The Office for Zero Emission Vehicles (OZEV) recently closed its consultation on the design of the Rapid Charging Fund (RCF). The RCF is expected to be a key driving force behind the zero-emission vehicle mandate, funding the grid connections which will power “a comprehensive ultra-rapid charging network” across the UK. The OZEV consultation sought views from across the electric vehicle (EV) industry to help the government shape the design of the funding model, criteria for applicants and scope of the project. 

The Competition and Markets Authority (CMA), the UK’s competition and consumer regulator, has now published its comprehensive response to the consultation, which you can read in full here.

Background

The CMA's response was informed by its in-depth 2021 market study, which revealed deficiencies in en-route charging, particularly at motorway service areas (MSAs). Recognising the vital role of robust competition in driving innovation and consumer choice, the CMA advocated for the swift implementation of the RCF, coupled with stringent conditions to stimulate competition among charge point operators (CPOs) at MSAs, aiming to ensure reasonable pricing for EV users.

Key principles 

The CMA response is built around three core principles:

  1. Encouraging Competition: Fostering a competitive landscape within the EV charging sector is the principle aim of the CMA – the importance of this also seems to be recognised by OZEV, as one of the specific points that OZEV listed that it was looking for views on was how to ensure effective competition as MSAs. To this end, the CMA recommends: 
    • Attaching conditions to RCF funding that prohibit exclusive arrangements between CPOs and MSA operators. 
    • Establishing a minimum number of CPOs at each MSA site, which it suggests will “help to deliver more choice, better reliability, lower prices and continued innovation for drivers”, as well as interoperability of charge points with all EVs. 
    • Open tenders for access to network capacity and the fair treatment of CPOs, which it suggests will benefit drivers due to improved choice, price and service. 
  2. Reliability and Availability: Ensuring the reliability and availability of EV charging infrastructure is paramount to facilitating mass adoption of EVs. The CMA supports OZEV's proposal to mandate minimum provision levels at MSA sites, emphasising the importance of future-proofing grid connections to accommodate growing demand. 
  3. Monitoring and Addressing Gaps in the EV charging network: Acknowledging regional disparities in charging infrastructure, the CMA advocates for targeted government intervention to address gaps in remote and rural areas. This should be reviewed through ongoing monitoring as well as considered in initial funding allocation. 

Conclusion

As would be expected, the CMA's response focuses on ensuring that the EV charging sector develops in a competitive and consumer-centric manner, centred around the core principles of fair competition, reliability and accessibility. Although OZEV will need to balance this with commercial considerations to ensure buy-in from CPOs and other private sector entities, ultimately growing consumer confidence through creating reliable and affordable nationwide charging is what will unlock the path to Net Zero transport. 

OZEV is currently reviewing feedback received from the consultation before it publishes further information on the design of the RCF. 

For any queries on the Rapid Charging Fund, EVs or other sustainable transport projects please contact Chris Lewis or Charlotte Robinson. For any queries in relation to the role of the CMA or Competition law issues, please contact Shachi Nathdwarawala.