Electric Vehicle Charging Infrastructure in Overburdened and Underserved Communities in The District of Columbia

By Tim Nau 

The transportation sector was responsible for the largest share of the United States’ greenhouse gas emissions in 2021 (28%). Promoting electric vehicles (“EV”) on the nation’s streets has been an important element of the United States’ strategy for meeting its ambitious goal of achieving a net-zero carbon economy by 2050.

Taking into consideration overburdened and underserved communities creates an important yet often undervalued perspective. This post will address the benefits of promoting equitable deployment of EV charging infrastructure in these communities in the District of Columbia (“DC” or the “District”) as well as the challenges associated with it, and present what has been done so far.

Fueling of EVs

EVs require new forms of fueling – their “fuel” is electricity. Different types of chargers serve different needs. Level 1 chargers can be plugged in from any standard 120V outlet directly into the EV and charge up to 5 miles of range per hour. Full charging requires a considerable amount of time – Level 1 chargers therefore are typically used for home charging overnight. Level 2 chargers require a 240V outlet (available at home) and charge between 10 and 80 miles of range per hour, on average 25 miles of range per hour. The exact charging speed is determined by multiple factors, e.g., the EV supply equipment, the wires and cords, and the EV itself. Because their cost is still reasonably low, Level 2 chargers are the most commonly used EV chargers, both in private and public settings. Direct Current Fast Chargers (“DCFC”) work with 400-900V outlets and charge up to 250 miles of range per hour. Therefore, they work best for long-distance traffic corridors where drivers take only short breaks, as well as fast charging hubs for transportation network companies (e.g., Uber and Lyft) and public transportation fleets. Additionally, they can provide quick and full charging for EV drivers without a private charging station at home.

Equity Through EV Ownership and Charging Infrastructure

The increased electricity demand of more EVs necessitates adjustments to the electricity grid and a significant expansion of EV charging infrastructure. While progress in increasing the total number of charging stations is constantly made, installing a comprehensive EV charging infrastructure network equitably across the District of Columbia has proven to be a challenging task. Equity has at least three components: restorative equity to address past harms; procedural equity, which addresses full participation in decision-making and related processes; and distributive equity, which  considers the resulting distribution of benefits and burdens across groups.

The U.S. Department of Energy’s (“DOE”) interactive map on (public) EV charging station locations and the District’s Electric Vehicle Infrastructure Deployment Plan identify Wards 5, 7, and 8 in the District as “disadvantaged communities” based on multiple factors, including: high asthma rates, high mortality rates from cancer and heart disease, low income levels, and poorer access to transportation and jobs. Residents here are most vulnerable to and significantly impacted by air pollution. This is caused by, among other factors, the location of interstate highways and major commuter routes, such as Interstates 295 and 695, New York Avenue (Route 50), and Rhode Island Avenue (Route 1) running through or adjacent to these communities. In addition, some of the longest commuting times in DC originate in these communities, and residents that hold jobs that extend into non-rush hour periods often have few mass transit options.

The DOE’s and District’s framework for transportation planning referenced above reveal that the portions of DC’s Wards 7 and 8 east of the Anacostia River are virtually blank of public charging stations. Further, exclusive of the chargers on Joint Base Andrews, all but three of the Level 2 or DCFC public charging stations in Wards 7 and 8 are in areas that, until 2022, were parts of Ward 6. In Ward 5, the public chargers are clustered near its southern border, primarily in areas where big box stores are located or around the gentrified Union Market area. In contrast, in the wealthier Wards 2 and 3, public charging stations are spread along the major thoroughfares or at multifamily buildings, closer to where residents live. In other words, there is a failure of distributive equity.

A 2022 market study showed these same Wards have a significantly lower market penetration of EVs. Although the study addressed correlation, not causation, the strong correlation between low levels of EV ownership and high percentages of people of color, lower-incomes, and percentage of people in multi-family dwellings indicate the justness of, and necessity for, restorative equity measures in these Wards.

One method to accelerate the adoption of EVs in these Wards is to assure access to EV chargers. The deployment of EV charging infrastructure along major commuter routes and additional locations easily accessible within the community could facilitate the adoption of EVs by residents in these communities and commuters. The lower operational costs of an EV as compared to an internal combustion engine vehicle could also benefit low-income residents. Increased EV ownership could reduce tailpipe emissions from vehicles driven in and through these Wards, which in turn will improve air quality, relieve serious health concerns, and allow residents to equitably participate in modern, clean, and sustainable transportation. Promoting EV access in disadvantaged communities is therefore particularly desirable as it furthers restorative and distributive equity. Doing so requires an understanding of why development of the EV market in disadvantaged communities is lagging and what type of development is needed.

The Lack of and Need for Public EV Charging in Underserved Communities

EV ownership requires overcoming at least two obstacles – the upfront cost and the ability to charge. Until recently, federal and DC subsidy programs have focused largely on the purchase of new EVs and home chargers, purposefully jump-starting the EV market among middle- and high-income residents (“early adopters”). These tax credits and other financial incentives disregarded low-income, tribal, and other historically marginalized communities. 

The first obstacle is increasingly relieved – EVs are becoming more affordable. Now that EVs have been on the market for several years, a secondary (used car) market is developing, driving down the price. Additionally, the Inflation Reduction Act introduced a tax credit for taxpayers below a certain income threshold against the purchase price of a used vehicle.

The second obstacle, the ability to charge, is not as easily or automatically understood or relieved. Residents in disadvantaged communities face several challenges, beginning with the sheer nonexistence of EV chargers. Existing EV charging infrastructure largely aligns with early adopters of EVs – and thus is concentrated in wealthier Wards. It consists of both private and public chargers. 

Most EV drivers conveniently charge their car at home, via private (mostly Level 2) chargers connected with their house. However, residents in disadvantaged communities oftentimes do not have access to on-street parking in front of their house, or do not own garages or driveways and therefore cannot install private EV chargers at their homes. Multi-unit dwellings (“MUDs”), if they have any charging facilities at all, may accommodate several EV-driving residents but lack the availability of EV charging for all of them at convenient times. Even if residents are willing to and capable of purchasing and installing EV chargers, tenants often are not allowed to do so. Survey data indicates that 52-81% of EV driving residents in apartment buildings depend entirely on public charging. Additionally, for low-income residents, the price of installing Level 2 chargers may be cost-prohibitive. Because of this widespread inability to install private chargers at home, there is a need for public EV charging opportunities in these areas to support growing EV ownership by residents. This need is not yet met, as shown above.

The market penetration study referenced above found that although the disparity in access to Level 2 chargers was “slightly less pronounced” than the disparity in EV ownership, it was still evident. That is, there was still somewhat better access to Level 2 chargers in wealthier Wards. There was little difference in access to DCFC only because there are very few DCFC in the District. But the study merely correlated data; it did not project need. Determining the “right” amount of any particular type of EV charger in a Ward is more complex than achieving an equal number of dots on a map.

Importantly, charging also needs to be affordable. Comments filed in DC Public Service Commission (“Commission”) Formal Cases 1130 and 1155 by charging companies and lobbying organizations highlighted some of the economic disparities between those who can charge at home and those who must use commercial public chargers.

In particular, public Level 2 chargers are not comparable to home chargers. Unlike home charging at prices per kWh, public chargers often charge rates based on the amount of time the vehicle is plugged in, including a premium charge for remaining plugged in after charging is complete. Thus, they are not appropriate for overnight charging, unless the charger is both near the vehicle owner’s home and the vehicle owner is willing to get up in the middle of the night to move the vehicle. 

Additionally, the charging stations operated by private networks charge electricity prices that are generally above the rates charged by the electrical supplier in private homes. This again reinforces existing inequities because wealthier residents who charge in their driveway at home charge at lower prices than poorer residents who can only charge at public charging stations. Nevertheless, private charging companies like ChargePoint and EVgo argue for unregulated, competitive prices managed by the site host, instead of allowing the public utility to own and operate charging stations and the Commission to regulate its prices, keeping them at lower levels than currently.

For these reasons, the Electric Vehicle Association of Greater Washington, DC argues for reduced emphasis on Level 2 chargers and instead, greater accessibility to Level 1 chargers close to where people live and at prices per kWh.

These economic disparities must be considered when siting new public EV charging infrastructure. An equitable system must make charging points both accessible and affordable.

Pepco’s Proposal To the DC Public Service Commission

In 2018, the Potomac Electric Power Company (Pepco), the regulated public utility that provides distribution service and, at the customer’s option, electricity, to residents and businesses in DC, applied for approval of its Transportation Electrification Program with the Public Service Commission of DC. The Commission can approve, approve with modifications, or deny such an application. Pepco included different Offerings to promote the deployment of EV charging infrastructure throughout the District. The company proposed, inter alia, to install 35 smart Level 2 charging stations and 20 DCFCs throughout the District, at least 20% of which were to be located in Wards 5, 7 and 8. In 2019, these Offerings were generally approved – but the allocation of 20% of public chargers to Wards 5, 7 and 8 was rejected by the Commission “at this time.” Order No. 19898.

The Commission generally acknowledged Pepco’s role in expanding the EV charging infrastructure and, therefore, supports such investments by the utility. However, the Commission maintained that the record did not (yet) show that the competitive market was failing to provide adequate EV charging infrastructure in disadvantaged communities. After reconsideration, the Commission reiterated that there was no evidence that the demand for EV charging in Wards 5, 7, and 8 exceeded the supply in charging stations. Order No. 19983. The EV charging network was therefore found not to be inadequate. Consequently, the promotion of EV charging infrastructure in disadvantaged communities was left to free market logic. Unlike the DC Public Service Commission, in 2022, the California Public Utilities Commission mandated that 65% of the funds for transportation electrification in the State be dedicated to underserved communities. Decision 22-11-040.

Are EV Charging Companies The Solution?

Private EV charging companies construct and operate public EV charging stations where it makes sense economically. Often charging is co-located with other businesses or in parking garages, as an amenity for the customers (the public) and employees that frequent those locations. In DC’s Wards 7 and 8 east of the Anacostia River, in particular, few businesses offer charging as an amenity, and there is generally less demand for charging stations from EV owners, whose numbers are kept low, in part, by the lack of charging capability.

This circularity reinforces the lack of financial incentive for private charging companies to invest in a public EV charging infrastructure network in disadvantaged communities outside of commercial zones. Investments in commercial zones facilitate charging by residents or non-residents who will be making extended stops there. Since a full charge will take multiple hours, public Level 2 chargers in commercial areas work best for customers that only need “top off” charging during the time they are shopping, dining, or otherwise engaged, or employees who will be there for the number of hours needed for a full charge. Level 2 chargers at commercial locations are not conducive to overnight charging by residents, other than those residents who live near the commercial location. As noted above, it would also be important that they are not financially penalized for leaving a vehicle plugged-in overnight. This reveals fundamentally different needs than in wealthier communities where EV owners primarily charge at home. Thus, although the recent increase in accessibility to Level 2 chargers in lower-income areas is convenient for some existing EV drivers, it may not be sufficient to induce EV ownership among other residents in these areas. The private market is failing here (failure of distributive equity). The lack of adequate EV charging infrastructure discourages EV adoption in these areas altogether.

To overcome this “chicken-and-egg”-challenge, government policies for facilitating the deployment of an accessible, public charging network in underserved communities are crucial. Once the penetration of the market with EVs proceeds, more EV charging opportunities in these areas will be needed. Compared to affluent communities where residents mostly use private charging at home, many people in these areas will depend on public charging stations. Therefore, public charging stations must offer a mix of services including Level 1 and Level 2 chargers suitable (and affordable) for overnight charging or at locations where the vehicle owners may spend several hours, as well as DCFC stations. Reliance on public companies to meet this need will depend on whether private companies can fill the need and profit. However, at this moment, public policies and financial incentives to invest in EV purchases and charging infrastructure networks in underserved areas are needed.

Federal Programs and Justice40

Fortunately, a paradigm shift is occurring. Policymakers increasingly consider both the charging infrastructure and equity goals in conjunction. However, it remains to be seen whether this will meet the needs of DC’s disadvantaged communities or not.

The DC government developed a multi-year plan, starting in 2022, to deploy the $16,179,459 it is slated to receive from the Bipartisan Infrastructure Law (BIL). Another $3,335,892 will be required in matching funds, likely from private sources. Consistent with federal highway standards, the District has prioritized placements along five “Alternative Fuel Corridors” (AFC) with the initial funding. These corridors are largely the same major transportation routes that blight Wards 5, 7, and 8. Indeed, 54% of the miles of AFC in DC are in disadvantaged communities. Thus, ironically, most of the initial investment will flow to these underserved communities not for equity reasons per se, but rather because federal standards require the priority chargers to be placed along interstate highways and heavily trafficked routes to facilitate through traffic. Nevertheless, residents who live near these emissions-spewing corridors will be secondary beneficiaries of the new chargers. The District expects to complete the installation of these priority projects by the end of 2023. Pepco’s Offering 7, as approved by the Commission in 2019, is supporting this growth. 

The new Charging and Fueling Infrastructure Discretionary Grant Program, established by the BIL, opened for another round of applications in March 2023. It will provide $1.25 billion to fund the deployment of charging infrastructure in any publicly accessible location in communities and neighborhoods (Community Program). Priority shall be given to projects within low- and moderate-income neighborhoods and communities with a low ratio of private parking spaces to households or a high ratio of MUDs to single family homes. This prioritization mandate is a step towards ensuring that at least 40% of the benefits of certain federal investments flow to disadvantaged communities, as required by President Biden’s Executive Order 14008 and the Justice40-Initiative. 

In addition, DC law directs its Department of Transportation (“DDOT”) to install 15 public stations, with at least one per Ward; and requires newly constructed or renovated multifamily or commercial buildings to equip at least 20% of their total parking spaces with “make-ready” infrastructure, if the building has 3 or more off-street parking spaces. 

All Stakeholders Involved Should Actively Promote Equity

In the District, the extent to which progress is being made on the “chicken-and-egg”-challenge of building access to EVs in disadvantaged communities through improved access to charging points appears to be a by-product of a federal initiative to electrify major traffic corridors. However, future rounds of federal BIL funding will be available for other roads and penetration into the neighborhoods where people live, presenting yet another opportunity for the DDOT, the DC Public Service Commission and Pepco to work together to advance equity. Rather than focus on existing EV ownership as the Commission did in Order 19983, emphasis must be placed on proactively changing the circumstances so that demand for EVs may develop further and justify increased deployment of EV charging infrastructure. In this process, it will be crucial to perform outreach efforts, carefully listen to the community needs, and engage the community in decision-making. Residents know best where EV charging stations are or will be needed most. In other words, procedural equity is important to a just result. Also, cooperation with local businesses can strengthen the local economy and secure or create jobs. The Commission and DC businesses, including Pepco, should combine efforts to accelerate the electrification of transportation in Wards 5, 7, and 8, so that eventually, residents in disadvantaged communities may breathe cleaner air and participate in the benefits of modern, sustainable transportation.

Additional Sources:

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