SEAI Consultation on EV chargers for Apartments

In response to SEAI's consultation: https://www.seai.ie/consultations/EV-Apartment-Charging-Programme-Overview-(Consultation).pdf, https://www.seai.ie/consultations/EV-Apartment-Charging-QA-Summary.pdf & https://www.seai.ie/consultations/EV-Apartment-Consultation-5.8.21-Webinar-Slides.pdf, my comments are as follows:

The programme should focus on quality of service to end users firstly, in order to ensure high take up, and movement of people away from ICE vehicles. 

I commend the principle that in the first instance, users should be accommodated by serving their charger / EVSE from their own ESB Networks supply rather than a shared scheme (and thank SEAI for it's efforts in making it legal now to connect in this manner).

I furthermore support, per the FAQs on your website https://www.seai.ie/consultations/EV-Apartment-Charging-QA-Summary.pdf question 42 [If this scheme is not compulsory, it makes it unworkable from an OMC?], that additional legislation be implemented to compel provision of chargers, by a deadline date for each scheme. Management companies and indeed landlords generally don't see the benefits of using EVs whereas users and the public as a whole do. Additional nudge factors should be provided here i.e. As an apartment (or indeed a house) with an EV charger can possibly have a lower carbon intensity than a comparable dwelling with merely a parking space, taking into account transport emissions too, the owners should see some benefit / recognition beyond just reduced operating cost. I propose that the presence of an EVSE charger should improve the BER of the dwelling in some measure. Otherwise, it could prove to be a hindrance to landlords to fund chargers (especially the Tier 2 approach as discussed SEAI's materials) as they won't see the benefit.

In the case where a shared scheme is required due to restrictions of the complexes' design, I propose SEAI ought to make funding contingent upon the management company having a good set of operational procedures to ensure a high quality provision by:

• discourage requiring people to have to wait to use their charger i.e. have adequate capacity of chargers / density of chargers per block to be per building regs or mitigation plan. If shared chargers are envisaged, there should be a choice of both quick charge type (>50kW) to avoid people having to get up in the middle of the night to unplug their car to free up capacity for others, and trickle charge chargers (>7kW) to promote battery State of Health longevity.
• Use common standards as applied to new construction i.e. CCS Type 2, and markings + capacity per Building Regulations ( Energy Performance of Buildings Regulations 2021 Technical Guidance / Energy Performance of Buildings Directive Articles 8(3), 14(4) and 15(4) – Electric Vehicle Recharging Points and Building Automation and Control: https://assets.gov.ie/180480/f1760b4e-113a-4dbb-add3-85891eb76cab.pdf)
• deal with "ICE'ing" of the EV charge spots by having a reporting service clearly marked with mandatory fines being levied against owner of the ICE. It cannot be permitted for people to not to be able to charge their vehicles. This should furthermore be discouraged by not putting the EV chargers in "prime" spots, while still accommodating disabled people in it.
• have capacity triggers for when additional chargers should be installed as people move over from ICE (and the SEAI programme ought to accommodate multiple steps as the EV density expands in each apartment building) - having people wait to use a charger is not fair
• provide a means to accommodate visitors charging i.e. possibility of paying with debit card, or using one of the existing ESB eCars accounts or similar national network
• bear in mind that there is a possibility for distortion of the market with respect to who can offer charging in complexes, it should be required that there is fair & simple payment scheme i.e. with conditions the same as ESB eCars network, interoperability with same, max pricing permitted for the lifetime of the installation. This was also a consideration with he termination of the ESB eCars initial roll out programme: https://www.cru.ie/document_group/electric-vehicles-2/.  In the past in Ireland, there has been non-competitive practices in apartments with telecommunications services i.e. one operator of TV/Telephone/Internet services would sign a deal with the management company to pay for the installation of their infrastructure at no cost to the management company on the understanding that other providers of the same services would not be installed in the future. Such a situation should not be permitted under the SEAI programme, and auditing should be implemented to guard against this.
• ensure that a charge is delivered even if comms failures for billing - if people need to charge they need to charge
• SEAI should commit to auditing of the installation regularly by speaking to users to ensure a high quality provision

Additionally, as the goal of the programme ought to be to move people away from ICE vehicles / decarbonisation of transport, it should not be a fait accompli that they need to move to an Electric Vehicle. Provision should be made to also accommodate the parking & charging needs of electrically assisted pedal bikes, cargo bikes etc. as these could suit people too (and have the benefit of reducing car traffic) - this could be achieved in as simple a manner as providing a conventional 13A socket in a shared space.

Continuing on the intent of decarbonisation, under the Tier 2 schemes, it should be a required that electricity suppliers used provide green electricity, not merely the cheapest fossil fuel supplied electricity. This should be regularly audited by SEAI.

The programme should also bear in mind that end users may be funding infrastructural improvements in common areas of apartment complexes. To this end, there may be a reluctance to fund assets that they would potentially lose access to or title to sell should they wish to sell their apartment (and so be unwilling to invest). The programme ought to accommodate & overcome this reluctance factor i.e. by assuring users that if they move to a new dwelling, be that a house or another apartment, they can avail of the grant again with the same vehicle should they leave the charger behind (especially important in Tier 2 approaches for renters). Also, it should be clarified that the management company of the complex shall not take "ownership" of any infrastructural improvements like EV chargers part funded by apartment owners upon sale - this should pass to the new resident or owner.