Electric vehicle chargepoints in buildings Introduction Thank you for responding to the Electric vehicle chargepoints in buildings consultation. Your responses will define the:

• proposal of introducing a requirement for electric vehicle (EV) chargepoints to be installed in new homes with an associated car parking space

• manner we transpose 3 new requirements of the European Union’s (EU) Energy Performance of Buildings Directive (EPBD)

The consultation will run until the 7 October 2019. Print or save a copy of your response When you get to the end of this questionnaire, you will be offered the chance to either print or save a copy of your response for your records. This option appears after you press 'Submit your response'. You have an option to 'save and continue' your response at any time. If you do you will be sent a link via email to allow you to continue your response where you left off. It's very important that you enter your correct email address if you choose to save and continue. If you make a mistake in the email address you won't receive the link. Confidentiality and data protection The Office for Low Emissions is carrying out this consultation to decide whether to introduce a requirement for EV chargepoints to be installed in new homes with an associated car parking space and will define the way we transpose 3 new requirements of the EU’s EPBD. This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, the Department for Transport will, under data protection law, be the controller for this information. As part of this consultation we’re asking for your name and email address. This is in case we need to ask you follow-up questions about any of your responses. You do not have to give us this personal information. If you do provide it, we will use it only for the purpose of asking follow-up questions. DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact the Data Protection Officer. Your information will be kept securely and destroyed within 12 months after the consultation has been completed. Any information provided through the online questionnaire will be moved to our internal systems within 2 months of the consultation end date.

Personal details

1. Your name and email address (only used if we need to contact you).

Your name Rick Hartwig

Your email Rhartwig@theiet.org

2. Are you responding as: *

an individual? (Go to question 4)

X on behalf of an organisation?

Organisation details

3. Your organisation's name is?

The Institution of Engineering and Technology

Building regulation changes: new residential and residential buildings undergoing major renovation We want every:

• new dwelling

• buildings undergoing material change of use to create a new dwelling

with an associated dedicated car parking space to have a chargepoint, where the space is 'within the site boundary' of the building. And for every residential building undergoing major renovations with more than 10 car parking spaces physically adjacent to the building to have cable routes for electric vehicle chargepoints in every space.

New dwellings

4. Do you agree with our proposed policy position to require a chargepoint in new dwellings? X Yes for all dwellings (Go to question 6)

Yes for single-dwelling buildings only

Yes for multi-dwelling buildings only

No

Don't know? (Go to question 6)

Against new dwellings proposal

5. Why not, including what requirement you think would be suitable (include any evidence you may have)? [Attach your evidence to your return]

Comments:

The proposal is good as far as it goes but it needs to go further.

Many new dwellings – especially affordable housing developments - either have no associated car parking space within the boundary of the property. Some have allocated parking bays but in communal areas where it would be impractical to wire the chargepoint back to the resident’s home wiring.

Consideration should be given to solutions that enable residents with allocated parking in communal areas to have access to a dedicated chargepoint/s in the communal parking area if they so choose – albeit this might need to be metered separately from the resident’s home electricity meter. In such cases the resident should not have to pay fixed use of system charges for both meter points, and from an energy billing perspective the consumption at the two meter points should be summated and charged as a single bill if the customer so chooses (the customer might elect to contract with a separate supplier for the EV chargepoint in which case summation of the two consumption volumes will be separately billed and two standing charges might be incurred).

Material change of use 6. Should we require the installation of an electric vehicle chargepoint in the car park of buildings converted into a new dwelling? X Yes (Go to question 8)

No

Don't know? (Go to question 8)

Against material change of use proposal 7. Why not (including any evidence you have)? [Attach your evidence to your return] Comments:

Major renovation For residential buildings undergoing major renovation we:

• do not propose requiring the installation of an electric vehicle chargepoint

• do propose requiring cable routes for electric vehicle chargepoints when the building has more than 10 parking spaces as per the minimum EPBD requirement

The reason we are not proposing to apply the chargepoint requirement is that we are mindful that this requirement would increase the capital cost of major renovations, and that this capital cost might ultimately fall on existing leaseholders. We also do not wish to discourage major renovations taking place by adding unacceptable additional costs to works. In a single-dwelling setting, there are more potential problems where a renovation of a separate part of the dwelling could result in the requirements being triggered.

8. Do you agree not to apply the chargepoint requirement to residential buildings undergoing major renovations? X Yes (Go to question 10)

No

Don't know? (Go to question 10)

Against major renovation proposal

9. Why, including any evidence you have, and to which types of residential buildings you wish to apply the regulation to (such as residential buildings with more than 10 car parking spaces only)? [Attach your evidence to your return] Comments:

Scope of requirement We propose that the requirement should be for one chargepoint per dwelling rather than every parking space associated with the building. Therefore if a building has more car parking spaces than dwellings, there will be a single chargepoint per dwelling rather a chargepoint per parking space.

10. Do you agree the requirement should be for one chargepoint per dwelling rather than every parking space associated with the building? X Yes (Go to question 12)

No

Don't know? (Go to question 12)

Against scope of requirement proposal

11. Why not (including any evidence you may have)? [Attach your evidence to your return] Comments:

Optional building regulations

12. Do you agree we should set the requirement as mandatory rather than optional in the building regulations? X Yes (Go to question 14)

No

Don't know? (Go to question 14)

Against optional building regulations

13. Why?

Other issue to consider

14. What other issues do you think, relevant to using building regulations to set standards for the provision and safety of electric vehicle chargepoint, we should consider?

Acknowledging this is a planning issue rather than a buildings regulation issues but there needs to be a fundamental review of car parking provision on new dwellings since many are under-provided for in this respect (resulting in cars parking on footpaths or other inappropriate areas).

The transition to EVs will make it impossible for residents to charge at home unless there is sufficient dedicated parking (including in communal areas) and unless adequate provision is made to facilitate the installation of chargepoints at allocated parking bays so that residents have the option to have a dedicate chargepoint if the resident is willing to meet the cost of provision and installation.

Careful consideration of The IET’s 18th Edition Wiring Regulations B7671 is important – particularly the earthing arrangements for outdoor chargepoints. Any new circuit should be notified to building control.

Building regulation changes: new non-residential and non-residential buildings undergoing major renovation

We propose to transpose the EPBD requirement for new non-residential buildings and non-residential buildings undergoing major renovation directly. This means that we want every new non-residential building, and every non-residential building undergoing a major renovation, with more than 10 car parking spaces to have: 1. one chargepoint 2. cable routes for electric vehicle chargepoint cabling for one in 5 spaces

15. Do you agree with our proposed policy position? Yes (Go to question 17)

X No

Don't know? (Go to question 17)

Against new non-residential policy position

16. Why, including what alternative requirement you think would be suitable (note we are obliged under the EPBD to transpose the proposed requirements as a minimum)? [Attach your evidence to your return] Comments:

The proposal is too deterministic and may result in under or over provision. There may be very different requirements between (say) an office building and a retail outlet. The former might logically provide for ‘at work’ charging (say 3.5kW) whereas the latter might be better served by a mix of parking spaces with rapid (21kW) charging and dedicated forecourts (many supermarkets already have these) where super-rapid charging facilities are available.

Existing non-residential buildings The EPBD includes a requirement for the government to lay down requirements for the installation of a minimum number of chargepoints in all existing non-residential buildings with more than 20 parking spaces. This requirement must be set by March 2020 and will come into force by 1st January 2025. We propose to set the minimum requirement at one chargepoint per existing non-residential building with more than 20 parking spaces.

17. Do you agree that one chargepoint per existing building with more than 20 car parking spaces is a suitable minimum requirement to transpose the EPBD?

Yes (Go to question 19)

X No

Don't know? (Go to question 19)

Against existing non-residential building proposal

18. Why, noting this is the minimum we must do under the EPBD?

The quantified requirement is unhelpful:

• the requirement for non-residential buildings will be determined by the nature of the business and number of employees or customers who will park at the premises.

• A single chargepoint where there are 20 car parking places is unlikely to be sufficient unless the parking places are for short-term visitor (not employee) stays and the nature of the business is that visitors stay for only a short period and hence are unlikely to derive any real benefit from plugging in to a charger.

If inadequate provision is made then prospective users will not have confidence that the facility will be available when needed and hence make alternative arrangements – leading to the possibility of stranded investment if the facility is little used.

We need to be more ambitious than proposed if we are to achieve the UK Governments net zero emissions targets.

Existing non-residential buildings: application 19. How can the government apply these regulations in a way which balances the benefit to EV drivers and the requirements of the EPBD, with the burden on landowners?

Building owners could monetise the EVCP and use the return on investment to amortise the cost of the meter.

Existing non-residential buildings: enforcement

20. Do you agree that the appropriate enforcement regime for this power should see a sliding scale of penalties for non-compliance? X Yes (Go to question 22)

No

Don't know? (Go to question 22)

Against sliding scale

21. Why, including what alternative enforcement regime you think is suitable?

Existing non-residential buildings: enforcement 22. In your opinion the enforcement body should be:

Local Weights and Measures Authorities

Local Authority Building Control

X I dont know?

another body:

Mitigations 23. What steps do you think we should take to mitigate against any potential negative impact of the implementation of these regulations?

Cost of provision of chargepoints, and the electricity tariff applied to a particular chargepoint is obviously a consideration and there may be exceptional circumstances where the cost of compliance would outweigh the benefit (especially if there are alternative facilities nearby – such as a rapid charging forecourt). This illustrates the need for an overall strategic approach to public and private EV charging facilities.

Perhaps simple support/subsidy to landowners is needed. One incentive could be a refund of a portion of Stamp Duty when a buyer installs a charge point within, say 3 months, of purchasing a house)

Technical specifications for building regulation requirements

Approved Documents (ADs) are provided alongside the building regulations to provide guidance about how to comply with the regulations. We have published our draft version of the AD text.

Definitions

24. Are the definitions in the draft Approved Document accurate and provide their intended meaning?

Yes (Go to question 26)

X No

Don't know? (Go to question 26)

Against definitions

25. How, in your opinion, could the definitions be improved?

The boundary of the land or buildings belonging to and under the control of the building owner’ is a pragmatic interpretation of ‘within the boundary’ but there may be cases where communal parking (with allocated parking bays) is provided on land which is not under the ownership of the building(s) in which the residents live.

Such arrangements are not uncommon in new affordable housing developments and it will be important that these are also catered for under the mandatory requirements.

Diagram 3 in the Draft Technical Guidance for Building Regulations illustrates some examples of this but for EV transition to be viable for residents in such buildings, consideration needs to be

given to provision of (or for) chargepoints in parking areas detached from the boundary of the building – such as car park 2 in Diagram 3

Has the position of the leaseholder’s responsibility been considered?

Definitions

26. Do you agree with using the concept "within the site boundary" to define which parking spaces are in scope of the regulations?

Yes (Go to question 28)

X No

Don't know? (Go to question 28)

Against "in the site boundary" definition

27. Why not and what do you think an appropriate definition would be?

The boundary of the land or buildings belonging to and under the control of the building owner’ is a pragmatic interpretation of ‘within the boundary’ but there may be cases where communal parking (with allocated parking bays) is provided on land which is not under the ownership of the building(s) in which the residents live.

Such arrangements are not uncommon in new affordable housing developments and it will be important that these are also catered for under the mandatory requirements.

Diagram 3 in the Draft Technical Guidance for Building Regulations illustrates some examples of this but for EV transition to be viable for residents in such buildings, consideration needs to be given to provision of (or for) chargepoints in parking areas detached from the boundary of the building – such as car park 2 in Diagram 3

Has the position of the leaseholder’s responsibility been considered?

Technical specifications for EV cable routes and chargepoints

The Approved Document includes some minimum technical specifications for the EV cable routes and chargepoint. The government proposes specifying that the chargepoints must have a minimum charging power of 7kW, be at least Mode 3 or equivalent and be untethered.

28. Do you agree that the government should specify a minimum charging power of 7 kW? X Yes (Go to question 30)

No

Don't know? (Go to question 30)

Against 7 kW

29. Why, including any evidence you have, and specify what specification would be suitable? [Attach your evidence to your return] Comments:

3.5kW might be sufficient for some residents for overnight charging and also for ‘at work’ charging where vehicles might be stationary for around 8 hours or more – but any new electricity infrastructure (cabling etc.) should be based on an assumption of 7kW chargers to allow for possible future upgrades. This would effectively halve the charging time.

Note that slow charging in such cases might be both sufficient and have less impact on the local network (i.e. since the energy taken might be more evenly spread across the night or day rather than peaking at (say) 6pm or 9am and when vehicles arrive at home or work. 3.5kW charging might also be more easily accommodated by the electricity supply to the property.

Notwithstanding the above, in the context of the electricity supply from the grid, consideration needs to be given to the likelihood of the property(ies) in question being converted to electric heating at some point in the future.

Technical specifications for EV cable routes and chargepoints 30. Do you agree that we should specify that chargepoints installed under the building regulations should be at least Mode 3 or equivalent? X Yes (Go to question 32)

No

Don't know? (Go to question 32)

Against Mode 3 or equivalent 31. Why, including any evidence you have, and specify what specification would be suitable? [Attach your evidence to your return] Comments:

Technical specifications for EV cable routes and chargepoints 32. Do you agree that we should specify that chargepoints installed under the building regulations must be untethered?

Yes (Go to question 34)

X No

Don't know? (Go to question 34)

Against untethered chargepoints 33. Why, including any evidence you have, and specify what specification would be suitable? [Attach your evidence to your return] Comments:

This seems short-sighted as it implies that all EVs will have to carry a cable which might become unnecessary in the future. Consideration should be given to chargepoints offering both a tethered (i.e. a cable) and an untethered (i.e. a socket) option (a requirement which might in future be revoked if tethered chargepoints become standard)

Technical specifications for EV cable routes and chargepoints 34. In your opinion do the draft Approved Document specifications adequately consider accessibility requirements with regards to location of the: Yes No Don't know?

cabling routes? X

chargepoints? X Why including alternatives?

35. In your opinion what, if any, other accessibility requirements should we include in the Approved Document?

The location of chargepoints for disable parking needs to be carefully considered to avoid a vehicle being ‘shut out’ by an internal combustion engine vehicle parking in their designated space.

Technical specifications for EV cable routes and chargepoints 36. Are the specifications with regards to safety standards outlined in the draft Approved Document appropriate? X Yes (Go to question 38)

No

Don't know? (Go to question 38)

Safety specification insufficient 37. Why including what further safety specifications do you think we need to include? [Attach your evidence to your return] Comments:

Notifiable building work We propose that the installation, addition or alteration of dedicated circuits and earthing and bonding arrangements for electric vehicle chargepoints to be notifiable work under the building regulations.

38. Do you agree with our proposal? X Yes (Go to question 40)

No

Don't know? (Go to question 40)

Against notifiable building work 39. Why?

Approved Document scope 40. Does the proposed guidance in the draft Approved Document provide sufficient detail to comply with the requirements? X Yes (Go to question 42)

No

Don't know? (Go to question 42)

Against approved document scope

41. Why including any suggestions for how to improve the guidance? [Attach your evidence to your return] Comments:

Approved Document scope 42. The diagrams in the draft Approved Document are illustrative only but do you think they provide sufficient detail for compliance? X Yes (Go to question 44)

No

Don't know? (Go to question 44)

Against approved document scope 43. Why? [Attach your evidence to your return] Comments:

Approved Document scope 44. Does the draft Approved Document meet our overall proposed policy intent? X Yes (Go to question 46)

No

Don't know? (Go to question 46)

Does not meet policy intent

45. What information do you think is missing from the draft Approved Document to meet the intended policy intent?

Approved Document: additional information 46. What additional information, if any do you think needs to be added to the Approved Document? [Attach your evidence to your return] Comments:

Exemption to EV installation We can include some exemptions both to:

• the EPBD requirements (defined in Article 8 of the EPBD)

• our domestic requirement of a chargepoint in every home

The intention is for the regulations to only apply to buildings where it is appropriate to install EV chargepoints.

Lead in times The EPBD allows for an exemption for buildings that have submitted their initial building notice or full plans applications by 10 March 2021. This implies a period of one year between the implementation of the requirements in national building codes and the regulations coming into force. We would like to hear opinions on a reasonable lead-in time between introducing the new regulations and the regulations coming into force, for the:

• EPBD requirements for new non-residential buildings

• chargepoint requirements for new residential buildings

47. What do you believe is a reasonable transition period between publishing the new regulations plus guidance and the requirements coming into force?

Proposed exemptions for residential buildings 48. Do you think we should apply an exemption to our proposal to require a chargepoint in every new home when the grid connection cost is high?

Yes (Go to question 50)

X No

Don't know? (Go to question 50)

Against grid connection cost exemption 49. Why not, including any potential exemption you think is suitable?

Only if by exception the grid cost is particularly high and there are adequate alternative provisions – such as adequate local rapid charging facilities.

For newbuild, the incremental cost of installing infrastructure (substations / cabling) of higher capacity will often be small. Moreover, in terms of the local network (as opposed to connections to the properties) consideration needs to be given to possible future electrification of heating.

Grid costs – i.e. the costs associated with any upstream network reinforcement (above the ‘sole-use’ assets involved in connecting new properties and chargepoints to the existing electricity network which are subject to connection charges) should in any case be largely socialised through electricity use of system charging as per the current arrangement.

Note that homes with off street parking (i.e. driveways) where 3.5 or 7kW chargers are installed will impose costs on the grid (in terms of reinforcement) which (whatever the cost) will be fully socialised in most cases. It would be discriminatory to treat new or renovated properties differently.

The ‘high’ grid connection costs assumed in Appendix B are exceptionally high and it would be reasonable to assume a weighted average much closer to the ‘low’ cost.

Proposed exemptions for residential buildings Our quoted technical feasibility criteria for new dwellings is: "the installation of an electric vehicle chargepoint should be considered technically feasible if the additional costs of reinforcement and upgrades to the local electrical distribution network would not exceed [£3,600] per dwelling. This cost should be calculated as the additional capital cost for electrical infrastructure, as compared to that which would be required without the chargepoints. This cost may be calculated either: a. for a development containing multiple new dwellings; or b. for an individual dwelling Note for new dwellings where the installation of an electric vehicle chargepoint is not technically feasible, enabling infrastructure might be required."

50. Does this text capture the intended exemption? X Yes (Go to question 52)

No

Don't know? (Go to question 52)

Not capturing intended exemption 51. Suggest an alternative drafting.

Proposed exemptions for residential buildings We propose setting a threshold of three times the high scenario cost of the average electrical capacity connection needed for a chargepoint in a multi-dwelling building. According to the costs we have collated for the associated impact assessment this would be £3,600 per chargepoint.

52. Do you agree with our suggested threshold?

Yes (Go to question 54)

X No

Don't know? (Go to question 54)

Against threshold 53. What do you think is a reasonable threshold including any evidence? [Attach your evidence to your return] Comments:

Only if by exception the grid cost is particularly high and there are adequate alternative provisions – such as adequate local rapid charging facilities.

For newbuild, the incremental cost of installing infrastructure (substations / cabling) of higher capacity will often be small. Moreover, in terms of the local network (as opposed to connections to the properties) consideration needs to be given to possible future electrification of heating.

Grid costs – i.e. the costs associated with any upstream network reinforcement (above the ‘sole-use’ assets involved in connecting new properties and chargepoints to the existing electricity network which are subject to connection charges) should in any case be largely socialised through electricity use of system charging as per the current arrangement.

Note that homes with off-street parking (i.e. driveways) where 3.5 or 7kW chargers are installed will impose costs on the grid (in terms of reinforcement) which (whatever the cost) will be fully socialised in most cases. It would be discriminatory to treat new or renovated properties differently.

The ‘high’ grid connection costs assumed in Appendix B are exceptionally high and it would be reasonable to assume a weighted average much closer to the ‘low’ cost.

Mitigation 54. Does this exemption sufficiently mitigate any negative impact on housing supply? X Yes (Go to question 56)

No

Don't know? (Go to question 56)

Against mitigation 55. Why? [Attach your evidence to your return] Comments:

Other technical feasibility considerations to include 56 What other technical considerations do you think should be included? [Attach your evidence to your return] Comments:

Proposed exemptions for residential buildings 57. For our a chargepoint in every new home created from a material change of use requirement do you agree that we should apply an exemption for: Yes No Don't know?

listed buildings? X buildings in conservation areas? X

Explain your reasoning if you disagree.

There is no reason for the required infrastructure to be considered obtrusive given reasonable attention to siting and aesthetics – most cables and installation could be hidden in a planned manner, albeit at a slightly higher cost.

58. For our a chargepoint in every new home created from a material change of use requirement should we apply an exemption in cases where there is adequate spare capacity in the incoming electrical supply to the car park?

Yes (Go to question 60)

X No

Don't know? (Go to question 60)

Against exemption for adequate spare capacity 59. Why not?

This legislation needs be effective and if any easy options are available developers will find ways to exploit them and even saturate the market with exempted buildings

Proposed exemptions for residential buildings 60. If we apply the chargepoint requirement to residential buildings undergoing major renovations should we allow an exemption in cases where there is adequate spare capacity in the incoming electrical supply to the car park? X Yes (Go to question 62)

No

Don't know? (Go to question 62)

Against adequate spare capacity in the incoming electrical supply to the car park exemption

61. Why not?

Cable routes exceeds 7% 62. Should we apply an exemption where the cost of installing the cable routes exceeds 7% of the total cost of a major renovations within: Yes No Don't know?

residential buildings? X non-residential buildings? X

Why?

There is a need to differentiate between private (beyond the meter) and public network cabling.

Costs associated with the latter will be largely socialised and for newbuild the marginal cost over what would otherwise be necessary to supply the premises would be hard to identify but small in most cases. The ‘high’ grid connection costs assumed in Appendix B are exceptionally high and it would be reasonable to assume a weighted average much closer to the ‘low’ cost.

Small medium enterprise exemptions 63. Should we apply an exemption for the requirement for existing non-residential buildings to small and medium enterprises?

Yes (Go to question 65)

X No

Don't know? (Go to question 65)

Against small medium enterprise exemptions 64. Why not including any evidence you think is relevant? [Attach your evidence to your return] Comments:

The definition of an SME is far too high and includes a lot of business that could easily support and finance the EVCP installation.

Perhaps an alternative could be based on the turnover of the business, for example below £2million rather than the SME definition generally used.

Evidence and analysis We have published 2 consultation stage Impact Assessments alongside this consultation, to capture the residential and non-residential building requirements. The Impact Assessments includes information about the costs of the proposed policies and are based on some key assumptions around the development of the EV and the EV chargepoint markets. We are, through this consultation, seeking further evidence to inform the final stage impact assessments. In particular, we welcome views on the costings we are relying on and the robustness of our main assumptions. We also welcome views on any impacts or benefits not reflected in the impact assessment.

65. Do you agree with the: Yes No Don't know? assumptions set out in the Impact Assessment?

X

costs set out in the Impact Assessment? X

impacts set out in the Impact Assessment? X

Explain your reasons if you disagree.

66. Provide any evidence you think relevant to the impact assessment. [Attach your evidence to your return] Comments:

One of our members provided a copy of a recent quote for a substantial additional load at a carpark and based on 22kw AC and the minimum requirement of 7kw would suggest that your costs are on the high side. This has been attached as Appendix 1

67. How do you think these costs are likely to change over time? [Attach your evidence to your return] Comments:

Costs should fall as provision of EV charging is designed-in to new development proposals. On the other hand, if retrofitting or expansion of facilities becomes necessary in future due to inadequate initial investment, such costs will be much higher than if adequate provision had been made at the time of building construction or renovation.

68. What do you think are the likely cost reductions from economies of scale specifying whether the cost reductions will be relevant for both installation and hardware costs? [Attach your evidence to your return] Comments:

69. Do you think there are groups who would be impacted by these regulations that have not been captured by this assessment? X Yes

No (Go to question 71)

Don't know? (Go to question 71)

Additional groups 70. What additional groups and why? [Attach your evidence to your return] Comments:

Groups who would be impacted by these regulations that have not been captured by this assessment include the not inconsiderable number of residents (especially in affordable home developments) that have only an allocated parking space in a communal area.

The provision of dedicated facilities in communal areas is entirely practicable and should be included in the scope of these proposals

Evidence and analysis

71. Do you think multiple single-occupancy developments (such as housing estates) will be able to take advantage of economies of scale savings for chargepoint installation? X Yes

No

Don't know? (Go to question 73)

Multiple single-occupancy developments 72. Why? [Attach your evidence to your return] Comments:

We think that the provision of charging facilities in communal parking areas associated with multioccupancy buildings could be even more cost-efficient than installing a facility at each individual property.

Evidence and analysis 73. What are the likely technological learning rates that chargepoint hardware would experience and why? [Attach your evidence to your return] Comments:

74. Do you think our methodology for capturing grid connection cost variation is suitable?

Yes (Go to question 76)

X No

Don't know? (Go to question 76)

Better methodology 75. What do you think is a more suitable methodology for capturing the variation in grid connection costs? [Attach your evidence to your return] Comments:

There are many variables in practice dependent on existing localised capacity. However, any network upgrading costs should be socialised (i.e. as is the case with network reinforcement works) so the fact that costs will vary should not be a major consideration. There could be unique local factors which make provision of capacity unduly expensive.

The ‘high’ grid connection costs assumed in Appendix B are exceptionally high and it would be reasonable to assume a weighted average much closer to the ‘low’ cost.

Evidence and analysis 76. Does the assessment of cost incidence seem accurate?

Yes (Go to question 78)

X No

Don't know? (Go to question 78)

Against cost assessment 77. Why not, including any evidence you have? [Attach your evidence to your return] Comments:

Grid connection costs assumed in Appendix B are exceptionally high and it would be reasonable to assume a weighted average much closer to the ‘low’ cost.

Evidence and analysis

78. Do you think there are likely to be disruption costs in a retrofit scenario, and if so how large do you think these will be? [Attach your evidence to your return] Comments:

Retrofit will incur additional costs due to the need for disturbance of made-up parking areas etc. for cabling and provision of chargepoints.

Deep retrofit is essential if we are to achieve national carbon reduction targets See https://www.theiet.org/media/1675/retrofit.pdf The cost of chargepoint installation is a marginal increase over deep retrofit costs.

79. In your opinion have we captured all of the benefits?

Yes (Go to question 81)

X No

Don't know? (Go to question 81)

Other benefits in impact assessment 80. What additional benefits do you suggest including and why? [Attach your evidence to your return] Comments:

The proposals fail to capture benefits of provision of charging facilities in residential communal parking areas

Evidence and analysis 81. What do you think will be the impact on housing supply of introducing a requirement for chargepoint infrastructure on new dwellings? [Attach your evidence to your return] Comments:

Some additional cost but also perceived added value which in future should attract prospective property purchasers / tenants.

Final comments 82. Any other comments?

The Institution of Engineering and Technology is a global diverse home for over 168,000 engineering and technology professionals in 150 countries. Our Mission is to inspire, inform and influence the global engineering community, supporting technology innovation to meet the needs of society. Our thought leadership activities provide expert advice to the UK’s Parliament, Government and other agencies. on engineering related policy issues. We are regularly in the mainstream and specialist media explaining the impacts of engineering and technology on society.

The IET Wiring Regulations are published and are the standard for wiring regulations in the UK.by the IET. In addition, we regularly publish Codes of Practice and guidance materials for professional engineers and other key stakeholders. Links to some of these documents can be found at the end of this section. We use our expertise to achieve consensus on best practice in emerging and established technology fields.

In the section above headed ‘New dwellings’ question 4. asks ‘Do you agree with our proposed policy position to require a chargepoint in new dwellings? We indicated YES, however we wished to comment on this point further, and the only way this can be done is by indicating ‘No’ and answering question 5. ‘’Why not, including what requirement you think would be suitable (include any evidence you may have)?’

We simply answered yes, inserted a comment into question 5 and repeat the text here:

The proposal is good as far as it goes but it needs to go further. Many new dwellings – especially affordable housing developments - either have no associated car parking space within the boundary of the property. Some have allocated parking bays but in communal areas where it would be impractical to wire the chargepoint back to the resident’s home wiring. Consideration should be given to solutions that enable residents with allocated parking in communal areas to have access to a dedicated chargepoint/s in the communal parking area if they so choose – albeit this might need to be metered separately from the resident’s home electricity meter. In such cases the resident should not have to pay fixed use of system charges for both meter points, and from an energy billing perspective the consumption at the two meter points should be summated and charged as a single bill if the customer so chooses (the customer might elect to contract with a separate supplier for the EV chargepoint in which case summation of the two consumption volumes will be separately billed and two standing charges might be incurred).

Our overriding comment is that the proposals are insufficiently ambitious given the UK’s 2050 Net Zero and Road to Zero Carbon ambitions which require that every EV owner has reasonable and practicable accessibility to EV charging infrastructure – which for most people will mean access to overnight charging facilities at or adjacent to their homes.

Proposals in this consultation build from an assumption that home charging for electric vehicles will be a preferred customer option on an enduring basis. From experience to date, there is evidence that home charging continues to offer solution options that are:

• Cost efficient (particularly when charging overnight)

• Convenient for customers to use.

Based on this assumption that home charging is an enduring option, a mandatory approach for charging infrastructure provision appears reasonable. However, mandating full chargepoint installation ahead of customer need will require greater level of upfront capital expenditure than would arise if the requirement was defined in respect of enabling infrastructure. Costs faced by a developer and/or landowner are generally recovered from building occupants. It is not clear from the consultation material that this consequence has been considered yet. It is important that assessments that inform Government policy thinking have fully:

• considered the value and costs associated with both chargepoint availability and usage

• assessed consequential financial impacts on building occupants.

We reiterate that little information is provided in this consultation about the proposed treatment of dedicated parking spaces that are not immediately adjacent to the meter point at the property with which they are associated. This point is applicable for single occupancy as well as multiple occupancy buildings. To date the cost benefits associated with home charging have been based on the use of the property’s electricity supply.

There is a risk in mandating installation of chargepoints that are dedicated to a property possibly many years ahead of actual need. This type of approach may:

• Constrain innovation

• Lead to unnecessary costs (e.g. due to equipment becoming obsolete before use)

• Restrict the development of other solution options and types of solution.

The proposed minimum chargepoint requirements in respect of size and connector type) appear reasonable for the future. However, it is unlikely to be reasonable for such requirements to be applied retrospectively. Proposal for an untethered chargepoint to be part of the mandatory requirement (i.e. attach your own charging cable) would seem to unnecessarily restrictive and may override homeowner choice. The reasons for restricting this choice are unclear in the consultation. We think there needs to be a consultation with EV manufacturers to agree a standard.

Within the consultation there is a focus on a specific approach for one chargepoint per dwelling. It is not clear from the consultation whether consideration was given to alternative requirements for chargepoint facilities that can be shared between occupants of a number of dwellings.

It would appear to be unreasonable if equivalent requirements for chargepoints were not applicable as part of a major renovation and/or change of use developments as are required for new developments.

Section 6.10 of the consultation document highlights possible additional power supply requirements for carparks with multiple charge points. It should be noted that similar capacity issues may arise on distribution networks connecting residential properties when there is less diversity in usage requirements between properties.

The consultation materials do not include results of sensitivity analysis to assess the robustness of this assumption as the volume of electric vehicles (and therefore charging demand) increases. Such analysis is recommended to establish whether there is a demand point (or demand points as this may not be a national figure) at which overnight electricity demand is unlikely to be treated as an off-peak product.

The policy position in respect of the proposed use of exemptions (in respect of requirements to install chargepoints) is not wholly clear. Whilst a mandatory requirement without an exemption regime is not advised, there are risks associated with unintended incentives that can be associated with exemption arrangements (e.g. the perceived attraction of being just outside the exemption threshold). Process guidance in respect of the proposed exemption regime is advised to ensure that there is clarity about the responsibilities of the:

• Applicant for exemption

• Party authorised to grant exemption

• Party(ies) that monitor conformance with the Regulations.

The proposed exemptions (from mandated requirements in respect of chargepoints) would significantly benefit from the introduction of monitoring arrangements as part of implementation, to ensure that the exemption regime is not used other than for its intended purpose.

Here are some links The IET’s publications that are pertinent to this consultation.

• Wiring Regulations B7671

• Draft public comment for the IET Guide to Smart Homes for Electrical Installers

• Guide to Energy Management

• Code of Practice for Electrical Safety Management

• Code of Practice for Connected Systems Integration in Buildings

• Code of Practice for the Application of LED Lighting Systems

• Code of Practice for Low and Extra Low Voltage Direct Current Power Distribution in Buildings

• Practical considerations for d.c. installations

In conclusion we received an email from one of our members that clearly demonstrates the need for an integrated consumer friendly solution to the installation of EV chargepoints:

My wife and I own a Renault ZE40 as our only car - giving us approximately a 170 mile range. My wife is the main driver as I use public transport to get to and from work. We have a son who is still at school. The main use of our car is domestic stuff - school runs, shopping, visiting friends, etc. However: twice a year we drive to my wife's parent's place for family visits. A 300 mile journey (600 mile round trip) We find that the existing EV charging network is not adequate for long journeys for a number of reasons:-

• The charging points do not give a full charge. They typically add 50 miles or so

to the range of the battery - usually just enough for us to reach the next charge

point.

• Charging points differ massively in their requirements for use. Some need an

app. Some need membership. Some are in use or not working even though the

app says they are available for use.

• There are not enough charge points. The service stations we use (because we

have the app) usually have two or three charge points, which would be insuffi-

cient if a queue were to form. We haven't experienced "pump rage" yet, but I've

sensed it lurking beneath the polite exterior of other users.

• If our mobile phone battery fails, or the phone fails in any way, we would be

stranded.

• All the above means we have to break our 300 mile journey at a friendly Bed and

Breakfast place which allows us to charge up from the regular mains supply. So

a seven hour drive takes almost two days. Not all EV owners have the equip-

ment available to charge up from a 13Amp mains plug.

I have two big suggestions:- 1. The charge points need to fully charge the car (or get us to around 90% charge) -

quickly. 2. The charge points need to be "pay as you go" like fuel pumps are. Turn up - fill

up - pay by cash/debit card/credit card. Ditch all the requirement for membership and apps (or make them optional).