Expanded guidance provides more clarity on electricity supply to EVs

In a burgeoning EV-centric world, Ofgem’s updated guidance on supplying electricity to electric vehicles (EV) should provide clarity for many organisations around the supply arrangements in place for different charging scenarios. Due to their mobile nature, EVs don’t fit in with the legislative model that defines an electricity consumer by the premises they occupy. Therefore, Ofgem considers in most scenarios, selling power to an EV driver is not considered to be supply, however, the conveyance of power to the chargepoint is.

In a bid to ‘cover all/most bases’ for the various recurring issues and themes that have emerged from its Innovation Link service, Ofgem’s guidance has outlined eight different scenarios: charging at home, destination charging at a public car park, forecourt, on-street, home and roam, peer-to-peer, mobile on-demand, and fleet charging.

Selling electricity usually requires a supply licence, but in some cases, providers can be exempt. Many of the scenarios are considered to qualify for exemptions from the need to hold a supply licence (Figure 1) in a bid to minimise the burden of regulation on persons operating in a limited manner.

Figure 1. Classes of exempt supply

Source: Ofgem

With home charging, the power provided comes from the customer’s standard domestic electricity supply, therefore, the EV is no different to any other household equipment in need of power. The same applies to peer-to-peer scenarios where the host is reselling power from their licensed supplier directly to the EV driver.

The Maximum Resale Price (MRP) prevents the host from reselling energy at a higher price than they paid. This does not apply in instances where a bespoke chargepoint is used, but if it is carried out via a standard plug and socket (in a domestic setting), it does.

Destination charging at a public car park with the power supplied by a licensed supplier qualifies, alongside forecourt charging, for Class B exempt supply. The MRP does not apply due to the reselling being carried out through dedicated EV charging infrastructure and not on domestic premises. A site may also be generating its own power through solar power output (for example) for charging EVs, making it eligible for Class C exemption, combining the Class B and Class C exemptions.

The supply of electricity to chargepoints for on-street charging via the local distribution network operator’s system is considered to be supply and is therefore subject to standard supply rules. However, a Class C supply exemption does apply in instances where the streets are on a microgrid with the supplier likely to be onsite. Conversely, in a home and roam scenario, customers pay for charging on-the-go through their domestic electricity supply and the roaming charging service is viewed as a ‘non-energy product’ and factored in by the supplier as a separate line-item in the customer’s bill.

With mobile on-demand charging, which involves batteries being charged in advance at the provider’s business premises and charging on the go, Ofgem considers that this is not classed as supplying power via a distribution system to a consumer’s premises and therefore supply regulations do not apply and the sale of electricity to the EV driver is not supply nor reselling.

Fleet-based EV solutions employ aspects of previous scenarios, most comparable to home and roam, and will therefore incur the same rules as scenarios above in similar instances of use and supply. The fleet provider will have a non-domestic supply contract for charging at its premises and non-domestic supply licence rules will apply.

As everyday use of EVs becomes more commonplace and varied, guidance such as this will be all the more important in aiding EV owners and chargepoint operators navigate the many rules to energy supply, and help to mitigate potential legal disputes arising from confusion. With many using Ofgem’s Innovation Link service to query how supply arrangements interact with EV activities there is a clear need for more clarity, and with the 2019 guidance only covering four scenarios and in much less detail, this latest version is a welcome upgrade.

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  • A weekly bulletin to ensure all the key issues and developments are tracked
  • Periodic alerts that analyse the most significant developments as they happen
  • A monthly metrics pack that tracks key industry data sources
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