The drive towards electric vehicles

LPAs, in more recent years, have sought to introduce requirements for EV charging points in new residential developments. However, all new developments in England could soon be required to follow suit.

Once again this week, Extinction Rebellion is dominating the national news headlines with a second week of staged protests in London, as part of its “International Rebellion”¹. Regardless of what you think of their tactics and motivations, you can’t escape the fact that they’ve forced climate change firmly onto the media’s and policy makers’ agendas.

Extinction Rebellion has set out three ‘Demands’, including that the Government must “...reduce greenhouse gas emissions to net zero by 2025”². Whilst Extinction Rebellion believes that the Government is not doing enough, quickly enough to combat climate change as a matter of urgency, the Government has pledged a commitment to supporting the development of “one of the best electric vehicle infrastructure networks in the world”³ as part of its ‘Road to Zero’ strategy published last year, to help meet the challenge of achieving net zero greenhouse gas emissions by 2050⁴.

In terms of planning, Local Planning Authorities have, in more recent years, sought to introduce requirements for electric vehicle (EV) charging points and other energy efficiency measures in new residential developments, and the revised National Planning Policy Framework (2019) encourages developments to be “designed to enable charging of plug-in and other ultra-low emission vehicles in safe, accessible and convenient locations”⁵. However, all new residential and non-residential development in England could soon be required to install charging infrastructure for electric vehicles under proposals detailed in the Government’s consultation on ‘Electric Vehicle Charging in Residential and Non-Residential Buildings’⁶.

The consultation details the Government’s proposals to introduce a new part to the English Building Regulations to require new buildings, and buildings undergoing material change of use and major renovation, to be equipped with EV charging infrastructure.

As part of the consultation, which ended on 7 October 2019, the Government outlined the following policy positions relating to new residential and non-residential buildings, in addition to existing non-residential buildings⁷:

Residential Buildings

• Every new residential building with an associated car parking space will have a chargepoint. This requirement will also apply to buildings undergoing a material change of use to create a dwelling.
• Every residential building undergoing major renovation with more than 10 car parking spaces will have cable routes for electric vehicle chargepoints in every car parking space.

New Non-Residential Buildings

• Every new non-residential building and every non-residential building undergoing a major renovation with more than 10 car parking spaces will have one chargepoint and cable routes for an electric vehicle chargepoint for one in five spaces.

Existing Non-Residential Buildings

• At least one chargepoint will be installed in existing non-residential buildings with more than 20 car parking spaces (applicable from 2025).

The proposed amendment to Building Regulations aligns with the requirements of the EU Energy Performance Buildings Directive (EPBD), which has been in force since 2010 and was subsequently revised in July 2018⁸.

With regard to existing non-residential buildings, the EPBD requires that Member States set a minimum requirement for EV chargepoints for such buildings with more than 20 car parking spaces, with this requirement enforceable from 2025. However, this requirement will need to be transposed through different legislation, as Building Regulations apply only to building work when it is being carried out⁹.

The measures to both require and encourage EV uptake outlined in the consultation represent a significant step not only nationally, but also on an international scale, with the proposed legislation, if implemented, set to represent a world first. If the proposed legislation is carried through, the provision of EV charging points would be required by law, rather than encouraged by planning policy.

The proposed legislation on EV charging infrastructure would have consequences for developers, introducing additional upfront costs to be considered. However, drawing on the Government’s evidence base, it is more cost effective to install EV charging infrastructure at the beginning of the development process, with the cost to retrofit the average home with an EV charging point approximately £1,064 more expensive than installing the chargepoint up front¹⁰. This is similarly the case when installing EV charging infrastructure in non-residential car parks. Consequently, it is likely that the installation of EV charging infrastructure is already on developers’ agendas, despite the legislation expected to come into force in 2020.

The Government’s stated position on EVs sends a positive political message in the context of growing international emphasis on climate change and in light of the UK’s commitment to achieving net zero greenhouse gas emissions by 2050. Nevertheless, encouraging EV uptake is unlikely to be easy, with the UK car market still dominated by petrol and diesel cars, and electric charging vehicles accounting for less than 4% of the overall market¹¹. Furthermore, the Government’s commitment to encourage EV uptake comes against a background of subsidy cuts¹², with the 2019-2020 budget for the plug-in grant scheme totalling £96 million, representing a decrease of approximately 23% on the period 2018-2019¹³.

In parallel with the above consultation, the Government has also consulted on proposals for EV chargepoints to have smart charging functionality to manage the effect of EVs on the UK’s electricity system and to allow consumers to take advantage of cheaper electricity¹⁴. Overall, it will be interesting to track the impact of the ‘Electric Vehicle Charging in Residential and Non-Residential Buildings’ consultation, with 2050 – and the net zero greenhouse gas emissions target - not a million miles away.

Georgina Blackburn
Graduate Planner
T: 0161 956 4006
E: [email protected]

References:
1.Extinction Rebellion
2.Extinction Rebellion
3.The Road to Zero Strategy, Next steps towards cleaner road transport and delivering our Industrial Strategy (July 2018), p.4
4.The Climate Change Act 2008 (2050 Target Amendment) Order 2019
5.National Planning Policy Framework (2019), Paragraph 110, Part E
6.Electric Vehicle Charging in Residential and Non-residential Buildings (July 2019)
7.Electric Vehicle Charging in Residential and Non-residential Buildings (July 2019), p.7
8.Energy Performance of Buildings Directive
9.Directive (EU) 2018/844 of the European Parliament and of the Council of 30 May 2018 amending Directive 2010/31/EU on the energy performance of buildings and Directive 2012/27/EU on energy efficiency, paragraph 26
10.Electric Vehicle Charging in Residential and Non-residential Buildings (July 2019), Paragraph 9
11.SMMT Vehicle Data, EV & AFV Registrations, September 2019
12.Changes to the Plug-in Car Grant (November 2018)
13.Electric car prices to soar as axe falls on green subsidies, The Guardian (October 2018)
14.Electric Vehicle Smart Charging (July 2019)