Electric Vehicles (Smart Charge Points) Regulations 2021

Lord Rosser Excerpts

Tuesday 30th November 2021 Grand Committee

London has as many charging points as the whole of the rest of the UK. This really requires a strong steer from the Government if we are to get over the psychological problem that the noble Lord exemplified perfectly just before I spoke. We find where our local charge points are and very quickly work out how to use them. We work how our own vehicles operate and how best to maximise the range. We manage all that, but you talk to any EV owner and the first thing they mention is the range for long journeys. Until we can be comfortable with that, we are not going to encourage people to go for EVs in the large numbers that we need to.

[Lord Rosser (Lab)]

As background, the impact assessment states in paragraph 1 that:

“In 2019, road transport accounted for 24% of all UK”


greenhouse gas

“emissions with cars and light commercial vehicles … accounting for 79% of this total,”

and that greenhouse gas

“emissions from transport have remained largely unchanged since 1990.”

The impact assessment then says in paragraph 1, as it does on a number of occasions elsewhere, “Error! Bookmark not defined” in bold letters. I would just like to ask what that means in paragraph 1 of the impact assessment I have and, indeed, in other parts of it. I take it that is an error but I would like to check what it means. Does it mean anything I need to be aware of or is it just a mistake?

With the ending of the sale of new petrol and diesel cars in the UK scheduled for 2030, the Department for Transport regards the transition to electric vehicles as crucial to achieving net-zero greenhouse gas emissions by 2050, with the electricity system having to be able to meet the increased demand that that will generate. Can the Minister say what the Government estimate the additional greenhouse emissions will be that will be generated by the increased demand for electricity arising from the transition to electric vehicles? This will have to be set against the reduction in such emissions arising from the phasing out of petrol and diesel vehicles?

As has already been said—and indeed is in the Explanatory Memorandum—most electric vehicles are expected to be charged at home, but the Department for Transport expects that without smart charging, this is most likely to happen during electricity system peak times when people arrive home from work. This would require, the EM says, “significant … additional investment” in the electricity networks and electricity generation capacity. Smart charging is intended to address this issue. Can the Government say in their response what the saving will be in these additional investment costs if there is a successful move to smart charging and what percentage of investment each year in electricity networks and electricity generation capacity that savings figure in additional investment represents?

With smart motorways and now smart charging, it is clear the Department for Transport has taken a fancy to the use of the word “smart”, but I would have to say that it did not figure greatly in the recent announcement on the backtracking on the northern powerhouse rail and eastern leg of HS2 commitments. As well as introducing a requirement for all domestic and workplace charging points to include smart functionality or charging, the regulations set out certain standards and requirements that smart charging points must meet. They also require a statement of compliance to go with every smart charging point sold, with penalties for selling a non-compliant charging point.

The Government estimate that 87% of private charging points sold or installed in this country currently have smart functionality. There is, however, the issue of accessibility of charging points for those who are unable to install a private charging point, not least those who do not have their own dedicated parking space at their place of residence. Could the Minister say how the Government intend to address this aspect of the issue of accessibility, and within what timescale?

Paragraph 7.6 of the Explanatory Memorandum says on interoperability that:

“The ability of consumers to freely switch energy supplier is a fundamental principle in the energy market. This instrument makes clear that a charge point should not introduce a new barrier to switching by being designed to lose its smart functionality when its owner changes supplier.”


What does not appear in the Explanatory Memorandum, as far as I can see, is an unambiguous statement that the instrument includes a requirement for all charging points to be interoperable. Could the Minister say in her response whether the wording in the Explanatory Memorandum to which I referred constitutes in reality a requirement for all charging points to be interoperable? I think the answer is that it does not, but I should be grateful for clarification on that point.

Paragraph 10.6 of the Explanatory Memorandum says that the Government have

“chosen not to mandate device-level requirements”

relating to demand side response interoperability

“at this time … because the smart charging market remains nascent, and because delivering interoperability would require broader powers than those set out in the AEVA”—

the Automated and Electric Vehicle Act 2018. That is despite the fact the Explanatory Memorandum states that:

“The ability of consumers to freely switch energy supplier is a fundamental principle in the energy market.”


The Government also say in paragraph 10.6 that:

“The Department intend instead to consider how best to deliver interoperability as part of a second phase of legislation, by looking at placing wider requirements on the entities … which could deliver DSR through charge points. Government aims to consult on this second phase of policy measures in 2022.”


That is a somewhat vague timescale, which contains no target date for actually legislating. Could the Government be more specific in their response today?

I also have a comment on the benefits and costs. Paragraph 12.3 of the Explanatory Memorandum says on impact that:

“The overall monetised benefits are estimated at £300m - £1.1bn up to 2050, primarily derived from reduced electricity system costs. The cost to industry of this instrument is estimated at £10 - £260m up to 2050”—


is that figure of £10 right, or is there an “m” missing after the 10? It continues that the cost is

“primarily related to product development costs to meet the requirements. The costs to industry are significantly outweighed by the benefits to the energy system and consumers, and this instrument has a Net Present Value of £0 - £1.1bn up to 2050, with a central estimate of £500m.”

As I understand it from these figures, there is in reality a very little gap between the highest cost figure to industry and the lowest monetised benefit figure. Perhaps the Minister could say whether she agrees or disagrees with that statement, but it seems to me to be the difference between £260 million and £300 million, looking at those two figures.