Written evidence from Dylan Khoo (ELV0105) 

 

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?

1.1. Though well intentioned, the UK’s target to restrict sales to PHEVs and BEVs after 2030 may cause issues. By 2030 the PHEV market will be in decline as they are not compliant with the EU or the UK’s 2035 zero emissions mandates. Many brands plan to sell only BEVs ahead of this 2035 date as they do not want to invest in a technological dead end. This includes Ford (2030), Audi (2033), VW (2033), Mercedes (2031), Vauxhall (2028), Peugeot (2030), MINI (2030), and Renault (2030), among others.

1.2. As well as this, PHEVs are generally larger SUVs or executive cars due to the added complexity and volume from fitting both ICE and electric propulsion. There are none available in the supermini segment, for example. This will not change as time passes lowering battery costs will mean that small and medium sized BEVs will reach price parity with their ICE equivalents around the mid-2020s, making small PHEVs even less economically viable.

1.3. For many drivers, the 2030 phase-out date will effectively limit them to BEVs only. This is feasible given the lower prices, increased availability, and wider variety of BEVs expected at this time, but will require a greater installation rate of charging infrastructure than a 2035 ICE phase-out. The Government should not expect PHEVs to “pick up the slack” and rely on them as a bridging technology between 2030 and 2035.

1.4. An issue that the Government must be prepared to deal with is losing £25 billion in fuel duty tax receipts. Mileage-based taxation would be the closest substitution that is viable for EVs. New EVs have the connectivity capabilities to accomplish this without additional physical infrastructure, but there may be significant political opposition as we are currently seeing with ULEZ implementation.

 

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?

11.1. Automakers in Europe are currently focused more on selling EVs in high-end segments, such as SUVs and luxury saloons, as the higher purchase price and margins help to offset the high cost of the battery. With limited supplies of batteries, OEMs have focused on putting batteries in cars which generate the most profit. The buyers of these cars are also more willing to accept the higher price of EVs in exchange for benefits such as a smoother ride, increased interior space and reduced noise.

11.2. In the coming years, battery costs will decrease, automakers will gain experience in EV manufacturing and adopt new electric platforms, and legislation will require them to sell more zero-emission vehicles. This will mean that they will move into selling smaller and cheaper EVs. We can see this with cars such as the VW ID.2, expected for 2025, and a currently unspecified Citroën BEV launching in early 2024, both of which aim to have a base price of under €25,000 (£22,000).

11.3. Cars imported from China will be important in providing consumers with low cost EVs in the near term. Chinese automakers have more experience in building smaller EVs due to the greater size, scope, and competitiveness of their domestic EV market. MG’s cars, now all made in China for the UK, have sold well due to their value for money, delivering a sizable battery for less than their competitors. The MG4 EV starts at around £27,000 with a 51 kWh battery, whereas the comparable British-made Nissan Leaf starts at £28,500 with a 39 kWh battery. When the Chinese-made BYD Dolphin comes to the UK with a cost of £25,490 and a 45 kWh battery later this year it will be in a class of its own. The Fiat 500e is in a similar segment but has an RRP of £27,364 with just a 24-kWh battery; the Peugeot e-208 has an RRP of £30,790 with a 50-kWh battery.

 

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?

15.1. A concern for many buyers of second-hand EVs will be the health of the battery. The UK should look to take advantage of EU battery passport legislation that will require an electronic record of each battery’s state of health and expected lifetime. This data could be used to ensure confidence in EV batteries when buying second-hand.

 

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?

21.1. CCS2 is the de facto standard for the UK and the official standard in the EU. There are now only a handful of EVs available in the UK that use the CHAdeMO plug type, and those brands will be switching to CCS in the future. There is need to legislate that chargers be fitted with a specific plug type as the CCS connector is so dominant that all CPOs will use them.

21.2. Some CPOs may choose to also fit CHAdeMO plugs to serve customers with cars such as the Nissan Leaf. This should be left to them to decide. Aside from the added cost of fitting both plug types, CHAdeMO cars are limited to charge speeds of 50 kW. This means that they cannot properly take advantage of infrastructure such as high powered 350 kW chargers. Mandating that these chargers accommodate CHAdeMO would lead to them being underutilised, negatively impacting the profitability of their operators and the charging experience for other users.