Navigating NEVI: How States Can Deliver a Reliable EV Charging Network

After three years of shifting federal priorities, court rulings and evolving directives, the $5 billion National Electric Vehicle Infrastructure (NEVI) Formula Program is entering a new phase defined by greater flexibility for states but also greater responsibility.

NEVI still aims to build the first nationwide fast-charging network, but the latest federal guidance places much of the structure, decision-making and accountability squarely on state departments of transportation (DOTs). Their success requires clear governance, proactive coordination and consistent performance tracking.

How has the NEVI program changed, and what new responsibilities do states now carry?

The Federal Highway Administration’s revised Interim Final Guidance (August 2025) reflects three major shifts:

• A narrower, statute-driven focus. Requirements tied to climate change mitigation goals, renewable integration, workforce standards and equity inclusion have been scaled back. Justice40 still applies, but with broader state interpretation.
• More flexibility paired with more responsibility. The guidance reduces procedural expectations but reinforces that technical compliance with 23 CFR 680 remains mandatory. With more discretion in solicitations, site selection and partnership structures, states must now implement stronger governance frameworks so that decisions remain consistent, transparent and defensible to federal oversight bodies.

• Pressure to accelerate deployment. The federal emphasis is clear: Get chargers deployed faster. For state teams already balancing procurement, utility coordination and contracting, this raises expectations while compressing timelines.

   

What do effective NEVI programs have in common today?

NEVI is more flexible, but also more demanding. For states to make the best use of NEVI funding, five elements are especially important.

1. Clear governance and defined roles

With reduced federal direction, states must take ownership of program governance. This begins with clearly establishing who holds decision authority, how program management is structured and what roles energy, environmental and transportation agencies will play in implementation.

Predictable processes for coordination with public utility commissions, engaging electric utilities and consulting regional, local and tribal partners throughout planning and deployment will be important.

When these roles and expectations are explicit, states are better positioned to navigate questions or disputes that emerge over multiyear infrastructure investments.

2. High-level, data-informed prioritization

Planning remains essential, but the federal government will not prescribe how states must conduct it. State DOTs must make decisions about corridor priorities, how far apart stations should be spaced, feasibility screening and reliability expectations over a five-year performance horizon.

External tools and partners can provide critical support, but states will need to set clear, data-informed prioritization frameworks to support fairness, transparency, long-term reliability and resilience across the network. 

3. Procurement that ensures long-term reliability

Given NEVI’s requirement that stations remain reliable for a decade or more, strong procurement solicitations should define expectations and evaluation criteria precisely, emphasizing reliability and long-term operations. Transparent scoring processes should stand up to audit and public scrutiny.

Reliability requirements, including uptime performance standards, corrective action mechanisms and data-sharing protocols, should be embedded from the outset to reduce the risk of non-performing awards. 

4. Proactive and consistent utility coordination

Interconnection is the biggest schedule risk for NEVI projects. Successful state programs will engage utilities early, use standardized or templated processes for identifying hosting capacity and work with utility partners to align on expectations for make-ready investments.

Equally important, states should establish predictable communication channels and project-tracking processes that give utilities clear visibility into timelines and program priorities. Early and consistent utility engagement prevents the multi-month delays that characterized many states’ early rounds of NEVI implementation. 

5. Performance tracking and program adaptability

NEVI’s performance and reporting obligations remain substantial. States must collect station performance data, ensure transparent pricing, submit annual updates and monitor uptime across the network. Programs that invest in strong data systems and feedback loops are better able to adjust program requirements based on actual performance and market conditions to maintain a reliable charging network over the long term. 

CSE’s Caret® EV Charging Knowledgebase is being used by leading states and utilities to securely aggregate, standardize and analyze anonymized charger session data to understand how, when and where EV charging happens and provide ongoing reporting.

What should states focus on moving forward with NEVI?

EV drivers expect stations that are reliable and widely available. State officials want investments that last. NEVI can meet both expectations and be successful if states adapt to greater flexibility and increased responsibilities.

With strong governance, clear processes and disciplined execution, states can deliver a national fast-charging network that meets public expectations, withstands federal scrutiny and remains reliable for years to come.

CSE will be exploring more facets of NEVI implementation in a series of articles over the coming months. 

State DOTs can explore CSE’s NEVI Playbook, a practical guide informed by CSE’s experience administering large-scale state EV infrastructure programs.

For help with EVI deployment, contact CSE at consult@energycenter.org.