Written evidence from SSE PLC (ELV0057) 

House of Lords Environment and Climate Change Committee Inquiry: Electric Vehicles

Written evidence from SSE plc

The SSE Group is a FTSE-30 company headquartered in Perth, Scotland and with interests across the UK and Ireland, Europe, North America, and Asia Pacific. We are a leading generator of renewable electricity and one of the largest electricity network companies in the UK. We develop, own, and operate low carbon infrastructure to support the low-carbon transition. This includes onshore and offshore wind, hydro power, electricity transmission and distribution grids, distributed energy systems and efficient gas-fired generation, where we are at the leading edge of decarbonisation with developments in carbon capture and storage and hydrogen. We also provide energy products and services for businesses.

In November 2021, SSE announced a fully funded, £12.5bn Net Zero Acceleration Programme, which will see us expand on our ambition to be the UK’s clean energy champion, creating 1,000 jobs a year to 2025. In May 2023, this plan was updated with a fully funded £18bn five-year investment plan to 2027. The programme will see SSE building the world’s largest offshore wind farm at Dogger Bank. We will also deliver over 20% of the necessary upcoming electricity networks investment in the UK to connect renewable energy and enable electrification of heat and transport, alongside investment in critical technologies like carbon capture and storage, hydrogen, solar and pumped storage hydro. Our investment could total up to £40bn across the decade to 2031/32.

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Call for Evidence questions.

1. What are the main obstacles to the achievement of the Government’s 2030 and 2035 phase-out dates? Are the phase-out dates realistic and achievable? If not, what steps should the Government take to make the phase-out dates achievable?

Transport is the UK’s largest emitting domestic sector and 91% of our transport emissions come from road transport. If ambitions to tackle climate change are achieved, essential progress on decarbonising Britain’s roads and motorways is vital. EV Rapid Charging Hubs are one of the leading low carbon solutions for this challenge, and by rolling out this technology at scale we will give consumers and businesses the confidence to go electric.

SSE’s Net Zero Acceleration Programme is investing £40bn by 2031/32 in the low carbon technologies we need to help get to net zero. As part of our future ambitions, we see EV Rapid Charging Hubs as offering an attractive investment opportunity which can help to mitigate climate change whilst offering social value and economic prospects for communities across our country. SSE has already delivered our first hubs at Castlebank in Glasgow and at Gapton Hall in Great Yarmouth, and we have huge ambitions to deliver 500 EV Charging Hubs with at least 5,000 bays by 2030.

SSE Distributed Energy takes a whole systems approach which invests in, builds and controls localised, flexible energy assets which are creating a more resilient energy system for the long-term. We view EV infrastructure as a critical part of this strategy and alongside flexible generation, storage, heat, and electrical networks, is integral to our development of local energy systems which harness innovative renewable energy solutions including onsite solar and battery, and energy to waste technology.

Despite our bold 2030 targets from government, progress will not be achieved on deployment of EVs until the UK has a reliable and resilient EV rapid charging network powered with traceable, renewable energy. All government decision makers, both national and local, need to move view EV rapid charging as a critical net zero infrastructure, recognising the vital role that EVs will play alongside public transport as part of a cleaner, greener transportation system. The UK Government needs to remain committed to the policy mechanisms to support EV deployment including the Zero Emissions Vehicle Mandate, as this will encourage more EV infrastructure deployment, helping industry to invest in communities, creating new highly skilled jobs, whilst contributing to reducing emissions, protecting public health and the climate.

If we are to accelerate the decarbonisation of the UK’s roads and motorways, we must ensure that the UK has both the workforce and skills to maintain our EV charging infrastructure. Currently we face shortages of both the labour and skills needed to roll out and maintain rapid charging infrastructure, whilst local government partners also need upskilling to deliver projects efficiently. A national EV charging workforce strategy designed and delivered with industry is needed to ensure that we have boots on the ground across the UK, including in remote and rural areas, to deliver and maintain projects, and to upskill our local government partners. Ensuring that we have a competent and trained workforce will create new highly skilled jobs, adding social value to communities, and establishing career pathways for this critical net zero technology.

21. How does the charging infrastructure for EVs need to develop to meet the 2030 target? Does the UK need to adopt a single charging standard (e.g., the Combined Charging System (CCS)) or is there room in the market for multiple charger types?

Yes, we would support the phasing out of Chademo which is already happening by manufacturer developments. It is important that we avoid the risk of NACS swapping as is happening in North America which means retrofitting lots of chargers at a significant cost. As CCS is now settled as the DC standard, we would suggest it is made a requirement.

22. The Government recently published the draft legislation of “Public Charge Point Regulations 2023”. What assessment have you made of the draft legislation text, and what contribution will it make in ensuring the charging experience is standardized and reliable for consumers?

To help the public convert to electric vehicles, customers need to be sure they can easily access public charging stations, they can quickly operate the charging station to get a charge, and that there is 24/7 assistance available in case something goes wrong.

To mitigate this, aspects of standardisation are required like those set out in the 2023 draft legislation, for example, the requirement for all CPOs to accept contactless payment, and clearly display set pricing, is key in making the sure that all customers can easily initiate a charge and have a clear understanding of what it will cost them. Mandating the implementation of a 24-hour helpline that is clearly displayed at charge points will assure drivers that they will be able to easily get assistance whenever they need it, and regular CPO reporting to make sure all CPOs are achieving a high network uptime, should help UK network reliability, and reduce customer range anxiety.  

There are challenges regarding how data will be utilised in order to build a level playing field in terms of 99% reliability. Government needs to be clear on its proposals as these may cause financial impacts for CPO businesses.

23. What assessment do you make of the requirements set out in the draft legislation of “Public Charge Point Regulations 2023” for charge point operators to make data free and publicly available, and how may this improve the EV charging experience for consumers?

It is important that certain data remains protected for commercial purposes, as could result in it being used for purposes contrary to what is being proposed. Further information is required as to what data is needed to be collected, how it will be presented and how it will be stored.

29. What are the challenges or concerns around grid capacity in relation to significantly increased EV adoption?

SSEN Distribution are part of SSE plc, the clean energy leader that develops, owns, and operates low carbon infrastructure to support the net zero carbon transition. SSEN Distribution, operating under licences held by Scottish Hydro Electric Power Distribution plc and Southern Electric Power Distribution plc, owns, operates, and develops the electricity distribution networks in the north of Scotland and central southern England.  

At the end of the next price control period by 2028, we expect that we will need to facilitate up to 1.3 million EVs on our distribution network. Looking further ahead through our analysis of the distribution future energy scenarios (DFES), our forecasts suggest that by 2030 in our central southern network[1], we may need to support around 2 million EVs and a further 300,000 in the north of Scotland[2]. By 2050, in our forecasts, this reaches up to a total of 7 million EVs spread across both of our license areas9.  

We know that electricity networks will need to grow exponentially to accommodate this take-up of low carbon technologies such as EVs and we are committed to being the enabler of the consumer transition to net zero. However, greater investment is required in both network capacity and reliability to facilitate decarbonisation and support an ever-increasing reliance on the electricity network. Following reductions by Ofgem in the ED2 determination process to our baseline allowance, we will now have to make use of uncertainty mechanisms during the next price control in order to fund strategic deployment of reinforcements to support low carbon technology.  

Despite the budget investment plans, there are other challenges which can affect the speed of decarbonisation of transport – principally the finite capacity of networks, and the time needed for upgrades to be carried out. On the low voltage networks, this can be a matter of days, weeks or months depending on the complexity of the network and the traffic/land permissions required. However, on higher voltage networks, the timescales can be significantly longer due to the scale of work required. In these cases, there are solutions which can be utilised to support the timely decarbonisation of transport by permitting EV charging infrastructure to be connected, for example through the use of flexibility services, on-site storage and load limiting. Therefore, the energy system will have to rely significantly on these alternative solutions moving forwards to avoid slowing the rate of decarbonisation. 

30. What is the role of distribution network operators in ensuring EV infrastructure can be rolled out sufficiently to meet 2030 target?

SSEN Distribution supports the need for significant and urgent reform of the connection’s regime so that new generation and demand projects critical to net zero can connect to electricity networks in a cost effective and timely manner. We are broadly aligned with Nick Winser’s Review from a distribution perspective and are prepared to work closely with Government to implement their action plan when published, whilst continuing to contribute to industry reform groups and implement both internal and external changes. As well as making changes to our own connections process, we are taking a key role in the industry connections reform which is being led by the Energy Networks Association (ENA) which is driving standards and performance across the industry. The ESOs 5 point plan is also working to improve connections to the grid What are we doing now? Our five-point plan | ESO (nationalgrideso.com).   

We also recognise that a key role of a DNO is to help customers and stakeholders quickly and easily understand the ability of local and wider networks to accommodate new connections. Therefore, we are advancing our Digital Strategy[3], aligned with the DSO Strategy, and make constant progress with the Open Data Portal. We have also created a web portal (NeRDA[4]) which allows stakeholders to view network data from LV monitoring and other datasets. Following support for Local Authorities building their LAEPs (Local Area Energy Planning) and LHEES (Local Heat and Energy Efficiency Strategies) via our innovation project RESOP[5], we are in the process of building a self-service and automated connections portal to further help customers have an easy and fast connections journey. DNOs are also collaborating via the ENA on the Digitalisation of Connections (DoC) project which is seeking to support LCT installations with near real-time confirmation of information and whether installs can go ahead or need an application to be approved first. The DNO role is providing visibility of network capacity and helping provide power systems analysis to advise where connections are possible or where further work is required. It is also about acting as a facilitator of flexibility, helping signpost where it is needed and using it to manage networks to further support EV infrastructure rollout.

Our understanding of our customers can also be improved by working in a Whole System way with our stakeholders. For example, our Project LEO3 is an industry-first and has set out to explore how the growth in local renewables including EVs, battery storage, V2G (Vehicle-to-Grid) technology and demand side response can be supported by a local, flexible, and responsive electricity grid. Thus, helping us to ensure value for consumers and opportunities for communities and market providers. Project LEO is one of the most wide-ranging and holistic smart grid trials ever conducted in the UK. The project balances local demand with local supply in a real-world environment, helping to test markets, inform investment models and, ultimately, assess the benefits of flexibility to the energy system. The £40 million project, supported by £13.8 million of funding from the UK Government’s Industrial Strategy Fund, it is a glimpse of the future and puts SSEN at the forefront of the UK’s preparations for a decentralised energy system capable of accommodating a dramatic increase in EVs. 

31. What are the requirements, challenges, or opportunities for the development of public charge point delivery across the UK? How will the development of EV charging infrastructure in the UK interact with existing planning regulations?

EV Charging

Local Government hold many of the levers which impact upon the delivery of EV charging including planning. Good planning policy is of course essential to ensuring that communities across the country have access to rapid charging hubs, located by the homes, businesses and public services which need them. At present huge variance exists across local government planning processes with councils adopting different approaches towards EV charging, including unnecessarily long delivery time frames. There can also be preference for other less established technologies such as hydrogen, which whilst are important, will not make the same quick wins as EV charging.

We would welcome if Government could standardise planning processes for EV rapid charging by introducing a set model which encourages timeliness, support for this technology and is easily replicable across all councils. Adopting a common-sense approach to planning which seeks to achieve consistency will support businesses to build out more EV rapid charging infrastructure supporting communities to go electric.

Local Government hold unparallel knowledge about their communities and need to be empowered to develop the EV charging solutions they require. Many Local Authorities lack the resourcing which is needed to explore new charging technologies which are over 50KW upwards or maintain and update existing systems. Funding streams including the Local Electric Vehicle Infrastructure Fund and the Rapid Charging Fund should be configured support local government to explore a broader range of rapid charging technologies, working with businesses to invest and deliver them. The Rapid Charging Fund needs to ensure a regional approach which supports areas of less commercial demand, as it was intended to do, and does not default to motorway service areas.

Distribution

For SSEN Distribution easy access to network data will be essential for organisations to install EV charging infrastructure from the ratings and remaining capacity of local transformers and cables their site is connected to, to the agreed Maximum Authorised Capacity their site is permitted to use. These are some of the key datasets needed to feed into the process of third parties establishing whether they can install sufficient chargers at their sites. 

However, with organisations renting units on businesses and industrial parks, for example, challenges arise to get permission from the landlords and landowners which hampers decarbonisation efforts. We would welcome any regulatory and policy initiatives that would support businesses in this type of situations and address the significant challenges around consent and land access rights which can hinder the installation of charging infrastructure and, as a result, decarbonisation. For example, we welcomed the UK Government initiative to revamp the Electric Vehicles Homecharge Scheme (EVHS) which saw eligible EV owners receive grants towards the cost of having a home charger installed - the scheme will now include renters and people living in flats.  

Through co-ordination and targeted investment, innovation can enable the uptake of low carbon technologies, enhance digital capabilities, and improve the efficiency of operations. We strive to put consumers in vulnerable situations at the heart of our innovation projects to ensure an inclusive energy future. For example, at the end 2020 we launched Equal EV[6], a Network Innovation Allowance (NIA) funded project in collaboration with Disabled Motoring UK (DMUK) to identify the enablers and barriers for EV adoption for drivers with disabilities, and to recommend traditional and innovative solutions for making EVs and EV infrastructure more accessible. The project also investigated the role DNOs can play in supporting disabled drivers, specifically what support and new services could be made available, such as installing V2G technology to offer at-home resilience for customers in vulnerable circumstances. The Equal EV project focused on two key vulnerable groups – those with mobility impairments and those with high levels of anxiety and highlighted three common barriers to these groups – lack of information on EVs and accessible charging, lack of disabled public parking spaces equipped with EV charge points and issues with domestic charging. The projects findings demonstrate the additional considerations that disabled drivers must contemplate before considering switching to an EV[7].

We note the government’s excellent work in building on the feedback from stakeholders and findings from projects such as Equal EV by introducing PAS 1899 to support accessibility of public EV charging. However, there is still a considerable number of installations taking place which do not meet the best practice and therefore will be excluding significant proportions of drivers from using them. To enact real progress towards an inclusive and equitable EV roll out, a collaborative cross-industry approach with regulatory intervention at local and national government level and the commitment of the automotive industry to make positive inroads towards better accessibility, must happen collectively.

32. What are the issues facing rural residents, urban residents, and sub-urban residents and how do they differ?

To overcome issues in different geographies government, both national and local need to be active partners in surrounding environment and infrastructure around rapid charging hubs. Local government is responsible for maintaining the roads which connect to our rapid charging hubs and physical infrastructure like drainage or street furniture, whilst national government oversees the connectivity to mobile networks which is required to use our sites. Flooding from drainage or poorly maintained adjacent roads can damage our rapid charging hubs, frequent road closures deter customers, and a lack of connectivity or poor coverage prevents build out particularly in remote and rural communities. Government, both national and local, must view itself as an active partner maintaining the surrounding environment, providing the necessary connectivity, and remaining responsive to operational needs. This will provide industry with the confidence to know that we can deliver and operate sites across all localities.

33. What role do you see local authorities playing in delivering the 2030 phase out target, particularly in relation to planning regulations, charge points and working with District Network Operators? How can government best support local authorities in their roles?

With the uptake of low carbon transport, local authorities are finding themselves in the driving seat to help plan the infrastructure that will support the choices that will drive net zero. Data sharing will be key for local authorities to unlock their potential and for the energy system to achieve a whole-system approach which SSE delivers. Earlier this month (September 2023), the Geospatial Commission published their ‘Charging Ahead: Using location data to boost local EV chargepoint rollout’[8]. The report sets out how location data can support local authorities to make good decisions about where EV chargepoints should be installed. The report highlights how SSEN as “leading the way with data sharing” between DNOs and local authorities with the use of the LAEP+ tool. 

The LAEP+ tool created by Advanced Infrastructure has data from SSEN and other Distribution Network Operators which demonstrates the grid capacity along a road for areas in the several DNO licence areas. The LAEP+ tool takes a ‘whole system’ approach, by drawing together data from multiple sources into a single tool that can be used to plan the roll out of low carbon technologies (LCTs) such as charging points for electric vehicles.  The tool can be used to model scenarios involving different types of chargepoints and different combinations of chargepoints spatially. This will help local authorities by enabling LCTs to be sited in cost effective locations and provide early notification to SSEN of additional network needs, creating an effective partnership for accelerating net zero. Future iterations of the tool will facilitate the creation of decarbonisation plans per neighbourhood based on local data. Our LAEP+ tool is currently being repackaged as LENZA (Local Energy Net Zero Accelerator) which will launch formally later this month.

The uptake of EVs requires electricity companies to collaborate with local authorities, original equipment manufacturers (OEMs) and transportation agencies (including Highways England and Transport Scotland) to ensure sufficient charging infrastructure is available across the country. Our Whole Systems strategy[9] provides the framework and approach for SSEN to work with our stakeholders to deliver net zero ambitions. This includes engaging with stakeholders such as local authorities, the transport sector and other DNOs to share information and better understand our customers’ needs to deliver our LV strategy. 

The democratisation of energy planning must be understood as an enabler to net zero rather than a box to tick; plans co-developed with local stakeholders will drive faster decarbonisation of our communities. This point was also underlined by the recently published work of Regen[10], in which they interviewed local authorities, devolved government and community energy stakeholders to understand how energy system planning should work at a regional level. The increasing interaction of energy systems, digitalisation of the sector, the increased volume of data to support decision making, and the imperative of decarbonisation all enable and necessitate a greater whole system approach from all industry participants, and markets that leverage these trends to deliver efficient and innovative solutions to grid and system constraints. Ofgem’s approach of socialising the costs is reasonable now, however, this may push up costs in the future for those who do not own EVs or HPs raising questions of fairness. We believe that regardless of the approach taken, just transition considerations and advice need to be at the centre of any decision making to ensure everyone can benefit from the transition to net zero and no groups are left behind or excluded especially those in vulnerable situations.

On the customer side, our understanding of our customers can be improved by working in a Whole System way with our stakeholders, including collecting and analysing additional data and information – such as applications for EV charger grants or engaging with Local Authorities on their plans. We can also build a fuller and more accurate picture of customer behaviour by implementing sophisticated data analytics tools. By drawing on, and analysing, limited information from multiple sources – and combining this with broader information on area demographics and other socio-economic factors, we can greatly improve our planning and decision-making to ensure we meet customer needs, when and where it is required.