Written evidence from the Electric Vehicle Association Scotland (ELV0039)


  1. The Association believe that there are numerous obstacles to the 2030 and 2035 phase out dates. Some key issues that we are particularly concerned with include: The inconsistent rollout of public EV charging across the regions of the countries of the UK.  Rural areas in particular are poorly served by the commercially driven approach; The whole approach likely leading to a class division around income and home ownership.  Those with off-street private parking have a significant advantage and are more likely to transition to EV while those who do not are impeded and will also be those who suffer most from the consequences of a transition that they are challenged in making; The focus of the majority of commercial charge point providers in the lucrative DC/#JourneyCharging market.  It is left to a few forward-thinking companies and local authorities to ensure that an equitable transition is possible; The continued focus on the car being the answer, when a more defined, coherent approach including the growth of all public transport and active travel is required, including Mobility as a Service.  Reducing the number of vehicles required will simplify and ease the 2030 and 2035 phase out dates.  The lack of a developed strategy for the roll out of infrastructure across the UK trunk road network is a major challenge.  The approach taken by our sister organisations the EU supporting the concept of nationally defined charging pools along major routes isa simple effective means to ensure all travel is enabled, including the development of freight as an EV transport.


  1. The view of the Association is that these dates are serving to focus the UK market, in conjunction with the larger market in Europe seeing similar targets.  From our viewpoint it is difficult to determine the extent of that focus, but we recognise that consumer confidence and demand is playing a significant part of this.  We do not have the qualification to make a definitive statement on the UK supply chain, but it is clear that there are currently issues in both vehicle, infrastructure and network connection streams.  A strong plan with key dates, timescales and mandated targets is essential to ensure a fully inclusive and affordable transition.  This need to ensure coordination between all parties, a role that would need to be led by the four governments in partnership.


  1. The Scottish Government approach with EV loans, particularly for second hand EVs have been particularly effective, enabling affordable uptake for those on lower incomes.  Similarly, the original support for charging infrastructure, both private and public has offered a broad network for charging.  Seeing this continued specifically to support all rural areas in the four nations of the UK in essential. Current policies and initiatives are not fit for purpose as they offer little in the way of targeted outcomes.


  1. The need for a fuller understanding of the NEED for a transition to cleaner transport is glaring.  A misinformed public will always take the apparently easier route.  Recent events have seen the policy position weakened by counterproductive rhetoric around difficult, necessary policies that are on the surface politically decisive.  Bravery and consistency is a requirement in pursuit of an improved life for all.  It would be beneficial if environment ceases to be a political punch bag for minor gain.  There are many effective voices in the EV world that would benefit from amplification through government. This is where the clearer communication should come from.  Misinformation is rife, with questionable funding. 


  1. Across the public domain there are many competing voices, with most of the loudest using platforms with significant backing and funding.  The facts are often disputed, but not with data or detail but with misinformation and weak anecdote.  The public need to be directed to a clear source of data, presented in simple, understandable and above all verifiable form. It remains disconcerting to read both in professional forums and the various media outlets, blatant untruths and misrepresentation on the broader EV supply chain and EV experience.



  1. These are explained in depth across many articles.  Cleaner air (urban and generally), lower costs for energy, greater autonomy in the energy market by means of dispatchable demand reducing the need for CO2 emitting peaker plants, lower cost of vehicle ownership, lower costs for public transport, reduced healthcare costs due to reduction in particulates and emissions, reduced emissions due to reduced road wear and replacement cycles (no oil/fuel spills significantly lower the number of potholes and road repairs).  Reduced need for cleaning and repairing buildings as the level of corrosive pollutant drops. This list cannot be exhaustive.


  1. At present consumers face a twofold change in cost.  Current EVs are more expensive than their ICE equivalent. This is changing, and savvy consumers understand that the Total Cost of Ownership for many is significantly lower.  Along with the purchase of the EV, the cost of charging infrastructure, either at home, or used in public are significant costs.  The most apparent cost barrier is in the perception and market skew in favour of high-power DC charging.  This inevitably is a premium product and makes EV ownership more expensive. Although these costs are driven by the electricity market, the shift in cost is comparable to the shift in costs for home charging, while the investment cost is a more stable aspect. Current proposed changes in Road Fund Licence are off-putting and not balanced with the broader policy aims.  If RFL for a hybrid is lower than for an EV, then something is significantly incorrect.  We do not recognise the broad statement that EV’s contribute less to the economy through tax, as we recognise that they also reduce the cost to taxpayer for roads and healthcare.  This is a complex dataset to model, with many variables less clear than would be ideally know.  However, in conjunction with policies to promote public and active travel, the overall benefit to the economy and reduction in cost burden, should significantly offset the loss of revenue from fuel duty and RFL. 


  1. While politically unpopular, the development of an intelligent form of road pricing would be worth of further development.  Such a pricing scheme would require a balanced approach, as the need to ensure that rural communities in particular are not adversely impacted by the change.  Such road pricing should also recognise the use of zero emission public transport and minimise or eliminate the cost of such vehicles in PSV roles.


  1. This data regarding the routes to EV acquisition routes is readily available from the respective trade bodies.  Our view is that the majority of new private vehicles are obtained via the various leasing, subscription, and PCP models.  This in turn supports a broader second-hand EV market where leasing option and subscription models are growing.  Businesses are generally leasing vehicles.  The key means of improvement here is the reduction of the need to win a vehicle by increasing the attractiveness of Mobility as a Service adoption, especially in urban environments.


  1. We recognise poor knowledge and/or misinformation for consumers at dealerships as well as in the national media are among the biggest consumer barriers.  The dealership issue is that of failing to have or supply the knowledge to allow the consumers to make a properly informed decision is a major impediment to uptake.  There are signs that this is improving.  Another key barrier relates in particular to those whose property does not have private of street parking, which inhibits access to the capability for lower cost smart charging.  This would need to be addressed by legislation ensuring a consistent approach across the four nations to ensure that cost effective solutions can be implemented.  Such legislation would have to encompass the roll out of kerbside charging solutions, including, but not limited to cable crossing solutions, kerbside charging solutions, wireless charging and support for local authorities in rolling such infrastructure out in areas where commercial operators are unlikely to operate without additional support.


  1. The current range of EVs for sale in the UK is in line with the typical market roll out of vehicle product, with the usual handful of exceptions.  Premium levels first then trickle down to the remainder of the market, maximising profit and return from all stages and previous stages.  The adherence to this model by UK and EU manufacturers creates a void for Chinese manufacturers to fill.  This will result in the opportunity for a price war to reduce the cost of EVs while also increasing the range available.



  1. L segment vehicle ideally have a huge role to play in Mobility as a Service in our towns and cities, as a viable alternative to car ownership and for some, for public transport.  At present the market is constrained in part by the availability of suitable vehicles, part by consumer perception, skewed by car focussed media and politics and a lack of effective LEZ rules supporting the growth of such services.


  1. While the Association claims no in-depth expertise on the market, our expectation is that the market will grow, particularly as many lease vehicles are brought to it.  This will create a price differential that we believe will increase the availability and lower the cost of smaller batteried vehicles, making them more accessible to the less affluent.  These may also be bought in larger numbers by community car clubs, to the benefit of many.



  1. The Association sees the car clubs and micro mobility as a fundamental element of achieving the 2030 target in urban and dense urban areas. (In conjunction with electrified public transport, trains, buses, taxis, and trams.)  Support for such enterprise needs to be more robust, and city infrastructure design which already sees better implementation of bike routes for example, can encourage micro mobility by creating micro mobility thoroughfares in cities, such that use of micro mobility instead of cars is seen as attractive.


  1. The challenges faced by consumers using EVs in the UK vary with location, affluency and approach of local authorities.  For those with access to home charging, issues generally only occur on the longest journeys.  Where a vehicle is used primarily of typical daily local use, home charging typically provides the support needed to enable this with no difficulty, irrespective of vehicle range.  With increased battery size, the area of operation without difficulty grows significantly lessening dependence on public EV charging provision.



  1. For resident who live in properties without private off-street charging, the challenges can be more significant.  Where they have an employer who offers workplace charging these can be ameliorated to offer a similar convenience to that experienced with home charging.  Where the local council or local authority has taken a proactive forward-thinking approach, installing infrastructure to support such users and also enable equitable access to lower cost off peak charging, then again a similar experience is achieved.  In the absence of these option then varying degrees of difficulty are experienced in achieving ‘normal’ daily use.


  1. On longer journeys, difficulty varies with location within the four nations, and also dependant on time and date of travel.  Bank holidays offer a greater challenge as the infrastructure is stressed at these times. As such, one of the difficulties is the challenge of habit change to support the shift to a slightly different model of planning.  While this will improve with additional infrastructure, there remains the perception around cost of using the necessary charging infrastructure.  Users have habitually assessed the cost of individual journeys but need to shift to thinking about average cost over a longer period, certainly at least 12 months.



  1. A further challenge should be remedied with the mandated network roaming nearing legislation.  This will reduce the number of memberships and cards that are required for long journeys.  Indeed, the Association expects to see such roaming see costs presented into home energy bills.


  1. For those on lower incomes, the use of contactless payment can represent significant challenge due to the size of preauthorisation hold imposed by network operators. Indeed, with a failed charge, this can render finance unavailable to some within a few transactions.  While the Association supports the provision of contactless payment on #JourneyChargers (Rapid, HPDC etc), we do not recognise the need on any AC only infrastructure, especially as it does not promote access to intelligent smart charging on such infrastructure, while also adding significantly to the cost of same.



  1. The clearest benefits of EV use are improved local environments, reducing pollution and noise.  The financial benefits, when understood are significant, but vary as previously indicated by the charging infrastructure used.   In practice, Total Cost of Ownership is lower for almost all users.


  1. The market in Europe has settled on CCS and Type 2.  The only key legacy standard that should be supported by all networks is CHAdeMO.  The networks need greater density and a coherent approach to roll out, including a requirement to offer coverage of the whole of the four nations.  As such the Association believes that all network operators need to work in collaboration to ensure that they have complete coverage available.  This may take the form of site sharing.  Roaming alone is not sufficient, as that does not guarantee the infrastructure investment in remote and rural areas.



  1. In terms of network reliability, it is not clear how the Public Charge Point Regulations 2023 can meaningfully or realistically measure or enforce this statistic.  While we support the metric, we cannot clearly comprehend the methodology that will achieve the desired aims.  The Regulations are welcome in providing a common standard for operators to work toward, allowing benchmarking and improvement.  99% uptime is, ambitious, as it can be achieved with almost no actual successful charging.  The requirement for publicly available data is something we have long seen as a requirement to enable effective journey planning, resolving one of the challenges faced by EV owners.


  1. Currently all EVs have extremely high recyclability.  Indeed, their longevity currently indicated that commercial recycling of battery packs will not be viable for some years yet.  Battery recycling already exceeds 95% of material recovery for reuse.  Some operators indicate processes with greater than 99% recovery.  Prior to recycling, reuse of the complete cell in local storage applications can extend the asset life beyond 25 years.  This recyclable value may impact the flow of EVs into the market to some extent, but as drivers generally like the vehicles, it is more likely that they will retain them longer term and may be able to upgrade batteries to newer more energy dense chemistries in time, offering a route to recycling that is circular and should keep vehicles in use for longer.


  1. National Grid see no challenges in the overall supply of energy for EVs. Downstream from the National Grid, challenges exist for DNOs in rolling out network capacity to meet the demand.  Currently the workforce and supply chain are all sought after by all involved parties, the networks, the Battery EnergyStorage companies, windfarm operators, EV charge point networks etc.  Additional bottlenecks exist in planning, land rights and network access constraints that can be imposed by all of the above.  A more integrated solution is desirable, but complex and dependant on actual collaboration.