Written evidence from the Institute of the Motor Industry (ELV0042)

 

The Environment and Climate Change Committee Electric Vehicles Inquiry

The inquiry on Electric Vehicles (EVs) is examining the importance of the decarbonisation of transport and transition to EVs to secure Net Zero targetsThis inquiry seeks to understand how the Government will achieve its upcoming 2030 and 2035 deadlines for the phase out dates for non-zero emission vehicles, as well as exploring the main obstacles and barriers to meeting these targets. The inquiry will focus on passenger cars and explore what steps could be taken by government to make the transition as easy and accessible as possible both for consumers and businesses involved in meeting market demand, while also assessing the opportunity costs and benefits of encouraging and delivering a greater uptake of EVs.

 

Background

On Wednesday 18 November 2020, the UK Government announced a 2-stage approach to decarbonising cars and vans in the UK. 2030 will see the end of all sales of new petrol and diesel cars and vans in the UK, whilst a second phase out date of 2035 will see new cars and vans “fully zero emission at the tailpipe”. The dates were published in the Government’s “Ten Point Plan for a Green Industrial Revolution”, which outlines the 2030 phaseout date and brings the end of new petrol and diesel car sales forward 10 years earlier than planned. The announcement was backed by an initial pledge of £1.3 billion to support the uptake of zero emission vehicles across the UK, which includes investment into charging infrastructure and grants for homeowners to install charge points at home.

The transition to Electric Vehicles (EVs) is central to the Government’s efforts to meet its target of reaching net zero by 2050, legislated in June 2019. The 2030/2035 phaseout targets were reiterated on 19 October 2021 in the “Net Zero Strategy: Build Back Greener” strategy document. The Department for Transport’s “Decarbonising Transport” document, published 14 July 2021, also restates the 2030 and 2035 phase out dates for achieving a zero-emission fleet of vehicles.

 

Aims

The aims of this inquiry are:

To understand how the Government will achieve its upcoming 2030 and 2035 deadlines for the phase out dates for non-zero emission vehicles, with a focus on passenger cars, as well as exploring the main obstacles and barriers to meeting these targets.

To understand the costs, alongside the benefits, associated with the 2030 phase out date, and to understand Government progress towards decarbonising car usage by this earlier date.

 

Evidence submitted from:

 

Institute of the Motor Industry

Given the specific focus on skills, the possible trust deficit between professionals and the government, and the unintended consequences of this, the Institute of the Motor Industry offers these responses in addition to the wealth of research previously published and available publicly.

Statement of fact: the role of the IMI

The IMI sets the standards in professional competence for those working in automotive. This is critical to ensure user confidence in the vehicles driven and used in all geographies around the world which, in turn, is essential for economic sustainability. Without properly maintained vehicles to accepted standards, market infrastructure would fail – individuals couldn’t be educated; people couldn’t get to their jobs; goods and services couldn’t be delivered efficiently.

Whilst being a global organisation, delivering professional competence and recognition that are deemed to be world-leading, the IMI has its greatest remit in the UK where it has its largest membership.

In the UK, the IMI’s mission is to support the continuation of innovation, skills, and employment in automotive to sustain user confidence. This it does through the delivery of relevant professional competence and recognition. It also has a responsibility to highlight and call-out perceived threats to user confidence and/or sector sustainability. For example, lack of diversity, unclear career paths, lack of investment in training that contribute to skills gaps, as well as threats from external market forces that could undermine confidence in and the competitiveness of UK automotive. 

The IMI does not have a political bias; it will call out any political party or nation state that represents a threat to the confidence and sustainability of any automotive market, using informed knowledge and insight.

Executive Summary of the Consultation Response on EV Phase-Out Dates and Implementation

The UK Government's 2030 and 2035 phase-out dates for non-zero emissions vehicles are central to the UK's transition to greener transportation. However, there are clear concerns and considerations:

The transition to net zero is multi-faceted, demanding collaboration across sectors and clarity in policy directions. This response aims to shed light on key concerns, particularly emphasising the significance of skills and the professional workforce in the UK's journey towards a greener future.

 

Call for Evidence Response

Government approaches

  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?

 

    1. A primary obstacle to changing the phase-out dates is the potential loss of trust within the skilled workforce. Many professionals upskilled anticipating the government's push for EVs. Should the government fail to meet its commitments, there's a risk of not realising the ROI on their training, causing disillusionment, and potentially leading to a reduced skilled workforce for high voltage technologies that are already in the car parc.

 

    1. If the current phase out dates required additional technologies to the high voltage approach, significant investment would be required for the skilled workforce to accommodate those technologies.
    2. Existing technological progress in Advanced Driver Assistance Systems (ADAS) which are already required for new vehicles also requires upskilling and should be considered when understanding the current skills needs of the modern motor industry.

 

  1. 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?

 

    1. The dates serve as a catalyst. However, for professionals who've invested time and resources in upskilling, these dates represent a commitment. Any shift or perceived lack of adherence can result in diminished trust and fewer professionals entering the EV sector, risking higher costs for motorists in the long run. Our research demonstrates that we are on track to create the skilled workforce needed for the originally stated phase out dates, with significant investment made within the industry. Many of which are part of our SME community.

 

    1. The lack of available supply of home manufactured private transport solutions mean a dependence on imported product and the access to technical data that would facilitate the maintenance, repair, and recycling of those vehicles.

 

    1. Access to vehicle systems that are connected to the manufacturer requires robust government support through enforcement of CMA’s MVBEO that came into effect this year, and training is required for professionals to work on these systems.

 

  1. 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?

 

    1. Policies like the 'Electricity at Work Regulation' and the emphasis on CPD have set high standards. But if the anticipated growth in the EV sector doesn’t materialise, professionals may find their skills underutilised, leading to potential career stagnation. The obligation to CPD also places a financial strain on the skilled community without the anticipated ROI to support it. If the dates where to be extended, government would need to consider how this obligation could be borne by the skilled professional community.

 

    1. The CMA implementation of the MVBEO is recently implemented and will need to be enforced if required.

 

    1. The MOT reform, required to make the MOT test fit for purpose, is still in an uncertain space reducing opportunity for strategy for road safety and communication to motorists about the need for inspections for EVs.

 

  1. 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?

 

    1. OZEV should take the lead on this, with contributions from industry stakeholders and experts. Our research demonstrates a concerning change in behaviour towards newer technologies with worrying trends for MOT failure rates, higher than those presented for petrol vehicles, and a lack of awareness regarding safety features such as ADAS.

 

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

 

    1. The information can be confusing, which builds distrust.

 

    1. There is significant evidence that motorists do not believe that EVs require the same level of safety inspections than ICE vehicles. This is further demonstrated by the MOT data.

 

    1. IMI research shows that there is a lack of thorough understanding of ADAS.

 

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

 

    1. The emissions data that is shown at MOT testing would be reduced, this reduction of tail pipe emissions would be beneficial, especial in urban areas where numbers of vehicles collect and produce fine particulate matter.

 

    1. The volume of service-related fluids that require careful recycling, such as engine oil, would be reduced.

 

    1. Further environmental and road safety benefits can be achieved through correct tyre management. This area requires urgent communication to motorists as shown by our data.

 

  1. 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?

 

    1. The skills aspect could mean more expensive maintenance and repairs as the requirement to cover many different technologies for a longer period should the deadline be extended which government. Policies to the motorists supporting greener technologies with grants, lower Benefit in Kind rates, reduced VAT, vehicle excise duty – all methods that supported uptake, could be used again. Further to this targeted help for motorists, such as reduced VAT for EV tyres could help. EV workshops could receive relief through the business rates system and/or lower VAT on electricity if savings could be made to their labour rate to consumers.

EV Market and Acquiring an EV

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

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

 

    1. Acquiring an EV can be expensive and so smaller private transport solutions could benefit from greater focus. The heavy quadricycle segment could be improved, the work from the IMI with DfT has highlighted misalignment of the MOT Inspection Manual and the legislation which has since been addressed. As an affordable EV solution for local travel, the use of these vehicles could be instrumental to the reduction of vehicular emissions. They are designed to only travel at just under 28mph, this will be an excellent solution in Wales where many speed limits have been reduced to 20mph. The Wales model to urban area speed restrictions will provide interesting data regarding road safety and environmental concerns.

 

    1. For motorists acquiring private transport solutions within schemes like Motability, this could highlight a need for on road charging availability owing to the interaction between customers of the scheme and providers.

 

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

 

    1. The expense of skills can impact the acquisition of EVs, as the vehicles are becoming more complex. So are the skills necessary to maintain and repair them. Our data shows that an EV is more likely to fail its first MOT than a petrol car meaning urgent motorist education is required to reduce the impact on the environment and road safety.

 

    1. Range anxiety is commonly reported upon, but repair anxiety can be impactive to those motorists who rely on older, more affordable cars, that they can access affordable maintenance and repairs, contributing to a reluctance for uptake.

 

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

 

    1. Greater support to those investing in skills and equipment would increase uptake, meaning greater consumer choice and availability. Too few skilled professionals will impact the price point to motorists of access to services. This support could take the shape of the previously used Super Deduction, expanding the scope to include training that contributes to net zero.

 

  1.                     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?

 

    1. Affordability will be critical to ensure private transport solutions are accessible to everyone. This will also mean the affordability for their maintenance and repair.

 

    1. Given the lack of available supply, the cost of UK and EU based manufacture of electric vehicles will be significantly higher than other nation state produced vehicles which may make the UK market uneconomical, with the consequence that brands may exit, creating job loss right the way through the supply chain. 

 

  1.                     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?

 

    1. L-segment vehicles, such as the electric heavy quadricycle have the potential to transform private mobility as they are cheap and easy to use. Motorist understanding of the segment and product availability may be frustrating uptake. Alignment with our countries regarding driver licensing may increase interest as many countries close to our own allow use of these vehicles from the age of 14.  Comparatively, access to licenses for these vehicles is more onerous in this country for young drivers. Currently in the UK, the largest group purchasing the recently launched Citroen Ami are part of the 65+ age group, highlighting the importance of smaller private transport solutions for that demographic.

 

    1. Personal light electric vehicles would benefit from regulation, especially in the manufacturing of battery packs to reduce the risk of fire. Further to this, heavier personal light electric vehicles, specifically commercial use cargo vehicles, should be periodically inspected for environmental and safety reasons. One potential area for environmental inspection would be for battery integratory. Another environment concern would be for refrigerant if used. Road safety inspections for braking, steering, and lights should be mandatory given the risk to more vulnerable road users. Dangerous vehicles that have no safety inspections would be detrimental to the overall uptake of active travel solutions which could encourage motorists out of cars.

 

  1.                     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?

 

    1. Outside the scope of skills

 

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

 

    1. Outside the scope of skills

 

  1.                     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?

 

    1. IMI research shows that we are on track to achieving the number of skilled professionals required to maintain the electrified UK car parc.

 

  1.                     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?

 

    1. Government should consider safety inspections for larger commercial cargo style micro transport solutions that would include steering, braking, and lights owing to their potential impact on more vulnerable road users. The development of appropriate skills would be essential for this as this could be a very workable solution for greener final meter delivery services.

 

    1. Regulation for the manufacture of batteries for these solutions should be implemented owing to the safety risks of poor manufacturing.

 

  1.                     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?

 

    1. Outside the scope of skills

 

Experience of using an EV

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

 

    1. From the skills perspective, motorists are required to find a professional with the appropriate skills to maintain and repair their vehicle. IMI data shows that motorists with EVs are more likely to fail their first MOT than their petrol counterparts. Therefore, motorist understanding of using EVs is a challenge to the net zero ambition if vehicles prematurely cease to be useful owing to poor inspection/maintenance.

 

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

 

    1. Outside the scope of skills

 

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

 

    1. Our data shows that we are on track to achieve the required number of technicians for 2030.

 

    1. There is potential for a disruption to this forecasting if there is a lack of certainty for ROI for skills and tooling.
    2. Roadside public services should also be considered, with information from police forces and fire services about their readiness for mass adoption of EV solutions.

 

  1.                     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?

 

    1. Outside the scope for skills

 

  1.                     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 standardized and reliable for consumers?

 

    1. Outside the scope for skills

 

  1.                     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?

 

    1. Outside the scope for skills

 

  1.                     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?

 

    1. Outside the scope for skills

 

  1.                     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?

 

    1. Outside the scope for skills

End of life disposal of EVs

  1.                     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?

 

    1. Recycling opportunities are numerous for EVs and their battery packs. This could have significant impact on motorists mindful of environmental impact. The IMI works with those organisations operating in this area.

 

  1.                     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?

 

    1. The IMI works with those skilled in this aspect of our sector but would not comment on the economic feasibility of this work.

 

  1.                     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?

 

    1. To recover the critical minerals, there would need to be a skilled workforce to make this operation safe, which could impact the value of the vehicle as a source of saleable assets.

 

    1. The expansion of ULEZs may place greater demand on the second-hand market, inflating the price and making maintenance and repair more attractive.

National and regional issues

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

 

    1. Outside the scope for skills

 

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

 

    1. Outside the scope for skills

 

  1.                     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?

 

    1. Outside the scope for skills

 

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

 

    1. Outside the scope for skills

 

  1.                     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?

 

    1. Delivery of skills in local areas could benefit from a targeted approach for skills funding to ensure repairs and maintenance services are accessible.

International perspectives

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

 

    1. The IMI’s mission is to support the global automotive workforce in achieving and maintaining professional competence and continuing professional development to service, repair and maintain vehicles to industry standards, including new automotive technologies such as EV and ADAS. This is critical to ensure consumer confidence in the vehicles driven and used in all geographies around the world which, in turn, is essential for economic sustainability. Without properly maintained vehicles to industry accepted standards, market infrastructure would fail – individuals couldn’t be educated; people couldn’t get to their jobs; goods and services couldn’t be delivered efficiently.

 

    1. The IMI is working with the UK’s Department for Business and Trade, supporting a UK–China, government-to-government initiative to assist with new energy Technical and Vocational Education and Training in China for the Chinese automotive aftermarket workforce. UK immigration rules mean that these individuals could not enter the UK workforce and, as such, do not represent any threat to current UK jobs.

 

    1. The IMI has set the benchmark in the standards for automotive skills globally and it firmly believes it is right to bring these skills to all geographies for worldwide road user confidence. This belief does not, in any way, prevent the IMI from continuing to represent the interests of the UK automotive and wider community in terms of the impact of the Chinese market on UK economy, infrastructure and security while the UK government lacks an integrated and clear strategy for zero emissions mobility.