certification and assurance scheme for interoperability. Both proposals were based on the use of PAS 1878 for these requirements. Many respondents agreed with these proposals, noting that testing, assurance and certification for these requirements would help to ensure that Government’s aims for cyber security and interoperability were met. However, some raised concerns over the burden this approach would place on industry, and thought that further detail on the legislative requirements would be needed before making a final decision.
Government will require that compliance with these regulations is demonstrated with an accompanying statement of compliance and technical file, which should give detailed evidence of how the requirements in these regulations are met. This file will need to be made available to the enforcement authority upon request. Government considers this a proportionate approach to assurance for these regulations, given the nascent nature of the smart charging market. Government will monitor compliance closely and will consider increasing assurance requirements over time.
Other Equalities Act 2010 The consultation asked respondents whether any of the proposed requirements would disadvantage people with protected characteristics, as defined in the Equality Act 2010, or could otherwise cause equality issues. Although some of the responses did discuss equality issues, the risks were generally in relation to fair access to smart charging, not specifically about discrimination in relation to the Equality Act resulting from this specific smart chargepoint legislation.
Taken in the context of a policy to increase the provision of domestic and workplace chargepoints, the overall conclusion is that the policy does not disadvantage people with a particular protected characteristic. The Government has since reviewed the legislation in relation to its public sector equality duty. The main finding of the review was that the legislation may increase the purchase price of a chargepoint which could create a barrier for households that are less financially secure. Poverty is higher among all black and ethnic minority groups than among the majority white group and among families where at least one member is disabled.
6 However, the chargepoint is only a small proportion of the cost of an electric vehicle itself and smart charging will help offset costs and reduce overall systems costs in the long run. The Government therefore concluded that the increased purchase price of a chargepoint will not cause discrimination. Furthermore, as smart charging becomes more common it is expected that there will be increasing choice in the variety and bundling of services. The complexity of the market might make it more challenging to understand smart charging tariff options. This might disproportionately affect older people, or those with a mental impairment.
But because of the opt-out function in the legislation, consumers will still have the option to charge their vehicle in a non-smart way, therefore government concluded that it would not cause discrimination due to age or disability. 6 Poverty in the UK: statistics Briefing paper Number 7096 , 18 June 2020, by Brigid Francis-Devine, House of Commons Library 22