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Key Takeaways

• Difficulties in connecting charging sites to the grid pose the biggest delays in bringing publicly accessible EV charging stations online.
• Permitting delays still occur in some local jurisdictions despite new streamlining measures.
• Planning code updates may be needed to facilitate approvals of EV charging stations as the primary use of a site.
• Standardized reporting of permit turnaround times is needed to track the effectiveness of EV charging station streamlining legislation.

California made headlines in 2020 when it became the first in the world to prohibit the sale of new gasoline-powered cars in the state by 2035, a mandate that will put more than 15 million plug-in electric passenger vehicles on the road (Lopez, 2022; Davis et al., 2023). In 2023, zero emission vehicles (ZEVs) represented 25 percent of new vehicle sales in the state, or nearly 445,000 vehicles (California Energy Commission, 2024a).

Expanding this market requires a robust network of charging stations at homes and along public roadways. Widespread availability to charging is essential for boosting consumer confidence in electric vehicles and ensuring everyone has access to a charging station (Hickerson and Goldsmith, 2023). Publicly accessible charging stations play a critical role, along with appropriate outreach and incentives for purchase, to ensure equitable access to ZEVs (Slowik, 2019; Elkind et al., 2022).

Direct current (DC) fast chargers — sometimes referred to as “Level 3” chargers — are particularly important for public use, since they recharge EV batteries to 80 percent  within 20 minutes to an hour (U.S. Dept. of Transportation, 2024). Level 2 chargers, which charge more slowly than DC fast chargers but faster than a standard wall outlet,  are also important.

In 2023, there were nearly 94,000 public or shared private charging stations, including over 10,000 fast chargers statewide (California Energy Commission, 2024b). In 2018, California had established a goal of 250,000 charging stations by 2025, but this is likely insufficient given the 2035 ban on new gasoline-powered car sales (Hickerson and Goldsmith, 2023). By 2035, the California Energy Commission (CEC) estimates that the state will need 2.11 million public and shared private charging stations — including 83,000 fast chargers — to support the 15.2 million passenger plug-in EVs expected to be on the road (Davis et al., 2023). The state has made significant funding available to accelerate the installation of EV charging infrastructure: for example, the CEC’s $2.9 billion investment to build 80,000 charging stations, particularly targeting low-income and disadvantaged communities facing the most significant pollution burdens (Office of Governor Gavin Newsom, 2022). Yet, despite these targeted investments, the CEC has found gaps in access to public charging infrastructure in some disadvantaged communities, especially in rural low-income communities (Davis et al., 2023).

Challenges in permitting for EV charging stations

The permitting process has long been a source of concern for installers and state government agencies charged with expanding the ZEV market.

California’s 482 cities and 58 counties are responsible for issuing permits for proposed charging stations, following the same processes as other building developments. When uptake for ZEVs began to increase in the early 2010s, both installers and local officials struggled to navigate this new terrain.

Jurisdictions varied widely in the type of permit required, ranging from no permit at all to a permit requiring a full review of plans. Applications were submitted in a wide range of formats and level of detail, often leading to multiple rounds of comments. Installers reported highly divergent timeframes for similar projects, ranging from a few weeks to a year (CA Plug-In Electric Vehicle Collaborative, 2012; Senate Rules Committee, 2015).

Permitting delays and uncertainties not only slow down installation of specific projects but also contribute to higher costs for installers. Data from Electrify America, a company that installs public charging stations, suggests that in 2019 permits in California took 75 business days on average, compared with a national average of 44 days — with extended zoning review and multiple comment rounds noted as the top two sources of delay. Costs were 24 percent higher than the Electrify America national average, which it attributes in part to permitting delays (Electrify America, 2020).

Streamlining EV charging station permitting

Since 2015, the state legislature has sought to streamline the permitting process for EV charging infrastructure. Two key pieces of legislation — AB 1236 (Chiu, 2015) and AB 970 (McCarty, 2021) — established standard requirements for all cities and counties with regard to EV charging station permits (see Table 1). The approach was modeled in part upon legislation to streamline residential solar installations, enacted in 2014 through SB 2188 (OPR, 2019).

Table 1. Key requirements of California state legislation to streamline EV charging station permitting.

Adapted from Table 3 and other information in the Electric Vehicle Charging Station Permitting Guidebook, 2nd Edition from GO-Biz (Hickerson and Goldsmith, 2023).

AB 1236 established EV charging station permits as administrative and non-discretionary, thereby removing most projects from the scope of the California Environmental Quality Act (CEQA), which would significantly lengthen the permit process. Non-discretionary permits can be granted by permit staff, rather than requiring planning approval. Furthermore, AB 1236 limited review to health and safety concerns; aesthetic and landscape aspects can no longer be considered. The legislation also sought to standardize the permit application process, requiring that a checklist be made available for permit applications to receive expedited review, for permit applications to be submitted online, and a single round of comments be provided to applicants (Hickerson and Goldsmith, 2023).

The Governor’s Office of Business and Economic Development (GO-Biz) tracks implementation of the streamlining legislation and supports jurisdictions with templates and technical assistance. GO-Biz’s streamlining compliance map, which tracks jurisdiction compliance with the provisions of AB 1236 using a Permitting Scorecard, shows increases in compliance over time (GO-Biz, 2024a; 2024b). In July 2021, 52 percent of jurisdictions were categorized as streamlined or in the process of streamlining, and in February 2024, 75 percent of jurisdictions were streamlined or in process.

Yet, permit delays have persisted, even in jurisdictions that already complied with AB 1236. For example,  2021 data from the installer Electrify America indicated an average permitting time of 79 days, 30 percent longer than in other states and contributing to higher average construction costs (Electrify America, 2022). 

AB 970 was enacted in 2021 to help address continued delays. It sets specific timeframes for permit review for completeness and for approval, depending on the size of a proposed charging station (see Table 1). Permits can be deemed approved if they are not acted upon within these timeframes.

Research findings

Undertaken during spring and summer 2023 in partnership with GO-Biz, our research involved document review and analysis, collection and analysis of permitting data from certain cities, and 16 interviews with officials in cities and counties, community choice aggregators, and EV charging station developers. See Table 2 for an overview of jurisdictions consulted. Local jurisdiction staff we consulted included planning and permitting staff, sustainability officers, and building officials. 

Key research questions included the following:

• What are the main sources of delay in installing publicly accessible EV charging stations?
• What additional resources or support do jurisdictions need to address these key barriers?

Limited data availability to evaluate the effects of streamlining legislation

Insufficient data was available to evaluate whether permitting turnaround times decreased following implementation of streamlining legislation. Each city and county manages its own permitting data, utilizing different databases and formats with limited data made available online. Publicly accessible databases in one city (Stockton) and one county (San Luis Obispo) above 200,000 with permit submission and approval dates were identified and analyzed. In both cases, no statistically significant change in permit approval timeframes could be detected for the small number of years of data available.

Webscraping methods offer promise in compiling a more expanded dataset, and the research team tested methods for accomplishing this. An August 2023 analysis conducted by Shovels — a service that analyzes building permits — showed highly variable experiences across cities (Shovels, 2023). Median permitting timeframes ranged from 3 days (Oakland) to 93 days (Los Angeles), and permitting timeframes were found to increase over time in some jurisdictions and decrease in others.

Standardizing permit data reporting across jurisdictions would be highly beneficial in tracking implementation of permit streamlining under AB 1236 and AB 970. In addition to permit submission and approval dates, other data — such as the type of charging station, whether it is part of new or existing construction, and more fine-grained information about the timing of comment rounds — are important to track if data is to help us identify whether streamlining legislation is effective.

Sources of delay for installing publicly accessible EV charging stations

Limits on grid capacity are the most significant source of delay, especially when installing DC fast chargers. Multiple jurisdictions, both large and small, reported long delays on the part of the utility to provide adequate electricity to a site. Timeframes can be on the order of months or even multiple years for large installations. Reasons for these delays vary, ranging from the complex regulatory process of laying new transmission lines to utility service department delays and shortages of transformers needed for site upgrades (Merchant, 2023). Examples from interview data include the following:

Table 2. Jurisdictions Consulted, Spring/Summer 2023.

• A representative of a community choice aggregator providing technical assistance and funding for EV charging stations sometimes advised applicants to install Level 2 chargers rather than DC fast chargers to avoid energization delays.
• After hearing from the utility that they could not provide adequate electricity to the EV charging installations that had already been permitted, one jurisdiction added a requirement that permit applicants show proof of electrical service before a permit can be approved.
• A large city sought to upgrade its fleet to electric vehicles — in an effort to meet the state’s expectations — but the utility indicated it would take years to provide the level of electricity they were seeking.

Staff capacity. Jurisdictions both large and small are experiencing capacity challenges that affect permit review. Factors contributing to delay include difficulties in coordinating across departments, permit reviews conducted by contractors who only work on certain days, slow recovery of staff levels after COVID, and competing priorities. Jurisdictions also reported limited staff capacity to apply for grants to build publicly accessible charging stations, for city or county vehicle fleets or for public use.

Project complexity. Charging stations range widely in terms of size, charger type, and location. More complex projects, especially when DC fast chargers are included, often require extra layers of permitting review, which sometimes extend beyond the AB 970 timelines. Interviews revealed the following factors that often lengthen permit reviews: 

• New or existing construction. EV charging stations may be part of the overall construction permit for a new construction, which can significantly affect the timeframe. When EV charging is added to an existing site, local permitting officials must ensure aspects of existing conditions are up to code, and these remedies may take time.
• Ensuring American Disabilities Act (ADA) compliance. This compliance review can be complex, involving ensuring an accessible pathway to an EV parking spot, signage, project costs dedicated to accessibility, and more.
• Location of EV charging stations with respect to electrical wiring and capacity. Installers need to ensure that adequate electricity is available to hook up the stations at the specific locations where the stations will be located. If a permit review finds that the location of the charging stations needs to be modified for health and safety or ADA reasons, electrical wiring and capacity as well as equipment storage issues need to be revised and reviewed again.
• DC fast chargers require more extensive safety reviews. These stations draw large amounts of electricity and involve heavier equipment at the site. This often leads to more extensive health and safety reviews. If insufficient power is available at the site, this often leads to even more extensive delay.
• Coordination across multiple departments. Complex projects may trigger additional levels of review and involvement from more departments, such as fire inspection, planning, and engineering. Under the streamlining legislation, comments from all departments should be consolidated and provided to an applicant in a single set. Further research is needed to determine how frequently the consolidation of comments is taking place.

Stand-alone EV charging stations may run into hurdles with planning codes. Currently, EV charging stations are most often installed as an “accessory” use on a site with another primary use such as retail shopping or a workplace. When charging stations are proposed on sites where EV charging would be the primary use, similar to gas stations, a jurisdiction’s planning code may not specifically provide for this. Planning departments may need to get involved in these cases.

Delays and uncertainties when requesting funding for EV charging stations.Smaller and lower-income jurisdictions often depend upon grant funding to build publicly accessible charging stations in locations that may not “pencil out” for private installers.

While there is substantial funding available for EV charging stations, interviews revealed that jurisdictions often encounter significant delays in grant decisions and/or lack the staff time to apply for these grant opportunities.

Yet, as noted earlier, building out publicly accessible charging stations is essential to ensure equitable access to ZEVs (Elkind et al., 2022). The CEC has found gaps in access for disadvantaged communities based on an analysis of drive time to DC fast chargers (Davis et al., 2023). Other research has found that the gap in access to charging stations in California is higher in areas with more multi-unit dwellings and that Black and Hispanic majority neighborhoods have lower access to publicly available chargers (Hsu and Fingerman, 2021).

Addressing barriers

When asked about what steps state agencies could take to help address barriers local jurisdictions face in building out EV charging stations, interviewees shared a number of suggestions.

Address energization delays. Bringing adequate electricity to a site represented the most significant source of delay uncovered in this research, affecting DC fast chargers in particular. State agencies need to work with utilities to substantially reduce these delays. The Powering Up Californians Act (SB 410, Becker), enacted in October 2023, directs the California Public Utilities Commission (CPUC) to establish energization timelines and track compliance (Baumhefner and Borgeson, 2023). In the meantime, GO-Biz, the CEC, and other state agencies could support jurisdictions to identify the best alternatives under current constraints. For example, the CEC’s new Electric Vehicle Supply Equipment (EVSE) Deployment and Electric Vehicle Supply Equipment (EVSE) Deployment and Grid Evaluation (EDGE) tool is designed to help installers, local government, and other users identify potential locations for charging stations based on existing data about grid capacity and other indicators (CEC, 2023a).

Help alleviate limitations due to staff capacity. Aside from grid capacity, the most frequent cause of delay appears to be limited permitting staff capacity. Several jurisdictions noted the need for additional staff to review permits and coordinate across departments. The overall push toward electrification is likely to exacerbate capacity challenges. However, raising fees to help cover administrative costs can be challenging at the local level.

To help make more efficient use of staff time, several interviewees suggested developing an automated permitting tool for EV charging stations, similar to a platform called Solar APP+ for residential solar energy systems. Created by the National Renewable Energy Laboratories (NREL), SolarAPP+ automatically checks data about a permit request against the electric code and building standards and provides an instant permit approval if criteria are met (NREL, 2024). An evaluation by NREL of pilots in Arizona and California showed that projects were installed and inspected an average of 13 days sooner through Solar APP+ as compared with traditional projects and estimated a savings of around 15 to 60 minutes of staff time per permit (Williams et al., 2022). Under SB 379 (Wiener, 2022), most jurisdictions in California are now required to adopt Solar APP+ (CEC, 2024c). Further study is needed to assess the potential benefits of a similar platform for EV charging station permits.

Update planning codes to allow for EV charging as a primary use. Some cities, such as San Francisco and Oakland, have updated their planning codes to allow for stand-alone EV charging site use, similar to gas stations. For example, in 2022 San Francisco adopted changes to its code to formally include EV charging stations under a new “Automotive Use” category and allows charging stations to be located at all sites where gas stations and parking lots are allowed (City of San Francisco, 2022). Prior to this change, stand-alone EV charging stations had to be approved on a case-by-case basis.

Provide additional support to jurisdictions seeking grant funds. While considerable funding is available — especially for disadvantaged communities — several interviewees suggested ways to alleviate delays and uncertainties:

• Provide more assistance in identifying promising grant opportunities.
• Design grant processes to reduce uncertainties, such as two-step grant processes and grants that are formula-rated rather than competitive. 

Continue providing technical assistance to jurisdictions to implement streamlining. According to GO-Biz’s streamlining map, as of February 2024 approximately 75 percent of jurisdictions are now in compliance or in the process of complying with provisions of AB 1236 (GO-Biz, 2024a). However, some jurisdictions still lack staff time to implement changes such as developing a checklist and enabling online permit requests. Grants to hire a consultant could assist with this process. For example, the CEC offers grants to jurisdictions seeking to implement automated solar energy system permitting (CEC, 2024d).

Looking ahead 

California has taken important steps toward building out its EV charging network, through permit streamlining and substantial funding programs. Yet, to meet the needs of the growing ZEV market, stay on track for 2035, and ensure equitable access to ZEVs for all Californians, the pace of installations must rapidly accelerate (Davis et al., 2023). As this research has shown, barriers still remain to reaching these goals.

Permitting delays still exist, and steps such as enhanced staffing, automated permit approvals, and changes to planning codes to allow for EV charging as a primary use will help.

But expanding grid capacity will make the biggest contribution. This is critical not only for EV charging but also for advancing building electrification and many other components of California’s decarbonization efforts. The recently enacted Powering Up Californians Act (SB 410, Becker) seeks to both speed up the process and increase transparency (Baumhefner and Borgeson, 2023; St. John, 2023). Utilities may face challenges regarding an adequate workforce and capacity to comply. But the new law holds promise, especially its steps to improve transparency and tracking of performance metrics.

Greater data consistency and transparency would help ensure full implementation of EV charging station permit streamlining. The CEC is developing an Electric Vehicle Infrastructure Project Tracker that will collect and publicly share data on the implementation of EV charging station projects, including permit turnaround times (CEC, 2023b). This will be a valuable tool, especially if it includes all EV charging station projects rather than only those receiving CEC funding.

The stakes are high. If California does not succeed in building out public ZEV infrastructure at an adequate rate, it may fail to reach the goal of 100 percent ZEVs for new sales by 2035, with significant equity implications. For those who cannot charge at home, accessible charging infrastructure, associated with appropriate outreach and purchase incentives, plays a crucial role in increasing ZEV uptake (Slowik, 2019; Elkind et al., 2022). If this gap is not addressed, ZEV uptake will likely continue to skew toward higher-income brackets, with others facing higher costs and lower convenience. As the 2035 ban on the sale of new gas cars approaches, lower-income communities could be left with more limited, less convenient, and potentially more costly vehicle options. Prolonged use of existing gas cars would extend the current climate change and public health consequences of tail-pipe emissions, with disadvantaged communities bearing the greatest burdens.

This decade will be a pivotal one as California grapples with the challenge of re-making its energy, transportation, and housing infrastructure. It is time to redouble our efforts to advance clean energy infrastructure in a manner that enables all communities to participate in this monumental transition.

Acknowledgements

The research team included the following ��ɫApp undergraduate students, who each made valuable contributions to this effort: Amaryllis Gao, Armita Hosseini, Andrew Huang, Judy Liu, Chloe Romero, Lee Rosenthal, Natalia Seniawski, and Logan Schreier. Michael Bennon, research scholar at the ��ɫApp Center on Democracy, Development, and the Rule of Law, and Jeremy Dennis, consultant and former city manager of Portola Valley, also made critical contributions to this research effort.

The authors would also like to thank Heather Hickerson, Gia Vacin, and Elsa Wright of the Zero Emission Vehicle Market Development Office staff at the Governor’s Office of Business and Economic Development for their partnership. We would also like to thank all those who took the time to speak with our research team and share their insights.

This effort was funded by the Bill Lane Center for the American West, the ��ɫApp Institute for Economic Policy Research, and a grant from the ��ɫApp Vice Provost Office for Undergraduate Education.

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