Comhairle Cathrach Chorcaí Cork City Council
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1 Transportation Division City Hall Cork Response to the Consultation Paper on the ESBN Electric Vehicle Pilot & Associated Assets Reference CER/16/286 Introduction welcomes the opportunity to respond to the Consultation Paper on the ESBN Electric Vehicle Pilot & Associated Assets Reference CER/16/286. Cork City Council has direct experience of deploying EVs on its own vehicle fleet and of facilitating and supporting the provision of EV charging the infrastructure on the street and in various car parks. participated as a partner on the Green emotion EU funded project and ESB ecars was the lead Irish partner. Green emotion was the leading electromobility project funded by the EU with a total budget of 21 Million as coordinated by Siemens AG in the period 2011 to Furthermore, Cork City Council participated on the very successful Drive4Zero initiative in 2014/2015 organised by the Energy Cork Group to promote the sales and deployment of EVs and, in particular, electric cars for private use in the Cork region. It is noted that the Commission for Energy Regulation, CER welcomes comments on any of the issues raised in this consultation paper, the ESB ecar proposals, and the report on the EV Pilot. Consultation Paper Summary With reference to the summary identified by the CER the following responses have been drafted on behalf of : 1. Funding of the EV trial: Traffic Division Phone:
2 a) The CER requests respondents views on the ESB ecars proposal regarding funding in relation to the additional expenditure on the trial. It is recommended that 50% of the additional costs associated with the EV Pilot should be recouped from the DoUS charges. In participating on the EV Pilot considerable benefits accrued to the ESB Group of companies in terms of profile and marketing opportunities. Benefits also accrue with regard to the various EVs and commercial EVs that have been incorporated on the companies own vehicle fleet. The ESB Group should therefore absorb the balance of the additional costs, being 50%, incurred on the EV Pilot. 2. CER objectives in relation to EV policy: a) Do you agree with the CER s objectives for EV policy? Yes, we agree with the objectives of the CER for EV policy. b) Are there other objectives the CER should consider? 1) Recognition that cross subsidising the promotion of EC charging is an appropriate cost for DUoS customers as a means of incentivising more energy efficient technologies and practices which delivers benefits for all customers in the future. Such cross subsidies should remain in place until 2020 or until such time as the national target for the uptake of EVs is achieved. 2) The issue of third parties being able to supply and charge for energy will need to be addressed in time. As the variety of EVs being developed by manufacturers evolves there will various options as to selection of battery capacity by the purchaser. There will be an increased demand by EV drivers to their being charged for actual consumption as against a flat charge or fee being applied. The CER should include future participation by third parties being able to participate as operators of Charge Points and being able to charge for energy as an objective to be considered. Traffic Division November, 2016
3 3) Public Authorities, local governments and municipalities have a crucial role as regards the procurement of low or zero emissions vehicles, such as EVs, for their own vehicle fleets, which should reflect a commitment to 2020 targets, thereby showing leadership and helping develop a market for Electromobility. The CER as a public regulatory authority should declare targets for its own vehicle fleet and use of EVs for work related duties, if such a policy initiative has not already been adopted. c) Do you consider conditions should be attached to the ownership of the assets? If so, what kind of conditions should be added? 1) It is recommended that ownership of the asset would include conditions to ensure that the EV Charge Point infrastructure is sufficiently well resourced to manage the maintenance, repair, replacement of degraded assets and to cater for expansion of the charging network as may be needed to cater for future demand. 2) As highlighted previously, Public Authorities, local governments and municipalities have a crucial role as regards the procurement of low or zero emissions vehicles, such as EVs, for their own vehicle fleets. Conditions should therefore be attached to the ownership of the asset whereby the ESB Group of companies, in particular, and ESB ecars as semi-state public authorities would declare targets, in excess of National targets given the particular context and need for leadership, for its own vehicle fleet and use of EVs for work related duties in the context of the proposed transfer of assets. 3. ESB ecars Proposal: a) Do you agree with the ESB ecars proposed four options? agrees with the ESB ecars proposed four options. b) Are there other ownership models the CER should consider? Traffic Division November, 2016
4 From a local authority point of view, we do not believe that there are any other viable ownership options to be considered. c) What is your recommended option? It is recommended that the ownership of EV Charging infrastructure be formally transferred to ESB ecars as proposed subject to conditions as deemed appropriate. d) Under your recommended option how would CER ensure that the current value of the assets is adequately reflected? The current value of the assets is reflected in the cost of undertaking all works associated with the installation of the network of Charge Points and all the associated system upgrades. The value of the asset should therefore be reflected in the Level of Service to be offered EV users and that the CER could consider agreeing appropriate KPIs with ESB-eCars in the proposed transfer of assets. The value of the asset would also need to be protected with reference to provision of resources to manage the maintenance, repair, replacement of degraded assets and to cater for expansion of the charging network as may be needed to cater for future demand as referred to previously. The provision of Charge Point accessible to the public has been and remains crucial to the promotion of and deployment of EVs as one of a series in a basket of measures that have been put in place as incentives for EV drivers. will continue to support the National policy on EVs and electromobility with reference to the following aspects: a) has adopted Parking Bye-laws 2016 to cater for the management of access to the Charge Points, amongst other parking provisions, on public streets in line with National Legislation. The approach has been informed by the view that the local authority is responsible for the allocation and control of road space for parking and also for the allocation of space on the footpath for any purpose. The arrangement Traffic Division November, 2016
5 whereby ESB Networks and ESB ecars are therefore allocated space on public roads to cater for the installation of Charge Points is undertaken by way of agreement or by licence. b) On the basis of the Bye-laws adopted in 2016, parking for EVs at a designated Charge Points will, in the first instance, be free of charge and will be restricted to a maximum stay of 4 hours for an EV while charging. c) will install appropriate sign posting at each Charge Point and time-plates to control parking by EVs. Consideration will be given to adopting the Amsterdam electric as in Cork electric to identify the limit of access to the EV parking spaces and the associated time-plate and enforcement. d) Indeed, it is recommended that the Electric Charge Point Logo developed in Amsterdam and now being adopted in different locations internationally be considered for adoption in Ireland to promote access to parking spaces associated with the EV charging facilities: References to the Amsterdam Logo graphic design and examples of use are attached with this submission. Examples include London electric, IKEA electric, etc. based on the original graphic. e) It should be noted, that the specific allocation and control of road space for parking and also for the allocation of space on the footpath to cater for the installation of Charge Points is undertaken by the Local Authority as the Road Authority but that there would not be any obligation, necessarily, to consider the provision of Charge Points by other third parties given the loss of revenue Traffic Division November, 2016
6 from parking charges which remains a matter of concern. Furthermore, the potential benefit of ensuring availability of spaces on-street when the scale of fees is established and properly implemented, to manage demand, is complicated by the introduction of additional free or discounted parking fees for designated groups of drivers. f) Consideration could be given in the future to the provision of additional Charge Point facilities in multi-storey car parks operated by, including the Black Ash Park & Ride, depending on increased uptake and an increased demand from EV drivers. It is envisaged that the supply of electricity would be made available from our own electrical power circuits, as is the case at present. However, the issue of being able to charge for any proposed recoupment of energy costs applies as highlighted above with regard to CER objectives. g) will continue to operate the fleet of 3 No. EV commercial vans in the Council s livery, 1 No. EV car and the 3 No. Pedelecs all of which reflects a very successful deployment of EVs on the public authority fleet. In addition, the procurement of another EV commercial van for the Fire Department and an EV utility vehicle will be considered in the future. h) With a view to making provision for EV Charge Points for all new developments in the city, as reflected in the City Development Plan, Cork City Council has drafted a Guidance Document based on a similar document issued by the City of London which references the Code of Practice for Electric Vehicle Charging Equipment Installation, 2 nd Edition published by the IET. The City Council s policy guidance reflects the national targets for the deployment of EVs and thresholds are established for the provision of charging infrastructure. Traffic Division November, 2016
7 Conclusion The need for further investment in the provision of charging infrastructure for EVs relates to the continuing need to roll out further EVs and the associated home charging. In particular, initiatives to cater for the more challenging apartment complex parking arrangements and multi-occupancy buildings are essential. In addition, the provision of charging facilities at the drivers destination is regarded as key to promoting further uptake of EVs. The EV support measures and policy initiatives highlighted in this response by Cork City Council will not be impacted adversely as a result of the current or future value of the assets being transferred to ESB ecars as proposed. There is scope and opportunity for other parties seeking to develop and operate their own charging infrastructure such as the superfast charging stations being considered for the future. There is clearly a need for initiatives in relation to destination charging in both surface level car parks and multi-storey facilities which has largely been neglected, with a few noteworthy exceptions, by private operators. As referred to above, in relation to CER identifying further EV policy objectives, the issue of future participation by third parties being able to function as operators of Charge Points and being able to charge for energy supply should be included as an objective to be considered. Traffic Division November, 2016
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