Written evidence from the Electric Vehicle Association (EVA) Cymru (ELV0052)

Response to Welsh Government Consultation: Taxi and Private Hire Vehicles (Wales) Bill

September 2023

The Electric Vehicle Association (EVA) Cymru is Wales’ national representative body for Electric Vehicle owners and drivers. EVA Cymru has three overarching objectives:

● To represent the interest of EV owners and drivers in Wales

● To promote the uptake of EVs in Wales

● To work with other stakeholders to achieve these aims.

Along with our partner associations EVA England, EVA Scotland, and EVA Northern Ireland we work with governments and private sector partners to ensure the voice of all Electric Vehicle owners and drivers is shared as widely as possible.

As a country, Wales is ideally suited to Electric Vehicles. Although it has a significant proportion of rural areas, no journey in Wales would exceed the range of a modern EV’s battery. As with the UK as a whole; infrastructure at home and en route, cost, awareness, and availability of EVs represent the key barriers for Welsh drivers to transition.

Our response seeks to support the Committee’s inquiry by contextualising broader UK trends with the unique characteristics, infrastructure and geography of Wales as well as bringing forward issues of particular relevance to Wales.

● EV Adoption in Wales

The current growth of Electric Vehicles in Wales is more rapid than most of the UK, however this is from a significantly lower base than the UK as a whole. In Wales, 1.47% of cars are plug-in capable versus 3.43% on a UK basis, with a similar Wales:UK ratio for vans.

Vehicles in Wales are generally older than the UK average, with 11% of cars under 3 years old compared to 14% for the UK. The difference for vans is even more pronounced, with 13.6% of Welsh vans being less than 3 years old, against a UK level of 19.8%.

Bringing EVs into the used market is important across the UK but the age of vehicles and higher proportion of Diesel cars (by 6%) in Wales would make incentives such as a ‘scrappage scheme’ or loan proportionately more impactful.

● Road Travel & Infrastructure

Wales represents 8.5% of the land area of the UK, with an average population density of c.150 people per square kilometre (compared to a UK average of 276 people per km2). Around half of the population live within the Cardiff City Region area which has more highly developed public transport infrastructure than Wales in general.

Travel habits are in line with wider UK trends, with the average car journey being around 9 miles. Inter-regional journeys for work are prevalent including very significant flows between Wales and England during the peak commuting periods.

New models such as car sharing schemes exist within Wales in both urban and more rural areas, including a growing number of community-run car sharing schemes using Electric Vehicles which make use of community facilities to park and charge, negating concerns about using EVs for ad hoc journeys.

Unlike England particularly, and the UK taken as a whole, Wales has a very low level of motorway infrastructure with the M4 and M48/A48(M) both being located in South Wales. This has meant that commercial interventions in rapid and particularly ultra-rapid charging have favoured this ‘corridor’ in particular with all of Wales’ 350kW+ charging infrastructure located on or south of the M4.

This presents an important context for UK-wide legislation and funding, where commitments and investment related to infrastructure on the Motorway network can have a far lower impact in Wales where longer distance journeys to, from, or within Wales are less likely to use the motorway network.

● On Street Charging

The length and type of journeys undertaken in Wales creates driver use patterns which focus on charging when vehicles are ‘parked up’, rather than en route. Not being able to charge on-street is generally seen as a barrier for EV adoption however research by the RAC Foundation [1] has shown that a high proportion (74.5%) of homes in Wales have or could have the ability to charge at home.

Whilst the c.350,000 homes which are not suitable are predominantly in built up areas with better public and active travel options, there remain a significant number of homes which would need options for charging at a location that is not their home - although this is a lower proportion than the UK in general (by c.10%).

● Energy Infrastructure

As with the UK in general, grid and local (DNO) capacity is cited as a key barrier to infrastructure development in Wales. This is particularly true of Mid Wales where no significant National Grid high-voltage infrastructure exists. Wales is also served by two DNOs (SP Energy Networks in the North and National Grid in the South) meaning that local infrastructure providers often need to work with both operators.

Whilst development of the grid and DNO capacity is vital across the UK, the significant levels of renewables and planned renewable developments in Wales provides the opportunity to connect small, community, and large-scale renewables with battery storage and EV charging in order to create smart local energy infrastructure (including ‘microgrids’) within communities which could overcome the lack of grid connectivity.

● EV Policies and Funding

Policy making and interventions to support EV uptake operate at UK, Wales, and Local Authority levels. UK policies, including the 2030/2035 phase out dates and the future Zero Emission Vehicle Mandate will play an important role in driving the transition to EVs by Welsh drivers. Equally, Welsh Government policies including those relating to public sector decarbonisation (for transport fleets), clean air and soundscapes, and taxi and private hire vehicles will all impact the speed of transition in Wales.

In 2021, the Welsh Government published an Electric Vehicle Charging Strategy for Wales [2] which set out a vision that “By 2025, all users of electric cars and vans in Wales are confident that they can access electric vehicle charging infrastructure when and where they need it.” Since that time, we have seen significant private and public sector investments in Wales, including schemes such as the Ultra Low Emission Vehicle Transformation Fund being used alongside OZEV grants to grow Wales’ infrastructure. However, there is still concern that Wales has not seen growth in private sector led key charging options including ‘Ultra Rapid’ charging and larger ‘hub’ locations with multiple rapid chargers at strategic road locations.

Government Electric Vehicle and EV Charging Infrastructure funding schemes differ across the UK, with some UK-level grants available in Wales and others not. Wales-specific funding has focused largely on infrastructure and infrastructure planning unlike Scotland, for example, which has also provided loans to support Electric Vehicle purchases.

Whilst we highly value the way in which this devolved funding supports investment through the most appropriate interventions for Wales, we are aware that this has created confusion for some infrastructure providers.

As in the rest of the UK, Welsh Local Authorities play a key role in ensuring the transition to electric vehicles is successful. Some Local Authorities have formal EV strategies and others are in more developmental phases in terms of the support needed to encourage residents to transition. In our discussions with Local Authorities, they have identified a range of ways in which they see their role in terms of supporting EVs and EV charging including:

- Responding to the Climate Emergency, including decarbonising their own operations

- Responding to demand from those who cannot charge off-street.

- Providing and supporting all members of the community to ensure a just transition.

- Raising income and use of Local Authority-run car parks

- Improving air quality

In 2022, four Corporate Joint Committees were formed in Wales, each of which covers the Local Authorities in its region. These committees now have a duty to project a Regional Transport Plan by March 2025 and these plans will also offer the opportunity for Wales to align EV infrastructure and planning across Local Authorities, ensuring strategic investments, and avoiding a confusing experience for EV drivers.

Transport for Wales, as the delivery arm for Welsh Government’s EV strategy, therefore, plays an important role in aligning the levels of policy and funding in order to maximise the opportunities to transition to Electric Vehicles in Wales.

● Skills and Employment

There has been substantial investment in skills development to support the transition to Electric Vehicles in Wales, including the funding of specialist Electric Vehicle training facilities in Further Education colleges, however, there remains a need to continue to support independent garages to support EV sales and to understand the maintenance requirements of EVs.

The EV and EV infrastructure sector in Wales remains small, although high-growth companies have been identified particularly in the infrastructure sector and the positive impacts on small businesses such as electrical contractors should not be underestimated. The Welsh Automotive Forum is currently working on behalf of Welsh Government to map the potential economic growth of the Zero Emission Vehicle supply chain [3] with a view to exploiting clustering and growth opportunities.

● Freight

Although the electrification of road-based freight transport is still developing globally. In Wales, and both North and South Wales are key connectivity routes between the UK and Ireland with 46.4Mt of Freight moved annually through Welsh ports [4].

Although this inquiry relates primarily to the 2030/2035 phase out dates for new cars and vans, the energy and infrastructure demands for freight are an important part of the broader picture and as the deployment of heavy electric vehicles increases, the identification of relevant locations and facilities to support these vehicles (and the provision of electricity infrastructure to those locations) will be important to the successful decarbonisation of both road freight and light vehicles in Wales.