As most folks reading this are likely to understand, the Department of Transport has begun consultation on their EV Infrastructure Strategy. IEVOA has been in discussion with the department itself prior to this consultation phase. And we have solicited feedback from corporate members and private EV owner members over the last few weeks, informing a documented response to the strategy itself.

In the spirit of transparency, we are publishing the reply here. But will also allow our working doc to be open to input from members to act as a “living document” as the strategy shifts and changes through this consultation phase. This is the best place for feedback.

Below is our raw response as per 25th May, 2022.

Executive Summary

We agree with the overall aim of the national strategy “to ensure that EV charge point infrastructure provision remains ahead of demand”. We agree with the language used to describe the challenge and we are aligned with  the principles of the strategy.  However, we strongly disagree with the analysis that “the current network of public charge points will be sufficient to meet the charging needs of BEV owners without access to home-charging for the next few years,..”  (3.1)

and

“However, modelling conducted in the development of this strategy, which assumes

an 80% rate of home charging, indicates that in reality the current supply of publicly accessible charge points will likely be adequate for the period out to 2025.” (2.5)

We believe there is a fundamental flaw in the argument for four main reasons:

1. The modelling does not seem to recognise that all EVs, with or without home charging, will require enroute charging
2. It is incorrect to assume that every EV is fully charged at the beginning of every journey, and that a typical EV has a range of 300km
3. The analysis does not seem to recognise the demand for enroute charging by tourists
4. The analysis lacks fundamental data on queues at charge points

The experience of our members queuing at chargers in 2022, and the knowledge of the increase in the number of EV (the government sees a four-fold increase by 2025), makes us concerned by the above statements.

We believe EV drivers have a fundamental “right to charge” which emanates from our responsibility to respond to climate change caused by transport in the way the government asks of citizens. That “right to charge” cannot change the reality that fuelling an EV takes six times longer than fuelling an equivalent ICE vehicle. However, the right does mean we have the “right to charge” at public chargers within a reasonable timeframe, e.g.  5 mins, especially during peak demand.

We are gravely concerned at the lack of data on queueing at public enroute charger points. Analysis without data on queues is deeply flawed.

We highly recommend a timely academic study of the real needs for charging, the level of use of charge locations, the length of queues and a subsequent change of the strategy. We ask that the data from countries like Norway and the Netherlands are reviewed, and instead of making the same mistakes, we use the  lessons learned that are available to us.

The Irish EV Owners Association appreciates the opportunity to contribute feedback to the Dept. Of Transport’s strategic vision of how we move forward to electrify the Irish fleet. We especially welcome the immediacy of the timeline to get actionable items in-place for 2025, and the creation of ZEVI to house the people who will influence future decisions to decarbonise our transport systems.

In the spirit of feedback, we have compiled some items that we feel are worth further discussion. Naturally, we are always available to discuss these in more depth at any time, and would appreciate being included in any future stages of the strategies’ development prior to full rollout.

We’ve formatted the notes based on the chapters within the strategy.

Foreword

• “Decarbonise private transport”
  • We feel emphasising private without noting public transport is critical. We already note a lack of general leadership on the adoption of EVs, leading to a lack of empathy from decision-makers on EV infrastructure. Making public vehicles EVs would be a huge step here.
• 1 million EVs by 2030 is a distraction
  • We need around 10k sales every quarter from here to 2030 to achieve that. We recommend the rhetoric be cooled, and focus on actionable steps to decarbonise our island.
• We are not at an early stage of EV adoption. We’ve passed the maven & early adopter phase and into high growth.
• “Equity of transition” is vital. 
• We ask to review what countries like Norway and the Netherlands have done and articulate why this wouldn’t work here and why we are reinventing what has been successful in other countries in the EU. 
• No mention of sustainability in this at all, which is disappointing.

Intro

• Here, we see EV adoption is tightly linked to climate action which is great, and important.
• Introducing buses, HGVs, etc. is positive; don’t put everything on private citizens as per note in foreword. However, no commitment to infrastructure for e-trucks or buses. It’s clear by now that EV will work for buses given that they have defined routes and schedules?
  • This is a big uplift in large urban areas like Galway, Cork, Limerick, Waterford, Dublin, etc. But other urban towns and villages should have this infrastructure as a priority.
• Focus on future innovations in tech is great, but let’s not be distracted by the basics. A cable is better than a wireless charging pad for most users now and in future.
• 4 categories of charging (home, residential, destination & motorway) are in-line with what we see and aspire towards.
• No plan for buses or HGVs feels short-sighted. 2025 is coming soon, and companies like Arrival are going to be shipping solutions that could be adopted in both urban and rural areas across Ireland.
• 3 areas of operations (public sector, integrated stakeholders & gov’t funding) are solid;
  • Perhaps missing are new entrants with new tech/startups.
• Destination charging is not necessarily DC. In fact, with longer dwell times AC is often more appropriate. It should allow for both AC and DC depending on the situation. Having DC where there are longer dwell times causes issues with hogging and overstaying as cars typically charge in under 1 hour on DC.
• Home charging infrastructure is relatively well established in Ireland [introduction]
  • Comment:  we currently install 7000 home chargers a year when we need an average of  8800 a month [to meet government targets]. The current providers focus on individual houses, mostly of middle class citizens.  The majority of citizens are in housing estates and are not served by the current model.
  • We need a policy on the right to charge vs the current right to refuse the installation of a charger by landlords. If someone in an apartment building wants a charger in the basement it should be a process agreeable steps to accommodate. 
  • We also see this same right to charge policy for those who do not have off-street parking. County councils should accommodate means to install chargers at dedicated parking spots and/or supply in each estate a 10% public charging capacity per allocated parking spots. Currently county councils do not allow for tunnels under footpaths to install charge points, which only create dangerous situations with people pulling cables across or overhead.  

Chapter 1

• We agree on the call-out re: noise pollution.
• Public sector leading CAP with delivery of EV charging infrastructure:
  • Are we seeing this now outside of funding schemes?
  • Are public vehicles electric? Will they be?
  • TEN-T has short term goals of sufficient charging capacity every 60kms by 2025. What thought process has gone into this already as this will be a shortened timeline due to TEN-T still being in negotiations? A reviewal process in 2025 is at the end point.
• 1.3.1
• Comment: solid -state batteries are a technology in development that might not get to scaled production, despite large investment e.g. VW into Quantumscape.  The current trend is towards LFP cells [50% Tesla and VW announced a large investment]. 

• 1.3.2 “These combined charging points form hubs where more than one electric vehicle can charge at a time.”   Comment:  the term “hub” should mean something substantial for EV charging, different to a charge point or two  i.e. 6+ fast chargers or 20+ slow chargers

Chapter 2

• Principle 1 missed a trick by not calling out specifics to reduce car usage in favour of cycling or public transport for short journeys
• P2: We’ve seen a lot of concern about EV charging for disabled or vulnerable folks; both in basic design (spaces too tight for wheelchairs) and security (dim lighting at night)
• P3: we suspect this is true but apartment owners are currently left behind (right to charge needed).
• P4 should call out affordability specifically — a huge advantage of home charging is cost, especially with solar PV. We should also not disadvantage those who live in apartments or those who only have off-street parking by denying them a fair fee for charging.
• “Current supply of public charge points will be adequate out to 2025” While we agree that we shouldn’t over-do the public charging infra, this statement doesn’t ring true & understanding how it was modelled would be helpful. There are issues already, especially at peak times, and in some locations, especially West coast where current public infra is totally inadequate.
  • Transport infrastructure in Ireland is measured by performance at peak times across major travel times (especially Friday & Sunday) as well as accounting for sports events, concerts, etc. IEVOA thinks the analysis done here does not take any of this into account and needs an independent, academic approach.
  • We also feel enroute/destination charging should be a fundamental need for folks traveling by EV. As opposed to a subsection of charging away from home.
• Specific call-out of fast taxi hubs is fantastic, we’ve seen this be successful in innovative hubs like Dundee. But this needs to work at-scale across the country and act as a carrot for drivers to switch to EVs. Goals should be set that any vehicle going into town/city centres should be primarily public service vehicles powered by electric motors.
• P5: charge point standards are settling down, but as part of a just transition we need to ensure older cars are not obsolete.
  • Incentives for second hand, import and EV conversions are necessary through SEAI schemes. For example, second hand EVs in the Netherlands get a €2000 incentive. 
• Need a standard on payments — it’s too confusing right now.
  • Regulations to force charge point operators to accept simple card swipe/tap is important.
  • Pricing should be made public in the same way it is for fossils. Not through an app, but through signage before the car pulls up and plugs in.

Chapter 3

• On Network Demand we have “Ireland’s public charging network is currently less than half of the current average EU level of provision.” And that “the current network of public charge points will be sufficient to meet the charging needs of BEV owners without access to home-charging for the next few years, but will need significant expansion from 2025 onwards.”
  • The first point indicates that we are behind where we should be, and the current network is being accepted as being sufficient for the next 3 years, which is not the case based on user experiences of the network. Current SCP/FCP/HPCP do not record queues or arrive-and-drive-off, where people have continued their journeys without a charge due to insufficient charging availability. 
• “night-time home charging would be the most beneficial to the grid”
  • Not true, solar PV enabled day-charging would surely be the best?
  • And public vehicles (ambulances, ministerial vehicles, An Post vans etc.) should have V2G tech to load-balance when they’re not in-use.
• Norway has grid capacity for 3,500 simultaneous rapid charging sessions — we should call out a number/goal in this vein.
• Forecourts should be required to have 20% of their capacity allocated to FCP/HPCP either through their own efforts or in partnership with a CPO. This is already the case in Norway where petrol stations are being replaced with charge points. Why does someone who charges need to stand in the rain to setup the connection while someone filling up a petrol tank can do it under a roof. 

Chapter 4

• MasS is going to be huge. Some of our committee are close to this from our private sector work (notably SAP & Stripe).
• On-street charging shouldn’t be the primary go-to in cities. We need to remove cars from them, and have more options for walking & cycling.
• In housing estates where there is no option for off-street parkering, public AC charge points need to be placed throughout the city and suburbs. The Netherlands does this really well. It is also safer for someone living in the estate to charge in their estate rather than having to go to the main road to charge up their car at night. 
• We should also lean into infrastructure design that allows for EV charging prioritised after cycle lanes, and remove fossil parking entirely, especially in areas with traditionally high noise pollution & outdoor dining
• V2G is a solid idea but “normal” cars don’t tend to ship with this tech. But it should be a requirement for public vehicles (post vans, ambulances, etc.).
• We’re not hearing about Rotterdam over and above Dundee.
• Dublin strategy has yet to be published & shouldn’t be referenced until it is.
• GAA clubs could be hubs in rural communities, also typically have lots of roof space for solar PV. Address partially on Page 48. Should also tie in to Tidy Towns projects.
  • We have members who’ve run EV meet-ups around Tidy Towns pushes very successfully, including committee members, most notably recently in Cork.

Chapter 5

• ZEVI needs to be operated by EV owners and technologists. It’ll fail to get traction with key stakeholders if it isn’t operated with an empathetic ear.
• A huge missing stakeholder is EV drivers and businesses not represented by any major bodies. IEVOA should be at the table representing some of these groups, but leaning into old voices will not drive innovative thinking.
• Will grants be wound-down in 2025? Or will we see a renewed Strategy from ZEVI directly then?

Chapter 6

• Grants are one thing for local authorities, but targets are more important. Huge projects are going live without EV charging as part of them, and conversely funding for EV infra isn’t being tapped into by local authorities.
• The latest we’ve heard from the SEAI is that even though the grants are in place for local authorities, they don’t have the expertise and knowledge to address and understand the needs for EV infrastructure and EV drivers unless someone is an EV owner themselves. More education is needed as thus the grants will be put to use by the local authorities. 
• ESB ecars are doing a decent job but they’re not future-proofed. Needs more funding to meet current demand with hubs, let alone for the future demand it’ll face if it’s to be the public face of infrastructure. They’re being out-gunned by private operators.
• FASTER is a world class project & should be aped in other rural areas.
• There are interesting co-charging companies in the UK we have contact with, doing stellar work. But as a solution to suburban charging, it should not be a priority. Communal charging locations in cul de sac / suburban streets should be researched as a route for areas where driveways aren’t common (e.g. Dublin’s Stoneybatter area).
• OPW should have specific targets levied against it for destination charge schemes;
  • Again, grants without targets have proven to not yield fast uptake.
• Home Charger Grant will be for smart chargers moving forward, when will this change? 
• Nothing referencing specifically the strategic importance of on-site battery storage and solar PV at charging hubs.
• Nothing specific about the importance of public events, independent EV information centres, or raising public awareness by appointing high profile ‘EV champions’.
  • IEVOA can assist ZEVI here.

Chapter 7

• Timeline looks good but will miss 1m EVs in 2030.
• Seems optimistic on infra delivery. We’re hearing from corp members that ESBN can delay projects for up to a year when a substation is required, or even when a grid connection is new.
• Lack of renewables being put on the agenda to drive charging infrastructure. Where is the solar PV or wind turbine push?
• On the flip side, there should also be deterrents for buying ICE cars. Norway reached this success as historically their taxes made ICE cars very expensive and EVs, when they entered the market, were financially hugely attractive as most of those extra taxes didn’t apply. Examples:
  • Zero Emission zones in cities
  • Higher costs for parking for ICE cars
  • Increase in road tax on ICE cars
  • Ideally extra levies on the purchase and resell price, which we know if not within your control
  • Block any future forecourt development unless it includes 50% FCP/HPCP allocation to future proof these forecourts. 
  • Bring entrants into the market like Fastnet, Gridserve etc, they can really shake up the market.