Written evidence from Salvage Wire Ltd (ELV0011)

1. What are the main obstacles to the achievement of the Government’s 2030 and 2035 phase-out dates? Are the phase-out dates realistic and achievable? If not, what steps should the Government take to make the phase-out dates achievable?

Two main obstacles - The Government and Media.

2030 and 2035 dates are achievable. The UK Government MUST confirm that the 2030/2035 roll out will happen and stop the constant debate and confusion that currently exists. Vehicle manufacturers plan their model releases many years ahead and this confusion is helping no-one.

Negative press and social media reports about EV’s - fires, poor charging experiences, cost of vehicles and more all add to the confusion.

2. Do the 2030 and 2035 phase-out dates serve their purpose to incentivise the development of an EV market in the UK? To what extent are car makers focusing on one date or the other? What are the impacts of the deadlines on the ability of the UK supply chain to benefit and how could the Government seek to further support the development of the UK EV industry? Would the introduction of a plan with key dates and timescales support the development of the EV industry in the UK?

The focus on EV in the question is concerning, this should be a focus on Zero Emission (ZE) vehicles. When legislation specifies the type of technology to be used (EV) there is a risk that other technologies that could meet the requirements of zero emission will not be developed.

The dates are only as good as the paper they are written on unless the UK Government categorically confirm that these dates are fixed, immovable and WILL happen.

If the dates are confirmed investment will follow - constant debates about dates will delay investment and reduce confidence in the UK marketplace.

Incentives must be given to support:

• The UK vehicle manufacturing industry especially where battery production is concerned - the lack of support for BritishVolt in 2022 is a classic example of Government stupidity. BritishVolt was an example of initiative and inspiration that should have been supported and allowed to succeed - failure to support the company immediately put a glass ceiling on the UK vehicle manufacturing industry and will ultimately limit the capacity of the industry.

• The battery charging industry need assistance, especially where they are looking to connect their charging stations to the grid - the length of time this takes is appalling and needs to be made much quicker.

• There is currently no facilities in the UK to recycle (at scale) large high voltage batteries from vehicles, these facilities must be close to battery production sites and the metals captured from recycling must be utilised in brand new battery production; creating a truly closed loop recycling process.

• The UK Government must also look at small car companies (Ariel, Morgan, Caterham for example), those producing less than 1000 units per annum, and bring in an exemption from zero emission targets for these companies.

3. What specific national policies, regulations or initiatives have been successful, or have hindered, EV adoption to date? Are these policies or initiatives fit for purpose?

Rebates off vehicle purchase price were good, but have now ceased. Incentives for company car drivers are good but only benefit one specific area of vehicle purchase/use - similar incentives need to be available to encourage private purchase of these vehicles.

Currently there are no initiatives or policies that are fit for purpose!

The government MUST give more help to facilitate vehicle charging facilities - this applies to all residential homes, businesses and hotels.

Legislation must be enacted that requires all new build houses to have off road space for a vehicle to charge and a charge point must be fitted.

Help must be given to businesses to fit charging points in their staff car parks

Hotels must be forced to fit charge points in their car parks.

4. Given that the Government should apply a behavioural lens to policy—which involves people making changes to their everyday lives, such as what they purchase and use—is there a role for clearer communication of the case for EVs from the Government? If so, who should take the lead on delivering that?

There is a very clear need for accurate and consistent communication from Government - this is such a big issue that it cannot be politically led so needs to be an independent organisation that has a very clear mandate, is supported by all political parties and can hold the UK Government (of whatever party) to account.

One example is about the change over date - some people I have spoken to believe that they MUST have an electric vehicle from 2030, there is obviously a need to communicate that this date is for brand new vehicles only.

This change from Internal Combustion Engine (ICE) to Zero Emission (ZE) is a complete mind shift - very similar to the change from horse and cart to ICE vehicles in the early years of the 20th century. This change will not happen overnight and there will be some that completely refuse to change, but for the majority there needs to be education, information, and advice available.

Where does a vehicle stand still most often? Home and work. Many will have facilities at home to charge vehicles, but for some this may not be possible, so businesses need to have charging facilities for staff who are not able to charge at home.

5. What is your view on the accuracy of the information in the public domain relating to EVs and their usage?

It is rubbish - too much dis-information, hype, speculation and bias is portrayed in the UK press and social media (in some cases funded by the oil companies). This must be changed and any incorrect or factually incorrect reporting must be shut down.

6. What are the overall environmental benefits that would result from achieving the 2030 and 2035 targets?

Clean air, reduction of pollution, combating climate change - do you need any more!

7. What are the likely costs that will be faced by consumers as a result of the Government’s phase-out dates for non-zero emissions vehicles? Are there policies or initiatives that the Government could use to specifically target barriers arising from unpredictable costs to the consumer, for example significant fluctuations in the cost of electricity, changes to road taxes, or the introduction of low emission zones?

This question applies to both ICE and ZE vehicles.

It is very possible that the UK Government would significantly increase tax on petrol and diesel as the projected phase-out dates get closer, they could also significantly increase road taxes to force more drivers towards ZE vehicles.

Petrol and Diesel prices have fluctuated for years so is electric cost fluctuation any different?

Any clean air zones must be consistent across the country - If a vehicle is compatible for ULEZ in London then it must also be compatible for all other cities across the UK.

EV Market and Acquiring an EV

These questions relate to the UK EV market and uptake of EVs by UK consumers.

8. What are the main routes for acquiring an EV? Which aspects of these routes are working well, and which aspects could be improved?

New and used vehicle sales are working well, and will continue to operate at scale.

9. What are the main consumer barriers to acquiring an EV, either through purchasing, leasing, or other routes?

Cost of the vehicles.

10. How is the Government helping to ensure that EVs are affordable and accessible for consumers, and are these approaches fit for purpose?

The UK Government is not helping in any way!

11. Do you think the range of EVs on offer in the UK is sufficient to meet market needs? Which segments are under-served and why? Why is the UK market not seeing low cost EVs, particularly in comparison to China?

Back in 2012 Tesla brought out the Model S that competed with luxury vehicles from Mercedes, Audi and BMW, so vehicle manufacturers brought out vehicles to compete in that new marketplace. Tesla then brought in the Model 3 so manufacturers responded to that competition. We are now seeing cheap imports from China coming into the UK marketplace at £10-£15,000 cheaper than European competition. There is a significant danger that these Chinese vehicles will start to dominate that part of the marketplace and push out ‘legacy’ manufacturers.

The UK government missed the opportunity to support UK manufacturers in the design, development and production of cheaper electric vehicles and we will never get that opportunity again, and this could be the reason why the UK doesn’t have sufficient battery production capacity right now and is lagging behind almost every other country in the world for this.

Currently China is leading the market for new EV’s, with Europe second and North America third. The recent changes in legislation in the USA (the inflation reduction act) is putting significant investment into the US vehicle manufacturing and EV research and development and allowing that region to catch up.

China is successful with low value EV’s because of the incentives given by their Government for the last 10-15 years.

12. What is the future role of L-segment and personal light electric vehicles, and how will that impact car ownership and usage? What is inhibiting their uptake?

No answer

13. What is your assessment of the current second-hand EV market? How is the second-hand EV market projected to develop between now and the phase out dates?

Will adjust to the new marketplace

14. What is the relationship between EV leasing and the second-hand market and how do they interrelate?

Many vehicle manufacturers want to control all aspects of vehicle use (from cradle to grave), how this changes the used vehicle marketplace will have to be assessed as these programmes develop

15. What barriers are there to achieving a sufficient supply of second-hand EVs, mindful that second-hand vehicles make up a high proportion of all vehicles purchased?

As more brand new ZE vehicles come into the market this will increase the volume of these vehicles heading into the used market place - the market will adjust naturally to the mix of models.

16. What is the value and role of alternative transport models such as car clubs and micro mobility vehicles in the Government achieving the 2030 phase out date, and how should the Government consider their roles and opportunities for use in transport decarbonisation?

No answer

17. Are consumers charged higher rates of insurance for an EV when compared to an internal combustion engine (ICE) vehicle, and if so, are these higher rates justified? Can the Government do anything to mitigate this?

No answer.

Experience of using an EV

18. What are the main challenges that UK consumers face in their use of EVs?

Currently charging the vehicle. A few years ago we had range anxiety - will the car get them to where they are going? We now have charge anxiety: will they be able to connect to a charger and will it work?

19. What are the main benefits that UK consumers could realise from using an EV?

Cheaper motoring, clean air, less pollution.

20. How prepared are car dealerships, service networks, repairs and maintenance organisations, breakdown services and aftermarket suppliers to meet the growing EV uptake?

Many are not - there needs to be significant effort put into educating, training and equipping these operations for ZE vehicles, this could include:

• Mandatory licensing for vehicle technicians

• Mandatory training for all the industry

• Support for tools and equipment required

The UK motor industry must be supported by the Government during this transition, this includes education, training, awareness and more. This is especially important for first responders and emergency services that deal with incidents and accidents. We have had 120 years to understand petrol and diesel, we have had 10 years to understand lithium batteries. We will learn, but we have to be quick.

There are many organisations ready to deliver this training and awareness for the automotive repair, first responder and vehicle dismantling and recycling industry. The UK Government must incentivise training and education for all these industries.

21. How does the charging infrastructure for EVs need to develop to meet the 2030 target? Does the UK need to adopt a single charging standard (e.g., the Combined Charging System (CCS)) or is there room in the market for multiple charger types?

Enough chargers to meet demand, chargers that work! Ideally there would be a single charging standard for all vehicles, but whatever system is in place must allow ‘legacy’ vehicles that may have a different system to be charged and not become obsolete.

22. The Government recently published the draft legislation of “Public Charge Point Regulations 2023”. What assessment have you made of the draft legislation text, and what contribution will it make in ensuring the charging experience is standardised and reliable for consumers?

Great ideas and lots of good words - the true impact of any legislation is how it is enforced and if experience of other legislation over the last few years is anything to go by there will be no enforcement and will not make any difference!

23. What assessment do you make of the requirements set out in the draft legislation of “Public Charge Point Regulations 2023” for charge point operators to make data free and publicly available, and how may this improve the EV charging experience for consumers?

24. In terms of charging infrastructure, are there unique barriers facing consumers in areas of low affluence and/or multi-occupancy buildings, such as shared housing or high-rise flats? Do you consider public EV charging points to be accessible and equitable compared to home-charging points? What can be done to improve accessibility and equitability?

More on street charging must be available. Incentives given to landlords for fitment of charge points, and, as stated previously, incentives for business owners to fit charge points in staff car parks.

25. Is there a financial benefit to the consumer of choosing an EV over an ICE vehicle? Are there further benefits, aside from financial, that a consumer may gain from EV use?

Currently cheaper to run than ICE, this should be maintained. Benefits are cheaper servicing and maintenance, easier to drive, and more relaxing.

End of life disposal of EVs

26. What options are there for consumers for end-of-life management of batteries and EVs, and what impact does this have on consumer attitudes towards buying an EV?

Options for ZE’s should be the same as current options for ICE. Education of consumers is essential and currently lacking for ELV disposal.

27. What are the current regulations and responsibilities of disposal and recycling for EVs, and how effective are they? How much of the battery can be recycled from a technical standpoint, and how much of that is economically feasible?

Current legislation covers ZE vehicle dismantling at end of life. There are a number of holes in the legislation and the infrastructure though.

Lack of enforcement of ELV legislation means that significant volumes of ELV’s are going through illegal dismantling. This has been consistently reported to appropriate Government departments over many years with very little change.

There is no facility in the UK for high voltage battery recycling - this needs to change!

All vehicle recycling facilities need to be trained on how to safely handle these vehicles and the components from them

The EU has a review of ELV treatment ongoing, will this be reflected in UK legislation and how will this change the outlook?

A recent discussion I had in the USA highlighted how the Inflation Reduction Act is impacting the recovery of critical materials from ZE vehicles - the company concerned was investigating the recovery of rare earth metals from electric motors. Their research had been funded by the US government and they could end up leading the marketplace with this work - is the UK Government doing anything similar?

28. Is there a risk that the residual value of EVs may be lower than the value of the EV as a source of recoverable critical minerals, and how might this effect the flow of EVs into the second-hand market?

Possible, but if legislation with definitive dates is in place then innovation and investment will follow that will increase the recovery of critical minerals.

National and regional issues

29. What are the challenges or concerns around grid capacity in relation to significantly increased EV adoption?

Reports I hear from the industry are implying that grid capacity will not be a major issue, especially with vehicle to grid capability, solar systems with battery storage (both residential and industrial).

30. What is the role of distribution network operators in ensuring EV infrastructure can be rolled out sufficiently to meet 2030 target?

Connection to charge stations and energy storage systems are essential and must be prioritised

31. What are the requirements, challenges or opportunities for the development of public charge point delivery across the UK? How will the development of EV charging infrastructure in the UK interact with existing planning regulations?

Must be easily accessible, clean, tidy and well lit.

32. What are the issues facing rural residents, urban residents, and sub-urban residents and how do they differ?

No answer

33. What role do you see local authorities playing in the delivering the 2030 phase out target, particularly in relation to planning regulations, charge points and working with District Network Operators? How can government best support local authorities in their roles?

No answer

International perspectives

34. What are the successful approaches to the rollout and uptake of EVs in other countries, and what can the UK learn from these cases?

The Chinese government have supported their ‘NewEnergy’ industry for many years, which is why their vehicles are becoming dominant. The Inflation Reduction Act in the USA is giving funding and incentives that is enabling the US market to catch up other regions. Both of these approaches look at the whole life cycle of the vehicle - design, manufacture, sales, servicing, and end of life recycling. The UK Government must look at all of these approaches and invest in each area to develop UK research and development, manufacturing, servicing and end of life industries to become the best in the world.