IEVA welcomes the work by ZEVI in bringing this document on “Universal Design Guidelines for EV Charging infrastructure” to public consultation, with the intention to have clear guidelines on the design, installation and operation of electric vehicle charging infrastructure in Ireland. This is a vital part of a Just Transition, giving individuals of all abilities an EV infrastructure that is universally accessible. A core tenet of the Association, we cannot transition to a sustainable transport model and leave people behind with facilities that are not easy, or safe to use.

We would also thank ZEVI for the time given in the Consultation phase to work through the initial framework of the Guidelines to give our initial feedback before this document went out for consultation.

Charging Station Design

With respect to the section on “Charging Station Design”, the guidelines set out are useful and wanted for any individual to be able to use a charge point. Cable Length, Weight and Rigidity are important to have right so that users can easily connect the cable to their vehicle. Currently we see issues for users where cables are too heavy or too short. This inhibits all users, especially those such as wheelchair users or individuals with mobility issues. We would see that there are no justifications for a charging station design in any location to be inaccessible, which many of the existing units today are, with Component, Screen and Footwells impeding their use.

Ease of payment using Tap-to-charge, and in the future Plug-and-charge should make up the minimum and first course of action for a user at a Charge point, and not the use of apps or fobs. The few charge points that have this functionality make for a much faster usage for new and existing EV users, as the process is simplified and typically easier to follow and implement repeatedly with ease. Apps normally work well, but far too often they don’t, so a simplified flow is required here.

Finally component labelling and Emergency stop buttons need to be clearer. This allows users to understand the differences that may exist between Charge point units, but also correct actions to take. Emergency buttons should be covered to prevent ease of being pressed as a means to ‘stop a car charging’, a common occurrence. With this, many charge points do not come back online after a user does this. All Charge Points should have a ‘built in self test’ upon releasing an Emergency Stop button to bring it back online, and to have an engineer call each time this is pressed.

Site Design

With respect to the section on “Site Design”, the key points here relate to safety and ease of use. Lighting, security cameras, weather protection are all items that should be a minimum standard for any charge point. Currently in the existing network, EV Charge Points are treated as street furniture that sits on the side of a footpath or road, and not as essential infrastructure for a decarbonised transport network. This leads to infrastructure being placed in locations where individuals, especially females do not feel safe. They are often placed in car parks with existing standard parking bay sizes, in poorly lit locations away from amenities and the main flow of traffic in an area (i.e. secluded).

No EV charge point should need to be designated with special marking for wheelchair users. All EV infrastructure should be accessible by everyone, in any location, at any time. Parking bay dimensions and Access should be universal for all users. Our existing re-fueling network is always covered and is set up to allow a ‘drive through’ approach to refuelling, we should be doing the same with our ‘new’ re-fueling network as the need for large or long vehicles and those with trailers will not disappear. The guidelines set out by ZEVI are welcome, and the bare minimum our members expect from a modern & inclusive charging infrastructure.

Information and Communications

Information for users is important. With multiple Charge Point Operators (CPOs) operating in Ireland, a central independent online database is important for end users. This will allow for Mobile applications & Navigation systems to know where to travel to with up to date information for all operators. Pricing should be available for all units through this system, so that users can make informed decisions on where and when they charge, before they get there. And when they do arrive, on-site signage is important to know where to go to use the Charge Points themselves. At times, Charge point units do not work, and 24/7 reliable assistance is important to have, which also ties in with safety for users at each site. At all times, there should be a means to contact a representative for any issues that may occur. Adding to this, we see that certain sites only have one CPO. We are starting to see monopolies of CPO’s at sites, with others being kicked out when leases come to an end. Ideally there should be a choice for the consumer of multiple CPO's as per other European sites, with clear signage and communications to pricing and usage to this effect.

Finally, any steps to give consistency in Charge Point usage across networks is welcome. Consistent light colours for charging status is welcome, along with audible cues. Some CPO’s show this, along with SOC % in lights, which allows for others to make clear decisions in the event of a queue for charging. Where EU wide standards come in relation to this is welcome, as this will in the end help both those travelling to Ireland in an EV, but also those travelling from Ireland to other EU countries to have a sense of ‘normality’ to the Charge Point process.

Any work to improve the experience across CPOs and even at an EU level is welcome, and this will only serve to improve the end-user experience.

Overall at IEVA we welcome the recommendations and guidelines in this document. There are many areas in the current network that are in need of improvement. And any course of action to implement the above in our network to provide a safe, reliable and inclusive user experience is welcomed.

And with that a reminder, The closing date for taking part in the public consultation is 5pm on Tuesday, September 26 2023. You can submit your own thoughts through the link here.