Citizens Advice response to the Smart EV Consultation on the Interim Solution for Domestic Managed Electric Vehicle Charging
In this consultation, EA Technology on behalf of the electricity network SSEN proposes a solution that should help electricity network operators manage overloaded parts of their networks to avoid an interruption of supply. Their proposal involves electricity networks managing the level of charge an electric vehicle (EV) can take from their network for short periods of time.
See our full response here 364 KB . In summary:
We agree that the managed electric vehicle (EV) charging solution could benefit electricity consumers. It is in the best interest of consumers to prevent a blackout if possible, which this solution tries to do. Without any intervention, the actions of a small number of EV owners could potentially put the reliability of the electricity supply of their neighbours at risk, including people in vulnerable situations.
We want to stress that the proposed solution should only ever be an emergency measure and a last resort. Twenty-eight percent of the average person’s electricity bill goes towards the transmission and distribution network ( Infographic: Bills, prices and profits, Ofgem, April 2018 https://www.ofgem.gov.uk/publications-and-updates/infographic-bills-prices-and-profits) . For this money, electricity distribution network companies should aim to keep their customers on full supply, all day, every day, apart from essential repairs and in severe weather.
We would like to see electricity networks being more proactive and seek to avoid the need for EV charge controllers to be used in the first place. Companies should explore cost-effective solutions to network constraints including energy efficiency measures and establishing markets through which end-consumers can offer their flexibility as a paid service.
The installation of an EV charge controller on a consumer’s property should be optional and require their consent. Network companies need to conduct more research to understand to what extent the interim solution is acceptable to their customers and what measures or conditions would make it more acceptable.
Electricity network companies need to give more thought to the needs of vulnerable individuals that live in a household that solely relies on an EV. In terms of the managed EV charging solution, we argue that such households should have the ability to provide consent for every single managed charging event - not just for the installation of the EV charge controller.
The governance arrangements for the managed EV charging solution need more consideration and justification. The evidence base on which current modelling rests is thin. We would also like Ofgem to explore the need for financial disincentives to prevent networks from using the managed EV charging solution too often and for too long.
For now we do not believe that there is a strong case for compensating consumers for the use of managed EV charging in emergencies, but there may be in the future. Networks should also conduct more customer research and trials to understand to what extent compensation is seen as necessary and what role it plays in increasing acceptability of managed charging.