Written evidence submitted by Brook Green Supply (SEV0081)
Introduction to Brook Green Supply
Brook Green Supply are a non-domestic gas and electricity supplier. Formed in 2016, we offer a range of energy supply products and flexible energy solutions to large industrial and commercial consumers. We bring together a series of services and solutions to support large-scale and complex energy users optimise their energy use, helping to accelerate the transition to a decarbonised energy system. We have grown both in the range of services provided as well as market share, now ranking in the top 6 energy suppliers by volume for electricity and gas to the business sector. Customers include FTSE 100 companies, public sector organisations as well as being the leading energy supplier of volume for Electric Vehicle (EV) public charge points.
Executive Summary
We strongly support the Government’s ambition to accelerate the transition to EVs and the rollout of public charging infrastructure. A comprehensive, reliable public charging network is essential to delivering the Government’s Zero Emission Vehicle (ZEV) mandate and a successful EV rollout. Without it, consumer confidence will stall, regional disparities in charging infrastructure will widen and the EV transition risks failing.
As a supplier of several large charge-point operator (CPO) businesses, EV delivery fleets and EV bus fleets, we are well placed to understand the implications of energy policy on these businesses, and our response focuses on the challenges we are seeing. Our extensive work with our customer base shows that electricity costs represent one of the largest costs and for Electric Vehicle operators and are now a major barrier to electrified infrastructure deployment. The current cost structure and development of policy facing EV operators risks undermining the delivery of a comprehensive and resilient public charging network.
• Ofgem’s Targeted Charging Review (TCR), implemented in 2022, has resulted in disproportionately high standing charge increase for high capacity, low utilisation electricity users, such EV charging hubs. For example, in South Scotland, standing charges for a High Voltage (HV) site increased from £157.43/day to £538.06/day – roughly 244% increase.
• These costs are particularly acute in rural areas, as lower utilisation rates and higher connection costs mean elevated standing charges often render charging sites commercially unviable, holding back rural EV adoption. As a result, investment is being deterred precisely where public charging is most needed.
• Recent increases in non-commodity costs to the electricity cost stack mean EV operators are facing reduced financial benefit from moving from ICE to EV. Examples of the changes include the addition of Nuiclear RAB, an expected 70% increase in TNUoS charges from April 2026 and DUoS increases expected from 2028.
• While the Local Electric Vehicle Infrastructure (LEVI) programme subsidises hardware for local councils, there are no policy interventions directed at addressing high CAPEX for private CPOs or electric fleet operators.
• Government must address the high operational costs for EV operators in order to improve the financial viability of infrastructure rollout. At present, this is only being driven by industry modifications. This is unlikely to deliver the scale of change required.
Government action must be decisive and centrally steered. The upcoming review of public charging costs now needs to drive forward measures to address high standing charges.
a. How effective have Government policies been in driving EV adoption to date, and what further action is required to accelerate take-up?
1. The UK Government’s Zero Emission Vehicle (ZEV) mandate is one of the most ambitious worldwide. We encourage the Government to continue with the ZEV mandate, as uncertainty around targets impacts EV investment and the net-zero transport transition.
2. Whilst all subsidies and support schemes are welcome, ultimately the transition will be suppressed unless some of the underlying electricity market issues are addressed.
3. The implementation of Ofgem’s TCR has increased residual charges for public charging EV sites, particularly affecting chargers in rural areas and areas of low EV adoption. The TCR has had a negative effect on the charge point rollout, and we are concerned about the lack of engagement from government departments on the issue.
4. Standing charges threaten to stagnate infrastructure development, with public and private charge point operators discouraged from securing grid connections accompanied by high fixed DUoS and TNUoS fees.
5. We are aware of a DfT review of public charging infrastructure being planned for this year and we’re strong advocates for change in this area. Separately we have been working closely on DCUSA modifications DCP420 and DCP454, which look to provide targeted support to CPOs. We believe that this should be extended to private fleets.
6. As a wider point, we are concerned that the continued addition of non-commodity costs to electricity bills is significantly increasing the cost of electricity at a time when transport and industry are being asked to electrify. New levies (Nuclear RAB, Energy Intensive Industry levy, British Industrial Competitiveness Scheme) and sharply rising network charges with an expected 70% increase in TNUoS from April 2026, risk undermining the economics of EV charging, particularly for CPOs.
7. The application of VAT remains an unaddressed issue that disproportionately affects poorer households who don’t have access to home charging. Government should equalise VAT on domestic and public charging.
f. What are the most significant factors affecting consumer confidence in EVs, including purchase and running costs, charge point availability, concerns about battery longevity, safety and fire risk, and what are the best steps Government and the sector could take to address them?
8. Charge point availability is a significant factor influencing the uptake of electric vehicles. Individuals who do not have access to private driveways or home charging must rely on public charging infrastructure.
9. As outlined above, due to Ofgem’s TCR, a number of EV charging stations have been rendered financially unsustainable due to high residual charges. This especially affects rural areas due to their smaller populations and subsequent lower EV uptake, as they cannot absorb such high costs.
10. The TCR has significantly increased standing charges for high capacity and low utilisation sites, both of which are characteristic of rural areas. The below data highlights standing charge increases for 4 predominantly rural areas around the UK, from 2021 (pre TCR) to 2026.
• In Yorkshire, a High Voltage (HV) site has seen standing charges go from £180.48/day to £500/day – roughly 174% increase.
• In South Scotland, standing charges for a HV site increased from £157.43/day to £538.06/day – roughly 244% increase.
• In Northern Scotland a HV site witnessed increases from £157.43/day to £392.65/day – roughly 150% increase.
11. Code modifications such as DCP420 and DCP454 (under DCUSA) aim to provide targeted relief to affected sites. However, as these are industry driven, the pace of these changes is limited and the likelihood of implementation is low.
12. Government should implement broader policy changes to address these challenges, such as reversing the TCR for public charge points. Once public charging sites become more accessible and affordable across the UK, more consumers will be encouraged to adopt EVs.
13. Government should also focus on policy that will directly impact and help private EV fleets. These businesses have limited cashflow for site and depot electrification. High and increasing electricity costs provide a barrier and reduce business appetite for investment in upgrading these.
g. What further action is required to ensure that the rollout of EV charging infrastructure facilitates transition at the necessary rate?
14. Currently, EV charging infrastructure facilities face challenges including:
o high standing charges driven by Ofgem’s TCR,
o higher non-commodity costs in the form of levies passed on to the non-domestic segment,
o overall increase in electricity bills – TNUoS charges are set to increase drastically for all non-domestic consumers from April 2026, by an average of 70%. DUoS charges are also expected to rise in 2028.
15. Government must:
o introduce sufficient policy interventions to accelerate essential electrification transitions in order to achieve net-zero targets
o ensure greater certainty in network charges to encourage sector-wide planning for electrification and future high-voltage grid connections
o address standing charge inflation to provide a tangible pro-growth signal and support the UK’s EV and renewables landscape.
16. EV rollout in the UK is fundamentally inhibited by insufficient government investment in infrastructure.
17. The recent allocation of £63m by the UK Office for Zero Emissions Vehicles (OZEV) aims to support the construction of charging depots, private home charging, and workplace charging stations. Nevertheless, charge point rollout ultimately remains restricted by delays in securing grid connections.
18. OZEV identified two primary drivers of this issue:
o an outdated administration process for assessing grid connection applications;
o insufficient reinforcement of the distribution and transmission networks to accommodate renewable energy onboarding and other low-carbon technologies, such as EV charging.
19. Without critical reconsideration of network planning, this bottleneck threatens to delay public charging roll-out and reduce the UK’s capacity to accommodate rising EV sales.
20. Government should prioritise reforms to the grid connection process, placing particular attention on EV charging companies essential for meeting national ZEV targets.
21. High capital costs affiliated withsite upgrades is another core challenge for emerging EV charging companies.
22. EV technology has rapidly evolved over the last decade, along with the need for chargers with improved efficiency, connection standards and charging speeds. The variable market landscape, coupled with the high capital requirements to install a multi-charger depot, prove discouraging for companies considering investment.
23. The challenge is exacerbated by high standing charges and electricity prices; both of which jeopardise the return on investment for EV charging businesses. While some charging companies have resorted to battery storage technologies to profit from arbitrage, this choice is accompanied by higher non-commodity charges and upfront capital costs.
24. While the Local Electric Vehicle Infrastructure (LEVI) programme subsidises hardware for local councils, there are no policy interventions directed at addressing high CAPEX for private CPOs or electric fleet operators.
25. Government must address the high operational costs for CPOs in order to improve the financial viability of infrastructure rollout.
How effectively is the Department for Transport addressing issues in the rollout of charging infrastructure such as affordability, geographic equity, accessibility, administration of funding, and the availability of grid connections?
26. The Department for Transport (DfT) has not effectively addressed these issues so far. However, it is hoped that many of the issues relating to the rollout of charging infrastructure will be addressed in the upcoming review in Q1 of 2026.
27. DfT has a representative in the DCUSA modifications working groups for DCP420 and DCP454, which are actively working to provide targeted relief to affected public EV charging sites.
28. Despite this, DfT and OZEV have not proven to be willing to engage on this issue. Their position is that this issue is being addressed within the DCP420 & DCP454, but we have concerns about the likelihood of success of these modifications. DCP420 has been active for over 2 years, with no clear end in sight. DfT’s position of allowing these modifications to culminate before taking action themselves does not sufficiently prioritise the issue that needs a more immediate resolution. As stated above, to address this challenge, steer from Government is required.
January 2026