Written evidence from Zapmap (ELV0102) 

Submission to: Lords Environment and Climate Change Committee

Organisation: Zapmap Ltd

About Zapmap:

As a pioneer in the early days of electric cars, Zapmap was founded in 2014 with a mission.

to make EV charging simple, wherever you go. Available on iOS/Android and desktop,

the Zapmap app helps EV drivers search for available charge points, plan longer journeys, pay for

charging, and share updates with other drivers.

Zapmap currently has around 650,000 registered users and over 95% of the UK’s public

points on its network, more than 70% of which show live availability data.

In addition to the app, Zapmap tracks the EV charging market and provides data and insights to organisations to help them on their electrification journey.

Submitted by: Melanie Shufflebotham, Co-founder and COO

Date: 15th September 2023

Questions:

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?

Yes achievable, although some challenges:

• 2030 target (all cars have a plug - PHEV - no petrol/diesel)
• On track to have >1.6 million EVs (BEVs & PHEVs) by end 2023
• EV sales represent around 23% (2023 YTD) with trend >25% by end 2023.
• Since 2019, EV sales have increased by 6.6% per year (average) as a proportion of the market (3.2%, 10.7%, 18.6%, 22.9%). 
• Trend supports market share of at least 75% by 2030 achievable with current incentives (see below).
• 100% therefore achievable with sustained incentives for PHEV and stronger disincentives for ICE from 2025 (see below).

• 2035 target (all cars full electric BEV)
• On track to have 1 million BEVs by end 2023
• BEV sales represent around 16% (2023 YTD) with trend >20% by end 2023.
• Since 2019, BEV sales have increased by 5% per year as a proportion of market (1.5%, 6.6%, 11.6%, 16.6%).
• Trend supports market share of at least 80% by 2030 achievable with current incentives (see below).
• 100% BEV therefore achievable with sustained incentives for BEV and stronger disincentives for ICE from 2030 (see below).
• Reality check: Norway already supports 80% BEV market - https://insideevs.com/news/670561/norway-bev-sales-may-2023/ 

Given that the 2030 PHEV/2035 BEV targets may need an additional 25%/20% stretch, it is likely that the market will need further and sustained incentives/disincentives to meet 100% targets. However, these may not be required as once the market passes the 50% mark then the private sector is likely to accelerate its own investment in PHEV/BEV at the expense of ICE production.

What steps from the government?

• Most important next step is to reaffirm commitment to 2030 ban on new petrol and diesel cars and in parallel the ZEV mandate. 
• Other important elements to ensure sufficient infrastructure to support the EV parc: investment in local rollout of chargers to support those not able to charge at home (LEVI+); unblocking the planning / grid issues which are slowing down charger deployment; reduce VAT on electricity for public charging to be the same as domestic; monitor compliance of Public Charger Regulations (pricing, reliability, 247 support and payment elements) to ensure excellent and improving consumer experience.
• Other key tax signals: Maintain differential Company Car Tax (CCT) incentives - Lower BIK rates – for as long as possible to incentivise BEVs and disincentivise ICE, Increase differentials on First Year VED to incentivise BEVs and disincentivise ICE.

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?

Yes, the 2030/2035 targets together with the ZEV mandates (see below) due to be introduced in 2024 are sufficient to incentivise the UK EV market from the supply side. However, these will need to closely be aligned with the demand-pull measures for consumers (see below). OEMs have a number of positional strategies on meeting these 2030/2035 targets with specific strategic groups emerging:

• Fully committed (Tesla, NIO, VW, JLR, MINI, Nissan, Volvo)
• Cautiously committed (Ford Europe, BMW, Renault, Stellantis)
• Resistant/late adopters (Honda, Toyota)

The relative commitment of the OEMs depends on a number of factors including existing ICE investments, tech strategy (ICE, mild-hybrid, full-hybrid, PHEV, BEV, hydrogen), global markets serviced (US, EU, Asia, etc), location of parent company (USA, EU, South Korea, Japan, China).

A key consideration for OEMs committed to BEV powertrains are the locations of Gigafactories to supply sufficient batteries to satisfy demand. In the UK, we currently only have secured two production facilities (at Sunderland and Coventry) with a max capacity of 70 GWh capacity which will support 1.4 million units annually. With respect to its BEV targets, without further investment in battery product facilities, the UK will be heavily dependent on car imports to meet its 2035 EV target. Ref: https://cicenergigune.com/en/blog/world-map-gigafactories 

As already mentioned, ZEV mandates are planned for introduction in 2024. Under the plan, from 1 January 2024, ZEV targets will require an increasing percentage of a manufacturer’s annual new car and van sales in the UK to be zero emission until reaching 100% in 2035. It is our contention that these sales mandate is an integral part of meeting the 2030 and 2035 targets phasing out ICE vehicles and supporting the rapid adoption of EVs.

Moreover, it should be noted that “Most respondents [of the ZEV Mandate consultation] … suggested that the car ZEV uptake trajectory should be more ambitious than the…trajectory proposed. A substantial portion of these respondents favoured following the Climate Change Committee’s (CCC) Balanced Net Zero Pathway trajectory.” Ref: https://www.gov.uk/government/consultations/policy-design-features-for-the-car-and-van-zero-emission-vehicle-zev-mandate/outcome/government-response-and-outcome-to-technical-consultation-on-zero-emission-vehicle-mandate-policy-design#part-a-zev-uptake-trajectories--stakeholder-views-and-government-response 

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?

Large number of financial incentives for EVs and ULCVs have been in place since 2010:

• Plug-in Car Grant (PICG) until June 2022
• Current purchase grants for: Wheelchair accessible vehicles, Motorcycles and mopeds, Vans - Plug-in Van Grant (PIVG), Trucks, Taxis
• Company Car Tax (CCT) incentives - Lower BIK rates - often delivered with Salary Sacrifice purchase schemes.
• VED annual vehicle tax - Zero-rated until 2025
• Home (now only supporting flats) and workplace charging equipment - EVHCS/ Work charge.
• National support for public charging infrastructure: GoUltraLow schemes - specific cities - Oxford, Dundee etc.
• ORCS - https://energysavingtrust.org.uk/grants-and-loans/on-street-residential-chargepoint-scheme/ which is being replaced by
• LEVI scheme - https://energysavingtrust.org.uk/grants-and-loans/local-electric-vehicle-infrastructure-scheme/ - £381M capital + £38M capabilities = £400M
• Rapid charging fund - £950M to upgrade elements of the motorway service. 
• GoUltraLow website was in operation until 2021/2 - simple clear information on EVs.

The above incentives have significantly supported the update of ULEVs (including PHEVs and BEVs) since 2010. Of the ones listed above there is evidence that the most effective schemes have been the purchase grants together with the company car tax benefits, the latter continuing to provide a significant driver of BEV sales in the UK. However, with the loss of the PICG in 2022, the CCT (and salary sacrifice) is now the key measure which is incentivising BEVs in the UK.

On the charging front the EVHCS scheme was very successful for consumers (if challenging from an admin point of view for installers). However, going forward, given the benefits of having a home charger, government support should be focused on helping local authorities to provide local charging for those who do not have off-street parking. It is hoped that the LEVI scheme will provide sufficient incentives and support for this.

Given the amount of misinformation in the market, there is also a case for reviving the old GoUltraLow website to provide independent factual information on EVs and charging.

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?

• Behavioural change research shows that environmental information is more effective in influencing change of the most environmentally conscious - with financial incentives (and disincentives) more effective in changing behaviours of the remainder of the population.
• There is therefore a continuing need for effective communication - about key information and the availability of incentives - as a relatively low-cost change measure.
• Clear messages about EVs from the Government are important for both consumers (confirming the environmental benefits, cost reduction opportunities, etc) and industry (as a signal of intent and technology policy).
• Government information complements communications from the private sector and ensures consumers continue to receive information from an independent source to balance information provided from companies, trade groups and other interest groups.

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

• Lots of misinformation and confusion about EV purchase, running costs, comparison with ICE models and charging terminology

• Part of confusion due to rapidly changing electricity prices and the large number of charges point operators (CPOs) who each have a number of tariffs (PAYG, subscription, etc).

• Need more environmental and cost calculators such as:
• https://www.zap-map.com/tools 
• https://www.transportenvironment.org/discover/how-clean-are-electric-cars/?

• Many OEMs present hybrids as ‘self-charging electric vehicles’ which is a misrepresentation of the technology. Hybridisation is more accurately an efficiency optimising engineering strategy. Moreover standard ‘hybrids’ cannot be refuelled directly by the grid. All EVs must have a plug to be classed as a PHEV or a BEV.

• Inclusion of hybrid UK sales data also creates confusion about the actual market development of the EV market. Hybrids (HEVs) and Mild Hybrids (MHEVs) often conflated with EVs which are capable of electric-only propulsion for a significant range. EVs should only include PHEVs and BEVs, and all reference of hybrids should be reported as standard petrol vehicles. 
• See: https://www.smmt.co.uk/vehicle-data/car-registrations/ 

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

• Reduction in CO2 - 69% reduction over lifetime for medium car - 55.6 tonnes vs 18.9 tonnes - reduction of 36.7 tonnes - Assuming 300 million cars in EU+EFTA+UK, current carbon intensity of vehicle production and electricity generation, this equates to a reduction of 11 billion tonnes CO2 saved over 15 years. This is likely to be an underestimate due to ongoing reductions in carbon intensity of the electricity grid across most of EU+EFTA+UK.
• Improvement in air quality due to increasing EVs and Clean Air Zones (which incentivise the use of ULCVs and EVs). The annual mortality of human-made air pollution (a proportion of which is caused by ICE vehicles) in the UK is roughly equivalent to between 28,000 and 36,000 deaths every year. Ref: https://www.gov.uk/government/publications/air-pollution-applying-all-our-health/air-pollution-applying-all-our-health 
• EVs could drop noise pollution by nearly 40%, and 20% people in UK have their health affected by noise pollution (much of which is generated by road traffic). Ref: https://www.vehiclecontracts.co.uk/blog/could-evs-solve-the-uks-noise-pollution-problem/ 

7. What are the likely costs that will be faced by consumers as a result of the Government’s phase-out dates for non-zero emissions vehicles? Are there policies or initiatives that the Government could use to specifically target barriers arising from unpredictable costs to the consumer, for example significant fluctuations in the cost of electricity, changes to road taxes, or the introduction of low emission zones?

• The increasing number of EVs on UK roads is already having an impact on CCT and VED tax revenues. At some point the Government will have to either increase the company car tax rates and circulation taxes for EVs or use the market switch as an opportunity for Differential Road User Charging (DRUC) to start to recoup its road transport taxation losses. Much work has already been done by the Dept for Transport and Campaign for Better Transport to plan for this eventuality. Ref: https://bettertransport.org.uk/. However, given that EVs only account for 4% of vehicles on the road, this should not be introduced until it reaches a higher threshold.

• There is currently a fairness and equity issue regarding the VAT payable on EV charging as, under existing rates, EV charged at home only pay the domestic rate of 5% VAT on the cost of the energy, compared with 20% which is levied on EVs charged at public charging network supplied by charge point operators (CPOs). While one CPO did try to use the 5% rate, in 2021 it was forced to align with other CPOs at the 20%rate. This VAT difference inherently benefits higher income households who are more likely to have a private drive at which they can install a private charger. In contrast, lower income households are more likely to have to charge their car locally on public ‘community’ chargers, or on the main public network - both of which use the 20% rate. Aligning the two rates to 5% would have two positive impacts: (i) would provide an energy and cost benefit to all EV users irrespective of whether they own a private drive, and (ii) improve the equity of EV use for households across all income ranges.

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?

• Currently there are 48,450 charge devices at 29,062 locations across the UK. This is an increase of 42% from August 2022 when there were 33,996 charge devices across the UK. (Zapmap database August 2023)

• Charging can be broken down further into four power ratings - with “slow (<7kW) and “fast” (8<25kW) low powered AC chargers and “rapid” (25/50kW-99kW) and “ultra rapid” (100kW+) high powered DC chargers.

Please note that these bandings are going to be changed by OZEV in the near future, but this is the way it is currently reported.

The relative size and growth rates of chargers by these power ratings can be seen below:

In addition to the above charging devices there are an estimated 680,000 chargers which are installed at peoples houses (80% of the 850k BEVs on the road) and a further unknown number at workplaces.

The charge devices have different power ratings, different charge times and support different use cases. The UK should not be chasing a number but rather making sure there are the right chargers for the right use case in the right place. There needs to be development on a number of fronts:

1. En-route charging - this is mainly to support EV drivers on longer journeys, the chargers need to be high powered and as fast as possible. Often, they are found in “charging hubs” of 6 or more devices, often close to the strategic road network. This area as you can see in the numbers above is growing well and mainly by the private sector. There is a large number of rapid / ultra rapid chargers in the pipeline, and this needs to continue to rollout at pace to support the needs of the growing EV community, key constraint is issues with planning, grid connections and lack of standardisation of process across organisations. In some areas (such as mid Wales), there may be market failure and needs some extra support by the government to ensure that there is sufficient provision.

2. Local charging - this is critical to support those who do not have off-street parking – an estimated 20% of current EV drivers, and up to 40% of households. There are multiple solutions available from lamp post charging to on-street posts, gullies, charging bridges, community sharing and local charging hubs.  There is no one-size fits all solution. However local authorities play a critical role here. Across the UK some local authorities have really engaged and have good provision, others have not. Government data which is based on Zapmap data https://www.gov.uk/government/statistics/electric-vehicle-charging-device-statistics-july-2023 shows this.The LEVI scheme should be a support on this, allocation of funds is in process and we should see the chargers rolling out in 2024. If the implementation does not work effectively, further measures may need to be taken.

3. Destination charging - this is charging at places where vehicles stop for 20 mins or more - could be at supermarkets, or attractions, hotels etc. This currently accounts for the majority of charge devices, they are typically slow/fast sub 25kW chargers, although there are some rapid / ultra rapid chargers. This will probably be driven by the owners of the locations and will become some form of hygiene factor e.g if you are a a hotel you will need to be able to offer charging to your guests. Limited intervention needed, only to make sure that charging points are simple to use and access.

4. Community charging where the extensive network of low powered charging is shared across different groups and individuals and reduces the need for installing a high volume of new charging points is also provides a way that the charging network can be extended.

Single charging standard - currently there is a key standard Type 2 Mennekes for AC charging and CCS for DC charging.

Whilst there are many second-hand Nissan Leafs and there are still some new Nissan Leaf’s being sold (which use a CHAdeMO connector), the vast majority of EVs support the CCS standard.  In our opinion there is no legislation needed as the market is moving (has moved) to CCS, the only issue is to make sure there remains enough CHAdeMO connectors to support the legacy EVs.

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?

The consumer consultation covers important issues for EV drivers - contactless payment on 8kW+, transparent PAYG pricing, 247 helpline and 99% reliability.  The biggest issue reported with using the public network in Zapmap’s 2022 survey was charge points not working, so the 99% reliability mandate for rapid+ devices is crucial. 

Zapmap tracks the number of out of service charge points based on live status data on c. 70% of all the chargers on the Zapmap database. In August 2023 this was running at c.4% of all devices, this has shown an improvement from c.7% last year. However, this is still quite a way from the objective of 1% - i.e., 99% reliability.

Whilst the government can legislate for 99% reliability, there must be a system in place to measure this by network in a fair and effective manner and also some way to enforce these regulations such as issuing fines.

85% of respondents in the 2022 Zapmap survey selected paying by contactless within their top 3 preferred ways to pay for charging. So, mandating contactless on devices 8kW and above addresses this desire. Currently the vast majority of +50kW chargers are already contactless.  The industry is also developing fully automated method for charging and payment. One such is the use of the ISO15118 standard which enable users to 'Plug & Charge' their vehicle with use of a payment card or app. This will however require continued coordination by OEMs, CPOs, and MSP and (if adopted) is likely to take the rest of the decade to be widely available across the majority of networks and usable by most vehicle brands.

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?

Many organisations such as Zapmap already have bi-lateral agreements with charge point operators to share data. The benefits to the consumer are that these organisations have created applications which show consumers where the charge points are and whether they are able to be used.

There are some charges point operators, with Pod Point and Tesla being the key examples, that do not currently share their data widely. Thus, the Public Charge Point Regulations 2023 would benefit consumers as this charge point operators would need to provide data, and then this data could be incorporated into third party applications. However, the charge point operators that do not share their data are an increasingly small proportion of the installed charge points, so this is a marginal benefit to consumers.

Sharing up to date pricing data would be a benefit to consumers, as this is patchily available at the moment, and the third-party organisations could display this / provide useful information to consumers.