Summary of responses
You can read detailed analysis of the responses received on the Scottish Government Website.
Overall, the majority of the consultation responses were broadly supportive of our policy proposals and the proposed exemptions. There were varying degrees of support for the minimum requirements we set out for EV charge points, with some advocating for a higher minimum standard, but there were also three cross-cutting themes raised by respondents.
Cost
The main concern raised was around the cost implications of the installation of charge points, including upfront costs and ongoing maintenance costs, and the cost of retrofitting existing non-residential buildings. Respondents also highlighted differences in the cost dependent on location, local labour requirements and local infrastructure costs and other additional pressures.
Additional points were made around the cost associated with publicly accessible chargers and the requirements not being fair to existing non-residential building owners, in particular the potential disproportionate cost of retrofitting existing car parks.
Response
The Scottish Government is committed to decarbonising transport and part of this requires increasing the network of reliable EV charging infrastructure, whether that be in public or at home. As demonstrated in the new residential and non-residential case studies (Hypothetical Case Studies 1,3, and 6) in Appendix A, and as we highlighted in the consultation document, it is cheaper to install charge points, and the associated infrastructure, at the point of construction versus the cost of retrofitting.
That being said, we acknowledge that there will be a small number of residential developments where the cost of installation will be higher than in the vast majority of developments. That is why, for new residential buildings with a parking space, we believe that our cost exemption for grid connection, of over £2000 per dwelling, provides a reasonable threshold for costs but, at the same time, does not stop residential developments proceeding. However, if the cost exemption is met, then there is still a requirement to ensure that the ducting infrastructure is in place, future-proofing the building and allowing future homeowners a cheaper installation than would be the case if fully retrofitted at a later date.
Grid capacity and infrastructure
Concerns around the capacity of the electrical grid, and associated infrastructure, was another common theme. Respondents highlighted the increasing requirements of a number of net zero technologies in residential homes on top of EV charge points, like electric heating, increasing the pressure on local grid networks.
Additional points were made around the cost of grid reinforcement and the investment needed to meet these additional capacity needs.
Response
We acknowledge that there will be unique grid capacity challenges in some rural and urban residential developments; that is why we are proposing the £2000 grid connection cost exemption for new residential buildings and the 7% cost exemption for buildings undergoing renovation. However, the additional power requirements of 7kW EV charge points themselves, particularly with the advent, and increased usage, of smart meters, is unlikely to put undue pressure on the power supply for the majority of new developments.
However, for existing non-residential buildings, we agree that grid capacity concerns and the potentially substantial grid reinforcement costs are a barrier for many of those building owners, as demonstrated in the existing non-residential case study (Hypothetical Case Study 5) in Appendix A.
We will continue to engage with the Distribution Network Operators (DNO) and energy providers as we take this work forward, particularly through the engagement we are undertaking for the technical guidance that will accompany the legislation later in 2022.
Transport hierarchy
Respondents also felt that the policy proposals were at odds with broader aspirations to reduce car usage by locking in the demand for and continued growth of private car ownership, which is the lowest priority in sustainable transport hierarchies. Some respondents also called for the Scottish Government to take local transport strategies and plans into account, particularly where those plans were focussed on reducing private car usage.
Response
There is a requirement to achieve a balance between public transport and active travel, and the use of electric vehicles. The Scottish Government is confident that our proposals will not hinder local planners from enacting transport strategies where active travel and public transport are the prime objective. The requirements we propose will only come into force if local planners decide to have residential and non-residential developments with parking spaces; in these circumstances, these requirements will ensure that the majority of those spaces are at least EV friendly and therefore encourage the use of zero emission vehicles.
The plans are aligned to our overall approach to enabling a more sustainable travel and transport system but we must also acknowledge that car usage will continue, particularly in the short to medium term. Therefore, if we want to decarbonise transport, then only by supporting the expansion of the EV charging network, publicly and privately, can we encourage car users to make their next car electric.
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