Electric utility investment in underserved communities has more than doubled since the end of 2019. This surge was driven by two major approvals in 2020, one for Southern California Edison and another spread across six of the seven investor-owned utilities in New York. The increasing allocation of investment to underserved communities signals a recognition by commissioners in leading EV markets that utilities are well-positioned to provide critical investment in markets where charging service providers and other private sector entities do not always reach.
State legislators in leading EV markets have also been supportive of the role of utilities in ensuring equitable access to the benefits of transportation electrification. In October 2020, California lawmakers enacted Assembly Bill 841 directing utilities to invest in make-ready upgrades allowing for lower cost charging infrastructure rollout. The bill requires that 35 percent of utility investment in this effort be directed to communities facing the heaviest air pollution and poverty burden. Industry associations including the Smart Electric Power Alliance continue to highlight utility investment in low-income and marginalized communities as part of the “best practices” approach to EV program design and implementation.
The urgency and opportunity for utilities to support underserved communities has only increased throughout the COVID-19 pandemic. EVNoire co-founder Dr. Shelley Francis has highlighted the disproportionate burden of the pandemic borne by communities of color throughout the country. These same communities also face increased exposure to air pollution, a factor that leads to increased mortality rates from the coronavirus according to a series of studies published this year by researchers at the Harvard T.H. Chan School of Public Health. The connections between air pollution, race, and the pandemic have led Dr. Francis and others to point to EV investment as an important vehicle for environmental justice during the COVID era.
Encouragement from leading environmental groups and associations has helped lead to electric utilities are stepping up their commitments to underserved communities. This update follows the first data story on equity investments in electric utility filings we published in December 2019 with the support of the Natural Resources Defense Council (NRDC). To track these equity elements, we used the Greenlining Institute’s Mobility Equity Framework as a guide and developed several indicators to classify and track the equity commitments of different utility transportation electrification programs. A program is considered equitable to varying degrees if it aims to ensure that underserved communities benefit from a program as opposed to only pursuing an economically efficient outcome. While this includes an assessment of investment committed to underserved communities, it also looks to Greenlining’s focus on community empowerment. In this sense, we track equity goals, requirements to invest a certain amount of funds in underserved communities, labor requirements, public reporting requirements, and engagement with underserved communities.
To date, 56 out of the 131 programs tracked on the EV Hub include an equity goal in at least one element of the program. As a reminder, a program only needs one element proposing to at least prioritize investment in underserved communities to be classified as including an equity goal. A deeper look at investment pledged directly to these groups reveals that at least 28 percent of the total approved utility investment in transportation electrification projects is designated for underserved communities. This is an increase of three percentage points over the amount calculated in last year’s tally. Table 1 summarizes total program investment and investment dedicated to underserved communities in each approved program based on information available through November 2020.
Table 1: Approved Utility Programs Including a Transportation Equity Element Through November 2020
|Utility||State||Total Program Investment||Dedicated Investment|
|Southern California Edison||California||$825 M||$392 M|
|Pacific Gas and Electric||California||$348 M||$92 M|
|San Diego Gas and Electric||California||$294 M||$89 M|
|Con Edison||New York||$237 M||$47 M|
|National Grid||New York||$117 M||$23 M|
|New York Utility EJ Grants||New York||$85 M||$85 M|
|New York State Electric and Gas||New York||$64 M||$13 M|
|Rochester Gas and Electric||New York||$32 M||$6.5 M|
|Central Hudson||New York||$21 M||$4.2 M|
|Orange and Rockland Utilities||New York||$19 M||$3.8 M|
|Eversource||Massachusetts||$45 M||$4.5 M|
|Portland General Electric||Oregon||$2.6 M||$2.6 M|
|All Other Utilities||California, Florida, Maryland, Massachusetts, Ohio, Pennsylvania, Washington||$28 M||$3.4 M|
|TOTAL||$2.12 B||$766 M|
This table summarizes potential utility investment in underserved communities through November 2020. California leads with more than 75 percent of approved investment dedicated to underserved communities. The dedicated investment, which is roughly 36 percent of the total approved funding, was estimated based on information from individual utility filing documents. “New York utility EJ Grants” refers to competitive environmental justice grants that could be awarded in any utility service area in the state as a part of the make-ready approval in July 2020.
Source: EV Hub Utility Filing Dashboard
Utilities around the country outline equity goals in different ways and California and New York lead in both total approved utility investment as well as investments designated for underserved communities. Both New York and California states have also implemented specific definitions for disadvantaged communities with clear targets to ensure these groups benefit from EV programs. The Utility Filings Dashboard uses the term underserved communities to capture more general utility efforts across the country. The two states account for the surge in equity-focused investment in 2020.
In July, the New York Public Service Commission approved a total of $701 million for the Electric Vehicle Supply Equipment and Infrastructure Program, with approximately $200 million dedicated to support investments in underserved communities. The order approved $600 million of make-ready investments supporting 53,000 Level 2 and 1,500 DC fast charging stations and designated 20 percent of this investment for disadvantaged communities. In addition, the order established $85 million in competitive grants for environmental justice projects to be administered by the New York State Energy and Research Development Authority. These competitive grants include funding for medium- and heavy-duty electrification.
In August, shortly after the New York approval, the California Public Utilities Commission approved Southern California Edison’s Charge Ready 2 program. In the $436 million approval order, the commission stipulated that the utility increase the proportion of investment in disadvantaged communities from the initially proposed 30 percent to 50 percent. This further increased Southern California Edison’s lead over the rest of the field and the company now accounts for half of the nation’s direct utility transportation electrification investment in underserved communities. However even with the Charge Ready 2 approval, California’s share of direct investment is down by 15 percent from our last report due to the commitments made in New York. Together, the approvals in California and New York account for more than 92 percent of the approved investment in 2020 and all of the direct investment in underserved communities this year.
The only programs included in the table above are those that require all or a certain percentage of investment in underserved communities. This excludes the programs with less concrete goals that indicate a prioritization of marginalized groups in the rollout of programs. One such program approved in 2020 is Duke Energy’s flagship transportation electrification pilot in North Carolina. The November approval included more than $1 million for charging station deployment for multi-unit dwellings that will prioritize buildings housing underserved communities throughout the state. Out of the $76 million initially proposed by the utility, only $25 million was approved in this round. The commission directed the utility to redesign other program elements and collaborate with regional stakeholders on the remaining elements of the pilot. This move could lead to an increase in the funding dedicated to underserved communities.
Utility investment in transportation electrification can also help in providing economic recovery from COVID-19. Minnesota utility, Xcel Energy’s COVID-19 stimulus plan is the largest program still pending a Commission decision that was filed this year and the program includes a specific focus on supporting minority-owned businesses. This is a slightly different approach from the typical equity programs which overwhelmingly focus on designating investment to underserved communities. Of the 56 filings with equity goals specified in at least one program element, only two include language focused on businesses owned by marginalized groups. Just over half require that underserved communities are directly engaged in the design and implementation of the program.
With the major New York and California programs approved, there will likely be less new investment in underserved communities in 2021 than the $765 million that was approved in 2020. Overall, there is $362 million in pending utility program elements that indicate some level of prioritization of underserved communities. Even if all of these proposals were to be approved and allocated to underserved communities, 2021 would still have less approved funding for underserved communities than 2020. The $362 million proposed investment would be distributed outside of California and New York with utilities in Minnesota, Colorado, and New Jersey accounting for most pending funds. All of these programs include some focus on medium- and heavy- duty vehicles operating in underserved communities. Since emissions from medium- and heavy- duty vehicles disproportionately burden underserved communities, these pending programs indicate likely future support for providing indirect air quality benefits to marginalized groups with the goal of supporting environmental justice in these communities.
With a majority of pending funding now approved, there will be increased attention given to lessons learned as utilities implement large-budget programs with underserved community targets. One way to track this next phase of engagement is through the regular public reports required in more than 74 percent of all approved programs. Initial reports from some of the California programs approved in 2018 reveal that underserved community investment and engagement increased during program rollout compared to what was ordered in the approval. We will focus on these reports in 2021, including new metrics on how utilities are living up to their equity goals. As indicated in the Mobility Equity Framework, there are substantial ways utilities can expand their engagement with underserved customers to provide not only investment but also education and outreach to ensure underserved communities are at the table and first in line as transportation electrification programs are rolled out throughout the country.