The UK Government has run a consultation on consumer experience at public charge points (Spring 2022). The outcomes of the study (link below) can be summarised in six bullet points. The consultation was run as a public consultation and received responses from individuals, industry and ‘interested parties’. 

The proposals will (subject to parliamentary timetables) be presented around April this year with some things kicking in immediately and others taking time. 

Below is a summary and the Paua team thoughts. As a provider of payment and access services via the Paua EV charge card it is inevitable that we have an opinion in this space so we have added that as well!

The six headline proposals are:

1. A minimum payment method at all new charge points of 7.1kW and above; additionally, to be retrofitted to 50kW and above. The implication is credit card terminals at all chargers.  Immediate upon legislation being laid (April 2023). The use of an EV charge card would not seem to satisfy the current regulations.
2. Payment roaming, i.e. some form of alternative access to the charge point providers’ own solution. Otherwise just referred to as roaming. Likely this is OCPI based and the Government will require connections with at least one other party. Timescale – 2 years after legislation (April 2025). This supports the Paua electric fuel card proposition.
3. Open data. The provision of real time data on all connectors (via OCPI) without contract or obligation on the using party. Timescale – 1 year after legislation (April 2024).
4. Pricing transparency. All chargers to present a price in £/kWh. So you can keep a fixed fee or a time fee as long as you present it in £/kWh.
5. 99% reliability standards on rapid chargers. Reporting to the regulator on this performance. Reporting has to be based on OCPI data. Implementation is stated as one year from regulations. BUT, it is understood this means the first report on reliability so operators need to start gathering data immediately.
6. All charging networks to operate a 24-7 helpline. And report on the call data to the regulator. 

Some views from the Paua team (Read as ‘personal views from Niall the Paua CEO‘, so take with a pinch of salt!)

• The UK already has regulations in place for EV chargepoints. This is based on the implementation of the Alternative Fuels Infrastructure Directive. However there is no active regulator for this and therefore a lot of the implementation is not enforced.
• A regulator has been proposed in the form of the Office for Product Safety & Standards. Nothing has been seen from them yet on EV enforcement actions. And it remains unclear what is being done to make this a proactive body. We expect to see something on this space post regulations being laid.
• There is the possibility for some gaming around the power capabilities on public chargers to avoid needing to fit costly additional payment equipment. This may well involve the proliferation of 7kW chargers below the proposed 7.1kW limit. Similarly a number of 50kW chargers only actually operate at speeds lower than 50kW so we anticipate these being re-rated at 48kW or similar. Credit card readers feel like this has been pushed by the big payment players on the basis that they operate ‘open loop’ payments. The ‘open loop’ payment methods work on the systems of the big players so avoids payments moving away from the historical payment ecosystems. 
• Payment roaming is inevitable and logical. However, it will be a burden on smaller operators who may not be set up to deliver OCPI. Particularly those networks who are building their own software.
• Open data is a total minefield for charge point operators. Whilst on one side it provides visibility for drivers, the current proposal also exposes businesses to releasing their confidential information without obligation to anyone. The visibility of attractive and less attractive locations has implications for investment into the future of charging networks. From what we at Paua understand, a number of CPO’s are not familiar with this requirement at all and will likely resist it strongly.
• Pricing transparency is a positive move, although it probably leads to only one outcome; a single p/kWh price which is likely to be the right direction, regardless.
• The overall strong lean towards OCPI is interesting. As an open standard it may not always do what governments want. And as above it will be a burden to implement for smaller operators.
• Reliability is a good thing to have. The reporting approach based on OCPI is sub-optimal and open to both abuse and false data. But the direction of travel is correct. The requirement as to the implementation date has not been confirmed by OZEV at the current time. It remains unclear as to whether the first report is to be released in April 2024 (i.e., data has to be gathered from April 2023 – Niall’s current view) or whether data gathering only begins in April 2024 with reporting from April 2025. We have asked OZEV for clarity. 

Overall this feels like a bundle of proposals intended to do the right thing. There are areas that could be improved and areas that feel like excess influence is being applied to the sector. As a leading provider of an electric vehicle fuel card to businesses we were pleased to see recognition throughout the proposal that fleets and business drivers were being considered. Currently there isn’t a centralised EV infrastructure body that presents a position on these topics but ongoing Government intervention in markets tends to lead to a consolidated group so we would expect to see such a body set up soon. 

Consultation results: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1066972/government-response-to-the-2021-consultation-on-consumer-experience-at-public-chargepoints.pdf 

Alternative fuels infrastructure regulation: 
https://www.gov.uk/guidance/regulations-alternative-fuels-infrastructure