Written evidence from WSP (ELV0096) 

House of Lords Environment and Climate Change Committee

Inquiry: Electric Vehicles

WSP Submission: 15 September 2023



WSP is a world-leading multi-disciplinary professional services consultancy which supports significant projects in both the built and natural environments. We provide engineering, planning, design services and strategic advisory support to public and private sector clients in the transportation and infrastructure, property and buildings, earth and environment, power and energy, resources and industry sectors. Our team in the UK of over 9,500 engineers, scientists, environmental specialists, and planners, is part of a talented family of more than 66,000 global changemakers, transforming what is possible in order to build a smarter, greener future for all.

WSP takes pride in leading the way we collectively tackle the climate emergency and, globally, we have committed to achieving Science Based Targets initiative (SBTi) verified net zero emissions by 2040. Our long and short-term carbon reduction goals have been approved by the SBTi and we will achieve carbon neutrality in our UK operations in 2025. In October 2020 we also committed to halving the carbon footprint of designs and advice provided to clients by 2030, a first in the engineering consultancy sector. On this trajectory, we have received external PAS2080:2016 accreditation, the global specification for carbon management in infrastructure, which assures our capacity and competence to apply requirements of the standard to infrastructure projects requiring carbon management.



The Future Mobility team within WSP are a marker leader in providing technical and advisory services across the Electric Vehicle (EV) and Mobility sector, offering expert advice to public and private sector clients. The team have provided responses to questions addressing Government approaches to EV, the overall state of the market and ability to acquire an EV, the consumer experience of using an EV and finally national and regional issues on EV.

Government approaches

4. 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?

With EVs becoming more prominent and the UK edging closer to phasing out the sale of ICE vehicles by 2030[1], now might be the time to switch the focus away from emissions, towards the repurposing of road space. EVs are likely to succeed in reducing most emissions (and may bring other full lifecycle emissions) but there will continue to be space issues surrounding private vehicles, as despite numerous interventions, many cities are still designed in a way which is dominated by the private car.

This is especially problematic in the case of cities which are becoming more and more overwhelmed with urbanisation. This is applicable to many UK cities, with England alone having a 6.6% increase in urban population between 2011-2020[2]. As a result, recent interventions, such as Dynamic Kerbside Management and Kerbside Strategies, have focused on the reallocation of urban space to provide a more liveable environment. In addition to the sector changing, we are also going through demographic changes that are impacting transport decisions. The younger generation are now considerably less likely to own a car and the continued improvement of sustainable transport alternatives can only enhance this trend. The sector is also impacted by the way society has been influenced by the COVID-19 pandemic, where trends of home working and less travelling have become prevalent. Home working and hybrid working peaked during the pandemic, but the trend appears to have levelled out as throughout 2022 the percentage of adults reporting some level of working from home has varied between 25% and 40%, without a clear upward or downward trend[3].

There can be a lot of misleading information about EVs, but consumers and drivers are subject to confirmation bias and will read statistics, data and reports that back up their own individual world view. News surrounding EVs is unlikely to break down any barriers, however, listening to trusted sources – of which can come in the form of individuals, members of industry or news outlets. From WSP’s perspective, successful change can be delivered through local actors and independent bodies and it is these who should take the lead on delivering the key messages.


5. What is your view on the accuracy of the information in the public domain relating to EVs and their usage?

Accurate and comprehensive data on EVs, charging behaviour and chargepoints is not currently available. This makes it difficult for local authorities, the private sector and investors to enact evidence-based planning and forecasting of EV infrastructure needs.

A combination of national level data collection and legislation mandating the sharing of data by CPO operators would be beneficial. The proposals in the draft “Public Charge Point Regulations 2023” would be a positive step forward in this regard.

Some examples of datasets currently unavailable but which would be valuable include:

There are some notable exceptions where high-quality data is being recorded and made publicly available. They represent best practice. These include:


EV Market and Acquiring an EV

12. What is the future role of L-segment and personal light electric vehicles, and how will that impact car ownership and usage? What is inhibiting their uptake?

There is a significant role for light electric vehicles in filling gaps in public transport provision, and as a first/last mile mode to connect to public transport corridors, expanding their catchment, and enabling end-to-end journeys to be made more easily without a car. Some of the most successful shared micromobility schemes in the UK have been in location such as Bristol[4], where e-scooters/bikes have been able to satisfy the latent demand for travel, previously constrained by a lack of mass transit and/or urban rail provision.

E-bikes are experiencing rapid growth in sales[5] and in usage via on-street public hire schemes[6]. This is accompanied by an increase in e-scooter use (both legal and illegal), and together they are demonstrating strong potential to replace local journeys of a few miles or less, a considerable proportion of which are still made by car[7]. The lack of appropriate legislation around light electric vehicles for personal mobility is resulting in many unrestricted and often unsafe vehicles appearing on our roads, spurred on by the difficulty in enforcing non-compliant and modified vehicles.

There are additional risks associated with charging of unregulated batteries and the resulting battery fires, leading to many property managers banning such vehicles from their premises. Regulation and more rigorous certification are needed very soon to appease concerns from industry and amongst insurers, whilst also allowing quality manufacturers to sell their products to legal users and discourage cheap imports from abroad.

One of the barriers to modal shift away from car and towards more sustainable forms of mobility such as cycling, is the need to carry cargo such as heavy shopping bags, and/or small children who are too young or inexperienced to cycle on their own. In countries such as Denmark and the Netherlands, e-cargo bikes have been proven as a versatile and effective means of personal mobility combining the sustainable credentials and congestion-busting benefits of an e-bike, with the versatility and cargo carrying capacity of a larger vehicle. E-cargo bikes are still quite a novelty in the UK, where despite increasing usage in the parcel delivery sector, use by people for utility and leisure trips is still extremely low.

EAPC legislation would also benefit from reform to focus purely on speed limitation as opposed to power. Many of the emerging e-cargo bikes being used by businesses in place of cars and vans are struggling to tackle larger hills when carrying cargo because the torque that is available from a 250W motor is often insufficient. This is limiting the competitiveness of e-cargo bikes in cities such as Bristol, Bath, and Sheffield where some areas of the city can become inaccessible. Furthermore, whilst e-cargo bikes are permitted on cycle routes, many are unsuitable for larger cycles (including many adapted cycles used by people with reduced mobility), meaning they can get stuck in the same traffic as the cars and vans we wish to replace.

An additional category of electric vehicle, which might encompass quadricycles and compact golf cart-type vehicles, would open the door to a new user class to provide a more space-efficient alternative to small cars and vans. This might resemble the Voitures Sans Permis (VSP) which have long been popular in France, which enable users to drive vehicles limited to 45km/h and 8hp. This would be particularly transformative in urban logistics as a mid-sized vehicle category between an e-cargo bike and an electric van, and perhaps in rural areas where local trips between villages and hamlets can be made with minimal impact, whilst providing greater versatility than a bike.


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?

The latest SMMT (Society of Motor Manufacturers and Traders) figures published in August 2023 showed the UKs used car market rose by 4.1% during Q2 of 2023, the equivalent of over 1.8m vehicles changing hands. Consensus from various industry news outlets is that the used EV market is growing at a healthy rate but there are still barriers to entry, particularly in battery state of health checks.

The main concerns in the second-hand EV market are fears of poor battery health once a consumer has purchased their second-hand EV. In addition to this, a clear disconnect has been identified between driver's perceptions of EV running costs and reality. Knowledge gaps, especially for new entrants to the EV market can make it difficult for those wanting to make the transition to an EV car.

WSP believes some solutions to overcome such barriers include:

The second-hand EV market is still very much in its infancy but more support in providing the right information and educating potential new entrants to the market, whilst supporting more accurate battery state of health checks will be key in making significant progress in achieving successful EV transition by 2030.


16. What is the value and role of alternative transport models such as car clubs and micro mobility vehicles in the Government achieving the 2030 phase out date, and how should the Government consider their roles and opportunities for use in transport decarbonisation?

Firstly, on the subject of micro-mobility vehicles, the government should seek to declare their position particularly on the legality of e-scooters, to avoid any further uncertainty on their legal status as a road vehicle. Whether this is through the adoption of a new vehicle classification or alternative, this would allow more people in dense urban areas to shift away from private car use and onto light electric vehicles (e-scooters, e-bikes). Doing so could reduce car dependency, reduce congestion, and reduce harmful CO2 emissions. It could mean less stress placed on households as there won’t be a need an inevitable transition away from their ICE car in the lead up to the 2030 phase out if they remove their car in favour of other modes of transport.

Car clubs forms part of the mobility mix that should be essential now and, in the future, particularly with the 2030 phase out date on the horizon. According to the Energy Savings Trust[8]:

Some case studies have been identified which provide key evidence in the ongoing need for car clubs and the opportunities for providing travel to those with disabilities. Car club providers and operators allow personalised service offerings, for example – Co Wheels has a ‘Free Buddy Scheme’ should disabled users have a Blue Badge permit. Users can set up an account with Co Wheels and add up to three Buddy Drivers free of charge. Co Wheels offers a promo code where the users will not be charged the £25 application fee or the £5 monthly membership for up to three drivers. Then when members need the Buddy to drive them, they can book the car which will be charged to the disabled member account. Disabled members of Enterprise Car Club can nominate someone as a surrogate driver as long as they have a valid driving licence. The members can become a (non-driver) member with up to 3 appointed people as the driver on your account, and Enterprise will remove the standard membership fee for these drivers. The surrogate driver will be issued with their own membership ID and any usage fees relating to their reservations will be debited from the payment source the disabled member provides as the account owner.  

Incentivisation and rewards programmes that benefit those who participate in car clubs, have found success at an individual and organisation level, but more support could be given to drive successful behaviour change forward at a larger scale. Research conducted by Zipcar has shown that its own car club members are 30% more likely to walk, cycle or take public transport to get to work and 50% less likely to drive overall”. This leads to fewer cars on the road, fewer trips made and a reduction in CO2 emissions.


Experience of using an EV

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?

The draft legislation text of the Public Charge Point Regulations is a major step forward.

By acting as a minimum national standard, WSP anticipates the regulations will particularly assist local authorities procuring public charging infrastructure, especially those still developing the depth of technical knowledge needed to write rigorous technical specifications and Key Performance Indicators (KPIs) to ensure good customer service. Currently, the quality of service and data variability between local authorities is highly variable.

WSP is satisfied that the regulations cover many of the crucial areas where we have seen insufficient progress and innovation in the market, namely contactless payment, reliability and reliability for rapid chargepoints. However, we are aware that the length of time elapsed since the initial consultation in 2021 and the enforcement dates of some requirements, and the lack of associated technical guidance for chargepoint operators, has caused frustration across the sector, especially given the current rapid growth of the network.

We are concerned by the weakened standards on reliability since the consultation, especially the major omission of any standard for chargepoints below 50 kW.

In addition to the regulations, WSP suggests that further work is needed in areas such as consumer protections. Implementation guidance on BSI PAS 1899 Accessible Charging Specification for local authorities and other landowners would also be welcomed, especially on the division of responsibilities between landowners and chargepoint operators, and ensuring compliance is independently assessed.


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? (Anna/George)

WSP’s assessment of the draft requirements is that it would enact a positive change which would have benefits for consumers, industry and local government.

The impact on the EV charging experience for consumers would be positive. Real time location and availability of all public chargepoints will be beneficial to drivers. Assisting with journey planning and improving range anxiety. Making the data freely available will also allow potential innovation, such as integration into MaaS (mobility as a service) apps.

For industry it will improve the ability to forecast EV uptake and charger requirements, which is essential if they are to carry out data led planning of EV charging rollouts and investments.


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? (Anna/George)

These groups of current and prospective EV drivers face significant barriers in the transition to EVs, during WSP’s involvement in the procurement of public charging infrastructure on behalf of local authorities and supporting developers.

Low affluence: Areas of low affluence risk under provision of public charging infrastructure in the near term, especially outside of London, depending on the nature of the data modelling undertaken by CPOs to select installation locations. As part of our support to local authorities, WSP ensures appropriate safeguards and review processes are in place to ensure an equitable distribution of installation sites are taken forward, but this relies on the continued availability of grant funding to subsidise these locations.

Sufficient capacity and capability within LAs are also needed to independently assess and if needed, challenge, the selection of sites proposed by CPOs.

The pressures from OZEV to maximise private sector investment secured as part of the Local EV Infrastructure Scheme and On-Street Residential Chargepoints Schemes and to increase chargepoint utilisation rates often seems to be in tension with the strategic role of the public sector to focus on areas in greatest need of subsidy, such as lower income areas.


Multi-occupancy buildings: In multi-occupancy buildings, there are several barriers to installing charging infrastructure:


24b. 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?"

It is vital that a just transition to zero emissions mobility is achieved. Significant progress will need to be made to ensure that this occurs.

Using a domestic off-street charger is generally the cheapest and most convenient way to charge an electric vehicle. However approximately 30-40% of households in the UK do not have access to off-street parking where they could charge a vehicle. For drivers without a home charger, they are reliant on the public charging network. There are three disadvantages to this situation, the cost of tariffs is higher, access to these facilities within a short distance of the home is currently limited and for those with mobility issues the design of chargepoints is often a barrier to use.

Accessibility: There are currently barriers to drivers with disabilities and mobility issues from using public chargepoints which are imposed through the design of equipment and layout of charging bays. Examples include screens which are too high for wheelchair users to view, cables whose weight makes them unmanageable for some users, and bays laid out without sufficient space around them to allow wheelchair access to the chargepoint.

Availability: The majority (~90%) of EV drivers currently have access to off-street charging where they can charge a vehicle and carry out the majority of their charging at home. However, in the population as a whole around only 70% of households have the same access to off-street charging. Therefore, the number of drivers dependent on the public chargepoint network for all charging is set to increase.

The current network of EV chargers does not provide equal access to chargepoints.  Units are mostly focused in areas of known demand where CPOs can ensure that the highest levels of utilisation will be achieved. This results in ‘charging deserts’ with no facilities within a reasonable distance of drivers homes, generally defined as a 10-minute walk.

Low affluence and rural areas are least likely to have the public charging infrastructure which will allow those without off-street parking to charge a vehicle. Similarly, a lack of en-route charging facilities can inhibit travel by EV into an area including visitors, deliveries, tradesmen, taxis, and tourists.

Solutions to this issue could include continued grant funding of new chargepoints, mandatory targets for local authorities and nationwide monitoring of progress towards these targets.

Cost: The cost of charging at home is significantly cheaper than using commercial public chargepoints. This presents an equality issue where drivers without access to a domestic home chargepoint will have higher fuel costs overall. Whilst it is expected that the cost disparity between home and public charging will always exist, the difference between the two could be reduced. One action would be to reduce the rate of VAT levied on public charging from the current rate of 20%, to be equal to the lower rate of 5% levied on home charging domestic energy tariffs. Further tax changes or subsidies could level the playing field.



National and regional issues

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

Distribution Network Operators have a crucial enabling role.

WSP would like to see several improvements by DNOs in how they interact with local authorities and other landowners to allow the timely roll out of infrastructure, such as:

31. What are the requirements, challenges, or opportunities for the development of public charge point delivery across the UK?

WSP works with local authority and private sector clients. Through this work we identify and provide solutions to overcome the challenges of delivering public charge points. We are also able to quantify the decarbonisation and air quality benefits, as well as the revenue and investment opportunities.

Key challenges which require government intervention to overcome include:

Trailing cables: The trailing of charging cables across the footway from home chargepoints to vehicles is now prevalent across the UK. Often a cable protector is used to minimise the trip hazard. A minority of councils have proactively defined a policy on this practice, both permitting and banning trailing cables. However, the majority have not. The reason being is that there is ambiguity about the legal position and the possible liability that councils could incur.

The risk of no action is that the behaviour amongst drivers will become entrenched and careless deployment of trailing cables will result in trip hazards and inhibit wheelchair users and those wheeling push chairs from using the footway. Clear national guidance on trailing cables would allow councils the clarity they require. Allow enforcement where required and clear policy and rules for safe application of cable protectors where appropriate.

Power connection: A major challenge when deploying chargepoints is the need to establish a connection to the local power grid. The cost of upgrades can be prohibitive and the time scale for those upgrades to be implemented can introduce long delays. This is particularly challenging for commercial rapid charging providers who have the greatest power requirements and require equipment to be generating income as soon as possible to ensure a return on investment.

31b. How will the development of EV charging infrastructure in the UK interact with existing planning regulations?

Existing planning regulations are currently having a mixed impact, depending on the type of EV charging infrastructure.

For the development of rapid and ultra-rapid charging hubs, the planning system is currently acting as a barrier, increasing costs, and delaying installations. As a result, the private sector is prioritising efforts to secure as many of the best sites as possible (and to mitigate the risk that some sites won’t achieve planning consent). A fast-track or accelerated planning regime is needed, one that recognises the urgent need for more charging hubs whilst ensuring high quality design and is in keeping with the planning policy for the area.

For new developments, the updates to building regulations to require chargepoint provision (Approved Document S: Infrastructure for charging EVs) have been beneficial in some respects, helping to standardise minimum requirements across planning authorities. However, they are only intended to be used as building regulations and yet they are often conflated with a planning policy requirement (particularly for local authorities that lack specific EV policy for new development). This leads to the placement and installation of EV charge points that lock in car ownership (i.e., encourage on-plot charging). If we are to achieve net zero, we need to recognise the potential for new communities that can benefit from communal charging hubs supported by smartgrid, battery storage and solar that serves the community as a whole. Implemented correctly, this could reduce the overall energy requirement for the development, lower energy bills for end users, encourage car sharing and alternatives to using the private car.

The Building Regulations are also unambitious in places, such as for commercial developments, and there is the risk that limited consideration is given to the long-term management and maintenance of the chargepoints and the process for converting passive provision into active or operational chargepoints.

WSP believes Transport Assessments for new developments (as a policy requirement) should include an EV assessment study which details the forecast EV demand (for all users), likely profile of charging behaviour and the resulting charge points and energy supply needed.

For most on-street, lower-powered freestanding chargepoints and installations in car parks (outside of conservation areas or near heritage assets), the permitted development rights provided in the amended Town and Country Planning Act 1990 and General Permitted Development Order 2015 are sufficient. However, the regulations did not anticipate the use of pavement cable gullies or channels to connect a private home chargepoint to an EV parked on-street. An amendment would be valuable to ease the deployment of this otherwise low-impact, low-cost intervention.

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?

Over the last few years, WSP has observed a substantial increase in the ambition of local authorities in relation to EV charging infrastructure. This has been driven by climate emergency declarations, the clearer allocation of responsibilities in Taking Charge: A national strategy, anticipation of revised requirements for Local Transport Plans, and the scale and per-authority allocation approach of the Local EV Infrastructure Fund.

WSP believes local authorities have a crucial role to play due to their land ownership of highways and key land assets, understanding of community needs, and focus on securing equitable distribution of charging infrastructure, complementing private sector led provision.

We anticipate an acceleration of the current trend of local authorities moving away from actively managing chargepoints (through subcontractors) and providing subsidisation (through grant funding) towards a facilitation role, where public chargepoints are deployed and manged through long-term concession or lease agreements which leverage private sector funding.

We except local authorities to work with Distribution Network Operators to undertake early, high-level assessments of potential installation locations, such as through online mapping tools offered by DNOs. However, CPOs are generally better placed to undertake the detailed engagement and site assessments needed, on behalf of the local authority.

As planning authorities, local authorities are likely to play an increasing role in the approval of rapid and ultra-rapid charging hubs, where these are not categorised as permitted development. National guidance for planning authorities, landowners and chargepoint operators on regulatory requirements and best practice would be welcomed. Enhanced powers (related to rapid and ultra-rapid charging hubs) in a similar style to the government’s action plan for Nationally Significant Infrastructure Projects (NSIP) which would streamline the planning process in support of economic growth and helping to achieve Net Zero could be explored. 

33b. How can government best support local authorities in their roles?

The LEVI Pilot Schemes, LEVI Capital Fund (subsidises the installation of lower-power chargepoints) and LEVI Capability Fund (to grow expertise and capacity within councils) have been highly successful at galvanising action by local authorities, including those previously resistant or cautious about applying to the On-Street Residential Chargepoint Scheme (ORCS).

To support local authorities to fulfil their strategic ambitions, a continuation of these schemes beyond 2024/25 would be highly valuable, with the expectation that the Capital Fund would be increasingly tightly focused on areas of market failure, such as rural areas. An update to Taking Charge: The EV Infrastructure Strategy to reflect the evolving roles of local authorities and nature of any grant funding would enable longer-term planning.

Many authorities have also benefitted from the independent technical and commercial guidance being provided by the LEVI Support Body. The continued development and updating of this content through the project lifecycle would directly support local authorities, reducing duplication of effort and facilitating the sharing of best practice.

Innovation: Whilst the range of technologies for public EV charging has expanded and matured over the last 5-10 years there remains potential for innovation, especially in the field of on-street charging. Further funding for innovation will allow local authorities to continue to trial new technologies and establish best practice which can be applied across the UK.

DNO connections: Establishing DNO connections for chargepoints poses a significant barrier to local authorities implementing chargepoints. There are multiple difficulties including cost, timelines, availability of guidance and the difficulty of obtaining quotes. More support for local authorities to remove these barriers would accelerate the rate at which chargepoints could be deployed. In particular, access to self-service online tools where detailed quotes and guidance could be obtained would be beneficial during the planning and site selection phases. These are provided inconsistently across the various DNOs.


[1] DfT. Office for Zero Emission Vehicles. 2021. Outcome and response to ending the sale of new petrol, diesel and hybrid cars and vans. [online]. Accessed 19th April 2023. Available from: https://www.gov.uk/government/consultations/consulting-on-ending-the-sale-of-new-petrol-diesel-andhybrid-cars-and-vans/outcome/ending-the-sale-of-new-petrol-diesel-and-hybrid-cars-and-vansgovernment-response

[2] Department for Environment Food & Rural Affairs. 2021. Statistical Digest of Rural England Population. [online]. Accessed 19th April 2023. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/102881 9/Rural_population__Oct_2021.pdf

[3] Office for National Statistics. 2023. Characteristics of homeworkers, Great Britain: September 2022 to January 2023. [online]. Accessed 19th April 2023. Available from: https://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/employmentandemployeetypes/articles/characteristicsofhomeworkersgreatbritain/september2022tojanuary2023

[4] https://uwe-repository.worktribe.com/preview/10901686/West-of-England-E-scooter-Trial-Evaluation-Final-Report-v3.6.pdf

[5] https://theelectricfuture.co.uk/blogs/news/the-rise-of-electric-bikes-in-the-uk-electric-future

[6] https://www.como.org.uk/shared-bikes/overview-and-benefits#bike-share-research-reports

[7] https://publications.parliament.uk/pa/cm201719/cmselect/cmtrans/1487/148705.htm

[8] How are car clubs a decarbonisation solution (energysavingtrust.org.uk)