Background
Scotland’s public charging network today
As a direct result of early investment by the Scottish Government, and increasing private sector investment in recent years, Scotland has one of the most comprehensive public charging networks in the UK today.
The development of public charging to date
The delivery of public EV charge points underpins the adoption of EVs in Scotland and the phasing out of Internal Combustion Engine (ICE) vehicles – a key part of meeting Scotland’s net zero targets, with cars and vans accounting for 17% of CO2 emissions in 2022. Furthermore, there is a direct economic impact via boosting accessibility and ensuring Scotland’s transport infrastructure is fit for purpose for years to come. Notwithstanding these positive developments, we recognise that drivers do still encounter a range of issues with public EV charging, including issues around the availability, reliability and affordability of public EV charging.
In 2011 the Scottish Government took the bold step of investing in public EV charging infrastructure ahead of demand to build confidence in the early adoption of EVs. Since 2011, the Scottish Government has invested over £65 million in public EV charging. This public EV charging infrastructure was initially free to use with the aim of supporting early EV adoption and was operated through the publicly funded ChargePlace Scotland network.
Private sector investment has played a role in growing Scotland’s public EV charging network since the first modern EVs appeared on Scotland’s roads in the 2010s, however in the early years of EV adoption, the vast majority of public EV charging infrastructure was funded by the Scottish Government. Local authorities played a key role in delivering this critical public EV charging infrastructure across Scotland and are expected to continue to play a critical role going forward.
By the end of 2021, Scotland had close to 4,000 public EV charge points. However, research undertaken by the Scottish Futures Trust for the Scottish Government in the same year, suggested that if Scotland was to have a public charging network that met its future needs, then the scale and pace of investment in public EV charging infrastructure would need to be accelerated to meet growing demand. The report suggested that in the coming years, new delivery models that enabled increasing private sector investment would be required.
In response, in 2022 we published our draft vision for the public EV charging network, identifying that the private sector was expected to play a much greater role in delivering public EV charging infrastructure going forward, and that significant private investment would be required to grow the network at pace and scale.
At the same time, we signalled we would continue to invest in public EV charging, whilst also enabling private sector investment through the multi-year £30 million EV Infrastructure Fund. This fund has supported all of Scotland’s Local Authorities to develop EV infrastructure Strategy and Expansion Plans identifying local current and future EV infrastructure requirements, and is supporting them to work in partnership with the private sector to leverage additional private investment to address these requirements and continue to grow public EV charging across Scotland. The public funding specifically targets those parts of Scotland less likely to see private sector investment in public EV charging infrastructure, such as rural and island communities and urban areas without access to off-street parking.
From 2022 onwards, tariffs were introduced across the public EV charging infrastructure on the ChargePlace Scotland network to help transition to a sustainable and fair approach to the long-term delivery of public EV charging. The ChargePlace Scotland network acted as an early catalyst for the development of public EV charging infrastructure across Scotland, but to increase the pace and scale of the expansion of public EV charging infrastructure it is necessary to transition away from the current delivery model, which means that the contract to operate the network will not be renewed once the current one expires. This shift will offer drivers much greater choice, and planning is already underway to migrate charge points to alternative public charge point networks by the end of 2025.
The introduction of tariffs on the ChargePlace Scotland network helped drive a significant increase in private sector investment to develop public EV charging infrastructure in Scotland. The Scottish Futures Trust estimates that the private sector invested approximately £25 million to £35 million in expanding public EV charging infrastructure in Scotland in 2023 and is expected to have invested between £40 million and £55 million in Scotland in 2024. In mid-2023, when we published our finalised vision for public EV charging, around two thirds of public EV charging in Scotland was owned or funded by the public sector, but now at end of 2024 with private sector investment fuelling rapid growth in public EV charging, over half of all public EV charging in Scotland is owned and funded by the private sector.
As a result of the legacy of early investment by the Scottish Government, and rapidly increasing private sector investment, today Scotland has one of the most comprehensive public charging networks in the UK. Scotland now has more than 6,000 public charge points, and the latest official UK Department for Transport statistics (from July 2024) show that Scotland has the highest number of public chargers per head of population of any part of the UK, except London, and the most rapid charge points of any part of the UK.
A key purpose of this Action Plan is to identify the shared actions required to address these issues and ensure that Scotland continues to lead the UK on public EV charging.
Public charge point numbers
Scotland has over 6,000 public charge points today. The Scottish Government’s 2024 Programme for Government includes the commitment to set a route map for enabling the delivery of approximately 24,000 additional public electric vehicle charge points by 2030 to support the transition to EVs. Research commissioned by the Scottish Government and undertaken by KPMG suggests that by 2030, Scotland will need between 22,000 and 30,000 public charge points depending on vehicle technology, levels of car use, and the impact of regulation on the speed of EV adoption.
| Year | Base | Improved Vehicle Functionality | Reduced car km | Improved vehicle functionality and reduced car km | Improved vehicle functionality, reduced car km, and sped up mandate |
|---|---|---|---|---|---|
| 2024 (Feb) | 5,077 | 5,077 | 5,077 | 5,077 | 5,077 |
| 2030 | 29,724 | 24,290 | 23,755 | 21,889 | 22,804 |
| 2035 | 66,840 | 51,622 | 53,449 | 43,889 | 46,307 |
| 2040 | 104,924 | 76,297 | 83,920 | 61,029 | 65,676 |
The upper end of this estimate informs the Scottish Government policy of enabling the delivery of an approximate 24,000 additional charge points by 2030. With over 6,000 public charge points today, this would result in approximately 30,000 public charge points by 2030. A public EV charge point forecast developed by Cenex for the National EV Insights and Support (NEVIS) tool kit suggests a similar range of charge point numbers by 2030, depending on demand for EVs and the provision of more numerous slower charge points, or less numerous rapid charge points.
Stakeholders made clear the need for better performance indicators to demonstrate delivery against the public charging Vision. While the national 2030 public charge point target is being retained, we emphasise that the target should be seen as a guide only, that the required number of charge points could be between 22,000 and 30,000, and that a key priority is to focus on ensuring the provision of the right charge points in the right locations across Scotland.
As outlined in our Vision for the public EV charging network, the private sector is expected to play a pivotal role in delivering the route map below by 2030 (as shown in fig.1). Scotland is already seeing significant levels of private investment in public EV charging infrastructure and this trend is expected to continue as EV uptake increases and the market for public EV charging infrastructure matures.
Figure 1 above illustrates this trend. At the base of the graph, it illustrates the impact of early investment by the Scottish Government which has enabled the delivery of around 2,800 public EV charge points through the ChargePlace Scotland network. As these charge points get older, they will gradually be replaced with new charge points largely funded by the private sector. It also shows the role that standalone private investment has played to date, demonstrated by the fact over 3,000 charge points in 2024 have been privately financed – bringing the total size of the public charge point network today to just over 6,000 charge points. The middle layer of the graph shows the contribution of the EV Infrastructure Fund, which is expected to support the installation of around 6,000 additional public EV charge points by 2030 through a combination of public and private funding. EV Infrastructure Fund-facilitated investment and standalone private investment grow out to 2030, resulting in a network reaching approximately 30,000 charge points by 2030.
The growth of the public EV charging network will not cease in 2030, and it is essential that steps are taken to develop a delivery landscape that will support investment in EV charging long into the future.
Whilst this forecast level of growth may appear exceptional, as stated above, Scottish Futures Trust estimates that the private sector invested approximately £25 million to £35 million in expanding public EV charging infrastructure in Scotland in 2023 and is expected to have invested between £40 million and £55 million in expanding public EV charging infrastructure in Scotland in 2024. Private sector plans for investing in Scotland do not end in 2024, and whilst plans for investment in future years remain commercially confidential, consultation suggests considerable levels of investment is planned for future years.
According to ZapMap Scotland experienced 49% growth in public EV charging between June 2023 (4,023 public charge points) and October 2024 (6,007 public charge points). This rapid growth was largely driven by private sector investment. However, delivering approximately 24,000 additional public charge points by 2030 will necessitate an 8-fold increase in the level of private sector investment over the next five years.
Consultation with public charge point operators and analysis by industry body ChargeUK suggests charge point operators are already working to meet and ideally exceed current growth rates, driven by the commercial imperatives of securing market share and attracting customers. This suggests that the private sector will continue to invest in growing public EV charging infrastructure in Scotland ahead of demand driven by the transition to EVs, supported by the actions identified in this Implementation Plan.
Charging technologies
The Vision for Scotland’s Public Electric Vehicle Charging Network focuses on public EV charging for passenger cars and vans up to 3.5 tonnes. The Public Charge Point Regulations 2023 defines a public charge point as one that is available for use by members of the general public and not those where access is restricted to owners or occupiers of premises or certain vehicle types, e.g. workplace charging for delivery vehicles or resident only charging schemes.
A variety of different types of public charge points exist, and they are often distinguished by power output. The table below provides a high-level summary.
| Speed | Typical power | Typical charging times | Typical uses | Typical locations |
|---|---|---|---|---|
| Slow | 3-7kW | 150 miles of range in around six to seven hours | Homes, workplaces, longer stay public car parks | Ideal when vehicles are parked for long periods such as overnight |
| Fast | 8-49kW | 60 to 80 miles of range in around two hours | Public car parks, longer stay enroute charging | Ideal when vehicles are parked for several hours |
| Rapid | 50-149kW | 150 miles in around 45 minutes or less | Public car parks, enroute charging | Ideal when vehicles are parked for less than an hour |
| Ultra-rapid | 150kW+ | 250-600 miles in around 10 to 40 minutes | Rapid charging hubs close to trunk roads and larger urban areas | Location close to the trunk road network |
According to LCP Delta and ZapMap (data used under licence), the most common types of EV charging are home and workplace charging, with public EV charging currently accounting for around 5% of all charge points. At the time of publication, according to ZapMap 1,565 of Scotland’s 6,007 public charge points are rapid or ultra rapid charge points and, on a per head of population basis, Scotland has the highest provision of rapid and ultra rapid charge points of any part of the UK.
This infrastructure is unevenly distributed across Scotland, with the majority of public EV charging infrastructure concentrated in Scotland’s urban areas, across the Central Belt of Scotland, and along the trunk road network. At the same time, some of Scotland’s islands, such as Orkney and Shetland, are relatively well supplied with public EV charging infrastructure, with more public charge points on a per head of population basis than some of Scotland’s more urban areas.
This highlights an important point that, whilst the overall number of public charge points may be an important measure of progress, it is not the only, nor necessarily the most important, measure. Stakeholders with whom we’ve engaged in the development of this draft Implementation Plan largely supported the view that the Scottish Government should not simply rely on a single numerical target for the delivery of public EV charging but should instead work with partners to ensure Scotland has the right charge points in the right locations so that the public EV charging network works for everyone.
Demand for public charging is directly influenced by the availability of other types of EV charging. Home and workplace charging complement the public charging network and can also reduce dependency on public charging, depending on how far an EV can travel on a single charge and how it is used. Consumer Scotland research in 2023 shows that 80% of existing EV users tend to charge at home.
On average, around 60% of homes across Scotland have access to off-street parking but this varies across the country. In some local authority areas, it is as high as 80% but in others it is lower than 40%. Whist it is likely that home and workplace charging will continue to play a major role in charging electric cars and vans, public EV charging will need to increase as the uptake of EVs increases. A comprehensive and affordable public charging network will also be essential for those who cannot charge at home and those who need to undertake longer journeys either from home or their place of work.
Research suggests that by 2030, the percentage split of charger types across Scotland will largely remain unchanged, however public charging will account for a greater market share as those without off-street charging enter the market.
Demand for electric vehicles
In 2020, the Scottish Government’s updated Climate Change Plan committed to phasing out the need for new petrol and diesel cars and vans by 2030.
According to latest Scottish road transport statistics , there are approximately 2.7 million cars and light goods vehicles on Scotland’s roads. According to UK Department for Transport data, 103,200 (3.8%) of these are plug-in electric cars and light goods vehicles (i.e. battery electric powered only by electricity, and plug-in hybrid/range-extended electric vehicles that can be powered both by batteries and fossil fuels). However, work commissioned by the Scottish Futures Trust to investigate the potential under-reporting of vehicles kept and used in Scotland suggests that these figures could be as high as 132,200 (4.9%).
Whilst these vehicles may only constitute a small percentage of the total on Scotland’s roads today, their numbers are increasing rapidly. The introduction of the Vehicle Emissions Trading Schemes (commonly referred to as the “ZEV Mandate”) at the start of 2024 this year has resulted in record levels of month-on-month EV sales, with sales of EVs above 20% of new car sales for successive months at the end of 2024, according to data published by the Society of Motor Manufacturers and Traders. This legislation mandates the sales of zero emission vehicles, with a target trajectory for new cars sold beginning at 22% in 2024, increasing to 80% in 2030 and reaching 100% in 2035.
KPMG research, commissioned by the Scottish Government, suggests that the direction of current policy and technology development will result in 20-30% of all cars and vans on the road in Scotland by 2030 being battery electric and 100% by 2046. It suggests that by 2035, most electric cars will have a range of 280+ miles and that by 2040 the majority will have ranges of 400+ miles, equalling the range of today’s petrol and diesel cars.
Consumer Experience
Consumer experience is critical to the continued expansion of public EV charging in Scotland. Negative experiences can have a significant impact on driver confidence in public EV charging infrastructure specifically, and in transitioning away from petrol and diesel vehicles to EVs more generally.
Consultation with stakeholders suggests that improving public education and awareness could have a big role to play in improving the consumer experience around EVs and public EV charging, particularly at a time when there is a high preponderance of negative news stories about EVs and EV charging, despite research suggesting that the experience of the majority of consumers is overwhelmingly positive. As the consumer experience depends on multiple factors, the following sections provide an overview of four important elements emanating from the original Vision: availability, accessibility, reliability and affordability.
Availability
The availability of public EV charging is critical in creating the confidence that enables drivers to transition to EVs. As already stated, due to the legacy of early investment by the Scottish Government, and rapidly increasing private sector investment, today Scotland has one of the most comprehensive public charging networks in the UK.
However, we recognise that there is a continuing need to expand public EV charging, and that is why we are continuing to invest in public EV charging, whilst also enabling private sector investment through the multi-year £30 million EV Infrastructure Fund. This fund supports local authorities to work in partnership with the private sector to leverage additional private investment and continue to grow public EV charging across Scotland, with public funding specifically targeting those parts of Scotland less likely to see private sector investment in public EV charging infrastructure, such as rural and island communities and urban areas without access to off-street parking.
Accessibility
For public EV charge points to be accessible to all users, the parking bays and the EV charge points located at those parking bays need to be designed for use by disabled users.
The Scottish Government worked with the British Standards Institute (BSI) in 2022 to develop the PAS 1899 (Electric Vehicles Accessible Charging Specification) standard. This industry standard provides specifications for the installers and operators of public EV charging infrastructure to ensure a more accessible and inclusive charging system across Scotland, and the UK as a whole. The Scottish Government will continue to work in partnership with key organisations and stakeholders to ensure that electric vehicle charge points are accessible for all users. All Scottish Government funding for installation of public EV charge points now requires grantees to demonstrate appropriate measures will be taken to meet requirements and recommendations set out in the PAS 1899. standard.
Most of Scotland’s public EV charge points were installed prior to the publication of the PAS 1899 standard and public EV charge point operators and owners need to give due consideration of how existing infrastructure can be upgraded to accommodate the needs of disabled users.
Given the additional space required to provide public EV charging built to the PAS 1899 standard, and the space-constrained nature of many older public EV charging sites, consideration should be given as to how best to accommodate public EV charging meeting the PAS 1899 standard, whilst also avoiding a significant reduction in public EV charging provision which could harm EV transition and reduce the viability of a site.
Reliability
The Scottish Government recognises how important a reliable public EV charging network is for instilling confidence in drivers. Most faults are transient and, in most cases, require no physical intervention. This means that a high proportion are quickly resolved. The overall reliability across the publicly-funded ChargePlace Scotland network is typically very good with the entire network up and running between 95% and 98% of the time each month. Reliability figures are not currently available for other public charge point networks, but it is important to recognise that even very occasional issues can have a significant impact on confidence in the public charging network.
The UK-wide Public Charge Point Regulations 2023 , aimed at improving the consumer experience of public EV charging, came into force in November 2023 and were phased in during 2024, with the requirement that all public charge point operators maintain 99% reliability over their whole network introduced in November 2024. This will be crucial in building public confidence as we move towards the mass adoption of EVs, and it’s critical that charge point operators and charge point owners comply with these regulations to ensure that EV drivers experience the reliable service they have every right to expect.
Affordability
Whilst at present they typically have higher upfront costs, EVs tend to be less expensive to own that petrol and diesel vehicles, once whole life costs such as maintenance are considered. The affordability of EV charging, including public EV charging, has a significant impact on relative affordability of EV ownership.
There are several different factors that shape the cost of public EV charging including wholesale electricity prices, a higher rate of VAT (20%) on public EV charging than domestic electricity (5%), the cost of purchasing or leasing the land on which public charge points are located, the cost of network connections and supply upgrades, and the cost of installing, operating and maintaining the charge points. Higher powered rapid chargers tend to cost around 50% more to install and operate than slower chargers and this is reflected in the higher tariffs for energy from these charge points.
High EV charging costs can disincentivise EV ownership, but charge point operators also need to ensure they cover their costs and make a return on their investments. Industry consultation suggests that the investment case for both low and high-powered EV charging necessitates taking a long-term view with some operators suggesting it could take seven to ten years to break even.
Variable pricing models such as off-peak tariffs may offer one solution that might help consumers manage costs and enable operators to maximise the utilisation of their charge points. Supported by the EV Infrastructure Fund, local authorities are in the process of developing concession contracts to partner with charge point operators to continue to expand public EV charging infrastructure and should guard against monopolistic supply situations emerging and in areas where there is limited competition, as lack of competition could have an impact on the affordability of public EV charging.
Current regulatory environment
The regulatory environment for public EV charging is divided across the UK, with many key powers relating to public EV charging currently sitting with the UK Government.
Vehicle Emissions Trading Schemes
Whilst pertaining to the sale of vehicles rather than charging infrastructure, the Vehicle Emissions Trading Schemes (VETS) Order 2023 (often referred to as the “ZEV Mandate”) places legal obligations on car and van manufacturers to sell new zero emissions vehicles each year, ramping up to 80% of all new cars sold, and 70% of new vans, being zero emissions by 2030. VETS is devolved legislation under the Climate Change Act 2008, which means that the Scottish Government and other Devolved Governments work in partnership with UK Government to implement the VETS Order.
Whilst it pertains to the sale of vehicles rather than charging infrastructure, VETS legislation provides the private companies investing in public EV charging infrastructure in Scotland with certainty over the transition to EVs. Powers relating to vehicle licensing and powers to ban the sale of petrol and diesel vehicles are reserved to the UK Government.
Public Charge Point Regulations
The Public Charge Point Regulations came into force on 24 November 2023. These regulations cover provision of contactless payment, payment through third party roaming providers, reliability requirements, provision of a helpline, open data, price transparency and reporting to the Office for Product Safety and Standards (OPSS) as well as the Office for Zero Emission Vehicles (OZEV). The UK’s Competition and Markets Authority (CMA) also plays a role in ensuring fair competition in the public EV charging market.
Value Added Tax
Taxation of the electricity provided via public EV charging infrastructure are levied through standard rate (20%) Value Added Tax (VAT). VAT is looked at further in a later section of this Implementation Plan.
Renewable Transport Fuel Obligation
Powers to regulate renewable fuels and electricity used for transport through the Renewable Transport Fuel Obligation are reserved to the UK Government.
The GB energy market and grid infrastructure
Across Great Britain (GB), regulation of the energy market and grid infrastructure is centralised. While Scotland has some say over aspects of energy policy, the strategic planning and regulatory oversight largely rest with UK-level authorities. The Scottish Government retains influence over certain areas, such as decisions on onshore energy production including renewables, and environmental policies impacting energy production and distribution.
Scotland's strengths in renewable resources like wind, hydroelectric, and tidal power have been harnessed to increase the share of renewable energy used in Scotland. However, the current GB wholesale electricity market is not fit for the delivery of our net zero ambitions and reforms are required to help reduce system costs and break the link to volatile fossil fuel prices. Reforms must also ensure that system efficiencies and the low generating costs of renewables are passed through to consumers in the form of lower costs. The Regional Energy System Plans (RESP) and National Energy System Operator (NESO) are soon to bring dedicated regional and national oversight for energy infrastructure. RESP in Scotland could support better regional coordination, enabling strategic alignment with local energy needs and capacity for renewables. NESO, with its UK-wide perspective, allows Scotland to benefit from comprehensive grid oversight.
Building Regulations and Permitted Development
Whilst not directly relating to public EV charging, amendments to the Building (Scotland) Regulations 2004, introduced in 2022, require new domestic and non-domestic buildings, and existing non-domestic buildings, with parking to have a minimum level of EV charging infrastructure. Given the importance of home and workplace charging to EV drivers, these regulations are important in complementing the public EV charging network.
Existing Scottish permitted non-domestic development rights under the Town and Country Planning (General Permitted Development) (Scotland) Order 1992 enable the installation of EV charging for off-street parking. This is most likely to enable the provision of lower powered charging as higher-powered charge points are too large and require additional energy infrastructure not covered by permitted development rights, therefore requiring planning permission. Just as local authorities have and will continue to play a key role in delivering critical public EV charging infrastructure across Scotland, local authorities have statutory duties regarding planning and road works, and they play a critical role in enabling new public EV charging through Scotland’s planning system.
The Scottish Road Works Commissioner is Scotland's regulator of road works, and oversees improvements to the planning, co-ordination and quality of road works in Scotland. The Commissioner plays a key role in setting standards for all road works, including those needed to install EV public charging infrastructure.
Planning
The Scottish Government’s National Planning Framework 4 (NPF4) supports the provision of EV charging infrastructure, especially when powered by renewable energy, and supports public transport infrastructure including multi-modal hubs. NPF4 sees EV infrastructure as part of a wider system response to net zero that also strengthens active travel and multi-modal hubs such as railway stations, bus stations, ports and harbours.
Scotland’s Local Development Plan guidance states that plans have a role in supporting the efficient roll-out of EV charging infrastructure by identifying potential locations for charging hubs, especially to support rural communities, and that careful consideration should be given to where these are located, ensuring best use of renewables and the electricity network.
Public charging delivery landscape
Public charge point operators pursue a range of different business models, targeting specific customer types, journey types and various ownership and operating models, investment payback timeframes and utilisation levels. The market and the business models employed are continuing to evolve, driven by the most commercially viable operating models. Operators closely monitor EV uptake, seeking to match supply of charging facilities with demand for EVs.
To date, private sector investment has mainly targeted the installation of rapid and ultra-rapid charging to support enroute charging close to key trunk roads and a mix of slower and faster destination charging at shopping centres, retail parks, sports, and leisure facilities. There is currently significant competition for sites offering high power, enroute charging close to high traffic routes, such as Scotland’s busier trunk roads. In the current market, these locations are seen as some of the most profitable. Scottish Futures Trust estimates that private sector has funded 52% of high-powered rapid chargers in Scotland and almost all new rapid charging is being funded by the private sector.
Public EV charging industry body ChargeUK estimates that the members it represents have access to £6 billion of investment in public EV charging infrastructure in the UK, including Scotland, by 2030. Private investment in charge points in Scotland to date has focused on the most commercially appealing sites, but in order to deliver the EV charging infrastructure Scotland will need in 2030, private sector investment will also be needed in locations such as rural and island locations with lower traffic volumes, more rural parts of Scotland where grid connection costs are higher and urban, near-home and on-street slow charging to support EV adoption (looked at in more detail later in this plan).
In order to create a stronger business case for private sector investment in locations such as these, it may be necessary to explore ways to reduce network connection costs, explore options such as battery storage and/or on-site power generation to avoid the need for higher voltage connections and substations back to the grid, and develop new business models designed to address the needs of specific communities yet to adopt EVs or only doing so very slowly.
Energy planning and collaboration
By 2030, Scotland is expected to be in a strong position to meet the requirements for electrifying cars and vans. Analysis published by the Scottish Government in May 2022 on demand forecasts for energy for transport suggests that forecast growth in renewable electricity generation in Scotland will more than accommodate the growth in demand due to EV uptake. Both analysis by the Scottish Government and independent analysis for industry indicates that charge point numbers are set to increase exponentially. Scotland’s production of renewable electricity was 71% in 2022, up from 29% in 2012. Scotland’s public EV charging network is therefore very well placed to be supplied by clean, renewable energy.
However, this analysis acknowledges that energy needs to be accessible in the right place at the right time to support the charging of EVs. From a corporate energy side, there are two Distribution Network Operators (DNOs), Scottish Power Energy Networks (SPEN) and Scottish and Southern Energy Networks (SSEN). Together they have the responsibility to ensure power is provided to local areas to support the public charging infrastructure.
In addition to this, the UK energy market is changing with the introduction of the National Energy System Operator (NESO) and Regional Energy Strategic Plans (RESPs). There will soon be a RESP covering Scotland, anticipated from 2025 onwards.
Engagement with stakeholders highlighted the importance of facilitating collaboration between different sectors. For example, bringing together energy providers, network operators, and charge point operators to address challenges such as local grid capacity, planning approvals, and the integration of renewable energy sources into the charging network, ensuring that the supply of clean energy keeps pace with demand in real time.
For sites that are less commercially viable, public and private stakeholders suggest that more coordination between CPOs, DNOs, local and Scottish Government could support the identification of sites and support routes to encourage further investment, with the sharing of data on traffic and energy investments being seen as a key element to enable such collaboration.
The grid connection process is looked at in subsequent section of this Plan.
The wider sustainable transport system
The public EV charging network is an important component within the wider transport system that supports the different needs of our cities, towns, remote and rural areas and islands. Scotland’s National Transport Strategy signals the requirement that the Sustainable Travel Hierarchy be embedded in decision-making by ensuring policies promote walking, wheeling, cycling, public transport and shared transport options in preference to single occupancy private car use for the movement of people. This is also to ensure alignment with the Scottish Government’s target to reduce overall car use by 20% by 2030, as set out in our draft route map published in 2022 (an updated route map following public consultation will be published in due course). At the national level, this Sustainable Travel Hierarchy is used to inform investment decisions and ensure transport options that focus on reducing inequalities and the need to travel unsustainably are prioritised.
At a practical level, enabling people’s first choice to be active travel, shared or public transport, wherever possible, means locating and designing public EV charging infrastructure to support those choices. This can be achieved by siting public EV charging in close proximity to transport hubs and interchanges. This has the benefit of enabling people to switch between modes, for example taking the bus or train into a town centre whilst an EV charges, but it also has the benefit of maximising potential utilisation of the charge point through its siting at a location with high traffic volumes.
Loch Ryan ferry port in Cairnryan: EV charging at transport interchanges
In June 2024, FOR EV and South of Scotland Enterprise unveiled a new rapid charging hub at Loch Ryan ferry port in Cairnryan near Stranraer to support the UK’s busiest domestic short sea route; Cairnryan-Belfast. This facility services both Stena Line’s customers as well as the local community and provides additional charging infrastructure for use by Police Scotland.
Source: Scottish National Investment Bank Plugs £10M Into FOR EV (digit.fyi) accessed 18/10/2024
The sustainable travel hierarchy approach is central to how the Scottish Government is supporting public EV charging. We have, for example, enabled the provision of new public EV charging infrastructure at new railway stations such as Levenmouth in Fife, East Linton in East Lothian and Inverness Airport station. Equally, it is a requirement of the EV Infrastructure Fund which has supported all of Scotland’s local authorities, to identify current and future public EV charging needs, and partner with the private sector to continue to expand public EV charging infrastructure. It is also a requirement that future charging provision is planned in line with the Sustainable Travel Hierarchy.
Not all public EV charging can be located in close proximity to transport hubs and interchanges, and the cost of installing new infrastructure is significant, but it is important to ensure that that wherever practical, public EV charging sites are designed and located to support and enable active travel, shared transportation and public transport.
Stakeholder feedback suggests that, in order to maximise the potential for public EV charging to support active travel, shared transportation or public transport, there may be a need for greater coordination across modes to identify and exploit opportunities for greater integration of transport solutions that charge point operators may otherwise be unsighted on.
Challenges and opportunities
There are currently a number of key challenges and opportunities arising from the development of public EV charging infrastructure in Scotland.
Location-based data
Engagement with key stakeholders suggests that there is a collective need for more open sharing of location-base (or geospatial) data such as existing public EV charging (through the regulatory requirement for open data), traffic data, more accurate EV ownership data and local grid capacity. Sharing these kinds of data could aid planning, support earlier collaboration between charge point operators, distribution network operators and local authorities, and support private sector investment in new public EV charging sites.
Planning
Engagement suggests that there is a widely held view amongst charge point operators that the planning process is a key factor delaying the rollout of public EV charging in Scotland, as well as the rest of the UK. Industry body ChargeUK suggests that very few EV charging projects are refused planning permission, but the length of time required to secure planning permission can vary significantly.
Engagement with charge point operators also suggests that some planning authorities consider the addition of public EV charging into an existing car park to be “removing” parking bays from that site and therefore may refuse planning on the grounds of loss of parking bays despite proposed provision of critical infrastructure.
Network connections, supply upgrades and wayleaves
Engagement with charge point operators has highlighted a number of challenges in securing essential network connections and supply upgrades to enable public EV charging. These include energy distribution network operators having differing application processes, legal agreements, design standards, and even variations with the same network operator where different solicitors are employed, resulting in time consuming additional work for charge point operators.
The public charge point industry is calling for a standardised grid connection agreement process and legal documents to drastically speed up the process and for priority to be given to net zero projects such as EV charging. Industry engagement has also highlighted that it can be challenging and time consuming to secure landowner permissions (wayleaves) to enable network connections and is also calling for standardised legal documents to cover land rights and access, wayleaves and substation leases.
A Strategic Transport Electrification Group has been established by the Scottish Government to draw on learning around short-term challenges to delivery and assist in medium to long-term distribution grid planning to support the electrification of transport in Scotland. The group involves Transport Scotland, the distribution network operators (DNOs), the national energy system operator (NESO) and the Scottish Futures Trust. It feeds into the Scottish Government’s Local Energy Network Coordination Group which is attended by ChargeUK and other transport stakeholders.
As already stated, many powers to regulate the UK energy market and existing and future energy grid infrastructure are reserved to the UK Government. As well as working with DNOs, the UK Government and Ofgem will continue to have key roles to ensure that potential barriers to the rollout of public EV charging infrastructure are identified and addressed to ensure that Scotland is well placed to ensure it has the critical EV charging infrastructure it will require in 2030.
Value Added Tax
Concerns have been raised by consumer groups and the public EV charging industry regarding the difference in Value Added Tax (VAT) levied on domestic energy (5%) and that levied on energy provided via public EV charging (20%). The crux of the issue is that EV drivers who cannot charge an EV at home pay four times the VAT rate for their electricity from public chargers. Around 40% of homes across Scotland do not have access to off-street parking, and most households do not have access to cross pavement charging (see below), meaning these households have the disadvantage of being taxed at a higher rate for transitioning to EVs. This unequal tax burden risks disincentivising EV adoption amongst a significant proportion of Scotland’s population.
As stated above, taxation of the electricity provided via public EV charging infrastructure is levied through standard rate (20%) Value Added Tax (VAT), but there were strong views amongst charge point operators that this issue is something that should be looked at further in order to ensure a fair and just transition to EVs.
Supply chain capacity
As identified above, delivering approximately 24,000 additional public charge points by 2030 will necessitate an 8-fold increase in the level of private sector investment over the next five years. Engagement with industry suggests that steps may need to be taken now to ensure that the supply chain has the capacity to deliver this increase in activity between now and 2030. It suggests that skills and workforce shortages, combined with demand from other sectors seeking to decarbonise, could potentially pose a barrier to the rollout of public EV charging.
Industry engagement also suggests that shortages in key skills in local authorities, such as in planning and procurement, could also have a detrimental impact on delivering the level of infrastructure required by 2030. As the number of public charge points increases, there will be an increased need for electricians capable of maintaining, servicing and repairing public EV charging infrastructure. Shortages, particularly in rural and island communities, could impede service provision and result in a failure to meet regulatory requirements on public charge point reliability.
Working with the college sector agency the Energy Skills Partnership (ESP), the Scottish Government is supporting Scotland’s colleges to develop the capacity to train existing qualified electricians to install, commission, service, repair and maintain high powered charging infrastructure. All of the key stakeholders involved in the delivery of public EV charging need to invest in developing the capacity to deliver the forecast increase in activity between now and 2030.
Less commercial locations
As stated above, private investment in public EV charging in Scotland to date has focused on the most commercially appealing sites, but to deliver the EV charging infrastructure Scotland will need in 2030, the private sector will need to invest in locations such as:
- Rural and urban locations with lower traffic volumes, including parts of Scotland’s trunk road network in far north and west coast of Scotland.
- Locations where grid connection costs are higher, including more rural parts of Scotland.
- Near-home and on-street slow charging to support EV adoption amongst those without access to off-street parking.
Feedback from industry trade body ChargeUK suggests that, to improve the commercial viability of sites, steps should be taken to address significant increases in the standing charges for grid connections resulting from Ofgem’s Targeted Charging Review (December 2019). These standing charges are a major factor in a site’s viability and are fixed amounts that must be paid regardless of the amount of energy used. Stakeholders report that they are a major factor in a reluctance to invest in sites other than those that are the most commercially appealing. There is also a lack of transparency, with operators unaware of the level of standing charges that will be applied until a site has been constructed. CPOs have also called on the UK Government to include renewable electricity in the UK Government’s Renewable Transport Fuel Obligation to improve the business case for investment.
As stated above, to create a stronger business case for private sector investment in sites that are currently seen as more marginal, lower traffic locations, it may be necessary to identify ways to reduce network connection costs, explore options such as battery storage and/or on-site power generation to avoid the need for higher voltage connections and substations back to the grid.
It may also be necessary to develop new business models designed to address the needs of specific communities yet to adopt EVs or only doing so very slowly. Engagement suggests that there may be opportunities to explore making depot charging available for public use to increase the availability of public charging in locations with lower traffic volumes.
Cross pavement charging
Cross pavement charging has an important role to play in enabling EV ownership and access to home and public charging for those without access to off-street parking, but it does raise several issues including planning, maintenance, liability and how solutions interact with existing utilities. The relevant powers sit with Scotland’s local authorities and, whilst there are existing examples of cross pavement charging being implemented in Scotland, currently there is no common approach across Scotland's local authorities.
For this reason, the Scottish Government is working with the Scottish Collaboration of Transport Specialists (SCOTS) network to address these issues and support local authorities to identify a consistent approach which enables the provision of cross pavement charging and supports Scotland’s Vision for public EV charging infrastructure and a public charging network that works for everyone.
EV uptake
Many stakeholders highlighted the importance of government involvement to ensure that the transition to EVs is both equitable and just; to avoid relying on market forces alone which may not result in the necessary infrastructure being delivered meaning some groups in society being left behind.
Research conducted by KPMG for the Scottish Government (unpublished at this time) suggests that early EV adopters are by and large concentrated in the central belt and in the east and northeast of Scotland, with access to off-street parking and with higher-than-average household incomes. The Scottish Government’s £30 million EV Infrastructure Fund is supporting investment in public EV charging infrastructure in those parts of Scotland less likely to see private investment in public EV charging infrastructure such as rural areas and the more deprived urban areas. This fund is working to crowd in private sector investment and avoid investment potentially neglecting certain areas.
KPMG research suggests that by 2030 urban areas with lower-than-average income levels and with no access to off-street parking and households in more rural communities may have significantly lower rates of EV uptake unless this continues to be an area of consideration and focus. Access to lower cost EVs, together with more equitable charging costs for those without access to on or off-street home charging, could have a significant impact on adoption levels in these areas. A standardised approach to enabling cross pavement charging in these areas could also have a significant impact in supporting EV adoption.
Scotland is the only part of the UK that currently supports consumers to purchase EVs. Since its launch in 2011, the Scottish Government’s Low Carbon Transport Loan has supported over 8,400 individuals and businesses across Scotland, providing over £233 million in interest-free loans to help support the transition to zero emission vehicles. The scheme currently provides interest free loans for used electric vehicles costing £25,000 or less for households with a gross household income that doesn’t exceed £50,000 per annum, and those living in rural and island communities. The loan also supports the purchase of new or used electric taxi and private hire vehicles.
A continued focus on ensuring a Just Transition to EVs will be essential to ensure that parts of Scotland are not left behind.