Draft Regional and Local EV Charging Network Plan

The Draft Regional and Local EV Charging Network Plan is the second element of the National EV Charging Network Plan and follows the development of the National Road Network EV Charging Plan which was launched for public consultation in September 2023. The plan sets out a pathway for the delivery of regional and local networks of public electric vehicle (EV) charging infrastructure in cities, towns and villages across Ireland, in line with both national and European ambitions.

You can find further details of the Draft Regional and Local EV Charging Network Plan here and Neasa’s submission to the public consultation below.

The Minister for Transport intends to publish a revised Regional and Local EV Charging Network Plan in late 2024.

Public Consultation - Regional and Local EV Charging Network Plan

Chapter 1 present key lessons learnt from international precedents related to destination and neighbourhood charging locations. Is there any additional learning that should be included?

Ireland should look to international examples that have successfully crafted multi-modal, low-carbon transport networks within rural areas, given Ireland’s low density dispersal of our population. Emphasis should also be put on studying international best practice when it comes to the unique challenges of implementing new infrastructure in the historic core of cities. For example, many parts of Dublin, Cork, Limerick and Galway provide housing in terraces with no driveways and only shared on-street options for parking, leaving residents with few options to charge.

The planning system should be considered when looking at international precedent. For example, other countries have also begun to look at planning permissions around new fuel stations, with some adopting measures to ban the construction of new filling stations completely, and others looking to ensure planning permission for new filling stations is only granted if they have more EV charging points than petrol and diesel pumps on their forecourts.

The issue of equitable access highlighted in “1.8 Enhance Equitable Access” is a key one for residents in Dublin Central many of whom only have access to on street parking. The lack of a driveway should not mean these residents have to pay significantly higher charges.

Mimicking the potential for home charging behaviours for those without access to off-street parking, by providing access to neighbourhood chargers that offer slower charging speeds in return for a more cost-effective charging session is critical to enabling access to low-cost charging solutions particularly for lower income users.

We note that the UK has an extensive network of on street chargers which includes chargers attached to public lampposts. However many such chargers in the UK are run by private entities (e.g. Shell) and are priced at points that could not be considered low-cost (e.g. £0.45 per kw off peak https://ubitricity.com/en/driver/pricing/)

Chapter 2 presents an analysis of user needs. Through this analysis, a set of personas have been used as different lenses to assess the main challenges experienced by EV users when charging at destination and neighbourhood charging locations, and to identify potential supports required. In your opinion, are these groups of personas representative enough? If not, please provide which additional group should be included and why.

A major issue that persists is the huge disparity in charge rates between domestic and on-street charging. A recent study by Switcher.ie found the average cost of charging an EV in Ireland is €22.25. Irish rates are almost double the European average and the annual cost increase across Europe was also far below Ireland’s at 4.4pc. A publicly available charging network that is equitable in cost with charging from your home is a crucial part of the EV solution.

Another often overlooked issue is accessibility. Problems can include not enough space to fit a wheelchair alongside your car, the height and weight of the charger, as well as the height of the screen and payment pad. Those with limited mobility can be negatively affected by where the charger is stored, how it connects to the charging port on their car, and the necessary force required to do so. It is important to ensure access for all citizens, and to incorporate the principles of universal access and design within the EV charging network.

Chapter 3 presents the modelling methodology and assumptions that have been used for the purposes of determining minimum public charging targets at destination and neighbourhood locations nationally based on the Alternative Fuels Infrastructure Regulation (AFIR) fleet targets. (Note, the plan indicates that the local authorities will undertake modelling at a local level to calculate charging requirements based on local needs. The local authorities will then determine which destination and neighbourhood sites are most suitable for charging infrastructure.) Are there any specific comments you have regarding the modelling undertaken for the plan?

Today there are roughly 2,400 charge points in Ireland delivering 70,000KW of capacity. This needs to increase to 214,000KW by next year and 712,000KW by 2030 if we are to deliver on commitments to the EU’s Alternative Fuel Infrastructure targets. This equates to roughly 18,000 charge points by 2030, a goal that would require us to double the number of charge points every two years. It is unrealistic to rely heavily on the private sector during that period and entirely on the private sector post 2030. Concerted and proactive engagement is needed with the private sector, as well as significant Government planning and investment to realistically achieve these targets. The private sector alone will not achieve these targets.

Chapter 4 lays out the project lifecycle local authorities will follow to deliver destination and neighbourhood charging infrastructure and the stakeholders that will be engaged with. Are there any key considerations that need to be noted in the lifecycle process or additional stakeholders to be engaged with to ensure the successful delivery of the 2025 and 2030 power output targets for public EV charging infrastructure?

As referenced in the previous response, Government involvement is needed to realistically achieve targets, and vitally, to ensure appropriate coverage across the country. It will be important to ensure that private businesses do not just operate high-demand, profitable locations, while local councils are left to operate other locations at a loss. Bundling of high profitability and low profitability locations should be considered.

Section 5.2 gives an overview of national supports that will be provided to enable the delivery of the plan. Do you think the supports proposed in the plan are adequate or do you think other or further support is needed?

Further support will be needed.

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