Letter to the Subsidy Advice Unit
Evidence submitted in challenge to OZEV's proposed SCI Scheme £190m subsidy, assessed against the SAU's principles.
In October, Osprey submitted evidence to the Subsidy Advice Unit (SAU), challenging OZEV's Assessment of their Strategic Charging Infrastructure (SCI) scheme against the SAU's principles. £190m of public funding is at stake, which we argue is an unnecessary subsidy.
Last week the SAU published its report, endorsing many of our points.
Read the full report: Subsidy Advice Unit of the Strategic Charging Infrastructure scheme
The SAU says OZEV cannot reach a definitive conclusion on proportionality (Principle B) or competition (Principle F) until the scheme design is finalised, and that OZEV should then complete its Assessment of the final design.
The SAU Report has a substantial list of "shoulds" for OZEV (the firmer SAU language than "could"), including:
- Distinguishing delayed investment from investment that would never happen.
- Explaining how the scheme will exclude investment that would proceed anyway, and why MSAO's ability to fund connections themselves is not factored in.
- Assessing the financial and non-financial benefits accruing to MSAOs, including from on-site commercial arrangements resulting from control over the land.
- Considering MSAOs' incentives to favour their own CPOs, and to either add mechanisms to limit distortion (i.e. mandate proper competition) or explain why this isn't needed.
- Evidencing why excluding non-MSA sites has low competitive impact, consider broadening eligibility and other options that have emerged since the original Rapid Charge Fund.
The SAU raises further points to ours, including that:
- there is no obligation on beneficiaries to actually build charge points
- there is no cap on the total subsidy a single MSAO could receive across multiple sites
- the scheme’s size should be put in context against recent and planned private investment.
Overall the Subsidy Advice Unit Report on the SCI Scheme recommends significant extra work is required by OZEV, backed up by new evidence such as investment plans and site level commercial analysis.
We look forward to seeing all these points covered in OZEV's final scheme design and subsequent Assessment.
Anything short of this calls into question the responsible use of such a large chunk of funding for EV charging infrastructure - funding that, as currently designed, only a handful of MSA-owned operators will see the benefit of.
Insights.
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