Consultation
Within Government
Consultation has taken place with colleagues in the Building Standards of the Local Government and Communities Directorate in respect to the implementation of the legislation through provision in Building Standards and through enforcement by Local Authorities.
Colleagues in Legal Services are involved in the process throughout ensuring that the correct path towards the implementation of the legislation is taken.
Public Consultation
In total the following numbers were registered for each of the webinar sessions that took place during the public consultation.
| Session | No. of Registrations |
|---|---|
| 17 August | 26 |
| 24 August | 42 |
| 31 August | 34 |
| 2 September | 31 |
It should be noted that some attended more than one session.
Public consultation has taken place through an online platform where the proposals were set out and a series of questions were posed. The consultation was available to all members of the public and promoted amongst key interest groups.
The majority of consultation responses were broadly supportive of the policy proposals and the proposed exemptions. There were varying degrees of support for the minimum requirements set out for EV charge points with some advocating for a higher standard. Three principle themes were raised by respondents being:
- Cost
- Grid capacity and infrastructure
- Transport hierarchy
In terms of cost the main issues were those of the installation of charge points and the ongoing maintenance costs. Differences in cost dependent on location, labour requirements and infrastructure costs were also raised. Cost exemptions are proposed within the legislation. For example, for residential developments where the grid connection exceeds £2000 per dwelling developers need not provide charge points. There would still be a requirement to provide enabling infrastructure.
Respondents highlighted the increasing requirements of all net zero technologies on local electrical grid capacity. It is acknowledged that there may be some grid capacity issues in localised areas, and that these may occur across the country. The creation of cost exemptions within the legislation provides protection to builders against excessive costs to meet the requirements. However, the additional requirements of 7kW EV charge points is unlikely to put undue pressure on the power supply for the majority of new developments. In addition, the advent of the developing technology in the form of SMART charge points will reduce the pressure on the grid infrastructure. The UK Government has recently implemented legislation mandating the SMART functionality of EV charge points.
Concern was also expressed in respect to the Scottish Governments desire to reduce car usage, for example the target to reduce car kilometres by 20%, and that the provision of EV charge points may increase demand for and growth of private vehicles. There is a requirement to achieve a balance between the use of EVs and other modes of transport. The Scottish Government is confident that EV charge point proposals will not create an issue for local planners to implement transport policies and plans to promote active travel and public transport as the principle modes of choice. The proposals will only be enacted if local Planners allow the construction of parking spaces with new buildings; there will be no requirement for developments without parking spaces to provide EV charge points. It is anticipated that despite the implementation of public transport and active travel infrastructure, services and policies a need for the use of private cars will remain. The proposals are intended to provide for these situations and to allow zero emission vehicles to be used at a greater scale.
In addition to the main public consultation, the series of webinars that were held had different themes to enable stakeholders to receive a presentation on the proposals and have the opportunity to ask any questions which they may have. The themes and dates of the webinars held were:
- 17 August – Policy Context
- 24 August – Technical Session
- 31 August – Accessibility
- 2 September – Islands
A further Technical Session on 21 September was cancelled due to technical difficulties. A sign language interpreter was in place during the Accessibility session.
These sessions allowed attendees to ask questions and clarify largely technical points on the proposals. These sessions were completed in advance of respondents completing their formal responses to the consultation. Some clarifications existed around the size of car parks that charge points had to start to be installed in and at what ratio. Further comments were raised in respect to who would be responsible for the charge points following their installation, which was confirmed to be the ultimate building owner.
The session in relation to the Islands showed that there were a number of additional considerations that applied to the Island communities and remote parts of the mainland. These centred around the difficulty in obtaining trained staff to install and maintain EV charge points, and higher costs that may arise. There was concern that alternative public charge points are not as well developed on the islands and that the islands may be left behind parts of mainland Scotland.
Other issues raised in the consultation included the provision of charge points to support older EVs of which consultees think there are a very small number left on the road. Questions relating to the charge points having to be accessible and around enforcement of the legislation were also posed and answered.
Business
While consulting on proposals a number of businesses registered to take part in the workshop sessions. These included:
- 9 construction or developer businesses, including 7 housing developers
- 4 architect or planner businesses
- 17 local authorities
- 1 national park
None of the events were aimed specifically at businesses or any particular sector, and business registrations occurred across all the events. Representatives were spread from across Scotland including the central belt, the north of mainland Scotland and the islands.