Written evidence from ChargeUK (ELV0076)

House of Lords Environment and Climate Change Committee inquiry into Electric Vehicles – ChargeUK response

1. ChargeUK is pleased to provide this submission to the House of Lords Environment and Climate Change Committee inquiry into electric vehicles (EVs).

2. ChargeUK is the trade association for the electric vehicle charging infrastructure industry across the UK. Our mission is to support the delivery of the UK’s net zero goals by advocating for policies that accelerate the rollout of a commercially led, consumer focused, fit-for-purpose EV charging infrastructure ecosystem. Together, our 24 members are publicly committed to investing over £6bn to deliver and operate a world-class charging infrastructure by 2030, supporting economic growth and powering the UK’s switch to electric vehicles. We are committed to the UK being the best place in the world to drive and charge an EV and to supporting a thriving net zero economy creating good, sustainable jobs.

3. The number of public electric vehicle charge points is increasing exponentially. At the end of August 2023, there were 48,450 public electric vehicle charging points in the UK, a 42% increase year-on-year and up from approximately 6,500 charge points in 2016. It should be noted that these numbers do not include charge points installed in homes and at some workplaces.[i]

4. Our foundational values are:

1. The UK must rapidly decarbonise its transport system to meet its net zero goals - this includes supporting the transition to electric vehicles.
2. Accelerated rollout of high-quality consumer-first EV charging infrastructure is necessary to support the transition to EVs, providing accessible, convenient, and affordable charging. 
3. An open and competitive market, which enables private investment in infrastructure, is best placed to deliver the charging infrastructure the UK needs.​​
4. ​Public policy has a vital role in creating a policy and regulatory framework that supports investment, accelerates rollout, and promotes consumer-friendly charging infrastructure.
5. To work with the wider mobility and energy sectors to collaborate on net zero ambitions and drive synergies between old and new markets.

5. ChargeUK members deliver the full range of public charging solutions: rapid, destination and on-street/residential, covering AC (slow and fast) and DC (rapid and ultra rapid) charging. A full list of our members can be found in Annex A.

6. In the submission below, ChargeUK outlines the status of the UK’s EV charging infrastructure. While the sector is growing and delivering at pace, we are working closely with central and local government on the levers that need to be pulled to allow us to go even faster, including:

1. Government confirmation of the 2030 phase out date for petrol and diesel cars and a strong ZEV mandate, which is essential for investor confidence in our sector.
2. Removing barriers that make rollout slower and more expensive than necessary.
3. Equalising the VAT rates on public and private charging to 5% to make charging fairer and more affordable for those who cannot charge at home.

7. There are a variety of tasks ahead of us to accelerate rollout and we are working closely with the Department for Transport, Treasury, the Department for Business and Trade and the Department for Energy Security and Net Zero to deliver the charging infrastructure the UK needs.
8. ChargeUK can provide further information as required by the Committee. To request any additional information please email the secretariat on chargeuk@connectpa.co.uk.

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? To what extent are car makers focusing on one date or the other? What are the impacts of the deadlines on the ability of the UK supply chain to benefit and how could the Government seek to further support the development of the UK EV industry? Would the introduction of a plan with key dates and timescales support the development of the EV industry in the UK?

The UK is at the forefront of the transition to Net Zero and the mass adoption of electric vehicles is an essential component of this process. This requires both a reliable supply of vehicles and the ready availability of charging infrastructure. ChargeUK believes that the phase-out dates for internal combustion engine (ICE) passenger vehicles are realistic and achievable with a strong zero emissions vehicle (ZEV) mandate.

The Government’s 2020 announcement of the phase-out date reflected a bold vision and ambition and sent a strong signal to investors. This facilitated billions of pounds of investment from charge point operators to date in addition to the over £6bn committed by our members to 2030. If government fails to stand firm to its commitments and the number of new EVs is slower than originally outlined, the investment in charging infrastructure is at risk. In August 2023, ChargeUK wrote to the Prime Minister to urge him to stand firm on the transition to electric vehicles.[ii]

The ZEV mandate must start with legally binding targets in 2024. ChargeUK members are concerned that the mandate has been substantially weakened, particularly through the banking and borrowing flexibilities and rumours that 2024 will be a monitoring year. These flexibilities will lead to poor outcomes for our industry and consumers.

The flexibilities through borrowing combined with the implications of the CO2 regulations have introduced the potential for a much weaker trajectory – particularly during the key 2024-2026 investment period – as well as a wide window of uncertainty.

As a result, as currently drafted, the mandate risks undermining infrastructure investor confidence at the very point when our members are keen to push beyond the more than £6bn investment already committed to 2030. A weakened trajectory may also increase the risk of delaying the ban on ICE sales from 2030. Investors in our industry must see the UK’s clear commitment to the transition to zero-emissions vehicles in order to continue investing at scale.

Experience of using an EV

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?

Developing EV charging infrastructure in the UK

The UK is at the forefront of the transition to Net Zero and the mass adoption of electric vehicles is an essential component of that process. The charging network across the UK is growing every day, with an average of one new charge point switched on every 20 minutes. Our members stand ready to exponentially increase the UK’s charging network to support the delivery of a clean and green transport system.

In the EV Charging Infrastructure Strategy, the Secretary of State for Transport outlined an expectation of “around 300,000 public chargers as a minimum by 2030.”[iii] ChargeUK members believe that numerical targets for public charge points are too simplistic and do not accurately reflect how or where the charging network needs to grow.

Consumers already have access to a variety of charging solutions to meet different needs, such as ‘destination charging’ (at home, at work or at other private locations such as gyms or supermarkets), home charging, on-street charging and charging ‘hubs. Deployment of all of these types of solutions will continue to meet the UK’s needs in 2030 and beyond.

While the majority of current EV drivers have access to a charging point at home, we expect that as EV adoption accelerates, the number of drivers who can’t charge at home will increase. ChargeUK members are committed to installing public charging solutions ahead of demand in order to serve those drivers and boost consumer confidence in the charging network.

Government support for the rollout

While the private market will lead the rollout of charging infrastructure, ChargeUK is supportive of government subsidies that are targeted at locations where charge points are not commercially viable and that further the overall objective of a market-led rollout of the right charging solutions in the right places, at pace. We are working with the Government to make the two main subsidies – LEVI and RCF – as effective as possible in meeting these aims.

The Government should also include renewable electricity in the Renewable Transport Fuel Obligation (RTFO). A consultation should be announced on the upcoming Low Carbon Fuel Strategy[iv]. For context, the RTFO is a mechanism dating from 2008 that was designed to support emissions reductions in transport and the cost of this policy is levied onto the cost of fuel. To date, the primary beneficiary of this policy has been biofuels, and some types of hydrogen included in recent years, yet electricity is still excluded. Jurisdictions that include electricity in similar mechanisms, such as California, Germany, Netherlands, and Austria (with the rest of Europe following suit), have successfully introduced this policy alongside the use of biofuels and hydrogen.

It would allow suppliers of relevant transport fuel (hydrogen, electricity, biofuels) in the UK to generate certificates that can be traded or sold to others to meet the RTFO targets. The inclusion of renewable electricity would use a market-based mechanism to support the roll out of EV charging infrastructure, potentially at no cost to the treasury. It may also decrease the cost of compliance with the policy overall. This could therefore reduce the cost of fuel at the same time as supporting charging roll out.

Barriers to the rollout of EV charging infrastructure are explored in our answers below.

Charging standard and charger types

As the charging network has developed, the standard charger found in electric vehicles has shifted from the ‘CHAdeMO’ charger to the Combined Charging System (CCS). Many public charge points offer connectors for both CCS and CHAdeMO sockets. Today, nearly all new EVs on the market in the UK and Europe come with a single CCS option, indicating that OEMs and consumers have chosen that CCS is the solution for the future. Year-to-date less than 2% of the 200,000 BEVs that have been registered in the UK have carried a CHAdeMO connector, with 98.5% offering CCS. In practice this means that nearly every EV driver in the UK will be able to find a connector compatible with their vehicle, wherever they charge. We see no need for any de jure mandate of any connector standard.

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?

ChargeUK welcomes the draft Public Charge Point Regulations 2023 that were laid in parliament in July 2023. We expect the regulations to come into force later this year and our members are appreciative of the engagement with the Department for Transport and the Office for Zero Emissions Vehicles (OZEV). Ensuring that charge points are easy to find, use and pay for is in the commercial interest of CPOs and our members are motivated to deliver the best possible consumer experience.

Many of the requirements included in the regulations around reliable charging, transparent pricing and helplines are now standard features of today's charging infrastructure. These minimum standards for consumer experience are welcome.

As with any new regulations, implementation requires close cooperation between the government, regulators, and industry. ChargeUK is working closely with the Office for Zero Emissions Vehicles and the Office for Product Safety and Standards to address urgent questions on issues such as open data, measuring reliability and timelines, particularly around lead times for kit standards that could significantly impact the rate of rollout. Our industry requires clarity and adequate lead-in times to make the relevant system developments and changes.

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?

Ensuring that those who cannot charge at home (for example with private home chargers) have easy and affordable access to charging close to their home is essential for fair transition to EVs where no-one is left behind.

For consumers who do not have access to private home charging, the availability of solutions such as lamppost and on-street charging is growing rapidly, and they offer a reasonably low-cost alternative. ChargeUK members are already deploying infrastructure at pace to ensure that charging is available for these consumers ahead of demand.

Workplace charging offered by employers can also be used to recharge while parked at the office, and many other ‘destinations’ such as supermarkets, hotels and shopping centres are boosting their offering of charging options for customers.

However, public charging is subject to 20% VAT, compared with just 5% VAT for those who use their home electricity to charge their vehicles. ChargeUK members agree it is unfair that those without access to a driveway or off-street parking pay more tax to charge their electric vehicle than others. The government should equalise the rate of VAT for public charging to 5%, the same as for people who can charge at home. This is a relatively low-cost step that would drive take up of electric vehicles and speed up the nation’s journey towards Net Zero.

National and regional issues

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?

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

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?

One of ChargeUK’s key areas of focus is on removing the barriers to accelerate the roll out of public charge points.

We believe that the Government can play an important role in helping us to cut red tape with some simple moves such as:

• Adopting the Scottish model on permitted development rights for EV charging projects of a certain scale[v].
• Bringing forward the response to the 2022 TRO consultation, which must include provisions for EV charging[vi].

As requested, following ChargeUK Chair Ian Johnston’s oral evidence session on 13 September, we will write to the committee with further information on these points.

ChargeUK is currently conducting a major investigation into the barriers encountered for both AC and DC charging. We aim to develop collaborative policy solutions to alleviate these issues and to accelerate deployment of public charging solutions across the UK. We look forward to sharing our results with the Environment and Climate Change Committee.

Annex A: ChargeUK members

1. Be.Ev
2. Believ
3. bp pulse
4. Char.gy
5. ChargePoint
6. ConnectedKerb
7. ESB energy
8. EVC
9. Evyve
10. Fastned
11. Geniepoint
12. Gridserve
13. Ionity
14. Mer
15. Osprey
16. PodPoint
17. PoGo
18. Raw Charging
19. Shell Recharge
20. SSE Energy Solutions
21. Tesla
22. TotalEnergies
23. Urban Fox
24. Wattif EV