Written evidence submitted by Osprey Charging Network (SEV0101)

Opportunity to give oral evidence welcome

Introduction to Osprey Charging:

• Osprey is the UK’s second-largest public rapid EV charging network, with 1500 rapid and ultra-rapid charging bays across 400 locations.
• Osprey funds, builds and manages this network in partnership with landlord partners and on its own land.
• Osprey locations are a mix of large hubs on major A roads and convenient local sites in towns and cities.
• Our focus going forward is high-power EV charging hubs of 8-16 charge points, at en-route and urban locations. In 2026 we will build 40 of these ultra-rapid hubs.
• Over the past seven years we have invested over £100million (all private) in EV charging infrastructure and will continue to invest over £25million each year between now and 2028.
• In 2026, Osprey ranked 10th in The Sunday Times 100 Tech - Britain's fastest growing private technology companies, for hardware/other tech.
• Osprey fully complies with the Public Charge Point Regulations 2023, enabled by our proprietary software platform Osprey Iris, developed in-house.

Reason for submitting evidence:

As the UK’s second-largest public rapid EV charging network, Osprey can contribute first-hand evidence of the challenges and opportunities facing the roll out of charging infrastructure. Over the past seven years, Osprey have built and now operate high-power EV charging infrastructure for public use at over 400 locations across Great Britain. We provide both large, en-route charging hubs on major A-Roads such as the Devon Expressway and A55 in North Wales, as well as on more rural routes such as coastal Norfolk and Northumberland.

To fund this capital-intensive roll out, we are backed by equity investors who have collectively invested over £100m, and more recently by institutional lenders, with debt facilities of £110m. We have therefore experienced first-hand the impact of government policy and signalling about Electric Vehicles on the sector’s attractiveness to private investment.

1.     Evidence that a stable policy environment, in particular a ZEV Mandate that is not continually revised, is critical for EV infrastructure investment and therefore for charge point roll out and consumer confidence.

EV charging infrastructure is a young sector with substantial investment success and growth potential. Charge Point Operators (CPOs) have invested over £1.5bn to date in the installation and maintenance of public infrastructure, with a further £8bn expected by 2030.[1]

However, it is an early stage market and most CPOs’ revenues do not cover operating costs, and do not make a return on capital invested: CPO businesses at present are loss-making. All depend on external capital for continuing operations and to build the critical charging infrastructure underpinning the EV transition.

At Osprey we have posted losses totalling £22m over three years. In that same time, we invested £60m into public rapid charging infrastructure, entirely met by private shareholders and lenders, who accept that this model is part of investing in a capital-intensive, long-term growth sector.

A stable policy environment is for investment confidence. Changes in direction by governments on key headline policies over the past few years, especially movements to the ‘ICE ban’ date have been harmful to investment.

Investors inevitably look to major policy announcements and changes; they are not necessarily aware of the policy detail (such as the ZEV Mandate ‘trajectory’ remaining unchanged).

Whilst the new Government’s clear re-commitment to the 2030 ‘ICE ban’ was welcome and helpful in providing investor confidence such that we were able to successfully raise £110m of debt facilities, this was by no means guaranteed, especially as the flexibilities of the Mandate were so easily expanded in response to some automotive manufacturers.

The e-mobility sector has the potential to attract significant inward investment into the UK, not just in charging infrastructure but into vehicle manufacturing, associated software and technology, and regional contractors and supply chains for construction and maintenance.

It is more important than ever that the direction of travel to ZEVs is clear and unwavering, underpinned by an unchanged ZEV Mandate and unchanged ‘ICE ban’ headline date.

2.     Evidence that addressing energy costs for Charge Point Operators (CPOs) will bring down public charging prices, supporting ongoing roll out of EV charging infrastructure across all regions and at affordable price points for consumers, thus enabling greater EV adoption.

One of the most significant factors affecting consumer confidence in EVs is the cost of public charging, especially for businesses and individuals relying more heavily on the public charging network. The cost of high-power public charging has a significant knock-on effect on running costs and therefore overall financial sense of switching to electric. There is also a public perception of unfairness, given the relative cheapness of home charging and therefore inaccessibility of some of the benefits of EVs to those without a driveaway.

According to findings from EVA England, petrol and diesel drivers without off-street parking were significantly less likely to consider an EV, with 60% saying they would never do so.[2] Three out of four drivers believe the high cost of public charging is the most significant barrier to wider uptake of electric vehicles.[3]

Action to bring down cost of public charging would therefore ensure the roll out of EV charging infrastructure is actually facilitating the transition: consumer confidence to consider EV relies on the visibility and availability of public charge points, but actual conversion to EV relies on the overall EV proposition being affordable – a more affordable public charging network will convert a wider range of people and businesses.

Affordability of public charging is an issue that could be addressed by Government. This is because it is the 460+% increase in energy costs that have had the biggest effect on prices at public charging stations, and this increase is a direct result of government policy. This is evidenced in greater detail in ChargeUK’s ‘Delivering Affordable Charging for All’ white paper,[4] and below with Osprey data.

Consequently, the Department for Transport is running an accelerated Cost of Public Charging Review, announced in the 2025 Autumn Budget and due to report by Summer 2026.

CPOs pay the following energy charges in addition to paying for wholesale electricity, supplier costs and policies and levies in their bill:

Unlike wholesale electricity, for which the CPO can negotiate, the fixed energy charges (standing charges) sit totally outside the CPO’s control, and the capacity charges reflect the large grid connections CPOs secure for their high-power hubs, being built ahead of demand to enable the EV transition.

Both types of charge have risen astronomically since 2022 and continue to rise (see timeline below). In some cases these charges make up over half of the total energy costs CPOs are paying, and render some high-power charging sites loss-making, reducing CPOs’ ability to invest capital in future sites.

The prospect of these high energy costs can prevent a site going ahead if combined with a high point of connection (PoC) cost. Osprey have examples of sites along strategic trunk roads rendered commercially unviable. One example is located less than a mile from Junction 3 of the M55, where the PoC feasibility cost alone reached £1,197,025, ultimately preventing the site from progressing.

Timeline of increases to fixed energy charges for CPOs over time:

Pre-2022

• Charge Point Operators (CPOs) pay:
• Standing charges (like other businesses)
• Capacity charges (£/kVA/day) for large grid connections needed to future-proof ultra-rapid charging hubs.
• High upfront grid reinforcement costs were a major barrier to new connections.

2022

• Access SCR introduced:
• Removed upfront grid upgrade costs for individual projects.
• Shifted upgrade costs onto all customers, spreading the costs but resulting in higher standing and capacity charges.
• Targeted Charging Review (TCR) reforms changed how distribution, transmission, and balancing charges are calculated.
• Result: significant increases in fixed charges, particularly affecting projects that build large connections ahead of demand (e.g. high-power EV charging).

2023

• Fixed charges accelerate sharply.
• From April 2023, capacity charges begin rising rapidly across regions.
• EV charging hubs are disproportionately impacted because:
• Capacity is secured for future EV adoption.
• Current utilisation is low (under 4% of cars are EVs; most early adopters charge at home).

2024

• Standing charges at some ultra-rapid hubs have increased by up to 10x–87x compared with 2022.
• Example: small Osprey hub in the Midlands rises from ~£99/year (2022) to ~£8,600/year (2024).
• Many CPOs have already paid grid reinforcement costs on projects built pre-2022 and are now also paying higher nationwide charges — effectively paying twice.

April 2025

• Standing charges reduce slightly, but:
• Capacity charges increase by ~100%, outweighing any reduction and disproportionately impacting EV charging hubs with large capacity built ahead of demand to support the UK’s EV transition.
• Since April 2023:
• Average capacity charges are now up 77%, with some regions up 168%.
• Fixed standing and capacity charges now account for:
• ~48% of energy costs and ~25% of driver prices
• Rising to ~53% of energy costs and ~30% of driver prices from April 2025.
• Charges vary widely by region (up to 2.5x difference for identical sites).

2026

• April 2026: TNUoS transmission charges set to rise again, by ~110% (slightly revised down from above).
• Adds ~£12,000 per site per year for a 1MW charging hub.
• Equivalent to £4–5 million annually across a large rapid charging network, wiping out any operational profit and pushing up public charging prices again for consumers.

Impact on a real-world example site, 2021–2026:

• Increase in fixed grid charges for a small charging hub such as Osprey’s 4x 150kW ultra-rapid charge points on a 450kVA connection – see full data below:
• ~£87/year (2021)
• ~8,700/year (2022)
• ~£37,300/year (2026)

Efforts to lower these charges for CPOs, even modestly and for a time-bound period, including through an ongoing DCUSA process (DCP420), have not been successful, not least because someone else in the energy system then has to pay the shortfall.

These energy charges are now the single largest driver of public rapid charging prices. For consumers, around a third of the price they pay “at pump” at a high-power charging site is simply passed on to pay for these site charges. Any further increase in the cost stack (such as the April 2026 TNUoS transmission charges increase above) cannot be absorbed by CPOs, so consumer pricing goes up again. The amount by which it goes up is further exacerbated by the 20% VAT that is added on top of the pre-VAT price CPOs set to recoup their costs and pay back their investment.

Conversely, reducing this element of the cost stack would allow CPOs to reduce prices; this is evident in the dynamic pricing offers already available in the market at times of the day (overnight) or week (weekend) when power is cheaper.

In turn this would free up funding to spend on more charging infrastructure, especially in regions where EV uptake is at an earlier stage and therefore projects more likely to be commercially edge cases.

To address affordability, geographic equity and ensure ongoing infrastructure investment, we urge the Government to:

1. Use part of the £400m funding announced in the 2025 Spending Review to provide targeted relief from standing charges for public rapid charging sites:

• Time-limited, until EV market is more established and higher utilisation covers costs
• Linked to connection sizes
• Non-market-distorting (all CPOs can benefit)

2. Provide relief from policy levies on CPO electricity bills (worth c.6p/kWh), recognising public charging as:

• Strategic national infrastructure
• A large and intensive energy user (like others who get relief already)
• A critical enabler of the EV transition

3. Align long-term grid charging policy and reform with the reality that EV charging infrastructure must be built ahead of demand, rather than penalised for low early-stage utilisation.

3. The implications of eVED communication and implementation for consumer confidence.

We understand and support the need for EVs to pay their share of road tax, and therefore the introduction of eVED in the future.

However, the communication of the new tax was poorly timed, appeared in opposition to existing tax policy that favoured EVs, failed to point out EVs were still cheaper, and lacked clarity on long-term implementation. It is this singling out of EVs for a new tax in such a high-profile way that is having the biggest immediate implication for the wider EV transition, via its impact on consumer confidence.

The Office for Budget Responsibility forecasts a deficit of an estimated 120,000 fewer car sales across the forecast period as a result.[5]

This deficit will disproportionately be seen in EV adoption by lower income drivers and businesses who look to EVs primarily to reduce running costs. The introduction of eVED and the perception that it will increase fixed annual costs, especially coupled with the perception of high public charging costs (see above), matters most when budgets are tight.

Only 48% of low-income households (earning under £40,000) considering an EV, compared to 84% of higher earning households (earning over £80,000).[6] This undermines the Government’s intent for a fair EV transition and will make the ZEV Mandate harder to meet as a smaller proportion of motorists can see financial sense in making the switch.

Implementation of eVED: 

To restore consumer confidence and allow businesses to better plan, the Government must set out whether and how it intends the eVED pay-per-mile system to replace fuel duty and apply across all fuel types in the long-term, and, if so, how rates would evolve.

Such clarity would give drivers and businesses greater confidence that ZEVs represent the correct long-term purchasing decision. In addition, setting this out would underpin the transition to a full ZEV market and therefore the certainty and stability for investors.

In setting this timeline, EV market penetration must be factored in, with eVED rates increasing only once the proportion of new car sales that are ZEVs becomes significant. 

To fairly reflect the wear and tear inflicted on the roads we suggest that a band system based upon the weight of the car should be included within the price structure of eVED. This system has been adopted in France and Iceland who both recognise different pricing structures for heavier vehicles. This would tax road users more fairly based both on the frequency of their road usage and the strain they place on the road structure. The further beneficial impact would be encouraging motorists to drive smaller cars that have a reduced impact on the road, reducing the amount required to be spent on regular upkeep and repairs. 

4.     Evidence from other countries’ EV road signage successes, to inform the development of UK road signage for EV

The UK should learn from European countries’ widespread implementation of (non-branded) EV charging road signage.

Currently the only types of signage allowed on UK roads of any kind without explicit Transport Minister approval (i.e. prescribed in the TSRGD “Planning Circular”) are:

1. An outdated symbol of a three-pin plug that can only be shown on Services signage IF there are also petrol pumps present
2. The new “EV Hub” sign on the A-Road SRN (the APTR)

The former is rarely allowed due to space constraints on Services Signage. The latter is a welcome addition to the TSRGD, but criteria for signage are so prohibitive that they effectively force the Charge Point Operator to own and operate a full Service Station. For example, EV hubs are expected to have a full changing places toilet, and the extensive hot food and drink provision must be under the control and ownership of the charge point operator. Only a handful of EV charging hubs meet them.

In contrast, in France, Germany and Norway:

• Amenities are not explicitly required for the installation of EV charging road signage, to show where drivers can refuel.
• EV charging stations are classified as services similar to campsites, fuel stations, airports and car parks, thereby gaining signs.
• EV charging stations can be included on directional or signalling signs (demonstrating how many km away the station or junction was).
• In Germany there is recognition that EV charging station signs should be included where the location is not expected or known for road safety.

The introduction of a system of clear and visible EV charging signage: on motorways, A-Roads and local roads, is a central enabler of the EV transition. Clear, consistent signage improves visibility of the charging network and therefore consumer confidence in EVs, and it improves the practical usability of charging infrastructure and safety of drivers looking for it; factors that directly influence ZEV adoption.

This is reflected in the European markets which, as above, have supportive policy frameworks already in place. France, Germany and Norway have seen BEV sales rise by +42.5%, +63.2% and +194.4% respectively, alongside significant declines in petrol car sales (-31.1%, -10.7% and -29.6%). All three countries are outperforming the UK in these areas, with BEV sales growth at just +8.0% and petrol car sales having only fallen by -7.1%.[7]

Providing clear prescription of up-to-date (i.e. not a three-pin plug symbol) EV signage for Motorways, SRN A-Roads and locally adopted roads in the TSRGD Planning Circular, with clear application processes and reasonable criteria, is a practical and low-cost step that will accelerate the uptake of ZEVs by consumers.

January 2026

Endnotes