Impact Assessments

This chapter highlights the key conclusions from the relevant parent policy impact assessment on Scottish Government responsibilities. Each set of conclusions are grouped by a key issue affecting the development of public charging infrastructure in Scotland. Actions from the draft Implementation Plan have been included for ease of understanding how these conclusions relate to the parent policies’ impact assessments.

A brief description of each type of impact assessment can be found in Annex A and Annex B contains a brief description of each parent policy.

Integrated Impact Assessment Analysis by Issue

The following tables cover the following issues:

• Decarbonisation of transport
• Need for a Wider Sustainable Transport System
• Holistic place-based approach for energy systems
• Affordable public charging infrastructure
• Accessible public charging infrastructure
• Health, Emissions and Pollution
• Employment and Skills

Decarbonisation of Transport

STPR2

EQIA

• Group affected: Cutting across more than one protected characteristic
• Topic(s) assessed (where relevant): Not Applicable
• Impact: Positive (original assessment conclusion)

ICIA

• Group affected: Island Communities
• Topic(s) assessed (where relevant): Public EV charging infrastructure
• Impact: Positive (for islands compared to the mainland) (original assessment conclusion)

NPF4

EQIA

• Group affected: Cross cutting (where two or more characteristics overlap, and the policy affects those people in a specific way)
• Topic(s) assessed (where relevant): Not applicable
• Impact: Positive (VIP conclusion)

Reasons for decision

STRP2

Transition to net zero emission infrastructure has potential positive impacts on groups who are more vulnerable to the adverse health impacts of transport-related emissions and air pollution. This includes children, older people, disabled people and pregnant women. However, the benefits of decarbonisation of transport services are likely to be dispersed and local to key transport routes, stations, stops and ferry ports. As such, the extent to which these benefits will be realised will depend on the interventions for decarbonised transport being located within areas of the highest levels of air pollution and areas with a high proportion of more vulnerable groups.

For island communities, STPR2 includes a recommendation of zero emission vehicles and infrastructure transition as part of the policy for decarbonising transport. The assessment notes the potential positive impacts on groups who are more vulnerable to adverse health impacts of transport-related emissions and air pollution as well as charge points at ferry terminals which would lead to a much better multi-modal integration and therefore a wider sustainable transport system even better when using the natural renewable assets of the island communities.

NPF4

Overall, NPF4 marks a shift toward more sustainable, inclusive and climate-resistant development in Scotland. One of the main priorities of NPF4 is Sustainable Transportation and Connectivity, with one element being decarbonised transport and the framework encourages transitioning to low-emission vehicles and charging infrastructure, therefore indicating a positive impact for the Implementation Plan. A place-based approach: NPF4 sets out a vision for Scotland’s places in 2045. The energy sector is an integral part of that vision, providing significant opportunities for growing rural and island communities and overcoming inequalities through a place-based approach. Its regional perspectives emphasise opportunities for the islands, for rural Scotland, for the North East, central belt and south of Scotland. This will be embedded in local development plans throughout Scotland and is equally relevant for energy provision for any EV public charge point infrastructure, therefore building EV range confidence.

The EQIA however, does not go into further detail with respect to EVs or the public charging infrastructure.

• Action 7 - Convene Key Stakeholders: Convening of stakeholders to understand local barriers that require place-based approaches to address consumer experiences of decarbonised transport.
• Action 14 - Policy certainty: A continued consistent policy approach to zero emission public EV charging infrastructure as part of the decarbonisation of transport will ensure that the health of those groups who are more vulnerable to health impacts related to air pollution from vehicle emissions are protected.
• Action 15 - Use of open-source data: The use of data can identify potential gaps in the provision of public EV charging including supporting multi-modal journeys and supporting a place-based approach for enabling EV public charging infrastructure investment. The data may also identify where vehicle pollution is at its highest, to ensure that charge point requirements for the populations residing in these areas (as well as those who pass through) are met, thus reducing harmful impacts to health.

Need for a Wider Sustainable Transport System

NPF4

FSD

• Group affected: Areas suffering from socio-economic inequality issues.
• Topic(s) assessed (where relevant): Not applicable
• Impact: Positive (VIP conclusion)

NTS2

ICIA

• Group affected: Island Communities
• Topic(s) assessed (where relevant): Reduces inequalities (RI5) minimise the connectivity and cost disadvantages faced by island communities and those in remote rural areas, including safeguarding of lifeline services (national policy).
• Impact: Positive after mitigations (VIP conclusion)

ICIA

• Group affected: Island Communities
• Topic(s) assessed (where relevant): Climate action (CA2) Support management of demand to encourage more sustainable transport choices (national policy).
• Impact: Uncertain (original and VIP conclusions)

NPF4

Post Adoption ICIA

• Group affected: Island Communities
• Topic(s) assessed (where relevant): Public EV charging infrastructure.
• Impact: Positive (original assessment conclusion)

Reasons for decision

NPF4

NPF4 supports developments that prioritise active travel and public transport for everyday travel to reduce the need to travel unsustainably. It sets out that local development plans should aim to reduce the need to travel unsustainably by prioritising locations for future development that can be accessed by sustainable modes. Proposals to improve, enhance or provide active travel infrastructure, public transport infrastructure or multi-modal hubs will be supported.

Although not stated explicitly, charge points for EVs should be part of multi-modal plans where spatial planning indicates that it supports sustainable travel, in particular where the charging market has previously shown less interest but where regeneration would help to overcome disadvantage.

For island communities, the regional spatial priorities for the North and West Coast and Islands as set out in the NPF4 seek to ensure a more resilient future for island communities, including through decarbonising transport and reducing fuel poverty. Regional perspectives emphasise opportunities for the islands, rural Scotland, the North East, central belt and south of Scotland and will be embedded in local development plans (LDPs).

Policy 13 supports multi-modal hubs for EV charging where it can be demonstrated that the transport requirements have been considered in line with sustainable travel criteria and the transport needs of diverse groups including users with protected characteristics amongst other conditions.

NTS2, Topic RI5

The ICIA recognises that the needs of island communities will differ and that there is a need to consult with island stakeholders. While NTS 2 does not include specific detail around the development of a public charge point network it is a strategy for Scotland’s whole transport system and considers why we travel, how these trips are made and sets out a strategic framework to achieve a sustainable, inclusive, safe and accessible transport system. The Island Connectivity Plan will identify island connectivity needs, including an integrated travel network on the islands, including public, active, sustainable and shared travel to, on and from the islands (please note, the Consultation on the strategic approach and the updated Vessels and Ports Plan are now closed, however these are the first elements of the Islands Connectivity Plan to be published for consultation.

Actions identified by the draft Implementation Plan will need to take into consideration the transition to EVs and their place within the integrated travel network, potentially necessitating new impact assessments dependent upon any new policy developments.

NTS2, Topic CA2

NTS 2 ICIA recognises that island communities have differing needs and expectations of the transport system due to greater difficulties accessing public transport for essential services. The lack of alternative public transport options means people remain reliant on cars in these areas and it is often necessary for individuals living on the islands to travel further to access essential goods and services. This being the case, there is a need for continuing car use.

The original assessment of CA2 concludes that the policy has limited impact on addressing existing social challenges, supports improvements to air quality which will have a potentially positive impact on the natural environment and biodiversity and overall has an ICIA score of ‘uncertain effect’.  It also points out that the policy can be developed or delivered to improve or mitigate these outcomes for islanders and provides the examples of Mobility as a Service (MaaS) and Demand Responsive Transport (DRT). Due to the transition of all cars and small vans to EVs, this proposed policy development will necessitate the development of a public charging infrastructure to support the demand of these services. Any future development of such services, for instance if provided by local government, my require an impact assessment at time of development.

The Implementation Plan assesses that actions under theme five of the Vision envisage a network of public charging stations supporting a wider sustainable transport system, which provides people with opportunities to travel using car clubs or public transport (multi-modal hubs) and aligns with the parent policy NTS 2. 

• Action 7: Convene key stakeholders. Convening of stakeholders to understand barriers to integrating EV infrastructure with other forms of transportation.
• Action 14: Policy certainty. A continued consistent policy approach to the decarbonisation of transport which promotes multi modal and multi energy models will encourage DNOs and CPOs to consider such solutions in the expansion of the public EV charging infrastructure.
• Action 15: Use open-source data. The Scottish Government will consider charging data in the context of wider transport requirements. Relevant insights may also be shared with distribution network operators (DNOs) and charge point operators (CPOs) as part of Action 13 Mapping of multi-modal, multi energy locations to support the development of a sustainable transport system. 

Holistic Place-based Approach for Energy Systems

NPF 4

Post Adoption Integrated EQIA

• Group affected: Cutting across more than one protected characteristic
• Topic(s) assessed (where relevant): Vulnerable Groups
• Impact: Positive (VIP conclusion)

Post Adoption Integrated EQIA

• Group affected: Island Communities
• Topic(s) assessed (where relevant): Not applicable
• Impact: Positive (VIP conclusion)

NTS2

ICIA

• Group affected: Island Communities
• Topic(s) assessed (where relevant): Climate Action CA10: We will support strategically coordinated investment in the charging network that enables wider energy and transport system benefits and efficiencies (national policy).
• Impact: Positive (original overall assessment conclusion – minor positive effects / VIP conclusion)

NPF4

Post-Adoption ICIA

• Group affected: Island Communities
• Topic(s) assessed (where relevant): Public EV infrastructure
• Impact: Positive (VIP conclusion)

Reasons for decision

NPF4

NPF 4 marks a shift towards more sustainable, inclusive and climate resistant development in Scotland, with one element being decarbonised transport. The framework encourages transition to low-emission vehicles and charging infrastructure, therefore indicating a positive impact for the Implementation Plan.  

To achieve a net zero, nature-positive Scotland, NPF4 will re-balance the planning system so that climate change and nature recovery are the primary guiding principles for all plans and decisions. The energy sector is an integral part of the vision, providing significant opportunities for growing rural and island communities and overcoming inequalities through a place-based approach.

For islands, the NPF spatial strategy includes supporting new development in areas where the market has previously shown less interest but where regeneration would help to overcome disadvantage. 

Although not specifically related to public EV charging infrastructure, this approach could potentially be applied to those EV stations where the benchmark of commercial viability has not been met, and where a multi-modal and/or multi-energy location (MMEL) to crowd in investment is not practical.

NTS2

Original assessment: Part of the explanation provided for this score includes the challenge of grid connection costs for EV charging while the roll out of EVs and charging stations is seen as a positive as it will facilitate the use of EVs on the islands without increasing vehicle ownership or transport options and also support tourism through enabling EV users to charge safely while supporting improvement to air quality.

The VIP assessment recognises that the ICIA does point out that this policy may need to include additional consideration of on-going maintenance requirements for charging points.

• Action 9: Collaborate to remove barriers to grid connection costs, in order to promote place-based solutions. The draft implementation plan assigns the overall responsibility for this action to DNOs, CPOs and NESO as part of theme 4: increasing private investment. The Scottish Government has a convening role here as these stakeholders already collaborate through the Strategic Transport Electrification Group which has been established by Transport Scotland to tackle challenges to the delivery of the electrification of transport.
• Action 13: Mapping of multi-modal, multi energy locations to support holistic place-based approach to public EV charging. The draft implementation plan assigns the overall responsibility for mapping to DNOs and CPOs as part of theme 4: Energy, however there may also be a convening role for the Scottish Government to promote such models.
• Action 14: Policy certainty. A continued consistent policy approach to the decarbonisation of transport which promotes multi modal and multi energy models will encourage DNOs and CPOs to consider such solutions in the expansion of the public EV charging infrastructure.
• Action 15: Use of open-source data. The use of data can help to identify potential gaps in the provision of public EV charging with respect to place-based solutions, including the development of spatial planning that may include the provision of energy from multiple sources or serve multiple transport modes.

Affordable Public Charging Infrastructure

TTP

CRWIA

• Group affected: Children and young people
• Topic(s) assessed (where relevant): Not applicable
• Impact: Full CRWIA not required; covered under EQIA

Reasons for decision

The TTP EQIA states that young people, particularly in rural areas, may need to travel more in order to access employment and that data from the Resolution Foundation stated that more than one in three 18-24 years old are earning less than before COVID.

We consider that the same barriers and challenges to using a car or van and refuelling/recharging the vehicle will exist for young people, whether the car is an ICE or an EV. The fall in the prices of second hand EVs below their ICE equivalent as reported by Autocar may support adoption of EVs by young people.

• Action 6: Ensure an affordable network. The Scottish Government will continue to provide a consistent policy approach for a fairer, sustainable and enabling regulation and tax environment for EVs and public EV charging tariffs, which will have the impact of bringing down the costs for future EV drivers, making the transition to EVs more affordable.
• Action 14: Policy certainty. The Scottish Government will aim to provide policy certainty so that there is a stable policy environment to expand investment.

Accessible Public Charging Infrastructure

NPF4

CRWIA

• Group affected: Children and Young People
• Topic(s) assessed (where relevant): Young People
• Impact: Not applicable

Transport Just Transition Plan

Statutory Assessment Interim Update CRWIA

• Group affected: Children and Young People
• Topic(s) assessed (where relevant): Young People
• Impact: Not applicable

Reasons for decision

NPF4

The NPF4 integrated impact assessment found that the proposals within the NPF4 do not impact negatively upon articles of the United Convention on the Rights of the Child (UNCRC) or the indicators of wellbeing and therefore it is content that it did not impact negatively upon children and young people.

TJTP

Through the stage 1 screening process, a full CRWIA was not required. It did, however, mention that an extended age - young person section would be included in the EQIA. This section does not include anything directly related to public EV charging infrastructure, however does state that young people, particularly in rural areas, may need to travel more in order to access employment and that data from the Resolution Foundation stated that more than one in three 18-24 years old are earning less than before COVID.

We consider that the same barriers and challenges to using a car or van and refuelling/recharging the vehicle will exist for young people, whether the car is an ICE or an EV. The fall in the prices of second hand EVs below their ICE equivalent as reported by Autocar may support adoption of EVs by young people.

• Action 7: Convene key stakeholders to identify measures to continue to improve the consumer experience. Bringing together key stakeholders with an interest in the consumer experience of EVs and public EV charging to identify and address key barriers to high quality consumer experience and improve understanding and awareness will also improve accessibility.
• Action 14: Policy certainty. The Scottish Government will aim to provide policy certainty so that there is a stable policy environment to expand investment with the aim of encouraging greater accessibility in the provision of new EVs, the cost of used EVs, and provide an environment that supports private investment in public charging infrastructure.   
• Action 15: Use of open-source data. The use of data can identify potential gaps in the provision of public EV charging with respect to areas where charge point requirements for the residing population, as well as those who pass through, are not being met, thus improving accessibility to charging.

Health, Emissions and Pollution

National Planning Framework 4

FSD

• Group affected: Areas suffering from socio-economic inequality issues
• Topic(s) assessed (where relevant): Not applicable
• Impact Positive: (VIP Conclusion)

NTS2

ICIA

• Group affected: Island Communities
• Topic(s) assessed (where relevant): Climate action (CA1) Reduce emissions generated by the transport system to mitigate climate change and improve air quality (national policy).
• Impact: Positive (VIP conclusion)

Reasons for decision

NPF4

To combat environmental conditions and other factors that negatively affect health and access to opportunities, including those relating to transport pollution effects and social isolation (amongst others) to achieve a net zero nature positive Scotland, NPF4 rebalances our planning system so that climate change and nature recovery are the primary guiding principles for all plans and decisions.

NTS2

The policy states that Transport is currently Scotland’s largest sectoral emitter, responsible for 37% of Scotland’s total greenhouse gases in 2017. Of this share, 40% of emissions are due to ICE cars.

The transition to EVs will therefore have a positive impact both on island communities and the mainland as it will reduce greenhouse gas emissions (before any reduction in car use for health and wellbeing reasons is taken into account). However, it does not mitigate other pollutants generated by vehicles, for example rubber particulates from road use ending up in water systems.

• Action 14: Policy certainty. A continued consistent policy approach to zero emission public EV charging infrastructure as part of the decarbonisation of transport can be used to promote the improvement of health through the reduction of air pollution by transitioning to EVs.
• Action 15: Use of open-source data. The use of data can identify potential gaps in the provision of public EV charging with respect to areas where vehicle pollution is at its highest, to ensure that charge point requirements for the populations residing in these areas (as well as those who pass through) are met, thus reducing harmful impacts to health by reducing emissions and therefore some types of pollution.

Business and Regulatory Impact Assessment (BRIA)

A BRIA looks at the likely costs, benefits and risks of any proposed legislation, codes of practice or policy changes that could have an impact on the public, private or third sector. 

The Scottish Government have invested £65 million in Scotland’s Public Charging Network since 2011. Transport Scotland has drawn upon the infrastructure investment expertise of Scottish Futures Trust to look at how the public charging network can be financed and grown at the scale and pace necessary to achieve Scotland’s Net Zero targets. In their 2021 review they identified that it was unsustainable for a public funded model to successfully achieve the required level of coverage necessary to support future demand. Moving away from the publicly funded charge point network model means that the current model will be phased out over the next two years, as a new network contract will not be renewed by Transport Scotland once it expires. All charge points owners will be required to move to an alternative delivery model by the end of 2025. This shift to a more commercial model will offer drivers much greater choice to suit their needs and it will offer the owners, the opportunity to maximise the potential of their EV charging assets. Charge point owners will need to decide on an operating model which will best meet their needs as owners and for the drivers which utilise those charge points. To prepare for the managed exit from the publicly funded model, all charge point owners will be required to begin planning their next steps to realise the full potential of their assets, whilst being supported through this journey by Transport Scotland colleagues, Energy Savings Trust and the current network delivery partner.

In line with this conclusion, Transport Scotland set up a new mechanism to bridge the just transition into private sector funding; the £30 million EV Infrastructure Fund to transition to private sector-led delivery, leveraging in £30 million of additional private sector funding. In the past two years, public funds have been made available for all 32 of Scotland’s local authorities to help them develop public EV charging strategies and infrastructure expansion plans, which have underpinned their procurement processes to offer concessionary contracts to private charge point operators to take over and expand what was the original publicly funded network.

The above process has removed the Scottish Government at this time, from having a publicly funded role in the maintenance, operation and ongoing expansion of Scotland’s Public EV Charging Network, either directly or via contracted third parties. This has had the effect of removing any direct causal impact on business from the future role of the Scottish Government, meaning that no BRIA assessments are required when analysing its future role in the delivery of the Vision through the draft Implementation Plan. 

Any indirect causal impacts which may occur; through UK government legislation, for example, the Public Charge Point Regulations 2023, or through third party voluntary codes of practice such as PAS 1899:2022 Electric Vehicles Accessible Charging Specification produced by the British Standards Institute (BSI) or policy derived actions such as regional 20% reduction in car usage local development plans by local governments, may require a BRIA and other assessments to be undertaken at a local level.