Written evidence from NFDA (ELV0112)


House of Lords Environment and Climate Change Committee call for Evidence on the upcoming 2030 and 2035 deadlines 

Introduction –

The National Franchised Dealers Association (NFDA) is the leading representative body for the UK’s automotive franchised car, motorcycle, and commercial vehicle dealers retailers. The NFDA retains around 85% of the 4,500 franchised car and commercial vehicle retailers within membership and among our members are some of the UK’s largest companies, including Arnold Clark, Sytner Group and Lookers. 


Government approaches

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?

Whilst NFDA and its dealer members are fully aware and committed to the climate benefits around reducing CO2 emissions within the private road transport sector and electrifying the vehicle parc, there exists several barriers that will make the respective 2030 / 2035 phase-out dates harder to achieve. These are:

1.       The UK’s electric vehicle charging network

2.       Cost of an Electric Vehicle

3.       A lack of effective government incentives

It will be challenging for the automotive industry to meet the 2030/35 phaseout dates. Franchised dealers are concerned about the current trajectory of EV uptake and as it currently stands NFDA members are worried about the 2030 phase-out date, as outlined in the graph below. NFDA members were asked for their opinions on the phasing out of diesel and petrol vehicles in a survey conducted in August 2023, attracting responses from over 360 dealership sites. NFDA and its members feel there are certain steps parliament can take to accelerate EV uptake. The 3 key issues are shown above and will be expanded upon later in our response.
















Figure 1- NFDA phase-out date survey (August 2023) – Representing 377 dealer sites

Zero-Emission Vehicle Mandate (ZEVM)

The Zero Emissions Vehicle Mandate is the key policy that the Government is planning to introduce to reach these phase-out dates. The policy sets out the minimum annual targets for the percentage of new car and van sales that must be zero emission. The ZEVM is an ambitious policy, and there is concern among dealers that the thresholds are initially too high, and a number of manufacturers will struggle to adapt so quickly. As you can see in the table of the total 2022 UK car registrations below, each of the top 20 brands held an average 6,252 credits/ vehicles deficit with only two manufacturers (Tesla and MG) holding a credit surplus. Some of the largest brands like Ford/Toyota, due to their high sales volume, will face heavy fines to meet the threshold and as such could see the UK as an unviable trading option.

Total UK (top 20)






ZEV Mandate Threshold (2024)








Bev (%) of Sales




























































































































Land Rover













































Figure 2 - NFDA ZEVM 2022 comparison


NFDA believes the UK should not move to restrict its own market but should instead align with its largest trading partner, the European Union, by being flexible and open to alternative fuel sources/powertrains. Otherwise, there is a risk that global manufacturers who produce 95% of the vehicles sold in the UK could see the UK as a less attractive option and pull their investment. The

automotive market shouldn’t be forced pre-emptively into one direction based on party political ideology. Although trading in the sector is strong, car sales are still yet to recover to pre-COVID-19 levels. The UK automotive industry could potentially miss out in the future, with manufacturers pulling out of the UK and moving abroad to more appealing destinations. The market should ultimately remain free, open, and decide for itself. We would suggest government moves with caution when looking to restrict the market. This mandate has the potential to disincentivise the exploration of other technologies and as mentioned above the UK needs to remain technologically neutral until all avenues are fully explored.

The UK must remain attractive to European businesses which are a critical sales and manufacturing trade bloc in the global automotive sector. The ZEVM must operate in a way that encourages investment and business. The EU expects approximately 46% of all new car sales will be ZEV across the EU in 2030, this is starkly different from the 80% that the ZEVM requires. Short-term reduction in the thresholds would give the industry time to process this change and build this transition into their business model, minimise any market shock and protect consumers from any price hikes. 











Figure 3 - NFDA phase-out date survey (August 2023) – Representing 377 dealer sites

There is a risk that manufacturers reduce their overall output of vehicles, as to remain within the ZEV mandate percentages, some manufacturers might pull out of the UK altogether, which would be disastrous for the UK automotive industry. It currently employs around 800,000 people with a turnover of over £200 billion. So, while the Government can enforce these phase-out dates, it does not necessarily mean they will achieve Net-zero in the most effective way or without harming the industry. 

Charging Infrastructure

For franchise dealers, the state of the charging infrastructure in the UK exists as the primary inhibitor to the adoption of electric vehicles. In August 2023, NFDA surveyed their members to better understand their perspectives on the upcoming 2030 and 2035 deadlines. When dealers were asked ‘To what extent is the UK's charging infrastructure network making the upcoming 2030 deadline harder to achieve?’ 89% of respondents responded with ‘a great deal’.











Figure 4 - NFDA phase-out date survey (August 2023) – Representing 377 dealer sites

This was the strongest response and highlights the concern amongst the dealer network around the development of the charging network. Some of the verbatim responses received on the issue are listed below:

“Pay far more attention to those who cannot have home chargers. They make up around half of the customer base but are over five times less likely to switch to EVs.  They do not consider public charging to be a viable option.”

“The ability to easily access of charging points for customers, especially in flats or terrace housing with no parking space, is a major deterrent to customers in cities. Then the cost of charging for our customers from public charging points is considerably higher than from private charging, as much as 10 times higher from a public charging point, as unable to access low-rate night charging rates.”

“Must increase support to improve electrical capacity to rural areas and increase support for charging infrastructure.”

Comprehensive charging infrastructure is essential to EV adoption. For many, the main worry is that they won’t be able to charge their car when they need it or quickly enough. The UK Government’s goal is to have 300,000 chargepoints in place as a minimum by 2030, pushing to have them ahead of demand, and inspiring confidence in drivers who have not yet made the switch. As of April

2023, there are 42,566 public electric vehicle chargepoints installed in the UK.[1] It has taken approximately

10 years to hit the milestone of 40,000+ chargers. The UK plan is to supposedly build 260,000 in less than 8 years. That would be 32,500 chargers every year until 2030. This will require a quick and dramatic change. 




The ratio of electric cars to chargepoints has grown from 5:1 to 15:1 in just three years and is forecast to hit 54:1 by 2030. A study carried out by Kantar in May 2023 revealed that the top 3 worries for those considering buying an EV in the

UK are the high purchase cost, lack of charging infrastructure and concerns about battery life and replacement, in that order.[2] The high purchase cost of an EV will eventually drop as more models are created, but the lack of charging infrastructure will only be solved if the Government helps to fix it. 

While most charging will be done at home for consumers (~80%), this is not the reality for everyone, such as people who live in flats or apartment blocks or rurally, etc. Mileage is also a big concern for people, and while mileage will improve (and is usually dramatised by media) a comprehensive network would help to quell some of these doubts. 

Regional disparities

There are also clear regional disparities in EV uptake and charging coverage that the government needs to address. Northern Ireland is a clear example of this. When compared to the other devolved nations of the United Kingdom, investment in charging infrastructure is rapidly falling behind. An alarming proportion of these NI chargepoints have also been antiquated and unreliable, and so a big focus has been on replacing these, diverging efforts from expanding the network. Northern Ireland only has 23 chargepoints per 100,000, over 66% less than the UK average. Northern Ireland cannot afford to develop a patchwork charging system, in which rural inhabitants would experience difficulty in accessing a charging station as purchasing an electric vehicle would be unviable. The graph below highlights this disparity. 

The problem with electric infrastructure in Northern Ireland is two-fold for dealers. There has to be sufficient charging infrastructure for electric vehicles and also enough electric power to support them. Currently, both are primary issues. Northern Ireland risks becoming a dumping ground for older ICE models with these current phase-out dates, as it is constantly playing catch up.

Furthermore, franchised dealers in rural areas, such as West Devon for example, where the percentage of on-street households in walking distance of a charging site is only 0.8%, may struggle to sell electric vehicles when compared with somewhere like London, where On-Street charging reaches over 75% of households in many boroughs, even over 90% in several. The impact in these rural areas would be considerable, primarily due to the lack of suitable public infrastructure. The significant need for public infrastructure and a suitable accompanying policy is high, otherwise, these rural communities will be left behind. It is paramount that the government is aware and alert to the geographical disparities in EV demand and the charging network. 

Price point

Currently, electric cars are typically more expensive compared to Internal Combustion Engine (ICE) alternatives. Many who can afford to pay the price premium for an Electric Vehicle have already done so and the market uptake is at risk of plateauing unless the government can help support demand and maintain the momentum. Price point should theoretically become less of an issue over time, as new models enter the market, and the used EV car market continues to mature. However, it is still important when considering the 2030 phase-out deadline, as this is less than seven years away. There is also no guarantee that the market will develop robustly, and many manufacturers may pull out of the UK entirely if they do not deem it profitable. There simply is not enough incentives for consumers to buy an EV. The removal of incentives like the Plug-in Car Grant (PiCG) and the introduction of VED for EVs in 2025 is hurting the demand for EVs. Instead, government support and assurance is needed to stimulate demand in the EV market at this critical time. 

Figure 6- NFDA phase-out date survey (August 2023) – Representing 377 dealer sites

The ongoing cost-of-living crisis will add to consumer uncertainty when buying an Electric Vehicle. The purchase of a motor vehicle is likely the second largest purchase in someone’s life, behind a house, and any downturn in general economic conditions can have profound impacts on the decision-making process for families looking to buy a car. While many drivers are committed to the transition to electric, the majority are putting it on hold due to the cost-of-living crisis. This is due to the generally higher outright expense of EVs. The cost-ofliving crisis won’t stop the transition to electric permanently, however, it may inhibit the Government’s 2030 and 2035 phase-out deadlines, as these are fast approaching. 

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?

The EV market is not developing quickly enough with the current structures in place. The current lack of incentives risks to get to the 2030 objective of no more new ICE vehicles being sold; it would be prudent to consider delaying the date to 2035 and bring it into line with the EU. 

The government could further support the development of the UK EV industry by making the UK a good place for manufacturers and businesses to invest. A domestic battery supply is a good example.

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?

Government incentives and policies around the cost of purchasing and running EVs are powerful tools in making these vehicle types more accessible to a wider consumer base and can help boost the demand for EVs. NFDA urges parliament to continue supporting the increasing the demand for EVs, through effective and generous initiatives aimed at less affluent households.

NFDA, dealers and consumers were disappointed at the government's decision to close the Plug-in Car Grant (PiCG) in June 2022. The scheme existed as a highly effective and highly utilised financial incentive to support UK motorists in their transition to electric. Although the market share of electric vehicles is continuing to grow at an impressive rate, this vital support mechanism was removed prematurely and risks the UK falling behind other G7 nations in reaching their challenging netzero targets. When NFDA surveyed its members in August 2023 to establish the greatest barriers to the 2030 phase out and they asked ‘To what extent is the reduction of fiscal incentives for EVs making the upcoming 2030 deadline harder to achieve?’ A majority of respondents indicated that reductions in incentives are making the upcoming deadline ‘a great deal’ harder to achieve.

Figure 7 - NFDA phase-out date survey (August 2023) – Representing 377 dealer sites

The EV chargepoint grant has also been a great success and offers an effective financial incentive to EV owners looking to charge their vehicle at home. However, this doesn’t address the less affluent households who do not have access to a driveway.

Finally, a great policy that incentivises EV uptake through the reduction in the running cost of an EV is the Vehicle Exercise Duty (VED). Whilst this does reduce road taxation revenue it is critical in helping make EVs more affordable and also more appealing. 

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?

The Office for Zero Emissions (OZEV) should take the lead in delivering clearer communication on the case for EVs. 

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

The information in the public domain relating to EVs and their usage involves a great deal of misinformation, and the subject of electric vehicles is becoming increasingly politicised. A good example involves battery degradation:

Battery degradation does occur over time and consumers are understandably concerned about this. According to a report published by the Green Finance Institute (GFI) of drivers who said they wouldn’t buy a used EV, 62% cited concerns around battery lifespan.[3] The data suggests battery degradation is not as big of an issue as it first seems, as we generally see a 1-3% range degradation per year. Battery replacements due to excessive degradation are extremely rare and lithium-ion batteries remain more resilient than first thought.

Only 1.5% have been replaced in Recurrent's community of 15,000 cars.[4] With proper care, you can reliably expect your EV battery to last as long or longer than equivalent ICE components.

There is also a clear lack of awareness from the public around EVs and what they offer. Most members of the public have not had an experience driving an EV and so many are understandably hesitant when making the transition. Raising awareness on the performance of EVs, how the technology is state of the art, and how they can offer good reliability, comfort and access would be beneficial to EV uptake. 

Finally, there is misinformation around car fires in electric vehicles, with many worried about lithium-ion batteries being dangerous. A recent study by US insurer, AutoinsuranceEZ found that hybrid cars had the worst fire record, while EVs were the least likely type of car to catch fire. Per 100,000 sales, Hybrid cars had 3474.5 fires, petrol cars had 1,529.9 per 100,000 sales and EVs had just

25.1 fires per 100,000 sales.[5] 

While EVs are less likely to catch fire compared to ICE counterparts, when they do catch fire, it is significantly harder to put out due to the lithium-ion batteries acting as a fuel source. Raising awareness of accurate information will make the public more knowledgeable on how to be safer and look after their vehicle. 

Figure 8 - NFDA phase-out date survey (August 2023) – Representing 377 dealer sites

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

Transport produced 24% of the UK’s total emissions in 2020 and remains the largest emitting sector in the UK. The majority (91%) of emissions from domestic transport came from road vehicles. The biggest contributors to this were cars and taxis, which made up 52% of the emissions from domestic transport.[6] Achieving the ambitious 2030 and 2035 targets would help to reduce the transport sector's emissions greatly, which is essential for the UK to reach its 2050 Net-zero targets

Petrol and diesel cars have harmful polluting emissions like NO2. EVs are zeroemissions at the tailpipe which would greatly benefit cities with air pollution problems, like London, where the air quality is so bad it is impacting the public’s health. In 2019, in Greater London, the equivalent of between 3,600 to 4,100 deaths were estimated to be attributable to air pollution, considering that health effects exist even at very low levels. This calculation is for deaths from all causes including respiratory, lung cancer and cardiovascular deaths.[7] 

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?

Irrespective of the pace of EV uptake in the 2020s, if the UK is to hit the government’s EV deployment targets, the Exchequer will lose almost £260bn in revenue by 2040, according to the Tony Blair Institute. The UK government needs to introduce a fair road pricing scheme. 

We have long lobbied for the harmonisation of VAT placed on the electricity between public and private charge points to decrease the running cost of an electric vehicle for less affluent EV drivers

who are predominantly using public chargepoint stations. Whilst on the surface this seems like a logical move and we hope the Government announce this, there needs to be assurances that consumers will see this reduction in VAT and that CPOs do not pocket any additional profit from the move. Also, maintaining a subsidy on the cost of electricity usage for electric vehicles is still vital until EVs become mainstream.

EV Market and Acquiring an EV

These questions relate to the UK EV market and uptake of EVs by UK consumers.

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

The primary route in which most EVs are sold will be through a Franchised dealership. A select few (new) manufacturers choose to utilise direct sales (E.g. Polestar/Telsa), however, nearly all heritage manufacturers utilise the franchised sales model. For the heritage brands, their selling avenue is critical in the EV adoption. Dealerships remain the customer-facing end of the industry and dealer sites are critical information hubs that interested customers can go to when enquiring about an electric vehicle. NFDA’s initiative ‘Electric Vehicle Approved (EVA)’ was started in 2019 and now has over 500 individual sites gaining accreditation, including 100% of Audi’s UK sites. The EVA programme is run by NFDA, with Energy Savings Trust conducting the independent audit to accredit sites and prove that they have an exceptional level of EV knowledge, models, and chargepoints on site. By gaining an EVA accreditation, dealerships are showing consumers that they understand EV products and a consumers can  be confident in the dealerships knowledge around electric vehicles.

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

Price point remains a key inhibitor to the adoption of acquiring an EV through the standard purchasing method. This will become less of a factor when the price disparity reduces, primarily deriving from the increase in the EV supply and the availability of more EV models within the UK market. 

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

Whilst the tax exemptions for EVs exist as a notable incentive for consumers, a more productive and effective approach would be to tackle the upfront cost of an electrically powered vehicle. The curtailing of the Plug-in Car Grant has slowed EV adoption and Electric vehicles are typically 20-30% more expensive than their ICE equivalent. This delta is reducing but we estimate it will remain for the near future.

Taking Norway as an example - a critical reason for their world-leading rise in electric vehicle adoption was the upfront price incentives that were offered.

Norway offered VAT exemptions of 25% on purchases (2001-2022), from 2023,

Norway will implement a 25% VAT on the purchase price from 500,000 Norwegian Kroner (approx. £37,000) and above. This is further expanded upon in question 34. 

The reason upfront price incentives are so effective is primarily due to the policy lever making electric vehicles accessible for less-affluent households who might not have the upfront capital to be able to purchase an EV. Essentially what has happened in the UK is that EVs have already been purchased by households who can afford these vehicle types and as such, policy going forward needs to accommodate the wider consumer base.

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?

The UK market will see low-cost Chinese vehicles enter the market very soon. Vehicles coming from China will disrupt the market for manufacturers; for consumers, they will have a positive impact within the UK. China is already years ahead with their electric vehicle production line, they have established players across every section of the supply chain and also have a huge domestic market to refine the vehicles that it produces. This is why China has been able to come to Europe and the UK with low and competitive price points for their vehicles. Once the European manufacturers have developed their supply chains and economies of scale, consumers will see a reduction in the cost of EVs. This is an additional positive of Chinese manufacturers coming to market as they will accelerate this price reduction to remain competitive with a dropping of price points across the board.

The range of Electric vehicles will continue to increase with the development of battery technology. Issues remain in rural areas of the UK where chargepoint destinations might be sparse and the current demand in these areas is also low as a result. However, when the range for EVs increases to a level whereby it is close to a typical ICE range, then we will see a large shift in demand.

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?

The L-segment plays a critical role in private road transport and will be critical in reducing congestion and last-mile deliveries going forward. Adoption is limited by charging infrastructure. As it stands, public confidence and demand for electric bikes won't increase if the charging infrastructure is not satisfactory, and manufacturers won't produce motorcycles if consumers don’t see this powertrain as a viable alternative. For motorbikes, the charging issue is further exacerbated by their reduced size and electric battery range, with the typical L-category vehicle possessing an approximate range of around 100-150 miles. This reduced range leads directly to a heightened dependence on chargepoints for riders and makes a network with sufficient coverage paramount to the transition towards electric. 

In the future, a fully functioning charging infrastructure in all towns and cities for L Category vehicles is essential for people to buy into it as a commercial delivery option. Other support could include priority traffic lanes and lights or use of bus lanes, designated L-cat-only vehicle zones and exemption or reduced zone/ congestion charge fees, along with designated delivery parking zones. However, a higher annual road tax or commercial permit on these vehicles would allow them to gain access to these facilities. 

The overall electrically powered motorcycle market is still very much in an embryonic state. As of July 2022, there were only 550 new registrations for electric motorcycles up to 11kw. This compares to 5025 new registrations for engine bands up to 125cc. There must be more time and support from the Government to allow the demand for L3e-A1 electric bikes to increase, organically. Motorbike dealers across the United Kingdom are at the forefront of this Electric vehicle take-up, existing as critical information hubs and touchpoints for prospective customers. Through the knowledge of staff in dealerships, they will continue to play a key role in informing the public of the economic and environmental benefits of an electric motorbike, therefore helping drive the takeup of these types of vehicles.

What is the 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?

The technology that surrounds electric vehicles is still developing at a rapid pace with battery health and range increasing with each model coming to market. As a result, what was new when a customer purchased an EV four years later could be regarded as ‘old’ or the technology and range obsolete, leading to big value depreciation. This will remain until EV technology and range starts plateauing. However, the more models available to purchase and the further choices consumers have with EVs will lead to a demand increase and thus prices in the second-hand EV market will improve. 

15. What barriers are there to achieving a sufficient supply of secondhand EVs, mindful that second-hand vehicles make up a high proportion of all vehicles purchased?

A key barrier is simply the supply of new EVs. By having a buoyant new electric vehicle market with new models and all manufacturers engaged in the drive to an electric vehicle parc, it will directly lead to an adequate supply of second-hand EVs entering the market. Without a consistently improving new car EV market then the supply of second-hand EVs will be impossible to improve.

Media misinformation also plays an inhibiting role here with the unfounded claims of poor battery degradation over time. This impacts consumer interest in the EV market and puts individuals off purchasing these cleaning modes of private transportation.

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

Recharging their vehicle. The UK needs a comprehensive charging network with plenty of rapid chargers. Consumers would also benefit from standardised charging regulations, to avoid confusion and create an accessible network. Payments should also be contactless and easy to use, it is best to avoid multiple apps for different stations. 

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

EVs are cheaper to run with energy compared to petrol or diesel cars, saving consumers money in the long run. They also benefit from a lower rate of road taxation, for example, the Vehicle Exercise Duty exemption running until 2025.  

EVs also offer a more integrated and seamless energy option. As EV technology advances, there is promise that it can be used as battery storage, which could power your house during expensive energy spikers. The power grid can also draw on EV energy when in demand so consumers could sell their energy if they so choose.

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

Franchised dealerships have invested heavily in this transition to electric. The NFDA set up EVA especially to prepare franchised dealerships, conduct an independent audit to accredit sites, and prove that they have an exceptional level of EV knowledge, models, and chargepoints on site. 

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 charger types?

Needs to expand at an exponential rate. 40k chargers currently, Gov. aiming for 300k by 2030. Need to be contactless, consumers shouldn’t have to download multiple apps every time they want to charge their vehicle. Some sort of charger standardisation would also be beneficial.

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?

No. As mentioned in other sections of this response, there is a clear advantage for more affluent motorists with access to home charging and more needs to be done to make public EV charging more accessible and equitable to all motorists. Planning regulation needs to be developed and clearer around multi-occupancy buildings and the chargepoint requirement within the planning for these buildings.

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?

EVs are cheaper to run with energy compared to petrol or diesel cars, saving consumers money in the long run. They also benefit from a lower rate of VED until 2025. As most EVs will be newer cars they are less likely to develop faults, which usually cost consumers a hefty amount. They are also less likely to fail MOTs, meaning that consumers avoid the retest fee. 

Newer vehicles are also safer than older ones as the design and technology is more advanced. There are also health benefits, with less air pollution when driving an EV.

National and regional issues

32.          What are the issues facing rural residents, urban residents, and suburban residents and how do they differ?

Of all the geographic population groups, rural residents would be at the greatest risk of being left behind in the shift to electric. Creating an effective charging infrastructure for this section of society is critical. It is typically more expensive to install and upgrade the charging network in these locations as the infrastructure is less developed. Rural motorists also have to travel further and as such the charging network is even more important. 

Urban residents may find it potentially harder to charge their EVs at home if they live in flats. Home charging is estimated to be around 80% of all charging. 


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?

Local authorities will play a key role in helping the rollout of chargepoints across the UK, securing funding through the successful applications to the On-street Residential Chargepoint Scheme (ORCS) and helping to work with CPOs to ensure effective planning regulations. The recent announcement of £15 million for the ORC scheme will help drive chargepoint installation massively and we are pleased to hear of the number of local councils that have taken up the funding. 

Local councils should also work with DNO providers to bring down the price of installation of DNOs and socialise the cost for dealers, otherwise dealer groups face having to invest heavily in the electricity grid. The cost associated with how the electricity grid is upgraded and updated varies by region, with different approaches being taken between GB and NI. For GB, the demand connection is shallow and thus costs to install and upgrade a more socialised. In Northern Ireland, the demand connection is deep and therefore costs to install and upgrade sit with the installer. A comparison is outlined below:



Figure 7 - NFDA table - Chargepoint comparison

NFDA is concerned that the transport decarbonisation targets will not be achieved within the current regulations and framework which exist in Northern Ireland. An urgent overhaul of the legislative side of the electricity system is required to modernise and then accelerate EV uptake. 

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?

The most successful approach to the rollout and uptake of EVs can be seen in the example of Norway.

While many countries offer benefits similar to Norway on a combined nationalregional basis, Norway is unique in that it has a nationally uniform policy that includes every major incentive category: parking access, infrastructure usage pricing benefits, point of sale pricing benefits, infrastructure access benefits, and charging access benefits. Norway also has the longest continuous support for EVs, which has allowed the market time to mature. 

A summary of Norway’s EV incentives:

          Exemption from 25% VAT on purchase (2001-2022). From 2023, Norway will implement a 25% VAT on the purchase price of 500,000 Norwegian Kroner and above.

          No annual road tax (1996-2021). Reduced tax from 2021. Full tax from 2022.

          No charges on toll roads (1997- 2017).

          No charges on ferries (2009- 2017).

          No purchase/import tax on EVs (1990-2022). From 2023 some purchase tax based on the cars’ weight, on all new EVs.



          Maximum 50% of the total amount on ferry fares for electric vehicles (2018).

          Maximum 50% of the total amount on toll roads (2018-2022). From 2023 70%.

          Free municipal parking (1999- 2017).

          Access to bus lanes (2005-). New rules allow local authorities to limit access to only include EVs that carry one or more passengers (2016-).

          25% reduced company car tax (2000-2008). 50% reduced company car tax (2009-2017). Company car tax reduction reduced to 40% (2018-2021) and 20 percent from 2022.

          The Norwegian Parliament decided on a national goal that all new cars sold by 2025 should be zero-emission (electric or hydrogen) (2017).

          ‘Charging right’ for people living in apartment buildings was established (2017-)

The success of BEVs in Norway is the result of a long chain of events leading to opportunities that could be exploited more efficiently over time. These incentives became more efficient over time and remained in place for so long that users and enterprises could take advantage of them. For instance,

the VAT and registration tax incentive lowered the price disadvantage of BEVs up to 2013 but has since then provided BEVs with a price advantage.[8] 

Compared to the UK, the Plug-in Car grant was introduced in 2011 and reduced the up-front cost of eligible cars by providing a 25% grant towards the cost, up to £5,000 towards the cost of a new plug-in car. From 1 April 2015, this was increased to 35%. The plug-in car grant ended on 14 June 2022, and while somewhat successful, it could have continued to help the EV market grow and mature if it had remained in place. 

A successful national BEV market is unlikely to grow out of the niche markets without the large vehicle manufacturers launching BEVs. The large manufacturers, profiting from the long BEV history in Norway and using their nationwide dealer and service networks, could go straight to mass marketing activities.[9] The UK is not quite at this stage yet. 

Consumers in Norway have proven to have the ability to utilize BEVs with a limited range in their daily transport, contrary to a belief in other countries and in the auto industry that the range must improve before consumers buy them. Culture in the UK is of course different. For example, Norway has been clever with taxes, applying them more heavily on high-emission cars, but in Britain, this sort of policy would be seen as a tax on the poor.[10] 

The UK will likely have to choose different policies as EV technology develops further and focusing on the charging infrastructure and consumer experience is a good place to start. The UK can learn from this case, however, that the key to building a successful EV transition takes careful planning and time, alongside proper investment, as the automotive market and industry need support if it is to be successful. 

[1] How many EV charging points are there in the UK - Zapmap (zap-map.com)

[2] Understanding Consumer Attitudes Towards Electric Vehicles (kantar.com)

[3] The-Key-To-Unlocking-Net-Zero.pdf (greenfinanceinstitute.co.uk)

[4] EV Battery Health after 250 Million Electric Car Miles (recurrentauto.com)

[5] Gas vs. Electric Car Fires [2023 Findings] | AutoinsuranceEZ.com

[6] Transport and environment statistics 2022 - GOV.UK (www.gov.uk)

[7] Health burden of air pollution in London | London City Hall

[8] Perspectives on Norway’s supercharged electric vehicle policy - ScienceDirect

[9] Ibid

[10] Ibid