The WDC recently made a submission to the ZEVI (Zero Energy Emissions Ireland ) consultation on the National En Route EV Charging Network Plan. In this blog post I give an overview of our key points. The full WDC submission is here and also linked below.
The WDC regards the provision of quality transport infrastructure, and in this case Electric Vehicle (EV) charging infrastructure, as essential to underpinning the economic and social development of the Western Region. Our region is very rural; Census 2022 shows that 63% of the population living outside of towns of 1,500 (compared to 31% in the rest of the state). While nationally 52% live in towns with a population of more than 10,000, in the Western Region only 23% do. Our focus therefore, in relation to transport policy, is Western Region wide access to opportunities, employment and services, through a variety of transport modes. While the focus is on our region our comments are relevant to similar regions and rural areas elsewhere in Ireland.
Key points from the Submission
- In the Draft En Route Charging Plan there is a clear prioritisation of the TEN -T core and comprehensive network, but the issue of geographical reach must be considered in more detail. At present there is no strong emphasis on prioritizing remoter areas. In the draft Plan it is clearly stated that TEN T single carriageway and national routes which are not part of the TEN T network will only be considered after the other categories of roads. We are very concerned that this will unfairly impact the West and Northwest where there is very little dual carriageway and no motorway north of Galway/Tuam. We believe that the prioritisation of the development of charging infrastructure should be based on gaps in provision and journey type and distance.
- A Plan for en route EV charging needs to consider journeys rather than traffic in order to meet the needs of EV users for en route charging. Although the national road network carried 43% of Ireland’s traffic and TEN-T roads carry 19.2% of the traffic kilometres nationally, understanding where on the network this traffic is and what kinds of journeys are being made is important to planning a charging strategy. For example, it is likely that the M50 and motorway routes close to Dublin carry a high proportion of this traffic. Many of the journeys on that part of the network are likely to be commuting and for local travel and hence there may be less requirement for a concentration of charging facilities. On other parts of the network a higher proportion of the traffic might be making longer distance journeys with consequently more need for EV charging facilities.
- In relation to the longer journeys taken by those travelling to the region, it might be assumed that their journeys will start with a full charge. Therefore, it is likely that most of the charging required will be at the farther end of the journey (e.g. away from Dublin, and larger cities and airports). The focus on the Core and Comprehensive Ten T routes mean that the higher provision of charging will be at the beginning or middle of the journey rather than closer to the end of range often in remoter or more rural areas.
- There needs to be more information about how this strategy will mesh with that for Local Authorities on the provision of charging facilities in their areas. This is particularly important in relation to national secondary routes which tend to be given lowest priority in the national road network, and yet can be important linking roads within regions. In many parts of our region long journeys can be made on these, with only minor interaction with national primary routes. Likewise regional roads in some counties serve important roles in connecting counties and regions. Therefore, it needs to be clear how charging strategies for these roads link to this one for en route charging.
- Many rural journeys are made by tourists, those travelling for work, enterprise and leisure who do not live locally. The WDC is concerned that EV drivers should not be deterred from visiting the more rural parts of our region because of actual, or perceived, lack of EV charging opportunities. While many rural residents can charge at home, overnight and day visitors may have fewer opportunities. This category needs more consideration, especially as tourists and other visitors are likely to be concentrated at particular times (summer, weekends and other holiday periods). Visitor numbers can easily exceed those of the local population, their demand for charging infrastructure is likely to occur at particular peaks. Addressing their needs, in the context of en route rural EV charging infrastructure is important. When considering tourists, it is important to have a broader focus than tourist hotspots so that less visited places do not have any disadvantages compounded.
- In planning for en route EV charging infrastructure in remoter areas, it should be remembered that while the range of EVs has increased significantly in recent years, maximum range is often not achievable. Drivers may not always anticipate the impact cold weather, rain, wind, darkness or undulating terrain can have on their range. Likewise, there is often occasion for unplanned or unexpected diversions including getting lost. These all influence the need for widespread fast EV charging infrastructure in rural areas.
It is important that there is a consistent national standard of charging infrastructure so that EV users can confidently rely on charging availability. Likewise, it is important that more rural and remoter regions are considered specifically in the charging plan, and that the prioritisation of the charging network is not just on road type (where the west and northwest is already disadvantaged) but is based on need and gaps in the network alongside a recognition that lack of such infrastructure will impact the economic and social development of remoter and more rural regions.
The WDC submission can be read in full here. Please note the actual submission was made in the PDF format provided by ZEVI.