U.S.: New federal strategy to develop zero-emission infrastructure along freight corridors

The 300-page Strategy, developed by the Joint Office of Energy and Transportation and Department of Energy (“DOE”), in collaboration with the Department of Transportation (“DOT”) and the Environmental Protection Agency (“EPA”), is designed to guide the deployment of zero-emission medium- and heavy-duty vehicle (“ZE-MHDV”) charging and hydrogen fueling infrastructure from 2024 to 2040 through a phased approach.  According to the Strategy’s “National Vision,” delivering ubiquitous and convenient access to electric vehicle (“EV”) charging and hydrogen refueling along our nation’s freight corridors, and at truck depots within freight hubs, is key to successfully deploying ZE-MHDVs. 

In addition to listing schedules and the specific freight hubs identified for the different phases of deployment, this Strategy lays out an all-of-government approach to aligning investments and accelerating sustainable and scalable deployment of reliable ZE-MHDV infrastructure.  Notably, a core objective of the Strategy is to meet freight truck and technology markets where they are today, determine where they are likely to develop next, and set an ambitious pathway that mobilizes actions to achieve decarbonization.  Therefore, the Strategy recognizes that last mile delivery vehicles and smaller trucks  (Class 4 through 6) are more likely to be the beneficiaries of this infrastructure development plan in the short term and the transition to zero-emission heavy-duty (e.g., Class 7 and 8) trucks is a longer term objective.  In an effort to achieve this overall objective, the Strategy is designed to address growing market demands by targeting public investment to (1) amplify private sector momentum; (2) focus utility and regulatory energy planning; (3) align industry activity; and (4) improve air quality in communities heavily impacted by diesel emissions.

Those four strategies – of aligning public policy and investments by prioritizing, sequencing, and accelerating infrastructure along the National Highway Freight Network (“NHFN”) – are designed to occur in four phases.  

Phase 1: Establish priority hubs based on freight volumes, from 2024 to 2027.  

Phase 2: Connect hubs along critical freight corridors by 2030. 

Phase 3: Expand corridor connections and initiate network development through 2035.  

Phase 4: Achieve a national network that links regional corridors for ubiquitous access by 2040.

Highlights for each phase include:

Phase 1: Establish priority hubs (2024-2027)

• Priority hubs will focus on states with regulations and market structures that encourage deployment of zero-emission vehicles (“ZEV”) , areas with EPA nonattainment status to accelerate environmental mitigation in disproportionately impacted communities, and facilities along corridors identified by the DOE Vehicle Technologies Office’s Fiscal Year 2022 MD/HD corridor planning projects.

• A total of 12,000 miles (23% of the NHFN) are identified as key zero-emission freight (“ZEF”) corridors, including I-5, I-10, I-25, I-75, I-80, I-95, and the Texas Triangle (I-10, I-45, and I-35).

• ZEF hubs include the 100-mile freight ecosystems centered around key ports, including but not limited to the Port Authority of New York and New Jersey, Ports of Long Beach and Los Angeles, Port of San Diego, Ports of Seattle and Tacoma, Port of Miami, Houston Port Authority, and Port of Savannah.

• Forty percent of the benefits stemming from the 898,000 square miles of ZEF hubs in Phase 1 are anticipated to flow to disadvantaged communities and represent the opportunity to decarbonize goods movement for more than 1 billion in total annual commodity tonnage. 

Phase 2: Connect hubs along critical freight corridors (2027–2030)

• The focus is on expanding prioritization of ZEF corridor segments to connect key ZEF hubs from Phase 1, prioritizing the connection of key ZEF hubs to support private market efforts to build out ZEF infrastructure along I-5, serving all ports along the West Coast, I-10 from California to Florida through the Southwest, major segments of I-95 on the East Coast, I-80 through the Midwest, and I-70 from Pittsburgh to St. Louis.

• Infrastructure buildout will begin to expand beyond states that have adopted California’s Advanced Clean Truck rule or have already taken proactive steps to plan for ZE-MHDV corridors. Non-tractor-trailer truck (e.g., Class 4–6 straight delivery trucks) activity will likely remain battery-EV-dominant, with early introduction of hydrogen fuel cell electric truck technology for longer-distance travel.

• Phase 2 also begins to see the construction and ramp-up of DOE’s Regional Clean Hydrogen Hubs. 

• Operations are to expand with increased regional goods distribution (e.g., port drayage) and initial deployments of long-haul transportation.

• This phase will prioritize 19,000 miles (36% of the NHFN) of ZEF corridors. 

Phase 3: Expand corridors connections and create a network (2030–2035)

• Facilities designated as ZEF hubs are expanded to include a larger percentage of ports and freight facilities (by annual commodity tonnage).

• Corridor connections are further expanded across the U.S. to reflect increased capacity to support point to point ZEF transportation along the entirety of I-80, I-95, I-10, and I-70, including access to charging and fueling to all coastal ports and their surrounding freight ecosystems for short-haul and regional operations.

• Both battery-electric and hydrogen fuel cell truck technology are included, with increased access to hydrogen refueling along freight corridors.

• A total of 37,000 miles (72% of the NHFN) of ZEF corridors are prioritized in this phase.  Forty-three percent of all benefits stemming from the 1.28 million square miles of ZEF hubs in Phase 3 are anticipated to flow to disadvantaged communities. ZEF hubs will represent the opportunity to decarbonize goods movement for more than 2 billion in total annual commodity tonnage. 

Phase 4: Achieve a national network (2035–2040)

• The  majority of the NHFN is prioritized to support expanded private investment that enables ubiquitous access to MHDV charging and hydrogen refueling along corridors east to west and north to south.

• Facilities in ZEF hubs expand from intermodal freight and port facilities to also include truck parking facilities, which will increasingly service ZE-MHDVs across all use cases.

• A fully integrated transportation energy system will be essential to supporting use cases across all vehicle classes and duty cycles, allowing for local, regional, and long-haul transportation of goods and services.

• By 2035, DOE Regional Clean Hydrogen Hubs will be in full production, serving critical regions with clean hydrogen transportation fuel and prioritizing 49,000 miles (94% of the NHFN) of ZEF corridors.

• Forty-seven percent of all benefits stemming from the 3.12 million square miles of ZEF hubs in Phase 4 are anticipated to flow to disadvantaged communities.  And the ZEF hubs will represent the opportunity to decarbonize goods movement for more than 2.3 billion in annual commodity tonnage.

Overall, the Strategy serves as a compass for public and private stakeholders to prioritize and guide investment, planning, and deployment of ZE-MHDV electric charging and hydrogen refueling infrastructure along the NHFN and complementary roadways.  Starting in favorable launch areas and with smaller trucks that will have lower total cost of ownership than existing internal combustion engine vehicles, that the phased development of electric charging and hydrogen refueling infrastructure will enable emerging markets to develop, expand, and fully transform overtime by 2040.

It is anticipated that federal and state governments, utilities and energy providers, fleets and technology providers, ports and freight logistics companies, and communities can implement the Strategy by doing the following:

• Targeting public investments. Government agencies will be able to incorporate the Strategy analysis into their own policy and program development. This “all-of-government” approach seeks to align federal and state investments by prioritizing funding decisions on projects that fall within the deployment areas defined in the Strategy. 

• Focusing on energy planning.  Energy markets and regulators will also be able to incorporate the Strategy into their systems-level planning and infrastructure needs assessments for the generation, transmission, and distribution of ZE-MHDV transportation fuel. 

• Aligning industry activity. On-road freight stakeholders, including MHDV original equipment manufacturers, fleet and depot operators, ports; logistics and warehouse industries, retail fuel providers, and charging and refueling manufacturers will benefit from greater transparency about national freight priorities and increased certainty in near-term, medium-term, and longterm investments, planning, and deployment. 

• Mobilizing communities for clean transportation. Communities seeking opportunities to promote ZEF transportation within their regions can use the Strategy to help advocate for the deployment of commercial ZE-MHDVs and infrastructure. 

• Fostering collaboration. By strategically allocating resources and fostering collaboration between public and private sectors, this initiative underscores the U.S. government’s dedication to fostering a cleaner, more efficient freight transportation system. 

For more information on the Strategy, please contact Mary Anne Sullivan, Senior Counsel, Earl Adams, Jr., Partner, Ed Fishman, Partner, or Stephanie Fishman, Associate