Written evidence from Mr Douglas Robertson (ELV0015)
Response to UK Government Call for Evidence into
“The Phasing out of ICE vehicles from 2030”
Submitted by
John Douglas Robertson
Ex. Chair and President of the EV Association Scotland
August 2023
Contents: Summary
Introduction
Possible solutions/answers to questions posed
Summary It has been impossible to answer 34 detailed questions in 3 and a half A4 pages…the 34 questions alone took 2 pages in “the Call” document, and then there were a further 5 large references to read before starting to answer even Q1. This response runs to 16 pages and I do hope somebody within the Government will read them all and respond appropriately.
The rollout of BEVs is being held back in the UK by
In order to overcome a. the Government can follow the “Norwegian Incentives” of raising ICE purchase Tax and lowering the equivalent on BEVs to create more pressure on the manufacturers to make and sell BEVs at sensible prices….the public will not buy high-priced BEVs in the UK very soon when they realise how cheap the Chinese makers can sell their products both here and around the world. Chinese BEVs will increasingly penetrate the UK BEV market this year and the Government will lose TAX from those sales.
In order to overcome b. the Government must first reduce the cost of electricity back to pre-pandemic levels in line with the fall in wholesale electricity prices and de-couple electricity prices from the price of gas. Secondly they must not allow the Bank of England to use out-dated economic measures like high bank rates to reduce inflation. These 3 measures will reduce inflation back to sensible levels and reduce wage/salary pay rise pressures and increase the market penetration of BEVs in the UK.
Lastly, the Government should act NOT to support the dubious lies and dis-information propagated in the press about BEV issues or faults. This false information does NOT support their planned BEV rollout by 2030 and merely causes BEV fear in the public mind.
Introduction and Background
I am a retired Mechanical Engineer and my last role in industry was as Project Engineer with the company Advanced Transport Systems of Bristol where I gained 10 years knowledge and experience of designing/developing the automatic electric vehicles which were installed at T5 Heathrow in 2007-2009. My duties in this role included battery and vehicle testing and I spent 3 years based at Heathrow in charge of the installation of the guideway and infrastructure.
In 2013 I bought my first Leaf24 which I ran for 26,000 carefree miles before up-grading it for the 2015 model which I still own and has done a further 45,000 carefree miles. In 2017 I bought a new Hyundai Ioniq28 which has done a further 65,000 carefree miles. Thus my family has been able to benefit from 136,000 carefree BEV miles over the past 10 years.
I joined the Electric Vehicle Association Scotland in 2013 and was their Chair from 2014 to 2017, and their President from 2018-2020 when I stepped down. The Association has a very active membership who all enjoy the benefits of owning and driving BEVs. Most owners have access to home charging but some do NOT and they have to rely on the Public Charging Network which has seen remarkable improvements in access and reliability over the past 10 years. But it still requires upgrades and improvements which I will try to detail later in this submission.
My family benefits from a domestic solar installation which further assists in lowering our BEV costs, and I am looking at the possible installation a “battery storage system” to further maximise our solar output.
Possible Solutions/Answers to questions posed
The UK ticket prices of BEVs have risen more than 100% in the period 2017-2023…my Ioniq28 cost £23k and now for the same vehicle effectively I would need to spend twice that amount. Battery costs in the same period have dropped from $300/kWh to under $90/kWh thus it would seem reasonable to suggest that the total cost of producing a BEV should now be significantly less than the equivalent ICE vehicle….yet BEV prices are probably 50% more expensive in the UK than ICE equivalents.
This is against a background of Chinese BEV prices (for all brands both Chinese domestic manufacturers, and foreign manufacturers like Tesla, VW etc.) reducing their prices not just in China but throughout the Asian region. These BEVs are not being sold at a loss so why can manufacturers like BYD sell its Atos3 in Australia, New Zealand and other Asian countries for £20k equivalent yet they are retailing in the UK for £36k+???
If the EU and US manufacturers do NOT meet these very competitive Chinese BEV prices within the next few months, then the Public will have no option than to buy the Chinese products at the expense of the other manufacturers who will see their market share drop dramatically with a associated drop in local employment. The Chinese have around 80% of the world’s battery production capacity and their BEV market excellent penetration means they have sold roughly 60-65% of all the world’s BEV sales to-date.
So what steps can the UK Government take to improve the take-up of BEVs when manufacturers are expecting unrealistically high ticket prices?
Well they have tried grants to buy BEVs, and all that seemed to happen was this was added to the ticket price…so clearly that does NOT work.
There was a “scrappage scheme” of £3000 for over 10 year old ICE vehicles and that had a limited effect.
There is an EU wide “Emissions Fine” system which effectively fines manufacturers if their total fleet sales’ emissions exceed 95gm/km. and this has added cost to manufacturers making and selling ICE vehicles…in some cases these amount to Euro Billons per year. But it would seem that BEV buyers are in effect paying these fines through their higher ticket prices….so maybe that has had a limited effect on the manufacturers overall profit margins.
So what is needed is some method of “incentivising manufacturers to concentrate their efforts to increase their production of BEVs”….and thus reduce their ticket prices to enhance their market share.
If manufacturers find they have to reduce their BEV ticket prices in the UK because of the aggressive Chinese BEV prices that in itself should be a strong incentive but perhaps the “Norwegian Solution” will further enhance the BEV uptake.
b. The high cost of electricity and thus the running costs of BEVs
The ridiculously high electricity prices caused by the “so-called energy crisis” has acted as a total dis-incentive for the UK public to buy BEVs.
The OfGen fixed energy prices especially for those suppliers claiming to be selling 100% renewable energy is far too high. Renewable energy like wind and solar is estimated to cost around 3 to 6p./kWh to produce, thus adding a further 3-6p./kWh for distribution and a profit margin of even 20% brings the cost to the public up to 8 to 15p./kWh and NOT the 30p./kWh being charged to home owners, and certainly NOT the 60-80p./kWh being charged at public chargers.
Currently home owners pay VAT at 5% on their home electricity costs whilst I understand that VAT is applied at 20% on public chargers….so here is a clear way forward for the UK Government to reduce BEV owners running costs.
In addition, OfGen needs to address the fixed electricity prices going forward in line with “Wholesale Electricity Costs” which have now returned to pre-2022 levels. Energy company profits for 2022 have soared compared with those for previous years and this has been caused solely by OfGen’s highly-elevated “Fixed Prices”.
Fuel-Poverty in the UK is estimated by various agencies to have doubled amongst pensioners last year and it is solely in the hands of the UK Government to fix that situation.
The artificially-high cost of energy in the UK has been the main driver of inflation and added to the self-inflicted “cost-of-living” crisis with its attendant pressures on salaries/wages.
The UK Public deserve better and the UK Government should act to implement these changes to the benefit of all living in the UK and this should enable the 2030-35 dates to be achieved easily.
2. Do the 2030-2035 phase-out dates serve their purpose to incentives the EV market in the UK?
These dates must achieve their desired goals and focus the minds of those in charge of car manufacturing not only in the UK but the EU.
Those manufacturers who do NOT take advantage of the benefit of higher margins from the lower production costs of BEVs over ICE vehicles will NOT survive the Chinese onslaught which is likely to hit the UK, EU, and US markets like a Tsunami wave very very soon.
A recent German report (see link below) clearly shows the necessity for the German manufacturers to reduce their ticket prices, and that should be a warning to all other manufacturers about the price-war from Chinese makers.
If the UK Public starts buying Chinese BEVs en masse soon, that may concentrate the minds of those in charge of domestic and EU car production; but that merely reinforces the Chinese BEV market dominance, and makes it more difficult for domestic manufacturers to compete in the future.
Thus some sort of federal UK policy along the lines of the US policy which requires local production of both batteries and BEVs may well be needed to ensure domestic producers “wake up and smell the roses” and not provide totally mis-leading hurdles in the Press to BEV adoption…BEVs cause excessive brake dust, tyre wear, and potholes to name a few!!!
Currently, as you will see from my thoughts above, the manufacturers do NOT seem to be taking advantage of lower production costs for BEVs in order to set fair lower BEV ticket prices which will enhance BEV uptake viz a viz ICE vehicles.
UK Government intervention is urgently needed to address the effects of the Chinese BEV onslaught by dis-incentising the UK Public from buying Chinese BEVs in favour of those from other non-Chinese companies.
For answers to questions 3 and 4 see above.
5. What is your view on the accuracy of the information in the public domain relating to EVs and their usage?
As you will see from my comments in response to Q.2 above, I believe there is a lot of mis-information (or indeed Dis-Information) in some sectors of the UK Press about “hurdles to BEV adoption” in the UK.
I encounter these “false issues” of BEV ownership and usage daily in my travels around Scotland. Some issues are indeed correctly reported as I have detailed in my answers to Q1. and the solutions to these are in the hands of the UK Government.
However the following perceived issues are a Total Nonsense and the Press should be encouraged not to speculate on these:-
a. BEVs cause excessive brake dust:
BEV owners knowingly or otherwise can use regenerative braking of their vehicles to feed energy back into their batteries and thus save their mechanical brakes and lower associated brake dust dispersion. My own experience shows that poor quality of brake discs and pads on certain BEV models and the lack of the use of mechanical brakes can lead to excessive disc corrosion and the need for their replacement. Higher quality discs do not experience this issue and the brake discs and pads should last a lot long on BEVs than on the same size of ICE vehicles.
BEV vehicle travel considerably further per kWh of battery capacity by using this feature thus it is in the owner’s interests to use regen braking whenever possible.
b. BEVs cause excess tyre wear:
BEV owners with correctly aligned tyres should experience less tyre wear because of the use of more gentle regen braking and more progressive acceleration from the electric motor…less tyre spin on take-off.
It is often claimed that BEVs are far heavier than the equivalent ICE vehicle, and this is just total rubbish…..modern battery vehicles are virtually the same weight as their ICE counterparts….and tyre wear is very little to d with vehicle weight and considerably more to do with wheel spinning and braking.
c. BEVs cause more potholes:
Absolutely NOT the case….axle loads for BEVs and ICEs weighing even 2tonnes are roughly 1T per axle, whilst Truck and Bus axle loads can be 4 to 6 times this level….so they are the main contributors to potholes.
d. BEVs take too long to charge:
Those with a home or workplace charger can charge either whilst asleep or whilst working.
Those without a home charger need to use the Public Charging Network and this can indeed be problematic in certain cases i.e. unavailable or unreliable or slow.
Using the main route Public Charging Network has improved greatly in the past 10 years but still needs more investment and thought for the user….more below.
A charging time of around 20-30 mins. on a motorway is just sufficient to access nearby cafes and toilets and it should not need to be the case that a BEV needs to charge in less time for convenience thus requiring very high-powered chargers with capacities greater than say 50-70kW with all their attendant power supply issues.
For town or city flat owners without the possibility of home or workplace charging, perhaps the “Norwegian model” again could be adopted in the UK whereby any mult-storey carpark could have simple 13A sockets at every parking space thereby offering users the chance to park and charge their BEVs say overnight.
e. BEVs range is too limited:
Most daily car trips in the UK are less than 20 miles so easily made with a BEV with relatively small (under 40kWh) battery pack….the larger the battery pack the heavier the BEV which in itself limits the BEV range in total….see d. above for those in flats whose weekly charge should provide 1 week’s BEV usage.
For BEV motorway/cross-country trips, a range of 140-150 miles should be possible within 2-2.5 hours after which a “comfort stop” is usually necessary and advisable….a 40kWh pack should be able to manage these trips.
f. BEVs catch fire easily:
This is total nonsense put about by un-informed Press. A BEV has a 1/10 chance of catching fire in use compared to an ICE vehicle…see quote below
Dirk Uwe Sauer : Safety is of the utmost importance for vehicle manufacturers. The statistics show that the number of vehicle fires per million kilometers traveled is at least a factor of 10 lower for electric vehicles than for conventional vehicles.
In an interview shown in Germany in the following link
Several very early model US BEVs exhibited fire hazards when operated in the high summer temperatures experienced in their sunnier states like California and Arizona, but this issue has been corrected by better “battery cooling” and “battery management systems”. Although some Chinese models appear to be still showing slight signs of these incidents but no where near as often as ICE vehicles worldwide.
f. BEVs use rare earth metals etc. and cause pollution:
Current battery technologies do require the mining of the above but developments in the use of sodium, silicone, and solid-state batteries which will all come to market in the near future will reduce greatly the need (if not eradicate) such activities and their attendant pollutions.
It should be noted that the mining of any materials causes pollution and that includes the mining of iron ore to make all manner of ICE drivetrain units such as engines, gearboxes, and exhausts and this mining can NOT be designed out of such a drivetrain.
g. BEV production causes the release of climate change gases:
It is often stated in some Press quarters that this is the case, and indeed, nothing is made by man which does NOT cause the emission of these gases. However, the benefit from a BEV’s usage instead of an ICE vehicle is that during its lifetime the production process gas emissions can be offset by the zero tailpipe emissions which can NOT be said for ICE vehicle usage. Whilst this breakeven point is reached at different stages in the life of a BEV depending entirely on the size of its battery…the smaller the battery the quicker this breakeven point is achieved. For example, a BEV with a 40kWh battery pack should reach this point in under 1500-2000 miles of usage (i.e. a few months and not years as has been seen in the Press).
BEVs have no required oil nor oil filter changes, nor gearbox, nor exhaust changes all of which generate more climate change gases during the lifetime of the ICE vehicle.
BEV do NOT produce any nitrous oxide emissions nor carbon particles which are present in the tailpipe emissions of ICE vehicles and these have been shown to cause serious human health issues.
6. Overall environmental benefits from achieving 2030-35 targets?
Many existing reports from across the world have shown these benefits much better than I can present here.
It is safe to say that the world will be a worse place to live as a human being or any other mammal or insect if the environmental effects of burning fossil fuels is not curtailed by these dates.
7. Likely costs to consumers as a result of the 2030-35 phasing out of ICEs, fluctuations in the cost of electricity, and changes in road taxes and introduction of low emission zones?
If the UK Government really wants to address these issues then they need to take on-board the main issues around BEV adoption/market penetration as suggested in my answers to Q 1 to 5 above.
Regarding fluctuations to the cost of electricity, BEVs can help the grid by providing “Peak Electricity Demand Loping” if V2H and V2G are encouraged in the public domain. Just imagine the benefits of 1 million BEV users providing say 10kWh of battery storage to the national grid each peak period around 5 to 7pm. ...that is enough to offset the peak demand of 2 million homes and could be provided at a fraction of the cost of building grid-based battery storage. The Government should provide households with home charger facilities with cheap loans to buy 2-way bi-directional smart chargers instead of wasting public funds on grants for Heat Pumps whose efficiency drops off dramatically when the user needs them in cold temperatures below say 5 deg.C.
Currently road tax is applied to ICE vehicles only but the Government has indicated that by April 2025 all BEVs registered before 1 April 2017 will be road taxed at the equivalent rates for ICE vehicles. This clearly does NOT look like an incentive to buy a BEV and shows that little thought has gone into that process. Perhaps the UK Government should look at the VAT they currently charge BEV home chargers and BEV Public Charging Network users at 5 and 20% respectively, and add that considerable amount into their Tax calculations e.g. a Home Charger BEV user doing 10,000 miles per year is already paying £37.50 per year in VAT, and if only Public Charging is used this increases to £150. Plus the health costs to the UK national health service from preventable hospital and doctors appointments due to the unhealthy emissions from ICE vehicles…some say this equates to nearly £100 per UK resident per year or a further £6 Billion per year see link below:
So-called “Low Emission Zones” (LEZs) which should in my opinion be classed as “Zero Emission Zones” (ZEZs) are set up in the densely populated areas of mainly our large cities and towns where typically the high percentage of the population is on lower incomes who can NOT afford a BEV nor even a cheap ICE car, nor expensive private medicine or health care. Thus they need the Government’s help more than the over-paid who tend to drive highly polluting ICE SUVs or very expensive BEVs. BEV Public transport is probably the only solution in these areas, and the Government is trying very hard through the “Electric Bus Initiative” to increase the adoption of these eco-friendly forms of above ground public transport.
8. Main routes for acquiring an EV?
I bought my first Leaf Acenta model in 2013 through a Nissan PCP, and closed that after 2 years to up-grade to the 2015 Leaf24 Tekna on a 3 year PCP; at the period end Nissan offer me a 0% loan payable over 4 years to buy that car outright and it is now fully owned by me.
Our ex-demo Hyundai Ioniq28 was bought through the Scottish Government’s BEV loan scheme at 0% over 6 years and it completes in October 2023.
I have been looking at replacing my Ioniq with a longer range BEV but because the ticket prices for a sensible 40-50kWh BEV are now around £36-40k. and the Scottish Government 0% loan scheme is limited to second hand BEVs with a limit of £30k and over only 5 years now, I can NOT find such a vehicle which is not made in China…thus I’m at a loss to make this switch…..maybe I will overcome my fears and buy a Chinese product???
The manufacturer sales options are either PCPs or Hire Contracts or Lease Deals and there are benefits (and drawbacks) to each of these purchase plans as far as the buyer is concerned. PCPs should be the cheapest option for the buyer but manufacturers tend to vary the Ts and Cs to their own advantage depending on the supply and demand in the market at that period of the year. Lease Deals appear to be heavily front-loaded in the favour of the credit companies and are very expensive for the buyer in terms of cost per mile.
The easiest purchase option for the buyer is the Government 0% Loan scheme. However limiting it to used BEVs does not seem sensible if the overall objective is to increase BEV market penetration….it should be realised that incentivising only used BEVs does NOT increase the total BEV market whilst incentivising both new and used BEVs does increase the total market. The idea of a loan limit on the Purchase Price of say £30k does seem to make sense in that it will make the salesman’s job easier if the Purchase Price is lower than this limit and may have some sway with the manufacturers who will try to increase their product selling prices in order to increase their profit margins.
Market forces may well help reduce BEV ticket prices so that these loan limits could be reduced in the near future.
9. Main consumer barriers to acquiring an EV?
These questions are answered in Q1 above. i.e. High BEV Purchase Cost and the Unrealistically high cost of electricity in the UK.
The UK Government can easily fix these issues and the BEV market will expand exponentially, hopefully with UK manufacturers leading the charge.
10. Government help to buy EVs? - Again this is covered above.
11. Range of EVs in the UK? Why is the UK market not seeing low cost EVs?
The range of BEVs available in the UK has increased dramatically over recent years but they are typically larger SUV type vehicles and not lower-profile saloon vehicles which are more energy efficient and thus cheaper to run, and in addition could cover the same range with a much smaller battery.
Thus the Public demand is being controlled by the manufacturers who clearly see higher margins in SUV type vehicles ….. why sell a 40-50kWh vehicle at £20 to 30k when you can sell a 70-80kWh vehicle at £40 to 60k and double your profit???
The Chinese BEV market has seen a lot of “Price-Cutting” recently and even at lower ticket prices some BEVs have not been selling as the manufacturers predicted….these units can not be shipped to the UK in LHD configuration and there may be some specification differences which might not allow them being sold in LHD EU markets. But The Chinese manufacturers are now 5-6 years ahead of the EU and US manufacturers who are all scrambling to do deals with Chinese firms for battery packs and indeed complete EV chassis. The Chinese manufacturers are now viewing the UK and EU, and US markets in their next phase of BEV domination…as indicated above, they currently have 80% of the world’s battery making capacity and nearly 60% of all BEVs sold worldwide.
12. What is the future role of L-segment vehicles and how will that impact car ownership?
By L-segment I take this to mean 2 and 3 wheeled light electric vehicles, and these are not really readily available in the UK.
In China and other parts of Asia where the public is more used to these vehicles their uptake has been incredible and I believe the market penetration is around 45-50%. I’m not sure the British public will accept moving away from their 4-wheel cars any time soon. The Citroen Ami is currently the only vehicle in that category.
Certainly smaller cheaper 4-wheeled BEVs will sell well as town personal transport if their ticket prices were around those found in China today i.e. £6-8k.
13. Current second-hand BEV market and its development between now and 2030?
The demand for all forms of personal transport has been reduced by the UK Government’s austerity measures like increasing Bank Rate and allowing exceptionally high energy prices which are the two main drivers of the so-called “cost-of-living crisis”. Keynesian economic theories and “trickle-down” economics have been proven since 2008-9 not to work without the un-intended serious consequences of higher wage demands which further escalate inflation. Therefore without the Government controlling the energy costs and financial costs on behalf of the UK pubic…..then demand across the second-hand BEV and other markets will continue to be low with attendant lower prices.
If the UK continues its downward path to less manufacturing in the economy and more reliance on “Financial Services” and “Retail” to improve our economic outlook then our “balance of payments” will be increased and more manufactured products will have to be imported thus further depressing the economy.
The UK Government can sort these issues of high energy and bank costs at a stroke…if it really wanted to???
14. EV leasing and the second-hand market and their relationship?
Clearly if more people could afford to lease BEVs then when these vehicles came “off lease” that would increase the second-hand market volume. However, leasing costs are affected by the artificially high UK bank rate and if the public does the sums properly, then they would see just how much their leased BEVs were costing them per mile…..I estimate my per mile cost of a new Ioniq28 equivalent would be around 70-90p./mile verses my bought-out cost of around 25p./mile so clearly a non-starter.
The car manufacturers use the PCP, leasing and other purchase offers to control the demand in the market. Currently BEV offers are far less attractive than ICE ones with the former heavily “front-loaded” which indicates their desire to have the customer/buyer accept the greatest market risk in the short to medium term (presumably because the UK, EU and US manufacturers fear the impending Chinese onslaught in their markets). ICE options still can be had at much more favourable deposits and rates. This indicates the true strategy of the manufacturers to promote and sell ICE vehicles in lieu of BEVs.
Again the UK Government could reduce energy costs and bank rates to improve both the new and second-hand sales of BEVs over ICE vehicles if they so wished…see answers to Q1 and 2 above.
15. Barriers to achieving sufficient supply of second-hand EVs? -See answers to Q13 and 14 above.
16. Role of car clubs and micro-mobility and their opportunities?
Car clubs can be an effective transport solution mainly for urban environments but tend to be less effective for those living in rural low density areas.
Micro-mobility (I presume E-Scooters and E-Bikes) again can work in the urban areas but they need to be better regulated (use of bike lanes and fixed dropoff /charging points to reduce dangerous inappropriate abandonment).
17. Higher rates of insurance for EVs are these justified?
Our own experience with 3 BEVs is that their insurance costs are marginally lower than our previous ICE cars. However insurers set their premiums based on many different factors like e.g. cost of vehicle, cost of repair, location, type of use and mileage per year, and cost of finance, so obviously an over-priced BEV will attract a higher premium than the same specification of ICE. Manufacturers are again charging much higher costs for BEV replaceable items such as bearings, suspension parts and even brake parts than the equivalent ICE parts…presumably to offset the lower service costs for a BEV viz a viz an ICE – BEVs have no oil/oil changes, no filter nor exhaust replacements and general have much fewer moving/rotating parts which can wear out than an ICE.
18. The main challenges for EV users?
Although the Public Charging Network has improved dramatically in recent years, it has failed to keep up with the increased demand from the many more users now seeking on-trip charging….Sales of BEV vehicles are estimated to be up by around 80-90% in 2023 verses the same period in 2022.
It is not “rocket-science” to understand the true requirements for the locations for this Network, namely the following 9 are the main ones:-
In addition to the longer trip charging there is the requirements for the adequate provision of both local rapid charging “hubs” and off-street (Multi Storey Carparks) with slow/overnight 13A sockets as the Norwegians enjoy should be rolled out in major UK cities and towns to provide sensible charging options for users without the possibility of home or workplace charging.
The longer range of modern BEVs has reduced the number of rapid chargers required per BEV sale but the incredible increase in uptake has overtaken this reduction. This has resulted in fairly long queues forming at some major charger locations around the UK.
19. BEV benefits to UK users?
The main benefits can be listed as follows:-
20. Preparedness of dealerships, service networks etc.?
The major dealerships and service networks are trying to gear-up to meet the growing BEV uptake, but gaps do exist and some BEV sales personnel show a reluctance to sell BEVs, whilst others appear “ill-informed” as to the benefits etc.
The relatively low incidence of requiring a “breakdown service” for a BEV (never been experienced by my family despite 136,000 miles of BEV experience) means I have no personal experience to offer here. However, I’m told that the Fire and Rescue Service and the “breakdown service” have all been trained to deal with incidences such as breakdowns, accidents and fires….see note in Q5 above.
21. Charging Infrastructure development etc.?
The majority of this is answered in Q18 above.
Multiple charger types are really an annoying part of BEV ownership. The orginal standard plugs and sockets were the Japanese standard Chademo DC as seen on Nissan Leafs. Then the EU decided (mainly the German manufacturers) that the CCS DC system had more advantages, and now the US is claiming their own standard (plus any other worldwide manufacturers who wish to sell into their market) and all BEVs sold there and in Canada will have to have the “Tesla style” North American Charging Standard (NACS) DC connectors and plugs. However, Tesla is still adopting the CCS system for its cars sold in the EU and UK…for the time being. The French also threw a spanner in the works with AC charging on their BEVs. This has meant that any UK charger installation has 2 or even 3 types of plug and socket with DC and AC charging available.
It makes complete sense to have a standard worldwide system/standard which would in theory reduce the manufacturers’ costs and thus the BEV ticket prices around the world….ICE vehicles went through this “teething process” which has meant finally worldwide standards for both petrol and diesel vehicles.
Perhaps there will be a similar movement eventually in the BEV field but a “half-way” house for the UK would be to follow the EU/German CCS route which is what I believe Nissan are doing with their newer products.
Currently there is a movement towards a CCS DC standard across EU sales and this perhaps is the way forward until a worldwide standard can be agreed. Recently some of the German manufacturers have agreed to the US standard for US sales…but are maintaining the CCS standard for other markets.
The current UK position is given below by The Sunday Times report of 6 June 2023:-
“Europe adopted an AC charging system called Type 2 and the standard for DC rapid charging is now the Combined Charging System (CCS), which effectively adds DC pins to the Type 2 plug, though Chademo can also be found as that was the rapid charging system introduced with the groundbreaking Nissan Leaf when it first launched in 2010. In the UK there remain 6,418 legacy Chademo connectors, according to Zap-Map.
However, CCS chargers offer higher charging speeds and so now dominate new installations, with 7,650 online as of the end of May 2023.
The European CCS Combo 2 standard has even been adopted by Tesla on the continent, which adds further clarity for buyers and car makers.”
Rapid charger type | UK chargers | Share |
|---|---|---|
CCS (up to 350kW) | 7,650 | 49% |
Chademo (50kW) | 6,418 | 41% |
Tesla Supercharger (pre-2019 Type 2, up to 120kW) | 434 | 3% |
Tesla v3/ v4 CCS (up to 250kW) | 1,011 | 7% |
Source: Zap-Map, data up to end of May 2023
This table does not show the French AC system plugs which are also available on some UK “rapid units” and can supply power up to peak of 43kW I believe.
22. UK Government draft legislation 2023?
A brief read of this proposal suggests the following:-
If a unit is “unavailable” say for regular routine maintenance then that should NOT be taken into account in any reliability assessment. If it is “unavailable” due to blocking by either another BEV or ICE” car again the remedy is in the hands of the operator. Any other “unavailable” factors should be noted as well. Clearly as written it would be very easy for any operator to meet this 99% reliability level e.g. the unit is available say 60% of the time and it works correctly every time it is used then that can be calculated as 100% reliable. Thus perhaps the text should read along the lines of the following:-
Reliability and Availability
7.—(1) A charge point operator must, one year from the date on which these Regulations come into force, ensure that its network of rapid and other charge points complies with the reliability and availability requirements set out in paragraph (2).
(2) The reliability requirement is that the network of rapid and other charge points is, on average, reliable for 99% of the time during each calendar year when the unit is deemed 100% available..
(2a.) The availability of the network of rapid and other charge points, on average, should exceed 90% thus providing a 10% allowance for the planned routine maintenance for each unit and any other downtime events outwith the control of the operator such as Force Majeure i.e. lightning strikes and/or DNO events and/or accidental damage.
No unavailability allowance shall be given for
2c. Blocked Chargers (either by BEVs or ICE vehicles) which should be the responsibility of the operator to mitigate against using applied penalty notices/over-stay charges or
2d. Inoperable, unknown, or out of order causes.
This would require the re-writing of the following sections as shown below:-
(3) A rapid charge point is considered to be reliable for the purposes of calculating compliance with the reliability requirement where it is only either (a) working at it’s planned performance/power output and as indicated by an EVSE object status of—
(i)available; (ii)charging; or (iii)reserved; or
(b)ineligible for measurement, indicated by an EVSE object status of—(i)unknown; or(ii)blocked. Not now required
(4) A rapid charge point is not considered to be reliable for the purposes of calculating compliance with the reliability requirement where it is not working, indicated by an EVSE object status of—(a)inoperative; or(b)out of order. Not now required as covered by 2d. above
(5) Where a rapid charge point can be accessed only during specific hours, reliability and availability is to be assessed only by reference to those hours.
(6) The charge point operator must publish information every Month on its compliance with the reliability and availability requirements on its website for each charger unit under its control.
What every user would like to see is sufficient coverage across the UK of a “Hub” system of mix-power charger units offering a range of charge-time options along with clean safe accessible areas for “comfort breaks” and “rest and food breaks” where the wait time for access to a suitable unit is less than 3-5 minutes and the area is well-lit and covered by canopies to provide weather-protection. This is probably ICE users requirements and their current experience.
23. Free and Publicly available data:
If a suitable monthly report can be drawn up for each charger unit under the management of each operator is available on its website within 1 month of its previous month end, then this should be acceptable to most users.
The advent of “billing” for charge periods should concentrate the minds of operator management because if the units are unavailable and unreliable then their revenues will be reduced.
24. Barriers for those with no “home” or “workplace” charging?
This has been covered to some extent elsewhere in my response…see q.18 above re. “Norwegian model” with lower levels in MSCP spaces each with 13A socket for safe overnight charging. Thus providing low-cost charging solutions.
In urban areas, more “rapid charging hubs” could help these categories of user as will the more widespread roll-out of “workplace” chargers again which could be simple 13A sockets in addition to more powerful say 7 to 50kW units.
Obviously access to a “home” or indeed a “workplace” unit is likely to be easier than access to a national public charger but no user should have to wait longer than 3-5 minutes to gain access to a reliable unit.
Low-cost loans for “workplace” chargers could be a great incentive for not only that category of location but could be useful for schools (and other educational establishments), restaurants and hotels, guest houses and bed and breakfast accommodations.
25. Financial benefits of EV ownership?
If the extremely high and unjustified UK BEV ticket prices can be reduced down to around those now prevalent in China, Asia, Australia and New Zealand then there are considerable cost savings in the lifetime cost of ownership of a BEV over an ICE vehicle. Depending on the vehicle specification and usage this could reduce ICE lifetime costs from around 80-90p./mile down to 25-40p./mile for a BEV…so a typical 10,000mile per year user could save £5,000 to 5,500 per year.
However, the current high ticket prices mean savings are only around £1000 to 1500 per year on a 10,000mile basis….with the difference lining the pockets of the BEV manufacturers and dealerships.
Other benefits of BEV ownership are described in Q19 above.
BEV owners with “home-charging facilities” should soon be able to benefit from 2-way chargers being available to reduce their home energy costs by offsetting peak billing time usage with lower cost night-rate based usage. Home battery storage owners can do the same but that means the owner is not using one of his BEV’s advantages over an ICE vehicle.
26. End-of-life management of batteries and EV?
Clearly if a BEV owner’s vehicle battery state-of-charge reduces below say a 70% level when fully-charged then the vehicle’s range could well be reduced by 30% and the owner could in theory remove the battery (or better still) use a 2-way charger unit to enable his/her home to be powered by his vehicle.
Currently with little degradation in batteries and little market penetration by 2-way chargers this is unrealistic. Thus it should not form any part of a new owners buying options. However an ICE vehicle can NOT provide this function without considerable technical knowledge and application.
27. Disposal and recycling of EVs? – No comment
28. EV residual values?
It is very unlikely that this scenario will be seen in the future due to the reduced use of “more exotic” materials like cobalt and nickel in the more modern battery chemistries of Lithium Iron Phosphate and Sodium Ion.
29. Regional Grid capacity?
The advent of very high-powered charger units (say those above a rating of 50-70kW) do put a strain on local grid capacities. However, operators are alleviating this situation by employing local “battery-storage” at these sites to enable lower average power demand and utilising the available excess “off-peak” capacity.
Whilst the majority of BEV charging continues to be done at “off-peak” times it should be possible to accommodate most of the BEV future demand especially if the current excess “night capacity” is used…thus there is ABSOLUTELY no need for 10 more Nuclear Power Plants across the UK as envisioned by the UK Government. Nuclear power is dangerous and very expensive when compared with Renewables energies like wind, solar and tidal.
Many subsea connectors are either planned or under-construction to bring the excess wind and solar outputs from Scotland down to England, and these plus the continental connectors provide a sensible and much cheaper method of Grid enhancement than building very expensive nuclear plants which will cost 2-3 times as much if proper “after-life” costing is applied.
30. DNO role to meet 2030?
Investment grants and loans I believe are available to encourage the deployment of the enhanced infrastructure needed to meet the move to net-zero. The move away from coal, gas and oil domestic industrial and commercial usage onto the electrical grid far outway the demands for running BEVs whose charging periods can be timed to make use of the 4GW current excess “off-peak” grid capacity.
Putting this into context means that the investments in grid enhancement required in order to move to “net-zero” can NOT be blamed on the role-out of more BEVs at ALL. In fact the use of BEV battery-storage reduces these investments which a feature that ICE vehicles usage can NOT claim.
31. Requirements, challenges, opportunities for the development of public charger network?
No comment on existing planning regulations.
Opportunities to use the public charger network with associated “battery-storage” are detailed above i.e. “peak-lopping” and use of excess “off-peak” grid capacity by charging BEVs “off-peak”.
32. Issues facing rural, urban, and sub-urban residents?
These are covered in my answers above. Clearly the “Norwegian” measures to provide simple, cheap charging facilities in urban areas are successful.
33. Government support to local authorities?
Again these are covered above. More accurate informed advice (from users not manufacturers) should provide LAs with the information they need to roll out a local charging network and more financial support from central Government.
34. Other countries successes in the rollout of EVs?
Again this is covered above…..follow the Norwegian ideas and achieve a 90% BEV penetration within a few years and well before 2030.
Do not trust the vehicle manufacturers to do it voluntarily because they have too much invested in ICE development and production facilities. The latter can be easily transformed to make BEVs with a little Government support based on them achieving fixed agreed milestones in their roll-out plan.
Response to UK Govt. call for evidence on 2030-35 ICE sales ban Page 19