Thinking about getting your campus ready for Electric Vehicles (EVs)? Here are some of the legal nuts and bolts of what you’ll need to do and when.
Electric vehicles are increasing in numbers and the availability of charge points needs to improve. There are enroute charging stations, charge points installed at people’s homes, and increasingly, charge points at places of work and other destination parking spots.
Car parks at university campuses need them, but decision makers often feel somewhat in the dark as to how to go about getting the systems installed and maintained.
The options for EV installation and maintenance:
An aggregated structure involves the landowner appointing one contractor to do everything: acquiring the charge points, installing them, operating them, maintaining them, and dealing with the billing.
Disaggregated structures involve multiple different contractors. This can lead to greater competition between contractors and potentially more attractive pricing. However, you will need to consider the risks in choosing this option. For example, if there is a problem with the charging kit and the operator can’t use the charging point to generate revenue, then who is responsible for this?
This is the best approach if you already know exactly what you want: how many charging points you need, the technology you want to use, the charging speed and the pricing. All you need is one person to set it all up for you.
A concession agreement will grant the operators rights to use your land to develop, construct and operate the EV charging infrastructure. In return, the landowner charges a fee for the space used or takes a rebate based on revenue profits.
As a landowner, university leaders should consider whether the charge point operator will take their own power supply directly from the Distribution Network Operator (DNO) or whether they will be relying on the university’s electricity supply.
The distribution grid infrastructure will need to be able to adequately support the increased load. This will depend on factors such as the type of charge point (i.e., slow or rapid), the existing connection capacity at the site, and DNO consent. It’s worth considering whether to build in excess capacity to prevent future shortage issues, considering that the UK is on track to have around half of all vehicles being EVs by 2035.
Who’s responsible for regulatory compliance?
Whichever structure you choose for your installation project there will need to be sufficient due diligence on the land to ensure the development can happen safely and practically. Fire safety risk, underground hazards and other ground conditions will need to be considered to ensure the proposed area is suitable.
It’s important to consider early on who be responsible during construction for any issues between the landowner, the charge point operator and any other third parties or contractors. There may be risks around the assembling of cables, connecting into sub-stations and installing infrastructure. If something goes wrong, who will be to blame? You should ensure you have protective cover by way of insurance.
Once built, the ‘infrastructure operator’ responsible for operating the charge point (whether the owner or a person operating it on behalf of someone else) is the person responsible for compliance under the Alternative Fuel Infrastructure Regulations, 2017.
Note that according to these regulations, car parks for consumers of goods and services e.g., retail car parks, count as “public”, unlike collective residential car parks and workplace car parks. This is important because “public” charge point operators must provide a “pay-as-you-go” option – this is so that all charge points accessible to the public are usable without a pre-existing contract (e.g., annual subscriptions).
Don’t forget that your campus is not an island! Consider whether there are other landowners or stakeholders who may be interested in joining up with you on an EV charge point project. For example, the University of Worcester has installed 100 charge points into a car park which also provides 200 other community spaces, and so has been able to benefit from LEP investment, while Keele University has partnered with Siemens on its ‘living laboratory’ campus and now has 38 charge points which are free to use for both staff and students.