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First published:
19 March 2025
Last updated:
19 March 2025

Response to Transport Scotland Draft Vision Implementation Plan Consultation

Consumer Scotland response to Transport Scotland's consultation on the Draft Implementation Plan for the Vision for Scotland’s Electric Vehicle Charging Network.

1. Introduction

Who We Are

Consumer Scotland is the statutory body for consumers in Scotland. Established by the Consumer Scotland Act 2020, we are accountable to the Scottish Parliament. The Act defines consumers as individuals and small businesses.

Our purpose is to improve outcomes for current and future consumers, and our strategic objectives are:

  • To enhance understanding and awareness of consumer issues by strengthening the evidence base
  • To serve the needs and aspirations of current and future consumers by inspiring and influencing the public, private and third sectors
  • To enable the active participation of consumers in a fairer economy by improving access to information and support

Consumer Scotland uses data, research and analysis to inform our work on the key issues facing consumers in Scotland. In conjunction with that evidence base we seek a consumer perspective through the application of the consumer principles of access, choice, safety, information, fairness, representation, redress and sustainability.

We have a particular focus on three consumer challenges: affordability, climate change mitigation and adaptation, and consumers in vulnerable circumstances.

Response to this Consultation

Consumer Scotland welcomes the publication of the Draft Implementation Plan and the opportunity to contribute to the discussion on the transition to Electric Vehicles. The transition is relevant to all three of our consumer challenges:

  • As the draft Plan highlights, the transport sector is the biggest single source of CO2 emissions in Scotland, and EVs offer a pathway to reducing those emissions, increasingly so as the electricity grid decarbonises
  • Our research shows that, while a majority of consumers are concerned about climate change, their day-to-day decisions are driven, to a large extent, by cost and convenience. Relative affordability of owning EVs in comparison to ICE vehicles combined with ease of charging will be critical to their widespread adoption by consumers, and we appreciate the importance of the draft Plan in responding to this
  • Our research also shows that current EV drivers tend to be better off than the population of Scotland as a whole, and are also much more likely to be able to charge at home. As EV ownership widens while the population of Scotland is also aging, the needs of EV drivers will change to more closely reflect all drivers, particularly in relation to the need for affordable and accessible charging. We welcome recognition of these challenges in the draft Plan.

We therefore recognise and agree with the headline aim of growing the charging network as a central need to provide confidence to future EV drivers, and particularly the focus on ensuring that the right charge points are delivered in the right locations. We also appreciate that constraints on public sector funding mean that private investment will be needed to achieve this.

Our consultation responses therefore concentrate on how best to achieve the outcomes we seek for consumers against that background.

Looking ahead, we are pleased to be named within the draft plan as jointly responsible, along with Scottish Government, to deliver action 7 to

Convene key stakeholders to identify measures to continue to improve the consumer experience.

Both Scottish Government and UK Government climate change emission targets require consumers to transition from petrol and diesel vehicles to EVs. We consider that this will only be achieved successfully if consumers have a positive experience of EVs across all aspects of the customer journey, with charging an essential component of this. In order to deliver a positive experience, it is necessary to both understand and respond to the current consumer experience. We therefore warmly welcome the inclusion of this action, and look forward to progressing it.

Below, we provide more detailed responses to selected consultation questions, and we look forward to working with Transport Scotland and other stakeholders as the Implementation Plan is finalised and moves to delivery.

Yours sincerely

Sam Ghibaldan

Chief Executive    

2. Consultation Questions and Responses

1. Do you think we have correctly considered the role of the private sector in delivering future public EV charging infrastructure? If not, what else should we consider?

2. The public EV charging infrastructure must scale up rapidly to meet future EV demand and can do so with private sector investment. Do you agree with this assessment of public EV charging infrastructure as it exists in Scotland today? If not, why not?

3. How would you approach the challenge of encouraging public charge point operators to invest in more marginal, lower traffic locations such as rural and island communities and lower income neighbourhoods in urban areas?

While Consumer Scotland recognises the ongoing pressures on public spending and the consequent need for private sector investment, we are less concerned about the source of finance for the charging network than about the outcomes needed to provide confidence for current and future EV drivers.

Based on our research and associated stakeholder discussions, those outcomes in relation to the network clearly include the availability and reliability of chargers, and also the affordability, and – increasingly in future - accessibility, of chargers.

Current progress suggests that the private sector can and will invest in charging infrastructure in profitable locations but is, understandably, and as recognised in question 3, much less likely to do so in areas where demand is less certain.

At the same time, without provision of charging in advance of demand, individual consumers will – also understandably – lack confidence to move to an EV. This was evident from Consumer Scotland research which found that 78% of Scottish drivers considering purchasing an EV in the future agreed that they worry they will not be able to charge an electric vehicle when out and about.

Additionally, recent Which? research also supports this view, in its findings that only 6% of non-EV drivers in the UK would consider purchasing an EV as their next vehicle; while high purchase costs remain the largest barrier, 52% cited a lack of public charging points as a deterrent.

We therefore agree with the plan’s focus on the challenge of ensuring the charging network develops not just at necessary scale, but also in the right locations and at affordable costs to meet the needs of consumers in rural, island and dense urban settings where charging challenges differ from other areas of Scotland.

We also agree that these are likely, at least initially, to be economically marginal locations, and also that provision of charging facilities in these areas is essential to provide confidence for potential EV drivers. However, we also note that the challenge is different in urban and rural areas.

In urban areas, chargers will more likely substitute for patterns of charging which drivers would otherwise carry out at home, were they able to do so.

Our research shows clearly that substantially lower running costs associated with at-home charging are one of the main attractions of EVs. Three in ten EV drivers who tended to charge at home reported running costs were lower than they expected, while the strength of feeling about the cost difference between at home and public charging was also a theme of focus group discussion, including comments such as:

“If I had to rely on public charging I’d sell the car and get something else. Public charging is out of control for cost.”

Our research also showed that EVs are less attractive for those not able to charge at home. Just under four in ten EV drivers without access to at-home charging reported running costs being higher than expected, while further analysis showed that while only a small minority of EV drivers in our survey would not purchase an EV in the future (13%), a higher proportion of this group reported range and battery life concerns suggesting these may be key factors in the decision.

The provision of affordable and stable prices for charging will be critical in high density urban settings where residents have less ability to charge at home, such that total EV running costs are measurably less than for ICE vehicles, if consumers are to be incentivised equitably to adopt EVs.

In rural settings, the challenge will be for the charging network to provide confidence to drivers covering longer distances. Access, rather than affordability, is likely to be the greater concern in this case, and faster chargers located in places where drivers might want to break their journey anyway, will be needed to meet this requirement. Hospitality businesses, for example, may have a greater role in hosting chargers in these circumstances. 

There will be different ways to achieve these outcomes, depending on circumstances, but all are likely to require enhanced local capacity to work with the private sector.

  • Firstly, as outlined in the draft Plan, we agree that a hybrid approach under which public sector subsidy is directed in proportion to identified need is likely to remain a prerequisite
  • Secondly, there may be circumstances under which private sector investment in a profitable location could be used to drive investment to less attractive local areas, similar to the planning gain approach commonly employed in relation to housing development
  • Thirdly, it may be helpful to consider whether existing, but not currently publicly available chargers, such as those currently owned and operated by public sector bodies or by private businesses, could form part of the solution – as the consultation makes clear, the visible public charging network accounts for only 5% of all chargers already installed in Scotland

We appreciate that each of the above approaches implies the existence and availability of sufficient data, understanding of local circumstances and capacity within local authorities to facilitate decision making. We expand on these points in responses to subsequent questions.

4. Are there specific barriers or opportunities related to the rollout of public EV charging across Scotland you would like to highlight that haven’t been covered in this document?

No additional points.

5. Do you agree or disagree with the actions in this draft Implementation Plan and the key stakeholders they are attributed to? Please provide additional information.

Broadly, Consumer Scotland agrees with the actions and responsibilities set out in the Plan. We comment below on some detailed aspects:

Data

We welcome the recognition of the importance of data to monitor progress and to inform strategy. In our view, technical data to facilitate this would ideally include:

  • Number and geographical spread of chargers, linked to:
    • data on housing type to reflect the needs of those unable to charge at home;
    • driving patterns by different groups of consumers
    • public transport routes
  • Charger speed, cost and accessibility
  • Charger reliability and utilisation

Our understanding is that much of this data is already available, but not necessarily in integrated or easily accessible formats. We would suggest that it would be more efficient and effective for Transport Scotland to co-ordinate data collection and collation at national level and for local authorities to add to that in their areas.

In addition to the above, consumer-facing data is of course also important and could include:

  • Perceptions of the affordability and convenience of charging, particularly for those unable to charge at home
  • Perceptions of reliability of the public network
  • Perceptions of the quality of information available about the public network (e.g. location, pricing, speed, number of charge points, availability, state of repair)
  • Insight on what consumers need and want from the public charging network (this would go beyond perceptions on what is currently available, instead speaking to alternatives that have not yet been provided)

Proposed Consumer Stakeholder Group

Consumer Scotland warmly welcomes this proposal (Action 7), and looks forward to working with Transport Scotland and stakeholders to take it forward. We would be happy to facilitate the work of the group while the Implementation Plan is finalised, and to contribute as appropriate to its longer term working after that time.

It will obviously be important to consider the detail of membership, Terms of Reference and remit of the group to ensure it is able to work towards these aims. However, we would also highlight the need for the Scottish Government to consider responsibility for actions proposed by the group.

Building on the above, we would suggest that understanding currently available data and any gaps or barriers to its use should be an early focus for the proposed consumer stakeholder group.

Affordability

We welcome the recognition in the draft implementation plan that affordability of charging is an issue. While we appreciate that responsibility for electricity pricing is a reserved issue, we would also emphasise that, as above, substantially lower running costs for EVs are a central part of the attraction for current drivers.

We would welcome consideration of other ways in which affordability could be improved, either within the charging system or in parallel to it. For example:

  • Both wholesale and distribution costs mean that electricity prices are typically lower overnight, and highest at the late afternoon and early evening peak. Reflecting these price variations for slower chargers where possible would both provide the opportunity to reduce costs for consumers while also reducing the impact of charging on peak demand
  • Outside the charging network, it may be possible to reduce overall running costs of EVs through measures over which the Scottish Government has influence; an example could be temporary reductions in the cost of residents’ parking permits for EVs where these are applied in urban areas

We are aware that a number of organisations are calling for the UK Government to align VAT on public charging points (20%) with that charged on domestic energy (5%). While we agree that aligning VAT would help to reduce the discrepancy in affordability between those able to charge at home and those unable to do so, such a change would not have a transformational effect as there would remain a significant discrepancy between the costs of charging at home and at a public charging point.

This can be illustrated using ZapMap’s analysis of average price/kWh as of January 2025 (Slow/Fast = 53p/kWh; Rapid/Ultra Papid = 81p/kWh; Home = 7.6p/kWh).

The current cost differential is 45.4p/kWh for average slow / fast charging compared to at home charging, and 73.4p/kWh for rapid / ultra-rapid charging.

If VAT on the public charging was reduced to 5%, then the cost differential would be 38.8p/kWh for slow / fast charging compared to home, and 63.3p/kWh for rapid / ultra-rapid charging.

While we would therefore support the reduction of VAT on public charging, we would at the same time encourage greater consideration of other options to improve affordability of charging EVs at public charging points, targeted at those unable to charge at home at present. We recommend that this should be an early focus of discussion for the proposed consumer stakeholder group.

More widely, we would suggest that the Scottish Government should take into account the potential to reduce EV charging costs as part of its wider work on the Reform of Electricity Market Arrangements (REMA). Consumer Scotland would be happy to discuss this further, alongside other elements of integration between electricity markets and EVs.

Role of Local Authorities

In terms of the delivery roles of stakeholders, we note that many of the detailed actions in the draft implementation plan are to be delivered by Local Authorities. However, our research showed that some consumers felt negatively about differences in experience between local authority areas – note that some of these quotes are previously unpublished:

“1 year after purchasing [my council] introduced a cost much higher than other council areas.”

[When asked about negative experiences] “The cost that some councils charge.”

“The Scottish Government has outsourced the provision of chargers to local councils which is why there's so much discrepancy in tariffs, availability, reliability and so on.”

Stakeholder discussion also suggest this reported variation reflects current capacity, which varies across local authorities.

There may be a risk, given current staff resources, that the current variable experience between authorities may be exacerbated without a more active approach. We appreciate that many authorities are part of regional groupings. We recognise the potential value in shared approaches, both for capacity and in terms of considering charger locations at appropriate levels, and would welcome discussion on whether such groupings could be better resourced, even as a temporary measure, to help address capacity and consistency issues.

6. Are there any key stakeholders in the delivery of public EV charging that you believe should have greater prominence in the Implementation Plan?

As above, we are aware that many local authorities have formed regional groupings. There may be a more explicit role for those groupings given the importance of local authorities in delivery.

For clarity, it might also be helpful to stakeholders to clarify what the Scottish Government does (and does not) intend to do itself to deliver the actions in the draft implementation plan. While we acknowledge that delivery of EV public charging infrastructure will primarily fall to other organisations, the Vision it underpins is that led by the Scottish Government. We therefore see the Scottish Government as having an important role to play around ensuring that the finalised Plan achieves the Vision, for example through monitoring and co-ordinating activity.

7. Are there any key aspects of the consumer experience of public EV charging that you believe should have greater prominence in this document?

Information

A key consumer principle is that of ensuring information should be available, accurate, and useful. In the case of public charging, however, there is anecdotal evidence that information provision could be improved, and this issue is not covered in the draft implementation plan.

There are two main aspects in relation to information for public charging that could be improved:

  • Signage to direct consumers to available public EV charging points
  • Clear and accurate information about pricing so that consumers can make an informed choice before they charge their vehicle

While petrol and diesel vehicles are refuelled at large and visible petrol stations, infrastructure that is easy for drivers to find, EV charging points are found in many different locations such as carparks, charging hubs, at the side of the street, or elsewhere. The lack of information pointing drivers to available EV charging points can make for a frustrating experience for the EV driver looking to charge in an unfamiliar location, as is evident from one story relayed during our research:

“I … used the Leaf Satnav to find a charger. It sent me to Newbridge [public site], but I couldn't find it, then Edinburgh airport, but I couldn't find that one either, then the [commercial location], I found the charger, it seemed to be working but wouldn't charge my car. Eventually I crossed the bridge and went to Halbeath [park and ride] and found a working charger!”

Clearer, universal signage to point drivers to charging points would increase consumer confidence and reduce charging anxiety for both existing and future EV drivers. Indeed, it was a suggestion for improvement raised by focus group participants in our research (note that some of these quotes are previously unpublished):

“Signage – please improve this, you can’t find chargers half the time.”

[When asked what needs to improve with charging] “Very important – good signage so one can actually find the thing [charger] - and a high expectation that it will be working when one finds it!”

Once at a chargepoint, it is essential that a consumer is able to access accurate information about the cost to recharge. This is particularly important given the variability in pricing that currently exists. Once again, however, our research suggests that current EV drivers can be left frustrated by the current complex system where not only is pricing variable, but also opaque including connection charges, minimum charges, and potential overstay charges as well as a cost per kWh. This is evident from comments such as the one below:

“.. I needed a few Kw to get home. The satnav sent me to a car park which only had 7Kw chargers, I waited 20 minutes for 2.2 Kw and was charged £5. Nowhere on the charger was there a sign stating a £5 minimum charge.”

We recognise that pricing practices for charging EVs cannot be identical to those for refuelling petrol and diesel vehicles, not least because speed of charge affects the cost in way that is not applicable to liquid fuel. Nonetheless, it is essential that consumers have sufficient upfront information about the overall cost in order to make an informed decision to purchase. It is also important that this information is equally available to all consumers, as opposed to being provided only via an app or other “opt in” solution.

We note that under the UK Government’s public charge point regulations 2023, charge point operators will have to clearly display maximum price, including fixed fees, either on a public charge point or through a separate device.

However, this does not go as far as we would like in terms of providing the required information in an accessible format to consumers. The requirement in the regulations is to display price in pence or pounds per kilowatt hour, and it will be complex to accurately represent fixed charge elements within this constraint, making it difficult for consumers to accurately compare actual prices.

We would therefore encourage the Scottish Government to consider ways in which they can improve or encourage charge point operators to improve available information about charge point locations and pricing.

Safety

A second key consumer principle is safety: goods and services provided should not prove dangerous to health and welfare.

Our research found that while consumers generally did feel safe while using public charge points (93% reported feeling personally safe at public charging points), the qualitative element of the research also provided a sense of the insecurity felt by some EV drivers when charging their vehicles, with such concerns being flagged more frequently by female drivers. Worries about charging at night and in isolated locations were particularly associated with charging in rural areas, where public charge points may be poorly lit. The following comments from our research are illustrative of the concerns expressed (note that some are previously unpublished)

“Some chargers are in remote car parks, and if I have to charge after dark it freaks me out.”

“Not enough cover at charge points - often get wet in rain- not the case for petrol stations.”

“It made me physically ill having to sit in subzero temperatures while the car charged.”

We would suggest that the proposed consumer stakeholder group be used to identify consumer barriers to public EV charging, such as those flagged above, and work with delivery stakeholders to resolve these issues. We are aware that in Northern Ireland, a similar forum has been working to better understand consumer priorities around charging infrastructure with the intention to either develop legislation or a code of practice for CPOs that addresses the consumer concerns. This may be something that could be informed through discussion at the proposed consumer stakeholder group.

8. Is there any other feedback you would like to provide on the draft Implementation Plan?

Improving EV public charging infrastructure is just one of three areas we previously identified that require improvement in order to increase consumer confidence and encourage wider uptake of EVs. It is important that EVs are accessible to, and a viable option for, all drivers if the Scottish Government’s transport emission targets are to be met.

We would therefore recommend that the Scottish Government considers additional measures to increase consumer confidence that reflect the other areas of improvement that we previously identified.

Information on EV performance in advance of purchase

While our research found that the vast majority of drivers (90%) were satisfied with the information they accessed in advance of making their purchase, this was primarily as a result of their own efforts. There was also anecdotal evidence of some dissatisfaction with information from mainstream dealers:

“The dealer didn’t know much about the car and definitely about charging. He said I will pick it up as I go along.”

The most significant information issue identified was the difference between advertised and real-world range, with around one third of drivers (34%) saying it was less than they had expected, and one quarter (25%) saying that maximum mileage had been overstated at purchase. Specific scenarios in which mileage dropped, such as motorway driving or cold weather, were also reported.

A positive finding from our research was that that the proportion of drivers holding concerns around range dropped as they progressed throughout the consumer journey. Range / battery degradation was identified by 73% of those considering purchasing an EV as a concern, dropping to 50% when current EV drivers were asked to recall what concerns they had prior to purchasing their vehicle, and to 35% for the current concerns of EV drivers. This highlights the extent to which a lack of accurate information is impacting consumer confidence.

Providing clearer, more accurate and easily accessible information on the real-world performance of EVs in Scotland, in advance of purchase, would help increase consumer confidence. Ideally this should be linked to existing information, support and advice provision, while dealerships should be supported to improve their advice provision.

Repairs and Maintenance

EV drivers in our research tended to own newer vehicles and to have purchased them new – 70% of drivers in our survey owned cars registered during 2021 or later. Despite this there are early indications from our research of consumer concerns around the vehicle maintenance and repair infrastructure.

Around one in five EV drivers reported dissatisfaction with ease of finding a technician and choice of technician for both servicing and repair. This rose to one in three (35%) reporting dissatisfaction with the length of time taken for repairs specifically. EV drivers reported having to send their vehicles away in order to get necessary repairs completed:

“Manufacturers don't seem to have provided the where with all for garages to fix battery problems – mine went from Edinburgh to Newcastle and took 5 weeks.”

This early indication of capacity concerns could become more problematic as the current fleet ages and the number of EV drivers increases, putting more demand on the system. This is of particular concern as previous research on consumer detriment has identified vehicle maintenance and repair as a particular cause for concern, with 17% of UK adults that used this service (and 9% of the UK adult population) experiencing detriment, defined as a problem or issue that caused stress, took time to resolve or cost money to fix or put right.

Increasing capacity of both dealerships and independent garages to provide specialist maintenance and repair services for EVs will help provide confidence to buyers of used EVs.

While we acknowledge that these areas are not within the scope of the draft implementation plan, they are just as important for consumer confidence as improving the public charging infrastructure. We would suggest that the Scottish Government considers how the necessary improvements can be achieved in order to support achieving net zero targets, and that the proposed consumer stakeholder group could be a mechanism to support this.

In addition to the above, further points on specific actions within the plan are set out below.

Action 1: Develop guidance on cross-pavement charging.  

While we appreciate this is a technical task, it is also important to consider consumer views. Consumer Scotland intends, if resources allow, to undertake research next financial year on what potential EV drivers living in dense urban areas would want to see in terms of charging infrastructure and their comparative views of options currently available, which might help inform and refine guidance over time.

Action 4: Provide accessible charging infrastructure

We welcome consideration of this point – the experience of consumers in vulnerable circumstances is an area to which Consumer Scotland is committed and in which we have carried out some work.

We would suggest that ongoing monitoring on the experience of disabled EV drivers would be helpful to inform approaches on this, and could form part of the agenda for the proposed stakeholder group; we are aware that Motability Scotland already gathers and interprets data from their clients.  

It seems almost certain this issue will increase in importance – not just in relation to EV charging - as the population of Scotland is aging, and that rates of disability rise with age. Previous research by the Equality and Human Rights Commission found that in 2021, 18% of 16–24-year-olds reported living with a limiting condition compared with 60% of those aged over 75.

Action 5: Agree quality standards that go beyond UK regulations, possibly through KPIs attached to public sector funding

While we agree that this approach may be appropriate and helpful in the short term and support the use of public funds to add value in this way, it is clear from the consultation that the majority of new charging capacity already comes from direct private sector investment, and that this is expected to continue in future.

This position emphasises the importance of the Scottish Government and others:

  • working with the UK Government and industry to raise standards for all CPOs to maintain a level playing field, and
  • in the interim, make use of the planning system to help ensure all developments are delivered appropriately

Action 6: Ensure an affordable network

As reflected in our responses above, Consumer Scotland strongly agrees with this aim.

Analysis of our research on consumer attitudes to net zero shows that, while a strong majority of consumers are concerned about climate change, their daily decisions are – not surprisingly – driven to a much greater extent by cost and convenience. This finding is exemplified by the current balance of EV users, which is concentrated among those able to charge at home, conveniently and at prices considerably below those of running an ICE vehicle (80% of drivers that participated in our EV research tended to charge at home via their retail energy supply).

From this perspective, the challenge is to deliver a network which provides similar benefits as far as possible to consumers unable to charge at home. This is likely to imply a greater density of slower chargers close to consumers’ homes, and, as highlighted in the consultation, ideally lower costs for charging at off peak times.

We would suggest that the proposed consumer group considers comparative EV and ICE costs for consumers, taking account of (currently) lower VED but also higher insurance costs as well as fuel costs. Collection of consumer-facing data on real world running costs will also be necessary to understand this, and will also be helpful in addressing current misinformation.

Action 12: Facilitate collaboration towards solutions

The consultation proposes the establishment of a technical working group. Consumer Scotland recognises the need for and benefits of this. It will be important for Transport Scotland to facilitate the information flow between this and the proposed Consumer Group groups so that technical solutions consider consumer views, while at the same time consumer research better reflects technical options and constraints.

Action 13: mapping multi-modal, multi energy locations

We support the aims and intentions underlying this proposal. We are aware that some such sites already exist in Scotland, and would suggest it would be helpful to understand patterns of use of these and consumer views of the services provided, including links to public transport, to help influence the design of future services.

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