The California Public Utilities Commission's recent approval of Southern California Edison’s Charge Ready 2 program is a big win for the future of transportation electrification and charging infrastructure. Last month, the $436 million program was given the green light to deploy 38,000 electric vehicle charging stations throughout Southern California Edison’s service territory-- an area encompassing 50,000 square miles. That will make it the nation’s largest light duty electric vehicle charging program operated by a utility to date.
The program includes three different categories of charging infrastructure investment, and requires that between 50% and 100% must be in disadvantaged communities. This approval represents a win for charging infrastructure efforts and accelerating climate goals in our state, but merely setting deployment targets in disadvantaged communities is not enough to ensure that residents who most urgently need access to charging infrastructure benefit from this type of investment. With the very real impacts a budget of this size can make on Southern California residents, the implementation of this program must be executed through an equitable process.
In addition to these set-asides, the California Public Utilities Commission also noted in their decision that it is, “looking at equity concerns and cost allocation principles with the TE rulemaking (R.18-12-006) and in its Draft Transportation Electrification Framework (TEF)...The equity chapter of the TEF discusses the barriers certain communities and customers face in electrifying transport and notes that utility TE investments must place a particular emphasis on removing those barriers.”
This means that the work does not end with the approval of Charge Ready 2 -- the CPUC must bolster equity guidance in the Transportation Electrification Framework which is currently under review and set for approval by the end of 2020. The Greenlining Institute provided public comments with detailed guidance to the CPUC on incorporating equity in the TEF in order to actively remove said barriers and create true access to TE investments.
Now, the CPUC must prioritize equitable implementation of not only Charge Ready 2 but all future charging infrastructure investment programs through thoughtful direction and a commitment to the practice of equity. Residents of disadvantaged and frontline communities are most severely impacted by poverty and pollution and therefore must be most invested in with time, resources, technical assistance and care, not just funding. Equity is not only a value; it requires actionable steps to make it real.
Now more than ever, equity must be at the core of our transportation electrification strategy. With Governor Newsom’s recent Executive Order which set a goal of ending new sales of internal combustion engine vehicles in 15 years, access to charging will be critical to making this goal feasible, and we must ensure EV charging is easily accessible and affordable to all communities and income levels. Given California’s state climate and transportation goals and upcoming election, we can no longer waste any time repeating mistakes from our inequitable past or be doomed to live under harmful policies. As the procedural schedule for this rulemaking comes to a close, CPUC should commit to the practice of equity in all the avenues of power that are within reach.
Measuring for Equity in Charging Infrastructure
One way to ensure charging infrastructure is accessible to all is by using data that can better measure this goal. Utilities have a wealth of knowledge and data from current programs in particular could play a big role in how we target our state’s transportation electrification resources. Utility companies currently have invaluable information regarding equity from charging infrastructure programs that include equity commitments. This data should be used to inform deployment strategies, best practices and lessons learned to further improve investment in our state’s disadvantaged communities. In addition, we must consider emerging data sets that speak to relevant deployment, public health, diversity, land use and climate change. That means looking at things like COVID-19 data and the potential of Prop. 16 for more race-conscious analysis, as well as land use, zoning, demographic trends and climate change data such as sea level rise, and information on flood and fire risks.
Establishment of an Internal CPUC Office of Racial Equity
Another strategy to ensure charging infrastructure is race conscious is through the establishment of an office or team dedicated to advancing racial equity to counteract historic, deliberate disinvestment in communities of color, empowered to actively work to dismantle unjust systems disenfranchising Black, Brown and Indigenous communities with high levels of pollution and poverty. The legacy of American racism has been upheld on the premise that Black, Brown and Indigenous bodies are collateral damage for maintaining the status quo and prosperity of White individuals. This legacy has continued a racist hegemony that has actively produced racist policies. In order to undo this legacy the CPUC must play its part in actively combating racist policies, with anti-racist policies as antidote.
EV charging infrastructure may seem to be about plugs and charging stations, but we can use it as a tool for righting historical wrongs and making sure that we all have access to clean transportation and cleaner air.
Leslie Aguayo is Greenlining’s Environmental Equity Program Manager. Follow her on Twitter.