Written evidence from Greenpeace UK (ELV0040)

Greenpeace UK’s response to the House of Lords Environment and Climate Change Committee Call for on Electric Vehicles

Introduction

Greenpeace UK welcomes this call for evidence on electric vehicles. We have campaigned for decades for cleaner transport to benefit the nation’s health and to abate catastrophic climate change. Our response is informed by Transport &v Environment UK’s response, and Greenpeace UK’s report ‘The Impact of a 2030 phase-out date in the UK’.

The transition to battery electric vehicles (BEVs) is absolutely critical to the UK’s climate goals. While the UK has taken important steps to get the transition underway, dithering and delay of key regulations as well as unclear policy direction in certain areas is creating unnecessary uncertainty around how the BEV market and related infrastructure will continue to develop in the years to come. Despite unrelenting media and political pressure on the UK’s phase out dates, BEV sales are continuing to rise, representing nearly 17% of new registrations and becoming ever popular in the corporate channels due to a very supportive benefit-in-kind regime. In addition, the UK’s public charging network is expanding at an average growth rate of 35% over the past three years - more than enough to get to the Government’s aim of at least 300,000 by 2030.

It is now crucial that the UK continues this trend and that the Government explores how to boost BEV uptake among private buyers, further builds out public charging infrastructure across all regions, and improves public confidence in the technology and infrastructure.

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?

On this question, it should be noted that there is a sustained campaign against BEV take up among some of the UK media. Whether this is entirely spontaneous or prompted by electric vehicles removing the largest source of demand for petroleum products, the campaign of misinformation on electric vehicles does seem designed to suppress demand and weaken government political support for decarbonising cars and vans. The government must stick to its laudable commitment to phase out petrol and diesel vehicles from 2030, sign off on the regulations to deliver it, and ignore attempts by siren voices to derail the EV transition. Failing to do so would mean waving goodbye to any meaningful electric vehicle manufacturing sector in the UK, which would put domestic car manufacturing as a whole in jeopardy. For several reasons, a more rapid transition remains the right approach.

A 2030 phase out has a positive impact on the vehicle fleet, including changes to fuel demand, emissions, infrastructure and government expenditure, and the overall macroeconomic impacts in terms of GDP, employment (including by sector) and total government revenues. In addition, the potential macroeconomic effects of leveraging such a phase out improve the UK motor vehicle industry’s competitive position.

A more rapid transition can represent a win-win to the UK; it will bring down emissions from the vehicle fleet more rapidly, and bring these segments of the transport system more closely into line with the UK Government’s 2050 net zero target; and, at the same time, it can create additional activity and jobs in the UK economy.

Under a 2030 phase out, well-to-wheel CO2 emissions from the fleet are expected to reach zero by 2040 (as a result of negative emissions technologies in the electricity generation sector), while the shift to zero-carbon powertrains can also be expected to reduce local emissions (such as nitrogen oxides) and therefore improve air quality. GDP is expected to be up to 0.2% higher as a result of a more rapid phase out, while 32,000 additional jobs could be created in 2030 (employment peaks at 48,000 additional jobs in 2035). This is primarily a result of the shift away from imported fossil fuels (the importance of which couldn’t be stressed more in the current geo-political context); the improved efficiency of electric vehicles (and lower tax rates) results in lower overall costs of mobility, and consumer spending on electricity (for fuel) and other consumer goods and services.

The main obstacles to achieving the Government’s 2030 and 2035 phase-out dates are dithering and delay by the Government itself over key regulations and a clear industrial strategy for BEVs. The Government’s delay in getting the zero emission vehicle (ZEV) mandate into legislation and starting from January 1st 2024, as originally planned, risks stifling millions of pounds of private investment in charging infrastructure and slowing down the supply of electric vehicles into the UK.

Delaying or weakening the UK’s ambition on BEVs will not resolve any of the issues that need addressing - private investment in infrastructure and domestic EV production would slow down if the UK doesn’t follow through with its commitments, as it would make the UK a less attractive market to invest in.

Ultimately, the global car and van markets are moving towards BEVs - this is not a UK, or even just a European trend, but a global one that the UK must stay competitive in.

This trend is clear in the UK. So far this year, BEVs represent nearly 17% of new registrations, with August 2023 representing a bumper month with BEVs making up over 1 in 5 new registrations. This trend is expected to continue, with the Government’s own cost-benefit analysis stating that the “do nothing baseline” (i.e. no new Government intervention and maintaining existing EU regulations) would get us to 23% ZEV sales in the car market in 2024.

The ZEV mandate will be crucial in setting a clear trajectory for new car sales in the UK - this will provide certainty for manufacturers, the charging industry, other related BEV industries and consumers.

The charging network is currently on track to meet the Government’s aim of at least 300,000 public chargepoints by 2030 - the current average year-on-year growth rate of the network is around 35%.

While much of the focus in the media has been critical of the charging network, we believe that the network is progressing at a good rate and recent new regulations around mandating high reliability rates and easier payments is a big step forward to reducing the user experience issues that some BEV drivers have faced. The Government must ensure that it is proactively monitoring the rollout of chargers across the country ensuring that no region is left behind - it is clear that some regions have progressed better than others to date. The new LEVI fund allocations to city regions and local authorities for capital spending may help to address this.

While the public charging network will be crucial for the BEV transition, it’s important to note that 71% of vehicle owners typically park [1] in a driveway or garage which is where much of the charging needs will be fulfilled. Among the other 30%, while over half park on-street and will require kerbside charging solutions, others park in communal or private car parks which, again, should be easy to have charging installed at - the Government should be exploring as many avenues as possible to ensure that people can charge their cars at or near their homes.

Currently the main demand-side support for BEVs is in the corporate market, where company car drivers benefit from low tax rates when picking an BEV compared to other fuel types. This has resulted in high levels of BEV registrations in this segment with recent data from the BVRLA showing that 43% of new leased vehicles are now BEVs. These beneficial tax rates are set to continue until 2028, which should result in almost all new company cars being electric by that time.

There are no such incentives in the private market, however. While there is a tax differential between new BEVs and polluting cars at the point of purchase (first year vehicle excise duty), the UK’s is one of the lowest in Europe according to analysis by Transport & Environment.

The Government should explore ways it can better incentivise the private market, particularly as we move beyond the “early adopters” phase of the BEV transition and into the “early majority” - i.e. drivers that may be agnostic about the technology and will choose BEVs if they are convenient and affordable.

BEVs are far cheaper to run and own over their lifetime than petrol and diesel cars, due to their lower fuel and maintenance costs. Meanwhile, the majority of EV drivers have very positive experiences of driving them, with low levels of issues with the charging network and other issues portrayed in the media. The benefits of switching to BEV need to be better understood by the general public.

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 EV transition is a global one - markets like the EU, US, Japan and Canada all have bans on new internal combustion engine sales from 2035 at the latest, with other countries like China, Australia, India and others also moving quickly on BEVs. The UK is currently among this group with its own phase out and it's imperative that this stays in place. Ultimately, the internal combustion engine is running out of markets to be relevant in the long term.

The phase-out date for the UK will help with investment to the extent that it makes the UK an attractive domestic market and will be particularly important to provide certainty for the UK’s charging network. However, due to the fact that the UK currently exports 80% of vehicles made here, domestic production is more significantly impacted by regulation in other countries, particularly key markets such as the US and EU.

To ensure that the UK’s domestic vehicle manufacturing is best supported, the UK needs to urgently come forward with a robust industrial strategy for BEVs - the UK’s approach cannot be reliant on one-off subsidies such as the deal agreed with Tata for its gigafactory plant in Somerset. The UK needs a clear strategy on how it will bring in and support private investment into BEV manufacturing, supply chain and battery production. Currently the UK is falling behind the other countries in building a strong industrial base, putting the country at risk of missing out on key investment opportunities.

The Government is due to set out its definition of “significant zero emission capability” (SZEC) - the criteria that new vehicles must meet to be sold between 2030 and 2035. This is an opportunity for the UK to set the right course for post-2030 vehicles, helping the UK to deliver on its climate commitments and providing a boost to consumers. Alongside battery electric vehicles (BEVs) and hydrogen fuel cell vehicles (FCEV), plug-in hybrids (PHEVs) will be the only other drivetrain allowed to be sold between 2030 and 2035, but SZEC should ensure PHEVs are meeting robust criteria to be eligible for sale. PHEVs are proving to be a climate problem rather than a solution. Evidence from the ICCT, backed up by real world testing by T&E, shows that the carbon savings of PHEVs are around three to five times lower than previously assumed. If new PHEVs are to be allowed to be sold between 2030 - 2035, the UK should ensure its SZEC criteria requires new non-zero emission vehicles to have:

● Minimum consistent fully electric range of at least 100 miles.

● Capability to fast charge at minimum speeds of 50kWh.

● Equivalent electric motor power compared to the power of the engine.

● Capability to run in zero emission mode irrespective of power demand of auxiliary equipment.

If the UK motor vehicle industry, with support from the UK Government where needed, can leverage a more rapid transition to improve the competitiveness of its products (‘first mover advantage’) then there is the potential for further substantial benefits. Increasing the proportion of UK demand for vehicles met by domestic production by 8% (from 34% of domestic demand being met by UK-based production, to 42% by 2040) as a result of the more rapid transition could increase GDP by 0.6%, and employment by an additional 63,000 jobs, in 2030. Increasing exports of vehicles to Europe, or securing a substantive share of the nascent vehicle battery industry, could also lead to greater

economic gains.

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?

The UK has had two major incentives in place to support BEV uptake. The first one was the plug-in grant which supported EV buyers with the higher upfront purchase cost of an EV - this grant was removed for cars in 2022 having played an important role in kicking off BEV uptake in the private and corporate channels. In the meantime, the Government also made changes to benefit in kind for company cars, which has allowed company car drivers to access BEVs at very good rates leading to a big uptick in BEVs in the corporate channel.

Elsewhere, the Government had a grant to support BEV drivers to get a home charger, which again has since been removed.

There are no other clear incentives for BEVs in the UK, as the VED tax system fails to act as a proper incentive for BEV uptake.

The government must:

● Generate investment in more gigafactories. Ten are needed by 2040 according to battery research experts, but the UK currently has just one, with a second potentially announced on Green Day.

● Increase funding (and mandate) for local authorities to roll out charging infrastructure.

● Support a ban on deep sea mining as a source of the critical minerals, and invest in international R&D collaboration to improve battery efficiency and reduce reliance on cobalt.

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 clear gap between people’s perceptions of BEVs (as well as their actual car needs) and reality. Bridging that gap is going to be crucial to ensure people are given confidence that they can make the switch to BEVs. This means better information about the cost benefits of switching to EVs, better information about the longevity of batteries and their performance, transparency of charging data and information about the vehicles themselves.

OZEV could be well placed to deliver or at least facilitate some of this information but thought should be given to who the most trusted communicators are of this information. Helping ensure accurate and consistent information from new and used car dealers will be important. The need for information should quickly decline over time as BEVs become much more common and people will know friends or family who drive an electric vehicle.

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

The coverage in the UK media recently has been generally misleading, certainly in recent months, using previously debunked information to delegitimise BEVs as a solution. Other coverage has been reliant on using anecdotal evidence of poor experiences of BEVs - while there are clearly some poor experiences of BEVs, they are not as frequent as media coverage may lead people to believe. Whether this is entirely spontaneous or prompted by electric vehicles removing the largest source of demand for petroleum products, the campaign of misinformation on electric vehicles does seem designed to suppress demand and weaken government political support for decarbonising cars and vans.

The government must stick to its laudable commitment to phase out petrol and diesel vehicles from 2030, sign off on the regulations to deliver it, and ignore attempts by siren voices to derail the EV transition. Failing to do so would mean waving goodbye to any meaningful electric vehicle manufacturing sector in the UK, which would put domestic car manufacturing as a whole in jeopardy.

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

Switching to BEVs offer significant environmental benefits and will be crucial to decarbonising surface transport, alongside reducing the number of vehicles on the road. The Government’s proposed ZEV mandate would be the UK’s biggest carbon cutting measure to date when implemented with the car ZEV mandate delivering 16.0 MtCO2e average annual savings in carbon budget 6 (2033-37) and the van mandate delivering 7.4 MtCO2e average annual savings in the same period.

The rules on what vehicles are allowed between 2030 and 2035 will be important for greenhouse gas emissions too. Research by T&E and others have shown that real world emissions from plug-in hybrids are much higher than in test conditions as the electric mode is used less than anticipated.

T&E analysis into lifecycle CO2 emissions of BEVs shows significant savings, with an average BEV in the UK emitting around 75% less over its lifetime than a petrol equivalent.

Meanwhile, BEVs are also significantly better from an air quality perspective too. The most recent research shows that BEVs’ use of regenerative braking to slow vehicles reduces harmful emissions by two thirds in urban areas.

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?

The primary cost to consumers currently with EVs is the higher upfront costs. However, this will continue to come down as battery packs become cheaper and we will see upfront cost parity with ICE equivalents by the middle of this decade, according to a BNEF study for T&E. Crucially, most people buy their cars in the second hand market so this will not be a significant issue to the majority of people - currently the used market is a great place to get a cheap EV and supply into the used market is picking up. The faster the new market transitions, the more cheap, second hand EVs will be available and faster costs in the new market will fall.

BEVs are cheaper to run and own over their ownership cycle - a potential cost issue is the cost of motorway rapid charging as it is, in some circumstances, more expensive than petrol. However, most people will not be reliant on the rapid network and only use it when absolutely necessary (as is the case with people who drive petrol - people don’t choose to fill up at a motorway service area if they can avoid it).

T&E research has shown that carmakers have been found to be prioritising the production, marketing and sale of larger vehicles like sports utility vehicles (SUVs) and e-SUVs over more affordable, smaller BEVs. The amount of net profit per car of the car makers studied - minus the higher costs of raw materials and labour - increased from between -€40 to €1,920 in 2019, to €510 to €8,940 in 2022 in real, or inflation-adjusted values. This increase in profits accounts for up to 94% of all revenue generated over the same period. This means carmakers’ race for profits, rather than supply chain problems, are at the heart of making cars more expensive. This increase in profits coincides with the size of cars being sold getting bigger and the number of smaller models available being reduced. This T&E research also shows that under a “favourable market conditions” scenario, small segment BEVs could be produced in Europe in 2025, priced at €25k with a reasonable 4% profit margin. It would have a 40 kWh LFP battery and deliver a range of 250-300 km. Smaller BEVs could help those on lower incomes gain from the benefits of using EVs as well as more efficient use of critical raw materials essential in efforts to achieve net zero.

The Government should continue to monitor both of these to ensure these higher costs don’t persist without intervention - targeted incentives to support people into BEVs could be an effective measure in the next couple of years as supply of EVs picks up due to the ZEV mandate.

Regarding future costs such as tax changes, it’s crucial the Government gives plenty of notice to drivers. This means having a clear strategy for what happens as new revenue is needed from reducing fuel duty receipts - the Government has kicked discussion about road pricing into the long grass but this cannot continue for much longer. They need to start having clear engagement on what such a system would look like as we move to BEVs.

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?

For a number of years, reports show that around 90% of new vehicles in the UK are bought using financing deals. In 2022, this is reported to have dropped to 84%, which has in part been attributed to the BEV transition with salary sacrifice schemes starting to become more and more popular than other “traditional” financing options, such as personal contract purchase (PCP) and hire purchase (HP).

The increase in popularity for salary sacrifice schemes for BEVs has been largely driven by the very low rates that company car tax (Benefit-in-Kind (or BiK)) has been set. In salary sacrifice schemes, monthly payments for the car are taken from the employee’s pre-tax salary - the employee has to pay tax on the value of the car; but with taxation rates on BEVs being set much lower than other fuel types, it has acted as an extremely effective incentive to get company car drivers into BEVs.

In fact, the British Vehicle Rental & Leasing Association says 91% of new salary sacrifice cars in Q1 2023 were BEVs, while 43% of new leased cars in the same period were BEVs. It’s clear that salary sacrifice has been and continues to be an incredibly effective way at accelerating BEV adoption. It’s important to note that BVRLA data also shows that over 60% of salary sacrifice users are basic rate taxpayers, showing such schemes can be vital in widening access to cheaper BEVs to all income groups. The Government could explore ways of widening access to salary sacrifice schemes to more people, particularly with the low BiK rates for BEVs now set in stone until 2028.

While much of the focus with speeding up the BEV transition naturally focuses on the new car market, over three-quarters of vehicles sold in the UK are in the used market, with the total volume of used car sales generally between 7.5 - 8 million in recent years. 600,000 fewer used cars were sold in 2022 compared to 2021, however, but the number of used vehicles being financed went up by almost 10%. This shift is thought to be largely a result of shortages of new cars coming into the UK in 2022 and people on PCP deals switching their contracts to used cars - this shift ultimately increased the prices of used cars. The used market will continue to be crucial as we switch to BEVs - due to their higher upfront cost, it is thought that financing deals will likely continue to grow in popularity, however there are recent examples of BEV models reaching cost parity with their fossil-fuel counterparts.

The used BEV market is increasing significantly. Recent SMMT data showed that sales for used BEVs were up by nearly 82% in Q2 2023, representing 1.7% of the market overall - up from 1% in the same period last year. While BEVs still represent a small chunk of the overall used market, their growing popularity is a sign of things to come. It was only back in 2019 that BEV registrations in the new car market were down at 1.6% - in 2022 it was over 16%.

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

Currently BEVs still have a higher upfront purchase cost compared to fossil fuel cars. This gap will close over time, but for some people this gap will be a barrier to purchasing a BEV. However, people can access affordable new BEVs on salary sacrifice schemes as well as picking up increasingly affordable BEVs in the used market. Financing deals could be structured in a way that helps absorb the higher upfront purchase cost of a BEV too. For people who can access a BEV, while they may pay more upfront, they will pay significantly less running the car than a petrol or diesel alternative due to their lower fuel and maintenance costs.

While costs are an important factor, it appears that some of the main barriers for consumers are more to do with perceptions of BEVs. Charging is often seen as the primary barrier that prevents people from getting a BEV. However, with two-thirds of households having a private driveway or parking space (i.e. where people can charge cheaply at home), and public charging infrastructure increasing at 42% over the last year, many people could switch to a BEV already. While there are undoubtedly challenges with some charging infrastructure in terms of reliability and coverage in particular regions, the network is generally sufficient to support current BEV uptake.

One of the other significant barriers in the used market is confidence around the longevity of batteries. Consumers are uncertain about how well the batteries in an older BEV will perform. While there is increasing amounts of evidence that shows that older BEV batteries are holding up incredibly well even and are expected to last at least 15-20 years, more transparency and information for consumers will be critical to increase public confidence in the technology.

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

Currently, it isn’t doing much to ensure this. The proposed ZEV mandate would speed up and provide certainty of supply of BEVs to the UK market, which would help to bring costs down, bring them to the used market quicker and, hopefully, ensure a wider variety of vehicles were available to people. This regulation must be brought in and start in January 2024 but the Government has dithered and delayed its implementation.

Elsewhere, the only real incentive is benefit in kind in the corporate channel. The Government has also developed an EV infrastructure strategy and invested money to enable local authorities to install charging.

The Government should continue to monitor the market and explore ways of offering targeted incentives to enable people to access affordable BEVs if the market doesn’t deliver that itself, ensuring particular groups are not excluded from the benefits of electric vehicles.

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?

The BEV market is currently dominated by larger cars (e.g. SUVs), which make up nearly half of sales. This is reflecting a wider market trend across the car market, but this is a trend that needs to be halted and reversed with smaller BEV models incentivised to ensure the right options are available to consumers. This is starting to happen naturally with smaller, cheaper BEV models due to come onto the market from next year but it’s clear manufacturers are prioritising SUV sales as a way to maximise profits.

The Government should continue to monitor this and introduce a weight based tax on new car sales to incentivise the purchase of smaller cars.

There is no reason why European carmakers can’t also produce high quality, low cost BEVs. Nor is there a reason why the UK can’t offer the right, supportive environment to make those sorts of BEVs here, with the right policy certainty, government and private finance and investment in the wider supply chains and skills.

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?

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?

The majority of people buy their cars in the used market, which underlines its importance to enabling consumers to access more affordable vehicles. The used BEV market is still in its infancy, making up just 1.7% of the market - where the new BEV market was at in 2019.

As the supply of new BEVs increase through the ZEV mandate, the used market will quickly develop and may track at similar rates to how the new BEV market has in recent years. The continued electrification of company cars will play an important role as those vehicles tend to go into the used market after just 3-5 years in a fleet.

Recently, the used BEV market has increased significantly (82% in Q2 2023) with prices also dropping to a point where equivalent petrol and diesel models are similar to battery electric.

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

Corporate registrations make up around half of new car registrations in the UK, with leasing and long term rentals specifically accounting for 20%. In 2022, BEVs accounted for over 34% of new registrations in the leasing sector, tracking ahead of overall corporate BEV registrations (23%). As discussed in previous questions, the changes to benefit-in-kind has led to a significant increase in BEV registrations in these channels, providing a clear incentive for company car drivers to switch to a BEV.

Pushing the corporate, and specifically the leasing segment to move faster now can have a positive knock-on effect for the used BEV market as these cars will tend to go into the used market after just 3-5 years. In other words, the faster corporate leasing vehicles switch to electric, the faster the UK will have a buoyant used BEV market. Not only will this increase the supply of BEVs into the used market, it will also help to bring prices down.

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?

The ZEV mandate will play a crucial role in providing certainty of the supply of new BEVs into the UK, which will then ultimately go into the used market. The delays around the implementation of the ZEV mandate cause unnecessary uncertainty for manufacturers and other related industries in ensuring the UK’s supply of BEVs can scale up in the coming years. In addition, unnecessary proposed flexibilities afforded to manufacturers in the early years of the mandate could potentially slow down the supply of BEVs in the next couple of years.

A lot of new BEVs entering the UK market are larger, often more expensive models, which will not necessarily be the preferred option for UK drivers in the used market. The Climate Change Committee pointed out recently that half of new BEVs in the UK are classed as SUVs. The Government should be closely monitoring this issue and exploring potential interventions that better incentivise the sale of smaller, more affordable BEV 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?

Increasing the use of car clubs can play an important role in reducing the number of cars on the UK’s roads overall, which could bring a range of social and environmental benefits particularly in urban environments. The average car is parked for 96% of its life, with the amount of space given over for parked vehicles enormous which is a particular issue in urban areas.

However, to better support electric car clubs, the UK needs: a coherent national policy on expanding their use, consistent local authority policies including access to parking bays, and ensure there is sufficient suitable charging infrastructure for these vehicles.

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?

Experience of using an EV

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

A phase out of ICEs will require a rapid deployment of charging infrastructure. The vast majority of this will be at drivers’ homes. But work and public charging is needed for the quarter of drivers without access to off-street parking, as well as to enable BEV to drive long-distance. Under a 2030 phase out of ICEs, by 2030 the UK would require 1.2m work, 240k slow public (3-22kW) and 62k rapid public (>50kW) charge points, as well as 13m home charge points.

In addition to this, the UK needs to speed up the installation of rapid chargers along the strategic road network. While rapid chargers will largely be used in emergencies, for top ups and for people driving long distances, this infrastructure will be crucial to give people confidence to buy a BEV. Many people will make their vehicle purchase decisions based on the longest or most difficult journey they take - if they don’t feel confident taking their annual trip to Cornwall in a BEV, for instance, then they may opt against.

Another challenge with charging infrastructure has not just been whether there are enough available, but whether they work reliably, have easy payment methods and are accessible for all drivers (e.g. people with disabilities). This has been a major challenge in recent years and has led to a number of anecdotes of broken chargers, poor customer service from the charging operators and the need to install a large number of apps to pay for the charge. This in particular is changing. It is changing in part to consolidation and progress in the charging industry itself making driver experience a lot better, but the Government has also stepped in with its regulations that require minimum levels of reliability, easier payment methods and 24/7 customer service. These regulations will go a long way to resolving many of the challenges consumers have faced. There should also be as much transparency of live data as well, so consumers can easily identify available chargers and their supposed charging speeds. Guidelines on how to make charging infrastructure accessible have also been developed but they are not legally binding on the chargepoint operators - we believe that these guidelines should be legally binding to ensure that no one is being held back from the BEV transition.

A final issue that has been raised with the charging network is the costs associated with rapid charging, which is often higher than filling up a tank of petrol or diesel. While rapid charging will be used very rarely by most people, these higher costs pose a potential issue for higher mileage drivers that may be more dependent on rapid, on-the-go charging as the fuel cost savings associated with BEVs diminish.

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

The main benefits for BEV drivers are the lower running costs associated compared to petrol and diesel cars. The total cost of ownership (TCO) of a BEV is lower than fossil fuel equivalents due to lower fuel and maintenance costs.

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

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?

The key is getting the right chargers in the right places, which will depend on a number of factors (e.g. proportion of local residents with driveways, amount of visitors to an area, through traffic). The UK needs to have a proper plan and clear policy guidance to enable this. Currently the Government’s approach has been to set a topline target and direct money and responsibility to local authorities - while both are helpful, they are not enough.

Without further action to secure more battery plants to deliver green job opportunities and adequate charging infrastructure to meet demand, the government’s EV strategy will still be in need of a jump start.

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?

The draft legislation is a major step in the right direction and will be a major boost for BEV drivers with regards to their experience of using public chargepoints. The regulations will set high standards for chargepoint operators to hit on reliability, customer service, ease of payment and transparency. The government should keep this regulation under review to enable updated standards to come into force if chargepoint operators are unable to meet expectations, specifically with regards to on-street charging infrastructure.

We would like to note that while we also welcome the PAS1899 guidelines on building accessible chargepoints, we believe these guidelines should be mandatory for new installations in the UK to ensure people with disabilities are not being left behind in the BEV transition.

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?

Getting the location of chargepoints right is just as, if not more, important as the total number - having public and accessible data can help to drive a far more targeted rollout for infrastructure. The new requirements to make data free and publicly available will enable chargepoint operators to provide a far more accurate picture of existing chargepoints, as well as providing consumers with confidence about where they can charge.

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?

People that have access to a driveway or private parking space at their house currently have the greatest benefit from switching to a BEV as they are able to access much cheaper charging tariffs than those using the public charging network. People in this group represent around two-thirds of UK households.

Meanwhile, Government data shows that around 17% of people park their car on the street, 8% in a communal car park and the remaining in private or council car parks.

Currently there are no regulations requiring existing residential buildings, such as shared housing or high rise flats to have charging installed - such regulations only apply for new buildings or buildings undergoing major renovation. It is clear that there will be a disparity for people living in such buildings compared to people with a driveway or private parking space which should be addressed by enabling residents to request a charger be installed when needed.

While this is not the case, people unable to benefit from cheaper domestic charging tariffs will end up paying more to charge on the public charging network which is a clear equity issue as many of the people that don’t have access to the driveway will likely be lower income.

There are a number of solutions that could be explored further. Fair Charge have long campaigned for VAT on public charging to be lowered to 5% to match domestic electricity, for example. However, it is important, as with any tax changes like this, that cost savings are passed down to drivers. Another solution could be for local authorities to provide RFID cards to residents that do not have a driveway and are on lower incomes to enable them to access cheaper rates of public charging at certain times.

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?

BEVs are cheaper to run than ICE vehicles due to their lower fuel and maintenance costs. In fact, on a total cost of ownership basis (taking upfront costs and running costs into account) electric cars are cheaper than ICE equivalents. The upfront costs will also continue to come down as battery pack prices fall. The point at which upfront costs of BEVs are at parity with ICE vehicles is expected to happen in the middle of the 2020s.

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?

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?

The current regulations around batteries have not been updated to reflect the new world of BEVs. It’s long past time that the UK updated its regulations around sustainable sourcing of raw materials, sustainable battery manufacturing and disposal and recycling of BEV batteries. The UK should follow the EU’s example with its new regulations with regards to recycling targets by requiring battery-makers to recover 90% of nickel and cobalt used from 202 rising to 95% in 2031, and 50% of lithium in 2027 rising to 80% in 2031.

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?

National and regional issues

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

National Grid has repeatedly allayed fears that the UK’s grid will be unable to cope with increased BEV adoption. The main concern would be if all drivers were charging their vehicle at the same time, which can be resolved by smart charging. Regulations introduced by the Government require that BEV chargepoints have smart functionality which will allow BEVs to be charged when there is less demand on the grid.

General energy efficiency improvements have reduced the demand on the grid by around 16%, while everyone switching to BEVs would increase demand by 10% meaning that it will be manageable within the national grid’s capacity.

Where there are potential challenges is not around the overall capacity of the grid, but instead its distribution around the country. Some areas of the UK will require significant grid capacity upgrades which can be costly, time consuming and administratively burdensome for the applicants.

High renewables electricity systems will become the norm over the next few years and the key tools to make it work will become desirable. The government must:

● Upgrade the national grid, including providing additional capital investment, to reflect the increase in electricity storage that will be necessary to meet demand.

● Introduce a cap and collar mechanism for the contracting of green storage tech, as is currently used for interconnectors. This would create a route for market for green storage developers through guaranteeing a minimum income while ensuring contract costs are not excessive; these contracts would be technology-specific and apply to green hydrogen, liquid air, flow batteries, pumped hydro and any other green storage tech that comes forward.

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

Distribution network operators will play a vital role in ensuring there is enough energy distributed around the country to install charging infrastructure, particularly for more energy intensive sites such as rapid charging hubs at motorway service areas, for example. Chargepoint operators and fleets specifically have complained of the expensive, time consuming and administratively burdensome processes for getting an upgraded grid connection. While the Government recently acted to socialise some of the costs associated with upgrading grid connections, there has yet to be concrete action taken to address other issues. The Government should step in to ensure that this is not an ongoing barrier for getting BEV charging infrastructure installed across the country.

High renewables electricity systems will become the norm over the next few years and the key tools to make it work will become desirable. The government must:

● Upgrade the national grid, including providing additional capital investment, to reflect the increase in electricity storage that will be necessary to meet demand.

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?

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

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?

Local authorities will need to play a significant role specifically in relation to the rollout of chargepoints in their districts, including managing conflicting demands for space on the highway. The Government’s EV Infrastructure Strategy is clear that local authorities will be responsible for delivering strategies and overseeing rollout of charging infrastructure in their areas, and have been given funding to do so through the Local EV Infrastructure Fund (LEVI). This fund provides capital for the installation of charging and capability funding for staff in the local authorities.

While we agree with the approach, as local authorities are best placed to determine local need, we believe the Government has fallen short in providing clear policy guidance for local authorities. It should also be acknowledged that even with the funding for bringing in more capacity at local authorities, there is a general lack of expertise at local government levels when it comes to installation of charging infrastructure and more will need to be done to ensure they are well equipped to install the right chargers in the right places.

The government must increase funding (and mandate) for local authorities to roll out charging infrastructure.

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 government must support a ban on deep sea mining as a source of the critical minerals, and invest in international R&D collaboration to improve battery efficiency and reduce reliance on cobalt.