Written evidence from Mr Allen Gilbey (ELV0027)



I am a private individual with over 45 years of experience as a motorist and in the motor industry encompassing everything from vehicle design to fleet and retail customer liaison.

My concern is that our elected representatives have set a vague target, with no strategy, tactics or plan to achieve the end the sale of ICE vehicles ‘by 2030’ - an ambiguous date - and allow unspecified hybrids till 2035. To this has been added some transitional forced target for yearly sales of BEV from 2024 even though the available product is in its early development.

Communication to the public, on what will be a costly exercise for them, has been abysmal especially as it is throwing away a well-honed manufacturing, servicing and fuel distribution system to one that is frankly in its infancy.

With the constant churn of elected politicians (3 prime ministers in 12 months, 5 ministerial posts already for Grant Shapps, etc. at least 1 general election by 2030, there is no consistency of approach or message demanded by this transition, which transcends numerous national and local government departments and numerous industries.

Short term thinking and sound bites based on MP job prospects, party line and next election do not fit with this transition’s needs.

Vehicle manufacturers – mainly overseas – are rapidly improving and developing their offering and building giga factories but the charging infrastructure, both home and public, needs fixing.

It all urgently need to be put in the hands of a well - qualified and authoritative ‘non political team. Think how Lord Beaverbrook and Hugh Dowding, combined with Winston Churchill ‘mobilising the English language, to provide a defensive infrastructure. Even a Dr Beeching character might help.

NHS might benefit from same approach to cut out waste in such a fragmented organisation. Sorry – I digress.

Unlike other changes – horse to coal, to steam, to petrol, to diesel, back to petrol this is an expensive and complicated mandated change with a fixed end date.

It is legislation rather than evolution.

Undoubtedly non – fossil fuelled vehicles are the future and one day petrol and diesel will be viewed as we now view coal fired steam locomotives.

However, we are at the early stages of the costly and complicated mandatory transition so it needs clear and careful handling across all sectors.

I will now attempt to answer your questions in order but there is inevitably some overlap.



Lack of a clear plan.

Shambolic lack of communication to the public. Public only see media reports which are not encouraging - cars variable but range and charge speeds improving. Charging infrastructure is awful.

Unclear targets – by 2030 could mean tomorrow or 31st December 2030. Now we hear government is wavering over targets to make them ‘pragmatic and affordable’ – Jeremy Hunt on Sunday politics shows on 3rd September 2023 related to all sorts of green issues – including heat pumps??

Fragmented charging structure needing numerous apps/RFID cards/contracts/ no clear pricing or signage especially as some are bollards below bonnet height. Compare to fossil fuel – highly visible, under cover, well lit, clearly priced, no contract of app needed, universal nozzle, accessible to vehicles with trailers/caravans, accept card or cash, usually cashier to resolve queries, minimal if any queuing.

Government subsidies come and go.

No plan to replace fuel duty or fuel VAT. Road pricing is pie in the sky stuff for this government.

No ideas on how to deal with ongoing ICE vehicles – road fund licence, fuel duties etc.

Like lemmings chasing the holy grail of BEV ignoring hydrogen or even alternative fuels that can be used as a drop in fuel for existing ICE vehicles.

Classic cars?

Battery life, replacement, used vehicle values – who will buy a 10year old Nissan Leaf or keep one as a future classic??

Vehicle cost

Vehicle range anxiety. Assume a vehicle WLTP range of 250 miles, actual is 80% of this and manufacturers recommend keep charge between 20%and 80 %. This gives a useable range of 250x80x60 = 120 miles only. Allow 80% capacity by 10 years gives just 96 miles. Believe it or not according to Autocar some new BEV only have a WLTP of less than 100 miles – you do the maths!

Unclear policies, if any on vans, HGV, buses, etc.

Government not leading by example.


2-date incentives

Manufacturers seem to have embraced the change and are rapidly developing their products almost from a standing start.

Setting false targets such as 22% in 2024 will force feed expensive underdeveloped products into hands of unsuspecting consumers. The cars of 2030 will undoubtedly be far superior in range, performance, charging speed and probably affordability.


3-national policies

No policies can be successful unless public know what they are!!!!!

Fragmented lack of coordination on public or domestic chargers. Each local authority seems to be setting its own rules which even seem to vary either side of the same road.

Near me council charge bollards have been put outside a busy chippy and in disabled bays opposite their town hall. Apart from being marked as disabled only bays they have signs saying specifically that electric and ICE vehicles can use the bays – thus BEV access usually blocked!! They need an app and no cost per KWh displayed.



For reasons given above no elected politician should be allowed anywhere near the communication process.

If you need to change behavioural policy suggest you look at House of Commons.

There must be clear, truthful, accurate, consistent, unbiased, written communication to every single householder, driving licence holder, registered vehicle keeper. Electoral language or Brexit propaganda won’t wash here. It has too much influence on everyone’s lifestyle and finances.

The overall benefit to the climate is not proven – cradle to grave including mining for the battery ingredients though to eventual recycling (which is likely to come prematurely due to battery fatigue)

Seems it was written on back of a fag packet by a long departed elected politician.

Someone also needs to come clean (pun) about where all this electricity is coming from. We hear tales of public chargers cannot get connected due to grid inadequacies and the greenwashing of Drax with subsidies to transport wood pellets across the world is a disgrace. Mind you it would help if our energy, water etc. industries weren’t controlled by overseas owners.

How can we trust elected politicians who told us to go diesel, then diesel was bad and we should go to petrol, but now petrol is bad and we must go electric with its untried technology and dubious green crededntials.


5- information accuracy

No idea – most of it is via media, or WLTP, or manufacturer marketing so take it with a pinch of salt.

Minimal public information from government – and can that be trusted anyway?

Road tests suggest ever improving vehicles and ever falling behind infrastructure.


6-environmental benefits

Unclear – is it just moving pollution from tailpipe to manufacture, mining, all the material needed for power distribution, charge cables, etc.?

Risk of people paving front gardens to access home charger point

Excess tyre, road, brake wear due to heavier vehicles

Are multi storey car parks capable of carrying weight of an all-electric car park need

Are spaces big enough for the seemingly larger electric cars

Big communication issue here.


7- cost to consumers


Increased cost of vehicle

Cost of installing home charge point (where possible) circa £1000

Loss of used vehicle value as battery comes to its end of life phase. Early scrappage.

Pace of development rendering cars obsolete more quickly

The unknown fiscal rules that will come in to cover lost fuel duty/fuel VAT


Difficulty finding public chargers

Need to keep charged – can’t do quick fill for an ‘emergency’ trip.

Slower long distance trips due to need to charge.



8-routes to aquiring EV

Similar to ICE but dealers seem to be unprepared and we have allowed the eastern Asian manufacturers to invade the market. Shades of motorcycles in 1960s and cars in general in 1970s.

Lots of new manufacturers entering market with no track record. Are they sound businesses??


9-consumer barriers


Inconsistent or non- existent information.

Lack of chargers

Fear of fire

Fear of obsolescence.

Fear of the unknown – who wants to be the guinea pig when it costs so much?

Pragmatic buyers wait till the MK2 of facelift comes out. Early versions of any new product are soon overtaken.


10-Government help

Seems to have disappeared without trace. Like most promises.


11- EV product range

Too much up market, loaded with trivia and too expensive. To an extent driven by manufacturers need to recover substantial research and development costs.

Some whacky designs and only a few have BEV and ICE versions looking similar – Vauxhall Corsa, Peugeot 2008 for example

Lower end of the market very poorly served unless you want an unknown make from far east and/or or minimal charge range.


12- L segment and personalised light vehicles

No different in transition to any other BEV?


13-second hand EV market

Crystal ball stuff this.

Depends very much on desirability, availability, remaining battery life.

Press reports vary from gloom and doom to a booming market so who knows?

Biggest issue may be how quickly todays BEV are superceded by those being developed now. ICE has had 125 plus years to get to where we are today and pace of development in power train is minimal (legislation excepted) and is now more trinkets and facelifts. BEV power train is at the beginning of the development curve.


14-leasing and the used market

As ICE a supply and demand balance

Has the tax incentives to get BEV into fleet and leasing caused an imbalance in what is going to hit the used market. It is clear fleet is taking a much higher percentage of BEV than retail.

Apart from the tax incentives the fleet driver has less interest in their vehicle which is a work tool to be disposed of in a few years with no worries about its batter y life etc.


15- supply of used BEV

First you have to sell them new. Obvious but true.

Beware of ‘early adopters’ ditching poorly performing BEV or where they have not cared for the battery – yes,traction battery care is part of the BEV experience not relevant to ICE


16-car mobility clubs

Likely to stay clear of BEV. Use/car requirements too different to ICE.

How to get it back fully charged.


17-insurance rates

Media reports suggest BEV attract higher premiums as they are more expensive, cost more to repair, not all repairers can handle them, if they do catch fire they are harder to extinguish as it is a chemical reaction, risk of putting in an integral garage, risk of combustion whilst charging, etc



18-main challenges

Range and charging



Possibly less expensive servicing

20- service and repair organisations preparedness

Supply and demand will rule but at present it’s a case of ‘catch up’. Again early adopters will be the suffering pioneers.

21-charging infrastructure

Start with the basis that, although it may not be as quick, it must be as easy to charge a BEV as top up an ICE vehicle.

With your ICE you can leave home with a near empty tank, find a readily available identifiable fuel station and fill up within minutes. Your only concern is petrol or diesel and every station offers the choice.

The current public charging set up is in disarray.

It needs:

-          Reliable chargers

-          Costs displayed

-          Visible chargers – bollard sized ones are invisible.

-          Easily located chargers

-          Accessible chargers – including for towing vehicles

-          Well lit chargers

-          Single connector type – (or every charger can charge every car type)

-          Chargers that can be paid by credit/debit card.

-          Facility to help if your contactless card decided it needs the PIN entering to pay.

-          Under cover – water and electricity don’t mix!!

-          Near rest/refreshment facilities but beware obesity due to eating whilst waiting for a charge

-          Plentiful – to avoid ‘civil unrest’ due to queue arguments

-          Provision for lots of vehicles arriving at one venue, sporting event such as British GP or Grand National, Glastonbury, etc. Plus of course holiday weekends on the motorways.

-          Clarity on various charging speeds

-          Adequate mobile network for queries. A local park has chargers that need an app but my phone (major provider) has no signal. Chocolate fireguard comes to mind.

-          Sensible parking time allowance

There also needs to be accurate information for travellers on location of public chargers. Where I live there is terrible inconsistency on the information they give and which chargers are listed. One app/website even lists chargers at a highly sensitive, highly secure, research function where the public are definitely not welcome!


22-Public Charge Point Regulations

Not studied these but as long as they cover the points covered in my submission that is a start.

Most importantly they need to be retrospective so that existing public chargers meet the latest needs – for example payment without need for app/contract/RFID.

23-Data availability

Data is vital provided it is not abused by those who trawl for it.

There must be a common database for location, cost and serviceability of every single public charging point to help drivers plan. After all you can’t carry a spare can of electricity in the boot!

24-low affluent areas

It is not just low affluent areas who will suffer from problems of difficulty in installing a home charger. Not all detached properties have off road parking.

Clearly cost is a barrier as is street/high rise etc. layout.

However, many affluent areas do not have off street parking – surely even those in the Westminster bubble can see this outside their windows!!!

And for those with ‘basement’ parking will BEV charging be allowed bearing in mind the risk of fire. Car fire far worse than an electric bike or scooter.

Amazing item on BBC recently showing thing to connect to a socket in pavement not dissimilar to Fire & Rescue connecting to fire hydrant – heavy and expensive bit of kit to lug around and pavement blocker. Not sure about its use when socket is filled with water!?

25-financial benefit to buying a BEV

Doubtful in the extreme under current situation for the reasons already stated – cost, poor resale, higher insurance, etc.


26- Options for consumer

There do not appear to be any but presumably vehicle dismantlers will be responsible as it seems replacing a dud battery is more expensive than the cars worth.

There is rhetoric about recycling but countermanded by suggestion that used BEV batteries get repurposed for power storage to support National Grid.

27- disposal and recycling regulations

Good point – needs careful regulation. Fire and toxicity risk of stored batteries.

28- value of end of life BEV intact v its constituents

Same as ICE – supply and demand will come to play.



29 Grid capacity

Immense challenges in organisation, resources and raw materials.

Reports already of public chargers installed but use delayed due to inability to connect to the grid.

Where will the electricity come from – if not 100% renewable the whole project becomes a massive waste of time, money and precious resources. Solar power, off shore or on shore wind is OK when weather plays ball, our foreign owned nuclear stations are either near end of life, in protracted build, or not even planned.

Subsidising bio mass, like Drax, is smoke and mirrors greenwashing.

So, like the magic money tree to pay for it all government needs to find a readily available electricity mine!

30-role of distribution networks in infrastructure roll out

Clearly they have a fundamental role to play in supplying and distributing the electricity. Without electricity readily available the plan, if there is one, fails.

31-public charging point delivery

Huge challenge that is off to a bad start as already described.

Needs tight regulation of public and home chargers to ensure they are safe and reliable as well as easy to access, use and pay.

Planning regulations need to be consistent across the whole country.

32-rural v urban v sub urban residents

The challenges are similar except the more rural the more difficult it is likely to be to access a charge point which is in conflict with need for more charging due to distances covered.

There is also the issue of home chargers where there are houses of multiple occupancy or multi car households. Seems only 1 charger per house allowed?

There is also some suggestion that ‘smart’ home chargers will stop charging, or even feed back to the grid during peak demand thus the car you left to charge may be flat as a pancake when you get up for work.

Not everyone works 9 to 5 so we have to cater for all.

33-local authority role

Their role is key being custodians of local planning, car parks, streets, pavements, social housing etc.

They need to be supported by clear national guidelines and some financial help from government.


34-International perspective

It is key to have international consistency and think of the less developed countries.

Currently we seem to have a VHS v Betamax standoff.

If we can agree worldwide on an AA battery, we can agree on other things surely.



This is a fiendishly expensive and complicated transition that transcends numerous government departments, agencies, suppliers, companies and of course the end user customer – who always pays.

It should be taken out of the hands of short term politicians and handled consistently and professionally by qualified senior professional individuals who will also communicate effectively and truthfully with the public.

I am happy to discuss my comments further if required.


Allen Gilbey