Written evidence submitted by Transport for the North (EVS0012)
Transport for the North (TfN) is a statutory Sub-national Transport Body (STB) established in 2018. It brings together the North’s Mayoral Combined Authorities (MCAs), Local Transport Authorities (LTAs), business leaders and other partners to advise central government on the investment in infrastructure and services needed to enable transformational growth in the region.
At TfN, our work is underpinned by an extensive evidence base, one gathered in collaboration with partners across the North and nationally. Our Strategic Transport Plan (STP), adopted by the TfN Board in March 2024, sets out how transformation of the North’s transport system is essential to realise the North’s economic potential, improve social inclusion and decarbonise the system.
Our vision is that by 2050 the North of England will have become a thriving, socially inclusive region. Our communities, businesses and places will have benefitted from sustainable economic growth, improved health and wellbeing, and access to opportunities for all. This is to be achieved through a transformed zero emission, integrated, safe and sustainable transport system, that will enhance connectivity, resilience, and journey times for all users. For more information, please visit: www.transportforthenorth.com
This response draws upon the evidence base held by TfN, which is already being used by partners across the North (and nationally) as they develop their plans. It is an established, trusted source of information. As such it could help inform the Committee’s inquiry into progress with the Electric Vehicle Infrastructure Strategy. We would be happy to provide further details if the Committee requires.
TfN’s EV strategy
We strongly advocate the benefits of a ‘whole journey’ and ‘whole network’ approach to investment decision making. Realising the potential of electric vehicles, including delivery of the associated charging infrastructure, requires an approach that harnesses public sector knowledge, working with private sector investment. The scale of delivery goes beyond individual local authority boundaries and benefits from a regional approach.
Utilising our regional analytics, transport modelling and inhouse expertise, we published our Electric Vehicle Charging Infrastructure (EVCI) Framework in 2022. This regional strategy provides a rich place-based understanding of charging need at a previously unmapped geographical scale. In parallel, we also launched an interactive visualisation platform to communicate our findings. These are publicly accessible in order to support our local authority partners, central government and the private sector - enabling effective collaboration and boosting confidence in delivering a rapid and equitable transition to electric vehicles (EVs).
In December 2024, at the request of the Department for Transport (DfT), we completed the rollout of our EVCI Framework to all Sub-national Transport Bodies (STBs) and their constituent local authorities across England. This ensures a consistent and common approach to assessing EV charging requirements in support of the transition to zero emission vehicles.
Also in December 2024, in collaboration with our local authority partners, we produced our EV State of Play report for the North. Providing an update on progress to date, this has fifteen key recommendations that will support an inclusive, fair and sustainable EV transition.
EV chargepoint rollout
Our evidence and tools allow us (and our partners) to monitor and evaluate actual and forecasted charge point numbers at a regional level. Whilst public charge points in the region have doubled over the last years, to around 15,600 (plugs) in September 2024, our forecast currently projects that between 178,000 and 240,000 are needed by 2030, a fifteenfold increase in only 6 years.
Taking a national view, our forecast projects between 395,000 and 730,000 chargepoints (plugs) are needed by 2030. We note that the national EV Strategy set an advisory minimum target of 300,000 charge points. The Environment and Climate Change Committee noted, ‘concerns with this advisory target and an insufficient sense of urgency’ in their 2024 EV Strategy: rapid recharge needed report.
‘Targets’ help define the scale of the market opportunity in response to an identified need. However, there is need for a strong focus on monitoring of progress to actively shape delivery of appropriate infrastructure investments and avoid geographic disparities in terms of coverage and availability. Monitoring must be based on localised intelligence, which is why our EVCI Framework evidence goes further than the national EV Strategy; by taking account of localised factors, resulting charging requirements are split by different charging type, as well as geographic and behavioural differences.
This is why we believe our publicly owned EVCI Framework, strategy and local authority facilitation can support the Government in responding to the NAO’s recommendations which inform this Committee’s inquiry. This includes recommendations for regional demand forecasts to provide confidence for public and private investments; a monitoring framework; and supporting sustained local authority capability post the Local EV Infrastructure (LEVI) programme.
Mitigating geographical disparities in the availability of EV charging points
We note that geographical disparities in the availability of chargepoints is a specific and critical part of the inquiry. Some 22% of the UK’s population live in the North, but at present public chargepoint numbers in the north represent just 14% of the UK total. As can be seen in the below image, a significant challenge exists when comparing forecasted future public chargepoint need with current deployment. Assessments such as this will enable us to monitor any geographic differences in our region, in particular the risk of variances between urban and rural locations.
The ability to charge at home is crucial to supporting the EV transition. Through a partnership with Ordnance Survey, using satellite imagery and spatial data TfN has mapped household level driveway availability for 6.4 million residential households across the north. Results suggest 47% of households do not have driveways, compared with a national average of 40%. This is provided free of charge to our local authorities and we are seeking to produce similar capabilities across England via the other STBs.
As highlighted in our report, charging at home is generally cheaper than via public charge points, a situation exasperated by the VAT rates applied. VAT is charged at 5% on home energy but 20% on public chargepoints. This adds a further barrier to those without access to a private driveway. Recently, cross pavement solutions or gullies have been deemed a solution by a few local authorities that have put in place the necessary processes to allow residents to install them. This has been further encouraged by a government grant toward such a solution and recently issued guidance.
However, this solution is not going to be applicable everywhere, with large numbers of residents still be reliant on public charging. The issue of VAT for charging electric vehicles in its current form is arguably regressive in policy terms and needs to be addressed.
Funding for local authorities to install public charging stations
Our work, complementing national government policy, serves to make the case for a whole network approach. Feedback suggests that TfN, in making our evidence publicly available, has given the private sector increased confidence to explore investment in our region. Importantly, our evidence can also be used to identify areas at greatest risk of the market failing to deliver the required EV infrastructure. This can in turn provide the evidence to justify public sector support such as LEVI to mitigate the risk of geographic disparities occurring.
Using our EVCI Framework, we have calculated that between £3.5bn to £4.9bn private and public sector investment will be required in our region by 2030 to meet forecasted charging point demand: this is over and above the investment required in energy production and distribution.
Alongside our charging demand evidence, we have recently assessed the likely commercial viability of charge point infrastructure investment across different areas across our region. This provides a focus on those localised areas potentially at risk of not having the required provision if the rollout is left purely to the market. This is being supplied to our local authorities to enhance their approach to addressing potential market failures in the delivery of enabling infrastructure which supports the EV transition right across the North.
Monitoring and evaluation
As highlighted in the recent National Audit Office report on public charge points, nationally around £1.5bn of government funding is being invested into local (£450m LEVI funding) and rapid charging (£950m Rapid Charging Fund). As these funds deliver on the ground it is vital, as outlined in recommendation 3 in our report, that their impact is monitored to ensure best use of public spend. We advise that an independent body is set up to monitor, evaluate and provide recommendations on future funding arrangements informed by the outcome of this monitoring.
We support the NAOs recommendations that national Government explore the development of a monitoring framework for the open data it collects through the Public Charge Point Regulations 2023. This will help improve understanding on emerging consumer and operator issues in the charging point market, including where regional variations may emerge. TfN are well placed to use its own expertise, data and contacts to inform such work.
Capacity to deliver outcomes
To order to achieve the transition to EVs it is imperative that government, local authorities and industry partners recruit, train and retain the people that will provide the capacity and capability to deliver investment at scale and pace.
The LEVI funding has been a significant positive step forward in supporting the deployment of the EV infrastructure. We provided advice to national government in summer 2024 outlining issues requiring action in the short term to ensure effective delivery of the LEVI programme. We are therefore pleased to see some of these recommendations taken onboard and the commitment in the Autumn Statement to invest further in local authority capacity.
Local authorities have increased resource and expertise in this area significantly (supported by LEVI capability funding) and are working hard to meet deadlines and reach deployment of infrastructure. However, the resource intensive nature of the LEVI application process means that authorities have used a large proportion of the initial resource funding provided by national government. Capability funding will, in many cases, run out before contracting processes are concluded, potentially impacting on delivery or requiring more funding to plug the gap. Where there is further public investment in developing capacity and capability the process for authorities securing such resource must be simplified.
Our advice also included recommendations on how the resulting capacity and capability is sustained and maximised in the long term - including empowering local partners further to accelerate delivery, simplification of processes, improvements in the way lessons learnt are shared across local authorities and the importance of improving alignment of investment across other relevant sectors, in particular the energy sector. Actions such as these will help ensure value for money and provide longevity of the LEVI programme outcomes.
TfN’s established close working with our energy partners has highlighted concerns whether all the electricity Distribution Network Operators (DNOs) having enough capacity to process the amount of connection requests they will receive. TfN continues to work with DNO’s in the North, identifying and sharing delivery challenges and opportunities through our EV forum and with OZEV, DfT, OfGEM and BEIS. We recommend that this Committee’s inquiry considers what further action is needed to make best use of existing capacity and capabilities across Government departments, delivery bodies and organisations such as TfN.
Accessibility of public charging infrastructure
There are several accessibility related topics highlighted in our EV State of Play report which may assist this Committee. Alongside an adequate network of enabling charging infrastructure, users of charging points want to be confident that they are available, easy to use, and that they feel safe doing so.
Accessibility standards
As described in recommendation 11 of our report, by 2035 it is projected that 2.7m disabled drivers will rely on public chargepoints. This is why we fully endorse the PAS1899 standard. We know from engagement with partners that full compliance can often be a challenge currently and this is why, in consultation with Motability, we support the idea of phasing the mandating of suitable new installations so that compliance grows overtime, and more real-world experience can go feed into the standard itself.
Theft, vandalism and safety
We suggest that a package of measures is required to address this issue e.g. charge point design, signage, CCTV, appropriate positioning, lighting, forensic marking, and enforcement and prosecution. It is also important that such measures can be eligible for public funding.
Maintenance
The Public Chargepoint Regulations 2023 provide measures to ensure customers can be confident that public charging points will be in good working order. This is critical to inspiring confidence in use and uptake of EVs. It sets out that 99% of rapid chargers should be reliable as an average across each chargepoint operator’s network. Consideration should be given to extending this measure across public non-rapid charging networks.
Data and internet coverage
The 2023 regulations also look to ensure consumers can easily locate the right charge point, be confident it is working, compare prices and find it easy to pay. However, whilst user experience is improving it is still too varied and affects the confidence of current and potential users. Also of importance is the ability to use the charge point’s connection and payment system. The vast majority of EV drivers use mobile phone apps to access such chargers, and the chargers themselves also need a signal to function. This relies on having an adequate mobile phone reception or a Wi-Fi hotspot. Research carried out by the RAC suggests that, outside of London, around two-thirds of the public charging points that are 8kW (kilowatt) or below (these are not obliged to provide contactless payment) do not provide adequate levels of mobile data coverage across the four main mobile networks. Making adequate digital infrastructure at charging locations a vital enabling component of supporting a rapid and equitable transition to EVs.
Further relevant recommendations in our EV State of Play report
Several of the recommendations in our State of Play report focus on practical considerations for speeding up the transition to EVs. Importantly these focus on the importance of an equitable transition, one that brings along sections of the population that are either sceptical or face financial challenges.
Recommendation 1 relates to consideration of targeted financial support to provide access to second-hand/lower cost EVs. It is our view that detailed consideration is given to a targeted package of financial support providing access to EV cars by those unable to make the switch otherwise. This could be through a combination of support for purchase of second-hand EVs and greater support for provision of EV car clubs. This will increase the chances of an equitable transition.
Recommendation 2 builds on this further by suggesting a national education campaign that provides trusted information. Again, the focus here is targeting the information at those least likely to switch who are more likely to have sceptical views of the changes taking place. With such an array of conflicting information regarding EVs in the public domain, we believe government needs to provide leadership nationally on this issue.
Recommendation 4 of our EV State of Play report highlights further practical issues with regards to the appointment of Charge Point Operators (CPOs) and speeding up the installation of the chargepoints themselves. As an emerging market it has been necessary to adapt existing processes or develop new ones. However, there is enough experience now to capture lessons learnt and create greater consistency and speed of delivery. For example, consistent contract terms can help create certainty amongst CPOs and support more efficient procurement processes for local authorities. In terms of speeding up installations, we welcome the recent announcement on CPOs being brought into the Street Works permitting regime, meaning they will no longer face the delay of applying for a section 50 licence. We will work with members of our regional EV Forum to understand any impacts of this change and support learnings as they develop.
Recommendation 12 of our EV State of Play report encourages further integration between the transport and energy sectors. Transport for the North (TfN) welcomes the Government’s Clean Power 2030 Action Plan and Ofgem’s Connections Action Plan (CAP) to significantly accelerate alignment of strategic planning and connections. We strongly advocate the benefits of a whole system approach being at the heart of infrastructure planning, and we have embedded this in our way of working across TfN programmes. We share Ofgem’s view that planning for single sectors (or vectors, i.e. electricity) in isolation is inefficient, and whole system thinking is necessary to maximise linkages in policy and decision making.
The existing capacity of distribution networks and future cross sector infrastructure demands is not as well understood as it can be. This therefore makes the level of investment required to meet the future trajectory of demand from low carbon technologies uncertain. New models of working and increasing alignments, especially across sector capabilities, are vital if energy infrastructure is to support the outcomes required across systems which depend on it.
The National Infrastructure Assessment provides a long-term assessment of the energy infrastructure requirements for the UK. The existing regulatory framework provides the mechanism by which investment to deliver that requirement is managed. The key, unresolved, issue is one of timing if the investment in energy infrastructure is to become truly enabling. There have been publicly owned and managed forward funding mechanisms operational in the past that could be provide a potential model in this regard. The evidence base underpinning regional and city-regional strategies increasingly provide a robust basis on which such mechanisms might be established.
January 2025
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