Written evidence submitted by char.gy (SEV0105)

Executive summary

char.gy is a specialist provider of on-street residential electric vehicle charging infrastructure. Founded in 2016, we operate a network of over 4,700 charge points across the UK, deployed through partnerships with more than 20 local authorities including Southwark, Merton, Coventry, Brighton and Hove, and numerous London boroughs. We specialise in lamppost-integrated and bollard chargers that utilise existing electrical infrastructure to deliver affordable charging for households without off-street parking.

char.gy is backed by the Charging Infrastructure Investment Fund (CIIF), a UK Government-backed fund managed by Zouk Capital, with more than £100 million committed to scale our network nationwide. We are also a certified B Corporation, having met rigorous standards of social and environmental performance, and provide 100% renewable energy to all our charge points, backed by Renewable Energy Guarantees of Origin (REGOs). char.gy has been independently verified as offering the most affordable public charging tariffs in the UK for three consecutive years (2023-2025).

This submission responds to the Committee's questions with particular focus on charging infrastructure (questions g and h), where we have direct operational expertise. We also offer perspectives on the broader questions where our experience of serving households without driveways provides relevant insight.

Government policies and EV adoption (Question a)

Government policy has been broadly effective in stimulating the EV market, with the ZEV mandate providing essential certainty for manufacturers and infrastructure investors alike. The UK now has over 75,000 public charge points — a 37% year-on-year increase — and EV sales accounted for a quarter of all new vehicle registrations in 2025.

However, policy effectiveness has been uneven across different housing types. For the approximately 60% of UK households with off-street parking, home charging at domestic electricity rates of 22-28p/kWh (or as low as 7-10p/kWh on overnight tariffs) makes EV ownership straightforward and economical. For the remaining 40% — concentrated in urban areas and lower-income demographics — the transition is significantly harder. Media coverage frequently compares the highest public charging prices against the lowest domestic overnight rates, presenting a misleading picture. According to Zapmap's Price Index (December 2025), the average PAYG price is 54p/kWh for slow/fast chargers and 77p/kWh for rapid/ultra-rapid chargers, with motorway rapid networks ranging from 57p/kWh (Tesla) to 89p/kWh (InstaVolt, bp pulse). This comparison ignores the fundamental difference in what these prices include. Public charging tariffs must recover capital investment in equipment; ongoing maintenance to achieve high network availability; 20% VAT (compared to 5% on domestic electricity); concession fees paid to local authorities; and operational costs including payment processing, cellular communications, electricity standing charges, 24/7 driver support, and insurance. Motorway rapid charging prices are higher still, reflecting substantial capital costs for ultra-rapid equipment, elevated grid connection charges for high-power supplies, and significant rents charged by motorway service operators. Residential on-street charging, char.gy's focus, operates at much lower price points (our tariffs are 39-59p/kWh) because we utilise existing lamppost infrastructure. We welcome the Government's Cost of Charging Review, due to report in Q3 2026, which should provide an evidence-based analysis of these cost structures and identify policy interventions that could narrow the gap without misleading comparisons.

Further action required: The LEVI fund was the right policy intervention for on-street charging, but implementation has failed. Central government must take a more active role in unblocking council procurement and ensuring allocated funds translate into infrastructure. Policy stability — particularly maintaining the ZEV mandate without further dilution — is essential.

EV take-up relative to targets (Question b)

EV take-up is progressing but remains vulnerable to policy uncertainty. The 2025 figures showing EVs at 25% of new registrations represent genuine progress, but this has been achieved despite — not because of — consistent policy signals. The previous government's decision to delay the ICE phase-out date undermined market confidence, and any further wavering on the ZEV mandate would be damaging.

From an infrastructure perspective, the charging network is broadly keeping pace with vehicle sales for drivers with home charging access. The concern is that on-street residential charging is not scaling fast enough to support take-up among households without driveways. If this gap persists, EV adoption will plateau before reaching Government targets, as the remaining non-adopters are disproportionately those without home charging options.

Effectiveness of incentives (Question c)

Purchase incentives like the Plug-in Car Grant (now ended) and its successors have played a role in early market development, but their impact diminishes as EV prices approach parity with ICE vehicles. The more significant ongoing cost differential is in running costs — specifically, the gap between home and public charging prices.

We would suggest that the most impactful forms of support now are those that reduce public charging costs: reducing VAT on public charging from 20% to 5% (matching home charging); reforming standing charges that disproportionately burden public charge points; and relief from policy levies on electricity. These measures would directly benefit the households least likely to adopt EVs under current conditions.

Electric Vehicle Excise Duty (Question d)

The introduction of EVED on zero-emission vehicles from April 2025 was an inevitable step as the tax base shifts from petrol and diesel. In principle, asking EV owners to contribute to road maintenance is reasonable and fair.

However, the timing and presentation matter. Introducing new costs on EVs while public charging remains significantly more expensive than home charging risks compounding the disadvantage faced by households without driveways. For a driver relying entirely on public charging, the combination of higher per-mile energy costs and now EVED liability makes the total cost of EV ownership less favourable than for those with home charging.

Our recommendation: The Government should reconsider EVED as part of the total cost picture for EV drivers. There should be a public campaign funded by government comparing the total cost of EV ownership compared to ICE vehicles to offset the negative press around the introduction of EVED. If EVED is to be applied, offsetting measures — such as VAT equalisation on public charging — become more important to maintain the overall incentive to switch.

Second-hand EV market (Question e)

A healthy second-hand EV market is essential for broadening access beyond early adopters and higher-income households. From a charging infrastructure perspective, second-hand EV buyers are more likely to be without off-street parking — they tend to be in urban areas, in flats or terraced housing, and on lower incomes than new car buyers.

This means that the development of the second-hand market is intimately connected to the availability of affordable public charging. Without adequate on-street infrastructure, second-hand EVs will be unattractive to the very buyers who would otherwise benefit most from lower purchase prices. Accelerating LEVI deployment is therefore a second-hand market intervention as much as it is an infrastructure intervention.

Additionally, Government could support battery health transparency (standardised reporting of battery condition) and consider incentives for battery refurbishment or replacement to address residual value concerns.

Consumer confidence factors (Question f)

char.gy's research with YouGov has identified that the biggest barriers to EV adoption are not the vehicles themselves but persistent misinformation creating a 'confidence gap'. Many potential buyers overestimate costs, underestimate range, and have unfounded concerns about reliability.

For households without driveways specifically, the most significant confidence factor is chargepoint availability and reliability. Prospective buyers ask: 'Will there be a charger near my home? Will it work when I need it? Can I afford to use it?' These are rational questions, and the answers currently vary enormously by location.

char.gy addresses these concerns through: high network reliability (99% uptime); transparent, affordable pricing (39p/kWh overnight); and convenient locations on residential streets. But we can only serve areas where councils have completed procurement — bringing us back to the central theme of this submission.

On battery longevity and safety: These concerns are largely unfounded but persistent. EV batteries are proving more durable than expected, and fire risk is statistically lower than for petrol vehicles. Government and industry should invest in public education to counter misinformation.

Charging infrastructure rollout (Questions g and h)

This is our area of primary expertise, and we provide detailed evidence below.

The on-street charging gap

The UK has made significant progress in building its public charging network. As of late 2025, there are over 75,000 public charge points across the country — a 37% increase on the previous year. However, this headline figure masks a critical imbalance: the vast majority of this growth has been in rapid and ultra-rapid charging hubs, not in the residential on-street infrastructure that households without driveways depend upon.

Approximately 8 million households in England (32%) lack access to off-street parking. In London, this rises to 61%. For these households, the promise of cheap home charging is inaccessible. While drivers with driveways pay domestic electricity rates of 22-28p/kWh (or 7-10p/kWh on overnight tariffs such as Octopus Go or Intelligent Octopus), those relying on public charging face average costs of 54p/kWh for slow/fast chargers and 77p/kWh for rapid/ultra-rapid chargers according to Zapmap's December 2025 Price Index. Motorway rapid charging is more expensive still, ranging from 57p/kWh (Tesla Superchargers) to 89p/kWh (InstaVolt, bp pulse). Even comparing like-for-like overnight charging, the gap is substantial — and it exists not because public charging operators are profiteering, but because public tariffs must recover costs that are invisible in domestic bills: capital equipment, maintenance, 20% VAT (versus 5% domestic), council concession fees, payment processing, communications, standing charges, 24/7 support, and insurance.

These cost differences are real, but they are not immutable. Much of the gap stems from policy choices that could be changed: VAT at 20% rather than 5%, disproportionate standing charges following Ofgem's Targeted Charging Review, and policy levies that burden public charging while exempting domestic supply. Additionally, the Government could require transparency on council concession fees — the charges local authorities levy on charge point operators for use of public land — which vary widely and are ultimately passed on to drivers. Making these fees visible would allow drivers to see how much of their charging cost goes to their council, and create accountability for authorities that impose excessive charges. Without action, the EV transition risks becoming a two-tier system — affordable and convenient for homeowners with driveways, structurally more expensive for the 8 million households without. The Government's Cost of Charging Review, due to report in Q3 2026, is the opportunity to address these disparities and ensure that drivers without driveways are not permanently disadvantaged.

LEVI fund delays: capital ready but unable to deploy

The £343 million Local Electric Vehicle Infrastructure (LEVI) capital fund represented a transformational opportunity to address the on-street charging gap. It was designed to deliver over 100,000 local chargepoints, ensuring that households without driveways would not be left behind.

That opportunity is being squandered through procurement delays. The scale of failure is stark: to date, only 7 councils have signed concession contracts and begun infrastructure rollout. Several councils have not yet even started their procurement processes — despite receiving their LEVI funding allocations over two years ago. While contract award announcements accelerated in late 2025, these have yet to translate into chargers in the ground. Many councils remain at pre-market engagement or early tender stages, with installations not expected until late 2026 or 2027.

This is not a problem of insufficient public funding. The CIIF — the Government's own charging infrastructure fund — has capital ready to deploy. Charge point operators have business models, supply chains, and installation teams prepared to deliver. The bottleneck is council procurement.

Council procurement practices: frustrating the market

Beyond the delays, the quality of council procurement is creating fundamental problems for infrastructure delivery. We observe three recurring failures:

1. Failure to use Crown Commercial Service (CCS) templates. CCS has developed standard procurement frameworks specifically for EV charging infrastructure. These templates reflect market realities and produce commercially viable contracts that operators can invest against. Yet many councils choose to draft their own bespoke procurement documents, often with terms that are fundamentally uninvestible — unrealistic risk allocations, inappropriate revenue share requirements, or obligations that no rational operator would accept.

2. Preventing use of existing electrical infrastructure. Some council procurement specifications explicitly prohibit or discourage the use of existing lamppost columns and street furniture for charging infrastructure. This ideology-driven approach ignores the substantial cost and time savings that existing infrastructure provides.

3. Insufficient understanding of CPO and driver needs. Many procurement documents reveal a fundamental misunderstanding of how charge point operation works commercially, or what drivers actually need.

Administrative barriers to deployment

Resident consultations: Many councils require formal resident consultations for each charge point location. We do not hold consultations before installing lampposts, parking meters, or telephone cabinets. In a future where all vehicles will be electric, charging infrastructure is no more controversial than any other street furniture.

Traffic Regulation Orders: Where charging bays require parking restrictions, TROs or TMOs must be obtained. These processes typically cost £2,000-£5,000 per order and take 3-6 months or longer to complete. For large-scale deployment, this creates an enormous administrative bottleneck and additional capital costs which need to be charged on to drivers.

The case for lamppost-attached charging

The economics are compelling. A lamppost-attached charge point typically costs £1,500 to deploy, utilising the existing electrical connection. A new-build charge point with a dedicated grid connection costs £5,000-£15,000, depending on location and grid capacity.

Over a 10-year concession, assuming each charge point serves 5 regular users and delivers 150,000 kWh in total: lamppost-attached capital recovery is approximately 1p per kWh, while new-build capital recovery is 3.3-10p per kWh. This difference — which could amount to hundreds of pounds per year for a typical driver — is a direct consequence of infrastructure choices.

Affordability for drivers without driveways

char.gy is committed to making on-street charging as affordable as possible. Our current tariffs — 39p per kWh overnight and 59p per kWh during the day — have been independently verified as the most affordable in the UK public charging market for three consecutive years. We achieve this through low-cost infrastructure (utilising existing lampposts), efficient operations (99% uptime), scale, and long-term CIIF backing.

Lessons from other countries (Question i)

The Netherlands offers the most relevant model for on-street charging. Key features of their approach include:

•        Demand-driven deployment: Residents can request a charge point, triggering standardised installation processes. This ensures infrastructure follows demand rather than relying on central planning.

•        Interoperability: A unified 'chargepass' system allows drivers to use any public charge point regardless of operator, with transparent pricing.

•        Streamlined grid connections: Distribution network operators have standardised processes for charge point connections, dramatically reducing deployment timelines.

•        Municipal coordination: Local authorities work collaboratively with operators through framework agreements rather than repeated bespoke procurements.

The result is that the Netherlands has among the highest per-capita public charging provision in Europe, with particularly strong coverage in residential areas. The UK could learn from this approach, particularly around standardised procurement frameworks and streamlined administrative processes.

Norway demonstrates the importance of policy consistency. Its world-leading EV adoption (over 80% of new car sales) was built on decades of stable incentives. The lesson for the UK is that policy stability matters as much as policy generosity — investors and consumers need confidence that the rules will not change unpredictably.

Our recommendations

We recommend the Committee focus on the following areas:

1. Accelerate LEVI fund deployment through central government intervention. Direct ministerial pressure on councils with stalled procurements; public reporting of council progress; a transparent dashboard showing procurement status for all LEVI recipients; and reallocation of funding from persistently delayed councils to those ready to deploy.

2. Mandate or strongly encourage use of CCS procurement templates. Councils should not be reinventing the wheel with bespoke procurement documents that produce uninvestible contracts.

3. Remove or streamline resident consultation requirements for EV charging. EV charging infrastructure should be treated as essential utility infrastructure, not as a controversial planning matter.

4. Streamline TRO/TMO processes for EV charging. Options include borough-wide TROs, fast-track procedures, or exemptions for certain types of charging infrastructure.

5. Prioritise use of existing infrastructure in guidance and LEVI criteria. OZEV guidance should explicitly favour approaches that utilise existing electrical infrastructure, recognising the cost, speed, and affordability benefits.

6. Equalise VAT on public charging at 5%. The current 20% VAT rate on public charging versus 5% on domestic electricity compounds the disadvantage faced by households without driveways.

7. Support ChargeUK's recommendations on taxation and regulation. Including standing charge reform, relief from policy levies, and inclusion of public charging in the Renewable Transport Fuel Obligation.

8. Maintain the ZEV mandate without further dilution. The charging industry has £6 billion of committed private investment ready to deploy; maintaining policy stability is essential to unlocking this capital.

9. Invest in public education to counter EV misinformation. Addressing the 'confidence gap' identified in consumer research is essential to broadening adoption beyond early adopters.

Conclusion

The EV transition will only succeed if it works for everyone — including the 8 million English households without driveways who cannot charge at home. The infrastructure, the investment, and the expertise exist to serve these households. What is lacking is the policy and procurement environment to deploy it.

char.gy stands ready to work with Government, local authorities, and the Committee to accelerate on-street charging deployment. We have over £100 million of CIIF-backed investment available. We have proven technology and the most affordable tariffs in the market. We have partnerships with over 20 local authorities demonstrating what is possible.

The barriers to deployment are not technical or financial — they are administrative and procedural. Removing these barriers is the single most important thing the Committee can recommend to supercharge the EV transition for the households who need it most.

 

January 2026