Written evidence from the Association of British Insurers (ELV0080)


ABI and Thatcham joint response to House of Lords call for evidence on Electric Vehicles


The UK insurance and long-term savings market and the ABI


The Association of British Insurers is the voice of the UK’s world-leading insurance and long-term savings industry. A productive and inclusive sector, our industry supports towns and cities across Britain in building back a balanced and innovative economy, employing over 300,000 individuals in high-skilled, lifelong careers, two-thirds of which are outside of London.


The UK insurance and long-term savings industry manages investments of over £1.9 trillion, contributes over £16 billion in taxes to the government and supports communities across the UK by enabling trade, risk-taking, investment and innovation. We are also a global success story, the largest in Europe and the fourth largest in the world.


The ABI represents over 200 member companies, including most household names and specialist providers, giving peace of mind to customers across the UK.


Executive summary


  1. We support the government’s ambitious 2030 and 2035 goals which have galvanised progress within the EV ecosystem, however, significant steps still need to be taken before we can achieve those targets.


  1. Concerns remain about the vehicle repair network and its ability to support a widespread electrification of the vehicle parc. The government has a role to play in continuing to fund and support the retooling and reskilling of automotive technicians. Beyond the shortage of trained technicians, there also needs to be a concerted effort to support the independent repair network, particularly in terms of access to proper tools and parts. Both these measures will be crucial to keeping the cost of repair down.


  1. We commend the government on its role in convening stakeholders to create a standardised battery health indicator system, recognising the credibility that government backing could add to it. A system that could help diagnose both the battery cell health and capacity would lend confidence to secondhand buyers and also give a much more accurate estimate of lifetime costs and insurance costs. On vehicle batteries more widely, there also needs to be more research and investment in battery end-of-life practices to ensure that residual value is reinjected into the supply chain.


  1. Charging infrastructure is a priority for the government and a key pillar in the widespread adoption of EVs. We encourage continued collaboration with many stakeholders from insurers, vehicle manufacturers, and local authorities, to name a few to ensure that access to vehicle charging is safe, economical, and equitable.


  1. Crucially, we are calling on the government and other stakeholders to add to a nuanced and fact-based discussion on EVs to reduce misinformation and disinformation in public discourse. We want to arm individuals with the information necessary to make responsible financial and environmental decisions about their transport needs.


  1. We appreciate the opportunity to feed into this House of Lords’ inquiry into Electric Vehicles. The industry stands ready to continue this dialogue and collectively work towards the electrification of the UK’s vehicle parc.



Question 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. We support the government’s ambitious target to phase-out the sale of petrol and diesel engine cars and vans by 2030 and hybrids by 2035. The government needs to closely work with the wider automotive industry to ensure that it is prepared to support the widespread adoption of zero emission vehicles (ZEV).


  1. There are concerns about the current state of the vehicle repair network and its ability to support an extensive electrification of the UK’s vehicle parc. According to the Institute of the Motor Industry (IMI), 39,000 UK mechanics are now EV-qualified. Even though this figure has been steadily increasing, they estimate that there could be a shortage of around 16,000 EV-qualified mechanics by 2032.[1] This deficit may increase the cost of repair and cost of insurance and the long wait times may discourage EV ownership. We are already seeing the impacts with BEV claims already ~25.5% more expensive than their ICE equivalents and are taking ~14% longer to repair. The government has a role to play in better funding and facilitating the reskilling and retooling of the repair sector to ensure that is it prepared to cope with the growing demand.


  1. Contributing to this issue is the growing trend for vehicle manufacturers to only sanction in-house repairs. In some cases, independent repairers have not been able to support repairs due to a requirement to use proprietary diagnostic equipment, tools, and parts in order to work on certain vehicles. We believe that more needs to be done to enable independent repairers to operate to give customers more choice, to reduce repair costs, and to support an already stressed repair sector. This would include safeguarding fair market access for independent repairers and putting limits on proprietary diagnostic tools and parts used in vehicle repair.


  1.                     In order to ensure that the 2030 and 2035 targets are met, we also need to better support the lifecycle of EVs. BEV batteries are a significant percentage of the original vehicle value, which, at present, poses a threat to the established economic model of vehicle repair. Despite the relatively small number of BEVs in the market, there is already a lack of affordable or available repair solutions, inadequate post-accident diagnostics, and limited availability of recycling and reusability options. Without meaningful change, there is a strong likelihood that claims costs will continue to rise disproportionally. Modelling shows that in 2022, 9400 vehicles were potentially involved in an accident which could result in battery inclusion in a post-accident repair. This is estimated to reach up to 260,000 vehicles annually by 2035.


  1.                     A key intervention to facilitate a robust secondhand market would be the establishment of a recognised battery health indicator system. For instance, at the point of sale, consumers could be provided with a ‘statement of health’ about the battery. This could help diagnose both the battery cell health and capacity, lending confidence to secondhand buyers and giving a much more accurate estimate of lifetimes costs and insurance costs. The government has a role to play in convening relevant stakeholders and continuing to fund and incubate promising technologies that could serve as a commercial solution. Furthermore, establishing a system of battery recycle or reuse could further help reduce costs and ensure that residual value is passed back onto customers. Feedback from the vehicle recycling industry in the UK is that no value is being recovered from UK based BEV batteries and in fact it costs money to dispose of batteries. Those costs include export of materials to Europe and re-import of waste.


  1.                     Furthermore, we know that one of the biggest most cited obstacles to EV adoption is the lack of charging infrastructure. This is especially true of certain dwelling types which are not conducive to EV charging such as high-rise buildings and terraced houses. Rural dwellers may also face issues related to lack of charging infrastructure density. The government should incentivise commercial charging operators to expand to regions that are not independently economically viable, but necessary in expanding EV ownership to rural areas. The government should also work closely with local authorities to help properly map and predict charging demand to ensure that access is fair and equitable. Further detail of this is captured within our answer to question 33.


  1.                     Lastly, there are many external factors that could potentially impact the ability for the government to achieve the 2030 and 2035 phase-out dates. For example, macroeconomic factors such as continued inflation and rising cost of living may delay EV purchasing decisions or add friction to widespread adoption.



Question 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?


  1.                     We are supportive of the government’s ambitious 2030 and 2035 goals which have galvanised progress within the EV ecosystem, however, significant progress still needs to be made before we can achieve those targets.


  1.                     There is some discourse that suggests vehicle manufactures are primarily focused on meeting production and sales targets but not necessarily on affordability or sustainability in the market. Developments amongst European manufacturers have situated them in a more advanced position on sustainability, but this is not reflecting practical post-accident or end of life disposal options in the UK. Moreover, with the European market setting 2035 targets, many global manufacturers may inevitably focus more heavily on this timeframe.


  1.                     Driving targets around the lifetime sustainability of vehicles in the market, availability of information, spare parts, repairability strategies and recycling options would be key to supporting sustainable adoption. Targets around charging infrastructure may also be a powerful tool.




Question 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?


  1.                     Grants, such as those obtained through the previous Electric Vehicle Homecharge Scheme and Workplace Charging Scheme, have played a crucial role in promoting the adoption of EVs. This has mainly been by providing financial incentives to both individuals and businesses, but many grants have also helped to establish charging infrastructure, which in turn has benefitted the wider population of electric vehicle drivers.


  1.                     Tax benefits have also helped with the adoption of EVs. This is the case both for individuals and companies, for instance, fully electric vehicles that produce no tailpipe emissions are currently exempt from paying road tax. However, it should be noted that this is due to end in 2025, with zero tailpipe emission cars first registered on or after 1 April 2017 set to be liable to pay road tax. When used as a company car, EVs generally allow employers to benefit from lower Benefit-in-Kind (BiK) tax rates and reduced National Insurance contributions (NICs) on salaries. An example by CarWow demonstrated a potential £4,500 annual tax saving by choosing an electric car over a petrol car.[2] However, industry is conscious that as the EV parc increases, government will need to provide clarity on filling the tax gap that ICE vehicle previously generated.


  1.                     Most of the above are also captured within the Road to Zero strategy, which was designed to facilitate the transition to electric vehicles. It has set ambitious emission reduction targets, such as ending the sale of new petrol and diesel cars and vans by 2030. The strategy has also encouraged research and innovation in battery technology and charging solutions to address technical barriers. Moreover, it has, to some extent, raised awareness amongst consumers about the benefits of EVs.




Question 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?


  1.                     While EV adoption is increasing, they still only made up 13% of new vehicle registrations in 2023 according to the SMMT.[3] While this figure is projected to increase, there is still a role for the government to play in increasing public knowledge of the realities of owning an EV to allow them to make responsible and informed decisions about their transport needs. 


  1.                     One of the biggest paradigm changes will involve how and when people can charge. For ICE vehicles, a majority of drivers will drive until the tank is almost empty, then refill a full tank. For EVs, it may be more prudent to “graze” – that is charging at every opportunity when they park at work, while out shopping, and at home. For most drivers, this eliminates the need for high-range vehicles and can help reduce range anxiety.


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


  1.                     There is still a certain amount of misinformation and scepticism in the market that could be improved with better education and awareness. For example, many still cite the fire risk that EVs pose. Research conducted by Thatcham concluded that the risk of fire for an EV and ICE are not significantly different. However, it recognised that EV fires burn much hotter and are more difficult to put out. There is one caveat being that most EVs on the market are quite new and it remains to be seen if the fire risk increases as the vehicle age.


  1.                     One survey of 2,000 non-EV-owning UK motorists found that 78% of drivers were incorrect when estimating the average distance, a fully charged EV can travel.[4] The same survey found that 58% of people were not aware of the potential monetary gains of owning an electric vehicle. And 35% overestimated the cost of charging an EV to full.


  1.                     Despite pertinent challenges related to the adoption of EVs, there is still a significant amount of negativity in the press, much of which is outdated or not based on fact. A prime example of this is the myth that EVs are worse for the climate than gasoline cars because of power plant emissions when in reality, EVs tend to have a smaller carbon footprint even when accounting for electricity generation.[5]


  1.                     At the same time, some believe that switching to an EV will be the most environmentally friendly option. In some situations, it may be better to explore car sharing options or driving an efficient ICE until end-of-life instead of immediately switching to an EV.


  1.                     Much of the publicly accessible information on EVs is highly polarised both positively and negatively with both extremes containing inaccuracies. An honest and engaged narrative, which is evidence-based and properly nuanced, will equip the public with the knowledge to make more responsible decisions for themselves and for the environment.




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


  1.                     Other organisations are better placed to respond to this question in detail.


  1.                     However, some accurate life cycle analysis (LCA) for modern EVs would help to understand the benefits and the importance of sustainability throughout the lifetime of the vehicles in the car parc. Most LCA calculations make out a perfect case and do not include important factors associated with long term sustainability for the lifetime of the vehicle in the UK car parc. Calculations should include typical allowances for accident repair and salvage, reflecting the specific challenges that exist with the BEV battery.




Question 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?


  1.                     Energy price caps for vehicle charging, road tax exemptions for ZEVs, and expanded low emission zones could certainly help reduce the total cost of ownership for EV owners. In addition, the government could continue or expand tax or rebate schemes for EV purchases and the installation of home charging capacity. The government could incentivise ownership by offering discounts at public charging stations where home charging is unfeasible such as multioccupancy high-rise blocks. Schemes could also make it more profitable for EV owners to sell surplus energy back to the National Grid via vehicle-to-grid balancing technology.


  1.                     Other specific initiatives could address potential increased costs, including the continued development of an independent repair network to reduce overall repair costs.


  1.                     On insurance premiums, the government could consider measures to waive the Insurance Premium Tax (IPT) burden on individuals who are purchasing motor insurance. 


  1.                     There is some concern about the secondhand value of EVs given the potential of supply shocks when commercial vehicle leases end. There are also questions about residual values as technology continues to develop. Government could explore grants or tax credits for used EV purchases as well.




EV Market and Acquiring an EV


Question 8: What are the main routes for acquiring an EV? Which aspects of these routes are working well, and which aspects could be improved?


  1.                     Other organisations are better positioned to answer this question.



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


  1.                     As above, there remains a gap in consumer knowledge that has led to sustained misconceptions about EVs, particularly in terms of economic cost and how well they perform. The main concerns relate to range anxiety, charging infrastructure, charging speed, upfront cost, resale value, lack of model variety and battery life. However, whilst these tend to be misconceptions several are grounded in some truth.


  1.                     One of the most cited obstacles to EV adoption is the lack of charging infrastructure. This is particularly the case for certain dwelling types that are not conducive to EV charging such as multi-occupancy high-rise residential buildings and terraced houses. Rural dwellers may also face issues related to a lack of charging infrastructure density.


  1.                     Another widely cited obstacle is the economic cost, both of purchasing the vehicle and running it. EVs do tend to command a premium, contributed to by the expense of batteries, the early-adopter ‘tax’ and the general trend of offering EVs only as high-specification vehicles. The average cost of an EV has been approximately £50,000 in recent years, however, there are now a number of sub-£30,000 models as well as finance and leasing options. Even still, this is likely to be financially unattainable for a large proportion of the UK population, particularly with the ongoing cost of living crisis. 



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


  1.                     There have been many different policies that have made EVs more affordable and accessible including EV car grants, benefit-in-kind tax for corporate EVs, waiving road tax for EVs, etc. While many have been effective, it is important to ensure that they are appropriate for the changing landscape. For example, interventions could be designed to provide benefit to secondhand EV buyers.



Question 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?


  1.                     Electric vehicles still remain prohibitively expensive for many buyers. This is also true of the secondhand market and government incentives should be aimed at both buyers of new and used EVs.


  1.                     For the range of new EVs, there are many new models that have come to market or will be coming to market in the next few years that will make EVs more accessible. However, while some of these vehicles may have a low sticker price, the total cost of ownership may not be as cheap as imagined.


  1.                     This is particularly true of new brands making their first foray into the UK market. The lack of widespread availability of parts or knowledge on how to work on new vehicles may make them more expensive to repair and insure, at least in the near term.



Question 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?


  1.                     The L-segment is comprised of many vehicle types ranging from 2 to 4 wheels and can include vehicles from motorcycles to microcar. While they are suited to certain environments, there is some concern over the safety of the vehicles.


  1.                     Most vehicles in the microcar category will underperform in safety metrics compared to regular passenger cars. Many may lack safety features that are standard on other passenger cars and the sheer difference in mass between microcars and other vehicles puts the former at higher risk during collisions. 




Question 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?


  1.                     Overall, prices in the second-hand vehicle market have generally increased over the past two years as supply chain issues have impacted the delivery of new vehicles. However, the second-hand EV market has been subject to some volatility and prices have dropped consecutively over recent months. According to Auto Trader, June 2023 marked the sixth consecutive month of year-on-year decline, with average EV prices (£31,430) falling by almost a quarter since their peak in July 2022 (£40,728).[6] This has largely been brought on by a significant increase in used EV supply as finance and leasing terms, particularly from large fleets, begin to end.


  1.                     Furthermore, several manufacturers including Tesla cut prices of new EVs earlier in the year which has caused some price fluctuation in the second-hand market.


  1.                     Analysts assert that EV prices are stabilising and the decrease in price does not reflect a decrease in demand. However, there is some concern from owners about residual EV values that may impact future purchasing decisions.



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


  1.                     Other organisations are better positioned to respond to this question.



Question 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?


  1.                     Battery degradation over time is a pivotal concern for the insurance industry. A key intervention to facilitate a robust second-hand market would be the establishment of a recognised battery health indicator system. A system that could help diagnose both the battery cell health and capacity would lend confidence to second-hand buyers and also give a much more accurate estimate of lifetime costs and insurance costs. Furthermore, establishing a system of battery recycle or reuse could further help reduce costs and ensure that residual value is passed back onto customers.



Question 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?


  1.                     Other organisations are better positioned to respond to this question.



Question 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?


  1.                     While we are unable to comment directly on the insurance premiums of ICEs and EVs, we can highlight some considerations that may drive variance between the two groups of vehicles. Crucially, insurance is priced based on risk, which amongst other factors may include the likelihood of a claim as well as the potential cost to repair the vehicle.


  1.                     The typical profile of EV drivers may have an impact on premiums. For example, EV drivers may be more likely to charge on their driveways or in garages, especially before the widespread development of streetside charging, which could make them less prone to damage from other vehicles.


  1.                     Since EVs are a relatively new technology, many EVs will come with significantly more standard safety features than older vehicles which could benefit the overall safety profile of the vehicle segment. Furthermore, with fewer moving parts than an ICE engine, maintenance of an EV could be cheaper, and parts could be less exposed to wear.


  1.                     Average EV prices are coming down as battery technology develops and as more entry-level options come to market. However, they still tend to be more expensive than their ICE counterparts and have historically occupied the higher end of the market. This means EV claims tend to be more expensive than ICE claims when the vehicle needs to be repaired or replaced.


  1.                     Batteries make up a large portion of a vehicle’s total cost. As previously discussed, there is a lack of affordable or available battery repair solutions, inadequate post-accident diagnostics, and limited availability of recycling and reusability options which will add to insurance costs.


  1.                     Furthermore, there are concerns about the current state of the vehicle repair network and their ability to support an extensive electrification of the UK’s vehicle parc. Addressing these issues could add downward pressure to vehicle repair costs.


  1.                     As above, government could consider measures to waive the Insurance Premium Tax (IPT) burden on individuals who are purchasing motor insurance. 


  1.                     Lastly, for insurers, it is important to not take questions related to EV insurance in isolation. The industry is aware of the intersection that EVs can create between home and motor when a vehicle is charging at home, for example. The risk of EV fire in commercial parking lots or underground parking spaces is also a consideration for property insurance and reinsurance more widely.



Experience of using an EV


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


  1.                     As discussed in responses to other questions.



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


  1.                     As discussed in responses to other questions.



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


  1.                     Other organisations are better positioned to respond to this question in detail.


  1.                     As discussed, there is good engagement in training and upskilling but there may be a need to address the types of skills required as the market grows and adapts. This is especially true as vehicles change and adopt new battery chemistries or other technologies. It is also important to remember that electrification is only one part of new vehicles, and these repair concerns will have to address increasing automation and connectivity as well.



Question 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?


  1.                     There is anecdotal reporting from businesses and the repair sector that local grid capacity and connectivity are significant barriers. Whilst the impact of this is not currently significant as BEV numbers in the market remain low, it does present a concern for the future.


  1.                     Uniform charging would be beneficial but should not limit the room for development of improved charging standards.



Question 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 standardized and reliable for consumers?


  1.                     Other organisations are better positioned to respond to this question in detail.


  1.                     However, we are pleased to see the inclusion of regular reporting and helpline requirements within the draft legislation, which will help to ensure public charging points are well maintained, which will likely reduce the chance of public charging points damaging EVs and increase user satisfaction.




Question 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?


  1.                     Other organisations are better positioned to respond to this question.


Question 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?


  1.                     There are certainly barriers to charging an EV for individuals who live in multi-occupancy buildings such as shared housing or high rise buildings. For example, the number of available chargers may not be sufficient to support the number of EVs in a given residential complex.


  1.                     There are a number of potential issues that government must consider in order to ensure that public charging is equitable compared to home charging. For instance, shared charging points may be more susceptible to wear and tear or even acts of vandalism. Hence, rigorous maintenance for shared charging points must be in place. Home charging is also considerably cheaper than public charging. Therefore, a comparably priced charging option will be key to wider public adoption.


  1.                     Moreover, the standardisation of public charging points could help improve accessibility and equitability. Making sure that charging points have support for people with various disabilities is fundamental. We are aware of and fully support the work of the Office for Zero Emission Vehicles (OZEV) and the British Standards Institution (BSI) to develop a national accessible charging standard for EV charge points.




Question 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?


  1.                     There are several organisations that have produced analyses on the total cost of ownership (TCO) for ICEs and EVs. Many point to the financial benefits of lower maintenance costs, government incentives including grants and tax breaks, and the lower average cost of energy versus fuel.


  1.                     For non-financial benefits, there are positive externalities associated with zero emissions and lower levels of noise pollution.




End of life disposal of EVs


Question 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?


  1.                     There are little to no commercially viable options for end-of-life management of batteries and EVs at this point in time. Whilst this is not currently causing issue, it is likely to become a significant risk to the public perception of the cost and sustainability of EVs in the future.



Question 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?


  1.                     There is currently a lack of regulation specifically focused on the disposal and recycling of EVs. Regulation should ensure that residual values are reinvested into the supply chain. For example, an end-of-life buyback scheme could ensure consumer benefit and create a more cyclical ownership model.


  1.                     However, there currently exists a gap in the market for a commercially feasible EV battery recycling scheme. In its development, there needs to be a focus on battery safety in addition to economic feasibility. This will be key to the long-term battery ecosystem.



Question 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 affect the flow of EVs into the second-hand market?


  1.                     There is significant residual value in end-of-life EVs. Critically, there are components and materials within the battery that could be extracted and sold, as well as parts from EV salvage. While economically viable, it may not be an environmentally sound practice. Regulations should be designed that give flexibility to maintain a robust secondhand market and ensure that the residual value is passed back onto customers.



National and regional issues


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


  1.                     Other organisations are better positioned to respond to this question.



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


  1.                     Other organisations are better positioned to respond to this question.



Question 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?


  1.                     Other organisations are better positioned to respond to this question.



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


  1.                     One of the most cited obstacles to EV adoption is the lack of charging infrastructure. This rings true for both rural and urban areas. Urban areas likely have more multi-occupancy high-rise residential buildings and terraced houses, many of which do not have residence parking let alone residence charging facilities. However, these areas will often benefit from higher levels of publicly available charging infrastructure. As above, there are issues associated with public charging infrastructure that government should look to address.


  1.                     Rural dwellers are likely to have suitable housing for private charging facilities but may face issues related to a lack of charging infrastructure density, mostly due to concerns over their cost-effectiveness. This is because the upfront investment needed to install a charging point will take longer to pay off in areas where there might be less immediate demand. Rural dwellers may also face increased range anxiety both from the lack of available public charging infrastructure and because of the necessity to undertake longer journeys.




Question 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?


  1.                     Government must ensure to include local authorities in the delivery of 2030 phase-out targets to ensure a coordinated approach that aligns local need with national plans. Local authorities should be involved in planning regulations to allow them to control the placement of charging infrastructure, ensuring it’s convenient and accessible for residents and visitors. Local authorities should also work with District Network Operators to ensure efficient integration of charging infrastructure with the grid.


  1.                     Government should develop clear guidance for local authorities to shape the overall national approach, with enough inbuilt flexibility for each area to design infrastructure in the most appropriate way. Moreover, local authorities must be well equipped by government to perform these duties, especially in terms of funding, training, and data access.




International perspectives


Question 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?


  1.                     The government should seek to learn from Norway, the Republic of Korea, the Republic of Ireland and the Netherlands. These approaches have used a multifaceted strategy that the UK should try to emulate. This involves a blend of financial incentives, industrial support, and behavioural change measures. Clarity and unwavering government support are also necessary to provide the motor manufacturing industry with certainty and nurture the desired environment.


  1.                     Government should be ambitious with its targets and learn from other nations' experiences to build a strong policy platform, enhancing the UK’s position in the global rankings. Private investment returns should be assured as the EV market relies on significant public investment until consumer habits shift. Government must take a proactive role, exemplified by ambitious tax exemptions and a supportive climate for private enterprise. It should enable local governments to lead in charging infrastructure rollout, clarifying responsibilities and ensuring provision keeps up with demand. Finally, open standardisation and interoperability of the charging network can maximise benefits for all stakeholders.


  1.                     Overall successful countries have ensured effective collaboration among government, authorities, manufacturers, utilities, and charging operators, which has created a positive experience for the end consumer.







[1] https://tide.theimi.org.uk/sites/default/files/2023-04/EV%20Technicians%20forecast%20report%20March%202023v2.pdf

[2] https://www.carwow.co.uk/guides/running/company-car-tax-on-electric-cars#gref.

[3] https://www.smmt.co.uk/vehicle-data/evs-and-afvs-registrations/

[4] https://elmodrive.com/electric-cars/attitudes-perceptions/

[5] https://www.epa.gov/greenvehicles/electric-vehicle-myths

[6] https://www.fleetnews.co.uk/news/latest-fleet-news/electric-fleet-news/2023/07/06/used-electric-vehicle-prices-down-19-year-on-year