Unreasonable Cost of DC Fast Charging

25th May 2023

eCARS

ESB Group, 27 Fitzwilliam Street Lower, Dublin  D02 KT92

Dear John and Team,

The Irish EV Association is keen to support all stakeholders in the transition of transport in Ireland to a more sustainable model.  While we strongly support a move to walking, cycling and public transport, after 100 years developing a socio-economic transport model largely dependent on the  individual car, we believe the transition to electric vehicles is vital to achieve our National carbon emissions targets.

While most charging of private EVs takes place at home, there is the need to provide a National infrastructure for inter-town and inter-city travel.  It is not wise, or sustainable,  to demand  that most EV’s will carry very large battery packs to enable long journeys.  And EV’s are not always fully charged when needed.  The better option is to provide a comprehensive DC fast charging infrastructure.

eCARS is a major provider of the current National DC fast charging infrastructure in Ireland.  We are very grateful for this service which has been primarily funded by the State.  However, our members were very surprised and concerned at the sudden increase in cost last year, over 100% increase.

We believe the maintenance of this high cost is unreasonable for four reasons:

1. A substantial % of the power in the National grid is generated by wind, whose base cost did not increase with the tragic Ukraine war.   We understand that while each company within the ESB group is separate, yet the State is the major stakeholder of the ESB group and can distribute your substantial dividends;
2. The speed with which eCARS increased the cost of charging, with the increase in the wholesale gas market, was not matched with an equivalent decrease when the wholesale price of gas market dropped. The wholesale price of electricity dropped 13.5% in April alone;
3. We strongly believe the increased cost will slow down the adoption of EVs which is contrary to Government strategy.  eCARS prices are comparable with some commercial providers, significantly higher than Tesla [€0.47], yet your service is primarily funded by the State. The high cost is being used by EV detractors to undermine the transition;
4. The quality of the current enroute charging service does not always match the cost.  We fully understand  the market has grown rapidly and you may not have had the funding to match the increase in demand.  And with increased use, the downtime of chargepoints has increased significantly. The speed of charging at some key locations, e.g. Portlaoise Plaza, is well below the minimum 50kW required to allow adequate charging for those using these points for inter-city travel.  EV drivers have to absorb  these performance inadequacies with undue time on their behalf.

For these four reasons, the IEVA membership strongly encourages you to reduce your prices immediately to pre Ukraine war levels. This action, we believe, will encourage other chargepoint providers to also reduce their prices.

We want to work with eCARS and all stakeholders to ensure our members,  and all EV drivers, get the equivalent service to drivers of ICE cars. We believe the ICE fueling infrastructure is the model to develop the EV charging infrastructure and have provided ZEVI with details on our analysis to this effect. eCARS has had great success in this process. We have one of the best electricity infrastructures in the world.  We believe the best strategy is to bring the “power to the pumps” – the electric power to most current fuelling stations. However, our analysis demonstrates the substantial shortfall of charge-points and charge-locations for today’s need, which gets steadily worse when we project demand forward towards 2030.

We look forward to hearing from you,

Eamon Stack –  Chief Executive