The Future Transport Regulatory Review: Zero Emission Vehicles - Which? response

Summary

Which? welcomes the opportunity to respond to this consultation on the Future of Transport Regulatory Review: Zero Emission Vehicles. As more drivers make the switch from petrol and diesel to electric vehicles (EVs), it is essential that a comprehensive network of public charging infrastructure is in place that meets motorists’ current and future needs; provides a seamless, user-friendly experience; and helps to drive uptake of EVs.

We welcome the Government’s intentions to introduce measures to help ensure charge point provision meets demand, address issues of limited competition, ensure there are adequate consumer protections in place, and ensure consumers feel safe while using the public charging network. We also strongly support measures to improve the accessibility of public charge points for disabled drivers. In particular:

• We welcome the proposals to clarify legal responsibility for both the planning and delivery of sufficient provision of EV charge points. If a statutory obligation is to be placed on local authorities (LAs) to deliver these duties, their resourcing must be reviewed, and ring-fenced funding must be provided if necessary.
• The Government should ensure that sufficient guidance and comprehensive national and local data are provided to better support LAs in the role they already are playing in the charging infrastructure roll-out, whether or not they are awarded a statutory duty.
• In principle, we support the Government’s proposal to seek powers to set a minimum level of EV charging infrastructure for all non-residential car parks, if necessary, which would help increase the opportunities for destination charging. It will be essential that any minimum level is futureproofed and matches need, and that clear guidance is provided to ensure that the most suitable type of infrastructure is installed.
• We agree that the Government should have the power to mandate more competition between charge point operators at service areas and large fuel retailers. This should help to expand charge point provision at these sites and drive better consumer outcomes including more competitive pricing.
• We agree that the Government should have the power to require charge point operators to offer ‘open access’ charging at service areas and large fuel retailers. This should mean that charge point operators are required to make their charge points open to all car users, and not limited to car users of a particular brand or network. The Government should also consider extending these requirements to all public charge points.
• The Government should also consider whether there is a need to provide guidance on differential prices charged to drivers of different brands of EVs, to ensure they are not punitive. ‘Open access’ should also mean accessibility for all drivers, including disabled drivers, and cross-network payment interoperability.
• We agree that the Government should have the power to require a progressive increase in the number of charge points provided at service areas and large fuel retailers, which could be used if the market fails to provide adequate charge points at these key sites.
• We welcome the Government’s proposals to ensure there are adequate consumer protections in place when encountering issues using the public charging infrastructure. Which? supports the appointment of a consumer protection service responsible for regulation of EV charge points, with administrative enforcement powers to ensure compliance. There should also be a mandatory single ombudsman service for there solution of disputes between consumers and companies in this sector.
• We support the Government’s proposals to mandate accessibility standards for public charge points. Disabled drivers currently face fundamental challenges in using public charge points, and we recommend that appropriate bodies representing disabled consumers should be consulted to ensure that their needs are sufficiently considered.
• We support the Government’s proposals to mandate that industry participants provide a safe charging experience at public charge points, which evidence shows is currently a concern for some drivers.
• We agree that the Government should have the power to mandate defined aspects of the design of public charge points. This should be those aspects which are essential to ensuring a positive consumer experience. As part of this, it will be essential that the existing issues of lack of payment interoperability and poor accessibility for disabled drivers are addressed.