Written evidence from Connected Kerb (ELV0064) 

 

 

House of Lords Environment and Climate Change Committee

Electric Vehicles Inquiry – Call for Evidence
 

Connected Kerb response – 15 September 2023

 

 

 

Executive summary

 

  1. The transition to Electric Vehicles (EVs) is essential if the UK is to successfully decarbonise road transport in line with net zero legislation. For that transition to be successful the UK needs both a strong EV market and widely available consumer-friendly charging infrastructure.
     
  2. The UK’s charging market has grown rapidly in recent years to deliver the infrastructure that EV drivers need – charging availability increased 42%[i] between August 2022 and 2023, and the sector has committed to invest £6bn of private capital through to 2030[ii].

 

  1. While overall charging network growth is important, having the right chargers in the right places, so that no drivers are left behind, is vital. Rapid, destination and home charging are key parts of the mix, but the UK also needs widespread availability of fast charging (7-22kW) in long-dwell locations, such on-street and car parks, for the millions of UK households[iii] that cannot charge at home. Today around half of the UK’s 48,450 charge points are “fast” and this number will need to grow rapidly over the coming decade to ensure a fair transition to EVs.
     
  2. Connected Kerb is a leading Charge Point Operator focused on this part of the market, delivering on-street community charging with local authorities for residents unable to charge at home. We also operate infrastructure at workplaces, retail destinations, car parks, commercial real estate and for residential developers, as well as some rapid (50kW+) chargers.
     
  3. In 2022 we secured up to £110million of investment from Aviva Investors to support our long-term plan to deliver 190,000 charging points by 2030. Connected Kerb, along with the rest of the UK’s charging market, is therefore poised to deliver the charging part of an equitable EV transition. Five policy steps – all of which are achievable – are now needed to enable us to deliver on this potential in the run up to 2030 and beyond:
     

 

 

 

About Connected Kerb

  1. Connected Kerb is a leading UK Charge Point Operator (CPO) and manufacturer. We’re building a publicly accessible charging network across the UK, supporting drivers and businesses in the global shift to electric vehicles by making charging inclusive, convenient and reliable. We deliver on-street community EV charging, working with local authorities (LAs) to support the c.40%[iv] of households in the UK unable to charge their vehicle at home.
     
  2. Our main focus is fast charging (7kw to 22kw AC chargers) in long-dwell locations such as on-street residential parking or car parks. We believe this is the fastest way for drivers to power their vehicle. Like charging a smartphone, the owner can just plug in and get on with their day. Today around half of the UK’s 48,450 charge points in the UK are “fast”[v] and this number will need to continue to grow rapidly over the coming decade to ensure a fair transition to EVs.
     
  3. We also install future-proof charging infrastructure at workplaces, retail destinations, car parks, commercial real estate and for residential developers. We also offer rapid charging for EVs (50kw+) to support those drivers that need an instant top-up for their vehicle.
     
  4. In 2022 we secured up to £110million of investment from Aviva Investors to support our long-term plan to deliver 190,000 charging points by 2030. We are making good progress against that goal, with more than 3,000 public charging sockets at 850 charging points across the UK today. To date, more than 25,000 EV drivers have used our network.

 

  1. Demonstrating our rapid growth and established position in the market, in 2022 we were contracted to deliver 16,800 charging sockets and were voted the top fast charging (AC) network in the UK by Zap Map[vi].             
     
  2. In short, we are positioned to play a significant role in delivering the charging infrastructure needed to enable the UK’s switch to EVs. We wish to work constructively with the UK Government and other stakeholders to create the conditions we need to deliver what is required and welcome the opportunity to submit evidence to the Committee’s inquiry.
     

Vision and the role of public policy

  1. Connected Kerb’s vision is fully aligned with the Government’s 2022 EV Infrastructure Strategy:
     

 

  1. A market-led rollout of this critical infrastructure, harnessing the increasing availability of private investment and the expertise of CPOs, such as Connected Kerb, to realise the rapid deployment of high quality, consumer-friendly charging.

 

  1. Thanks to a supportive public policy environment, and in particular the 2020 announcement of the 2030 phase out date, a market-led rollout to deliver this vision is underway. The UK charging market has grown rapidly in recent years and is set to see exponential growth in the near term – charging availability grew 42%[vii] between August 2022 and August 2023, and the charging sector’s trade association ChargeUK says that members are committed to invest £6bn through to 2030 to support this growth[viii].
     
  2. However, charging availability will need to accelerate even faster if it is to stay ahead of demand. Government – at both a central and local level – has a crucial role in supporting Connected Kerb and other CPOs to do this by:

 

  1. Before answering the Committee’s specific questions, we would like to highlight five policy actions that Government can take now to help us deliver this shared vision:

 

  1. Progress against all these actions is necessary – but achievable – to enable a smooth, consumer-friendly transition to EVs ahead of the 2030 phase out date and beyond.

 

ZEV mandate and the 2030 phase out date

  1. For the EV transition to be successful the UK needs both a strong EV market and widely available consumer-friendly charging infrastructure. The growth of these two markets is entirely interdependent: consumers need to be confident there is sufficient charging infrastructure to switch to EVs and charging infrastructure investors need to be confident there will be sufficient EVs on the road to invest and realise and a return on that investment.
                 
  2. The ZEV mandate should therefore be seen as a key policy to support the growth of the EV charging sector and not just an intervention in the automotive sector. Quite simply, charging infrastructure investors cannot invest at scale if they cannot be confident of the size and trajectory of demand.             
     
  3. Despite the vital importance of this policy, and with a matter of months until the ZEV mandate is due to come into force, we are yet to see a final mandate. Further, the last few months have seen uncertainty about the 2030 date and rumours that the ZEV mandate will be weakened. This uncertainty – and the prospect of policy change – is extremely damaging to the goal of widespread and equitable charging provision.

 

  1. Therefore, we urgently need to see the following:
     

 

 

LEVI and ORCS public subsidy schemes

  1. Although the UK’s charging infrastructure rollout will be led by private investment, public subsidy will play a vital role in some parts of the market, including some parts of the on-street residential market.
     
  2. Lower utilisation levels in these locations and/or the cost of deployment mean that at present the commercial case requires subsidy to ensure that charging is provided ahead of demand. Deployment ahead of demand is an important policy objective, as people tend not to make the decision to switch to an EV until they know how they will charge.

 

  1. Connected Kerb is supportive, in principle, of well-designed subsidy schemes that work with the grain of the commercial sector, to unlock and maximise the impact of private investment so that these sites are served. Key features of well-designed schemes include:
     

 

  1. At present, the £450m LEVI (Local EV Infrastructure) and £15m ORCS (On-street Residential Chargepoint Scheme) are the two grant funding schemes aimed at supporting LAs to deliver on-street charging – LEVI is two-year funding programme aimed at accelerating large-scale strategic deployments and comprises a Capital Fund and a Capability Fund to enable LAs to recruit in-house EV managers; ORCS is aimed at smaller, more targeted projects. 
     
  2. Connected Kerb had primed itself to deliver at pace this year, building on the momentum of the success we’ve had in a growing market over the last few years, as well as the prospect of the LEVI fund (and ORCS) injecting subsidy into the market to further accelerate it.
     
  3. However, we are very concerned that – at present – these schemes are delaying rather than accelerating rollout, because they have not moved at the pace of the market; the grant approval process has not been swift and predictable; and there have been issues with clear and consistent communication about timelines, requirements and success criteria.
     

LEVI

  1. Any subsidy scheme has an impact on market behaviour as soon as it is announced, particularly one of this size. LEVI was first announced in July 2021[ix]; applications for the pilot took place in spring 2022[x], with the main Fund formally launched in March 2023[xi]. The first projects are invited to submit detailed applications by November 2023 and OZEV will approve/reject these applications from September 2023 and throughout 2024.
     
  2. In theory this means that the first successful LAs will go out to tender with LEVI funding from late 2023 – although based on our experience in this market, this is more likely to be early 2024 – with the remaining project approvals and tenders taking place throughout 2024 and 2025. There will therefore have been c.30 months between the Fund being announced and CPOs being able to participate in the first tenders, at the very earliest.

 

  1. LEVI is impacting pace of rollout in four ways:

 

 

 

 

 

 

 

ORCS

  1. ORCS was first launched in 2017 and has funded 1000s of charge points. With the advent of LEVI, the role of ORCS is evolving. In March 2023, a 12-month extension of ORCS for 2023/24 worth £15m was announced with an amended focus on smaller projects. We have experienced the following delays related to ORCS:
     

 

 

Accelerating deployment related to LEVI and ORCS

  1. Connected Kerb remains confident that the market, with subsidy support, can deliver the infrastructure needed to enable those without access to home charging to switch to EVs ahead of and beyond 2030. However, to help us to do this, and in addition to the other steps outlined below to speed up rollout, we propose:
     

Deployment barriers – planning, highway permits, grid connections and community engagement

  1. In order to build, electrify and operate charge points, CPOs rely on close cooperation with multiple other actors: central government, local authorities (who play the role of planning and highways authorities, as well as the client and landlord in many cases), private landlords, DNOs, manufacturers, installers, meter operating partners and residents.

 

  1. However, while CPOs are laser-focused on deploying high quality infrastructure at pace – motivated by commercial and public policy incentives – interactions with key stakeholders often take months instead of weeks, and years instead of months. Because these interactions with external stakeholders are on the critical path to a charge point becoming operational, we can only deploy infrastructure at the pace of the slowest interaction.

 

  1. This is not to criticise our partners, but to explain that the way in which CPOs interact with them is not as efficient, transparent or streamlined as it needs to be to for charging infrastructure to be deployed at the pace required.

 

  1. The delays experienced are worsening, as already inefficient systems are put under increased pressure. As the rollout continues to accelerate, we should expect the delays to do likewise. Concerted and urgent public policy focus is therefore required to address these barriers.

 

  1. Along with CPOs across the whole sector, Connected Kerb experiences significant delays with planning permission, highways permits, grid connections and meter installation. The experience varies significantly between LA, highway authority and DNO, and while there are pockets of good practice, the overall picture is one of slow and unpredictable timelines; overly complex and non-standardised contracts; and processes that are not tailored to the needs of charging infrastructure. Our trade association ChargeUK is currently mapping these barriers to identify priority areas of action and will shortly put forward a suite of solutions.

 

  1. For those CPOs operating in the on-street part of the market, in addition to these delays and the lengthy process of public sector tenders and subsidy schemes (see above), formal consultation with local residents on the location of charge points can add 3-5 months to deployment.

 

Local resident consultation

 

  1. Community consultation is an important and valid part of the charge point installation process either for legal/regulatory reasons – as part of a consultation to change a parking space into an EV only bay (TRO) [xii] or to secure a highways licence – or to ensure charging is deployed where it will best serve the community, including through demand generation and aggregation. However, this consultation process could be made more efficient and consistent.
     
  2. As charging is a relatively new consideration for LAs and highways/traffic authorities, processes for other types of planning or highways notifications are often used for charging, rather than tailored processes, which can lead to inefficiencies. We also encounter a great deal variation between different LAs, as well as significant uncertainty about what type of consultation is required by law as opposed to being at the discretion of the LA or CPO. This leads to huge variations from project to project about:
  1. Not only does this add substantial time and costs to prepare and conduct the engagement but it can lead to high rate of site rejection, an already lengthy site selection process being repeated multiple times and otherwise “good” charging sites being rejected.
     
  2. We should stress that community consultation is an essential part of determining where to situate a charge point, but believe the process would benefit from the following:

VAT

  1. In addition to ensuring we have an increasing supply of affordable vehicles EVs we also need to ensure the cost of charging is fair. The current VAT rules are currently unfair – 20% for public charging and 5% at home – discriminating against those people who don’t have driveways, often those who live in lower income areas. Connected Kerb therefore stands with colleagues across the EV and charging industries in asking for Government to abolish the “pavement tax” by equalising VAT applied to public charging to 5%.

 

Consumer confidence

  1. In recent months, coverage of EVs in both traditional and social media has become increasingly sensationalist and inaccurate, driven by anti-EV agendas and the need to secure clicks, rather than to inform consumers of the facts. This is beginning to have a negligible impact on consumer sentiment, which will of course be reflected in levels of EV adoption, especially as we move beyond the current wave of adopters to those who require greater reassurance about what the transition means to them.
     
  2. There is therefore an urgent need for a neutral, fact-based source of information for consumers to counter this misinformation. The exact nature of communication is to be determined, but it should involve all stakeholders in the EV ecosystem – OEMs and their supply chain, CPOs, manufacturers, installers, fleet operators, retailers – as well as local and central government and consumer groups, to provide factual, sober and reassuring information to consumers at every stage of their journey from the media to the dealerships and beyond.
     
  3. Industry and Government have cooperated before on the Go Ultra Low campaign. While we don’t suggest an exact replica of this campaign, it shows that cooperation between parties is possible to create and distribute information that is authoritative and digestible.

 


Answers to specific consultation 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?
  2. Do the 2030 and 2035 phase-out dates serve their purpose to incentivise the development of an EV market in the UK?
  3. What specific national policies, regulations or initiatives have been successful, or have hindered, EV adoption to date? Are these policies or initiatives fit for purpose?

 

 

 

 

  1. Given that the Government should apply a behavioural lens to policy – which involves people making changes to their everyday lives, such as what they purchase and use – is there a role for clearer communication of the case for EVs from the Government? If so, who should take the lead on delivering that?
  2. What is your view on the accuracy of the information in the public domain relating to EVs and their usage.

 

13. What is your assessment of the current second-hand EV market? How is the second-hand EV market projected to develop between now and the phase out dates?

21. How does the charging infrastructure for EVs need to develop to meet the 2030 target?

24. In terms of charging infrastructure, are there unique barriers facing consumers in areas of low affluence and/or multi-occupancy buildings, such as shared housing or high-rise flats? Do you consider public EV charging points to be accessible and equitable compared to home-charging points? What can be done to improve accessibility and equitability?

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

 

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 standardised and reliable for consumers?

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?

 

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

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

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?

33. What role do you see local authorities playing in the 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?

 

  1. To build, electrify and operate charge points, CPOs rely on close cooperation with multiple other actors: central government, local authorities (who play the role of planning and highways authorities, as well as the client and landlord in many cases), private landlords, DNOs, manufacturers, installers, meter operating partners and residents. Each of these stakeholders has a vital role to play, but the processes for CPOs’ engagement with them are not as efficient, transparent, or streamlined as they need to be for charging infrastructure to be rolled out at the pace required.

 

  1. Along with CPOs across the whole sector, Connected Kerb experiences significant delays with planning permission, highways permits, grid connections and meter installation because of slow and unpredictable timelines; overly complex and non-standardised contracts; and processes that are not tailored to the needs of charging infrastructure.

 

  1. CPOs in the on-street part of the market also experience significant delays before the delivery phase can begin, because of the time taken to secure local authority contracts, especially when public subsidy is involved, as well as time to consult residents to select sites.

 

  1. All these delays are addressable by stakeholders working together in focused way, and with oversight from Government – perhaps via a “barrier busting team” as has been the case in broadband rollout to:

 

 

 

 


[i] https://www.zap-map.com/ev-stats/how-many-charging-points

 

[ii] https://www.chargeuk.org/post/launch

 

[iii] It is commonly cited that around 40% of the UK’s households cannot charge at home; DfT’s EV Infrastructure Strategy states that 30% of households have access to private parking, but this does not include parking that is not close to the house or another energy supply and is therefore not suitable for charging and so this figure is likely to be much higher than 30%. This figure rises sharply in urban areas, for example TfL estimate that 60% of households in London cannot charge at home and this may be c.80% in Glasgow. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1065576/taking-charge-the-electric-vehicle-infrastructure-strategy.pdf https://content.tfl.gov.uk/ev-uptake-and-infrastructure-impacts-study-updated-nov-2016.pdf

 

[iv] Ibid.

[v]https://www.zap-map.com/ev-stats/how-many-charging-points

 

[vi] https://www.zap-map.com/news/best-worst-rated-ev-charging-networks-uk

 

[vii] https://www.zap-map.com/ev-stats/how-many-charging-points
 

[viii] https://www.chargeuk.org/post/launch
 

[ix]https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1009448/decarbonising-transport-a-better-greener-britain.pdf

 

[x] https://www.gov.uk/guidance/apply-for-local-electric-vehicle-infrastructure-levi-pilot-funding

 

[xi] https://www.cenex.co.uk/news/381-million-government-funding-local-electric-vehicle-infrastructure-fund-launches/

 

[xii]Statutory Consultations on a proposed Traffic Regulation Order (TRO)s are required to introduce a designated EV charging space onto the highway.

 

[xiii] https://www.gov.uk/government/consultations/traffic-regulation-orders-changes-to-publishing-requirements-and-special-events-order-approvals

 

[xiv] https://www.zap-map.com/ev-stats/how-many-charging-points
 

[xv]https://www.smmt.co.uk/2023/09/august-boost-for-ev-market-but-regulatory-uncertainty-threatens-future-ambitions/