Question Number

Question

Response

1

What are the main obstacles to the achievement of the Governments’ 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?

The key obstacles are:

 Slower growth in EV sales

due to infrastructure issues

at a time when new Rules of

Origin requirements on batteries

resulting in millions in

tariffs.

 Poor charging and national

grid infrastructure.

 Lack of government incentives

for a nation-wide behavioural

shift to EVs.

For BMW Group the phase-out targets

are achievable from a manufacturing.

point of view however we do not believe this will be replicated by consumer behaviour due to incentives and infrastructure. To make these dates more achievable the UK government

need to strategize a holistic plan which solves issues regarding incentives,

infrastructure, taxation, and rules of origin. BMW Group believes closer alignment with European phase out dates (2035) will be more realistic.

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?

BWM Group does not believe that mandates make markets and that the

consumer will ultimately decide. BMW

Group wants a focus on technology openness rather than a strict focus on

BEV vehicles – this includes the use of

FCEVs and PHEVs alongside any

other carbon limiting technologies.

The deadlines restrict this technology and innovation forcing OEMs to focus on specific BEV technology. Further

key dates and timescales would provide increased certainty.

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?

The plug-in car grant was a success.

Unfortunately, once the funds expired no successor programme was named and there seems no ambition to replace this key incentive scheme.

The EVHCS was a successful initiative however this recently came to an end,

other policies such as the ERGF and the ATF have limited accessibility due to barriers to entry.

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?

If the government want to adapt a behavioural lens clearer communication

on the environmental benefits of switching to EVs this should be a holistic approach taken by the government. The Go Ultra Low campaign provided a good partnership between government,

manufacturers and consumers providing the knowledge people need when making a decision to purchase a

plug-in vehicle, the end of this scheme

in 2021 meant there is now little information and understanding for consumers prior to purchasing an EV.

5

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

BMW Group was pleased by the announcement of the draft on the ‘Public Charge Point Regulations’ as currently there needs to be greater certainty and reliability regarding information and EV usage.

6

What are the overall environmental benefits that would result from achieving the 2030 and

2035 targets?

Through phasing out ICEs by 2035

the key environmental benefits are a

significant reduction in CO2 emissions,

this will also improve local air quality reducing pollution. This part of

the road to achieving net zero by

2050 and adhering to the Paris Agreement of limiting temperature rises to 1.5 degrees of which BMW Group has committed to.

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 switch to new technologies will

be challenging for many – we need to

help customers to see the benefits and support UK competitiveness in manufacturing EVs. The cost of new EVs alongside the lack of development in the second-hand market means the average cost of EVs are significantly higher than the cost of ICEs. Future taxation plans are still unknown and will be an important factor in buying choices.

8

What are the main routes for acquiring an EV?

Which aspects of these routes are working

well, and which aspects could be improved?

Currently seen as broadly a company car market due to BIK incentives. Harder sell for private buyers without

clear incentives.

9

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

Cost is a key barrier, along with concerns about charging infrastructure.

10

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

Following the conclusion of the Plugin

Car Grant and the EVHCS there is currently very little by way of fit for

purpose government schemes to bolster the accessibility and affordability of EVs. These are urgently needed to boost take up amongst private buyers in particular.

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?

BMW Group believes that the customer will ultimately decide on the case of the range of EVs, certainly in terms of L-category vehicles, the market is not developed enough (see below). BMW Group are also invested in technology openness focusing on a range of ICEs using renewable fuels, hybrids and BEVs. For China, the main factor in lower cost EVs are significantly lower labour costs alongside a much more developed and competitive domestic supply chain and access to rare earths for the manufacture of batteries.

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?

BEV technology for L-category vehicles

is not as developed as BEV technologies for larger vehicles, the phase out dates do not allow for the development and innovation for batteries as they are currently not suitable in terms of weight, energy content and space requirements. To enhance the uptake of ZEV L-category vehicles a more realistic yardstick than 2030 needs to be in place to allow electrification of l-category vehicles.

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?

There is a real lack of consumer confidence in the second-hand EV market. Our own testing of ten-year-old BMW i3 models has seen battery range of 84% of original capacity, so there is a

clear education point we need to get across with the consumer.

14

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

N/A

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?

There is a direct correlation between

the number of vehicles sold new and the number available second hand. As

more new vehicles are sold the number will increase.

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?

N/A

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?

N/A

18

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

Charging infrastructure is the major

challenge which UK EV consumers

face. The lack of public charging stations

has forced many consumers to invest in home charging stations which is not an option for many lower income households. Furthermore, whilst BEV technology has developed EV range is less of an issue however for HGVs BEV technology is not developed enough to sustain longer journeys.

19

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

EVs offer a range of benefits from the

cheaper recharging compared to fuelling an ICE, access to ULEZ zones across a number of cities, and crucially lower CO2 emissions.

20

How prepared are car dealerships, service networks,

repairs and maintenance organisations, breakdown services and aftermarket suppliers to meet the growing EV uptake?

N/A

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?

The main issues with UK charging infrastructure are a lack of accessible public charging stations alongside the

capacity of the National Grid currently not being fit for purpose. We hope that the latter will be partially solved by recent announcements on changes to Grid accessibility, but the former

will need careful planning.

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 draft legislation on ‘Public Charge

Point Regulations 2023’ provides greater certainty and regulation over EV charging. Considering the increase in charging anxiety this will hopefully make charging processes more reliable and allow users to access more accurate information regarding prices.

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?

(See above)

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?

The current public charging infrastructure in the UK is not fit-for-purpose with many customers relying on their at-home charging stations. For lower income customers, people in shared housing or high-rise flats at-home charging stations are not an option due to high cost and space. To improve the accessibility and equitability of EV charging points the UK government needs to invest into increasing the number of public charging stations across the country both in highly populated areas and areas of lower affluence.

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?

Customers may experience a financial

benefit however this is only in specific cases rather than across the market,

aside from this consumer will benefit from cheaper fuelling costs with a

shift to EVs.

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?

The BMW Group is looking at extensively at the circularity concept of EVs, with as many components within our new cars to be as recyclable as possible. This work will continue towards 100% where possible and will be publicised for our customers.

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?

N/A

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 effect the flow of EVs into the second-hand market?

N/A

29

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

Currently the grid is not fit-for-purpose if EV adoption and ICE phase out reaches the targets set out in the

ZEV mandate, investment is needed to increase the scope and capability.

The lag time between application and

operation is huge and the cost to entry is high. Both of these need to be cut.

30

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

N/A

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?

The government has set a target for 300,000 public charge points by the

end of the decade, they are currently far from reaching this target. To reach

this target the government will need to commit to further investment in the

National Grid to increase both its

scope and capacity.

32

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

Access to appropriate charging infrastructure is key. The current system is set up for urban residents and less for

rural residents who have far less access

to rapid or other chargers. The system needs to be geared around all residents in order to meet the stretching targets for EV adoption.

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?

N/A

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?

In the US we have seen the introduction

of the Inflationary Reduction Act

(IRA) alongside the Green Deal which

involve tax breaks and other financial incentives for the purchase of EVs. In

the EU similar subsidy schemes exist to promote both the second- and first-hand EV markets. The UK government

should integrate similar policies into UK legislation to ensure increased purchasing of EVs.