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We considered the impact of other device requirements such as default and grid stability, but given they have opt-out functions we concluded that they will not cause equality issues. The overall conclusion is that the policy does not disadvantage people with a particular protected characteristic. However, the Government is taking a range of steps to ensure fair access to smart charging for EV drivers. Government and Ofgem will outline in the 2021 Smart Systems and Flexibility Plan the steps being taken to ensure that consumers are informed and have trust and confidence in the smart charging market.

Furthermore, Government has committed to working with the EV Energy Taskforce and industry to improve the provision of information and advice on EV energy issues such as smart charging. More broadly, Government and Ofgem will continue to work together to ensure that consumers who participate in a smart energy system are appropriately protected, and to help those who may otherwise struggle to participate, such as low income and vulnerable consumers.

In addition, in the recent consultation to improve the consumer experience at public chargepoints 7 we asked stakeholders how all consumer needs should be met when using the public charging network for consumers with visible and non-visible disabilities. It is essential that all EV consumers can easily find, charge and pay at public chargepoints. Energy efficiency The consultation asked respondents for a view on whether there should be a specific energy efficiency requirement on chargepoints. The Government did not express a view on including such a requirement within the legislation.

Some respondents thought a requirement should be included, making suggestions such as a minimum acceptable standby power draw. Those who disagreed recommended that efforts should be focused on improving the energy efficiency of vehicles, rather than on placing requirements on chargepoints, since these are largely efficient products already. Considering the evidence provided in consultation responses, Government does not consider the energy efficiency of smart chargepoints an issue that requires intervention at this stage, particularly given the energy consumption of smart chargepoints themselves is low. We will not place an energy efficiency requirement on chargepoints via these regulations.

Impact of proposed measures on different Parties To assist with internal evaluation of the above proposed measures, the consultation asked for evidence and views on the impact of these regulations on the following parties: consumers, chargepoint manufacturers, DNOs, energy suppliers, chargepoint operators, Government (local/national) and other relevant parties. Responses covered a range of the above groups, citing both the cost and benefit to consumers and manufacturers where chargepoints may need to be upgraded in line with regulations, and the benefits to DNOs and chargepoint operators from increased flexibility. A full read out of these views is published in the summary of responses.

7 https://www.gov.uk/government/consultations/the-consumer-experience-at-public-electric-vehicle-chargepoints 23