Our response to Transport Scotland’s consultation on the Draft Electric Vehicle Public Charging Network Implementation Plan

Yes, Figure 1 is consistent with our view of how the private sector will be involved in financing electric vehicle infrastructure (EVI) in Scotland across the next five years.

It is expected that the private sector will provide more investment than the public sector (where available) within procurements. In some cases, the private sector will offer to fully fund EVI contracts, depending on the area and the commercial interest of the project. Further considerations can be seen through alternative financing models in the response to Question 3. 

It is important to consider the impact of relying heavily on the private sector to deliver future public EVI. The private sector can only run the network if it is a profitable exercise. It will therefore gravitate towards higher traffic, higher profit locations and tend to avoid areas likely to see lower usage. Without intervention, this risks certain areas being left behind in the clean energy transition, for example rural and island areas.

There may be solutions that ensure all areas can cover their costs as a minimum – such as reducing CapEx and OpEx costs with integrated battery storage. If such solutions don’t materialise, then either the private sector will be allowed to largely disregard these areas, leaving the public sector to step in as provider of last resort, or the private sector will be compelled as a condition of local authority concession contracts to attend to these areas. 

The former option will mean propping up loss-leading locations with public money, while the private sector capitalises on profitable locations. This could be perceived as an inequitable situation. The latter option will require private providers increasing tariffs to cover their losses in lower traffic areas.

This will increase the cost and convenience charging gap between people with off-street parking who are able to access cheap overnight tariffs and those wholly reliant on more expensive public charging. This could potentially exacerbate inequality and compromise a just transition. The higher cost of charging could also disincentivise switching to EVs and slow the clean energy transition. 

These are the risks of depending on the private sector to deliver this transition. An alternative approach would be to treat this infrastructure as an extension of the publicly funded road networks and fund it from the public purse. The risks and advantages of both approaches should be fully considered in the context of the Scottish Government’s social and environmental ambitions. 

It is also worth noting that vehicle Original Equipment Manufacturers (OEMs) may be well placed to run a private network, as the existence of a well-functioning, comprehensive network will underpin their EV sales success. They may be able to hedge the low margins of operating an effective network across the more profitable parts of their portfolio – ie vehicle sales.

This could explain why, according to ZapMap, Tesla ranked the highest for user satisfaction in the ‘ large’ category (300+ rapid/ultra-rapid) in the UK in 2024 – achieving a 4.7 star rating vs second placed MFG’s 3.8 stars. In the medium network rankings (100-300 rapid/ultra-rapid), the major vehicle OEM joint venture, Ionity, ranked second. These OEMs have significant legacy ICE technology investments they still want to maximise returns on and are therefore arguably not yet fully committed to electrification.

This high ranking of some OEM’s could therefore be a conservative indication of what’s achievable once these companies have fully committed to the low carbon transition.

It is essential that the pace of new chargepoint installations increases significantly in Scotland to get from the current 6,000 to the target of 30,000 units by 2030. This will require major investment. The private sector has thus far demonstrated a willingness to withstand current losses in anticipation of future revenue. This appetite for losses rests on the expectation of future revenue from greatly increased numbers of electric vehicles on the road.

New and used EV sales continue to achieve record breaking growth year on year in Scotland and the rest of the UK. However, the pace of this growth is still slow. Scottish new battery electric vehicle registrations from 2020-2025 were 5.7%, 7.9%, 10.6%, 10.2% and 11.8%* of overall sales, respectively.

While battery technology continues to advance and the price of these vehicles to drop correspondingly, there are significant challenges preventing sales from truly taking off. These include challenges such as those relating to delivering a fair priced network, as discussed in our response to question 1, as well as increasingly entrenched political and cultural opposition to these technologies.

We do not know what proportion of Scotland’s vehicle stock must be electrified before public charging networks can become profitable, nor how long the private sector can sustain investment in these networks’ development before this tipping point is reached. We do however know that this point must be reached, or private investment will cease. 

The industry recognises that the uptake of EVs and the rollout of supporting infrastructure are entirely codependent components of the wider transition to an electrified, low carbon energy system. It is therefore vital that we make all possible efforts to facilitate the success of both.

This means using whatever financial levers are available to incentivise this transition, as well as identifying and tackling barriers to success. The latter will include making concerted efforts to counter the spread of mis and disinformation intended to slow or prevent the clean vehicle transition.

*Please note that these sales growth figures come from SMMT and should not be shared beyond Transport Scotland. These figures must be excluded should the results of this consultation exercise be made public. 

Provide guidance for local authorities to use in their EVI procurements to encourage private sector investment into the market, while also protecting the interests of local authorities to ensure there is a fair level of compromise between both the local authority and the Charge Point Operator (CPO), that achieves large scale deployments and substantial private sector investment. 

This guidance should outline best practices for procurement and contract design, drawing from established models of best practice. This should also cover common pitfalls likely to deter potential bidders. 

Transport Scotland should also support the development of a standardised approach to procurement across all local authorities. This would minimise the burden on private sector players who currently have to respond to multiple highly varied tenders. 

Transport Scotland may also be interested in a recent webinar on maximising private sector investment in EV infrastructure which we hosted and included speakers from PA Consulting, Green Finance Institute, and the UK Infrastructure Bank (now National Wealth Fund):

These barriers are generally well understood within the industry, and many are touched on elsewhere in this response, but are worthwhile summarising here. They include: 

• Higher upfront cost of electric vehicles compared to ICE vehicles. 
• Lack of electric alternatives in all ICE vehicle operational spaces – eg those well suited to all season driving in very remote and rural areas.
• High cost of public charging vs home charging. 
• Electrical regulations pertaining to ‘simultaneous contact risk’ that may restrict or prevent mass roll out of cross pavement solutions. 
• Meeting planning requirements and obtaining timely planning consent. 
• Lack of resources in in critical sectors – eg planning departments and knowledge specialists within local authorities. 
• DNO costs and timelines in delivering their enabling works. 
• Lack of viable locations for charging infrastructure in some areas of need. 
• Growth of misinformation around the low carbon transition 
• Lack of understanding among the public of the benefits of switching to an EV to drive-up adoption 
• Low visibility and awareness of existing EVI with non-EV drivers, which feeds into the negative attitudes that EVs are only suited for short-medium journeys and/or for people with offstreet parking. 

Theme one

Guidance should also be developed at a wider government level, as well as the local level. Central guidance can act as a blueprint for local authorities to adapt to their local needs and conditions. This will be particularly useful for authorities who are further behind than others in their thinking around cross pavement solutions. We suggest including Transport Scotland as a responsible authority as well as local authorities.

Guidance must also take into account electrical regulations pertaining to ‘simultaneous contact risk’ as they relate to multiple cross pavement solutions installed in close proximity. The implications of these regulations and the actions needed to overcome the obstacle they create must be investigated in the course of developing this guidance.

These actions may necessitate providers of home chargepoints being required to share all details relating to earthing systems used (including on previous installs) somewhere other installers operating in the same area will have sight of them. This information should also be collected for street furniture and housed in a central database. Due consideration would need to be given to data privacy as part of this.

Building capacity through EVI contracts should clearly set out any concession fee and what it is for. This can be applied as an indexed annual charge to cover the cost of contract management and administrative costs. In addition to this, a small revenue share could be applied as part of the contract. We note that high concession fees in contracts might deter the private sector from responding to tenders and recommend that concession fees should be consulted on with the market, through pre-market engagement.

Theme two

We agree with this action. We note that it might not be possible for all sites to conform to the standards. It would be best practice to adhere to the standard and conform to the conditions for accessible bays and consider the recommendations in the standards for standard bays. It is also the responsibility of the local authority to ensure that this is covered in tender documents and contracts with suppliers.

We agree that an appropriate tariff administration strategy should be implemented by the local authority as part of the procurement. The suppliers would also be involved upon bidding for the contract and agreeing the figures that fill in the theory. We also recommend that chargepoint operators are included as a responsible stakeholder.

Theme three

We agree, other financing groups in these discussions, such as the Green Finance Institute, should be included in these discussions. 

We agree, engaging distribution network operators is key in understanding capacity to deliver large scale EVI rollout. Ensuring DNO application processes are clearly laid out by the DNOs, and kept up to date with any changes, so they are clear for the local authority or CPO to apply through. Engage through forums mentioned in our response to question 6.

We agree, the market should continue to commercialise. Though with a recognition of dynamics outlined in response to question 1. 

Theme four

We agree, and it will be important to engage with these stakeholders regularly as mentioned in our response to question 6. We think it would be helpful for Transport Scotland to liaise with rural authorities in England to learn lessons about how these barriers can be overcome.

Through delivering the LEVI scheme for the Department for Transport we have developed good working relationships with a number of English rural authorities that have made considerable progress in EVI development. We would be happy to facilitate introductions with some of these local authorities if Transport Scotland would find this useful. 

Theme five

We agreed, a central monitoring and reporting log for chargepoints installed across the nation would be key.

Key stakeholders have been mostly noted in the executive summary as CPOs, DNOs, local authorities, UK Government, and National Electricity System Operator (NESO).

It is recommended that these groups should be engaged with regularly in a recurrent series of forums in order to share implementation plans for EVI rollout, and to enable a feedback loop to help inform policy decisions to rollout EVI from stakeholders. We suggest the introduction of the following forums: 

• Local government forum, inclusive of key local authority contacts, COSLA, and sub-national transport bodies. 
• CPO forum, inclusive of all suppliers for public charging and cross pavement solutions providers and major highways contracts that work within EVI.
• DNO/iDNO forum, inclusive of wider electricity organisations such as NESO, Ofgem and Consumer Scotland.
• Centralised forum for Transport Scotland, Scottish Futures Trust and Crown Commercial Services.
• Advisory forum, to include key contacts from different areas of EVI including procurement (CCS, Scottish Futures Trust, experienced local authority officers in EVI), finance (including the Green Finance Institute), analytical companies, delivery organisations such as ours. 

We recommend that the following key stakeholders should also be involved more broadly:

• Local authorities and local government representative organisations such as COSLA. 
• Chargepoint Operators, spanning each tech and power output speciality, inclusive of cross pavement solutions providers, highways contractors.
• Distribution Network Operators and Independent Distribution Network Operators.
• NESO. 
• Ofgem. 
• Sub-National Transport Bodies. 
• Communities, and residents (through councils). 
• Other governmental bodies such as Scottish Futures Trust, the Crown Commercial Service, SCOTS etc. 
• Other public sector bodies including blue light services. 
• Other analytical companies such as field dynamics and Zap-Map, to understand demand for EVI in the future based on EV uptake.
• Vehicle dealerships. 
• Car hire/car club businesses. 
• Fleet managers. 
• Media and other public engagement outlets. 
• SMMT. 

Most of the key aspects of consumer experience have been detailed in the report, particularly: 

• Affordable tariffs and ease of payment (contactless etc).
• Accessible infrastructure, and surrounding environment. Considerations of standards such as PAS 1899 considered for standard bays and adhered to for accessible bays. This section could include some wording around safety of charging sites, particularly the inclusion of CCTV and appropriate lighting.
• Visibility of chargepoints, locations, availability.
• Reliable network and high uptime requirements for suppliers (PCPR 2023). 

There is no mention of smart charging in the consultation document. This is a developing part of the industry and should be considered in the approach to rolling out EVI at scale. Measures such as preferential tariffs (time-of-use) and dynamic load balancing can benefit both the consumer and the network. We recommend that the following regulations are considered when incorporating smart charging into the implementation plan: 

• Regulations: electric vehicle smart charge points
• Public Charge Point Regulations 2023 guidance

Another element of the consumer experience that should be considered is enforcement and penalising improper use of EVI bays that are designated. ‘ICE-ing’ of bays can be a frustrating consumer experience. 

We also think that the potential role that booking systems could play in a comprehensive, accessible network considered in the final implementation plan. This technology could help give those who would be wholly reliant on public infrastructure assurance that they can arrange to have guaranteed access to infrastructure at times and places they choose.

It could also help boost usage rates of the EV charging infrastructure, accelerating the return on investment. This could in turn enable lower tariffs in areas where booking capable infrastructure was available and widely used.

Overall, public engagement is key to not only improving the consumer experience of Scotland’s public network but also increasing EV uptake across Scotland. With continuous improvement and growth of Scotland’s network in addition to emerging technologies across vehicles and charging infrastructure (public, destination and home) it is key that the public are informed about the current experience and the future experience. 

We would very much welcome a conversation with Transport Scotland about the experience of EVI rollout and grant schemes that have proven effective in England. These insights could provide valuable input on successful approaches, which may be useful for informing Transport Scotland’s final implementation plan. 

We think that Transport Scotland should consider additional funding streams for the financing of EVI, including (but not necessarily limited to) asset financing and or Equity loans.

As the market moves to an early majority, private lenders are beginning to offer loans for EVI. The key factors to consider are the tenure of the loan (length of term) and interest rates which can be fixed or floating. The repayment of the loan will typically rely on revenue from the EVI deployment.

Therefore, a good view of current and future utilisation of the EVI and a commercial arrangement which allows the local authority to earn sufficient revenue are essential to secure the loan, some sources are Public Works Loan Board (PWLB), Asset Finance by Crown Commercial Service (CCS), National Wealth Fund (NWF) – previously UKIB.

We would also welcome a conversation about the role we could play in engaging with the public on EVI to support EV adoption and help counteract misinformation and negative attitudes to electric vehicles. Such engagement activity could be undertaken in a number of ways: 

• National consumer advice campaigns through established advice services such as Home Energy Scotland and Business Energy Scotland.
• Online, up to date information to provide trusted and impartial advice on the current and future EV landscape in Scotland. 
• Engagement with dealerships to improve their understanding of the charging needs of different customers based on their vehicles, property type, property tenure and driving behaviour. This could improve customer’s experience by providing impartial and accurate advice on how they can charge their vehicle at the point of sale.