IEVA welcomes the work by ZEVI in bringing the "Draft National En-Route EV Charging Network Plan 2023-2030" to Public Consultation. As EV uptake increases, and fleets begin their transition to EVs in both Light-Duty vehicles (LDVs) and Heavy-duty vehicles (HDVs), the charging network will form a crucial aspect to give strength to individuals and businesses that this sustainable transition is being brought about through strategic planning and careful consideration.

In July, the European Parliament and European Council adopted the Alternative Fuels Infrastructure Regulation (AFIR). This sets out minimum specific deployment targets for 2025 and beyond along the Trans-European Transport Network (TEN-T). Within this requirement, the Core Network (500km) in Ireland is only small part of the overall network. We welcome ZEVI's approach to target more than the minimum outlined network of just the Core Network as set out in "Alternative 1: Alternative Fuel Infrastructure Regulation 2025" for passenger and LDVs. While we would like to see "Alternative 3: High EV Charging Scenario" being implemented, we can see that "Alternative 2: Medium EV Charging Capacity Scenario" is a more realistic target to work towards for 2025.

On top of the Core Network as set out through AFIR, Alternative 2 accounts for the TEN-T Comprehensive Network (1700km) as well as the Primary and Secondary roads (3100km) not targeted by the TEN-T network. We welcome these targets of 600kW of charging every 60kms on the Core and Comprehensive Network (Motorway/dual carriageway), 300kW of charging every 60kms on the Comprehensive Network (Single carriageway) and 100kW every 30kms on the Primary and Secondary roads in each direction of travel by 2025, and for a doubling to tripling of these charging pool targets for 2030.

For the HDVs rollout of charging, we can see that the charging requirements set out by AFIR is substantial (1,400kW every 120km by 2025, 3,600kW every 60km by 2030 on the Core & Comprehensive Network) and that there are no alternatives to what is set out by AFIR in this document. We are most likely not in a position to comment on this as we do not engage with enough HDV operators to comment. However we would encourage a review on the rollout of charging in Urban nodes being limited to four locations (Dublin, Cork, Foynes and Galway) and for other cities and towns to be investigated for charging hubs/nodes outside of these points on the TEN-T Core Network.

Smaller HDV vehicles (ex. rigid trucks) or other commercial vehicles such as Buses will need to make the switch to EVs in the coming years, and as such should not be forgotten. We would also encourage the requirement for 2 recharging stations by 2027, and 4 by 2030 at HDV parking and rest areas to be revised upwards as existing rest areas can see up to and around 30 HGVs at each stop.

The North-West and South-East of the country are not as clearly called out in the document, and it would be good to have some planning put into place for these locations. "En-Route Charging Infrastructure required for Heavy Duty Vehicles" in the document outlines an approach that takes into account those routes that fall below the AADT (Annual Average Daily Traffic) of 2,000 vehicles per day, and where derogations may be allowed. So while these locations have lower traffic counts, considering the distance between these locations and the Core network, it is important to plan the accessibility and serviceability of these areas by HDVs. Rosslare is currently undergoing investment to the port itself, as well as haulage companies expanding in this region, and the North-West will need investment to encourage HGV operators to change to fully electric vehicles in this region.

Fundamentally, the key success to this En-Route EV Charging Network plan is funding. We encourage the government to take on board the lessons learned from other countries as outlined in the draft, to fund this En-Route charging network for success. For all categories of vehicles, the development of known locations and distances to travel to find a reliable and available charge point is important for EV adoption. We are encourage by what is outlined in this document as a plan to work towards, and welcome the outlines as set here.

To our members, a reminder that the closing date for taking part in the public consultation is 5pm on Friday, November 10 2023. You can submit your own thoughts through the link here.