600 kW, to support at least 150 kW per port
simultaneously across four ports.

 Each charger must be equipped with a CCS connector.

Arizona’s EV Charging Infrastructure Deployment Plan will comply with the aforementioned
requirements. The 2023 Plan accounts for progress made in EV charging infrastructure deployment
since the approval of the 2022 Plan. The 2023 Plan identifies the locations of new and upgraded
EVSE stations along newly proposed AFCs. All of the proposed corridors are pending AFC designation
by the USDOT. They are:
 US 93, Kingman to Nevada

 SR 95, I-40 to Quartzsite

 SR 347, Maricopa to I-10

 US 89, Flagstaff to Utah

 SR 87, Phoenix to Payson

 SR 260, Payson to Show Low

 SR 64, I-40 to Grand Canyon National Park

Funding Sources
The deployment of ADOT’s EV infrastructure will involve partnerships with private companies that
have the interest, expertise, and resources to meet federal funding match requirements. These
partners will upgrade existing or design, build, own, maintain, and operate new EVSE locations, as
well as meet the required non-federal share to match the NEVI Formula Program funds.
Potential funding sources for EVSE stations in Arizona are displayed in Table 26. These sources
include utility incentives for which EVSE station owners may be eligible, federal NEVI Formula
Program funds, and the required non-federal match. Additional programs, such as time of use
programs offered by local utilities, are also available to reduce the cost of EV ownership but are
excluded from this list as they do not directly reduce upfront EVSE costs.
Table 26: Potential Funding Sources
Name Program Description Type of Administering Amount
Funding Organization(s)
Electric Vehicle Rebate for installing networked Rebate SRP $1,500 per
Charging Station Level 2 chargers at commercial, port
Rebate workplace, or multi-family sites.

73
Name Program Description Type of Administering Amount
Funding Organization(s)
Electric Vehicle Rebate to cover installation of Rebate Mohave Electric $1,000 per
Charging Station Level 2 and Level 3 chargers for Cooperative Level 2
Rebate residential and commercial charger,
customers. $2,750 per
Level 3 charger
Electric Vehicle Rebate to cover installation of Rebate APS $250 per Level
Charging Station Level 2 charger at residential 2 charger
Rebate sites.
Electric Vehicle Free EV charging stations, Program APS Varies
Charging Station installation, maintenance, and
Pilot Program educational services to its
workplace, fleet, and multi-unit
dwelling customers.
Electric Vehicle Rebate to cover installation of Rebate TEP $500 for two-
Charging Station Level 2 charger at residential way charger,
Rebate sites. $250 for one-
way
Commercial Rebate for technical assistance Rebate TEP Between
Electric Vehicle and installation of Level 2 or 3 $4,500 and
Charging Station stations. Higher rebates are $40,000,
Rebate available for low-income depending on
residents. charger type
and income
level
Commercial Rebate to install, among other Rebate SRP $1,500 per
Electrification technologies, Level 2 charging port
Rebates stations at commercial sites.
NEVI Formula Funding to build EVSE every Formula FHWA $76,483,976
Program 50 miles within 1 mile of AFCs to funding over five years
establish an interconnected
network.
Non-Federal Share Private entity investment in Private EVSE Station $19,120,994
(Match) EVSE and EVSE operations every investment Owners
50 miles within one mile of AFCs.
Charging and Funding to deploy EVSE along Grant FHWA $2.5 billion
Fueling AFCs and in communities. nationally
Infrastructure

74
Name Program Description Type of Administering Amount
Funding Organization(s)
Discretionary
Grant Program

ADOT anticipates allocation of the federal NEVI Formula Program funds across the five-year life of
the program as shown below by federal fiscal year (FFY):

 FFY 2022-FFY 2023: $27,600,000

o FFY 2022: $11,300,000 (rolled over to FFY 2023)

o FFY 2023: $16,300,000

 FFY 2024: $16,300,000

 FFY 2025: $16,300,000

 FFY 2026: $16,283,976

The deployment strategy for 2023 is described below. Each subsequent year, the Plan will be
updated with funding allocation amounts for the upcoming year.

2023 EVSE Deployment Strategy

ADOT proposes an EVSE deployment strategy, aligning with the 2022 Plan. This strategy is designed
to meet the objectives set forth in the Vision and Goals section of this Plan. This includes increasing
the long-range mobility for EV drivers and supporting the development of an equitable national
charging network by closing gaps in charging infrastructure along the State’s highway system. The
strategy includes:
 Utilizing existing creditable stations that meet NEVI Standards and Requirements

 Using discretionary exemptions as appropriate.

 Closing remaining gaps with DCFC station upgrades or the construction of new
stations

NEVI Creditable EVSE Stations

The 2022 Plan identified 13 EVSE stations on the Interstate highways that were creditable, i.e., met
NEVI Standards and Requirements. The 2023 Plan adds two stations, at Show Low and Payson,
identified along the new pending AFCs. All creditable stations are listed in Table 27. The map in
Figure 10 shows the distance in miles between each existing creditable station, as well as the closest
DCFC charging stations in neighboring states. While these chargers may need to be upgraded to
develop a cohesive interstate network, charging stations in neighboring states are excluded from the
purview of this Plan.

75
 Table 27: NEVI Creditable* EVSE Stations, 2022 - 2023
State Route Locations Address Exit EVSE Utility Station
EVSE Number Network Territories Ownership
Location
Unique
ID

2023
207916 SR 260 Show Low 180 N. 9th St Electrify TBD Existing
Manzanita
Show Low, AZ America
Dr.
86046
238674 SR 260 Payson 400 E. Highway Electrify TBD Existing
260 Payson, AZ N. 9th St. America
86322
2022
187879 I-40 Kingman 3490 Stockton Electrify TBD Existing
Hill Rd. America
51
Kingman, AZ
86409
184916 I-40 Williams 1100 W. Electrify TBD Existing
Cataract Lake America
Rd. 163
Williams, AZ
86046
127934 I-40 Flagstaff 2601 E. Electrify TBD Existing
Huntington Rd. America
198
Flagstaff, AZ
86004
135874 I-40 Winslow 700 Mikes Pike Electrify TBD Existing
St. America
253
Winslow, AZ
86047
187948 I-10 Quartzsite 760 S. Electrify TBD Existing
Quartzsite Blvd. America
17
Quartzsite, AZ
85346
121828 I-10 BuBEckey 1060 S. Watson Electrify TBD Existing
e Buckeye, AZ 117 America
85326

76
State Route Locations Address Exit EVSE Utility Station
EVSE Number Network Territories Ownership
Location
Unique
ID

149194 I-10 Tempe 5000 S. Arizona Electrify TBD Existing

Mills Circle America
155
Tempe, AZ
85282
191561 I-10 Chandler 4976 Premium Electrify TBD Existing
Outlets Way America
162
Chandler, AZ
85226
198884 I-8 Yuma 1450 S. Yuma EVgo TBD Existing
Palms Parkway 2 Network
Yuma, AZ 85365
169411 I-8 Dateland 1734 Ave. 64 E. Electrify TBD Existing
Dateland, AZ 67 America
85333
145749 I-10/I-19 Tucson 6401 W. Marana Electrify TBD Existing
Center Blvd. America
244
Tucson, AZ
85742
123483 I-10 Benson 201 S. Prickly Electrify TBD Existing
Pear Ave. America
303
Benson, AZ
85602
124348 I-17 Anthem 4435 W. Electrify TBD Existing
Anthem Way America
229
Anthem, AZ
85086
*Pending verification by the Joint Office of Energy and Transportation.

77
 Figure 10: NEVI Creditable EVSE Stations, Arizona, 2022 - 2023

Discretionary Exemptions
ADOT is requesting two continued discretionary exemptions from the requirement that charging
infrastructure be installed every 50 miles along the state’s AFCs. These exemptions were approved
for the 2022 Plan. The proposed discretionary exemptions are described below and illustrated in
Figure 11. Additional information regarding the discretionary exemptions may be found in
Appendix A.

Kingman to Seligman
The 57-mile segment of I-40 between Kingman and Seligman is in a rural area with no existing
amenities within one mile of the corridor. ADOT limited the distance of this gap as much as possible
by proposing a new charging station just east of Kingman. The proposed exemption is for a 7-mile
gap, as NEVI-compliant chargers will be sited 57 miles apart from each other.

78
Gila Bend to Casa Grande/Eloy
East of Gila Bend, I-8 is a rural area with no existing amenities within one mile of the corridor until
reaching the interchange with I-10. ADOT proposed upgrading the existing stations in Casa Grande
and installing a new site in Eloy to ensure convenient charging options for both westbound and
eastbound I-10. The proposed exemption is for a 17-mile gap, as NEVI-compliant chargers will be
sited 67 miles apart.
Figure 11: Discretionary Exemption Requests, 2022-2023

79
Closing Gaps in the Existing Network with New and Upgraded Stations
The 2022 Plan identified eight existing stations with the potential to be upgraded to meet NEVI
requirements, as well as locations for the construction of new stations, along the Interstate
highways.
The 2023 Plan calls for the upgrade of two stations, at Tusayan and Willow Beach, identified along
the new pending AFCs, and for the construction of 13 new stations along those AFCs. These stations
may need various improvements to be considered as creditable per NEVI, including installation of
CCS ports, ensuring four ports capable of 150kW simultaneous charging, and meeting other NEVI
requirements. New stations will be placed at these locations if upgrades are not proposed and
selected through the contracting process.
Locations identified in this plan for new construction are not specific. The selected contractor will
work with property owners and ADOT to establish exact locations. The contract may specify the
areas surrounding certain interchanges within which actual construction sites may be located. At
certain locations more than one interchange may be eligible as sites for station construction. These
sites will be identified in the contract.
Proposed station locations were identified using NEVI Standards and Requirements and the
following criteria:
 Traffic volume

 Availability of amenities

 Presence of infrastructure

 Justice40 designations

 Cost

 Proximity to other EVSE stations in Arizona and neighboring states

 Utility capacity

 Public and stakeholder feedback

Table 28 and Figure 12 show the existing stations identified for potential upgrade and the locations
identified for new stations in the 2022 and 2023 Plans.

80
 Table 28: Potential Upgrades and New EVSE Station Locations, 2022 – 2023
Stations to be potentially upgraded indicated in bold.

State EVSE Anticipated NEVI Estimated

Anticipated Utility Number Estimated
Location Route Location Exit Number Station Funding Year
EVSE Network Territories of Ports Cost
Unique ID Ownership Sources Operational

2023

Unknown at Unknown at
Page Utility
TBD US 89 Page Haul Rd. time of Plan time of Plan FFY 24 4 TBD TBD
Enterprises
submittal submittal

Unknown at Unknown at
498 US 89,
TBD US 89 The Gap time of Plan NTUA time of Plan FFY 24 4 TBD TBD
Cameron,
submittal submittal

Cameron Unknown at Unknown at

TBD US 89 Cameron Bridge time of Plan APS time of Plan FFY 24 4 TBD TBD
Bypass Rd. submittal submittal

Fort Unknown at Unknown at

Fort
TBD SR 87 McDowell time of Plan SRP time of Plan FFY 24 4 TBD TBD
McDowell
Rd. submittal submittal

Unknown at Unknown at
S. Beeline
TBD SR 87 Rye time of Plan APS time of Plan FFY 24 4 TBD TBD
Hwy
submittal submittal

Unknown at Unknown at
Forest Lakes
TBD SR 260 Highway Lp. time of Plan APS time of Plan FFY 24 4 TBD TBD
Estates
submittal submittal

81
State EVSE Anticipated NEVI Estimated
Anticipated Utility Number Estimated
Location Route Location Exit Number Station Funding Year
EVSE Network Territories of Ports Cost
Unique ID Ownership Sources Operational

Unknown at Unknown at
Navopache
TBD SR 260 Overgaard Mogollon time of Plan time of Plan FFY 24 4 TBD TBD
Electric Co-op
submittal submittal

Unknown at Unknown at
W. Smith Electrical
TBD SR 347 Maricopa time of Plan time of Plan FFY 24 4 TBD TBD
Enke Rd. District No. 3
submittal submittal

Unknown at Unknown at
TBD SR 64 Valle US 180 time of Plan APS time of Plan FFY 24 4 TBD TBD
submittal submittal

Unknown at Unknown at
Lake Havasu McCulloch
TBD SR 95 time of Plan Unisource time of Plan FFY 24 4 TBD TBD
City Blvd N.
submittal submittal

Unknown at Unknown at
W. Riverside
TBD SR 95 Parker time of Plan APS time of Plan FFY 24 4 TBD TBD
Dr.
submittal submittal

Long Jim
153422 SR 64 Tusayan Tesla APS Existing FFY 24 12 N/A TBD
Loop

Willow
TBD US 93 CR145 Tesla UNS Electric Existing FFY 24 8 N/A TBD
Beach

82
State EVSE Anticipated NEVI Estimated
Anticipated Utility Number Estimated
Location Route Location Exit Number Station Funding Year
EVSE Network Territories of Ports Cost
Unique ID Ownership Sources Operational

2022

Unknown at Unknown at
Lake Havasu
TBD I-40 9 time of Plan UNS Electric time of Plan FFY 22/23 4 TBD TBD
City
submittal submittal

Unknown at Unknown at
TBD I-40 Seligman 123 time of Plan APS time of Plan FFY 22/23 4 TBD TBD
submittal submittal

Unknown at Mohave Unknown at

TBD I-40 Kingman 66 time of Plan Electric time of Plan FFY 22/23 4 TBD TBD
submittal Cooperative submittal

Unknown at Unknown at
TBD I-40 Twin Arrows 219 time of Plan APS & NTUA time of Plan FFY 22/23 4 TBD TBD
submittal submittal

Unknown at Unknown at
Petrified
TBD I-40 311 time of Plan APS time of Plan FFY 22/23 4 TBD TBD
Forest
submittal submittal

Unknown at Navopache Unknown at

TBD I-40 Sanders 339 time of Plan Electric time of Plan FFY 22/23 4 TBD TBD
submittal Cooperative submittal

83
State EVSE Anticipated NEVI Estimated
Anticipated Utility Number Estimated
Location Route Location Exit Number Station Funding Year
EVSE Network Territories of Ports Cost
Unique ID Ownership Sources Operational

Unknown at Unknown at
TBD I-17 Munds Park 322 time of Plan APS time of Plan FFY 22/23 4 TBD TBD
submittal submittal

Unknown at Unknown at
TBD I-17 Camp Verde 287 time of Plan APS time of Plan FFY 22/23 4 TBD TBD
submittal submittal

Unknown at Unknown at
TBD I-10 Salome 45 time of Plan APS time of Plan FFY 22/23 4 TBD TBD
submittal submittal

Unknown at Unknown at
TBD I-10 Tonopah 94 time of Plan APS time of Plan FFY 22/23 4 TBD TBD
submittal submittal

Sulphur
Unknown at Unknown at
Springs Valley
TBD I-10 San Simon 378 time of Plan time of Plan FFY 22/23 4 TBD TBD
Electric
submittal submittal
Cooperative

Unknown at Unknown at
TBD I-19 Nogales 4 time of Plan Unisource time of Plan FFY 22/23 4 TBD TBD
submittal submittal

Unknown at Unknown at
TBD I-10 Eloy 200 time of Plan APS time of Plan FFY 22/23 4 TBD TBD
submittal submittal

84
State EVSE Anticipated NEVI Estimated
Anticipated Utility Number Estimated
Location Route Location Exit Number Station Funding Year
EVSE Network Territories of Ports Cost
Unique ID Ownership Sources Operational

101984 I-40 Holbrook 286 Tesla APS Existing FFY 22/23 12 N/A TBD

Cordes
Lakes /
101986 I-17 262 Tesla APS Existing FFY 22/23 8 N/A TBD
Cordes
Junction

101981

or I-17 Casa Grande 194 Tesla or EVgo APS Existing FFY 22/23 6 or 4 N/A TBD

198884

101994 I-10 Tucson 273 Tesla TEP Existing FFY 22/23 10 N/A TBD

Wellton-
Mohawk
154797 I-8 Tacna 42 Tesla Existing FFY 22/23 8 N/A TBD
Irrigation
District

122249 I-8 Gila Bend 115 Tesla APS Existing FFY 22/23 16 N/A TBD

Sulphur
Springs Valley
101996 I-10 Willcox 340 Tesla Existing FFY 22/23 8 N/A TBD
Electric
Cooperative

85
State EVSE Anticipated NEVI Estimated
Anticipated Utility Number Estimated
Location Route Location Exit Number Station Funding Year
EVSE Network Territories of Ports Cost
Unique ID Ownership Sources Operational

205372, Green
I-19 69 ChargePoint TEP/Trico Existing FFY 22/23 4 N/A TBD
211832 Valley

86
 Figure 12: Proposed Charging Network, 2022 -2023

2023 EVSE Deployment Strategy Summary

As described previously, ADOT’s 2023 EVSE deployment strategy aims to increase long-range
mobility for EV drivers by closing gaps in charging infrastructure along the State’s AFCs and
supporting the development of an equitable national charging network. The deployment strategy
identifies NEVI creditable EVSE stations and non-compliant DCFC stations for potential upgrades,
then fills in gaps by providing funding for the design, installation, operation, and maintenance of
new stations in locations addressing those gaps. Exemptions are being requested only as necessary
and will not jeopardize a convenient, affordable, reliable, and equitable national EV charging
network.

87
2024 - 2025 Deployment Strategy
ADOT has solicited information from stakeholders and the public about what additional routes
should be considered for AFC nomination. Only routes on the National Highway System (NHS) are
eligible for nomination as AFCs. Based on feedback from the solicitation, the proposed AFC
nominations for 2024 and 2025 are found in Table 29 and Figure 13.
Table 29: Preliminary List of Proposed New AFC Candidates, 2024-2025
Corridor Name Location

US 60 Phoenix to Wickenburg; Phoenix to Globe; Show

Low to New Mexico border

US 93 Wickenburg to I-40

US 95/State San Luis to Quartzsite; I-40 to Bullhead City

Route (SR) 95

SR 68 US 93 to Bullhead City

SR 69 I-17 to Prescott

SR 77 SR 260 to I-40

SR 85 I-8 to I-10

SR 90 I-10 to Bisbee

US 160 US 89 to Four Corners

SR 260 Camp Verde to Sedona

SR 80 Bisbee to Douglas

SR 77 Tucson to north end of NHS route (Pima/Pinal

County border)

SR 179 I-17 to Sedona

SR 287 Casa Grande to I-10

SR 89/89A SR 69/SR 169 to north end of NHS route

88
 Figure 13: Proposed New AFC Candidates, 2024-2025

The evaluation of candidates for AFC nomination will be based upon the improvement to State and
national EV connectivity, public input, funding availability, and other factors. Nominations of AFCs,
along with their corresponding EVSE infrastructure deployment plans, will be included in future plan
updates. Following plan approval, ADOT intends to deploy stations on the newly designated AFCs.

Deployment Criteria for 2024 - 2025

To prioritize and support an equitable, efficient, charging network, ADOT will assess potential
locations based on the following criteria, as it did in preparing the 2022 and 2023 Plans:
 Traffic volume

 Availability of amenities

 Presence of infrastructure

 Justice40 designations

 Cost

 Proximity to other EVSE stations in Arizona and neighboring states

 Utility capacity

 Public and stakeholder feedback

89
Other Considerations
Public transportation is a key consideration when addressing the mobility needs of DACs. The
proposed charging sites will be accessible to electric rideshare vehicles and transit vans along the
corridors.
FHWA has designated four Arizona highways (I-10, I-17, I-19, and I-40) as Primary Highway Freight
System routes that are critical to the movement of freight. ADOT will evaluate EVSE needs for
medium- and heavy-duty vehicles in periodic updates to its freight plan.

State, Regional, and Local Policy

ADOT has identified plans, policies, and studies relating to transportation electrification. This Plan
can help advance the goals of those plans and policies. EVSE locations may utilize utility or other
incentives contemplated by these plans and policies for the installation of EVSE infrastructure. ADOT
plans to continue coordination and engagement with state, regional, and local policy related
stakeholders. Table 30 summarizes the relevant Arizona policies and plans.

90
 Table 30: Arizona EV Policies and Plans
EV Policy Breakdown

Policy Entity Description

State
Arizona Statewide APS and TEP In 2021, APS and TEP released the Arizona Statewide Transportation Electrification Plan:
Transportation Phase II as a follow-up to the Phase I plan released in 2019. It put forth a comprehensive
Electrification Plan: and actionable roadmap for transportation electrification in Arizona, including an analysis
Phase II of promising EV opportunities and significant engagement with the state’s TEP stakeholder
community. Updates are anticipated every three years.
A cost/benefit analysis of electrification opportunities and stakeholder engagement found
that transportation electrification could generate net benefits of $28 billion for Arizona, $9
billion for drivers and fleet owners, and $12 billion for utility ratepayers, in present value.
Within this Phase II plan, APS and TEP propose statewide 2030 EV goals by vehicle segment
and utility, with a proposed goal for electric light-duty vehicles at 450,000; 95,000; and
1,076,000 vehicles for APS, TEP, and State service areas, respectively.
EV Cost-Benefit Southwest Energy SWEEP released an EV Cost-Benefit Analysis for Arizona in December 2018 with a focus on
Analysis Efficiency Project passenger vehicles in two scenarios (moderate and high adoption rates). For the moderate
(SWEEP) scenario, it was estimated that a cumulative net benefit from plug-in electric vehicles (PEVs)
use in Arizona will exceed $3.7 billion statewide by 2050, but this number could increase to
exceed $31 billion under the high scenario. These savings would be derived from electric
utility customers in the form of reduced electric bills, from drivers in the form of reduced
annual vehicle operating costs, from owners of public charging infrastructure, from
residents due to reduced costs of complying with future carbon reduction regulations, and
from society at large based on the value of reduced nitrogen oxides emissions.

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EV Policy Breakdown

Policy Entity Description

Regional
Transportation TEP and UNSE TEP and UNSE intend for the implementation plan to build off the Statewide Transportation
Electrification Electrification Plan, to focus on the barriers best addressed by the electric utility. This
Implementation Plan includes public lack of awareness, insufficient charging infrastructure and network, costs of
EV charging and grid impacts, and access for underserved and low- to moderate-income
customers.
Regional Electrification Maricopa The plan will prepare the MAG region for an increasingly electric future. The strategic plan
Readiness Strategic Association of will include a range of recommendations and strategies to enhance electrification readiness
Plan Governments (MAG) for MAG and its member agencies. The study aims to accomplish these three main
objectives:
Assess the current and future state of electrification and regional implications
Define roles and responsibilities for applicable strategies
Identify strategic funding opportunities and next steps for action
Local
Draft Transportation City of Phoenix In June 2022, the City of Phoenix approved the Draft Transportation Electrification Action
Electrification Plan Plan, which summarizes the current state of the city’s EV adoption and infrastructure, their
target goals for the year 2030, and a list of goals with provided action items to achieve their
target number of 280,000 EVs. The plan follows a ‘Roadmap 2030,’ which includes five steps
to prepare for the increased adoption.
The plan notes issues related to charging infrastructure shortages, actual/perceived cost,
limited model availability, range anxiety, lack of EV-ready building codes, and public
knowledge and experience with EVs as a few of the factors still standing in the way of
greater adoption rates. To overcome these issues, the plan sets three distinct
goals/strategies: Prioritizing Equity, Accelerate Public Adoption of EVs, and Lead by

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EV Policy Breakdown

Policy Entity Description

Example. Currently, Phoenix has set adoption goals in line with the federal government’s
2030 nationwide EV adoption.

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Implementation
Implementation requirements and considerations are crucial to ensuring the feasibility of the Plan’s
recommendations, as well as the long-term sustainability and resiliency of charging stations. These
considerations are expected to promote the efficient use of funds and support effective EVSE
infrastructure deployment. They are also intended to meet broader equity goals (including
Justice40), by supporting labor, safety, training, and installation standards, and by providing
opportunities for small businesses. ADOT will incorporate the relevant requirements and monitoring
provisions into the contracts to be established with EVSE owners.

The following implementation requirements and considerations align with the NEVI Standards and
Requirements to develop a set of expectations related to operations and maintenance, data
collection and sharing, resilience, and labor training for station owners using NEVI Formula Program
funding.

Strategies for EVSE Operations and Maintenance

EVSE are only an asset to EV owners if they remain in working order. The investment of public funds
should be protected by ensuring that operations and maintenance best practices are implemented
by station owners. ADOT intends to comply with NEVI requirements for EVSE operations and
maintenance.

Requirements
ADOT will ensure that station owners are maintaining EVSE infrastructure in good working order by
using qualified technicians in compliance with all EVSE infrastructure manufacturer requirements
and with all requirements issued by NEVI. Technician qualifications are more fully described in the
Labor and Workforce Considerations section. Requirements and monitoring provisions will be set
forth in the contract between ADOT and the station owner.
ADOT will require that owners of the EVSE infrastructure provide reasonable plans, to include
funding considerations; and guarantees for maintaining the EVSE and related equipment in good
working order. Those reliability standards are more fully described in the Program Evaluation -
Metrics section. ADOT will review plans and guarantees for sufficiency prior to acceptance. ADOT
will monitor compliance with maintenance plans and guarantees through reported data and
periodic onsite inspection of charging locations, EVSE, and records.
ADOT will require that infrastructure be maintained at the same location for a period of no less than
five years from the installation date with the consideration of service beyond the NEVI Formula
Program funds. ADOT will request that prospective station owners identify their plans to operate
and maintain the charging infrastructure during and after the five-year required maintenance period
and may make this a consideration in the contract award.
Annually, information about the organizations operating, maintaining, or installing EVSE will be
submitted. A use, reliability, and maintenance data submittal will occur quarterly. One of the
primary categories of data collection will be maintenance and reliability data. Further details about
this data submittal are described in the Program Evaluation - Reporting section.

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ADOT will require that EVSE owners provide mechanisms for customers to report outages,
malfunctions, and other issues with charging infrastructure. ADOT will require that site owners make
these reporting mechanisms accessible and equitable by complying with the American Disabilities
Act of 1990 and by providing multilingual access as required by law.
If appropriate and cost effective, ADOT will consider requiring that the station owner purchase an
EVSE equipment warranty.
When a charger is part of a network, the network provider may cover payment and maintenance
costs. If selecting a networked charger for purchase, ADOT will encourage site owners to first
consider the necessity of adequate cell service at the proposed site to ensure the station can
communicate with its network and users can access applications for payment.

Strategies for EVSE Data Collection and Sharing

ADOT recognizes that data collection and sharing can be used to update and improve the program
over time, as well as provide users with the information needed to use the network. This Plan
ensures compliance with NEVI Standards and Requirements relating to EVSE data collection and
sharing. Any cybersecurity recommendations or requirements related to data sharing or network
connectivity are addressed in the Cybersecurity section. The following strategies are based on the
NEVI Standards and Requirements:
 To increase awareness of charging infrastructure and improve customer and station
host satisfaction, ADOT will require its EVSE owners to share data describing EVSE
location, type of equipment available, price, status, and other information—free of
charge—via an application programming interface with public-facing directories,
including the Alternative Fuel Data Center’s Station Locator.

 Station owners will comply with the proposed interoperability requirements for
charger-to-EV communication to ensure that chargers are capable of the
communication necessary to perform smart charge management and Plug and
Charge. Chargers will be required to be capable of using Open Charge Point
Interface (OCPI) for interoperability and the ability to communicate through Open
Charge Point Protocol in tandem with ISO 15118.

 To allow for secure remote monitoring, diagnostics, control, and updates, station
owners will comply with network connectivity requirements for charger-to-charger
network communication, charging network-to-charging network communication,
and charging network-to-grid communication.

 Station owners will comply with the proposed requirement that payment options
include contactless payment methods, that contactless payment be accepted by all
major debit and credit cards, and that access and service are not restricted by
membership or payment method type. ADOT will require that station owners do not
limit or curtail power flow to vehicles on the basis of membership or payment
method. ADOT will require that multilingual access and access for people with
disabilities be provided when creating payment instructions. Provisions for payment

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 options will be set forth in the contract. Station owners will also be required to
provide an automated toll-free phone number or a SMS that provides the EV
charging customer with the option to initiate charging sessions and submit
payments.

 Charging station owners must display the price of charging prior to initiating a
charging transaction and the price must be based on the price for electricity to
charge in $/kWh.

 The price for charging displayed must not change during the charging session, and
price structure including any fees and the price of electricity must be clearly
displayed and explained.

Strategies to Address Resilience, Emergency Evacuation, Snow Removal/Seasonal

Needs
The following strategies are based on and ensure compliance with NEVI Standards and
Requirements.

Emergency Evacuation, Snow Removal, and Seasonal Needs

EVSE infrastructure should be conveniently and safely located. If the EVSE cannot be safely accessed
during snow events or emergency situations, they are not as strong an asset to the AFC. EVSE
stations should provide convenient charging to allow vehicles to evacuate an area safely and quickly
in an emergency.
Strategies
 ADOT will consider the potential impacts of extreme weather events, including the
use of currently available USDOT tools and resources to assess the vulnerability and
risk of planned and existing EVSE stations and the development, deployment, and
monitoring of resilience solutions.

 ADOT will consider emergency and evacuation needs, including how they will
support overall emergency evacuation plans along roadways. ADOT will consider the
location and construction of EVSE infrastructure with respect to the Federal Flood
Risk Management Standard, as well as how climate may affect the floodplain.37
ADOT will consider to the importance of ensuring access to EVSE during times of
emergency, such as evacuations from natural disasters, and design requirements
that address the risk associated with locating EVSE in floodplains. If an existing
station that is proposed for an upgrade is identified to be in a floodplain, there must
be proposed mitigation strategies if continuing with the selected station. For new
station location selection, the owner would identify the station location but be
responsible for environmental and floodplain considerations.

● In areas that experience annual snowfall, such as northern Arizona, ADOT will ensure its station
owners take preventive actions, such as salting, and reactive actions, such as snow plowing, to
address snow buildup that could block access to the station.

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● In areas that experience intense sun and heat, such as central, southern, and western Arizona,
ADOT will recommend that station owners consider ways to protect EVSE, such as shade
structures, where feasible.

Resilience Considerations
The AFCs are only an asset if EVSE are functional when needed most—during extreme weather
events, emergencies, outages, and evacuations. This requires consideration of resilience strategies
such as identified below:
Requirements and Strategies
● ADOT will consider the inclusion of distributed energy resources (DERs) (e.g., solar arrays,
energy storage) and electrical distribution and switching equipment where practicable and
necessary. DERs are small, localized energy production sites, like solar arrays, which allow for an
electrical system to be self-sufficient by producing its own power in the event of a grid outage.

● ADOT will require that EV stations located in floodplains be upgraded to mitigate the impacts of
flooding.

● ADOT will require station owners to identify and adopt a plan for snow removal where
applicable.

Strategies to Promote Strong Labor, Safety, Training, and Installation Standards

Developing an EVSE network provides opportunities to create well-paying jobs to build a modern
sustainable infrastructure. Minimum skill, training, and certification standards for technicians ensure
that the deployment of EVSE infrastructure will support stable career-track employment for
workers, creating more openings for workers to pursue training in the electrical trades—critical
occupations for the clean energy transition. By requiring installation, maintenance, and operations
to be performed by a well-qualified, highly skilled, certified, licensed, and trained workforce, the
EVSE network’s safety and reliability will be increased. The following strategies are based on NEVI
Standards and Requirements.
● ADOT will require that designs meet all applicable fire protection and prevention standards and
traffic safety requirements.

● ADOT will ensure that station owners consult local emergency management and public safety
agencies, as appropriate.

● ADOT will ensure that station owners are operating and maintaining EV charging infrastructure
with a focus on public safety. This includes the provision of adequate lighting, fire protection,
and other traffic safety features.

● As discussed in the Labor and Workforce – Training Strategies section, requirements for training
and hiring standards will be included in EVSE contracts.

● ADOT will encourage station owners to have trained staff on call in emergency situations.

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Additional Strategies
The following recommendations will be provided to site owners as suggested best practices to help
them enhance labor and workforce considerations at EVSE stations and the overall network. These
recommendations will be provided to potential owners, along with other solicitation documents
provided during the EVSE station owner selection process, and discussed during pre-bid or similar
meetings and in communications with selected owners.
● ADOT will make its site owners aware that several additional DOT funding and finance programs
are also available to support workforce training for innovative technologies.

Opportunities for the Participation of Small Businesses

When selecting charging station locations, ADOT will consider locations at or immediately adjacent
to land uses with food retailers, convenience stores, and small businesses with an ADA accessible
pathway between the EVSE infrastructure and the identified establishment’s front door, and other
comparable facilities.

ADOT will continue to engage the public and stakeholders that represent or provide services to
small businesses including the Arizona Small Business Association, the state and local chambers of
commerce, and other chambers of commerce such as the Hispanic Chamber of Commerce, the Black
Chamber of Commerce, and the Chinese Chamber of Commerce.

Installation Standards
Meeting current and anticipated market demands for EVSE infrastructure—including expected
power levels and charging speed—and minimizing the time needed to charge vehicles is crucial for a
successful EVSE network. Designing and managing facilities properly before installation can reduce
upfront costs and, later, the operational costs associated with charging stations. The following
strategies are based on NEVI Standards and Requirements:
 ADOT will only consider DCFC for NEVI Formula Program funding.

 ADOT will consider future-proofing EVSE to accommodate expansions needed to

support growing demand. Futureproofing considerations may include station size,
power levels, and oversized conduit and pre-wiring new buildings for future EVSE
stations.

 ADOT will submit one-time, annual, and quarterly data as required by NEVI
Standards and Requirements, such as the submission of detailed EVSE acquisition
and installation costs, and grid connection and upgrade costs paid by the charging
station operator. Refer to the Program Evaluation – Reporting section for more
detail.

 Station owners will be required to account for the cost of the minimum
infrastructure needed to safely operate EVSE, such as protective bollards or curbs
and gutters to support a curbside PEV charger installation. Station owners must
consider installation of signage and pavement markings to designate EVSE locations,
prevent non-EVs from parking, and direct EV drivers to station locations. This

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includes complying with existing requirements in the Manual on Uniform Traffic
Control Devices for Streets and Highways found at 23 CFR part 655 and the Highway
Beautification regulation at 23 CFR part 750 and any processing updates to those
requirements.

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Equity Considerations
ADOT is committed to complying with the Justice40 Initiative—a part of Executive Order 14008—
when using NEVI Formula Program funds. This section outlines how the Plan identified and engaged
with DACs throughout the Plan’s development, as well as the actions taken to ensure that benefits
to DACs are captured throughout this work.

Identification and Outreach to Disadvantaged Communities in the State

As part of the public involvement planning process, a review of statewide census data was
conducted to identify the State’s demographics. Data points reviewed included race/ethnicity, age,
income level, and disability. Separately, vehicle accessibility/ownership was reviewed to assess the
current status of EV market penetration. As part of planning for public meetings, additional reviews
were conducted to identify specific areas within geographic regions for targeted outreach and
notification of public meetings.

Tools to Engage Disadvantaged Communities

Tools utilized to ensure opportunity for meaningful participation by disadvantaged and traditionally
underserved individuals and communities are listed below. These tools will continue to be utilized as
outreach is conducted for further refinement of the Plan:
● Translation of public involvement materials, including notices and the project fact sheet, into
Spanish and other languages, as identified through the LEP Four-Factor Analysis or by request.

● Spanish oral interpretation at all public meetings and Spanish translation of graphics on the
project webpage. Additional language services were available by advance request. The Navajo
Nation requested, and ADOT provided, oral interpretation in Dine´ at the virtual public meeting
held July 18, 2023.

● Use of Google Translate on the ADOT project webpage, allowing the translation of information
into approximately 100 languages.

● Outreach and engagement of local government partners and special interest groups to
participate and share information with their constituents and members.

● Promotion of public meetings and other outreach efforts by posting flyers in English and Spanish
at community gathering places.

● Utilization of community contacts, mailing lists and other means to initiate and continue
communication.

● Targeted public outreach to the identified low-income and minority communities within the
project area via stakeholder partner channels.

● Display of Notice of Availability of Reasonable Accommodations on all project public-facing

materials.

● Selection of meeting venues accessible by public transit.

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Actions to Ensure Nondiscriminatory Practices
To ensure nondiscriminatory practices based on Title VI, ADOT has adhered to the following
applicable actions and will continue to do so during outreach throughout Plan refinement.
● Provide ADOT Nondiscrimination brochures in both English and Spanish to public meeting
attendees.

● Display the ADOT Nondiscrimination Notice to the Public poster in English and Spanish at public
meetings and encourage meeting participants to read the information.

● Include ADOT’s Nondiscrimination Notice to the Public slide in English and Spanish in the
meeting presentations and read the accompanying script in Spanish, as well as in Dine´.

● Provide the opportunity for in-person and virtual meeting attendees to complete the voluntary
Title VI Self-Identification cards. Virtual meetings provide the Self-ID Survey through a slide with
a link and the link posted in the chat for attendee convenience. Hard-copy cards are provided to
attendees at in-person meetings upon check in.

Actions to Ensure Accessibility

The following strategies have been utilized when appropriate for the outreach activity and will
continue to be utilized throughout Plan development to comply with the ADA’s statutory
requirements.
● Ensure public meeting venues are ADA-compliant and accessible by ADA-compliant
transportation options, and that information provided is accessible for persons with vision or
hearing disabilities.

● Ensure that virtual public meetings and stakeholder workshops are ADA accessible, which
includes instructing users how to turn on closed captioning services, having speakers turn on
their cameras, providing minimum font sizes in presentations, and including a required Auxiliary
Aids and Services slide regarding how to request ADA accommodations.

● Ensure that materials posted to the website are accessible PDFs that are compatible with
readers.

● If online resources are used to provide project information, provide guidance on how to use
online resources and resources will be ADA accessible, including assistance for those with visual
impairment and information about alternative methods for participation.

● Provide the Notice of Availability of Reasonable Accommodations on all public-facing materials

for the study. Reasonable accommodations are provided upon request (e.g., sign language
interpreter, copies of materials in accessible formats, etc.).

DAC Outreach Results

The virtual survey in the outreach conducted in Fall 2022 received 1,423 responses, exceeding the
combined total responses from the public survey (919) and its accompanying stakeholder survey
(157) distributed earlier in 2022. While the ADOT team is also guided by factors such as cost and

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feasibility in decision-making, public input is a vital factor that helps to establish priorities and
generate new ideas and perspectives. Considering the number of responses and the focused nature
of the questions in the 2022 survey, the ADOT team identified public preferences, particularly:

 No single proposed criterion for prioritizing future alternative fuel corridors was
supported significantly more or less strongly than others.

 The potential future alternative fuel corridors listed for preference, indicated a clear
hierarchy, with the top five locations picked by more than one in three respondents
and five more picked by more than one in five.

 Respondents strongly preferred more traditional methods of payment, with credit

and debit cards—whether chip-and-pin or tap-to-pay—scoring highly, and many
asking about cash options.

 Preferences for information available online strongly favored being able to ensure
that chargers are available and functional, though high ratings for all options
suggested all information is welcome.

An online comment form was distributed in July 2023 during development of the 2023 Plan update
invited respondents to ask questions and make open-ended comments. Themes identified in the
comments focused on connector types, the desire for shade structures at stations, and ADOT’s
approach to completing the state’s charging network. Survey results are included in Appendix E.

Process to Identify, Quantify, and Measure Benefits to DACs

Executive Order 14008 states that “40 percent of the overall benefits” of Federal investments from
covered programs should flow to disadvantaged communities (DACs). The USDOT methodology for
defining DACs includes data for 22 indicators collected at the census tract level and grouped into six
categories of transportation disadvantages:
1. Transportation access disadvantage identifies communities and places that spend more, and
take longer, to get where they need to go.

2. Health disadvantage identifies communities based on variables associated with adverse health
outcomes, disability, as well as environmental exposures.

3. Environmental disadvantage identifies communities with disproportionately high levels of

certain air pollutants and high potential presence of lead-based paint in housing units.

4. Economic disadvantage identifies areas and populations with high poverty, low wealth, lack of
local jobs, low homeownership, low educational attainment, and high inequality.

5. Resilience disadvantage identifies communities vulnerable to hazards caused by climate

change.

6. Social disadvantage identifies communities with a shared history of discrimination, racism, or

other forms of disadvantage that warrant consideration along with each/any of the above
measures.

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 To respond to the Justice40 directive, ADOT will adhere to and comply with all federal requirements.
ADOT’s EV Infrastructure Deployment Plan intends to meet the Justice40 program requirements by
monitoring program success in identifying, quantifying, and measuring benefits to DACs. Due to the
nature of different communities possessing different needs, documentation of benefits to DACs will
ensure ADOT’s goal to meet NEVI equity requirements. These measures can include documentation
of EV charging incentives and low-cost initiatives for DACs.
ADOT intends to monitor and report progress as required by NEVI Standards and Requirements.
ADOT is soliciting feedback regarding DAC benefits and metrics through stakeholder and public
engagement. ADOT will amend the Plan to reflect input from stakeholders and the public through
the public outreach and involvement activities.

Benefits to DACs through this Plan

ADOT plans to measure benefits to DACs associated with implementing the Plan by assessing
impacts aligned with the USDOT categories and the interim Justice40 guidance. These benefits and
associated metrics reflect the positive impacts of expanding EVSE access to DACs and tribal
communities, as well as avoiding the exacerbation of existing disparities, as defined by Justice40,
through transportation planning that emphasizes equitable investments. These equitable
investments will be important as Arizona’s population continues to grow and impact the distribution
of EV and EVSE access in DACs.
For example, in 2020, Arizona recorded the second fastest growing population in the nation, and
approximately 45% of Arizonans identify as minorities.38 Arizona is also home to one of the largest
Native American populations in the nation, and approximately 27% of the State’s land is owned by
Native American Tribes.39 Measuring benefits to DACs in a rapidly changing and growing
environment will better inform decision-making around EVSE access throughout the duration of this
program.

Metrics to Measure Impacts and Benefit to DACs

Table 31: Metrics to Measure Impacts and Benefits to DACs

Benefits Category Strategy for Tracking Benefits
Improve EV transportation and Metric: Number of total new EVSE chargers installed and the
accessibility, reliability, and number installed in DAC- defined census tracts and tribal
options lands.
 Frequency of Measurement: Annually
 Data Source: Alternative Fuels Data Center,
Justice40 Map

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Reduction of exposure to harmful Metric: Number of total new EV registrations in DAC-
transportation-related emissions defined census tracts and tribal lands.
 Frequency of Measurement: Annually
 Data Source: ADOT Motor Vehicle Division

Increase the clean energy job Metric: Number of EVSE installation, operations and
pipeline, job training, and maintenance, network connectivity, and other support jobs
enterprise creation in held by residents in DAC-defined census tracts and tribal
disadvantaged communities lands.
 Frequency of Measurement: Annually
 Data Source: ADOT contracts to build, operate,
and maintain ESVE which include regular
reporting of employee zip codes

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Labor and Workforce Considerations
ADOT has developed labor and workforce strategies to support and expand existing EVSE programs
to build an equitable, diverse, and local EVSE workforce.
ADOT will require a minimum level of skill and training through certification (e.g., Electric Vehicle
Infrastructure Training Program [EVITP] or another qualifying program). This ensures that the
workforce installing and maintaining EVSE has the appropriate level of training, licenses, and
certifications to ensure that the installation and maintenance of EVSE is performed safely by a
qualified and increasingly diverse workforce.
In addition, ADOT will encourage EVSE owners to hire from existing certification, licensing, and
apprenticeship programs to build a cohesive EVSE workforce pipeline that provides careers to
personnel qualified to perform EVSE installation, maintenance, and operations.

Workforce and Training Strategies

The following strategies are based the NEVI Standards and Requirements (23 CFR 680).

ADOT will require the following certification/training standards. These standards will be set forth in
the contracts between ADOT and ESVE owners, and ADOT will monitor compliance through periodic
review of station records and site visits.

Requirements:
 ADOT will require that, apart from apprentices, all electricians installing and
maintaining EVSE must be certified through EVITP or be a graduate of a Registered
Electrical Apprenticeship Program that includes EVSE-specific training and is
developed as part of a national guideline standard approved by the Department of
Labor in consultation with the Department of Transportation.

 For projects requiring more than one electrician, at least one electrician must meet
the requirements above, and at least one electrician must be enrolled in an
electrical registered apprenticeship program.

 Other onsite, non-electrical workers involved in the installation, operation, and

maintenance of EVSE must have graduated from a registered apprenticeship
program or have the appropriate licenses, certifications, and training as required by
the State.

ADOT will consider additional strategies for recommendation to EVSE owners to help them enhance
labor and workforce considerations at charging stations and the overall network.

Recommendations:
 ADOT will consider funding individual EVITP certifications as part of the contract for
EVSE deployment.

 ADOT will inform site owners that several additional USDOT funding and finance
programs are also available to support workforce training for innovative
technologies.

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 ADOT will also consider partnering with other government agencies who develop
programs that increase women and minority participation, address workforce gaps,
build skills supporting emerging transportation technologies, and attract new
sources of job-creating investment.

 ADOT will aim to encourage EVSE owner participation with training providers,
including existing pre-apprenticeship and apprenticeship programs, workforce
boards, labor unions, community-based organizations, and nonprofits to support a
diverse, local workforce for the EVSE network. To build a diverse, local EVSE
workforce, ADOT plans to encourage EVSE owners to coordinate with and hire from
the below list of existing electrician licensing, certification, and apprenticeship
programs. ADOT will reevaluate opportunities at these and other programs
annually.

 Existing electrician licensing and certification programs:

 AZ Department of Economic Security Apprenticeship Office: Arizona's

Apprenticeship Program40

 Pima Community program (certification and associate degrees)

 Gateway Community College (certification and associate degrees)

 Chandler-Gilbert Community College (certification)

 Existing electrician apprenticeship programs:

 ABA-AGC Education Fund

 Independent Electrical Contractors of Southern Arizona

 Independent Electrical Contractors Association

 Tucson Electrical Joint Apprenticeship and Training Committee (JATC)

Program

 National Electrical Contractors Association Apprenticeship Program

 Western Electrical Contractors Association

 Globe-Miami Electrical Jt. Apprenticeship and Training program Phoenix

Electrical JATC

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Physical Security & Cybersecurity
Owners of EVSE stations will be responsible for meeting the cybersecurity requirements defined within
this section of the Plan, the cybersecurity specification attached as Appendix D, and other applicable
State and Federal regulations. The specification in Appendix D may require updates in future
publications depending on future guidance. The cybersecurity requirements posed here will ultimately
work to ensure the safety and security of planned EVSE infrastructure. Requirements will include
considerations for secure system updates, event logging and intrusion detection, secure operation of
EVSE during communication outages, ensuring appropriate encryption systems are in use, and identity
and access management processes. The following are based on compliance with the NEVI Standards and
Requirements (23 CFR 680).

Requirements
● Provide feasible plans and agreements to address how service will persist in the event of a
communications outage. Required output from owners must properly define the minimum amount
of information necessary to continue providing service to customers, how that information will be
securely stored on the EVSE and illustrate ways that the physical connection to the vehicle will be
secured while operating in this mode.

● Enact appropriate physical security measures. These practices must include procedures pertaining to
physical access allowed to EVSE by customers and service technicians in order to prevent physical
tampering of equipment. Enact physical security strategies to address lighting, siting, driver and
vehicle safety, fire prevention, tampering, charger locks, and illegal surveillance of payment devices.
Additionally siting and station design to ensure visibility from onlookers, video surveillance or
emergency call boxes.

● Adhere to strict identity and access management procedures based on industry best practices to
prevent administrative or technological access to equipment by unauthorized personnel.

● Adopt the most current and stable encryption mechanisms to secure any data stored and
communicated as which is relevant for service provision to customers.

● Adhere to update and patch management procedures adherent to industry standards and best
practices. This works to mitigate the possibility of malware installation and propagation throughout
the EVSE network and its vehicular connections.

● Employ mechanisms to detect malware and intrusion attempts into the system. Documented proof is
required to ensure the functional capabilities of these mechanisms, which ensure the ability to
detect and respond to cybersecurity exposures and potential breaches and additionally to reduce
the risk of malware installation and propagation throughout the charging network and vehicular
connections.

● Employ event logging and reporting of auditable events, such as logins, failed logins, high-value
transactions, warnings and error messages, input validation errors, etc. Documented proof is
required to ensure accountability, visibility, incident alerting, and forensics.

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● Demonstrate that appropriate cybersecurity assessments are conducted at least annually on
deployments and equipment in accordance with the National Institute of Standards and Technology
Special Publication (SP) 800-115.

● Ensure the protection of collected, stored, and communicated customer payment information.
Ensure that only the minimum required customer payment information is collected, stored, and
communicated with appropriate payment services and administration centers as applicable.

● Provide feasible plans for how they will address future cybersecurity considerations as they pertain
to the equipment and charging network. As new cybersecurity incidents occur and exposures are
discovered, the cybersecurity posture of EVSE deployed must scale and adapt to meet the further
growing security requirements and best practices.

● Cybersecurity requirements and guidance provided by the latest revisions of applicable standards
and regulations shall be adhered to. These include, but are not limited to:

o NEVI Standards and Requirements (23 CFR 680)

o Architecture Reference for Cooperative and Intelligent Transportation (ARC-IT)

o National Institute of Standards and Technology (NIST)

o SP 800-53

o SP 800-115

o Arizona Statewide Policy (8130) System Security Acquisition and Development

o Payment Card Industry Data Security Standard (PCI DSS)

o Health Insurance Portability and Accountability Act (HIPAA)

o North American Electric Reliability Corporation Critical Infrastructure Protection (NERC CIP)

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 Program Evaluation
ADOT’s data-driven program evaluation plan will ensure accountability, evaluate performance toward
meeting the State’s vision and goals for the EV Plan, and meet NEVI Formula Program Guidance
requirements by monitoring three key areas of success: data collection, equitable access, and network
reliability. ADOT intends to monitor and report progress as required by FHWA, in compliance with 23
CFR 680.112. This plan will be revisited and updated annually to address opportunities for improvement.

Metrics
ADOT will monitor and evaluate the program using the metrics in Table 32. A summary can be found in
Appendix B. The Performance Goals in the following bullets refer to the Goals set in the Plan Vision and
Goals section.
Table 32: Program Evaluation Metrics
Performance Goal Metric Frequency of Data Source
Measurement
Develop a Number of new EV Annually ADOT charging station location
convenient public charging stations identifier for potential new EV
EVSE network along developed charging stations
Arizona’s AFCs (Plan
Goals 1, 2, 4, 6)
Provide access to EV adoption rates Annually ADOT Motor Vehicle Division, vehicle
program benefits registration records
(Plan Goals 1, 2, 3,
Estimated number of Annually ADOT
4, 5, 6)
EV charging stations
installed
Percentage of Annually Contract and reporting information
minority, and veteran from station owners
and/or woman-owned
businesses that
participate in the
operation,
maintenance, and
installation of EV
charging stations

109
Performance Goal Metric Frequency of Data Source
Measurement
Achieve a resilient, Number of charging Quarterly Total hours of outage and total hours
equitable, stations that meet the of outage for reasons outside the
accessible, and EV charging uptime charging station operator’s control
reliable EV charging (functioning) goal of
network (Plan Goals 97% (calculated as
2, 5, 6) required by program
guidance) at the
individual port level
EV charging station Quarterly EV charging stations utilization
utilization rates metrics including the number of
charging sessions, energy (kWh)
dispensed per session and successful
session completion
Installation costs per One Time Real property acquisition cost,
EV charging station charging connection, and upgrade
cost on the utility side of the electric
meter, equipment acquisition and
installation cost, DER acquisition and
installation cost, and grid connection
and upgrade costs paid by the
charging station operator

Operating costs per Annually Total maintenance and repair costs

EV charging station per charging station
Number of EV One Time DER installed capacity, in kW or kWh
charging stations with as appropriate, of asset by type (e.g.,
DERs stationary battery, solar, etc.) per
charging station
Maintain high Number of Annually ADOT stakeholder engagement
stakeholder engagement activities records
engagement in the held
development of the
Number of Annually ADOT stakeholder engagement
EV charging
engagement activities records
network (Plan Goals
held among DACs and
2, 3, 4, 6)
tribal communities

110
Performance Goal Metric Frequency of Data Source
Measurement
Number of Annually ADOT stakeholder engagement
participants in records
engagement activities
Efficient use of Quantity of funds Annually ADOT FFY funding records
Federal funding distributed
measured by
Charging station Annually Number of successful EV charging
amount of charging
utilization rate visits per month
leveraged per
Federal Dollar

Annual Plan Update

Before each FFY, ADOT will review and assess program performance using the metrics in the Program
Evaluation Plan and other relevant data. Performance metrics will be made available to the public on at
least an annual basis. Opportunities for improvement will be identified and addressed as necessary
through the Plan’s annual update.

Reporting
Reporting will occur through a one-time data submittal as well as additional quarterly and annual
submittals. The method and format of reporting will be in accordance with that required by the Joint
Office.

Quarterly Reporting
Data will be submitted quarterly on charging station use, including:
● Charging station location and port identifier

● Charging session start time, end time, and successful session completion (yes/no) by port

● Any error codes associated with unsuccessful charging sessions by port

● Energy (kWh) dispensed to EVs per session by port

● Peak session power (kW) by port

● Charging station port uptime, T_outage, and T_excluded calculated in accordance with the equation
in § 680.116(b) for each of the previous 3 months

● Payment method associated with each charging session

Annual Reporting
● Information relating to the operation, installation, or maintenance of EVSE. These reports will
contain:

111
 o For private entities, identification of and participation in any state or local business opportunity
certification programs including but not limited to minority-owned businesses, veteran-owned
businesses, woman-owned businesses, and businesses owned by economically disadvantaged
individuals

o Annual maintenance and repair cost per charging station

● Community Engagement Outcomes metrics will be included in the annual Infrastructure

Deployment Plan. This section will address community engagement activities conducted in
accordance with the approved EV Plan, including:

o Community engagement type

o Dates of community engagement activities

o Numbers of attendees

o Communities represented by attendees

o How community engagement is included and reflected in the Plan

One Time Data Submittal

● Charging station real property acquisition cost

● Charging equipment acquisition and installation cost

● DER acquisition and installation cost

● Grid connection and upgrade cost on the utility side of the electric meter

● DER installed capacity in kW or kWh, as appropriate, of asset by type (e.g., stationary battery, solar,
etc.) per charging station

● The name, address and type of private entity involved in the operation, maintenance, and
installation of EVSE

● Aggregated grid connection and upgrade costs paid to the electric utility as part of the project
separated into total distribution and system costs, and total service costs

112
 Appendix A Arizona EV Deployment Plan Exception Request
ADOT is requesting two continued discretionary exemptions from the requirement that charging
infrastructure be installed every 50 miles along the State’s AFCs that were approved for the 2022 Plan.
The proposed discretionary exemptions are described in Table A-1 and shown in Figure A-1.

Table A-1: Discretionary Exemption Requests

A-1
 Figure A-1: Map of Discretionary Exemption Requests

Justification for Exceptions

Kingman to Seligman
The 57-mile segment between Kingman and Seligman on I-40 is a rural area with no existing amenities
within one mile of the corridor. ADOT limited the distance of this gap as much as possible in the new
station proposal just east of Kingman. The proposed exemption is for a 7-mile gap as NEVI-compliant
chargers will be sited 57-miles apart from each other.

Gila Bend to Casa Grande/Eloy

East of Gila Bend on I-8 is a rural area with no existing amenities within one mile of the corridor until
reaching the interchange with I-10. ADOT proposed upgrading the Casa Grande existing stations and a
new site in Eloy to ensure convenient charging options for both westbound and eastbound routes on I-
10. The proposed exemption is for a 17-mile gap as NEVI-compliant chargers will be sited 67 miles apart
from each other.

A-2
 Appendix B Supporting Materials
Table B-1: Performance Evaluation Metrics Summary Table
Performance Goal Metric Frequency of Data Source
Measurement
Develop a Number of new EV Annually ADOT charging station location
convenient public charging stations identifier for potential new EV
EVSE network along developed charging stations
Arizona’s AFCs (Plan
Goals 1, 2, 4, 6)
Provide access to EV adoption rates Annually ADOT Motor Vehicle Division, vehicle
program benefits registration records
(Plan Goals 1, 2, 3,
Estimated number of Annually ADOT
4, 5, 6)
EV charging stations
installed
Percentage of Annually Contract and reporting information
minority, veteran from station owners
and/or woman-owned
businesses, and/or
economically
disadvantaged
businesses, that
participate in the
operation,
maintenance, and
installation of EV
charging stations
Achieve a resilient, Number of charging Quarterly Total hours of outage and total hours
equitable, stations that meet the of outage for reasons outside the
accessible, and EV charging uptime charging station operator’s control
reliable EV charging (functioning) goal of
network (Plan Goals 97% (calculated as
2, 5, 6) required by program
guidance) at the
individual port level
EV charging station Quarterly EV charging stations utilization
utilization rates metrics including the number of
charging sessions, energy (kWh)
dispensed per session and successful
session completion

B-1
Performance Goal Metric Frequency of Data Source
Measurement
Installation costs per One Time Real property acquisition cost,
EV charging station charging connection, and upgrade
cost on the utility side of the electric
meter, equipment acquisition and
installation cost, DER acquisition and
installation cost, and grid connection
and upgrade costs paid by the
charging station operator

Operating costs per Annually Total maintenance and repair costs

EV charging station per charging station
Number of EV One Time DER installed capacity, in kW or kWh
charging stations with as appropriate, of asset by type (e.g.,
DERs stationary battery, solar, etc.) per
charging station
Maintain high Number of Annually ADOT stakeholder engagement
stakeholder engagement activities records
engagement in the held
development of the
Number of Annually ADOT stakeholder engagement
EV charging
engagement activities records
network (Plan Goals
held among DACs and
2, 3, 4, 6)
tribal communities
Number of Annually ADOT stakeholder engagement
participants in records
engagement activities
Efficient use of Quantity of funds Annually ADOT FFY funding records
Federal funding distributed
measured by
Charging station Annually Number of successful EV charging
amount of charging
utilization rate visits per month
leveraged per
Federal Dollar

B-2
 Appendix C Utility Capacity
Determining the available capacity on electric distribution infrastructure for proposed EV charging
station locations allows cities and community planners to understand whether grid upgrades will be
needed. Such upgrades can include substation level upgrades to increase capacity or re-wiring of
distribution lines. Grid upgrades are a complex undertaking and can often include significant costs. This
coupled with considerations such as long lead supply chain items that add to implementation schedules
can create delays and complexities in deployment. To better understand grid capacity and ensure that
the local grid has sufficient capacity for planned deployments, surveys were sent to each utility serving
proposed sites as part of the technical effort supporting the Plan. Results are still ongoing and further
utility responses are still awaiting from routes in the following Table C-1.

Table C - 1: Utility Substation Survey

3 Phase 600kW
Serving
Charger Location Route Exit Number/ Street Service Capacity
Utility
Available Available
2023
Page US 89 Haul Rd. TBD TBD TBD

The Gap US 89 498 US 89, Cameron, AZ

86020 APS No Yes
Cameron Bridge Bypass
Cameron US 89
Rd. APS Yes
Fort McDowell SR 87 Fort McDowell Rd. TBD TBD TBD
Rye SR 87 S. Beeline Hwy APS Yes Yes

Forest Lakes Estates SR 260

Highway Lp. APS Yes Yes
Overgaard SR 260 Mogollon TBD TBD TBD
Maricopa SR 347 W. Smith Enke Rd. TBD TBD TBD
Valle SR 64 US 180 APS Yes Yes
Lake Havasu City SR 95 McCulloch Blvd N. TBD TBD TBD
Parker SR 95 W. Riverside Dr. APS Yes Yes
Yes, 3 phase
within 2000ft
of
Tuseyan SR 64 Long Jim Loop APS intersection Yes

Willow Beach US 93 CR 145 TBD TBD TBD

2022
Capacity
will be
Camp Verde1 I-17 287 APS Yes
Available
in 2025
Casa Grande I-17 194 APS Yes Yes
Cordes Lakes / Cordes
I-17 262 APS Yes Yes
Junction
Eloy I-10 200 APS Yes Yes

C-1
 Gila Bend I-8 115 APS Yes Yes
Green Valley I-19 69 TEP/Trico Yes Yes
Holbrook I-40 286 APS Yes Yes
Mohave
Kingman I-40 66 Electric Yes Yes
Cooperative
Lake Havasu City I-40 9 TBD TBD TBD
Munds Park I-17 322 APS Yes Limited
Nogales I-19 4 Unisource Yes Yes
Petrified Forest I-40 311 APS Yes Yes
Salome I-10 45 APS Yes Limited
San Simon I-10 378 SSVEC Yes Yes
Navopache
No
Sanders I-40 339 Electric No Response
Response
Cooperative
Seligman I-40 123 APS Yes Yes
Welton –
Mohawk No
Tacna I-8 42 No Response
Irrigation Response
District
Tonopah I-10 94 APS Yes Yes
Tucson I-10 273 TEP Yes Yes
APS
APS does not would
APS &
Twin Arrows2 I-40 219 have 3 phase require
NTUA
service grid
upgrades
Willcox I-10 340 SSVEC Yes Yes

DCFC typically require three phase, 480 V input service to operate. Four 150 kW DCFC units, as specified
by NEVI also require 600 kW of power capacity available if all units are operational. Based on the survey,
sixteen of the twenty proposed sites of locations identified in the Plan have capacity and service
conditions available to support DCFC charging stations. Hence, no major grid infrastructure upgrades
would be required for these sites based upon current conditions. It should be noted that some utilities
did not respond to the survey provided. In these instances, further utility coordination would be needed
for these sites.

As grid conditions consistently change, establishing early utility engagement to confirm grid capacity is
important as well as continuous utility engagement throughout the entirety of planning and
deployment. Early engagement also streamlines installation timelines and can help mitigate supply chain
concerns of electrical components, such as transformers. The Plan details highway exits to site proposed
chargers, additional best practices can be followed to reduce the amount of electrical upgrades. Best
practices include siting chargers near existing electric infrastructure to minimize conduit runs and closer
to substations so as to be more likely to have available capacity. Additionally, distributed energy
resources (DERs) should be investigated as potential technologies to co-locate at charger sites to help
supplement energy needs, reduce emissions from EV charging, and avoid costly peak demand charges.

C-2
Appendix D Cybersecurity Specifications

ADOT EV Charging
Infrastructure Cybersecurity
Specification

D-1
CHAPTER 1. TERMINOLOGY AND ABBREVIATIONS
ACRONYMS
Abbreviation Meaning
ADOT Arizona Department of Transportation
ARC-IT Architecture Reference for Cooperative and Intelligent Transportation
CISA Cybersecurity and Infrastructure Security Agency
CSO Charging Station Operator
CSMS Charging Station Management System
CVE Common Vulnerabilities and Exposures
EV Electric Vehicle
EVSE Electric Vehicle Supply Equipment
ICS-CERT Industrial Control Systems Cyber Emergency Response Team
ITS Intelligent Transportation Systems
IVI In-Vehicle Infotainment Center
NEVI National Electric Vehicle Infrastructure
NERC-CIP North American Electric Reliability Corporation Critical Infrastructure Protection
NIST National Institute of Standards and Technology
OBE On-Board Equipment
OCPP Open Charge Point Protocol
PCI DSS Payment Card Industry Data Security Standard

TERMS
Term Definition
Charging Station The physical system where Electric Vehicles can be charged.
Charging Station Operator The mobility partner who operates the charging station
infrastructure. For purposes of this specification this term will
simultaneously refer to the Charging Station Vendor since the
vendor is fulfilling this same role.
Connector/Plug An independently operated and managed electrical outlet on a
charging station which corresponds to a single physical connector.
Electric Vehicle Supply An independently operated and managed part of the charging
Equipment station that can deliver energy to one EV at a time.

D-2
REQUIREMENTS TERMINOLOGY
The key words “MUST,” “MUST NOT,” “REQUIRED,” “SHALL,” “SHALL NOT,” “SHOULD,” SHOULD NOT,”
“RECOMMENDED,” “MAY,” and “OPTIONAL” in this document are to be interpreted as described in the
Internet Engineering Task Force Requests for Comment 211041 and 2119, 42 which are defined in the
below table.

Key Word Definition

MUST This word, or the terms “REQUIRED” or “SHALL,” mean that the
definition is an absolute requirement of the specification.
MUST NOT This phrase, or the phrase “SHALL NOT,” mean that the definition is
an absolute prohibition of the specification.
SHOULD This word, or the adjective “RECOMMENDED,” mean that there
may exist valid reasons in particular circumstances to ignore a
particular item, but the full implications must be understood and
carefully weighed before choosing a different course.
SHOULD NOT This phrase, or the phrase “NOT RECOMMENDED” mean that there
may exist valid reasons in particular circumstances when the
particular behavior is acceptable or even useful, but when the full
implications should be understood, and the case carefully weighed
before implementing any behavior described in this label.
MAY This word, or the adjective “OPTIONAL,” mean that an item is truly
optional. One vendor may choose to include the item because a
particular marketplace requires it or because the vendor feels that
it enhances the product while another vendor may omit the same
item. An implementation which does not include a particular option
MUST be prepared to interoperate with another implementation
which does include the option, though perhaps with reduced
functionality. In the same vein an implementation which does not
include a particular option MUST be prepared to interoperate with
another implementation which does not include the option (except,
of course, for the feature the option provides.)

D-3
CHAPTER 2. INTRODUCTION
PURPOSE
The purpose of this specification is to establish a statewide cybersecurity standard for the deployment
of Electric Vehicle (EV) charging infrastructure along the state’s NEVI Formula Program funded EV
charging installations by illustrating cybersecurity provisions derived from federal laws and regulations,
and industry best standards to create cybersecurity requirements which the Charging Station Operator
(CSO) MUST strictly and completely fulfill regarding the deploying and maintaining of EV charging
infrastructure throughout the state of Arizona’s EV charging installations.

Through strict adherence to the requirements in this document, the CSO can assure ADOT that the EV
charging infrastructure met a baseline of substantial cybersecurity controls throughout ADOT’s EV
Infrastructure Deployment Plan.

SCOPE
 Requirements in this specification apply strictly to and are the responsibility of the CSO.

 Requirement items in this specification MUST be strictly and completely fulfilled by the
CSO and submitted to ADOT for assessment.

D-4
CHAPTER 3. CYBERSECURITY RATIONALE
To establish the foundation of cybersecurity for the state of Arizona’s EV charging installations, ADOT
has constructed a set of requirements which correspond with both federal laws & regulations and
industry best practice cybersecurity controls. These requirements are based primarily on cybersecurity
provisions from the NEVI Formula Program Guidance and the National Electric Vehicle Infrastructure
Standards and Requirements (Title 23 CFR Part 680)43 and the National ITS Architecture and Standards
(ARC-IT) conformity requirements from the Intelligent Transportation System Architecture and
Standards (Title 23 CFR Part 940).44 The narrative for requirement creation and steps are described
herein.

CONTROL MAPPING
A crosswalk mapping all relevant cybersecurity provisions present in the various requirement sources
and NIST SP 800-5345 was created. Primary and secondary requirement sources utilized in this mapping
are described below.

PRIMARY
NEVI

In order to address the cybersecurity provisions in Title 23 CFR Part 680, each provision was mapped to
applicable cybersecurity controls defined in NIST SP 800-53r5 Security and Privacy Controls for
Information Systems and Organizations. 46

ARC-IT

Next, the cybersecurity requirements defined in ARC-IT’s Device Class 5 Areas47 (the security class
applicable to ARC-IT’s “Electric Charging Station” physical object) were mapped to applicable NIST SP
800-53 controls in much the same manner.

SECONDARY
Statewide Policy (8130): System Security Acquisition and Development

ADOT relied on its own System Security Acquisition and Development Statewide Policy (P8130),48 which
contains relevant third-party information system acquisition and deployment controls for the Payment
Card Industry Data Security Standard49 (PCI DSS) and the Health Insurance Portability Act50 in order to
meet the customer and payment info cybersecurity considerations defined in Title 23 CFR Part 680. The
PCI DSS and HIPAA controls51 contained within this statewide policy document were mapped to the
applicable NIST SP 800-53 controls.

North American Electric Reliability Corporation Critical Infrastructure Protection (NERC CIP)

To address the cybersecurity consideration contained within Title 23 CFR Part 680 defining the security
of Charging-Network-to-Grid Communication, NERC CIP standards were utilized (NERC CIP-011-2
“Information Protection” Requirements 1.1 & 1.2)52 and mapped to NIST SP 800-53.

D-5
CONTROL BASELINE
An initial cybersecurity baseline was constructed in accordance with NIST SP 800-53Br5 Control
Baselines for Information Systems and Organizations53 tuned to the Security Control Baseline of “High”,
which was further modified with supplemental controls which were a product of the mapping crosswalk.

CREATION OF REQUIREMENTS
Submission of NIST SP 800-53A Assessment
Title 23 CFR Part 940 pertains to additions of modifications to ITS systems which are funded partly or in
whole by the Highway Trust Fund.54 This requirement was created to fulfill the conformity provisions
present in Title 23 CFR Part 940 as it pertains to ITS conformity requirements with The National ITS
Architecture and Standards (ARC-IT), of which therein defines “Securing ITS” as a core architectural
directive. Fulfillment of the current cybersecurity baseline (Appendix A) covers the physical components
with the security class of ARC-IT's Device Class 5 Areas.55

Fulfillment of Cybersecurity Compliance Controls Table

This requirement was created to meet cybersecurity provisions defined in Title 23 CFR Part 680 by taking
each particular cybersecurity provision and citing the cybersecurity baseline and component each
provision should apply to. From there, the CSO MUST submit their plan to meet each requirement in the
table.

Security Testing and Assessment - NIST SP 800-115

This section elaborates on the expectations with respect to security testing and assessment, guided by
NIST SP 800-115 Technical Guide to Information Security Testing and Assessment. 56 The goal of this
guidance is to ensure that vendors and owners regularly conduct security testing and assessments to
demonstrate the effectiveness of security controls established in equipment, software, and networks
utilized by EV charging infrastructure components. The CSO shall ensure that the activities outlined in
NIST SP 800-115 are conducted on a regular interval, which includes policy reviews, vulnerability
assessments, penetration testing, and others, as well as creating and maintaining a plan which shall
define the logistical and technical details required to execute these activities.

D-6
CHAPTER 4. EV CHARGING INFRASTRUCTURE COMPONENTS
This section illustrates the multiple components which comprise electric vehicle charging infrastructure
as defined in ARC-IT and OCPP diagrams and documentation. For the purpose of this specification, the
CSO MUST address requirements for each relevant component listed when filling out requirements (see
Chapter 5. Cybersecurity requirements for further details).

COMPONENT LIST

Below is a list of components owned by the CSO which facilitate the charging station’s functionality.

Component Description
Electric Vehicle Charging Provides access to electric vehicle supply equipment that is used to charge
Station hybrid and all-electric vehicles. For the purpose of this specification, this
component will include the EVSE and connector(s). This component is
provided, owned, and managed by the CSO.
CSMS The system utilized by the CSO to manage charging stations. A majority of
the CSMS core functions, including collection and management, overlap
with that of the Traffic Information Center defined in ARC-IT. This system is
owned and managed by the CSO.
PCI DSS Compliant Supports vehicle payments for charging of EVs. Charging stations may
Vehicle Payment Service utilize various methods of payment, to include an interface on the
charging station itself which accepts debit/credit payment, or contactless
methods in which the operator engages with the charging station remotely
via either a mobile phone application or other OBE methods such as in-
vehicle applications via the EV’s IVI. Payment service mechanisms are
provided, owned, and managed by the CSO.
PCI DSS Compliant Provides general payment administration capabilities and supports the
Payment Administration electronic transfer of funds from the customer to the CSO for charging
Center services rendered. This system may be owned and managed by the CSO.

D-7
COMPONENT DIAGRAMS

Below are physical and interface diagrams of EV charging stations from ARC-IT and OCPP
documentation. These are included as a resource for the CSO and others to describe the various
components of EV charging infrastructure. [Note: “Electric Charging Station” as labeled by these ARC-IT
diagrams is synonymous with “EV Charging Station” as utilized in this document.]

ARC-IT
ST05: Electric Charging Stations Management57 – Physical Diagram

Figure E-4-1. ARC-IT Physical Diagram - ST05: Electric Charging Stations Management

D-8
Electric Charging Station – Interfaces Diagram

Figure E-4-2. ARC-IT Interfaces Diagram – Electric Charging Station

D-9
Open Charge Point Protocol

Figure E-4-3. 3-tier model as used in OCPP

D-10
CHAPTER 5. CYBERSECURITY REQUIREMENTS

This section contains mandatory cybersecurity requirements the CSO must fulfill. These requirements
exist to fulfill the following cybersecurity provisions:

 Cybersecurity considerations present in the NEVI Formula Program and requirements defined the
NEVI Formula Program Guidance and the National Electric Vehicle Infrastructure Standards and
Requirements (Title 23 CFR 680). View Appendix B for exact definitions.
 Device Class 5 Areas58 (security Controls) defined in the National ITS Architecture
Reference/Architecture Reference for Cooperative and Intelligent Transportation (ARC-IT) for Electric
Charging Station59 and Vehicle Payment Service.60 View Appendix B for exact definitions.


The mandatory cybersecurity requirements are detailed in section REQUIREMENT SUBMISSION

GUIDELINES below, and steps include:

7. Submission of NIST SP 800-53A Assessment61

8. Fulfillment of Cybersecurity Compliance Controls Table
9. Security Testing and Assessment – NISP SP 800-11562

Though these requirements may be addressed in any order, it is RECOMMENDED that the CSO
address each requirement in numerical order. By completing step 1 Submission of NIST SP 800-53A
Assessment first, this significantly expedites step 2 Fulfillment of Cybersecurity Compliance Controls
Table.


REQUIREMENT SUBMISSION GUIDELINES

Submission of NIST SP 800-53A Assessment

The CSO is required to submit the attached NIST SP 800-53A assessment spreadsheet, fulfilling each
control listed in Table E-6A-1. Cybersecurity Control Baseline in Appendix A. Fulfillment of each control
must be met for each component as applicable. If a control is deemed as non-applicable for one or more
components, then CSO must provide further detail in Column I – “EXPLANATION & COMMENTS” of the
assessment document. For certain requirements with no present control, the CSO must provide a
detailed explanation as to how exactly they are meeting the requirement for each component. While
this baseline has been designed to incorporate PCI-DSS required controls outlined in ADOT P8130, the
CSO shall be responsible for putting further controls in place as required by the latest version of the PCI
DSS for payment systems.

While assessing each control, the CSO MUST annotate in Column I – “EXPLANATION & COMMENTS” how
each control is applying to each component.

D-11
Cybersecurity Compliance Controls Table
Each requirement listed in the Cybersecurity Compliance Controls Table must be addressed and filled
out in full by the CSO.

Column/Field Descriptions & Requirements

Cybersecurity Compliance Controls Table Columns

Column Description

# Numeric identifier of each requirement.

Requirement The stated cybersecurity requirement which must be met by the CSO.

Baseline Controls The controls which fulfill the stated requirement.

Comp. Code Component code for each component a requirement applies to. The codes are
as follows:

- CS: EV Charging Station

- MS: CSMS
- PS: Vehicle Payment Service
- PA: Payment Administration Center

If one of more of the components listed above are deemed as non-applicable to

the charging station deployment by the CSO, then the CSO must provide in
detail which components meet non-applicable status and a detailed
explanation as to why it’s non-applicable. This explanation must be provided in
the column titled “Compliance Description” on how they are to meet said
requirement. The CSO may also add listed component codes to this cell which
weren’t previously listed by default and must provide a detailed explanation on
that component’s inclusion into the requirement. Requirements will apply to all
newly added component(s).

Compliance Status CSO must denote compliance status by inputting a bold and capitalized X in the
sub-column:

- Yes if the requirement is fully and strictly met for all listed component
codes for the relevant requirement.
- No if requirements are not fully and strictly met for 1 or more of the
listed component codes for the relevant requirement.

Compliance This is where the CSO must describe:

Description
- Compliance status.
- Plan to address compliance for the relevant requirement item.

D-12
 - Any components which are deemed as non-applicable for the charging
infrastructure deployment and a detailed explanation as to why.
- Any added components outside of the default listed components which
are deemed as applicable to the charging infrastructure deployment,
and a detailed explanation as to why.

Each cell contains default pre-filled text which may contain additional
information or description needs which the CSO must address in their entry.

D-13
Cybersecurity Compliance Controls Table

# Requirement Initial Control Comp. Compliance Compliance Description

Baseline Code Status

Yes No

1 Ensure contactless NIST SP 800- CS; A detailed plan shall be

remote payment 53 Control provided that addresses
MS;
methods are secure. Numbers: how contactless payment
PS; methods will be secured
AC-4;AC-
on the charging station.
10;AC-25;CA- PA
Include payment
2;CA-7;CA-
methods applicable to
8;PE-3;PL-
the charging station in
8;PM-4;RA-
explanation (i.e., mobile
3;RA-5;SA-
app, terminal payment,
3;SA-4SA-
etc). This plan shall
5;SA-8;SA-
additionally incorporate
10;SA-11;SA-
and maintain compliance
15;SA-17;SC-
with all elements of the
7;SI-2;SI-3:SI-
latest versions of PCI DSS
4;SI-5;SI-12;
and PCI SCC.
SI-13; SI-14;
SI-16; SI-
17;SR-2;SR-
3;SR-4;SR-
5:SR-6;SR-
7;SR-8;SR-
9;SR-10

2 Physical security NIST SP 800- CS A detailed plan shall be

strategies to address EV 53 Control provided that addresses
charging station Numbers: physical security
tampering and strategies of the charging
PE-1;PE-2;PE-
unauthorized access. station.
3;PE-4;PE-
5;PE-6;PE-
8;PE-9;PE-
10;PE-11;PE-
12;PE-13;PE-
14;PE-15;PE-
16;PE-17;PE-
18

D-14
3 Cybersecurity strategies NIST SP 800- CS; A detailed plan shall be
to address user identity 53 Control provided that addresses
MS;
and access management, Numbers: user identity and access
selection of appropriate PS management, selected
AC-1;AC-2;AC-
encryption systems, encryption systems,
3;AC-5;AC-
intrusion and malware intrusion and malware
6;AC-7;AC-
detection, event logging detection, event logging
8;AC-10;AC-
and reporting, and reporting,
11;AC-12;AC-
management of software management of software
14;AC-17;AC-
updates, and secure updates, and secure
18;AC-19;AC-
operation during operation during
20;AC-21;AC-
communication outages. communication outages.
22;AU-1;AU-
2;AU-3;AU-
4;AU-5;AU-
To address “…secure
6;AU-7;AU-
operation during
8;AU-9;AU-
communication outages”
10;AU-11;AU-
describe the plan in
12;IA-1;IA-
detail on how you will
2;IA-3;IA-4;IA-
persist service under this
5;IA-6;IA-7;IA-
circumstance.
8;IA-11;IA-
12;MA-1;MA-
2;MA-3;MA-
4;MA-5;MA-6;
SI-1;SI-2;SI-
3;SI-4;SI-5;SI-
6;SI-7;SI-8;SI-
10;SI-11;SI-
12;SI-16;SI-18

4 Ensure secure collection, NIST SP 800- CS; A detailed plan shall be

processing, and 53 Control provided that addresses
MS;
retention of only the Numbers: how the charging station
personal information PS; will account for and
AC-1;AC-2;AC-
strictly necessary to enact secure collection,
3;AC-5;AC- PA
provide charging service processing, and retention
6;AC-7;AC-
to the customer, to of personal information
8;AC-10;AC-
include information strictly necessary to
11;AC-12;AC-
required to complete the provide charging service.
14;AC-17;AC-
charging transaction.
18;AC-19;AC-
20;AC-21;AC-

D-15
22;AT-1;AT-
2;AT-3;AT-
4;AU-1;AU-
2;AU-3;AU-
4;AU-5;AU-
6;AU-7;AU-
8;AU-9;AU-
10;AU-11;AU-
12;CA-1;CA-
2;CA-3;CA-
5;CA-6;CA-
7;CA-8;CA-
9;IR-1;IR-2;IR-
3;IR-4;IR-5;IR-
6;IR-7;IR-
8;MP-1;MP-
2;MP-3;MP-
4;MP-5;MP-
6;MP-7;PL-
1;PL-2;PL-
4;PL-8;PL-
10;PL-11;PM-
3;PM-5;PM-
18;PM-19;PM-
20;PM-21;PM-
22;PM-24;PM-
25;PM-26;PM-
27;PT-2;PT-
3;PT-4;PT-
5;PT-6;SA-
1;SA-2;SA-
3;SA-4;SA-
5;SA-8;SA-
9;SA-10;SA-
11;SA-15;SA-
16;SA-17;SA-
21;SA-22;SI-
1;SI-2;SI-3;SI-
4;SI-5;SI-6;SI-
7;SI-8;SI-10;SI-

D-16
 11;SI-12;SI-
16;SI-18

5 Enact Charger-to- NIST SP 800- CS; A detailed plan shall be

Charger-Network 53 Control provided that addresses
MS
communications using a Numbers: how the charging station
secure communication will secure
SC-1;SC-2;SC-
method. communications to its
3;SC-4;SC-
charging network.
5;SC-7;SC-
8;SC-10;SC-
12;SC-13;SC-
15;SC-17;SC-
18;SC-20;SC-
21;SC-22;SC-
23;SC-24;SC-
28;SC-39

6 Ensure charging stations NIST SP 800- CS; A detailed plan shall be

have the ability to 53 Control provided that addresses
MS
receive and implement Numbers: how the charging station
secure remote software will secure remote
AC-1;AC-2;AC-
updates, conduct real- software update receipt
3;AC-5;AC-
time protocol and implementation,
6;AC-7;AC-
translations, encryption conducts real-time
8;AC-10;AC-
and decryption, protocol translations,
11;AC-12;AC-
authentication, and handles encryption and
14;AC-17;AC-
authorization in their decryption, enacts
18;AC-19;AC-
communications with authentication and
20;AC-21;AC-
charging networks. authorization in
22;AU-1;AU-
communications within
2;AU-3;AU-
their charging networks.
4;AU-5;AU-
6;AU-7;AU-
8;AU-9;AU-
10;AU-11;AU-
12;IA-2;IA-
3;IA-4;IA-5;IA-
6;IA-7;IA-8;IA-
11;IA-12;MA-
1;MA-2;MA-
3;MA-4;MA-
5;MA-6;SC-

D-17
 1;SC-2;SC-
3;SC-4;SC-
5;SC-7;SC-
8;SC-10;SC-
12;SC-13;SC-
15;SC-17;SC-
18;SC-20;SC-
21;SC-22;SC-
23;SC-24;SC-
28;SC-39;SI-
1;SI-2;SI-3;SI-
4;SI-5;SI-6;SI-
7;SI-8;SI-10;SI-
11;SI-12;SI-
16;SI-18

7 Ensure charging stations NIST SP 800- CS; A detailed plan shall be

and charging networks 53 Control provided that addresses
MS
securely measure, Numbers: how the charging station
communicate, store, and securely measures,
AC-1;AC-2;AC-
report energy and power stores, communicates,
3;AC-5;AC-
dispensed, real-time and reports required
6;AC-7;AC-
charging-port status, information within their
8;AC-10;AC-
real-time price to the charging networks.
11;AC-12;AC-
customer, and historical
14;AC-17;AC-
charging-port uptime.
18;AC-19;AC-
20;AC-21;AC-
22;SC-1;SC-
2;SC-3;SC-
4;SC-5;SC-
7;SC-8;SC-
10;SC-12;SC-
13;SC-15;SC-
17;SC-18;SC-
20;SC-21;SC-
22;SC-23;SC-
24;SC-28;SC-
39

8 Ensure charging stations OCPP v2.0.1 CS List and provide detail

utilize appropriate Part 2 – here regarding which
cybersecurity use cases Section A2 applicable use cases and

D-18
 and requirements in “Use cases & requirements are fulfilled
their communications Requirements” and how. Additionally,
with any charging list and provide detail
network provider. regarding which use
cases and requirements
are deemed non-
applicable to your
charging station system.

9 Ensure charging stations N/A CS; A detailed plan shall be

are designed to securely provided that addresses
MS
switch charging network the design strategy for
providers without any securely switching
changes to hardware. charging network
providers without any
changes to hardware.

10 Ensure the charging N/A CS; A detailed plan shall be

network must be capable provided that addresses
MS;
of communicating with how the charging
other charging networks PS network will enable
to enable an EV operator utilization of a single
to utilize a single credential for EV
credential to charge at operators to charge at
charging stations that charging stations that are
are a part of multiple a member of multiple
charging networks. charging networks.

11 Ensure charging NIST SP 800- CS; A detailed plan shall be

networks are capable of 53 Control provided that addresses
MS
secure communication Numbers: how the charging
with electric utilities, network will secure its
SI-1; SI-2;SI-
other energy providers, communication with
3;SI-4;SI-5;SI-
or local energy electric utilities, energy
6;SI-7;SI-8;SI-
management systems. providers, and local
10;SI-11;SI-
energy management
12;SI-16;SI-
systems.
18;SR-1;SR-
2;SR-3;SR-
5;SR-6;SR-
8;SR-9;SR-
10;SR-11;SR-
12

D-19
Security Testing and Assessment - NIST SP 800-115
Active assessment and testing of security controls and policies from both procedural and technical
standpoints are critical to verify proper security control implementation and procedure compliance, as
well as to demonstrate their practical effectiveness against modern cyber-attack methodologies. NIST SP
800-115 shall be utilized by system integrators, vendors and owners (CSO) of EV charging infrastructure
as the guiding standard for security testing and assessment of their equipment and networks. For
vendors, efforts shall include code reviews, periodic vulnerability analysis and security testing (white box
and black box) of their equipment. For the CSO and system integrators, similar assessment efforts shall
be conducted at the system level, with a primary focus on the network, interfaces, and site-specific
configuration. Vulnerability scanning and penetration testing shall be conducted at both the equipment
level (by the vendor) and at the system/network level (internal and external) by a professionally certified
tester (e.g., OSCP, PNPT, eCPPT, or similarly qualified with demonstrated hands-on experience) using
modern techniques, frameworks, and tools.

The CSO shall both develop cybersecurity assessment plans in accordance with section 6 of NIST SP 800-
115. Assessment planning shall adhere to the following steps, which are quoted from section 6.7 of this
standard:

 Developing a security assessment policy. Organizations should develop an information security

assessment policy to provide direction and guidance for their security assessments. This policy
should identify security assessment requirements and hold accountable those individuals
responsible for ensuring that assessments comply with the requirements. The approved policy
should be disseminated to the appropriate staff, as well as third parties who are to conduct
assessments for the organization. The policy should be reviewed at least annually and whenever
there are new assessment-related requirements.
 Prioritizing and scheduling assessments. Organizations should decide which systems should
undergo assessments and how often these assessments should be done. This prioritization is
based on system categorization, expected benefits, scheduling requirements, applicable
regulations where assessment is a requirement, and resource availability. Technical
considerations can also help determine assessment frequency, such as waiting until known
weaknesses are corrected or a planned upgrade to the system is performed before conducting
testing.
 Selecting and customizing technical testing and examination techniques. There are many
factors for organizations to consider when determining which techniques should be used for a
particular assessment. Factors include the assessment objectives, the classes of techniques that
can obtain information to support those objectives, and the appropriate techniques within each
class. Some techniques also require the organization to determine the assessors’ viewpoint (e.g.,
internal versus external) so that corresponding techniques can be selected.
 Determining the logistics of the assessment. This includes identifying all required resources,
including the assessment team; selecting environments and locations from which to perform the
assessment; and acquiring and configuring all necessary technical tools. - Developing the
assessment plan. The assessment plan documents the activities planned for an assessment and

D-20
 other related information. A plan should be developed for every assessment to provide the rules
and boundaries to which assessors must adhere. The plan should identify the systems and
networks to be assessed, the type and level of testing permitted, logistical details of the
assessment, data handling requirements, and guidance for incident handling. -
 Addressing any legal considerations. Organizations should evaluate potential legal concerns
before commencing an assessment, particularly if the assessment involves intrusive tests (e.g.,
penetration testing) or if the assessment is to be performed by an external entity. Legal
departments may review the assessment plan, address privacy concerns, and perform other
functions in support of assessment planning.

The CSO SHALL, in concert with the requirement defined in section 3544 of the Federal Information
Security Modernization Act of 2014,63 conduct “periodic testing and evaluation of the effectiveness of
information security policies, procedures, and practices, to be performed with a frequency depending
on risk, but no less than annually.” This is echoed in the recommendation provided by NIST SP 800-115,
which also recommends conducting such reviews “whenever there are new assessment-related
requirements.” NIST SP 800-53 provides further recommendations regarding the frequency of
conducting security assessments. Vulnerability scanning and penetration testing shall be part of the
activities conducted at least annually.

Assessments for payment systems must additionally comply with all PCI-DSS requirements. A PCI
Security Standards Council (SCC) certified Quality Security Assessor (QSA) shall be utilized to determine
the appropriate assessment frequency of EV charging payment systems, to verify that the latest PCI DSS
requirements are being properly met, and to review/recommend changes to plans and controls as
required for the payment system to maintain PCI DSS compliance. Payment software must additionally
comply with PCI SSC Software Standards.

CSO SHALL also actively monitor and react to threat intelligence (including new CVEs and ICS-CERT
advisories related to elements of their systems) which may necessitate re-assessment of their
equipment and/or networks and may require patching or re-configuration to mitigate risk from
emerging threats. Vendors shall immediately inform owners of any such information that may adversely
impact their systems and provide guidance for temporary and long-term mitigation of associated risks.

D-21
CHAPTER 6. APPENDICES
APPENDIX A – CYBERSECURITY BASELINE

Table E-6A-1 contains a listing of identifiers for cybersecurity control families and their enhancements
for environments with a High security control baseline in accordance with NIST SP 800-53B r5, which has
been further modified to include additional controls to meet requirements of Title 23 CFR Part 680, Title
23 CFR Part 940, and the Statewide Policy (8130): System Security Acquisition and Development.

Table E-6A-1. Cybersecurity Control Baseline

CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

Access Control

AC-1 Policy and Procedures AC-1

AC-2 Account Management AC-2 (1) (2) (3) (4) (5) (11) (12) (13)

AC-3 Access Enforcement AC-3

AC-4 Information Flow Enforcement AC-4 (4)

AC-5 Separation of Duties AC-5

AC-6 Least Privilege AC-6 (1) (2) (3) (5) (7) (9) (10)

AC-7 Unsuccessful Logon Attempts AC-7

AC-8 System Use Notification AC-8

AC-10 Concurrent Session Control AC-10

AC-11 Device Lock AC-11 (1)

AC-12 Session Termination AC-12

AC-14 Permitted Actions Without AC-14

Identification or Authentication

AC-17 Remote Access AC-17 (1) (2) (3) (4)

AC-18 Wireless Access AC-18 (1) (3) (4) (5)

AC-19 Access Control for Mobile Devices AC-19 (5)

D-22
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

AC-20 Use of External Systems AC-20 (1) (2)

AC-21 Information Sharing AC-21

AC-22 Publicly Accessible Content AC-22

Awareness and Training

AT-1 Policy and Procedures AT-1

AT-2 Literacy Training and Awareness AT-2 (2) (3)

AT-3 Role-based Training AT-3

AT-4 Training Records AT-4

Audit and Accountability

AU-1 Policy and Procedures AU-1

AU-2 Event Logging AU-2

AU-3 Content of Audit Records AU-3 (1)

AU-4 Audit Log Storage Capacity AU-4

AU-5 Response to Audit Logging Process AU-5 (1) (2)

Failures

AU-6 Audit Record Review, Analysis, and AU-6 (1) (3) (5) (6)
Reporting

AU-7 Audit Record Reduction and Report AU-7 (1)

Generation

AU-8 Time Stamps AU-8

AU-9 Protection of Audit Information AU-9 (2) (3) (4)

AU-10 Non-repudiation AU-10

AU-11 Audit Record Retention AU-11

AU-12 Audit Record Generation AU-12 (1) (3)

Assessment, Authorization, and Monitoring

D-23
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

CA-1 Policy and Procedures CA-1

CA-2 Control Assessments CA-2

CA-3 Information Exchange CA-3 (6)

CA-5 Plan of Action and Milestones CA-5

CA-6 Authorization CA-6

CA-7 Continuous Monitoring CA-7 (1) (4)

CA-8 Penetration Testing CA-8 (1)

CA-9 Internal System Connections CA-9

Configuration Management

CM-1 Policy and Procedures CM-1

CM-2 Baseline Configuration CM-2 (2) (3) (7)

CM-3 Configuration Change Control CM-3 (1) (2) (4) (6)

CM-4 Impact Analyses CM-4 (1) (2)

CM-5 Access Restrictions for Change CM-5 (1)

CM-6 Configuration Settings CM-6 (1) (2)

CM-7 Least Functionality CM-7 (1) (2) (5)

CM-8 System Component Inventory CM-8 (1) (2) (3) (4)

CM-9 Configuration Management Plan CM-9

CM-10 Software Usage Restrictions CM-10

CM-11 User-installed Software CM-11

CM-12 Information Location CM-12 (1)

Contingency Planning

CP-1 Policy and Procedures CP-1

CP-2 Contingency Plan CP-2 (1) (2) (3) (5) (8)

D-24
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

CP-3 Contingency Training CP-3 (1)

CP-4 Contingency Plan Testing CP-4 (1) (2)

CP-6 Alternate Storage Site CP-6 (1) (2) (3)

CP-7 Alternate Processing Site CP-7 (1) (2) (3) (4)

CP-8 Telecommunications Services CP-8 (1) (2) (3) (4)

CP-9 System Backup CP-9 (1) (2) (3) (5) (8)

CP-10 System Recovery and Reconstitution CP-10 (2) (4)

Identification and Authentication

IA-1 Policy and Procedures IA-1

IA-2 Identification and Authentication IA-2 (1) (2) (5) (8) (12)
(organizational Users)

IA-3 Device Identification and Authentication IA-3

IA-4 Identifier Management IA-4 (4)

IA-5 Authenticator Management IA-5 (1) (2) (6)

IA-6 Authentication Feedback IA-6

IA-7 Cryptographic Module Authentication IA-7

IA-8 Identification and Authentication (non- IA-8 (1) (2) (4)

organizational Users)

IA-11 Re-authentication IA-11

IA-12 Identity Proofing IA-12 (3) (4) (5)

Incident Response

IR-1 Policy and Procedures IR-1

IR-2 Incident Response Training IR-2 (1) (2)

IR-3 Incident Response Testing IR-3 (2)

IR-4 Incident Handling IR-4 (1) (4) (11)

D-25
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

IR-5 Incident Monitoring IR-5 (1)

IR-6 Incident Reporting IR-6 (1) (3)

IR-7 Incident Response Assistance IR-7 (1)

IR-8 Incident Response Plan IR-8

Maintenance

MA-1 Policy and Procedures MA-1

MA-2 Controlled Maintenance MA-2 (2)

MA-3 Maintenance Tools MA-3 (1) (2) (3)

MA-4 Nonlocal Maintenance MA-4 (3)

MA-5 Maintenance Personnel MA-5 (1)

MA-6 Timely Maintenance MA-6

Media Protection

MP-1 Policy and Procedures MP-1

MP-2 Media Access MP-2

MP-3 Media Marking MP-3

MP-4 Media Storage MP-4

MP-5 Media Transport MP-5

MP-6 Media Sanitization MP-6 (1) (2) (3) (7) (8)

MP-7 Media Use MP-7

Physical and Environmental Protection

PE-1 Policy and Procedures PE-1

PE-2 Physical Access Authorizations PE-2

PE-3 Physical Access Control PE-3 (1)

PE-4 Access Control for Transmission PE-4

D-26
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

PE-5 Access Control for Output Devices PE-5

PE-6 Monitoring Physical Access PE-6 (1) (4)

PE-8 Visitor Access Records PE-8 (1)

PE-9 Power Equipment and Cabling PE-9

PE-10 Emergency Shutoff PE-10

PE-11 Emergency Power PE-11 (1)

PE-12 Emergency Lighting PE-12

PE-13 Fire Protection PE-13 (1) (2)

PE-14 Environmental Controls PE-14

PE-15 Water Damage Protection PE-15 (1)

PE-16 Delivery and Removal PE-16

PE-17 Alternate Work Site PE-17

PE-18 Location of System Components PE-18

Planning

PL-1 Policy and Procedures PL-1

PL-2 System Security and Privacy Plans PL-2

PL-4 Rules of Behavior PL-4

PL-8 Security and Privacy Architectures PL-8

PL-10 Baseline Selection PL-10

PL-11 Baseline Tailoring PL-11

Program Management

PM-3 Information Security and Privacy PM-3

Resources

PM-5 System Inventory PM-5 (1)

D-27
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

PM-18 Privacy Program Plan PM-18

PM-19 Privacy Program Leadership Role PM-19

PM-20 Dissemination of Privacy Program PM-20

Information

PM-21 Accounting of Disclosures PM-21

PM-22 Personally Identifiable Information PM-22

Quality Management

PM-24 Data Integrity Board PM-24

PM-25 Minimization of Personally Identifiable PM-25

Information Used in Testing, Training,
and Research

PM-26 Complaint Management PM-26

PM-27 Privacy Reporting PM-27

Personnel Security

PS-1 Policy and Procedures PS-1

PS-2 Position Risk Designation PS-2

PS-3 Personnel Screening PS-3

PS-4 Personnel Termination PS-4 (2)

PS-5 Personnel Transfer PS-5

PS-6 Access Agreements PS-6

PS-7 External Personnel Security PS-7

PS-8 Personnel Sanctions PS-8

PS-9 Position Descriptions PS-9

PII Processing and Transparency

PT-2 Authority to Process Personally PT-2

Identifiable Information

D-28
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

PT-3 Personally Identifiable Information PT-3

Processing Purposes

PT-4 Consent PT-4

PT-5 Privacy Notice PT-5 (1) (2)

PT-6 System of Records Notice PT-6

Risk Assessment

RA-1 Policy and Procedures RA-1

RA-2 Security Categorization RA-2

RA-3 Risk Assessment RA-3

RA-5 Vulnerability Monitoring and Scanning RA-5 (2) (4) (5) (11)

RA-7 Risk Response RA-7

RA-8 Privacy Impact Assessments RA-8

RA-9 Criticality Analysis RA-9

System and Services Acquisition

SA-1 Policy and Procedures SA-1

SA-2 Allocation of Resources SA-2

SA-3 System Development Life Cycle SA-3

SA-4 Acquisition Process SA-4

SA-5 System Documentation SA-5

SA-8 Security and Privacy Engineering SA-8

Principles

SA-9 External System Services SA-9

SA-10 Developer Configuration Management SA-10

SA-11 Developer Testing and Evaluation SA-11

D-29
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

SA-15 Development Process, Standards, and SA-15 (3)

Tools

SA-16 Developer-provided Training SA-16

SA-17 Developer Security and Privacy SA-17

Architecture and Design

SA-21 Developer Screening SA-21

SA-22 Unsupported System Components SA-22

System and Communications Protection

SC-1 Policy and Procedures SC-1

SC-2 Separation of System and User SC-2

Functionality

SC-3 Security Function Isolation SC-3

SC-4 Information in Shared System Resources SC-4

SC-5 Denial-of-service Protection SC-5

SC-7 Boundary Protection SC-7 (3) (4) (5) (7) (18) (21)

SC-8 Transmission Confidentiality and SC-8 (1)

Integrity

SC-10 Network Disconnect SC-10

SC-12 Cryptographic Key Establishment and SC-12 (1)

Management

SC-13 Cryptographic Protection SC-13

SC-15 Collaborative Computing Devices and SC-15

Applications

SC-17 Public Key Infrastructure Certificates SC-17

SC-18 Mobile Code SC-18

SC-20 Secure Name/address Resolution SC-20

Service (authoritative Source)

D-30
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

SC-21 Secure Name/address Resolution SC-21

Service (recursive or Caching Resolver)

SC-22 Architecture and Provisioning for SC-22

Name/address Resolution Service

SC-23 Session Authenticity SC-23

SC-24 Fail in Known State SC-24

SC-28 Protection of Information at Rest SC-28 (1)

SC-39 Process Isolation SC-39

System and Information Integrity

SI-1 Policy and Procedures SI-1

SI-2 Flaw Remediation SI-2 (2)

SI-3 Malicious Code Protection SI-3

SI-4 System Monitoring SI-4 (2) (4) (5) (10) (12) (14) (20) (22)

SI-5 Security Alerts, Advisories, and SI-5 (1)

Directives

SI-6 Security and Privacy Function SI-6

Verification

SI-7 Software, Firmware, and Information SI-7 (1) (2) (5) (7) (15)
Integrity

SI-8 Spam Protection SI-8 (2)

SI-10 Information Input Validation SI-10

SI-11 Error Handling SI-11

SI-12 Information Management and SI-12

Retention

SI-16 Memory Protection SI-16

SI-18 Personally Identifiable Information SI-18

Quality Operations

D-31
CYBERSECURITY CONTROL BASELINE

Control Control Name Initial Control Baselines

Number

Supply Chain Risk Management

SR-1 Policy and Procedures SR-1

SR-2 Supply Chain Risk Management Plan SR-2 (1)

SR-3 Supply Chain Controls and Processes SR-3

SR-5 Acquisition Strategies, Tools, and SR-5

Methods

SR-6 Supplier Assessments and Reviews SR-6

SR-8 Notification Agreements SR-8

SR-9 Tamper Resistance and Detection SR-9 (1)

SR-10 Inspection of Systems or Components SR-10

SR-11 Component Authenticity SR-11 (1) (2)

SR-12 Component Disposal SR-12

D-32
APPENDIX B. DEFINITIVE TEXT
The excerpts below are extracted from normative references in this document and MUST NOT be
accepted by the CSO as applicable cybersecurity requirements for the CSO, but instead the text is meant
specifically as a reference.

The National Electric Vehicle Infrastructure (NEVI) Formula Program Guidance

Section III. STATE EV INFRASTRUCTURE DEPLOYMENT PLAN – B. Plan Format – Cybersecurity

This section of the Plan should discuss how the State will address cybersecurity. The Plan should
identify considerations when software updates are made to ensure the station or vehicle is not
compromised by malicious code, or that a vehicle infects other stations during future charges.

National Electric Vehicle Infrastructure (NEVI) Formula Program – NEVI Formula

Program Guidance and the National Electric Vehicle Infrastructure Standards
and Requirements - 23 C.F.R. § 680
§ 680.106 - Installation, operation, and maintenance by qualified technicians of electric vehicle
charging infrastructure.

(f) Payment methods.

(1) Charging stations must 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 Plug and Charge payment capabilities using
the ISO 15118 standard (incorporated by reference, see § 680.120);

(h) Security. States must implement physical and cybersecurity strategies consistent with their
respective State EV Infrastructure Deployment Plans to mitigate charging infrastructure, grid,
and consumer vulnerability associated with the operation of charging stations.

(1) Physical security strategies may address lighting, siting, driver and vehicle safety,
fire prevention, tampering, charger locks, and illegal surveillance of payment devices.

(2) Cybersecurity strategies may address user identity and access management,
selection of appropriate encryption systems, intrusion and malware detection, event
logging and reporting, management of software updates, and secure operation during
communication outages.

(k) Customer service. States must ensure that EV charging customers have mechanisms to
report outages, malfunctions, and other issues with charging infrastructure. States must
comply with the American with Disabilities Act of 1990 requirements and multilingual access
when creating reporting mechanisms.

D-33
 (l) Customer data privacy. Charging Station Operators must collect, process, and retain
only that personal information strictly necessary to provide the charging service to a
consumer, including information to complete the charging transaction and to provide

the location of charging stations to the consumer. Charging Stations Operators must
also take reasonable measures to safeguard consumer data.

§ 680.114 - Charging network connectivity of electric vehicle charging infrastructure.

(a) Charger-to-Charger-Network communication.

(1) Chargers must communicate with a charging network via a secure communication
method.

(2) Chargers must have the ability to receive and implement secure, remote software
updates and conduct real-time protocol translation, encryption and decryption,
authentication, and authorization in their communication with charging networks.

(3) Chargers and charging networks must securely measure, communicate, store, and
report energy and power dispensed, real-time charging-port status, real-time price to
the customer, and historical charging-port uptime.

(4) Chargers must be capable of using Open Charge Point Protocol (OCPP)
(incorporated by reference, see § 680.120) to communicate with any Charging Network
Provider.

(5) Chargers must be designed to securely switch Charging Network Providers without
any changes to hardware.

(b) Charging-Network-to-Charging-Network communication. A Charging Network must be

capable of communicating with other Charging Networks to enable an EV driver to use a single
credential to charge at Charging Stations that are a part of multiple Charging Networks.

(c) Charging-Network-to-grid communication. Charging Networks must be capable of secure

communication with electric utilities, other energy providers, or local energy management
systems.

Architecture Reference for Cooperative and Intelligent Transportation (ARC-IT)

Device Class 5 Areas

Device Class 5:

- Confidentiality: HIGH

- Integrity: HIGH

- Availability: HIGH

D-34
Devices of this class must meet controls from NIST 800-53 and ISO/IEC 15408 in the following
areas:

- Access Control

- Audit and Accountability

- Configuration Management

- Contingency Planning

- Identification and Authentication

- Incident Response

- Media Protection

- Personal Privacy

- Risk Assessment

- System and Services Acquisition

- System and Communications Protection

- System and Information Integrity

In addition, organizations that develop, operate or maintain devices of this class must meet
controls from NIST 800-53 and ISO/IEC 15408 the areas above and the following additional
areas:

- Awareness and Training

- [Security] Assessment and Authorization

- Maintenance

- Physical and Environmental Protection

- Planning

- Personnel Security

D-35
 Appendix E Supporting Materials
Note: Some comments have been edited to remove identifiable information.

Table E – 1: Online Comments Received from 2023 Form

# Timestamp Comment(s): ZIP Code
1 2023/07/12 10:54:47 How will EV drivers be taxed so that the drivers of these vehicle 85297
PM MDT only are held responsible for the addition financial burden to the
states citizens and not the rest of us who cannot afford one of
these luxury vehicle ?
2 2023/07/13 10:21:17 Please create this corridor as a hybrid owner the only reason I 85225
AM MDT don't have fully electric vehicles is because of the lack of chargers
in az highways
3 2023/07/13 8:52:01 The plan is excellent. thank you 85212
PM MDT
4 2023/07/14 10:32:48 I think this is great as we transition to EV's and away from fossil 85143
AM MDT fuels the more chargers that are available the better for everyone.
5 2023/07/14 3:04:37 As someone who, at one time, was very reluctant to accept 85086
PM MDT electric vehicles as a viable transportation option, I can say this is
an important investment in what the people want. Whether it is
for environmental responsibility (however dubious that may be) or
for the myriad of benefits electric vehicles offer, more and more
people are adopting electric vehicles. The well travelled corridors
are already populated with chargers, so I am glad to see these
lesser served corridors receiving these infrastructure upgrades.
6 2023/07/15 2:41:27 Don't waste the $$$. 86301
PM MDT EV's are a complete waste of money, time and the environment.
7 2023/07/17 9:45:38 I am totally against spending ANY state money on the "EV Charging 86305
AM MDT Infrastructure Deployment Plan". Gas stations were built with
private funding, and allowing public funding for EV charging is not
fair, and goes against our free-market system. I oppose spending
any of my state tax dollars on this project. I can't do anything
about the federal expenditure, because the current regime in
Washington is determined to tip the scales in favor of ridiculous
EVs. But I do oppose using any state highway right-of-way for such
a purpose.
8 2023/07/17 1:15:38 Is the team aware that Ford, GM, Volvo, Rivian, and Mercedes 85021
PM MDT Benz have announced that they are leaving the CCS standard in
favor of NACS?
9 2023/07/17 1:24:57 Hello, as you consider the new EV stations to be installed 85298
PM MDT throughout the Arizona highway system please also consider
designing and installing an awning or stable covering over these EV
charging stations. As a current user of EV charging stations, I've
noticed that none have a covering. With the sweltering Arizona
heat there is no relief or protection from the sun. This would be
much appreciated. Thank you!
10 2023/07/17 1:33:44 The rural communities are still missing critical EV charging 85282
PM MDT infrastructure. The cities and transportation corridors are well
covered with charging stations, especially since EV makers are
adopting the NACS standard.

E-1
 Rural locations we need charging infrastructure:
1) Kayenta
2) Chinle
3) Jacobs Lake
4) Show Low
5) Globe
6) Sierra Vista
7) St. Johns
8) Bisbee
11 2023/07/17 2:14:20 Yes, build them! But take special care to ensure they are specced 85004
PM MDT for extreme thermal management -- planning the user interface
around the angles of the sun, so the screen doesn't fry in the first
summer, for example.
12 2023/07/17 3:11:06 You don't need to waste our money on this! You can't maintain 85396
PM MDT rest stop restrooms! Let the gas stations handle the a refueling s a
. Electric vehicles are not going to succeed!
13 2023/07/17 4:55:22 I believe that AZ 77 should be included in the 2023 or 2024 plan as 85715
PM MDT well all the way from Tucson to Show Low. Parts of that highway
already are included. I drive that route a few times each year and
there is always traffic on the road.
14 2023/07/17 5:01:01 You don't need to waste our money on this! You can't maintain 85396
PM MDT rest stop restrooms! Let the gas stations handle the refueling .
Electric vehicles are not going to succeed!
15 2023/07/17 6:16:15 We own two EVs and frequently travel through and to Arizona. 81147
PM MDT Please make sure contracts with companies obtaining public funds
for charging infrastructure contain both a mandatory completion
date and specific requirements for maintaining the equipment. We
see dozens of "coming soon" chargers, particularly Francis Energy
in New Mexico, that have been coming soon for two years.
Between that and chargers that are broken frequently or for
weeks at a time EV travel is a challenge.
16 2023/07/17 7:58:02 Please ensure any charging solution adopted uses the NACS 85254
PM MDT standard, as most of the major automotive manufacturers have
now adopted this standard. Any other solution would be a waste
of taxpayer funds.
17 2023/07/18 12:55:08 We need a charger in Ajo, Az. 85321
PM MDT Ajo is on the route to Rocky Point and hundreds of vehicles drive
by each day.
Please consider adding Ajo to current plan.
Ajo also has many electrical vehicles owned by businesses and
residents.
18 2023/07/18 3:10:48 The thing is in adding so many stations so close, is it could really 85029
PM MDT wreck the wild feel of the state. It would be horrible of every
station suddenly is circle k, starbucks and McDonalds. Each
charging station should be as blended in the natural surroundings
as possible. Should be no eye sores and no litter. In fact how about
helping our state do a better job about litter. over the past 15
years Az has been terrible about making sure litter is not a
problem. Also concerned about the land footprint of each station.
So many want to just pave over our state with wall to wall city.
These stations have high probability of making tons of
development to spring up near them. This needs to be ban, and

E-2
 the charging footprint should be as minimal as possible. With tons
of native and natural vegetation added to ensure they look
blended into their surroundings.
19 2023/07/18 7:40:14 I believe US-160 should be moved to the 2023 EV plan. 86005
PM MDT
20 2023/07/18 7:42:42 Is funding available to government entities 85365
PM MDT
21 2023/07/18 7:45:35 Was any part of the 22/early 23 plans approved? Or were they 85747
PM MDT withdrawn for this current 2023 plan?
22 2023/07/18 8:33:45 [Name] here with [Organization]. I want to thank ADOT for 85003
PM MDT opportunities to provide input on the NEVI plans. Our volunteer
force of veterans and military families attended many of the in
person events.

What will ADOT do to make sure there's a transparent process and

in the public interest for the public-private partnerships associated
with this plan?
23 2023/07/18 8:33:46 Was any part of the 22/early 23 plans approved? Or were they 85747
PM MDT withdrawn/not sent for this current 2023 plan? Has ADOT actually
received any RFPs from EV Charing Providers yet?
24 2023/07/18 8:39:50 Will the EVSE be designed and made of materials that prevent 85648
PM MDT rodent/ wildlife damage? Can EVSE be placed at Casinos? Can the
EVSE screens be designed to be easy to see the instructions in our
bright AZ sun and made of glass/ substrate that will prevent graffiti
damage where the instructions cannot be read?
25 2023/07/19 10:52:18 I own an electric vehicle and I am in favor of adding electric vehicle 85739
AM MDT charging stations throughout Arizona. However, I live in
SaddleBrooke, Arizona and there are no electric charging stations
on my route to visit my sister in Pinetop, Arizona. There isn't even
one in Show Low, Arizona. Arizona is a long way off from other
states providing electric vehicle charging stations so I am
disappointed in this plan to only add charging stations primarily on
major freeways in the state.
26 2023/07/19 7:02:44 Fast charging in Arizona needs to focus on rural highways and a 85212
PM MDT focus on all charging sites having a pull through for trailers. Sunrise
ski resort, lake Powell, lake Havasu and more need to have a
focused effort to place fast chargers there.
27 2023/07/20 12:31:42 I don't think any ev stations are the answer and are a waste of tax 85041
AM MDT payer money there are not enough driver to even off set the
spending of this. In all honesty there should be more farm lands or
more trees near our interstates. If you look at the bread basket of
our country when corn or any crop it produces a ton of o2 and eats
up carbon. Even with this ev station you are not off setting and
global climate you are still producing green house gases with ev
station it is a load of crap that yall are spinning it is still coming
from the same place every one gets their power from so it isn't self
sustaining so it is doing nothing to save the planet. Also these
batteries of these cars are more pollutant than our gas power
vehicles. Your agenda is flawed and no one wants your stations
and people don't want to pay for them. How about fix the damn
roads first that's a novel idea and plant dome trees. Thanks for
agenda and wasting our money. Way to not listen to the majority

E-3
 of the people in your state. You are all not think about tue people
but your stupid agenda that no one wants. And who the is this
mayor or governor that no one has ever heard of and never had a
clue of what to do. This is how we show how we are as a state. It is
pretty sad. How about use yalls common sense for once get what
we need fixed then maybe consider these ev stations when the
time has come for them. Now is not the time. I would like to know
where there is a petition or way to voice and help strike down this
awful idea and blast whose it was. You are not helping out with
anything with these things just making it worse and you don't care.
That's the issue. Fix what needs fixed before you go on to do
something else that's gonna be a failure. There been one installed
by my area and it has no one using it everytime i drive by and im
on the road all day. What a waste money, and time and breath we
have to deal with this garbage. When can we finally get a person
with some sense to get done around here yall have been nothing
but a joke. It is sad that everything is politicized and not to help
out the people but you make things worse. Grow the up and get
some common sense. Your green push is and no one wants it
unless there is a good plan but there isnt one. You cant fix what
the issues are now infront of you so stop the and handle what you
fail to promise from before. Main thing is fix the roads you
pompous before you spend our money on anything else
28 2023/07/20 12:00:30 Hello, 92705
PM MDT Thank you for the recent presentation. Can you clarify how the
funding will be deployed? It sounded like there will only be one or
a limited amount of people awarded for 50+ sites. Does this mean
1 or 2 companies have to own/build all of the AZ DOT sites? I have
plans submitted to develop 2.5 acres on I-40 & 95 that will include
multiple DCFC and will be using my own contractor that has
extensive experience with EV Charging installation. What is the
best way for me to qualify for funding to assist with this build-out?
29 2023/07/20 12:06:44 Can you be a resource to where the new fast chargers are located, 85020
PM MDT and if they are Testla fast chargers or the other chargers. Also how
many of each type are installed. Thank you
30 2023/07/20 12:09:27 I assume ADOT will require the NACS plug? 85262
PM MDT
31 2023/07/20 12:12:56 PLEASE install (fast) charging stations on I-17 between Phoenix and 85259
PM MDT Flagstaff!!!!
32 2023/07/20 12:25:05 Of critical IMPORTANCE as you develop Charging Facilities around 86303
PM MDT Arizona should be the Knowledge that Right Now GM, FORD,
Mercedes and others Have already agreed univerally to ALL Use
the TESLA re-charge Connector as the National Standard. Also
surprisingly there are NO existing Public Quick Charge facilities
located ANYWHERE in Prescott or Prescott Valley, THE Geographic
Center of the State with an AREA Metro Population exceeding
250,000 + FYI I own and drive an EV and have to fast charge at
home due to NO PUBLIC Charging available period. Tourist and
Travel Promoters CLAIM there are over 150 EV charger locations
around Prescott. FACT is they are ALL ONLY End Destination, SLOW
Chargers On Site for the exclusive use of their Hotel Guests ONLY
to SLOW Charge OVER-Night. Please Feel free to Contact me

E-4
 anytime if can assist as an EV owner, entrepanuer, retired Fire
Inspector or other info resource. Thanks for keeping Arizona
Moving Forward
33 2023/07/20 12:34:17 With most manufactures changing to the NACS from CCS, will AZ 85045
PM MDT also pivot to ensure that funds are not going to a outdated
standard?
34 2023/07/20 12:57:00 Please don't limit stations to 150 kw. Some need to be 350 kw. 85142
PM MDT
35 2023/07/20 1:27:51 During the RFP process, please include expansion options. Every 85041
PM MDT site will eventually need to be expanded for new and more
chargers as technology progresses. Please keep in mind those that
are excited to be towing in an EV. For this we need pull-through
charging as you would expect to see at a traditional fueling center.

Finally, please try to include accommodations, restrooms with a/c

security lighting and cameras, etc.
36 2023/07/20 1:43:07 Implementing fast (level 3) charging accessible by all charging 85225
PM MDT protocols (NAS vs CCS) along the interstate highways and high-
traffic sections of the 101 and 202 loops will significantly improve
the charging infrastructure for the valley. The main need for fast
charging for my personal use would be to enable more convenient
road trips from Phoenix to Tucson, California, and northern
Arizona. At the moment, the non-Tesla charging options have poor
reliability making it difficult to plan a road trip. The Electrify
America fast chargers add a long of range anxiety since they often
have issues.
37 2023/07/20 2:13:17 This is goverment overreach in forcing others whom KNOW this is 86442
PM MDT a Technology with a limited future ,using our Taxpayer monies to
finance for the few elite this program.
These " E " vehicles are more costly to the enviroment than the
tried and true technology of internal combustion vehicles.
This is just another solution looking for a problem . This is an
instance where the private sector should be deciding upon , not by
mandate of the Federal and State governments.Doesn't seem the
Private sector is beating down the doors to get into the business of
building Charging Stations does it ? Neither should the Taxpayer
funded Department of Transportation..
The cost to us taxpayer is beyond the pale and it is time these sort
of actions by the Federal Government STOP !
The search for these Rare Earth minerals which are required for
this tecnology is actually more destructive upon the earths
environment than the footprint for the Petroluem industry it
attempts to replace , again by government mandate.
I liken it to the issue of strip mining in the United States 50 years
past. But of course the ELITIST of America have no problem with
the extreme damage it does enviromentally as it is done outta
sight out of mind in other countries ..
I for one am tired of Government spending my tax dollars on such
foolishness driven by a mere small minority < 0.05 % of the
populous.
You folks at the National D.O.T. as well as the States D.O.T's . are
just one more example of Bloated , Bullying , Goverment agencies

E-5
 which need to be Defunded and replaced with an agency which
works for , rather than against the TAXPAYERs of these UNITED
STATES .
This issue which these Electric Vehicles are aimed at Curbing is a
"non-issue". At least to those of us whom Worship GOD our
Creator and know our Bible.
Human Caused Global Climate Change is a Fallacy. The Climate
changes yes, as it is a dynamic, never static force of GOD ! It is
called WEATHER . Man is so filled with his own perverted VANITY
to even think he can control GOD's Creation.
We are given to Delusion.
I say get out of the business of mandating THIS Technology... If it
is so great , well then allow the private sector to build out these
charging stations and get my taxpayer funds out of it.
38 2023/07/20 4:00:10 Are you working with Tesla directly to coordinate their plans of 85338
PM MDT adding Tesla Chargers in AZ?
39 2023/07/20 5:22:55 I think each EV charging station should be required to display the 86326
PM MDT current generation source of the electric energy being provided;
ie.: Wind, Solar, Coal, Diesel, Nuclear, Hydro, etc.
40 2023/07/20 5:39:10 Please STOP this nonsense! NO taxpayer funds should ever be 86404
PM MDT spent on Electric Vehicle Charging or any other special needs of
any kind. If someone wants an electric vehicle they need to deal
with all that it involves. I want to know what is wrong with ADOT
to even consider using taxpayer funds for such a small group of
users.
41 2023/07/20 6:13:40 How has the recent adoption of NACS by GM and Ford to go along 85249
PM MDT with the massive number of Teslas on the road impacted the plans
for charger rollout? Will the new sites include both NACS and CCS
DCFC plugs?
42 2023/07/20 6:23:24 Move Highway 60 that goes through Globe up to the 2023 EV Plan. 85501
PM MDT This highway and Globe are a major east-west corridor and
requires ev charging stations.
43 2023/07/20 6:27:08 Highway 60 going through Globe has to be moved up into the 2023 85502
PM MDT EV Plan. The highway and Globe are major travel ways through
Arizona and require ev charging stations.
44 2023/07/20 6:38:34 The City of Globe and Highway 60 going through Globe should be 85501
PM MDT in the 2023 EV Plan. This is a major corridor and requires ev
charging stations.
45 2023/07/20 6:44:36 Put Highway 60 and the City of Globe into the 2023 EV Plan. This 85501
PM MDT corridor requires ev charging stations.
46 2023/07/20 8:34:48 Since deploying these sites is costly and we are not at the point 85301
PM MDT where we can have 20 plus charging plugs for DC fast charging at
each location, at least outside of the Tesla charging network,
wouldn't it be a good idea to ask charging providers to opt for
smarter power distribution at their sites like how Kempower does
it in Europe? It's a little frustrating as an EV driver to have to worry
about what charging stall I'm plugging into. Not everyone is
educated on the difference between 400V to 800V cars, and
150kw and 350kw charging stalls. This is a challenge as I've ran
into drivers who misuse the charging stalls not knowing any better,
or some just plug into whatever is available out of convenience. I
would hope that by deploying balanced charging points, this would

E-6
 move the headache from the driver to some machine on site that
decides how to allocate power as it is needed. Also, this may have
been touched on already, but any plans for NACS support when it
becomes an SAE standard at these new and existing charging sites
as part of this deployment?
47 2023/07/21 7:44:40 I think service stations should be paying for this. Not the 86432
AM MDT government.
48 2023/07/21 9:39:42 ADOT needs to charge Electric Vehicle owners road tax before 86404
AM MDT NOW. Stop using taxpayer money for this ridiculous plan.
ADOT needs to repair the bad roads before anything else.
49 2023/07/21 10:05:58 I'm wondering what the plan is to make charging stations available 85255
AM MDT to apartment and condo dwellers many of whom don't have the
luxury of having a personal garage in which to install EV charging
equipment? I feel that apartment and condo dwellers are getting
left behind in this absolutely essential effort to move our country
away from the burning of the planet killing fossil fuels that
threaten the survival of humanity.
50 2023/07/21 11:56:10 With the NACS standard becoming the dominant standard and 85233
AM MDT other states have started creating a requirement for it, will AZ
follow suit?
51 2023/07/22 8:58:49 The 2023 update looks great, thanks ADOT! My only suggestion 85050
AM MDT would be to prioritize charging on Highway 93 between Kingman
and Wickenburg. That stretch has limited cell service and I
personally have had several close calls on whether I would make it
to a charger.

Lastly, I appreciate that ADOT is being cognizant of the NACS

transition that the EV industry is currently undergoing. It appears
as though CCS might be phased out by most (if not all) auto
manufacturers by 2025, so having the foresight to 'future proof'
these chargers is admirable.
52 2023/07/23 11:10:29 I am pleased to see the plans including some smaller highways in 85719
AM MDT the '24 and '25 implementation, but I'd love to see expansion of
those plans on the east side of the state to ease transportation
between Tucson, Cochise, and the northeastern cities like Chinle
and Alpine
53 2023/07/23 4:03:21 I just read my updated terms of use for Electrify America and I 85382
PM MDT noticed you have to be 18 to accept. Wouldnt that preclude them
from being a provider for Arizonas program since many drivers
may be 16 or 17?
54 2023/07/24 9:22:28 I'd love to see more NACS charging ports along highways and in 85305
AM MDT more rural areas now that the majority of the auto industry is
moving toward that connector.
55 2023/07/24 9:23:56 In the interest of fairness and equity we ask that you mandate a 75254
AM MDT set-aside for minority and woman owned business participation in
the deployment, installation, construction and on-going
maintenance of these projects. Please require either WBENC or
WOSB certification for participation by women owned businesses.
56 2023/07/24 9:26:55 Can you add SR-95 between the Needle Bridge and SR-68? There is 86426
AM MDT a lot of traffic that goes between the State Line and Bullhead City.
57 2023/07/24 9:27:00 sufficient, accessible EV charging needs to be available off major 85718
AM MDT highways such as I-10, I-19 & I-17. It would be great to have EV

E-7
 charging available midway between Tucson and Phoenix
58 2023/07/24 9:28:35 We need to get on this ASAP. The trip between PHX and California 85257
AM MDT is terrible with backed up or unworkable chargers. Flag to
California is also terrible. The EA station in flag is too small and
poorly designed. The situation is unacceptable now, in a year it will
be ridiculous, need to speed this up, other states are already
allocating funds.
59 2023/07/24 9:28:54 The addition of the Hwy 87 and 260 corridors is fantastic because 85048
AM MDT there are very few charging options along those routes.
60 2023/07/24 9:29:20 I am in favor of the proposed ev charging station plan. 85339
AM MDT
61 2023/07/24 9:29:48 I would suggest the standardization of NACS due to automakers 85262
AM MDT announcing the commitment to switch instead of CCS, or a hybrid
of the two to accommodate new and existing cars. Thank you!
62 2023/07/24 9:30:14 Plan looks adequate. I support it and timing rollout. 85749
AM MDT
63 2023/07/24 9:31:03 Will there be more chargers (that aren't Tesla) provided along the 85338
AM MDT I-10, I-17, SR 51 etc. at certain intervals?

I see I-10 was 2023-2024, I haven't seen much being done, when
will this actually begin?
64 2023/07/24 9:32:36 Add chargers at Kayenta. These would serve highway 163 North to 86401
AM MDT Monteceillo and highway 160 North/East to Cortez.

Note: We have a Tesla due to lack of charging @/near Kayenta; we

drive from Kingman to Gallup & then north to Cortez -
approximately 50 miles longer.
65 2023/07/24 9:32:50 The current plan is supporting the needs of EV road trips. 85044
AM MDT
66 2023/07/24 9:34:34 There should be additional consideration on the timing of placing 86442
AM MDT EV charging stations on Highway 95 running through Bullhead City
AZ. This is an important roadway with broad-based state/regional
tourism and other economic implications. It is also important to
note, currently, there are no charging stations along this route.
Tourist frequently travel the route to enjoy the river and other
outdoor activities in the area. Adding additional charging stations
is an opportunity to further capitalize on out of state tourism
revenue, will adding to the tax base for Arizona. This route should
be moved up in the instillation planning with a focus on 2023/2024
funding.
67 2023/07/24 9:39:00 U.S. 93 between Phoenix and Kingman should be prioritized before 85338
AM MDT SR 87 / SR 260 from Phoenix to Show Low because there is already
an Electrify America fast charger operating in Payson however
there is not yet any fast charging for non-Teslas between Phoenix
and Kingman.
68 2023/07/24 9:39:06 I truly believe that the corridor for SR 93 from Phoenix to Kingman 85044
AM MDT needs a higher priority than some of the other routes. Efficiency it
updating the shortest distance between 2 points first that is well
underserved, then fill in the gaps on routes that already have
coverage. By my estimates standard non-tesla chargers on this
route have a gap of approximately 185 miles as it stands today. All
other routes have coverage between every 80-90 miles. Seems like

E-8
 SR 93 between Phoenix and Kingman should have been addressed
first for those travelers going between Phoenix and Las Vegas.
69 2023/07/24 9:39:07 The plan update should address the NACS connector because it is 89451
AM MDT becoming widely adopted by the auto OEMs. Because NACS is not
an official standard issued by a recognized standards development
organization (SDO) such as SAE, NACS should not be mandated
today. However, stations not having NACS in the near future will
be functionally obsolete with respect to NACS-equipped vehicles.
Therefore, NEVI funding recipients should be required to have
NACS connectors on any new installations no later than 12 months
after SAE adopts the NACS standard and UL has a certification
process in place.
70 2023/07/24 9:40:06 Please add a charger between Phoenix and Kingman 85224
AM MDT
71 2023/07/24 9:42:04 The plan is on the correct path. More CCS chargers at each 85746
AM MDT location is key. Presently most charging stations only have four
terminals, which causes back ups, and long delays. On a recent trip
to California, I had to wait three hours to complete my charge in
Quartzsite at the Electrify America charging station.
72 2023/07/24 9:43:14 Please put more EV charging stations for people traveling out of 85748
AM MDT Tucson!
73 2023/07/24 9:43:16 I don't think the government and my tax money should be 86004
AM MDT involved in creating businesses or in providing ev charging stations.
If this is to be a viable alternative mode of transportation free
enterprise will rise to provide those services. Already established
gas stations could add a charging station to shore up what will be
lagging income one day. Don't force this down our throats. The
struggling workers Can't afford to replace their autos with ev. The
others don't need the government's help.
74 2023/07/24 9:44:42 Please consider adding highway 87 from Payson to Winslow 86047
AM MDT
75 2023/07/24 9:46:02 I support the plan as shown. I have owned two EV's the last six 85044
AM MDT years and could never take it anywhere but along the interstate
system, and even then it was iffy. This past weekend I drove to my
cabin in Pinetop and with chargers now in Payson and Show Low
made this trip possible. Each time I stopped at those locations,
multiple vehicles were there. Thank you!
76 2023/07/24 9:47:15 See no survey at all 86004
AM MDT
77 2023/07/24 9:48:41 I'm glad you are addressing US 93 from Wickenburg to Kingman 85308
AM MDT
78 2023/07/24 9:51:54 As an ev driver, I look forward to connectable, serviceable, 85365
AM MDT available fast charging stations to ultimately be at every or most
highway intersections and most smaller towns. Where you would
expect gas stations today.

The goal of at least every 50 - 75 miles is reasonable.

I would hope that the 2024 proposals can make the 2023
implementation - the sooner I can hit the road in my newest car.

Thank you

E-9
79 2023/07/24 9:57:32 Most important is to provide shade, right up there with reliability. 85396
AM MDT
80 2023/07/24 9:57:45 This is very good for our environments and for us all. I will suggest 85142
AM MDT all homes/living areas be given the opportunity to add EV charging
stations with lower cost or no cost. This will encourage
involvement and a good conversation in communities.
81 2023/07/24 9:57:49 Quartzsite needs a lot more CCS DCFC. The 4 chargers there are 85383
AM MDT woefully inadequate for current and future volume of traffic. Tesla
by contrast has 30+ chargers there.
82 2023/07/24 10:01:10 We love the additional highways you Re adding. 85225
AM MDT Also is there anyway you could get one of the new DCFC UNITS
installed at a ADOT office or otger public location so drivers can try
it and see how it works forbilling and the many different cars?
83 2023/07/24 10:06:17 I own approximately 4 acres at Interstate 40 and Hwy 95 in Lake 86406
AM MDT Havasu City, Arizona and would like to build an electric truck
charging station for Class 8 vehicles. Not certain if this type of
charging station is involved in the Electric vehicle charging
infrastructure deployment plan. This would be a MegaWatt
charging station, with 24 hour truck parking.
84 2023/07/24 10:09:03 You are ignoring the entire US 60 Corridor. 85539
AM MDT
85 2023/07/24 10:11:12 This is a 100% complete waste of taxpayer money. The only reason 86336
AM MDT AZ is doing this is that the federal government is providing the
funding and AZ doesn't want to turn down "free money". Get a
life!!!
86 2023/07/24 10:13:51 Are all devices DC Fast Chargers? 89011
AM MDT
87 2023/07/24 10:14:08 looks like good coverage. perhaps another station in Phx - area (so 85737
AM MDT populated there ).. aound Glendale? and perhaps another in the S.
Tucson - by Airport area or the Kino parkway I-19 area?
88 2023/07/24 10:15:24 A lot of great information was shared, and I'm appreciative this 85388
AM MDT online presentation was available to the public. I look forward to
future presentations discussing renewable energy's
implementation at specific DCFC sites.
89 2023/07/24 10:15:58 Why are you wasting our tax dollars? Our systems can barely 85142
AM MDT handle the homes and businesses we power. I am sick of the
brown outs destroying my appliances, so goody lets make it worse
by adding in charging stations. Stop the insanity, EV are not
sustainable and there is no such thing as green energy!
90 2023/07/24 10:16:09 Would like to see a greater focus on equity, per the overall goals of 86001
AM MDT NEVI and the state.
91 2023/07/24 10:16:22 I would like to see as many super-ultra-fast chargers as possible 87577
AM MDT along your proposed routes. When traveling, it would be nice to be
able to charge up in 20 minutes rather than 1 hour (level 3) or 7
hours (level 2). The fastest chargers I have seen from Electrify
America are the "Hyper Fast 350kW". I'm sure each company has
a different name for their different charger levels, but I will only
use these when traveling, so would like to charge as quickly as
possible. Thank you.
92 2023/07/24 10:16:29 I just want to say thank you for the transparency on the state's 85338
AM MDT NEVI program plan and i'm excited about what's on the horizon. I
wish other states of personal interest were at the level of

E-10
 engagement and transparency ADOT is at. Looking forward to
seeing the first round of chargers by end of next year! I can't wait
to take my family roadtripping across the state and country in our
EV!
93 2023/07/24 10:16:52 I'm working on getting a solar farm going along Highway 160 86514
AM MDT [Specific Location] in Mexican Water, AZ and would like a charging
station installed to.
94 2023/07/24 10:17:26 Only electric vehicle owners should be paying for the construction 85715
AM MDT and maintenance of charging stations.
95 2023/07/24 10:17:58 Why are we still not including the highway between Payson and 85284
AM MDT Holbrook to I-40? This would be 260 to 277 to 377 into Holbrook.
96 2023/07/24 10:18:03 It is baffling to me that the speaker of this plan have never driven 85086
AM MDT or plugged in an EV. I challenge all of you to do so
97 2023/07/24 10:24:33 I fully understand that this was a specific survey, funded by the 85212
AM MDT Federal government, and specific to electric vehicle charging
station locations. HOWEVER, it fails to deal with other BETTER (or
potentially better) technologies for reducing CO2. Are these same
locations going to be available for Green Hydrogen powered
vehicles? A brand new electric vehicle, for example a Tesla Model
3, starts out with a CO2 deficit - that is it requires MORE CO2 to
produce than a typical gasoline powered vehicle due the the
production of batteries and motors with exotic metals; according
to Bjorn Lomborg, a climate researcher, a Tesla Model 3 will not
produce a net CO2 improvement over an equivalent gasoline
vehicle until it is in use for more than eleven (11) years!! Compare
that to a Green Hydrogen vehicle, which starts out with NO CO2
deficit and immediately benefit the climate/environment. Why is
ADOT helping the Federal government to chose one technology
over another? If you want to reduce CO2, tax it, and let the market
decide how to resolve the issue (i.e. which technologies are best) -
- this is another Bjorn Lomborg idea.
98 2023/07/24 10:32:02 I have been attending the ADOT zoom meetings and following the 85928
AM MDT program's progress. I would like to see the program succeed;
however it appears ADOT may be missing or downplaying a couple
significant aspects of the program.

The user interface to the charging infrastructure is as important, if

not more important, than the actual installation of the charging
stations. It appears ADOT is approaching the user interface as an
afterthought. Whereas it should have its requirements defined,
and probably high-level design, to be included in the RFP. Without
a common interface across all vendor's stations, users will not be
happy. Fixing the problem after the fact would be challenging. The
need for the EV driver is to be able to plan their long-distance trip
knowing where charge stations are located, but also near real time
information as to number of chargers available at each station. If
users need to check multiple vendor apps to glean this
information, there will be a lot of complaining. At a minimum
there needs to be one app showing all charging stations, total
number of chargers at each location and the number currently
available. The application should be available on both Apple and
Android phones and allow vehicle manufacturers to integrate it

E-11
 into their vehicle software. Tesla's current app is a good example
of what is needed. The companies bidding on the charging station
RFP need to understand this requirement is detail and explain how
they will address it. This can significantly effect their cost/price. As
to who would build the application, it should be at a national level,
but at a minimum the state level and coordinate with other states.
A significant challenge for the application developer is to bring
competing companies together onto the single platform. The best
approach is to establish the interfacing requirements up front, in
the RFP, requiring the bidders to address in their solution.

As a point of reference to validate my above comment ... I have

been driving EVs (tesla and other) for 10 years. I have also run
software development programs from small projects of a million
dollars to tens of millions of dollars, including bringing competing
companies together onto one project. I would be happy to talk to
the appropriate person with suggestions as to how to address.

A second concern, which I do not hear much about being

addressed is the lack of standardization with the location of the
charge ports on EVs, and how charging stations will address.
Although ICE vehicles are not standard on the location of the fuel
door, there is no issue since gas pumps are pull through from
either direction. Currently, nearly all EV fast chargers are parking
spaces perpendicular to the charging cord (few pull throughs). This
is an issue. For example, all Tesla vehicles have their charge port
on the left rear corner of the car. Tesla DC charging stations are
designed specifically for Tesla's charge port location with a short
cord. Tesla charge stations are designed to back the car into the
parking spot and use the charger next to the left rear. This is a
problem for other manufacturers vehicles which place the charge
port in another location. For example, the Ford F150 Lightning
must parallel park across 2-3 charge stations to use a tesla charger.
Other vehicles must park in one spot but use the charging cord
from the adjacent parking spot. The RFP needs present the
situation and require the bidders to address. One solution is to
have some rather long cables, but this presents other concerns
and costs.

I see some other challenges which I am not hearing addressed, but

these are the big two.

99 2023/07/24 10:34:21 Too long. Accelerate deployment to complete by end of 2024. 85750
AM MDT
100 2023/07/24 10:35:35 I don't want to see more of my tax dollars wasted on EV 85086
AM MDT infrastructure.
101 2023/07/24 10:35:59 Thank you for this opportunity. 86413
AM MDT I've been an EV owner now going on 7 years.
I would like to address the issues of quality control and
maintenance of DCFC. I'm retired and travel 30k per year. It's come
to my attention in the last 18 months not just Arizona but all the
western states a horrible issue with maintenance and repairs. In
my time at chargers I have talked to repair technicians and

E-12
 manufacturers of chargers at the site. They all agree the
manufacturer has a greater understanding of troubleshooting an
issue. Getting parts can take up to a month at some locations. This
is were I would like to make a suggestion. AZDOT has the ability to
Store replacement parts closer to the charger unit than does the
operator or manufacturer. Instead of master warehouse in
Phoenix there could be 6 areas where parts are located nearer the
chargers. Meaning the repair could be hours instead of days.
Uptime is critical for these chargers as demand increases.
Thank you for your time.
Sincerely
[Name]
102 2023/07/24 10:39:38 If gasoline tax pays for roads if we do not use gaoline who pays for 85658
AM MDT roads
103 2023/07/24 10:48:19 I hope you'd consider route 66 tourist traffic between Flagstaff and 86401
AM MDT Kingman. If a charger was in Peach Springs and Seligman that
would also cater to Supai and Indigenous peoples of AZ and
include the many tourists who travel this area.
104 2023/07/24 10:56:09 I would really like to see highway segments 60 to 93 to the Az. Nv. 85735
AM MDT border completed sooner than currenty scheduled. I travel this
route frequenty, and there is usually a lot of traffic.
105 2023/07/24 10:58:36 I think the car companies should pay for charging stations since 85390
AM MDT the gas companies was started by the car manufacturer.
106 2023/07/24 11:01:14 I was unable to attend the ADOT video conference on July 18th. 85719
AM MDT Here in Tucson that evening at a public meeting, I was attempting
to tell our mayor and city council that the purchase of methane
(CNG) buses was ill advised. Unfortunately, they chose these
polluting antiques over modern electric buses.

As for state public EV charging infrastructure, it seems to be

moving along quite well. Just about everything proposed here to
be added, though, looks to be infill in the northern part of the
state. Please keep me on your list for the next round of proposals,
which will hopefully address the southern part of the state.

So much has changed in the way of plug choice since mid 2022.
Who would have guessed that Ford and GM would have chosen
the Tesla NACS (now SAE J3400) over CCS-1? I think Arizona should
follow the industry trend, such as Texas and Washington State
have already done, and insist that this plug specification now be
part of any federally funded installation. By the time these
terminals are built and operational, it will be J3400 on just about
every new EV sold in the US.

That said, I drive an "antique" EV: a 2012 Mitsubishi i-MiEV with a

CHAdeMO DC charging port. Last year, I lobbied for the inclusion
of at least 2 CHAdeMO installation along I-10, since I'm sure
almost all cars in Arizona so equipped (the Nissan Leaf being the
most well-known one) are located in the Phoenix and Tucson
metro areas. Us early EV adopters never got truly reliable charging
infrastructure for our cars along the 100 mile stretch between
Arizona's 2 largest cities. If not, every ADOT installation should

E-13
 include at least 1 J-1772 AC terminal. The specification for these is
up to 70A, but most J1772 public terminals in metro areas rarely
are this robust. With a higher amperage J1772 available, though,
older EVs such as mine can at least functionally travel out of town
on occasion.
107 2023/07/24 11:01:14 Provide as many EV charging stations as possible without 85032
AM MDT endangering wildlife corridors.
108 2023/07/24 11:02:21 My taxes had better NOT go up because of this. I never own an 85387
AM MDT electric car.
109 2023/07/24 11:02:47 This seems to be well thought out 85742
AM MDT
110 2023/07/24 11:04:18 As an owner of an Audi EV, I look forward to the implementation 85711
AM MDT of this plan. I was unable to drive my EV from Tucson to St George,
Utah, a couple months ago because of a lack of CCS charging
stations along my planned route. That route is now included in the
2023 plan!
111 2023/07/24 11:06:10 Please design an awning or some sort of cover over these EV 85298
AM MDT charging stations. As a current user of these EV charging stations,
none of them have a covering and it is extremely hot during the
summer months. Please design them with a covering to protect us
from the sun. Thank you!
112 2023/07/24 11:09:13 Unrelated to EV charging infrastructure location discussions, I note 85719
AM MDT that Governor Hobbs has recently expressed an interest in finding
a way to include EVs as part of the revenue stream for funding
road repairs. I have such a proposal, which is in the form of a 5
page PDF. Could someone please email me, so I can submit this to
whoever at ADOT might be interested in reviewing it? Thanks in
advance.
113 2023/07/24 11:10:47 I have been looking at putting a charging station on my property in 86025
AM MDT Holbrook, Az. Any consideration from ADOT in helping this become
a realty?
114 2023/07/24 11:15:19 Charging near or in Yuma would be great 85374
AM MDT
115 2023/07/24 11:23:59 Looks better for northern AZ. Would appreciate adding more 85658
AM MDT coverage around Tucson, eg route 77.
116 2023/07/24 11:24:42 The plan for the most looks pretty good. We do need in the next 85749
AM MDT round to provide charging in STH 70-191 corridor; e.g. Globe to
Safford as well as the STH 82 Tombstone-Patagonia corridor.
117 2023/07/24 11:26:09 I think what you're doing is great and long overdue. We need to 85745
AM MDT encourage the use of alternative fuels and stay ahead of the
market as much as possible.
118 2023/07/24 11:30:37 Stop wasting tax payers money on something that only benefits 2 86303
AM MDT percent of the population
119 2023/07/24 11:30:43 Since the State of AZ is drinking the kool-aid and pushing EVs, what 86315
AM MDT are the plans to assess/collect road taxes from all these proposed
electronic charging station since right now, they don't contribute a
single penny to help maintain our seriously deteriorating highways
and interstates, not to mention local streets?
120 2023/07/24 11:35:55 Installing a couple of DC Fast charging stations on 89 north from 86004
AM MDT Flagstaff to Page and Jacob Lake would make a huge difference to
the viability of EVs in Arizona.
121 2023/07/24 11:36:05 1. PLEASE consider Tesla as a prioritized contractor, their chargers 85021

E-14
 AM MDT are significantly more reliable, easier to use, and less expensive
than Electrify America. Tesla's newest chargers have CCS capability
in the US so they would be NEVI compliant.

2. In the later phase plans, please consider Kayenta as a site. Even

though it is a low traffic route, Kayenta is a critical bridge to SW
Colorado from Phoenix (Telluride, Durango) that currently is a
complete charging desert, this is the type of application that public
funding is meant for (weak business case but significant public
benefit).
122 2023/07/24 11:41:52 I oppose public funds being used for electric car charging stations. 85254
AM MDT Not only are they a burden on our environment, but public funds
should not be used to accommodate the choice a few make. It is
not the government's place to spend funds on this.
123 2023/07/24 11:42:16 Please include the installation and maintenance of rubbish bins, 85224
AM MDT windshield squeegies/water, and shade areas wherever possible.
Currently the Tesla chargers in AZ lack all of these "amenities".
124 2023/07/24 12:05:15 Where is the survey? 85045
PM MDT
125 2023/07/24 12:10:03 EV support on 347 is critical. There is a big gap between I10 and 85138
PM MDT Maricopa, Running out of power on 347 is dangerous.
126 2023/07/24 12:25:35 Those who use this service should pay for it, not those who do not 86301
PM MDT use it. Require a credit card to purchase electricity at the charger.
127 2023/07/24 12:27:50 ADOT should look for placing EV chargers in locations 50 - 80 miles 85749
PM MDT away from existing commercial EV stations in order to help cover
the state and be profitable.
128 2023/07/24 12:35:11 I think it would be wonderful to have more charging options when 85901
PM MDT traveling
129 2023/07/24 12:48:42 Big waste of our money. Why does our State have to provide EV 85933
PM MDT stations? Let private companies that build the vehicles put them
in.
130 2023/07/24 1:03:35 I am admittedly biased. But there is a reason why many EV car 85298
PM MDT manufacturers have been adopting the NASC charging standard
(formerly Tesla charger) - it is simply better than the CCS standard.
And the CCS consortium is also working to make NASC an official
standard. Looking to the future, it seems prudent that the majority
of new charging stations should be using the NASC charging
standard.
Beyond the charging standard, I would also recommend covered
charging stations. Just as most every gas station has overhead
canopies to protect from rain or sun, so should the election
charging stations. And, since they are electric, it would make sense
to have those canopies by solar panels. Maybe even mandate solar
panel canopies for electric charging stations that receive federal
funding.
Are there any other mandates for things like bathrooms that gas
stations have? Or that there are bathrooms within X feet?
Anyways, those are my thoughts.
131 2023/07/24 1:06:46 I want to see Level 2 charging available at every station on the 85354
PM MDT highway system as well as more Level 2 stations in the Phoenix
Metro area as well as Tucson.
132 2023/07/24 1:11:35 I feel govt and ADOT has assumed there is a consensus about 85254

E-15
 PM MDT electric vehicles. I understand the Federal Govt has incentivized
the auto manufacturers to build EV's, but I am not in favor of
spending all this money and resources on the building of the
vehicles nor the charging infrastructure.
133 2023/07/24 1:14:47 EV chargers should be placed 86324
PM MDT in easy on/off locations from major traffic corridors
near shopping, entertainment & sports venues
in highway rest stops
at certain gas stations along major routes
add EV chargers in small towns & smaller cities (e.g. there's no
public EV charger in Cottonwood AZ. Clarkdale AZ has collaborated
with APS to install 4 EV chargers in this small town

In re: taxing EV drivers for using AZ highways/roads.add a tax at

the charging station similar to gas tax. Tax the electricity not car
mileage

Bring back the big discounts on registration fees for EVs.

134 2023/07/24 1:17:40 Please consider including overhead covering for the chargers. I've 85207
PM MDT seen too many instances of burned out video displays on chargers
in my extensive road trip experience. Also, I see you have pushed
back the US-93 corridor down in priority. Serious consideration
needs to be taken to routes without alternative charging. This
route is known as a difficult leg for EVs due to no chargers
between Kingman and the Phoenix area. Why were other routes
that already had existing chargers rated above this charger-less
route? Currently this route is not an option for me as I would be
worried about running out of charge.
135 2023/07/24 1:33:44 Please stop wasting money on this left wing political crap and fix 86303
PM MDT our roads. That's what we pay taxes for.
136 2023/07/24 1:35:26 I recommend adding all State and National Parks/Monuments in 85641
PM MDT Arizona as locations for EV chargers in the first rollout. Some of
these locations (like Chiricahua National Monument) are very
remote and are not served well by chargers on interstate
highways. I also highly recommend adding chargers with the NACS
connector. The CCS1 connector will not be used as the dominant
interface by most EV manufacturers in the US long term.
137 2023/07/24 1:35:34 Need more chargers for the Las Vegas trip from the Valley. HWY 85388
PM MDT 60/95.
138 2023/07/24 1:39:55 Safford, Alpine, and Jacob Lake could really use DCFC in the 24-25 88005
PM MDT plan.
139 2023/07/24 1:46:10 The more the better! Installation should expand to points where 85087
PM MDT people gather for extended periods of time; Costco, Sams,
stadiums, ball parks, theaters, etc.
140 2023/07/24 2:00:59 I hope that the cost of providing EV chargers and the cost of 86001
PM MDT electricity can be recouped fro m the users and not be a burden to
others who don't use them.
141 2023/07/24 2:09:27 Please install a DC charger in Kayenta. There are few charging 86336
PM MDT opportunities on the reservation
142 2023/07/24 2:10:27 I think it would be great to have a charger every 50-75 miles from 85305
PM MDT particular stages of major freeways. And for non-major freeways
perhaps a charger every 75 to 100 mile range.

E-16
 Also it would be great to have chargers equipped with multi plug
connection that accounts for regular vehicles versus Tesla. Most
work with the typical J1772. Also some network Wi-fi connection
that keeps folks aware of availability and accessibility of the
chargers - working status and super charging options.
143 2023/07/24 2:11:15 ADOT should gather metrics and set minimum requirements for 85283
PM MDT charger availability. The current federal standards are insufficent
and do not indicate if a user is able to actually charge their car or
charge at a reasonable speed for long trips. ADOT should validate
chargers are consistently working and delivering reasonable
charging speeds.
144 2023/07/24 2:21:29 NO 85901
PM MDT
145 2023/07/24 2:32:27 I have a Kia EV. Will be happy to have more fast charging stations 85718
PM MDT from Tucson to Phx and in Tucson itself that can accommodate
Kias.
146 2023/07/24 2:39:52 We need more information before installing these EV stations. The 85225
PM MDT EV vehicles haven't been proven as reliable means if
transportation. The state shouldn't invest large sums of money for
EV charging stations. I recommend waiting another year. The
whole EV's need more refinements to make them a reliablr vehicle
for driving everyday. Arizona isn't ready for them, one reason the
extreme tempetures we have!
147 2023/07/24 2:47:06 [Company] believes existing sites and new construction sites 97405
PM MDT should be considered at all targeted exits. Of course upgrading
sites is often less expensive, and if cost is the only distinction
between a new construction and an existing site at a targeted exit
the less expensive project should be awarded. However,
[Company] knows that some existing sites are plagued by
downtime, no driver support line for charging help, inadequate
electric service, lack of parking, poor site design, and a other issues
that lead to a poor driver experience and a lack of public interest
in transitioning to EVs.

For proposed exits, [Company] suggests ADOT consider new

construction and existing upgrades at the exit to make sure any
NEVI money spent goes to a company/site with an excellent plan,
strong track record, and reasonable budget to make EV Charging
as easy and accessable as pumping gas.
148 2023/07/24 2:49:42 The East Valley is sorely short on EV charging infrastructure. The 85248
PM MDT first Tesla Supercharger station finally went up at the 101/Ray
Road in Chandler, but more are needed. It would be nice to see EV
charges placed at some rest stops on the major state highways,
such as the 87, 74 and 79.
149 2023/07/24 2:55:48 YES IF NEEDED, Ekectric Vehicles won't work In AZ Summers! 86426
PM MDT Power Grid don't need it at all!
150 2023/07/24 2:59:21 My only comment is that the highways you have slated for 2024 85308
PM MDT and 2025 should be completed by the end of 2024. These are
critical for people traveling to Eastern Arizona.
151 2023/07/24 3:01:02 I like the EV charging that is being proposed. Keep it up and add 86336
PM MDT more.
152 2023/07/24 3:03:55 There needs to be some kind of reservation system and time limit, 85044

E-17
 PM MDT from an experienced existing EV owner. Some people park and
leave for hours tying up a charger. And take payment for a
reservation, and if a no show they are charged a penalty, maybe
with a few freebies a year to avoid frequent cancellations. Thanks
for doing this and moving us forward with cleaner quieter vehicle
options.
153 2023/07/24 3:21:37 Recommend a minimum reliability standard be required for 86404
PM MDT chargers. I just completed a 5600 mile trip in my EV and found an
unsuitable number of chargers down or operating at very low
levels (38 - 45 kw/h)
154 2023/07/24 3:23:02 What is the state process for requiring hardware to allow all types 85748
PM MDT of vehicles especially those with the Tesla connectors, and those
who would like to be compatible with the Tesla connectors to have
access to charging stations throughout the state? I just bought an
EV that does not have a Tesla connector And I'm wondering if
there is any requirement that there be interconnect ability
between the various types of chargers?
155 2023/07/24 3:29:10 Are there going to be charging stations on 83 to Sonoita? 85637
PM MDT
156 2023/07/24 3:30:23 Seems like if there are vending machines at our rest areas, that 85748
PM MDT there should be the possibility of power vendors as well. The
eastern stretches of a I-10 in our state are heavily underserved for
EV charging. If you're trying to drive from Tucson to Las Cruces or
Deming or Silver City, there is one level two charger in Lordsburg,
which is probably the only one available for a 2 Hour Dr. along I-
10. It seems only reasonable that the state would address that
disparity for EV charging on a long lonely stretch of interstate
highway. The state of New Mexico does not have plans to install
chargers in Lordsburg. And this is certainly a concern of mine as an
EV owner in Arizona.
157 2023/07/24 3:34:51 We need fast charging in Prescott Valley / Prescott area. Also on 86314
PM MDT something between Aguila and Quartzite.
158 2023/07/24 3:38:49 There is no point in installing anything but fast chargers. Users will 85383
PM MDT not leave their car overnight.
159 2023/07/24 3:41:15 I notice that there is not much coverage of the north eastern 85008
PM MDT quadrant of the state in particular on the Navajo reservation
which attract a lot of tourists
160 2023/07/24 3:43:39 ADOT needs to really consider their AFC's off the normal Interstate 85338
PM MDT freeways and use their AZ highways for consideration of the EV
charging station locations. Typically those highways such as AZ
260, 277 and 77 leading from both Payson & Show Low to the I-40
corridor. In addition, US 60 from Globe going North and East
would be a AFC that should be considered as these routes are
tremendous cut off's from the I-17 to I-40 Corridors.
161 2023/07/24 3:55:32 Could it more simple and save money, while expedite the EVSE 85648
PM MDT installation if you only require the growing popular NACS ( One
type plug per EVSE ) assuming a low cost ( at cost ) adapter is
made to anyone that needs them. NACS plug are smaller and
easier to handle more robust plug and simpler than CCS and
Chademo. Most non Tesla EV made before 2024 will only need a
NACS to J1772 adapter rated to the max amperage used/
compatible with the DCFC. ( Many Like me and non Tesla owner

E-18
 already carry a NACS to 1772 adapter which was rated for use on a
Tesla Destination charger ( not Supercharger) this adaptation is (
safe) possible there may not be the need for the new Magic Dock
at new Tesla Superchargers ? ( I am not an electrical engineer or
know the Tesla platform ) .
162 2023/07/24 4:00:11 I do not agree with all the EV plans. Our current grid does not have 85541
PM MDT the ability to keep up with all these additions. We are always
worried about conserving electricity and yet we want to add tons
of EV's and charging stations?? It makes absolutely no sense!
These plans that are trying to move forward to force everyone to
have an EV is not even possible with the state of our current grid
system. We need to put money and focus on updating our grid
system to allow it to even supply all that is drawing from it
already! I OPPOSE this plan!
163 2023/07/24 4:04:12 I am a knowledgeable EV owner/driver 85050
PM MDT I own 2 vehicles; both are all electric, and I have been driving EVs
for the past 2 years
I have read the 2022 plan and the 2023 update and agree with the
vision, goals and the comments submitted. I submit the following:
Distance between stations and consideration of vehicle charge
ranges, was of concern, but 50 miles between should satisfy
everyone
Want to see improvements to the electric infrastructure (both by
utility companies and service providers) to actually provide fast
charging, and also more standardized charging speeds. Station
speed provided is not even close to 150 kW. In a recent trip of
approximately 3,000 miles, I charged 39 times at stations in AZ, CA,
OR and WA. The average charge speed in AZ was 76 kW while the
average speed of all chargers was 85 kW.
This is a great plan, and completion of the project will be of great
benefit to the public. A future plan with additional resources and
financial participation should include more stations at future
tourism sites (national, state and local). A map showing
connections between tourism sites should have been included in
the reporting.
The RFP process should include consideration of station providers
that have contracts with auto manufacturers that give owners free
charging. Currently several of the EV manufacturers provide
various amounts (1 to 3 years) of free charges using three brands
of stations: Electrify America (EA), EVGO, and ChargePoint. Two of
these also have extensive networks and I believe would be more
reliable for a project of this magnitude.
CVW is missing from the list of auto manufacturers.
A clear summary of the number of built stations should be
included, and how many were completed since the 2022 plan, if
any.
164 2023/07/24 4:30:44 I think EV is a dangerous proposal. With snow and fires and floods, 86305
PM MDT terrible if evacuation needed. Batteries China controlled. Gas
much more reliable. Waste of tax dollars.
165 2023/07/24 5:11:03 I feel that transportation money be spent on roads, bridges and 85132
PM MDT the like. Not on EV stations. If anyone truly cares about damage to
the environment they can find information, facts, that electric car

E-19
 batteries are far more damaging to mine, produce and dispose of
than any gas car related fuels. I do not want to see my tax dollars
spent on EV anything.
166 2023/07/24 5:16:31 We need to have EV infrastructure in place so people feel 85705
PM MDT comfortable buying an electric vehicle. This is the investment we
need for our future. The extreme heat we are experiencing now in
Arizona is the prime example of why we need to work away from
fossil fuels and toward sustainables.
167 2023/07/24 5:18:57 As an EV owner my biggest issue has been the unreliability of the 85255
PM MDT charger network. It does no good to install chargers that end up
not working - the vendor needs to be held accountable for a
working network. Also, all chargers in AZ should have a shade
structure for both the user and the life of the unit. It is almost
impossible to read the screen in the bright AZ sunshine.
168 2023/07/24 5:31:49 The City of Bullhead City is grateful for the opportunity to provide 86442
PM MDT comment to ADOT about its Arizona Electric Vehicle Program.
Based on the ADOT EV Program update given on 7/18/2023, we
understand that State Highway 95, through Bullhead City, is
included in the 2024 & 2025 EV Plan. This is exciting news for us!
We encourage ADOT to further explore the benefits of deploying a
charging station in our community as soon as possible. We are
conveniently located, and our location allows for infrastructure
development to build onto the NEVI and AZEV Plan vehicle to grid
infrastructure (AFC's). The City is prepared to provide further
evidence and welcomes robust discussions as to why our location
is optimal for a station, sooner rather than later.
169 2023/07/24 5:35:18 The more the better in my opinion. Especially in rural areas in case 85305
PM MDT folks leave town without fully charging and can charge up in the
middle of no where.
170 2023/07/24 5:35:42 I'm not interested in electric cars until they improve the Exploding 85650
PM MDT batteries. Also, I drive across country in rural areas. Barely enough
gas stations sometimes let alone somewhere to charge, and I don't
have time to sit and wait for it to charge.
171 2023/07/24 5:39:45 Please provide for competition with these charging station. Just 85250
PM MDT one provider leads to high costs for the service
172 2023/07/24 6:16:21 I want to thank and applaud ADOT for their comprehensive and 85004
PM MDT consumer-friendly NEVI process. The outreach and educational
materials have been fantastic, like you actually want to hear from
Arizonans. From what I understand, Arizona is outperforming
other states and will likely get chargers in the ground quicker than
others. I hope that is the case because we desperately need to get
this money out the door. Great to see Highway 93 on the update
connecting to Nevada. Keep up the great work!
173 2023/07/24 6:28:42 I believe they need to go back to the drawing board on electric 85383
PM MDT vehicles and will never own one. The fires are too hard to put out
and the used batteries are not environmentally sound.
174 2023/07/24 7:20:11 Thank you for the presentation. I look forward to seeing universal 85308
PM MDT fast chargers throughout our state. I am waiting to see more of
these and them I'm ready to buy an EV!
175 2023/07/24 8:39:59 The EV Charging Stations are a joke, all it means is more money 86401
PM MDT being spent and the taxpayers footing the bill, even for the people
who don't have and won't have a EV. Having the EV Charging

E-20
 stations means that when the summer heat comes our electric
power can become outage prone more than usual or the
government saying to not use power (a/c) our power grid cannot
handle the EV's need to charged every 200-350 miles.
176 2023/07/24 9:21:42 So needed with the number of people converting to EVs to give 85085
PM MDT more freedom and confidence to be able to drive distances to
enjoy other parts of Arizona without worry of being stuck.
177 2023/07/24 9:35:33 I'd like to see Rt 93 be a priority upgrade. From Phoenix to 85383
PM MDT Kingman is a nowhere land for non-Tesla EV owners like myself.
I'm not going to trust that the one viable location in Kingman will
be available when I drive to Vegas. I end up driving my ICE vehicle
instead of my EV. I'm sure I'm not alone here. Thanks for your
time.
178 2023/07/24 10:07:56 The 2022 plan looks good, but I was totally unclear as to when it 86301
PM MDT all would be in place.
179 2023/07/24 10:39:05 Not sure what this means 86351
PM MDT
180 2023/07/24 10:41:43 I just want to say I hope the electric charging stations on the 86351
PM MDT Interstates are completed before the secondary highways are
started. I 40 is in desperate need of additional stations.
181 2023/07/25 6:48:26 Tesla Superchargers are designed with limited cable length to just 85648
AM MDT reach the NACS plug on Teslas. All Tesla models plugs are rear
driver Should the magic-dock cable be slightly longer given the
varied position of the CCS plugs on non Tesla vehicles?
182 2023/07/25 8:17:25 We have a ton of places to charge EVs where I live and i have yet 85123
AM MDT to see anyone use them. Five billion dollars seems ridiculous for
something so useless.
183 2023/07/25 8:46:12 Are you going to switch from CCS to NACS, now that many of the 85749
AM MDT major EV manufacturers have agreed to switch to NACS
184 2023/07/25 9:33:10 This is my own perspective and not endorsed by the broader 85710
AM MDT organization, though it is well aligned with administrative and
board policies surrounding vehicle electrification in Pima County:

Partnering with Counties to Electrify Highways

Opportunity: There is an opportunity for the state DOT to partner

with counties to electrify highways. Counties can help identify
scenic and cultural destinations that would be attractive to electric
vehicle (EV) drivers, and they often have lots with electrical service
that could be used for charging stations. This would make it easier
for EV drivers to reach these destinations and enjoy the benefits of
electric transportation, such as reduced emissions and noise
pollution.
Benefits: Partnering with counties to electrify highways would
have a number of benefits, including:
Counties can help to identify the best locations for charging
stations, based on factors such as traffic volume, proximity to
tourist destinations, and availability of electrical service.
Counties can help to obtain the necessary permits and approvals
for the installation of charging stations.
Counties can help to raise awareness of the charging network and
encourage EV drivers to use it.

E-21
 Win-win: This partnership would be a win-win for both the state
DOT and the counties. The state DOT would be able to expand the
reach of the charging network, while the counties would be able to
promote economic development and tourism.
Conclusion:

I believe that partnering with counties to electrify highways is a

great idea. It would have a number of benefits for both the state
DOT and the counties, and it would help to promote the use of
electric vehicles. I hope that this partnership will be explored
further.

Additional thoughts:

In addition to the benefits mentioned above, partnering with

counties to electrify highways could also help to reduce congestion
and promote healthy outdoor activities.
This partnership could be a model for other states and counties
that are looking to expand the reach of their charging networks.
I am excited to see how this partnership develops in the future.
185 2023/07/25 9:44:04 This is a waste of my taxpayer money. Only benefits the minority 85045
AM MDT of people with EV's. Also, even if these charging stations are built, I
can only see the scenario when someone pulls in to charge and
there are 10+ cars ahead of you also waiting! So, a person is
supposed to wait hours to charge ! Also, what happens when there
are power outages and the stations don't even work! Also, we
then have to pay to maintain these stations....for the minority.
Government overreach!
186 2023/07/25 10:08:41 The alternative fuel corridors are phenomenal!! Please make sure 85225
AM MDT that we (the state of Arizona) stay with international standards
and leverage the CCS connector (supported by all electric vehicles)
as opposed to Tesla's NACS, which is still locked down. Obviously,
It's no issue if Tesla establishes supercharges on the route (in fact,
it's welcome). But I feel that taxpayer dollars should support the
connector types that most new elective vehicles leverage.
187 2023/07/25 10:26:21 We definitely need more charging stations in AZ. Also, we have 85383
AM MDT attempted to used charging stations found in shopping centers
only to find gas powered vehicles parked in them! PLEASE
construct and secure them so ONLY EVs have use of them! Thanks.
188 2023/07/25 11:03:55 This doesn't affect me because I don't have an electric car. I don't 85653
AM MDT like the idea of them. The batteries are very expensive and I don't
think they can be recycled like normal batteries. Why not just
make a solar car? There's too much to go wrong with technology
like this. I'd prefer to have a car pre computer. If ever there's a day
when a war breaks out, where it affects the computers in the cars
and makes them stop in their tracks, I'll still be driving along,
waving as I go by.
189 2023/07/25 11:39:34 As Charge stations are built, please consider class 8 semi trucks 85233
AM MDT charging, with space around and access.
190 2023/07/25 12:02:15 Arizona should consider the emergence of automotive 95008
PM MDT manufacturers adopting the North American Connector Standard
(NACS) in their plan. ChargePoint is committed to delivering

E-22
charging for all EV drivers regardless of make or model of vehicle
and have announced intentions to integrate NACS connectors on
our respective networks and/or within our product lines. We are
concerned, however that a mandate to include NACS connectors in
the early rounds of NEVI funding will delay deployments of
chargers at a time when more, not fewer, chargers are quickly
needed.

There is currently a significant need to grow the number of

installed fast chargers to serve CCS vehicles on the road today. This
need will continue to grow as auto manufacturers stated that they
will adopt the NACS inlet in model year 2025. As such we caution
against taking any action that could further delay the deployment
of fast chargers along Arizona highways.

Industry needs time to develop and secure a Build America Buy

America NACS supply chain sufficient to meet industry demand
and to test and certify chargers with the NACS connector. First, the
supply chain for NACS connectors and cables is not yet developed.
Commercial adoption can only occur with a diversified supplier
base, which will take time. Notably, cable suppliers and
manufacturers may wait until the NACS connector is standardized
before scaling up manufacturing operations.

Second, the NACS connector and cable are not currently

individually certified to the UL safety standards, like CCS cables
tend to be. We expect cable manufacturers and suppliers to
emerge that will obtain certification to UL standards for NACS
cables and connectors. However, in the meantime, charging
manufacturers will need to re-certify their chargers with the NACS
cable and connector in order to meet the Federal Highway
Administrations (FHWA) minimum standards. This certification
process can take a number of months.

Further, many charging manufacturers and network operators

conduct additional performance, reliability, and safety engineering
and testing on new cable and connector suppliers that go above
and beyond UL standardization. Examples could include: (1)
extending the cable length from its current size, so it can reach
charging inlets at any location on any EV; (2) ensuring the locking
mechanism between NACS and CCS is compatible and safe to use;
and (3) testing and engineering NACS connectors and cables to
meet certain technical parameters (e.g. thermal, volts, amps) to
comply with the NEVI minimum standard and provide ultra-fast
charging speeds. These additional efforts can prolong the timeline
for when NACS connectors may be broadly available on non-Tesla
chargers.

Third, the industry is just beginning work to standardize the NACS

connector. Both CharIN2 and SAE3 have announced plans to
standardize the safety, security, and interoperability of the NACS
connector and we expect these processes will take time. The
outcome of this effort may impact the design and engineering of

E-23
 non-Tesla chargers that integrate NACS connectors. We caution
Arizona against requiring NACS cables and connectors before
CharIN and SAE have concluded these processes and the charging
industry has had time to implement the resulting standards.
191 2023/07/25 12:11:15 Looking forward it makes sense to ensure that NACS IS A MAJOR 86017
PM MDT PART OF ANY CHARGING BUILD OUT
192 2023/07/25 12:15:41 Please send an alert as each public charging station becomes 85086
PM MDT active. Also provide an map of the current active charging stations
throughout AZ. If an alert went out to notify is a charging station
is down or not active would be helpful.
193 2023/07/25 1:08:29 Excited that routs to the NE part of the state are in the works 85018
PM MDT
194 2023/07/25 2:37:21 You will have a line up waiting to "charge" at every station. Think 85381
PM MDT of the weekend traffic coming back from the high country on a
Sunday afternoon- its stop and go. Who wants to wait their turn to
charge? I resent my tax dollars going to this short sighted system.
There is no way I will ever be able to afford an electric car at $50K
and up. Just another way to separate the elite from the average.
195 2023/07/25 6:09:36 It's encouraging to see that US 60 from Phoenix to Globe is 85546
PM MDT included in the 2024-2025 EV Charging Infrastructure plan.
Graham and Greenlee County strongly encourage ADOT to include
US 70 from Globe to Safford in the 2025-2026 deployment plan
followed by US 191 to Morenci and I-10 in 2027 & 2028. This will
improve tourism, support public transit and increase commerce
for Graham and Greenlee County.
196 2023/07/25 6:09:58 Lake Havasu City would like to give input into the project and is 86403
PM MDT available to work with any developer who receives the contract.
Given that many of our businesses are closed late at night, we
recommend the charging station be located at Pima Wash (an
open area) along with a shade structure and a bathroom. This
location will give EV drivers access to many amenities during the
day and a safe neighborhood at night.
197 2023/07/25 10:07:44 Generally, the plan seems reasonable and workable, with a high 85306
PM MDT likelihood of success.
The public communication process is not as transparent as it could
be, and the staff seemed hesitant to respond to the more probing
inquiry while eagerly responding to the softball inquiries, like the
nature of the connectors at the charging stations. The public utility
and value of this type of update are questionable.
There was not enough discussion of the following topics:
contracting opportunities; contracting in general; MBE contracting
opportunities; Operations and Management;
coordination/integration of this project's networking requirements
with offer state network and agency projects,
I am concerned that contracts will be awarded in a manner that
does not optimize or maximize the positive and practical benefits
to the state and its citizens in favor of (potentially) excess profit to
contract awardees.
The EV project is yet another excellent opportunity for Arizona to
show leadership in technology, innovation, and competent
execution of major initiatives. My wish is to see "AZ on Top."
Thank you for the opportunity to provide feedback.

E-24
 198 2023/07/26 8:31:20 none 85546
AM MDT

Note: Some comments have been edited to remove identifiable information.

Table E - 2: E-mail Comments Received from 2023 Form

# Date Comments/Questions
1 7/12/2023 Your update shows you plan an EV charging station between Payson and Show Low on AZ-
260. While I think any charging stations you put in will be great, I believe there is a greater
need on 260 closer to Eager. There are currently no charging stations in that area and we
could sure use one!
2 7/13/2023 Please send me a link to join
the meeting on EV Charging stations.
Thank you
3 7/16/2023 Dear Sir, I would like to sign up to be invited to attend your EVPLAN Webinar to be held at
6PM on July 18th.

My Name is [Name] and Email Address is [Email]. Thank you for the opportunity to view
this Webinar.

A note of interest, I am a retired ADOT Maintenance Engineer from the [Location and
Time] and formally the [County Name] County Engineer from [Time Range] and always
had a close working relationship with ADOT staff on Local Government projects with.

Thanks, [Name]
4 7/17/2023 I tried to sign up to attend the virtual meeting about EV cars, but the website led me to
three different menus. I didn't find a way to sign up after going to: AZDOT.gov/EVPlan

Could you either sign me up or give me the exact site to go to?

Thanks,
[Name]
5 7/15/2023 This has to be the most dishonest and irredeemable act of a politician I've ever seen in my
73 years. Force the public to buy cars they cannot afford! Buy energy to power the vehicle
for which they neither can afford. Nor can they afford the time inconvenience to wait to
fill up, even for moderate range. Force us to pay for energy supply infrastructure that the
government can't afford, and we sure as hell can't afford, to produce waste and
environmental gouging that we neither have nor can we afford, eitheidiots hat the hell is
wrong with you idiots???!!!!

Oh did I mention, your grand plan doesn't even provide coverage for the main North
South artery of Phoenix, RT 17. My God, how can so many people be so utterly stupid????
6 7/15/2023 Stop pushing electric vehicles that only the very rich can afford and waisting tax dollars.
7 7/13/2023 why should we spend any money on this?
a typical tesla battery weighs 1,000 lbs
a typical full tank of gas weighs 80 lbs.
encouraging ev's which this plan would do is wrong.
they pose a risk to firefighters if there is a car fire
they don't work as efficiently in cold temp.,i.e. flagstaff
they are much dirtier to make, many of the mines that produce materials for the car
batteries use child labor, especially in africa, china owns many of these mines

E-25
 when the battery's life is over, they are almost impossible to recycle

if someone
thinks they're making the world a better place by buying an e.v., they need to read the
above points.
why should adot spend any money on this , when many of our state highways are not in
good shape?
thank you,
[Name]
8 7/15/2023 I feel that it is wrong for Pinal County to get involved with EV though the government
offers them money. The expenses are still being paid by all the consumers.

Disappointed that Pinal County is thinking about offering stations on our highways. This
was never offered to people who choose to us gas.

In addition, at this time, how are the EV consumers paying towards the upkeep of our
highways? Disappointed again that this was never thought about in the first place. People
who are driving gas cars shouldn't be paying for it.

[Name]
9 7/17/2023 There are a lot of seasonal drivers who commute from Tucson and Phoenix to Show Low
and Pinetop, especially during the summer. We're interested in purchasing an EV vehicle
for the drive between Phoenix and Pinetop, but we need non-Tesla charging stations in
Globe, Payson, Heber, Show Low and Pinetop for that to be an option.

Are there any plans to add charging stations along these routes?

Thanks,
[Name]
10 7/17/2023 There are far fewer fast charges than needed between Phx and LA and often lines to use
what few there are. It would be very beneficial to have some placed in Quartzite along the
I-10 corridor. Thank you!

[Name]
11 7/14/2023 I hope this email finds you well. I have continued tracking the AZ NEVI process, but I had a
question regarding the target vehicle type for infrastructure deployments from the state’s
plan. To my understanding, NEVI infrastructure deployments in Arizona are slated for
light-duty, passenger vehicles, correct? Some states are entertaining light-duty and
medium- heavy-duty infrastructure deployments to accommodate both passenger
vehicles and goods movement vehicles like tractors, so I wanted to reach out to see if
there were any plans for this. I may be preemptively asking this as the ADOT Electric
Vehicle Charging Infrastructure Implementation RFI is currently open for comment and
may inform this question, but any information you are able to share is appreciated.
12 7/15/2023 You may be aware of the critical need for increased DCFC capability at Quartzsite. The low
number of DCFC chargers, poor reliability of EA, and increased EV adoption are creating
an untenable bottleneck for drivers traveling between Phoenix and southern CA.

Is ADOT planning for DCFC expansion in Quartzsite?

The new EVgo chargers on Litchfield Rd in Goodyear are getting good reviews for speed
and reliability. Could you please consider awarding EVgo a contract at Quartzsite?

E-26
 Thank you in advance for your consideration.

[Name]
13 7/15/2023 I applaud the state's initiatives on making a better EV network as a Tesla owner. But I do
want to make a few comments. We need to get EV charging stations installed at TUS as
Tucson Airport has no charging stations. This needs to change and I wouldn't mind seeing
a bank of 120 plug-in chargers in the TUS parking garage similar to what PHX has outside.
We really need EV charging at TUS as that is currently nonexistent.
14 7/14/2023 With more and more mainstream automakers adopting the NACS connector standard, I
am writing to encourage ADOT to adopt/include the NACS for all EV charging stations.
Thank you.
[Name]
15 7/14/2023 I am interested in hearing what effect the changes announced by Ford and GM (to switch
to Tesla charging configurations) will have on this project. Will the statins being put in be
useable by all??

[Name]
16 7/17/2023 You need to share also all of the written comments you may have received
with the public, at the seminar as well as on your web site.

Arizona public has the RIGHT to know, who is saying what, especially
from the real transportation professional individuals. It is the PUBLIC,
who is paying for all of this !!!

Seriously, [Name]

[Name and Titles]

17 7/17/2023 What are the plans to address the data storage, cybersecurity, and reporting component
of the NEVI program? Does the agency plan on opening an RFI/RFP process? Is the Agency
open to idea or suggestions to address this key component?

Thank you,
[Name]
18 7/18/2023 I mean, it is the public. Good job.
19 7/19/2023 To whom it may concern,

It has been brought to my attention from one of my associates who attended the planning
meeting on July 18th that AZ DOT hasn't reviewed any of the studies that have been done
on the necessity of shading EV chargers.

I've attached a comprehensive study that has been conducted for your review.

I hope this information is useful in determining the need to shade the EV chargers for the
reasons outlined in the study.

1. Prolonged life of the equipment

2. Comfort to those sitting in the sun while charging
3. The increased efficiency in charging when in shade.

https://financialpost.com/commodities/energy/electric-vehicles/heat-wave-cook-ev-
battery

E-27
 Best Regards,
[Name, Title, Company]
20 7/18/2023 I say let the free market carry this one. That way if it is not cost-effective, it doesn't drag
everybody down. It takes a lot of resources, and at this point slave labor, to build those
batteries.

Batteries store electricity, they do not produce it. Charging batteries takes fossil fuels. So
much for Green energy.
21 7/18/2023 Thank you for your reply. Whether state or federal funding, taxpayers are paying for it.
Why aren't EV owners paying for our highways expenses? This whole thing is totally
wrong and I wish that AZ would not get involved with it.
22 7/19/2023 Hello, I was unable to attend the webinar yesterday. Was it recorded by chance?
23 7/17/2023 Thank you for your prompt reply.. I am not impressed with your comments stating that
the state has no liability. Rather, you point out, your responsibility will be to manage and
administer funding derived from Federal Funds (80%) and private funds (20%). When ever
I hear Federal Funds used, I begin to have nightmares. Of course, with the Feds running a
deficit of some 30 trillion dollars, doesn't it scare you, that we're all of us on the hook for
everyone of those dollars!
24 7/18/2023 Looking at the proposed routes to add EV chargers, I do not see any for southern Arizona.
Southern Arizona has been neglected as far as EV chargers. There are no Tesla
Superchargers, for instance, south of I-10 in Arizona. We need to add chargers along the
north-south routes south of I-10, specifically we need chargers:
Along I-19: in Green Valley, Tubac, and Nogales
Along Hwy 90 from I-10 to Sierra Vista: Chargers are needed in Sierra Vista and Hereford
Along Hwy 80 from I-10 to Bisbee: Chargers are needed in Tombstone and Bisbee
Along Hwy 83 and 82 from I-10 to Sonoita and Patagonia: Chargers needed in both these
locations.
South Hwy 191 from I-10 to McNeal: these rural routes are used to get to
backcountry/mountain areas and lack of chargers make it difficult for EV drivers to enjoy
these areas.
In addition, North Hwy 191 from I-10 north to Safford: Safford is also lacking a Tesla
Supercharger.

As someone who has embraced driving a Tesla but who is also an avid bird watcher, hiker,
and camper, I have found it frustrating that it is difficult to go and camp with my Tesla in
our National Forests as there are just not enough places to charge. Look at the White
Mountains, for instance, around Greer. Nothing there.

Thank you for your consideration,

25 7/18/2023 t's 180 miles from Tucson to Show Low and there is only one small fast charger on that
route, in Globe. AZ 77 is the only route from Tucson to the White Mountains and it is a
very important route for Tucsonan's recreation and other tourism. A station between
Tucson and Globe and one between Globe and Show Low would make the trip a lot less
stressful.
Thank you
[Name]
26 7/19/2023 Thank you for your presentation this evening. It was a great help in
understanding how ADOT's rollout of EV charging stations will be
implemented in phases over the coming years.

One of the team's stated goals is to reduce range anxiety for existing
and potential EV owners. As an EV owner who has traveled between

E-28
 Phoenix and southern California, the paucity of available CCS chargers
between the valley and the greater LA area is a contributor to range
anxiety. Dianne stated correctly that the Electrify America (EA)
charger in Quartzsite is NEVI compliant in that it has four CCS
chargers. However, it is well known in the EV community that east/west
travelers are underserved in Quartzsite with the existing EA chargers
which are too few in number and too poor in reliability. Waiting for
turns on a charger will only slow EV adoption, and long waits are
common at this location on high traffic weekends. For context, please
view the link below for photos and comments about this station, posted
by EV owners:

https://www.vwidtalk.com/threads/charging-line-18-cars-at-quartzite-az-ea-on-11-26-
22.11131/

I hope the ADOT team will consider the amount of traffic through
Quartzsite and its critical location and identify the need for
increased carrying capacity of charging there. Thank you for all you
are doing to speed EV adoption in Arizona.

Are there volunteer opportunities for your program? If so, I would be

interested in applying. I have been an EV owner for 3 years and 55,000
miles and have used DCFC with my 2017 Chevy Bolt to travel to CA, NV,
UT, and CO. I would be happy to share my experience and give of my
time toward the cause of speeding EV adoption.

Sincerely,
27 7/18/2023 I was not aware State Routes were eligible to receive EV chargers, not being part of the
National Highway system. However, I see SR 64 and SR 95 are both on the 2023 plan. If
you can tell me how these state routes were selected to be part of the plan and other
state routes were not, I would appreciate it - perhaps a matrix showing the ranking of the
various NEVI criteria for each State Route.

I’m lobbying for an EV charging location along SR 66 in Peach Springs, an historically over-
looked and underserved town on the Hualapai Reservation which was bypassed by I-40 in
1978. And yes, Mohave Electric Cooperative has a 14.4 KV, 3-phase power line serving our
local market, hotel and the historic Osterman Gas Station, with the latter being
designated one the 11 Most Endangered Places in America and has garnered a significant
amount of press (https://www.azfamily.com/2023/07/14/new-effort-restore-iconic-gas-
station-northern-arizona/ and attached press release).

I look forward to your response

[Title]
28 7/19/2023 I wasn't able to attend the virtual meeting on the 18th. Will it be available as a recording
somewhere?
29 7/19/2023 I own property at Interstate 40 and Hwy 95 at exit #9.
I want to build a truck parking facility and Electric truck charging station on approximately
4 acres.

[Company], we've been in Trucking business for 30 years.

How can we obtain information please?

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30 7/18/2023 Please reply to this message with an explanation of the best method for the Tribe to
engage on this issue, including the State's availability to set a time for a direct
conversation with Hopi by Webex or Zoom. As I was finally able to indicate by phone
before the session ended, as the State has repeatedly acknowledged, the federal funds
for this program require prioritization of underserved communities and Hopi disagrees
that it has received the outreach the State described in this session, especially considering
the Hopi I-40 travel site east of Holbrook I noted in my Q&A entry (which was ignored in
the session and has been ignored by the State at earlier discussion opportunities) but
referenced as a priority site category by one presenter tonight.

I look forward to your prompt follow up, thank you for your assistance.
31 7/20/2023 Hi, my name is [Name] and I missed the recent call about electric vehicles. I downloaded
the app about traffic but I would like to know if you show where all of your electric
charger stations are on the major highways I do not see that on the map and if so, how
can we get it on the map?
32 7/20/2023 Hello. I am a reporter with the [Media Outlet] in Prescott. I listened to the Zoom
discussion about NEVI on Tuesday night, and I have a few questions:

- Could I get the number of people who tuned in to the meeting?

- Also, how many questions did you get from the public?
- Just to clarify, when will the Prescott-area Highway 69 corridor be added to the plan,
and when might those charging stations be under construction?
- When is the next public meeting about NEVI?

Thanks so much for any help you can give me on these questions.
33 7/20/2023 I own a corner lot in the Marana Twin Peaks and I-10 interchange shopping center. This
lot is on the main road in the center of the development. It will accommodate charging
stations. I want to offer this site as a potential candidate. Please contact me for more
details if of interest. Thank you.
34 7/24/2023 We were not able to respond to your entire RFI but wanted to provide some brief
comments on a couple topics related to your NEVI Plan. Please let us know if you have any
questions or would like to talk further on this. Thanks again— we appreciate the
opportunity to provide feedback.

---

EVgo recommends ADOT avoid “bundling” all sites in its solicitation process.

ADOT notes that one approach being considered is to select a single Developer to install
EVSE at all 21 NEVI sites. EVgo strongly recommends ADOT avoid grouping or “bundling”
sites in its solicitation process. Instead, we recommend ADOT allow applicants to apply on
a site-by-site basis. By bundling sites, ADOT risks vendors refraining from bidding on the
bundle due to obstacles that arise for one or more of the sites in a bundle, such as
difficulties securing site hosts, funding, or permitting. The New Hampshire Department of
Environmental Services experienced this in 2019 when it tried to release its VW
“Dieselgate” funding and received no qualified bids due to the overly specific
requirements and statewide scope of the RFP. Creating an open solicitation for individual
stations will likely increase competition overall because a greater number of vendors are
likely to be well-positioned to apply for individual locations as opposed to a large set of
locations. Furthermore, multiple networks operating within a state or corridor provide
other advantages for drivers. They create redundancy during the construction and
operational phases, so a state isn’t dependent on one network to build out a corridor.

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Another option would be to allow applicants to propose a bundle or group of sites, but
not require bundles of sites.

EVgo recommends state DOTs avoid including NACS requirements in phase one of their
programs, and instead monitor industry trends and solicit stakeholder feedback to inform
requirements in phase two.

As ADOT considers program requirements for connector types, we would like to provide
comment on the potential requirement of the North American Charging Standard (NACS)
within the NEVI program. EVgo has a history of delivering charging for all EV drivers, and
recently announced we intend to integrate NACS connectors on the EVgo network in
future deployments. While we look forward to continuing to serve all EV drivers –
regardless of make or model – after NACS makes its way through standards bodies for
reliability and safety, the reality is that any requirement to include NACS in the first round
of NEVI funding is premature.

Specifically, a NACS requirement is likely to delay NEVI deployments. No NACS cable and
connectors have received UL certification, and as manufacturers develop new offerings
with NACS connectors they will need to re-certify for safety. Further, before
manufacturers can develop their own NACS products, there are still several critical details
not fully outlined in the NACS designs released to date that will need to be understood.
Finally, until NACS is published by a standards body, a process just now getting underway,
the NACS specifications are governed by a single company without standardization that
suppliers can rely on to ensure safety, security, and interoperability of this connector.

Following certification by UL and a standards body, it will be necessary for electric vehicle
service providers (EVSPs) like EVgo to conduct our own qualification process, which
includes a number of tests for safety, reliability, durability, and interoperability as
governed by UL, SAE, the Federal Communications Commission, and Open Charge
Alliance. As any NACS connector deployed will need to undergo vetting by both standards
bodies and subsequently, EVSPs’ own internal processes for safety and reliability, as well
as vehicle interoperability once non-Tesla NACS vehicles come to market beginning in
2025. Altogether, the process to ensure safety and reliability both through codes and
standards bodies and EVSPs’ own internal tests – combined with necessary testing for
vehicle interoperability once non-Tesla NACS vehicles come to market – will be extensive.
As such, prematurely requiring NACS in the first phase of NEVI would significantly delay
deployments.

NACS connectors are not necessary at this stage to provide charging access to vehicles
equipped with a NACS inlet, which until 2025 are limited to Tesla EVs only, and thereby
serve all EVs. Adapters are already available for Tesla vehicles to enable them to plug into
CCS chargers—for example, Tesla vehicles already charge on CCS connectors with a CCS1
adapter, and General Motors has announced it will make adapters available for NACS
vehicles when they come to market in 2025. However, there are currently no adapters
available to enable CCS vehicles to utilize NACS chargers. As a result, while
implementation details are still being worked out for NACS – including the safety and
reliability testing mentioned above - it would not lead to a stranded asset risk if state
agencies continue to support the development of CCS chargers, as CCS chargers cater to a
wider range of vehicles compared to NACS connectors, and will continue to do so as
adapters are expected to become ubiquitous for NACS drivers in 2025 and beyond.

I will also attach a letter our coalition of EV charging companies recently provided to KY
on this same topic.

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 Again, please let me know if you’d like to talk further.

Thanks so much,

35 7/24/2023 I could not get comments in via the link provided, so I am emailing.

The whole nation is not ready for EV. We are rushing into this without taking into
consideration the supporting materials needed and other factors. For example, mining
and related endeavors will increase greatly to develop EV batteries. Not doing a whole lot
for preserving Planet Earth. I don’t believe that a good number of AZ drivers are that
eager to purchase these vehicles.

EVs cost is steep There are electric car safety concerns; if on fire, they require thousands
and thousands of gallons of water to put said fire out (great use scarce resource). EV have
long charging times.
People will be standing in line quite a bit for a limited range of travel (miles) even with
more charging stations. One thing that came to light recently, probably not applicable to
AZ most of the time is the fact that electric vehicles struggle to perform when weather
turns cold.

We would do better in investing in a combo of nuclear power and fossils to improve

overall efficiency of energy consumption and the environment instead of pushing these
EV plans without having an alternate source of energy for the whole nation.

Thank you for your attention.

36 7/22/2023 Thank you for contacting the Arizona Department of Transportation (ADOT). Your
comments are important to us and have been shared with the appropriate members of
our team.
37 7/22/2023 I appreciate the planned proposals for the Alternative fuel corridors . I have two
questions,
1) Where is the energy coming from to feed these charging stations? Will another nuclear
plant like Palo Verde be considered that can produce 32 million KW of carbon free power?
2) Most important to AZ drivers is this question, will the I40 and I10 corridor roads be
repaired in this budget as well? The roads are destroying cars that use them especially
through the Flagstaff to Kingman corridor.
38 7/25/2023 Charge Ahead Partnership (“CAP”) is a coalition of businesses, associations, and
individuals that
share the common goal of efficiently and effectively developing a charging network for
electric vehicles
(“EVs”) across the United States, CAP respectfully submits the following comments in
response to the
Arizona Department of Transportation’s (“ADOT”) request for input as you update your
Electric Vehicle
Infrastructure Deployment Plan (“Plan”). CAP looks forward to working with Arizona
policymakers to
create a robust marketplace for EV charging so that Arizona’s system of charging locations
is positioned to meet drivers’ expectations of quality service, safety, and affordable,
competitive pricing. CAP aims to
empower the consumer and ensure that they have the confidence to transition to EVs
knowing that they
will be able to conveniently recharge no matter where they go in the country Drivers of
gasoline-powered vehicles will only transition to EVs when they are confident that the

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fast charging experience will be as safe, convenient and reliable as their current refueling
experience. These comments are intended to guide Arizona’s EV infrastructure
deployment in a manner that will help realize this objective as promptly and efficiently as
possible.
Many of CAP’s members own the real estate that is best suited for direct-current fast
charging
infrastructure. CAP members operate hundreds of store locations in Arizona, most of
which are located
along highway corridors, and all of them offer the amenities that drivers will demand
while refueling.1
CAP applauds Arizona for its intention to issue competitive contracts to private entities to
either
upgrade existing stations or to install new stations using NEVI funds. We encourage ADOT
to clarify that
“private entities” in this instance does not include quasi-governmental entities such as
electric utilities thatcan pass their cost share to the ratepayer. This distinction is critical.
Private enterprise must put their own money on the line, meaning they are incentivized to
ensure their investments – and consequently NEVI funds – are spent on a refueling
experience for which consumers will want to pay. Arizona should prioritize grant
applications that specifically involve a company placing their own capital at risk to own
and operate charging stations.
Having “skin in the game” is essential to a consumer-focused EV charging network.
Charging station operators with their own investments on the line will be motivated to
offer consumers more attractive pricing and better amenities. Meanwhile, if electric
utilities are permitted to supplement NEVI grant dollars with ratepayer money in a risk-
free, guaranteed rate of return environment, it will discourage private
investment and engender a faulty market structure. EV drivers will face more challenges
and prospective EV purchasers will be less inclined to buy an EV.
A primary concern for our membership under Arizona’s deployment plan is a potential
preference
for awarding funds to a single entity to implement the program or divide up corridors of
the state and solicit one entity for each region, and then tasking those grantees with
identifying real estate to install chargers.
Arizona should avoid the outsourcing of siting authority to entities whose priorities are
misaligned with the best interest of drivers. Moreover, a single entity that enters into
several site host agreements across the entire state may be forced to settle for siting
locations without the amenities or convenience that drivers are used to, which would
degrade the customer experience and disincentivize EV adoption.

The inevitable outcome of this approach will be that EV drivers’ recharging experience will
be short-changed. Rather than having convenient, fast and reliable access to state-of-the-
art EV chargers, EV drivers in Arizona will
continue to confront a less reliable network of chargers.
CAP is aware that ADOT is considering the implications of several automakers announcing
that
they are moving to the Tesla, North American Charging Standard (“NACS”) connector.
CAP’s members
are eager to provide any charging technology that EV drivers desire; however, CAP
discourages ADOT
from requiring the NACS connector for the pending request for proposal (“RFP”).
Requiring NEVI applicants to deploy stations with NACS connectors is premature and will
increase costs unnecessarily for this first phase of NEVI. More time is needed to properly
standardize, test, and certify the safety and

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 interoperability of the NACS connectors across the industry. While the direction is clear
that NACS will
be needed to meet future charging demands, additional time is needed in order to
standardize NACS. Efforts have been announced by CharIN and SAE to standardize the
safety, security, and interoperability of this previously proprietary connector.
It is important to note that currently adapters are easily available for NACS vehicles to
charge on
CCS connectors, but adapters are not yet widely available for CCS vehicles to charge on
NACS connectors.
The lack of any standard for adapters may pose a significant risk to reliability and safety in
the short term; and will require further time to certify and test quality control. As a result,
NACS connectors exclude a
significant number of CCS vehicles on the market in a way that CCS connectors do not.
Congress designed the NEVI program to catalyze private investment in an EV charging
network
on which drivers can rely. As customers utilize EV charging stations, they will expect a
seamless and
predictable experience not unlike their current refueling experience. The market
dynamics that govern
today’s liquid retail fuel sector should be replicated to facilitate greater EV charging
investment. CAP
encourages ADOT to prioritize policies and applications that promote competitive market
dynamics for EV charging. Thank you for consideration of these comments. CAP is happy
to be a resource for ADOT and participate in any future stakeholder engagement
opportunities.
39 7/25/2023 ADOT EVSE Planning Staff – In response to your EVSE deployment RFI, I am submitting the
information below and attached regarding a related interstate planning project for
medium and heavy-duty accessible alternative fuel infrastructure development.

Under our West Coast Collaborative (WCC) public-private diesel emissions reduction
partnership program, U.S. EPA has facilitated this project since 2016. While the data
gathering portion of the project concluded last year, we continue to convene our partners
to discuss related topics and follow up actions. Please let me know if ADOT would be
interested in participating in the WCC AFICC Steering Team moving forward; our next
virtual meeting is currently targeted for late-September 2023.

Additionally, while I may not be available to regularly participate in ADOT’s EVSE planning
proceeding, I would be happy to speak with relevant ADOT staff at an appointed time to
share findings from the WCC AFICC project, and answer related questions. Please let me
know if that is desired.

West Coast Collaborative Alternative Fuel Infrastructure Corridor Coalition (WCC AFICC)

Phase 1: CALSTART Strategic Development Plan for initial MHD alternative fuel
infrastructure projects in California, Oregon, and Washington.
Main Page - https://westcoastcollaborative.org/workgroup/wkgrp-fuels.htm#plan
Plan Document (published 3/13/2020) - https://westcoastcollaborative.org/files/sector-
fuels/wcc-aficc-mhd-infrastructure-development-plan-2020-03-12.pdf
Executive Summary - https://westcoastcollaborative.org/files/sector-fuels/wcc-aficc-mhd-
plan-exec-summary-2020-03-12.pdf
Highlights Fact Sheet - https://westcoastcollaborative.org/files/sector-fuels/wcc-aficc-
mhd-plan-highlights-2020-05-19.pdf

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 Phase 2: ERG MHD alternative fuel infrastructure survey for EPA Regions 9 and 10.
Sought information on potential MHD alternative fuel infrastructure projects in western
North America (including Arizona).
i. Project Page – https://westcoastcollaborative.org/workgroup/wkgrp-
fuels.htm#recommend

Phase 2 survey closed on 9/30/2021

i. See project summary materials attached (.pdf and .pptx).

Survey Data and Readiness Evaluation Method

i. See attached survey data obtained by the WCC AFICC from 2018-2021 regarding
investment needs for MHD-accessible alternative fuel station development (see .xlsx,
Tabs 2-3 for Arizona data).

ii. See attached Phase 2 survey form and project readiness evaluation methodology
(.docx).

iii. Note - We received a very robust submission from the Hydrogen Fuel Cell Partnership
for Class 8-accessible H2 stations. Most of these proposed sites are existing truck stops
and freight gateways/hubs, so additional alternative fuels could be located there as well
(e.g., EVSE).

I hope that you find this information useful for informing your ongoing work to support
ZEV infrastructure deployment throughout Arizona.

Again, please let me know if you have additional questions, would like to schedule a ADOT
staff briefing on the WCC AFICC project, and/or if ADOT staff would like to participate in
the WCC AFICC Steering Team moving forward.
40 7/22/2023 So who pays for this? Does it come out of the funds that are charged via the gasoline tax?
It seems to me the people that benefit (I.e.) electric vehicle owners) then they should
bear the burden of the cos to create this power grid, not the people driving traditional
gasoline powered vehicles. - Also who is buying the power to sell to these ev owners? Will
it be the companies that will be receiving revenue from the electric charging stations, or is
the state going to be the supplier and seller? Why should tax payers fund the
infrastructure for the income for these companies? Will there be a tax on the electricity
similar to the gas tax? The use the same roads, causing wear and tear just like the petrol
vehicles. And what is the state going to do about the disposal of the hazardous material in
the batteries when they have to be disposed of? Will there be a tax on that as well? How
about who provides the fire fighting services when one of these cars catching fire while
charging? Will the local agencies receive any financial support from the state for that?

E-35
 Table E - 2: E-mail Comments Received from 2023 Form
Note: Some comments have been edited to remove identifiable information.

# Date Time Area Message

Code
1 6/27/2023 4:35:22 PM 425 Hello, my name is [Name]. I'm calling from [Company]. We're
an electric vehicle charging infrastructure provider in Seattle,
Washington. We have some customers in Arizona, so we are
wondering about whether there is an RFP out for Arizona's
NEVI program yet and if so what are the upcoming deadlines
to apply for NEVI funding in Arizona. I'm referring to the
National Electric Vehicle Infrastructure program. We are very
curious what the upcoming deadlines are. So, please, do let
me know. Again, this is [Name] with [Company] and I can be
reached at [Phone Number], that's [Phone Number]. Thank
you and have a great day. Bye.
2 7/18/2023 2:45:09 PM 425 Hello, this is [Name] with [Company]. I am wondering if a
recording of tonight's meeting will be available for those who
were invited but cannot attend. Please let me know if the
recording will be available and, if yes, how I can access it. Feel
free to give me a call back here anytime. Again, I'm [Name]
with [Company]. My number is [Phone Number] or please do
feel free to follow up over email. I'm at [Email]. Thank you,
and have a great day. Bye.
3 7/20/2023 3:59:57 PM 480 Wow, this is kinda hard to get through, but hey! I'd like to
know more about the EV charging program you guys are
working on. I got an email like two hours before the program
and I'm trying to get caught up so I could not attend the
online program, if it was on Zoom, because there's like two
hours ahead of time. I didn't check my email. Anyhow, my
name is [Name], [Email] - I'd sure like to know what's going on
and I'm trying to find out. Please call me if you can help me.
Thank you. Bye.
4 7/24/2023 6:19:07 PM 928 Hi my name is [Name], I'm calling from Lake Havasu City City
Managers Department. We have some questions about this
proposal that's coming out from ADOT and phase 2. If you
could, please call me back. My phone number is [Phone
Number]. Thank you.
5 7/25/2023 11:03:41 AM 928 Hey, good morning. I just read the article in the Daily Courier
up here in Preston about charging stations. There's nothing in
the article that says how much it's gonna cost these folks to
charge their vehicle. I hope it's not free. Once again it's a case
of the haves versus the have-nots. If you can afford a $70,000
car, hey, great, but why should you get to drive it for free?
They don't pay road taxes, either. Anyway, that's my concern.
I'm getting nickeled and dimed by everybody. See you later,
bye.

Note: No comments were received by postal mail.

E-36
Endnotes

1 Alternative Fuel Corridors (AFCs) is an FHWA designation that support to deployment alternative fueling
infrastructure along highways.
2
ADOT. (n.d.) Fast Facts from ADOT. Retrieved from https://azdot.gov/fast-facts
3
IAP2 International Federation (2018). IAP2 Spectrum of Public Participation. Retrieved from
https://cdn.ymaws.com/www.iap2.org/resource/resmgr/pillars/Spectrum_8.5x11_Print.pdf
4
U.S. Department of Energy. (n.d.) Electric Vehicles. Alternative Fuels Data Center. Retrieved from
https://afdc.energy.gov/vehicles/electric.html.
5
U.S. Department of Energy. (n.d.) Vehicle Cost Calculator Assumptions and Methodology. Alternative Fuels Data
Center. Retrieved from https://afdc.energy.gov/calc/cost_calculator_methodology.html.
6
Electric Vehicle Database. (n.d.) Useable Battery Capacity of Full electric Vehicles. Retrieved July 22, 2022, from
https://ev-database.org/cheatsheet/useable-battery-capacity-electric-car
7
Office of Energy Efficiency and Renewable Energy. (n.d.) FOTW #1206, Oct 4, 2021: DOE Estimates That Electric
Vehicle Battery Pack Costs in 2021 Are 87% Lower than in 2008. Retrieved from
www.energy.gov/eere/vehicles/articles/fotw-1206-oct-4-2021-doe-estimates-electric-vehicle-battery-packcosts-
2021
8
ADOT. (n.d.) Fast Facts from ADOT. Retrieved from https://azdot.gov/fast-facts
9
Phoenix Commits to 100% Zero-Emission Bus Fleet by 2020 (December, 2022). Retrieved at
https://www.phoenix.gov/newsroom/district-7/2600.
10
Gallego and Stanton Announce $16 Million for Valley Metro to Improve Electric Bus Infrastructure (2022, August).
Retrieved from https://rubengallego.house.gov/media-center/press-releases/gallego-and-stanton-announce-16-
million-valley-metro-improve-electric.
11
The Future is Electric – Phoenix Celebrates First Electric School Bus. LCV. (2020, January). Retrieved from
https://www.lcv.org/article/future-electric-phoenix-celebrates-first-electric-school-bus/
12
Sun Tran rolls out GILLIG battery-electric bus. AzTA. (n.d.) Retrieved from https://www.azta.org/news/sun-tran-
starts-service-of-first-electric-bus
13
Mountain Line Zero-Emission Bus Implementation Plan. (2020, December). Retrieved from:
https://mountainline.az.gov/wp-content/uploads/2021/03/Phase-2-Implementation-FINAL.pdf
14
Alternative Fuel Corridors (AFCs) is an FHWA designation that support to deployment alternative fueling
infrastructure along highways.
15
Arizona Revised Statute §1-215.4. Retrieved from https://www.azleg.gov/ars/1/00215.htm
16
ADOT. (n.d.) Fast Facts from ADOT. Retrieved from https://azdot.gov/fast-facts
17
EV Market Share by State. EV Adoption. (n.d.) Retrieved from https://evadoption.com/ev-market-share/ev-
market-share-state/

113
18
Stockkamp, C.; Schäfer, J.; Millemann, J.A.; Heidenreich, S. (2021, October 2). Identifying Factors Associated with
Consumers’ Adoption of e-Mobility—A Systematic Literature Review. Sustainability 2021, 13, 10975.
Retrieved from https://doi.org/10.3390/su131910975.
19
Gas Prices. AAA. (n.d.) Retrieved from https://gasprices.aaa.com/.
20
Federal EV policy. Union of Concerned Scientists. (n.d.). Retrieved January 31, 2022, from
https://www.ucsusa.org/resources/federal-ev-policy.
21
New and used passenger car and light truck sales and leases. New and Used Passenger Car and Light Truck Sales
and Leases | Bureau of Transportation Statistics. (n.d.). Retrieved January 31, 2022, from
https://www.bts.gov/content/new-and-used-passenger-car-sales-and-leases-thousands-vehicles.
22
Arizona Statewide Transportation Electrification Plan (2019, December). Retrieved from
https://illumeadvising.com/files/Arizona-Phase-1-TE-Report-Final.pdf
23
Bauer, G.; Hsu, C.; Nicholas, M.; Lutsey, N. (2021, July). Charging up America: Assessing the growing need for U.S.
Charging Infrastructure through 20230. Retrieved January 31, 2022, from
https://theicct.org/sites/default/files/publications/charging-up-america-jul2021.pdf
24
The United States Government. (2021, August 5). Fact sheet: President Biden announces steps to drive American
leadership forward on clean cars and trucks. The White House. Retrieved January 31, 2022, from
https://www.whitehouse.gov/briefing-room/statements-releases/2021/08/05/fact-sheet-president-biden-
announces-steps-to-drive-american-leadership-forward-on-clean-cars-and-trucks/
25
The 2.1% growth rate is based on historical VMT trends and will fluctuate slightly from year to year.
26
Battery energy consumption refers to the energy consumption rate of the EV and accounts for propulsion, cabin
climate control, and other subsystems. It does not include losses during charging.
27
AAA Electric Vehicle Range Testing. AAA. (2019, February). Retrieved January 31, 2022, from
https://www.aaa.com/AAA/common/AAR/files/AAA-Electric-Vehicle-Range-Testing-Report.pdf
28
State of Arizona (2014, 2015). AZ Statutes 1-215 and 28-877
29
State of Arizona (2005). Arizona Revised Statutes 28-876
30
State of Arizona (2014, 2015). AZ Statutes 1-215 and 28-2416
31
State of Arizona (2018, 2005). AZ Statutes 49-542 and 49-542.05
32
State of Arizona (2014, 2015, 2015). AZ Statutes 1-215, 28-5805, and 28-5801
33
Take Charge AZ. APS. (n.d.) Retrieved from https://www.aps.com/en/About/Sustainability-and-
Innovation/Technology-and-Innovation/Electric-vehicles/Take-Charge-AZ.
34
Electric Vehicle (EV) Price Plan. SRP. (n.d.) Retrieved from
https://www.srpnet.com/prices/home/electricvehicle.aspx.
35
Electrification rebates. SRP (n.d.). Retrieved from https://www.srpnet.com/energy-savings-
rebates/business/rebates/electrification.

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36
Our EV Plan Gets Green Light. (Feb 2023). Retried from https://www.uesaz.com/news/our-ev-plan-gets-green-
light/#:~:text=As%20part%20of%20our%20plan,rebate%20for%20lower%20income%20customers.
37
U.S. Department of Homeland Security. (n.d.). Federal Flood Risk Management Standard. FEMA. Retrieved from
https://www.fema.gov/floodplain-management/intergovernmental/federal-flood-risk-management-standard
38
Arizona Commerce Authority. (n.d.). Demographics (Census Bureau Data). Retrieved from
https://www.azcommerce.com/oeo/population/demographics-census-data/
39
U.S. Department of Agriculture. (n.d.). Managing Semi-Arid Watersheds: Watershed Basics - Public Land
Management and Land Ownership in Arizona. Retrieved from
https://www.fs.fed.us/rm/boise/AWAE/labs/awae_flagstaff/watersheds/basics/management.html
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