Chapter 6. Funding Charging Infrastructure

As identified in Chapter 3, there are several different EVSE ownership models that may be implemented based on airport contracting requirements, the use case being served, the operators’ appetite for risk and experience with EVs, funding availability, and other factors. The cost for charging infrastructure projects can vary dramatically based on the number and type of charging technologies, which may dictate the level of investment and ownership models that an airport chooses.

EVSE use case will be central to the selection of ownership approach:

• Public chargers, such as those serving TNCs and travelers, are expected to have high rates of usage and higher fees for dispensing of electricity than private chargers. Public charges are more likely to be owned and operated by EVSPs or other third parties.
• Private chargers, such as those serving eGSE or airport fleet vehicles, are more likely to be owned and operated by an airport due to dedicated vehicle charging with known utilization.

Airports may choose to work with a third party who will own and operate all charging across all use cases. Alternatively, at airport may wish to own all EVSE across the airport to control charger O&M, the setting of fees and increase the revenue generation potential. It is likely that many airports will employ both ownership approaches will be employed, depending on the use case. Ownership models are detailed in Who owns and operates charging infrastructure?

What federal funding sources are available?

Airport operators should understand what grants and incentives may be available through federal, state, and utility programs that may reduce the capital costs associated with EV and EVSE procurement and electrical system infrastructure upgrades. Available funding programs may also offer technical assistance that can help with site design, workforce training, utility coordination, and overall project implementation. Many EVSPs and other partners also offer services to help guide customers through incentive programs, which may be of particular interest to small airports with limited financial and labor resources.

Federal Funding

A summary of key federal funding programs that may be applicable to EV and infrastructure deployment at airports can be found in Table 8. A summary of federal tax credits relevant to procurement of EVs and charging infrastructure can be found in

Table 8. Key Federal Grant Programs Relevant to Electric Vehicle Infrastructure at Airports

Table 9. Key Federal Tax Incentives for EVs and Charging Infrastructure

There are several requirements for federal grants that airports should consider when planning charging infrastructure projects and pursuing federal monies. During the planning phase, airports should be prepared to undergo the NEPA Review Process for their projects.⁶³ NEPA requires environmental impact analyses of proposed projects that are federally funded. The environmental review process must be completed before a project commences. However, most projects would likely fall under a categorical exclusion and not require further NEPA consideration. VALE and ZEV funding have traditionally been prioritized to airports located in EPA-designated nonattainment zones.

During the planning phase of a project, airports should also consider placement and purpose of charging infrastructure. For example, many airports operate shuttle buses for transporting passengers and employees around the airport from parking facilities to terminal buildings or other airport facilities. Airports should consider the operation-ownership model they currently have in place or may pursue

when looking to install charging infrastructure for electric shuttle buses. Airports often contract out shuttle bus services to a third party, and contractors may operate facilities on non-airport-owned property. Grant assurances stipulate that federally financed infrastructure must be built on airport-owned property. Airports looking to install charging infrastructure at contractor-owned bus depots and maintenance facilities would not be eligible for federal funding.

In the procurement phase of a project, there are other applicable requirements tied to federally funded projects. The Davis-Bacon and Related Acts⁶⁴ applies to federally funded projects more than $2,000 for construction. Under this act, contactors installing charging infrastructure must pay local prevailing wages, as set by the Department of Labor. Purchased equipment must also meet the provisions of the Build America Buy America Act.⁶⁵ This act, which was enacted as part of the IIJA on November 15, 2021, established a domestic content procurement preference for all federal financial assistance obligated for infrastructure projects after May 14, 2022. The domestic content procurement preference requires that all iron, steel, manufactured products, and construction materials used in covered infrastructure projects are produced in the United States. Specifically for FAA funding, the Buy American Preferences⁶⁶ requires that all steel and manufactured goods used in Airport Improvement Program (AIP) funded projects be produced in the United States. There are certain instances in which the federal government may waive these Buy American Preferences.⁶⁷ These are:

• Applying the Buy American Preferences would be inconsistent with the public interest
• The steel or goods produced in the United States are not produced in a sufficient and reasonably available amount or are not of a satisfactory quality
• The cost of components and subcomponents produced in the United States is more than 60% of the cost of all components of the facility or equipment procured and final assembly will occur in the United States
• Including domestic material will increase the cost of the overall project by more than 25%

The FAA maintains a list of nationwide waivers that have been issued on its website.⁶⁸ Airports should work with funding agencies to understand current waivers and to navigate the waiver process for the Buy American requirements applicable to the specific project. Procurement documents should communicate prevailing wages; Buy American requirements; and any other local, state, or federal requirements to prospective vendors and contractors.

Over the course of the project and for a certain time after installation, there are recordkeeping and reporting requirements for federal funding.⁶⁹ State funding apparatuses also likely have recordkeeping and reporting requirements. Quarterly and annual reports are typically required over the course of the project. Airport sponsors are required to provide financial and performance reports, including information on purchase and maintenance costs, maintenance records, emissions, and emissions reductions. Airports may be required to keep records pertaining to financial information such as invoices and canceled checks, procurement information such as contracts and purchase orders, administrative information such as grant applications and agreements, and project information such as drawings and reports for up to three years after the final payment. Projects receiving federal funding are also subject to federal audit requirements.

Several funding mechanisms have been used to replace older diesel equipment, such as the federal Diesel Emissions Reduction Act (DERA) grants, DERA grants administered by the states, and Volkswagen Mitigation funds administered by the states. Some of these grants and funds also require that the diesel equipment be decommissioned, by scrapping the equipment or permanently disabling the engine. Federally funded equipment is also required to be kept on airport property for the duration of its life, with few exceptions, such as vehicle servicing, as outlined by the FAA’s ZEV guidance.⁷⁰

State Funding

The availability of funding programs for charging infrastructure at airports varies by state. However, there are several federal programs with state allocations, including state-administered DERA grants and Volkswagen Environmental Mitigation Trust funds. In addition, the Federal Highway Administration is administering the NEVI Program,⁷¹ funded through the 2021 IIJA. The NEVI Program has a state allocation, as well as the federal Formula Program to develop a nationwide network of charging infrastructure. A full list of state-level funding for EV and charging infrastructure is available in several locations such as the DOE’s Alternative Fuels Data Center⁷² and third-party organizations like Electrek.⁷³

Utility Funding

There are significant grant, rebate, and incentive programs available from utilities across the United States. One of the largest and most common types of utility funding are Make Ready programs, in which utilities will pay for some or all the electrical improvements needed to support charging at a property, including (in some programs) BTM components like electrical panels, conduit, trenching, and other items. These incentives typically do not include funds for EVSE hardware. Other utilities may provide specific grants or other incentives for the procurement or installation of EVSE. Examples of utility programs can be found in Table 10. Note that this is not an exhaustive list: a full inventory of utility incentive programs can be found in an online article by Electrek.⁷⁴

Table 10. Examples of Utility Incentive Programs