March 16, 2026
Sean McMaster
Administrator
Federal Highway Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
RE: Notice of Proposed Modification of the Waiver of Buy America Requirements for Electric Vehicle Chargers
Docket No. FHWA-2025-0070
Administrator McMaster:
On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Highway Administration’s (FHWA) proposal to modify its existing waiver of Buy America requirements for electric vehicle (EV) chargers. As America’s largest transportation labor federation, TTD represents unions whose members work in all modes of transportation, including those in construction and manufacturing who are directly impacted by Buy America policies. TTD and our affiliates have long embraced the principle that a strong transportation system and strong manufacturing sector are intrinsically linked. To ensure that investments in our nation’s infrastructure will sustain domestic manufacturing and the millions of jobs it supports, we have consistently advocated for the inclusion of strong Buy America policies in federal transportation infrastructure investments.
The FHWA is seeking comment on whether it should modify its existing waiver of Buy America requirements to increase the cost threshold of components manufactured in the United States for EV chargers used in Federal-aid highway projects from 55 percent to up to 100 percent of the cost of all components.
We appreciate that the FHWA’s current waiver implemented a phased Buy America approach for EV chargers. This framework has driven significant U.S. manufacturing investment and job creation by providing clear, predictable market signals. Following the implementation of FHWA’s previous waiver, nearly a dozen electric vehicle charging manufacturing facilities began production in the United States.[1] The EV charger manufacturing sector supports and maintains good union jobs, and growth in this industry must continue.
In order to protect these important gains, we encourage the FHWA to exercise caution when raising domestic content requirements. While the FHWA has the authority to increase domestic content above 55%, doing so should be gradual, market‑informed, and paired with sustained funding to avoid waiver spikes and deployment delays. Without a carefully designed approach that supports the expansion of domestic production capacity, this proposal could undermine the very manufacturing growth it seeks to promote. Ambitious domestic content thresholds are essential, but to be beneficial, these requirements must be based on current and future market capabilities.
We appreciate the opportunity to comment on this proposal and look forward to working with the FHWA in the future.
Sincerely,
Greg Regan
President
[1] https://www.the-big-green-machine.com/