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07 August 2019

171: Electric vehicle charging consultation – a step forward or already outdated?

The Department for Transport has issued a consultation on the delivery of its intention for all new homes to be electric vehicle (EV) ready as set out in its Road to Zero strategy. They propose the following:

  • all new residential buildings with associated car parking should have EV charging points;
  • all residential buildings with more than 10 car parking spaces which undergo renovation should have at least one EV charging point and cable routes in all car parking spaces for charging points to be installed in the future;
  • all new non-residential buildings with more than 10 car parking spaces should have at least one EV charging point and cable routes for charging points to be installed in at least one in five spaces; and
  • all existing non-residential buildings with more than 20 car parking spaces should have at least one EV charging point by 2025.

The DfT has recognised that the key to encouraging the take-up of electric vehicles is by ensuring that consumers can be assured that they will have access to EV charging points and they take the view that the majority of EV charging will take place at home overnight.

There is a significant overall cost saving by installing a charging point during construction of a new home as opposed to retrofitting it (on average around £976 for the former, and around £2,040 for the latter), but the responsibility for the initial outlay will shift to developers rather than to the consumer. A number of exemptions will be provided which centre around viability of installations based on cost and the electricity infrastructure available.

Clearly the consultation is only a first step and the government will refine their proposals once they have reviewed the responses. However a number of questions arise, both around the detail and the policy itself:

  • in many new developments residential dwellings will have associated car parking which is not located within the site boundary but is in a small grouping of spaces nearby. In this case thought needs to be given as to who will have ownership of the spaces and the charging points, how will use of the charging points be controlled and who will be responsible for their maintenance. In communal environments security also needs to be considered – not only the security of the equipment itself to avoid theft but also how the electricity use will be measured and charged to the user;
  • the DfT is sensitive to concerns that developers may have about the cost of installing EV charging points in every new home. However in addition to the cost of each installation, consideration needs to be given to the additional capacity required in the utilities laid in developments, the capacity of local substations and whether a requirement to install this cabling in new developments will have a time cost in the construction process;
  • the proposed lead in time for the new regulations to come into effect is March 2021 (so buildings for which initial building notices or full plans applications have been submitted before then will not need to comply) and if this timescale is applied it is likely that many developments which will be caught will already be in the land acquisition stage now and cost appraisals may need to be updated accordingly; and
  • no mention is made of existing residential buildings, and particularly tenanted dwellings. Given the rise in the number of people living in tenanted properties for longer periods of time, might there be an argument for requiring existing dwellings which are tenanted to have EV charging points installed in a similar fashion as is being applied to existing non-residential buildings?

The consultation is a step forward and shows the government understands the need to take steps to enable further progress to be made with electric vehicles given the high cost barriers to entry as a consumer. However, one might question whether the government should focus energy on steps which continue to encourage car ownership and private car use when car sharing / hiring schemes are already commonly used and are often a requirement of new residential developments.

Equally, new settlements are increasingly developed in a manner which does not encourage reliance on a private car and by enabling developments in the right locations they can benefit from the right public transport infrastructure from the outset.

With the prospect of driverless cars or taxis on the horizon, could this policy be out of date by the time home owners pick up their keys to the first houses constructed in line with it?

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