States are resuming their National Electric Vehicle Infrastructure (NEVI) programs, and several are doing so with newfound flexibility as they achieve “fully built out” (FBO) certification—a new status that unlocks funding for rural communities, secondary highways, and other destinations charging beyond major corridors. This change is thanks to updated guidance released August 2025 from the U.S. Department of Transportation that says states no longer have to follow the strict 50-mile spacing requirements along designated highways if they submit a letter with reasonable justification to the Federal Highway Administration (FHWA) for approval.
Source: PennDOT
Pennsylvania was the nation’s second FBO-certified state, exemplifying a new era of strategic charging deployment by dedicating its remaining $102 million across three targeted programs—Corridor Connections, Community Charging, and Critical Investments—for both direct current fast chargers (DCFC) and level 2 (L2) stations. Seven other FBO states (Michigan, Rhode Island, Ohio, North Carolina, Vermont, Utah, and Wyoming) are navigating how to best utilize excess discretionary funding to address charging deserts.
Still, significant challenges persist for many states. Utility grid capacity, permitting bottlenecks, interconnection delays, zoning obstacles, and limited administrative capacity continue to delay progress even with simplified federal requirements. Meanwhile, states like Arizona are awaiting an additional alternative fuel corridor (AFC) nomination round to close remaining corridor gaps. Hawaii faces unique costs that are expected to consume its entire allocation on designated highway projects alone.
The streamlined certification process is impactful, but it doesn’t eliminate the complex on-the-ground realities of building a nationwide charging network. States should continue to identify opportunities for discretionary fund use that meet growing consumer demand, align with state priorities, and allow for the dream road trip.
Here are the Electrification Coalition’s recommendations for how states can best utilize excess NEVI discretionary funding once they have built our charging infrastructure along their designated highways:
1. States should consider investing in medium- and heavy-duty charging infrastructure and upgrading existing charging stations.
As medium- and heavy-duty electric vehicles (MHDEVs) gain momentum through supportive policies and increased investment, states have a critical opportunity to build MHDEV infrastructure and upgrade existing charging stations to meet surging demand. Priority should be given to freight activity hotspots (especially those designated by the Federal Highway Administration), regions where electric freight operations are already emerging or planned for deployment, and key freight hubs outlined in the National Zero-Emission Freight Corridor Strategy. These regions can be seen on the Electrification Coalition’s Electric Freight Dashboard.
Outside of freight corridors, states should identify strategic charging locations that would enable longer-distance travel for electric school buses, enable tourism by catering to electric RVs, and support local delivery performed by cargo vans. We recommend states also consider upgrading existing stations with MHDEV-compatible chargers and pull-through designs can accommodate these larger vehicles while maximizing infrastructure investments.
This proactive approach positions states as leaders in the MHDEV transition while creating jobs and bringing cost-savings to school districts, businesses, and residents.
2. States should work with municipalities to install public charging stations in high density areas with multi-unit dwellings.
Many city governments have introduced sustainability plans that encourage local EV adoption; charging infrastructure must be deployed to support these transitions. States should work with local officials to expand charging access for non-single-family homeowners and residents with no access to garages, such as those residing in multi-unit dwellings (MUDs). About 31% of U.S. households live in MUDs where EV charging is limited, and 75% of these households own vehicles. A lack of accessible charging hinders EV adoption among this demographic.
EV charging in parking garage.
Source: EC staff.
While challenges exist surrounding the establishment and operation of charging in MUD parking (private, owned, or leased), states should establish eligibility criteria that meet public charging access requirements and dedicate a specific percentage of funding towards these projects. MUD charging plans should consider the number of parking spaces available and an appropriate ratio of DCFC ports to L2 ports, especially in high-density residences that lack access to reliable charging stations. DCFC can offer a convenient re-fueling option for travelers, a secondary option for community members in need of a quick charge, and increased revenue potential for nearby businesses.
3. States should work with state and municipal agencies overseeing fleet electrification to expand fleet and workplace charging opportunities.
Many states are electrifying their fleets to meet state/inter-agency sustainability goals and leverage the cost-savings EVs offer. However, building out the charging infrastructure needed to support electric fleets remains a barrier for many agencies, often due to funding constraints.
States should work across agencies to identify charging needs for both state fleets and EVs owned by personnel, enabling workplace charging. Charging can be located near state-owned buildings or in designated parking lots that also allow for public use. As with MUD charging, states should consider a combination of DCFC and L2 ports and ensure that the sites are future-proofed with electric capacity.
4. States should continue to deploy charging infrastructure at retail sites.
Most NEVI awards have been allotted to gas stations (250), truck stops (210) and convenience stores (109). This is because NEVI requires sites to be accessible 24/7 and offer nearby amenities like restrooms and Wi-Fi. States should consider continuing to expand chargers at gas stations outside of alternative fuel corridors and at other retail sites such as supermarkets, shopping centers, and restaurants. Many of these sites already have added capacity to support the installation of both DCFC and L2 charging infrastructure, requiring less investment.
61% of EV owners are more likely to shop at retailers with charging stations. IKEA and Whole Foods both offer EV charging, and are nearly twice as likely to attract traffic from EV owners compared to other shopping locations. Location and amenities, such as nearby restrooms, restaurants, and shops, are also a top priority for EV users. These perks play a key role in charging station use success.
While installing charging at major retail locations is important, states should ensure excess NEVI funding is distributed strategically and equitably. This should involve prioritizing funding for sites that need financial support for deployment, like small businesses. For larger retailers and gas stations, states should establish eligibility criteria that require a minimum cost-sharing amount and provide extra points to applicants offering higher cost-sharing. PennDOT, for example, established that no single site host or charging station operator can receive more than 25% of the total amount awarded in each funding round.
5. States should consider expanding charging deployment in national and state parks.
State and national parks are taking steps to open public EV charging stations, allowing drivers to explore nature as they refuel. There are over 140 chargers (DCFC and L2) in or near national parks across the country, from Yosemite in California to Biscayne in Florida. Yellowstone’s L2 chargers are located throughout the park at hotels, and in the gateways of West Yellowstone and Gardiner in Montana. One of the chargers in the park’s Mammoth area saw a 527% increase in use between 2017 and 2021.
NEVI station near Arches National Park, Utah.
Source: Joint Office of Energy and Transportation.
National and State Park Service lack the funding to meet growing demand. Consequently, parks have relied on external funding sources to install charging infrastructure—BMW sponsored 100 stations at various parks (2017-2019), and Yellowstone secured a Department of Energy grant to install chargers (2015-2018).
States should work with national and state park officials to identify which parks attract the most people and where charging can be built nearby so that it is accessible and easy to find. Additionally, states should prioritize DCFC stations for road trippers on the go, while integrating some L2 ports for longer-term visitors like campers and hikers. States should also incorporate site design elements such as canopy coverage and lighting at these locations to ensure a safe and comfortable user experience. The chargers can ultimately help drive revenue for parks to build more chargers in the future and cover infrastructure update costs.
6. States should improve and streamline the application process.
States can reduce administrative costs and accelerate NEVI charging deployment by streamlining administrative processes like application proposals. For example, states should allow charging providers to apply for multiple sites through a single application, as this can help ensure charger reliability and maintenance, a prominent concern of EV drivers.
States should also establish a weighted evaluation criteria and scoring system that prioritizes applicants with proven track records, such as experienced site hosts and equipment suppliers with successful deployment histories. However, this system should also reserve a percentage of funding for emerging companies/technologies and rural projects with unavoidably higher costs. For rural projects, states should consider location as the key scoring criteria, prioritizing sites that close charging gaps and benefit local communities and rural businesses.
7. States should continue to follow federal minimum standards during post-AFC deployment.
To ensure consistent, high-quality charging infrastructure that serves all EV drivers effectively, states should continue to follow NEVI minimum standards, and maintaining 97% uptime to guarantee reliability.
Federal requirements also mandate essential interoperability and connectivity features that enable real-time data sharing across networks, open payment access through contactless cards without proprietary apps, and robust privacy protections. By maintaining these standards, states ensure their discretionary investments complement the foundational NEVI network rather than creating a fragmented charging landscape with inconsistent user experiences.
The Electrification Coalition is ready to help states and communities maximize this opportunity to accelerate transportation electrification through effective, efficient, and equitable deployment of federal funding. Contact us at infrastructure@electrificationcoalition.org to get plugged in to our resources.