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Representation ID: 44977

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

16.0 Policy TRAN8 - Planning for Low Emission
Vehicles
16.1 Policy TRAN8 states that proposals for low emission vehicles will be supported by ensuring that
new developments include adequate provision for charging infrastructure.
16.2 The Viability and Delivery Study does not appear to apply any cost to this policy requirement
but does cover electric vehicle charging points under Policy CC4. It notes that the current policy
is for one electric vehicle charging point required for each home, where feasible and viable, as
set out in Black Country Air Quality SPD and states:
“For the purposes of our viability assessment, we have included £800 per unit for EV charging
(and £5,000 for a multi-charging point for every 4 x flats). This is based on the
Wolverhampton average cost”.
16.3 Typically, the provision of car charging points will require higher voltage cabling to be installed
throughout the site, resulting in higher on-site infrastructure costs. The policy requirement as
drafted is also onerous given that there can be varying requirements for the provision of car
charging points across developments with some LPAs requiring the necessary infrastructure to
be in place and others to deliver the actual charging point.
16.4 It is also possible that capacity for such voltage will not be available on the current network and
therefore the costs to upgrade the network can be significant, requiring on site substations or
off-site primary substation upgrades. These costs are extremely difficult to quantify and can
exceed hundreds of thousands of pounds dependent on site size and current service capacity.
This scenario is untested in the Viability and Delivery Study and should be considered further,
particularly as the expectation to have usable and fit for purpose EVCPs is going to increase.
16.5 We also understand that the Government is proposing to introduce requirements for charging
points under Schedule 1 to the Building Regulations 2010, which are expected to come into force
in 2022. This will introduce a nationwide standardised approach to the provision of charging
points in new buildings. It is therefore questionable whether this Policy is required as it will
duplicate national policy. It is also considered that the £800 per unit under-estimates the actual
cost for providing a charging point. The Government Electric Vehicle Charging in Residential &
Non-Residential Buildings consultation estimated a cost of £1,000 per EVCP plus an automatic
levy for upgrading networks capped at £3,600.
16.6 The Government’s intention is to ensure that the introduction of this requirement does not add
such a burden on developers that certain developments become unviable.