Office for Zero Emission Vehicles, Rapid Charging Fund Pilot Scheme

• The Rapid Charging Fund will support new infrastructure for zero emission vehicles. This pilot will in particular fund part of the cost of upgrading the electricity grid at motorway service stations, allowing the private sector to install EV charge points at the service stations.
• The scheme is a Subsidy Scheme of Particular Interest as it is likely to give rise to funding to a single beneficiary in excess of £10m.
• Our key takeaways from the Subsidy Advice Unit (SAU) report are:
  • The OZEV’s assessment refers to a CMA market study on EV charging. The SAU notes that it would expect public authorities to take account of recommendations made by a regulatory body (or explain the authority’s reasoning for not following any such recommendation).
  • The SAU took into account submissions from two third parties. These submissions raised issues that the OZEV’s assessment could have considered and identified areas for improvement. This shows that third party feedback is taken into account by the SAU and is worth participating in.
  • The OZEV’s assessment relies on future action to be taken by the CMA. The SAU notes that public authorities should actively seek to address market distortions themselves, rather than relying on action which may or may not be taken by a regulator.
  • Where referring to documents such as Outline Business Cases, public authorities should provide such documents to the SAU.
  • The OZEV’s market failure assessment could have been improved by focusing on the principal market failure (i.e. rather than confusing that main market failure with secondary market failures) and using a wider range of evidence.
  • The OZEV was commended on its approach to identifying alternative levers (Principle E). The approach was to identify a longlist of 15 options, rank those on the basis of objective criteria, and then produce a more detailed assessment of the viability of a shortlist of six options.
  • The OZEV’s “high-level” counterfactual was criticised by the SAU. This serves as a reminder to authorities to formulate a fully thought through (and ideally well-evidenced) counterfactual scenario.
  • Where schemes have in-built mitigants against distortions (for instance use of a competitive tender process), public authorities should explore these mitigants in their assessments.
  • When carrying out the balancing exercise, authorities should remember to take account of negative effects on competition, trade and investment.

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