Written evidence submitted by The West of England Mayoral Combined Authority (EVS0018)

The West of England Mayoral Combined Authority, established in 2017, covers the unitary councils of Bath and North East Somerset, Bristol City and South Gloucestershire Councils.

The region has a strong history in supporting the delivery of electric vehicle infrastructure, dating back to the Go Ultra Low Cities Programme in 2015, and recognises the critical importance of developing EV charging infrastructure. The Mayoral Combined Authority declared a climate emergency in 2019 and set the ambition to be net zero by 2030. Reducing transport emissions will be critical to achieving this aim. To help accelerate the transition to electric vehicles, the Mayoral Combined Authority has:

• Secured funding from the Local Electric Vehicle Infrastructure (LEVI) fund for the region

• Adopted an Electric Vehicle Charging Action Plan “Leading the Charge”, outlining its plan for adoption of electric charging points across the region: https://westofengland ca.moderngov.co.uk/documents/s7727/Item%2015A%20 -%20Transport%20IP%20 %20Appendix%20A.pdf

In comparison to other regions, the West of England has performed well in delivering additional capacity in this area. However, the region is not where it needs to be in absolute terms and a significant upgrade in the region’s EV infrastructure is needed. This in turn will need further investment to support delivery, which will be essential to meet both the region’s and the Government’s ambitions in this sector.

As a Mayoral Combined Authority, we want to do more to accelerate the adoption of electric vehicles. We recognise the benefits that this will bring in terms of reducing emissions and the potential to create new jobs to install and maintain the charge points. We are keen to work with Ministers, the Department for Transport and Department for Energy Security and Net Zero to deliver this ambition and have responded to your call for evidence in the points below.

1. Does the Department of Transport have a strategy to address the geographical disparities in the availability of EV charging points.

• To date, both the Go Ultra Low Programme and the LEVI fund have involved some element of competitive bidding to receive a share of funding for the installation of public charging points. While the LEVI fund did provide an indicative capital funding allocation on a formula basis across all local authorities for public charging points, the Go Ultra Low Programme only targeted eight city areas.

• Based on engagement with commercial operators of charging points as part of the LEVI project, the private sector will generally operate charging points which are in locations considered commercially viable, with these being in locations that are in urban areas with high levels of car trips, with charging points generally located at retail sites (such as supermarkets) and employment locations. Higher kilowatt charging points are more viable in urban locations allowing faster charging times for vehicles.

• Rural locations tend to be less financially viable for commercial operators as a result of lower usage. As a result, individuals within rural areas have to travel further to reach public charging points, especially for charging points with faster charging times.

• The LEVI scheme seeks to mitigate potential inequities in access to charging, primarily by focusing on on-street provision. However, applying the criteria to rural areas proves more challenging due to their lower commercial viability. Without public investment in the form of subsidies for rural communities, the charging needs in these areas are unlikely to be adequately addressed.

• The grant conditions relating to the LEVI funding can restrict the ability to match against other objectives for the region, including digital connectivity in rural areas where there is an opportunity to address both connectivity to charging points and for broadband connectivity.

• Electrical grid connections are a key constraint for installing public charging points. Proximity to these grid connections can result in higher installation costs where physical distance between the charging point and a suitable grid connection is larger. Electrical grid capacity is also a constraint, especially if considering higher kilowatt charging points. Both these issues disproportionately impact rural locations. This also makes it difficult to provide a standard unit cost for the installation of a charging point. As part of the LEVI project, the West of England Mayoral Combined Authority is working with the local operator National Grid, to better understand local grid capacity constraints. Further investment in infrastructure to support grid connection would enable a higher number of connections to be made or upgraded and / or reflect the higher costs associated with rural charging locations.

2. Are sufficient funds available to support local authorities to install public charging stations.

• The capital funding by the Department for Transport is welcomed. Work undertaken by the West of England Electric Vehicle Action Plan indicates that a 1,863 public charging points are estimated to be needed by 2030 within the West of England. It is anticipated that the LEVI fund – alongside investment from the private sector into charging points will meet this need in the short term.

• However, there remains challenges as to delivery of charging points longer term. There is still a degree of uncertainty regarding Central Governments intentions and setting of targets promoting the uptake of electric vehicles, which has a strong influence on the level of demand for public charging points needed. If Central Government intends to accelerate electric vehicle uptake, then this will greatly increase the demand for charging points above current projections.

• In addition to the provision of capital funding for providing public charging points, suitable levels of revenue funding should also be provided to local authorities. Experience of the LEVI fund within the West of England shows that highly complex concessionaire procurements in a relatively new industry are required to be undertaken, which are resource intensive. Without sufficient funding for resourcing these procurement processes risks the abilities of local authorities in delivering the required number of charging points across the country.

3. The accessibility of public charging infrastructure.

• The British Standards Institute (BSI) Electric Vehicles Accessible Charging Specification (PAS 1899), is welcomed in designing accessible charging point infrastructure. However, there are different levels of the standards above the baseline which are not mandatory which local authorities have to make decisions over in an unclear manner. There is a balance between providing charging points in terms of numbers/locations covered and going above the minimum standards outlined within the specifications to provide high quality infrastructure.

As a result, drivers with disabilities may face additional barriers to accessing charging points.

• On-street charging points remain an issue in terms of solutions to provide charging points for residents that do not have off-street parking spaces. This includes the protection and enforcement of charging spaces for electric charging, as well as the added process and timescales of undertaking a Traffic Regulation Order (TRO) for these spaces, which may attract objections.

• In addition, the lack of well planned on-street charging spaces may mean that residents end up without access to charging points or utilising trailing cables across the highway to charge their vehicles. This may then cause significant issues in terms of obstructions to pavement width and trip hazards for pedestrians, especially when demand for electric vehicles increases. At present, there are no standards for providing cross-pavement charging for onstreet parking, leading to a diverse range of solutions being proposed, which impacts the accessibility of charging solutions for on-street charging points.

4: Additional evidence

• The West of England Mayoral Combined Authority, while being the recipient of funding for the installation of charging points, does not have highway authority powers to directly deliver charging points. Highway powers remain within each of the local authorities.

• Each individual local authority has different standards and processes for the installation of charge points, as well as different priorities in terms of site selection where charging points want to be installed, leading potentially to an inconsistent network of sites across the region. This includes Traffic Regulation Orders (TROs) which are required to designate electric vehicle parking bays.

• As part of the Go Ultra Low programme, a public charging network was set up, owned by four local authorities (Bath and North East Somerset, Bristol City, South Gloucestershire, and North Somerset Councils) known as the REVIVE network. The Mayoral Combined Authority does not have ownership or direct involvement in this network. This has further complicated the procurement exercise due to being set up under different funding arrangements and results in multiple networks in the region, which may be confusing from a user perspective.

• As the result of ‘legacy’ charge point operator from previous funding, and working with multiple highway authorities with different processes, the procurement for charging points is extremely complex. Both funding flexibilities, long term thinking regarding EV charging point infrastructure, and applicable powers to Mayoral Combined Authorities would help in the delivery of electric vehicle charging points.

January 2025