Vehicle Technology and Aviation Bill

Written evidence submitted by POD Point (VTAB 16)

1. Respondent Profile

1.1 POD Point are a leading UK provider of Electric Vehicle (EV) charging infrastructure and associated systems and services.

2. Introduction

2.1 POD Point is supportive of the Vehicle Technology and Aviation (VTA) Bill and believes it appropriately addresses key areas where the Government may seek to take powers. POD Point provided a full response to what was then the "Modern Transport Bill" Consultation

2.2 This document provides emphasis on some key areas for the committee, expresses some general views on how EV charging best work s , following concern over a representation made to the committee, and offers a view on those areas the government should seek to prioritise its action more broadly.

3. Points of Emphasis (Further to "Modern Transport Bill" Consultation Response)

3.1 3.1 .1 The government should not seek to regulate the way charge point providers display the location of their charge points, there is a clear market incentive for them to do this well. Nor should they seek to regulate speci fic user interface for charging i nfrastructure, only to seek to encourage easy access and price transparency at the point of use for ad hoc users.

3. 1.2 Whilst there is a market demand for unified access and payment methodologies, the industry is currently too young and too technologically dispersed to impose a single solution. Over-regulation risks stifling innovation in a fast-developing market.

3.2 3. 2.1 The government does need to act to ensure grid load can be balanced when we move towards mass adoption. However, how best to do this is non-trivial. It is POD Point’s strong preference that control of charging events remains within the domain of the charging companies, though they should be supported through the establishment of a marketplace to sell Demand Side Response (DSR) services to the grid operators at a national, regional and local level .

3. 2.2 POD Point welcome any opportunity to share their extensive thoughts on how this proposed marketplace might function, and how this positively builds on the existing fast reserve / spinning reserve market .

4. Concerns over Representation Made to the Committee

4.1 Reading the evidence presented to the committee it might be that an overly simplistic view of the market was presented via anecdote. In particular the following:

4.2 The critical thing is the availability of rapid chargers. Rapid chargers are the game changer. You can charge your car within 30 minutes to 80% of its battery life. Therefore, you can do multiple charges in a day, bringing the feasible range from this notional 130 miles for a Nissan LEAF to as much as 300 miles. I did a journey from Birmingham to Milton Keynes and back, charged twice at a rapid charger and arrived at Milton Keynes with 90 miles still on my battery range. So the Bill must make sure that these rapid chargers are rolled out much more and we see many more at motorway service stations and at key points within cities, because they will enable people to believe that their range is much wider than they are led to believe.

4.3 It is true that rapid charging has an important part to play in extending longer journeys and indeed encouraging drivers of Internal Combustion Engine (ICE) vehicles to feel comfortable making the switch to electric. However, it is critical that the Committee is made aware of how rapid charging fits into a broader charging ecosystem.

5. Understanding the Charging Ecosystem of Private Car Owners

5.1 EV motoring cannot work by trying to directly replicate the petrol pump with massively high powered chargers (e.g. >1MW) - this is neither feasible, nor desirable. EV charging typically works, particularly for private car ownership, by placing chargers in the locations that cars are parked whilst their drivers are engaged in other activities.

5.2 For example, many of the VTA Bill Committee will own cars, those cars are most likely parked doing nothing whilst this submission is being read - would it not be wonderful if they were fuelling themselves with very inexpensive fuel, such that they are fully "fuelled" upon your return to them? This is a great experience and a tremendous advantage EVs have over ICE vehicles.

5.3 In POD Point’s view the ideal charging ecosystem for an example EV driver with a 150-250 mile range car (e.g. the current Renault Zoe) who commutes by car should be considered as follows:

a) Hom e Charging (Typically 7KW AC) - For those with off street parking (the majority of UK households), a home charging point is the truly critical piece of infrastructure. In a successful charging ecosystem it should account for at least 70% of all charging, for many it accounts for more still. Those who don’t have the ability to charge at home represent a genuine challenge to full adoption and there is no one solution to this, but thankfully the majority can have a home charging unit which gives the opportunity to drive substantial uptake before we solve for the minority cases .

b) Workplace Charging (Typically 7KW AC) - Though less relevant in central London, cars spend long periods stationary outside workplaces making them optimal places to install charging points. Indeed installing charge points at workplaces has been shown to be one of the most potent means of encouraging uptake (hence OLEV’s Workplace Charging Scheme (WCS) grant). It is possible for some EV drivers to survive on workplace charging as their primary charger, if home charging is not available. For those who have both home and work, this should account for circa 20% of charging .

5.4 You will note the above two have accounted for circa 90% of charging in this exampl e s .

c) Destination Charging (Typically 7KW AC) - Destination charging means anywhere else a car is parked for circa an hour or more. There are a very large number of such locations, e.g. supermarkets, dedicated public car parks, airports, train stations, gyms, cinemas, restaurants, hotels etc. We believe this should be considered to provide circa 7% of charging. It is critical that use of these chargers is easy, conveniently located and competitively priced. This provision encourages a "grazing" type of opportunity chargin g.

d) En Route Charging (Typically 50KW DC) - This is where rapid charging becomes critical, for those longer range trips, provision at Motorway Service Areas (MSA) is optimal, as Quentin Wilson indicated. But in our "typical" home charging, driving commuter scenario, rapid charging is likely to be circa 3% of charging for occasional longer journeys (NB: average UK daily mileage is circa 21 miles) .

5. 5 Return to base fleets offer another excellent use of a rapid charger for vehicles with high mileages and limited down time. But the committee must note that installed rapid chargers cost circa 30 times as much as installed 7KW units and there are limited locations with sufficient spare electrical supply to feed them .

6. Conclusions from the Top-Up Model Approach

a) The majority of charging can happen at home, and another significant proportion at places of work. This is a key insight, because it is relatively straight forward to provide these chargers and it is already being achieved. It means we already have the infrastructure necessary to substantially increase EV ownership today .

b) Widespread 7KW type charging is relatively to achieve, but it will present challenges for grid operators as we move toward mass adoption. This needs to be planned for now, POD Point’s calculations show the first issues will appear within a 5 year time line, unless demand can be controlled .

c) The visibility to potential EV drivers of rapid charging infrastructure is particularly significant in supporting uptake and removing barriers to adoption, even if it is only for minority usage. Clearly in this regard the significance is greater if we are to offer significant (>10) rapid charging facilities at MSAs at 50KW, or the 350KW devices being considered, the government may need to support the provision of enabling infrastructure (significant grid connections, potential battery back up to lessen grid impact, etc ), as the costs are likely to make such provision unfeasible for MSA operators in a reasonable time frame .

7. POD Point Recommendations for Government Focus in the EV Sector

7.1 Funding of EV charging infrastructure has direct benefits to the EV charging industry, and POD Point is appreciative of the support the government has and continues to offer. However, such top down funding is not sustainable in the long run.

7.2 POD Point believes the government should focus its efforts on influencing and enabling drivers to switch to EV through a coherent framework of incentives for (particularly) zero emission EVs and potential moderate disincentives for carbon intensive alternatives (e.g. introduction of a Carbon tax).

7. 3 Key Incentive Areas:

· Low Company Car Benefit in Kind Tax ( BiK ) rates for zero emissions (bringing forwards the proposed 2020 reduction to 2%, and removing planned interim increases, would significantly benefit EV uptake);

· Maintain VED tax advantages;

· Exempt zero emission EVs from other disadvantages (congestion charge etc ); and

· Require EV charging points to be installed at parking bays by planning system (already part of London Plan, this requirement should develop and proliferate to other regions).

8. Further Information

If you would like to discuss, or receive any further information on the above, please do not hesitate to contact us at your earliest convenience.

March 2017


Prepared 23rd March 2017