Question

Response

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?

Technically the phase out dates are realistic. The electricity system can cope, the automotive sector can supply enough EVs, and the charging providers can deploy sufficient charging capacity, albeit against some significant public procurement barriers when it comes to deploying on-street chargers in particular. We believe supporting this on-street component of the charging ecosystem is crucially important.

As we've seen with recent anti-EV alarmist reporting in media outlets such as The Sun and The Daily Telegraph, public support for the transition is undermined by gaps in charging coverage, especially for communities that will be wholly reliant on public charging, i.e., households without off-street parking and the means to install home chargers. This could create a political barrier to maintaining the phase out dates as politicians at all levels come under pressure to delay the phase out dates.

One of the obstacles is public on-street residential infrastructure to provide the equivalent of home chargers for those without driveways, living in rental accommodation or in multi-tenanted dwellings, estimated at 40% across the UK but up to 76% in conurbations like London. The LEVI fund is providing local authorities with huge funding to provide this infrastructure in England, however the roll-out has been delayed while the councils get the funding and go out to market. The structure of the funding requires the councils to build a strategy, apply for the funding, get allocated the funding, build a bespoke procurement exercise, and then go out to the market. The funding is arranged in two tranches of councils, half in 2023/4 and the other half in 2024/5. This slowdown has meant that virtually no councils are going to market at the moment. An additional issue is that councils are looking to procure under long term contracts to maximise the private sector proportion of bids. The private sector has to make investment decisions based on assumptions around the uptake of EVs which is highly speculative at the moment and dependent on policies like the ZEV mandate, ULEZ zones, clean air zones, taxes on road usage versus VAT on charging, and local authorities appetite to help deploy the infrastructure. There is a lot of uncertainty in this fast growing, but nascent market and large investments are required.

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?

Yes. The firm phase-out dates provide the automotive and charging providers with greater certainty of demand which improves their ability to invest.

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?

There is legislation that gives London Councils protection from the fear of implementing a trip hazard when deploying charging infrastructure. London Local Authorities and Transport for London Act 2013 Part 5 - 16 (8) https://www.legislation.gov.uk/ukla/2013/5/part/5/enacted specifically indemnifies the council from trip hazards. I’m not a lawyer but as I understand it, this indemnification isn’t available to councils outside of London. Extending this legislation would encourage non-London councils to roll-out on-street charging and reduce their risks.

Some councils (Warwickshire and Surrey, for example) are interpreting Section 115B (5) a of the Highways Act https://www.legislation.gov.uk/ukpga/1980/66/section/115B to include charging infrastructure. Councils use s.17's that form part of the consultation process with residents. There is a minimum of 28 days for residents to respond and raise concerns/objections. Any objections then have to go to a cabinet member to see if the complaint can be upheld or rejected. If the government is aiming to install 300,000 of these charge points, then this will result in consultations to millions of residents, and the councils work in managing these consultations. It is also opening up the possibility that residents who want the charge points installed will not be able to get one because of the objection of their neighbours. It would be really useful if the government could clarify to councils that charging infrastructure does not fall under Section 115B (5) a of the Highways Act.

There is no specific legislation to compel council to provide charging infrastructure.

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?

There is a large and growing voice from parts of the media, possibly with an eye on large fossil fuel advertisers, to produce inaccurate anti-EV articles. The government does run nudge advertising campaigns for other aspects of public life. Campaigns with the backing of Government, explaining the benefits of the transition to electrifying transportation, dismissing the myths and explaining the imperative in the context of climate change, would be invaluable.

Additional investment in a strategic country-wide implementation plan for the deployment of infrastructure and support services like servicing of electric vehicles, battery manufacturing, MOTs for EVs, driver education, etc. would improve the speed of transition. At the moment, for example, local authorities are procuring single figure up to low thousands of on-street residential chargers, consulting with residents for each installation, requiring individual costly permits for each installation, on a street-by-street basis, with each council having a bespoke procurement process, a bespoke permitting, consultation, and implementation process. If the cost of the hardware is less than £1000, the cost to the supplier for permitting can be several hundred pounds, the costs to dedicate a parking bay is several thousand pounds, and the return on the equipment is measured in pence per kWh, the economics mean that deployment is slow and sparce.

5

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

Certain sections of the main-stream media, including The Sun, Daily Mail, Daily Telegraph, and even the BBC, are producing negative or biased coverage, pointing out incorrect and inaccurate evidence about EVs and the voices of the sensible are being drowned out.

7

What are the likely costs that will be faced by consumers as a result of the Government’s phase-out dates for non-zero emissions vehicles? Are there policies or initiatives that the Government could use to specifically target barriers arising from unpredictable costs to the consumer, for example significant fluctuations in the cost of electricity, changes to road taxes, or the introduction of low emission zones?

Drivers are accustomed to petrol and diesel prices changing frequently. Even with today's volatile wholesale power market, public charging operators tend not to change their prices to drivers as frequently as petrol forecourts. We do not see fluctuations in the cost of electricity being a barrier to EV adoption.

Drivers that can only charge on public networks face unnecessarily higher costs due to the discrepancy in how VAT is applied to domestic and commercial electricity use. This disadvantage may slow the adoption of EVs amongst this part of the community.

Overall, we believe most drivers should see a reduction in driving costs, especially if they can undertake most of their charging in the lower cost periods of time of use electricity tariffs. Public on-street networks like char.gy offer drivers much lower prices for overnight charging. Our rates currently deliver 25% and 50% savings compared to the average cost of charging on AC and DC networks respectively (source: Zapmap Price Index). Only long dwell charging options such as on-street chargers can offer this benefit to drivers which is why on-street low power charging should be prioritised for residential areas.

Low emission zones and pollution-based parking fees seem to rapidly increase adoption of EVs.

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?

This sector will fill a gap between walking and mass transit. As a lime bike subscriber, living in London, I use the service frequently but almost never to replace a car journey but rather to reduce the time I take on a public transport journey by cycling rather than walking or making different inconvenient connections.

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?

The market has, in effect, already adopted CCS as the single standard for DC (Rapid) charging and Type 2 / Mennekes for AC (long dwell / low power) charging for the UK and Europe. We don't believe there needs to be any additional local regulation on this element of the technology.

Wireless charging has not yet coalesced around a similar standard, but the technology is immature and the UK market is too small to influence the industry. This is also unlikely to be a material factor in meeting the 2030 targets.

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?

With one exception, we agree with the regulations as drafted and believe they will build consumer confidence in the UK's public charging infrastructure.

The exception is the requirement for contactless payment terminals for AC chargers.

Until the threshold was raised to 8kW, the regulations represented an existential threat to the deployment of sufficient affordable on-street charging for communities without home charging. In our assessment, the high running costs of contactless payment terminals suitable for unmanned locations like charge points would have further penalised drivers with an extra 3-4p/kWh - roughly £70/year for an average driver. This would have further widened the "driveway divide" between people who can charge on their home electricity supply and those who cannot.

We believe the process to develop the regulations did not sufficiently consider the use case of public AC charging. A proper assessment of how drivers use on-street charging would have revealed how contactless payments are redundant for these drivers. As these drivers use on-street charge points as their proxy home charger, repeat use is high. Payment methods such as accounts, apps, web pay, Apple Pay and Google Pay better serve these drivers in these locations. Contactless payments is also a short-term issue for AC charging. It will soon be redundant as the Plug & Charge standard is adopted by car manufacturers. This will eliminate the need for manual payments on networks that drivers use often.

This near miss illustrates how regulations need to be developed with the charging industry to fully understand the market impact.

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?

We already publish the live status of our charge points on our own channels (app and website) and via consumer apps such as Zapmap.

25

Is there a financial benefit to the consumer of choosing an EV over an ICE vehicle? Are there further benefits, aside from financial, that a consumer may gain from EV use?

Total cost of operation (purchase + running costs) should be substantially lower for an EV vs an ICE. The elevated cost of electricity seen recently has reduced the differential. Assuming EV drivers can access time of use tariffs for the majority of their charging, they should enjoy significant long term financial benefits. This includes driveway-less drivers using on-street AC chargers.

29

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

As we specialise in low power AC charging and our model encourages drivers to carry out most of their charging overnight when national energy demand is low, we believe our form of public charging makes good use of underutilised grid capacity. In other words, our model can help the grid accommodate more EVs.

However due to the condition of LV cables in streets where more on-street charging is needed, local distribution networks occasionally limit the charging capacity installed per street. We believe distribution networks should begin a cable renewal programme to ensure Britain’s streets are capable of handling higher electrical loads as transport and heating electrify.

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?

A lightweight off-the shelf planning process for all councils for public consultations - ideally digital, low cost and tightly time-bound. Resident or CPO requests a location, digital notice published, and objections raised for a very narrow list of reasons within a tight timeframe and location gets accepted.

32

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

Research and market behaviour shows that EV drivers do most of their charging at home. Those without private home chargers will need local public charging to make living with an EV an appealing prospect.

As with any shared public infrastructure or service, population density is a driving factor in the ability of commercial operators to deliver the service to the public and maintain low prices. Higher footfall leads to greater utilisation which helps spread fixed costs (e.g., hardware, maintenance) over more usage.

As a specialist on-street charging provider for residents without private home charging, we believe we can serve most urban and suburban areas with convenient local charging (within a 2-minute walk of home) at very competitive prices.

As most rural locations cannot offer high utilisation potential from residents, commercial charging providers may need long term support to offer charging services at similar prices to urban & suburban locations. This could be modelled on a universal service obligation fund as per the postal service or the levy called "Assistance for Areas with High Electricity Distribution Costs (AAHEDC)" from the electricity market. These mechanisms help ensure rural communities are provided with the services they need for modern living at affordable or comparable prices to people in urban & suburban areas.

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?

Local authorities have a major role to play as landowners where charge points can be installed and as the curators of local EV charging and parking strategies.

As an on-street charging provider, we need the permission of councils (in their role as highways authorities) to install our charge points. We work closely with councils to develop deployment strategies to ensure areas of need have suitable charging service provision. This process runs best when councils share more data with us.

Where we can reduce the cost of installation and maintenance, more areas become commercially viable without subsidy support. We have had success working with councils to simplify local permitting rules to significantly reduce the cost of installing charge points. This means we can offer a better service provision (more local) to residents without driveways.

Government can support local authorities by ensuring regulations that local authorities need to comply with, such as the Highways Act, are updated to reflect EV charging requirements.