Costs and Benefits
Option 1
EV Infrastructure Market
It is not considered that there will be any impact on competition associated with the introduction of the legislation as this will apply equally to all developments and is proportional to the scale of development. Competition for the provision of EV charge points is well established and the legislation is likely to lead to the enhancement of this by requiring the installation of new charge points increasing demand in the market. The legislation requires the implementation of charge points that are available from a range of manufacturers and may encourage additional manufacturers to enter the Scottish Market.
The market supporting EV charge points following their installation, EV drivers and EV charge point owners is developing within Scotland and services are likely to be provided by charge point manufacturers. The legislation is likely to have a similar impact on this market as for the installation of charge points. It will be the decision of the EV charge point owner whether or not to purchase support services, and some may choose not to depending on the intended use of the EV charge point.
Building Developers
The impact of the legislation on building developers will be to increase the cost of developments, though the opportunity will be there to recover that cost from the consumer through higher prices. There will be parity across all developers in the same geographic context as the legislation will apply uniformly and it will be a business decision and the market that will determine if this is acceptable. Those businesses involved in the delivery of EV charge points and the services associated with these will see a rise in the demand for their products and services. This may lead to new entrants or the emergence of new technology in the market increasing competition.
Research was undertaken into the cost of implementing charge points at different points in the lifecycle of a building and this has also taken into account numerous other factors including geographic location. The research is published on the Climate X-Change website. The cost of implementation of the legislation will vary depending on building type and location, along with stage that the building is at in its lifetime. An indication of the overall range of costs of installation without taking account of whether EV charge points are being implemented in new buildings or retrofitted is given in the table below:
| Geography | Residential | Non-Residential |
|---|---|---|
| Urban | £579 - £1,035 | £2,044 - £11,569 |
| Rural | £570 - £1,030 | £1,273 - £7,255 |
| Remote island | £777 - £1,307 | £1,653 - £26,584 |
The research has found that it is most likely that the installation of EV charge points in new buildings will be lower than retrofitting to existing buildings. As the technology and the market is still emerging the researchers found it difficult to quantify this difference. Costs are given per charge point. The research has also presented a series of case studies and established the costs of those case studies. An extract from these case studies is presented below illustrating the costs of implementing the charge points:
| Case Study | Example Costs (Bottom Up Methodology) | Example Costs (Top Down Methodology) |
|---|---|---|
| New Residential Building | £1,605 | £579 - £1,035 |
| Residential Building Undergoing Major Renovation | £6,138 | £579 - £1,035 |
| New Non-Residential Building | £3,638 | £2,044 - £11,569 |
| Non-Residential Building Undergoing Major Renovation | £6,138 | £2,044 - £11,569 |
| Existing Non-Residential Building | £6,138 | £2,044 - £11,569 |
| New Residential Building (Shetland) | £1,605 | £777- £1,307 |
For the purposes of the above table:
- The bottom up approach was developed using market data for individual components of EV charge point installation
- The top down approach was developed using total cost of installation data from the Energy Savings Trust
Consumers
Consumers are also likely to benefit from the introduction of additional charge points facilitating the ownership of EVs across Scotland. They will likely be able to benefit from the selection of a range of charge point provision, potentially helping to keep the charging process competitive, particularly in the larger urban areas, mirroring the effect present in the petrol and diesel markets at present. Consumers may see increased prices for housing if developers seek to recoup the cost of charge point installation.
Public Sector
Initial costs to the Scottish Government for the implementation of the legislation are estimated to be approximately £325,000 excluding permanent staff time. This includes the cost of preparing the legislation, consulting on it and the preparation of Technical Guidance to allow developers, building owners and Local Authorities to comply.
The proposed legislation will impact Local Authorities and other organisation accredited to undertake the enforcement of Building Standards regulations. They will be responsible, through Building Standards services for the enforcement of the legislation. This will lead to an additional burden on resources in all Local Authorities, however this is assumed to be minor as the buildings involved will be either under construction or refurbishment in any case. The additional checks required for the implementation of the legislation is likely to be relatively minor.
Other services within Local Authorities will also be involved in the process, and may also be affected. Planning Services and Road Development Management Services will be involved in the assessment of planning applications and it is likely that the locations and volume of EV charge points will have to be brought forward at the time of an initial planning application. It is again considered that the additional burden will be relatively small and that there will not be a requirement to consider any building or development that would not otherwise have been considered by these services.
Similarly the impact of the EV charge points on listed buildings and protected landscapes may require that the Landscape and Heritage Services may be involved, and this may involve additional burden for these groups. However this is likely to affect very few buildings in these categories.
Local Authorities may be affected when seeking to bring forward their own new buildings with qualifying buildings. The legislation will require that Local Authorities implement new EV charge points in new buildings, adding to the cost of constructing these buildings to the public purse.
Therefore, overall, we have assessed that there will be a small, undetermined, cost for Local Authorities to oversee the implementation of the legislation on an ongoing basis. This will be undertaken by their Building Standards teams and will represent a small additional task to be completed by these teams as they undertake already mandated Building Standards checks. It is therefore considered that the cost to Local Authorities of these additional checks will be minimal.
Other Organisations
Organisations in the third sector will only be impacted if and when they are introducing new buildings with car parks that qualify for the provision of charge points, including in their own premises which may lead to higher rental charges. This will increase the cost to the third sector of those buildings along with the ongoing payment for EV charge point support services.
Some organisations will be exempted from the requirement to install EV charge points due to the cost cap or for other reasons such as having enclosed car parks. This may lead to some disparity in provision, though building owners and developers would have the choice to implement charge points if the cost cap is exceeded.
Option 2
The emerging EV industry and networks of charge points is complex and involves a large number of operators carrying out a range of different activities. There is at present no regulating or standard setting industry body covering all aspects of EV charging. Therefore, it is unlikely that bodies would come together voluntarily, and with ease, to quickly develop a set of guidelines by which all parties would adhere. The implementation of guidelines would cross a large number of developers across a large number of development industries, at all scales, to be involved creating a complex environment for the implementation of voluntary regulation.
In addition, this would also lead to a cost advantage to developers not adhering to the voluntary regulation, and higher costs for those wishing to install charge points at a later date post-construction.
Without legislation and enforcement of the legislation there is a strong chance that some developers in some areas may not adhere to voluntary regulation leading to a shortage of charge points in some locations or in some building types – this would make the Scottish Government’s goal of a just transition to net-zero emissions transport more difficult to achieve. Meeting Scotland’s climate goals are critical (as outlined in our rationale for intervening) and by not doing anything, we would hamper Scotland’s chances of removing the requirement for petrol and diesel cars by 2030 and hitting our net-zero emissions target by 2045.
Finally, given Scottish Ministers have stated that it is in Scotland’s national interests to align with the EU’s approach to legislation and policy, and the UK Government’s recent legislation in this area, it was not deemed appropriate to do nothing in this policy area.