Submission

For further information, please contact:

Megan Edwards, Public Affairs and Campaigns Adviser

Email: megan.edwards@local.gov.uk Tel: 07827083928

Local Government Association Company Number 11177145

 

 

Written evidence from the Local Government Association (ELV0079) 

 

 

LGA submissions to the House of Lords Environment and Climate Change Committee inquiry into Electric Vehicles

 

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  1. About the Local Government Association (LGA)

 

1.1.            The Local Government Association (LGA) is the national voice of local government. We are a politically led, cross-party membership organisation, representing councils from England and Wales. 

 

1.2.            Our role is to support, promote and improve local government, and raise national awareness of the work of councils. Our ultimate ambition is to support councils to deliver local solutions to national problems.

 

LGA submissions to the House of Lords Environment and Climate Change Committee inquiry into Electric Vehicles

 

  1. Summary

 

2.1 Councils are committed to delivering Net Zero and transport decarbonisation. Local leaders are playing the central role in supporting residents without off-street parking to switch to electric vehicles (EVs) through providing on-street and off-street public EV charging infrastructure.

2.2 The LGA has welcomed the new £500 million Local Electric Vehicle Infrastructure (LEVI) Fund as a significant improvement upon the On-street Residential Chargepoint Scheme (ORCS). We also welcome the clarity that has now been provided by Taking Charge, the national EV charging infrastructure strategy.

2.3 Councils will play an important role in the 2030 and 2035 phase outs of petrol and diesel vehicles, by working with partners to roll out a reliable and accessible charging infrastructure and by improving the connectivity and accessibility of active travel and public transport. This must include new mobility options such as car clubs and e-bikes. Improving air quality and reducing road congestion will require reducing the number of private vehicles on the road. Councils want to ensure that residents have access to alternative, sustainable transport options and a real choice about whether to buy an EV or not replace the car at all.

2.4 Government needs to provide councils with the long-term funding, powers and local flexibility to decarbonise transport and deliver place-based solutions that meet local needs. Councils are still waiting for the guidance to develop Local Transport Plans (LTP) and for confirmation of the level of funding support they will receive to develop a realistic LTP.

  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?

 

3.1                        These responses will focus mainly on Government policies and initiatives to support a public charging network.

 

3.2                        EV adoption has been rapid in England, with 20 per cent of new cars now battery EVs. But homeowners without access to off-street parking, and drivers with significant ‘range anxiety’ fuelled by uncertainty about the accessibility, reliability, and affordability of the public EV chargepoint network, have been slower to adopt EVs.

 

3.3                        The Government’s ORCS was frustrating for local authorities. In the early years of ORCS, councils found the scheme inflexible and restrictive in terms of councils’ contributions to capital costs and what sort of schemes could qualify.

 

3.4                        In 2021, the LGA commissioned Local Partnerships to ‘Scope the role of local authorities in the provision of electric vehicle charging infrastructure’. The report sets out the following ten issues for the LGA to address with Government on public charging infrastructure:

 

3.4.1   To clearly articulate the national roll out strategy for EV charging and the specific role to be played by councils. This should be supported by forecasts of requirement / targets for areas.

3.4.2   To provide national leadership on the issue of technology selection

3.4.3   If Office for Zero Emission Vehicles (OZEV) want to increase the pace of delivery, revenue and capital resource will need to be provided.

3.4.4   To move away from the stop/start short term funding arrangement to a longer term outcome based approach to funding, with the potential for this to be allocated based on predicted need, rather than competitively.

3.4.5   To strengthen relationships between Sub-National Transport Bodies (STBs) and housing and planning authorities, if OZEV see STBs as important to future delivery

3.4.6   To provide access to data in areas including market data, location modelling, delivery model choice, procurement, and technology guidance

3.4.7   In the forthcoming [national] guidance, to identify criteria for selecting the best technology for a particular location (which should include dumb gullies)

3.4.8   To make use of the LGA and STBs to support and enable knowledge sharing.

 

3.5                        In addition, the research identified areas where local authorities would welcome more support and/or guidance, including:

 

3.5.1   Procurement, including best practice and template documents.

3.5.2   use of data, including sharing of demand models and existing local authority data sources that can be used.

3.5.3   Member education and training on issues relating to EVs.

3.5.4   Use of pavements.

 

3.6                        The LGA welcomed recognition by OZEV and the Government that the scale and design of ORCS hindered the ability of councils to use it and deliver on their own and the Government’s ambitions. The successor to ORCS, the new £500 million LEVI fund has responded to many of the challenges raised in the LGA’s report. It is more generous, simpler and provides capability funding for local authorities to make use of it effectively. Taking Charge, the Government’s EV charging infrastructure strategy, explicitly considered our report’s findings and hence provides much clearer articulation of the role of local government in the roll out of EV charging.

 

3.7                        The primary goal of faster EV adoption is decarbonisation. EV charging strategies must sit within Local Transport Plans. But councils still lack the guidance and a clear funding envelope to help them generate sequenced pipelines of local transport schemes to support our ambitions to achieve net zero, improve air quality, achieve 50 per cent of all trips in urban areas walked and cycled by 2030, and deliver high-quality public transport systems. In some areas, more funding will be needed to support the charging infrastructure, while in others a combination of better buses, car clubs or parking policies will be the best route to decarbonisation and better transport accessibility.

 

 

  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?

4.1                        Government must provide long-term clarity to consumers and councils about the regulatory environment for public EV charging infrastructure and road taxes for EVs. 

Charging infrastructure

4.2                        Councils with public charging infrastructure have made long-term commercial agreements with charging point operators (CPOs). If the government decides that electricity pricing for public chargepoints will be regulated to match rates for domestic charging, this may make these commercial contracts no longer viable. At a time when many councils are facing extreme financial challenges to provide the most basic services to vulnerable residents, the government must think hard about the impacts of any regulation of pricing from public chargepoints. If changes are made, government must compensate CPOs and councils for any costs and not leave them paying the penalty for following government advice. 

4.3                        In our report, Understanding local authorities' views on a national road user charging system, the LGA took a sample of local authorities’ views towards the government’s plans to replace fuel duty. Those interviewed as part of the research agreed that a new way is needed for electric vehicles to pay to use roads to replace lost fuel duty. The report outlined that:

4.3.1   A national road user charging system is needed.

4.3.2   A national road user charging system must be seen to be fair (e.g., across different groups of the population, regions and between urban and rural areas).

4.3.3   Clarity is desired on the resulting funding model.

4.3.4   An adequate portion of the funds generated from a national road pricing system should be allocated to local authorities for transport investment.

4.3.5   Strong (national) government leadership and good communication is needed to encourage the electorate to accept the need and see the benefits of a national road user charging scheme.

 

4.4                        As more drivers switch to EVs, Government will find it increasingly politically difficult to deliver on its commitment to increase motoring taxes for EVs. The example of Clean Air Zones, where government asked local areas to deliver schemes as fast as possible without adequate funding to help drivers adapt, has highlighted the challenges. Residents and businesses who purchased their vehicles in good faith are unsurprisingly dismayed when presented with little time and scant funding to adapt to a new policy.

Car clubs and micromobility

 

4.5                        Car clubs and micromobility will help government to achieve its 2030 phase out target by helping to reduce the total number of EVs needed to electrify vehicle journeys, easing the pressure on UK and global manufacturing capacity. The LGA commissioned Steer to explore these new mobility options looking at car clubs and shared micro-mobility. It set out the significant benefits to areas that supported car clubs:

4.5.1   Cleaner vehicles. The average age of a car club vehicle is 1.6 years compared to 8 years for private cars. And BEVs (Battery EVs) account for 11 per cent of the car club fleet compared to 1 per cent of private vehicle.

4.5.2   Fewer vehicles. Work by CoMoUK says each car-club car can take up to 20 private cars off the road.

4.5.3   Reduced congestion: Access to a car club vehicle with each journey priced by the hour reduces the total number of car trips taken compared to access to a private vehicle where each journey costs only the amount of fuel used. Car club vehicles tend to have higher occupancy too.

4.5.4   More sustainable travel. CoMoUK found that 61 per cent of car club members used public transport at least once a week. This compares to the national average of only 19 per cent of people using a local bus at least once a week. The report also found that 37 per cent of users had used a bicycle once a week, compared to the national average of 20 per cent. here are emerging examples where car club operators and public transport operators collaborate. For example, Go North East and Co Wheels formed a partnership whereby the Go North East smartcard season ticket was combined with a car club membership including free membership, £30 driving credit and no monthly subscription fee.

4.5.5   Opening up access to EVs. Poorer households are less likely to own a car and will be the last group to benefit from EVs. Car clubs with BEV fleets can open up the exceptional transport benefits of cars and the environmental benefits of EVs for people currently unable to afford any vehicle, or a second vehicle for the household.

4.6                        Leeds City Council developed supplementary planning guidance which requires developers to fund memberships for car clubs at new developments. In the Leodis Square development, this policy has been implemented which has seen 61 residents join the car club scheme. This is particularly important as this development has a ratio of 0.3 spaces per unit.

4.7                        Car clubs offer a significant scope for expansion. The UK’s membership figures represent only around 0.5 per cent of the population compared to 3 per cent in Germany today.

4.8                        The potential of e-bikes, either private or public hire schemes, could further ease the demand for a private vehicle by 2030. The lack of a regulatory framework for private e-scooters and trial regulation of shared schemes makes it difficult for councils to plan for the long-term integration of these new modes. Widespread adoption of e-bikes and e-scooters before 2030, alongside investments in segregated lanes for them and improvements in local transport systems, including supporting car clubs, could have an impact on the levels of demand for private vehicles and in many towns and cities.

4.9           E-bike and e-scooters, car clubs, electric buses, and cycle lanes all serve the same decarbonisation goal as EV uptake for many journeys, but with wider benefits in areas of high congestion. As each area will have its own unique infrastructure, demographics and geographic, local authorities should have the freedom and flexibility to invest in the right transport solutions for their area while delivering on national ambitions.

5       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?

 

5.1                        Public chargepoints are more challenging for commercial provision where the consumer demand is weaker, due to higher levels of off-street parking and/or lower levels of EV uptake due to lower incomes.  The ‘EV chargepoint grant’ for landlords and tenants and the ‘EV infrastructure grant’ for landlords supports residents of multi-occupancy buildings or high-rises.

 

5.2                        Councils have worked hard to provide chargepoints on-street and at council car parks to enable residents without access to off-street parking to charge their vehicles. The LEVI fund will enable more chargepoints, such as through mobility hubs, to provide options for residents without off-street parking. The major challenge is that these schemes must be commercially viable due to the funding constraints councils face.

 

5.3                        The cost of on-street charging is higher than home charging, especially with overnight tariffs or the potential to use home solar power generation. Any government policy to reduce the costs for users of the public chargepoint network must not force the costs onto councils, as they do not have the flexibility within their budgets to take on these costs.

 

5.4                        Currently, VAT on domestic electricity is charged at 5 per cent, however, those using public charge points to charge their EV have to pay VAT of 20 per cent. Domestic tariffs for charging an EV are already considerably cheaper than public chargepoints, and even more so compared to rapid chargers. A recent Which report states that from 1st October 2023 a household with special off-peak domestic charging tariff, could pay just 3.8 pence per mile to charge their EV, with regular public chargers costing up to 16 pence per mile and rapid/ ultra-rapid chargers costing up to 25 pence per mile. The difference in VAT widens the gap. Aligning VAT of non-residential EV charging with the domestic rate would help incentivise the switch to EVs and also reduce the differential in charging rates for those people who do not have a driveway. If the Government were to do this, it would be bringing in another exemption to VAT and a decision would need to be made on recovering lost revenue to the Treasury.

5.5                        Councils are also mindful of ensuring pavements remain accessible and clear of charging clutter, so that public highways remain public and accessible to non-EV users. There are challenges arising from EV drivers claiming space outside their homes for charging, which can push out non-EV drivers who also rely on the space for parking.

 

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

 

6.1                        There are many, increasing demands on the grid for new housing, industrial uses, as well as the electrification of motoring and home heating. Increasing grid capacity is vital for local economies and decarbonisation. In Hounslow, Ealing and Hillingdon, a lack of grid capacity due is limiting the development of new housing, potentially until 2030. 

 

6.2                        Government must work with Distribution Network Operators (DNOs) to ensure that greater resources are available so that grid access is not a bottleneck to the new housing, and EV uptake that our communities and the country need.

 

6.3                        Given the likely additional increase in demand for electricity from the transition to EVs it is important that as much as possible is generated from a renewable source and that there are incentives in place for EV chargepoint operators to use renewable sources.

 

 

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

 

7.1                        DNOs are a vital partner for councils, business, and government. Their capacity to accelerate connections to the grid must be supported. The existing collaboration with councils and CPOs to support the roll out EV charging infrastructure, where the capacity is available and conditions are suitable, should be strengthened.

 

7.2                        LAs working with and through Subnational Transport Bodies have shown that they can work with DNOs such as through Transport for the North’s regional steering group and their Electric Vehicle Charging Infrastructure (EVCI) model, which helps LAs and DNOs make the most efficient use of data and resources to roll out EV charging infrastructure.

 

 

8       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? 

 

8.1                        Local authorities are supporting the roll out of the EV chargepoint network to meet local needs.

 

8.2                        This does not mean that every application for sites on public or private land will be granted permission. Public space has many uses, and local authorities must balance the desire to support on-street EV charging with the primary role of pavements to provide equal and unimpeded access to all residents. Councils are happy to support public chargepoints on private land where this fits into local plans. 

 

8.3                        The level of public chargepoint provision varies across the country and demonstrates that rapid rollout is possible under the current planning system. Westminster City Council has supported over 2,200 public, largely on-street chargepoints. The planning system is not a major barrier where the business case is strong enough and clear enough for a council to commit to. As the number of EVs on the road continues to grow, the business case for public chargepoints will also grow.

 

8.4                        The Government helpfully updated Building Regulations with ‘Approved Document S: Infrastructure for charging electric vehicles’ in December 2021. From June 2022, all new build homes with associated parking (including those undergoing major renovation), and buildings undergoing a change of use, will require installation of EV charging infrastructure during construction. New non-residential properties, such as retail and commercial builds, will also have to install charging infrastructure. This requirement can help to future proof assets.

 

8.5                        One major challenge many councils see for public chargepoint provision is that it remains a nascent industry. Consumer behaviour, government regulation, and technology may mature in many different ways. For example, the emergence of solid-state battery technology could more than double the range and reduce the charge time to minutes for EVs – drastically changing the business model for future chargepoints. The broad scenarios for chargepoint demand models set out by government highlight this uncertainty. It is important that councils have a strong evidence-based approach to policy. Letting some areas take the lead, while others wait-and-see approach is a prudent response to such uncertainty.

 

 

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

 

9.1                        Local authorities understand the challenges to EV take-up within their communities. Rural residents are more likely to have off-street parking than urban residents. This provides access to the best value domestic tariffs for charging. The increasing range of EV batteries means that the demand for public chargepoints as they go about their day-to-day business may be lower.  But the higher average mileage of drivers in rural areas compared to urban areas provides greater carbon savings and lower running costs for rural drivers of ICEs who switch to EVs compared to urban drivers. 

 

9.2                        In more built-up areas, the level of off-street parking is lower, making public provision much more commercially viable. These conditions mean that CPOs can offer urban and suburban councils revenue generating deals, taking advantage of lamp post chargepoints, for example. Car parks and business or residential sites can take care of themselves in most areas. 

 

10  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?

 

10.1                  Local authorities are committed to reaching Net Zero, and many have committed to going further and faster than the Government’s target. Although the provision of public EV chargepoints is not a statutory service, councils are already playing a major role in supporting the phase out by providing EV charging infrastructure and improving local transport systems that help to reduce car dependence. 

 

10.2                  The LGA welcomes the proposed government policy in this area but needs to see the government follow through and deliver on it. An anticipated update on guidance on Local Transport Plans (LTPs) is welcome, but at the time of this submission councils are still awaiting its publication. To allow councils to deliver on Local Transport Plans, they need adequate funding. Funding for local transport should be based on the quality of a LTP with a budget envelope and allocations provided in advance, over at least a 5-year period, so that they can work as concrete, cohesive plans and not bidding documents.

 

10.3                  The LGA has long highlighted that delivering funding via competitive bidding processes and short-term schemes is inefficient.

 

10.4                  LTPs can be the tool that ensures that every pound of public spending achieves the best outcome that the Government and councils share: how to achieve Net Zero as sustainably and efficiently as possible, improving air quality, getting 50 per cent of journeys in towns and cities by walking and cycling, delivering a sustained recovery in bus services, and supporting the potential for new mobility options such as car clubs and electric bikes and scooters.  Supporting the uptake of EVs should fit within, not outside, this plan. 

 

10.5                  Councils continue to face significant resourcing challenges within their planning departments, which play a key role in delivering EV infrastructure. The increase in planning fees by 35 per cent does not match the 57 per cent that LGA research has found is required for council planning departments to break even and solve capacity issues that frustrate councils, residents, CPOs and DNOs. We are calling for councils to have the ability to set planning fees locally, so they can recover the full costs related to administering planning applications. This would help to future-proof the sector and ensure planning departments can continue to support the deliver of the infrastructure the country needs.

 

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