Written evidence from Pod Point (ELV0101) 


Pod Point Response to Call for Evidence on Government Approaches to EV Phase-Out and Adoption


**Executive Summary**


Pod Point is a leading provider of charging infrastructure in the UK, addressing home, work and destination charging. Pod Point is a founding member of ChargeUK.


This response goes into detail that each question calls for. Given the importance of EV uptake for the charging sector, it is not possible to condense the answers to five pages, not least as the questions themselves cover three full pages.


For brevity questions that can be better answered by others have been left. They are 16, 17, 26, 27 & 28.


Given some headwinds, the Government must stay active in adjusting its bonus-malus policy framework to ensure it has the correct incentives for EVs and disincentives for internal combustion engine vehicles to ensure timely EV uptake, fairly and equitably.


The fundamental policy priorities for the Government at this time are as follows:


1.      Maintain the 2030/35 phase out dates, which are achievable.

2.      Immediately confirm the Zero Emission Vehicle (ZEV) Mandate to start from 2024, as planned, to secure the 2030/35 dates.

3.      Act to remove exemptions for fitting active charge points in covered car parks in Multi-Tenancy Dwellings (MTDs) under the Part S Building Regulations and ensure chargepoints are installed in these locations unimpeded both in new buildings subject to the regulations and existing buildings in general.

4.      Advance the delivery of the Rapid Charging Fund (RCF).

5.      Investigate including electricity as a fuel type within the Renewable Transport Fuels Obligation (RTFO) to provide a revenue stream that will speed charging infrastructure rollout.

6.      Reduce VAT on public charging from 20% to 5% to align it with domestic electricity VAT.

7.      Clarify Significant Zero Emission Capability (SZEC) as soon as possible.

8.      Seek to ease planning and regulatory hurdles to public charging rollout, e.g., via Scottish style permitted development scheme for larger charging sites.




**Government Approaches and Phase-Out Dates**


1. What are the main obstacles to the achievement of the Government’s 2030 and 2035 phase-out dates?

There are five effective obstacles to the mass adoption of full battery electric vehicles (BEVs):


  1. Range. EVs must have sufficient range to overcome “range anxiety”.


  1. Cost. BEVs must be comparable in cost to internal combustion engine (ICE) equivalents.


  1. Charging infrastructure. Charging infrastructure of the right type must be easily available and accessible for drivers in appropriate locations.


  1. Choice and availability. There must be a readily available supply of BEVs that satisfy a sufficient number of vehicle segments.


  1. Education and perception. Drivers must understand how to live with a BEV and, in particular, the myriad ways in which they are superior for drivers than ICE cars.


Are the phase-out dates realistic and achievable?

To convert all, or almost all drivers to BEVs will require the above obstacles to be overcome for all, or almost all drivers is not realistic for 2030. However, given that most drivers do not buy new vehicles, and some form of hybrid will still be on sale until 2035 (the Society of Motor Manufacturers and Traders’ (SMMT) indicates that only 20-30% of all passenger cars on UK roads will be BEVs by 2030) the phase-out dates are both realistic and achievable, so long as the Government acts to secure progress. But if certain projects and policies are not implemented sufficiently, there is some risk to the dates.


The 2035 date aligns with other jurisdictions (e.g., the EU) and, as such, has greater momentum behind it. Again, the availability of existing petrol and diesel vehicles will help those who aren’t able to switch immediately continue to drive, whilst the vast majority of drivers should be ready to switch by some time prior to 2035.


If not, what steps should the Government take to make the phase-out dates achievable?

In order of the obstacles, taking a 2030 lens:


  1. Range. No Government action is required on range, as sufficient range vehicles (typically 250 and up to 400 miles on a single charge) are already available.


  1. Cost. At present BEVs cost more than ICE equivalents due to the cost of batteries. These costs have fallen radically since 2010 and some analysts (e.g., Bloomberg New Energy Finance) indicate they could fall to the ~$100 per kWh area where it is possible to make a longer-range BEV at a similar cost to an equivalent ICE by 2026.


As drivers become comfortable using abundant charging infrastructure, many will become comfortable with smaller battery and lower range BEVs. This will further help reduce the cost of BEVs.


Finally, the Government has chosen to remove many direct incentives for buyers of BEVs prior to the market running into headwinds in 2023, predominantly in the form of concerted anti-EV campaigns in publications like the Daily Mail, The Sun, and the Daily Telegraph. The Government should review this position in line with ongoing BEV uptake.


  1. Charging infrastructure. Please see detailed response in Question 21.


  1. Choice and availability. Today there aren’t enough BEV variants across enough vehicle segments, that can be delivered in short enough lead times to fully satisfy consumer expectations.


Conventional automotive OEMs are proving slower to move to electrification than new entrants like Tesla and Chinese OEMs, as they balance electrification with conventional vehicles sales. While some are further ahead than others, clear regulatory indicators like the 2030-35 dates and, critically, the Zero Emission Vehicle (ZEV) Mandate, which enforces a manageable path towards full ZEV manufacture in 2035, act to provide absolute clarity for automotive firms planning their product roadmap.


As such, it is imperative that the ZEV Mandate is implemented, as planned, starting in 2024.


  1. Education and perception. While there is a significant degree of undue negativity in the press at present, the BEV is the best and most convenient form of road car for drivers. Addressing the material barriers listed above will ensure this becomes apparent to the vast majority of drivers, who will want to switch to lower cost, higher performing and more convenient to own vehicles.


The Government may wish to consider educational programmes, but addressing material barriers will be most powerful in ensuring drivers have confidence.


2. Do the 2030 and 2035 phase-out dates serve their purpose to incentivise the development of an EV market in the UK?

Yes, clear dates provide clear incentives for the EV market. Albeit there is a degree of uncertainty regarding what “Significant Zero Emission Capability” (SZEC) means for vehicle sales between 2030 and 2035.


To what extent are car makers focusing on one date or the other?

In combination, the dates make it clear that ZEV is the future of their businesses in the UK, particularly given typical lead times for vehicle development. However, manufacturers will focus on 2030 as a priority and will be keen to learn what SZEC will mean as soon as possible.


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?

From the charging sector perspective, the 2030/35 dates are pivotal in securing investment into our businesses, and thus readying our supply chains and operations to scale sufficiently. Moving either date would be profoundly harmful to the charging sector or must be avoided.


Would the introduction of a plan with key dates and timescales support the development of the EV industry in the UK?

The ZEV Mandate is the policy that achieves what is needed here.


3. What specific national policies, regulations or initiatives have been successful, or have hindered, EV adoption to date?

Plug-in Vehicle Grants have typically been well utilised, particularly the now withdrawn Plug-in Car grant. However, they are expensive as vehicle sales start to scale.


Electric Vehicle Homecharging Scheme (EVHS) and similar proved very successful prior to its withdrawal in April 2022.


The current replacement grants target the likes of Multi-Tenancy Dwelling (MTD) scenarios offer more challenging circumstances and, as such, haven’t proven as successful. That said, the support is very welcome, Pod Point would call for their extension as interest is starting to materialise and they address an area of charging infrastructure that is progressing slower.


Workplace Charging Scheme (WCS) has been a successful grant for some time in encouraging businesses to provide charging infrastructure. It would be beneficial to see it extended beyond April 2024.


Rapid Charging Fund (RCF). While the RCF addresses a key area of need in UK charging infrastructure, to date it has materially hindered rollout by introducing uncertainty that risks private sector investment, causing material concern to the Competition and Markets Authority over competitiveness and having failed to deliver a single charger since the conception of “Project Rapid” in 2019.


Low Benefit in Kind (BiK) Company Car Tax Rates. Very low BiK rates have proved a very successful policy that has meant EV uptake via company fleets has been very significant. These cars have begun to hit the second-hand vehicle market in volume and are making EVs much more affordable for retail consumers. The Government should keep rates under review pending the success of EV uptake in the run up to 2030.


Are these policies or initiatives fit for purpose?

The UK has relatively sparse consumer support for EV uptake when compared to its European counterparts. Some decisions were made prior to the market encountering recent headwinds, and while Pod Point is optimistic that uptake will continue healthily, the Government must not be complacent.


Where the Government chooses to directly fund charging infrastructure (e.g., the RCF or the Local Electric Vehicle Infrastructure Fund) it often has a delaying and/or distorting effect on the market, at least until the fund is activated. The private sector can and will provide a national charging infrastructure. Government help is only required where there is a specific market failure.


In terms of helping the charging infrastructure industry, Government focus should be predominantly on driving EV adoption - and the ZEV Mandate would be the most important current policy in that area.


Grants can be helpful, but since they will be time limited, reductions should be clearly communicated and should taper gradually. Reductions should link to EV adoption.


Government should take a bonus/malus approach where incentives to drive EVs should be accompanied by disincentivisation of polluting behaviour, in particular by:

        Unfreezing fuel duty.

        Implementing carbon credit style models to make fossil fuel providers pay - Specifically reworking the Renewable Transport Fuels Obligation (RTFO) to work properly for EVs and electricity could provide a fund to support charging infrastructure rollout (see Question 7) for further detail; and

        Make VAT on public charging 5%, as it is for domestic charging. The current approach is regressive as it penalises those without access to home charging, who are typically less affluent.


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?

There may be a role for the Government to communicate the case for EVs, in order to overcome the barrier of education and perception. Ultimately supporting material improvements in the availability of affordable EVs and delivering their role in infrastructure provision are most important.


If so, who should take the lead on delivering that?

Businesses and the private sector who benefit from EV uptake should take the lead.


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

Formal information is generally accurate and effective. Several stakeholders, including Pod Point make great strides to ensure useful and accurate information is provided to our customers.


Public discourse is typically centred around existing ICE drivers. This is understandable, but it tends to result in much comment on the availability of public charging infrastructure and the apparent importance of charge time. Private charging infrastructure (home and work charging) is used much more and longer charge time is rarely an issue for EV drivers on a day-to-day basis, as all cars are usually parked anyway.


6. What are the overall environmental benefits that would result from achieving the 2030 and 2035 targets?

While EVs currently have a higher carbon footprint in manufacture, on average this is overcome within the first 2 years of operation in the UK. Focus on decarbonising both electricity generation and EV manufacture must also be maintained. EVs also remove air pollutants from both combustion and almost all from brake disc wear.


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?

As per the answer to Question 1, the higher vehicle costs for EVs are the primary additional cost to consumers. This will be overcome in due course from falling costs of batteries, until such time measures such as the low BiK rates are powerful.


Historically high electricity prices have materially weakened the economic case for EVs, and the Government should be doing all they can to reduce these costs.


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?

The Government should focus on reducing electricity costs and should ensure there is a coherent bonus-malus framework, where those driving ZEVs are incentivised to do so, and those driving more polluting vehicles see additional tax burdens.


In terms of cost, as per Question 1, the Government should equalise VAT on public charging to 5%, the same as domestic electricity to ensure those who can’t charge at home aren’t further penalised.


The Government should also seek to amend the RTFO such that provision of electricity as a type of fuel is within scope. This would provide a revenue stream to support the rollout of charging infrastructure. This is already in effect in several European countries (Austria, France, Germany, and the Netherlands) and works very well within a bonus-malus framework. Should further information on RTFO be required, please contact ChargeUK for a briefing.



**EV Market and Acquiring an EV**


8. What are the main routes for acquiring an EV?

Company car leasing is the most successful route for acquiring a new EV. Due to the success of company leases the 2nd hand market for EVs is becoming more affordable.


Which aspects of these routes are working well, and which aspects could be improved?

The direct-to-consumer retail market for new cars could be stronger, as EVs remain expensive, and consumers are not able to access the potent BiK tax incentives. Those BiK incentives should be maintained for company car drivers, but the Government should keep incentives under review with a view to ensuring sufficient uptake for 2030 is met.


9. What are the main consumer barriers to acquiring an EV, either through purchasing, leasing, or other routes?

Please see answers to Question 1 and Question 8.


10. How is the Government helping to ensure that EVs are affordable and accessible for consumers, and are these approaches fit for purpose?

See Questions 1, 3 and 9.


11. Do you think the range of EVs on offer in the UK is sufficient to meet market needs? Which segments are under-served and why? Why is the UK market not seeing low cost EVs, particularly in comparison to China?

See Question 1.


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?

These segments will thrive as battery costs fall and charging infrastructure proliferates.


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 second-hand market is experiencing a fall in vehicle values as the first vehicles that benefited from very low BiK rates have ended their 3-year leases. This should be seen as a correction to the recent very high second-hand values.


14. What is the relationship between EV leasing and the second-hand market and how do they interrelate?

EV leasing can positively influence the second-hand market by increasing availability and affordability. A strong leasing market contributes to a healthier used EV market.


15. What barriers are there to achieving a sufficient supply of second-hand EVs, mindful that second-hand vehicles make up a high proportion of all vehicles purchased?

Second-hand vehicles can’t be created, they are simply old new vehicles. As such, encouraging new EV sales means a supply of second-hand vehicles is achieved.



**Experience of Using an EV**


18. What are the main challenges that UK consumers face in their use of EVs?

Please see answers to Question 1 and 21.


19. What are the main benefits that UK consumers could realise from using an EV?

EVs are the best road cars. They are the fastest, safest, most sustainable and most convenient form of vehicle to own (so long as the driver has access to the right charging infrastructure), and they are cheaper to run than fossil fuelled alternatives.


20. How prepared are car dealerships, service networks, repairs and maintenance organisations, breakdown services and aftermarket suppliers to meet the growing EV uptake?

Pod Point would defer to those with greater expertise to answer. However, Pod Point does seek to engage and support these stakeholders to understand charging infrastructure.


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

When considering charging infrastructure development, it is important to understand how recharging differs from refuelling.


Core to the convenience advantage of driving EVs is the recognition that vehicles spend the vast majority of their life parked, and it is far more convenient that they be easily recharged during this period, rather than periodically interrupting the infrequent period when they are mobile to refuel. An infrastructure that allows drivers to charge while they’re doing something else is optimal, rather than one that requires deliberate trips to charge. Of course, sometimes vehicles need to drive beyond their battery range, and in these circumstances providing ~200 miles of range in a ~20 minute stop every 4 or so hours is very adequate. However, this requirement is rarer than many petrol drivers imagine it will be.


Together this informed the “Charging Ecosystem” model, a forward-looking projection of where proportions of energy will charge EVs:



Home Charging


Homes with driveways


The most conventional home charging takes place at a house with dedicated off-street parking, where a chargepoint can be installed onto the house’s consumer unit, such that charging is added to the home’s electricity bill. This is a healthy competitive market that is functioning well.


Demand side response services for supporting the grid have the most potential in locations with high dwell times that offer significant flexibility to modulate scheduled charging to optimal periods and home is the most common such scenario. As such, home chargers are where most of the demand side response activity is likely to take place.


Multi-tenancy dwellings (MTDs), shared car parking


There are many shared off-street residential parking arrangements, particularly in MTDs that do not lend themselves to having a home charger wired back to the drivers’ consumer unit. In these scenarios an under-sized communal power supply is used, meaning the charging infrastructure provider must use load management technologies to maximise the number of chargepoints that can be installed on the supply, and offer billing services to identify and directly bill the driver.


There are regulatory and educational hurdles to the installation of communal charging infrastructure in MTD scenarios, particularly in terms of establishing ownership and obtaining permissions, but also that 20% VAT is still frequently billed for what is effective domestic charging, where 5% VAT can be billed instead if the appropriate exemptions are sought.


Furthermore, there is an increased uncertainty regarding fire risk liabilities regarding charging infrastructure installed in covered car parks, as such these installations were exempted from the Oart S Building Regulations. OZEV commissioned a study by Arup which concluded that there is no significantly elevated fire risk from charging EVs, yet this has not resulted in the exemption being lifted This lack of clarity has seen increased unease in the market for covered car park chargers. The Government must work to overcome these unnecessary concerns and clarify that charging infrastructure can, and must, be installed in these locations.


On-street charging


It is possible that on-street charging can fulfil a similar role to home charging. However, with the exception of lamp-post charging (a technology with a hard limit on its scale) it currently has not made significant progress. Due to the constraints of installing in the public realm, costs are elevated, and provision tends not to make commercial sense at a smaller scale.


There are some scenarios where a conventional home chargepoint could work for drivers with on-street parking, where a simple civil engineered solution can ensure the cable does not foul a public right of way (e.g., cable gulleys).


In time, Pod Point believes that there is potential for mass deployment of minimally intrusive street infrastructure that is privately funded. However, this requires a significant increase in the deployment of BEVs to guarantee sufficient utilisation to make the investment viable and a change in the way local authorities approach street infrastructure.


Government may wish to support some technical trials (both for e.g., charging gulleys and/or full-on street charging solutions) and watch developments in this area. But equally, progress can be made much more swiftly in car parks than on-street.


No appropriate home charging solutions


Ultimately there is no one solution for those who can’t home charge. If none of the above options are available, then its best substitute is Workplace Charging. If not, then regular usage of Destination Charging can work well - and has significant scope to scale, particularly in poorly utilised car parking overnight. There is the potential to use high powered chargers in a similar manner to petrol refuelling, but with high infrastructure costs this may prove expensive and inconvenient as drivers must make an additional journey to charge there.


The Government, and particularly Local Authorities, should be seeking to ensure public car parking is equipped with lower cost AC charging infrastructure for local residents to charge easily, particularly overnight, as a priority. The Government should also be encouraging/supporting owners of private car parking, e.g., car park operators, retailers etc, to provide low-cost charging infrastructure for both day visitors and nearby residents overnight as much as possible. Substantial progress can be made here in making EVs viable for local residents without home charging.


Workplace Charging


Pod Point believes Workplace Charging has a very significant role to play, as much as 30% of all charging could take place at work. This will be a mix of slower AC charging for employees and company fleet vehicles, potentially overnight, but also some targeted DC for faster turnaround applications.


Regular Workplace Charging, when combined with public charging, can make private EV ownership viable even without home charging and is critical to decarbonising business fleets.


The Government should consider extending the Workplace Charging Scheme support, slated to end in March 2024, together with maintaining Enhanced Capital Allowances for businesses that install chargepoints and maintaining low Benefit in Kind (BiK) tax rates on electricity provided to employees.



Destination Charging


Destination Charging should take place where drivers naturally tend to park. It should be a background activity that is secondary to a driver’s primary activity in the vicinity of the charger. Charging speeds can vary to match the typical site dwell time, though high-powered chargers do consume grid capacity that can be used for many more AC chargers.


Destination Charging has substantial scope to scale and multiple potential business models have proven viable for deploying charging infrastructure in this environment. It should be noted that high electricity prices have all but wiped out quite common provision of free charging as a loss-leader to attract drivers to businesses. The return of affordable electricity can have a very positive impact here.


En Route Charging


En Route Charging is the most analogous type of charging to petrol refuelling, where drivers seek to extend the range of their EV mid-journey. It must happen while the driver waits, so it must be quick. This means high power, which in turn means high-cost infrastructure. It is critical to ensuring drivers have unrestricted mobility, beyond the range of their car. However, for most drivers, it is needed very irregularly. With high costs and irregular utilisation, correct siting of this infrastructure is critical, and Motorway Service Areas (MSAs) are one such critical location.


At present en route charging provision, whilst better than the general public is being led to believe, is not as comprehensive as it should be. Tesla’s proprietary Supercharger network remains a compelling incentive to buy a Tesla vehicle. Given the huge optical importance of en route charging, this is an area that needs to improve quickly.


The Government has established the RCF to support grid connections into key locations, particularly the MSAs. The RCF is taking some time to have a positive effect, and the knowledge that Government funding is on its way is discouraging private investment. There are also concerns over the competitive landscape in MSAs.


Were Pod Point to design the RCF deployment, the Government would take control of charging provision in each MSA and award a period of exclusive operation of en route charging at individual MSA sites by tender to a shortlist of competent CPOs. This would ensure no CPO owns two neighbouring sites giving drivers choice of who to use and that there is a downwards pressure on price and upwards pressure on standards. Furthermore, MSA Operators (MSAOs) would not be permitted to act as CPOs, as they will already benefit from the significant grid subsidy ensuring the future viability of their sites. This approach would lead to a fair and competitive landscape, understood to be akin to the model in Switzerland, but would be very interventionist. The current approach of seeking multiple providers per site gives huge advantage to incumbent providers, making utilisation risk modelling extremely difficult for new entrants, whilst allowing the MSAOs to compete as CPOs gives them untold advantage as they control the layout of their sites and can give their own infrastructure preferential placement.


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?

Any issues regarding standardisation of sockets are historic. The current use of Type 2 AC sockets with CCS for DC is all but universal, works well and requires no Government intervention.


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?

Pod Point supports and welcomes the draft legislation. While there are some elements that require some clarification (particularly in terms of the reliability requirements, or grey areas on what classes as a public charge point in some edge cases) and there are some minor annoyances (e.g., a full year for the implementation of contactless payment on >8kW AC charge points prior to their first installation would be preferable), the regulations should improve the charging experience for drivers.


OZEV is engaging with industry on remaining issues, and this process should provide needed clarity. It should be noted that the regulations do have significant material impacts upon CPOs on an ongoing basis and will prove challenging to fully comply with.


One priority for Pod Point over the next two years will be to ensure that CPOs retain the freedom to enter roaming agreements on a bilateral basis, where it makes commercial sense. Mandating roaming across all CPOs will reduce the value of CPO’s networks, which will harm certain business cases, thus slowing charge point rollout. Where roaming agreements make commercial sense for each partner, they will flourish.


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?

Making charge point data freely available has the potential to improve the charging experience. Transparency in charging availability and reliability can build trust among consumers. However, the plethora of reporting requirements in the Regulations represent a burden to CPOs.


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?

Please see answer to Question 21 relating to MTD scenarios.


Do you consider public EV charging points to be accessible and equitable compared to home-charging points?

Home charging points are more convenient and cheaper to use than public charging points, although they do have an upfront cost of installation.


What can be done to improve accessibility and equitability?

Much greater provision of a mix of alternative charging infrastructure is the best way to improve accessibility in general. The industry is working with stakeholders to consider accessibility for disabled drivers, for example PAS1899 contains excellent thinking in this area (though its binary pass/fail nature and countless requirements make it wholly impossible to mandate in its current form).


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?

Financial benefits of choosing an EV, including lower operational costs and tax incentives, are evident. Additional benefits, such as reduced maintenance and positive environmental impact, further enhance the case for EVs.



**End of Life Disposal of EVs**


Pod Point would defer to those with deep expertise in this field (Redwood Materials based in Nevada being one such firm), however recycling of batteries is proving hugely exciting, where only tiny proportions of metals are lost in the process.



**National and Regional Issues**


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

Pod Point would defer to the likes of National Grid Future Energy Scenarios but emphasise the huge flexibility inherent within the charging of EVs.


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

DNOs are mandated to ensure electricity is provided to their customers within certain voltage bounds. Anything they require to do this can be billed to their customers via network charges. However, it is imperative that Ofgem ensures that DNOs make use of flexibility within charging to minimise expensive grid reinforcement. This can be done by forming and participating in commercial flexibility markets.


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

Please see answer to Question 21.


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

Some elements of charging infrastructure, notable high powered and on-street installations would benefit from a streamlining in terms of obtaining planning and related permissions.


It should be noted that Part S of the Building Regulations introduced in 2022 has compelled an active chargepoint to be installed in every parking bay associated with a dwelling. This has been a very positive policy, though the Government must remove the exemption for chargers in covered car parks, particularly since their “T0194 – Covered car parks - fire safety guidance for electric vehicles” showed there is no material reason not to.


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

The issues are universal - do you have access to off-street parking at home? This is more common in suburban and rural areas, tougher in dense urban areas. Whilst access to public charge points is typically better in urban areas.


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?

The exact role of local authorities is still to be determined, they have some responsibility to ensure there is adequate charging provision in their area, but equally it is the private sector who should be doing most of the infrastructure provision. The LEVI Capability Funding providing resources to local authorities to consider these issues is a positive recent development.



**International Perspectives**


34. What are the successful approaches to the rollout and uptake of EVs in other countries, and what can the UK learn from these cases?

Pod Point would highlight the success of ZEV Mandate policies in California and British Columbia and considering electricity as a transport fuel within the RTFO mechanism in Austria, France, Germany, and the Netherlands are great examples to learn from. Scotland has implemented permitted development rights for certain larger scale charging infrastructure projects that should be copied on a UK wide basis.