Written evidence from Transport for London and Greater London Authority (ELV0121) 

Friday 22 September 2023

Dear Environment and Climate Change Committee,

Transport for London and Greater London Authority joint response to the Environment and Climate Change Committee’s inquiry into electric vehicles

Transport for London (TfL) and the Greater London Authority (GLA) welcome the opportunity to present evidence to the Lords’ Environment and Climate Change Committee’s inquiry on electric vehicles (“EVs”). This submission sets out London’s strategic approach to decarbonising cars and vans, demonstrated by our EV Infrastructure Strategy and Delivery Plan, as well as Mayoral policy, and provides answers to the questions relevant to our experience.

TfL works to support the Mayor of London, Sadiq Khan’s ambitious aims for London to be a net zero-carbon city by 2030. This is in addition to targets for 80 per cent of all trips to be walked, cycled, or made by public transport by 2041. The Mayor’s Transport Strategy is clear that any remaining car and van journeys should use the cleanest possible vehicles. TfL continues to lead by example with the vehicle fleets that we manage, license and tender, namely London’s bus fleet and taxis and private hire vehicles.

We have introduced ambitious targets which will see our 9,000 strong bus fleet in London being zero-emission by 2034, or by 2030 if we can secure additional Government funding. We currently have over 1,100 zero emission buses in London, and we are trialling new electric bus technologies such as hydrogen fuel cell double decker buses and pantograph bus charging technology to demonstrate how different zero emission technologies can meet the requirements of London’s varying bus routes. Our strict licensing requirements also mean we have one of the greenest taxi and private hire fleets in the UK. All newly licensed taxis and private hire vehicles (PHVs) must be zero-emission capable (ZEC) as well as meeting a 10-year age limit for PHVs and a 12-year age limit for Euro 3, 4 and 5 diesel taxis or a 15-year age limit for Euro 6 diesel, LPG conversions and ZEC taxis. We currently have 7,430 actively licensed ZEC taxis in London (49% of the fleet) and 35 per cent of the PHV fleet are ZEC.

Along with our policies to discourage the use of the most polluting vehicles, including the newly expanded London-wide Ultra Low Emission Zone and our work to increase EV charging infrastructure, we are seeing significant increases in zero emission vehicles registered in and driving in London. Over 25 per cent of newly registered cars and vans during 2022 were plug-in vehicles (battery electric and plug-in hybrid electric vehicles) and four and a half per cent of all cars and vans currently registered in London are plug-in vehicles. The share of vehicle kilometres driven by EVs is also increasing across London, with EVs making up around 10 per cent of all kilometres driven by cars in central London and around five per cent in Inner London (April 2022).

It is essential that the more widespread adoption of EVs complements our efforts to increase walking, cycling and public transport. Therefore, we are focusing on the needs of key high mileage essential road users, such as taxis, PHVs and commercial vehicle drivers, and how we can support their transition to zero emission vehicles by delivering the infrastructure they need.

London’s EV Infrastructure Strategy1, sets out what infrastructure London will need to transition to zero emission vehicles. By 2030 we forecast London will need between 40,000 and 60,000 public charge points, of which up to 4,000 will need to be rapid charge points. The EV uptake scenarios that inform our infrastructure modelling forecasts take into account significantly increasing volumes of EVs registered in London due to reducing purchase costs, a rapidly expanding range of models and improved battery range, acknowledging that the zero-emission vehicle market, particularly for cars, has reached the point where the uptake curve is accelerating. In our response to the consultations on the Government’s 2030 zero emission vehicle mandate, we welcomed the 2030 phase out date but considered this should cover all hybrid cars and vans, in line with the Mayor’s net zero carbon ambition. Strong government policy is vital to ensure the availability of EVs in the UK in the near term in a competitive world market and we are extremely disappointed with the Prime Minister’s announcement on 20 September that he would delay the 2030 phase out date to 2035. The certainty provided by strong Government policy, including the zero-emission vehicle mandate, helps to ensure a viable commercial market for charge points, reassuring operators that there will be an increasing customer base and utilisation to deliver a return on their investment.

To support a net zero carbon target for London by 2030, and better air quality, we will need to accelerate the transition to zero emission vehicles, with a world-class infrastructure network, and a focus on essential trips. London now has over 16,500 public charge points, one third of the UK’s total, including 977 rapid charge points. But we will need to substantially expand our infrastructure delivery to meet our forecast infrastructure requirements.

The strategy sets out our approach to working with the wider public and private sectors to accelerate the transition to zero emission vehicles. Our key 3 commitment is to unlock public sector land for EV charging. TfL has already delivered 300 rapid charge points in London, and we continue to assess sites across GLA Group land for their suitability for EV charging. We are currently tendering to deliver rapid and ultra-rapid charge points across 100 parking bays on our road network, with the first contract to deliver 25 charge points issued in May 2023. Places for London, a dedicated commercial property company within TfL, expects to tender in the autumn for a joint venture partner to deliver EV Charging Hubs, with an initial 50 ultra-rapid charge points at locations using TfL land across London.

London has also been allocated almost £39m of Local EV Infrastructure (LEVI) funding which will enable the London boroughs to substantially increase low powered charge point delivery, expanding on-street residential charging options for drivers without access to home charging. TfL will continue to work with London Councils and the boroughs to develop proposals to access the LEVI funding, with a focus on addressing gaps in infrastructure and meeting future demand, in line with our strategy.

EV market and acquiring an EV.

In May 2018, the Mayor of London established the world’s first EV Infrastructure Taskforce. It consisted of industry leaders from 17 organisations, from both the public and private sector, with the aim of unlocking barriers to expanding charging infrastructure and accelerating the switch to EVs in London. Following multiple workshops and stakeholder discussions on topics such as user needs, land and energy issues and financial models, the Taskforce published the London Electric Vehicle Infrastructure Delivery Plan in June 2019.

The Taskforce identified that:

• Public charge points should be open to all, with a few exceptions, notably taxi drivers and other specific, priority groups.
• Different types of charge points support different user needs and a mix of rapid and slower chargers will be needed to 2025.

• For rapid charge points, the focus should be on rapid charging hubs which primarily serve high mileage/ business users who require fast and available charging.
• Additional rapid charge points are required to improve overall coverage.
• For slower charge points, the focus is on uplifting volume, reducing the streetscape impact of charge points, maintaining accessibility of the pavement for pedestrians, and exploring new models around deployment off-street.
• EV driver behaviour is evolving, and lessons should be learned to avoid stranded assets.

We undertook further industry engagement and research to update our infrastructure modelling assumptions, reflecting EV uptake and charge point delivery following the publication of the 2019 Delivery Plan. The modelling provided updated forecasts of London’s infrastructure requirements in 2025 and new forecasts out to 2030. These are set out in London’s EV Infrastructure Strategy, along with updated work on specific user needs.

Given our commitment to shift toward sustainable modes in London, it is important that while we welcome a switch to zero emissions for all, our policies should not encourage avoidable car use. The strategy therefore focuses on key EV user groups who make high mileage, essential trips, including taxis, PHVs and other commercial trips, as this will also be where the biggest emissions reductions will be achieved by switching to zero emissions.

The strategy identifies access to public charging infrastructure where drivers live as a barrier to the uptake of electric vehicles by taxi and private hire drivers, given the high proportion, particularly of private hire drivers, who live in areas of London without access to off-street parking and home charging. Drivers also need convenient access to rapid charging infrastructure that is accessible, reliable, and available when needed to enable them to top-up while they work. Drivers have identified rising energy prices which have increased the cost of charging, particularly in comparison with petrol and diesel, along with the high cost of new vehicles and low availability in the second-hand market as impacting EV uptake. We are concerned that the discontinuation of the Plug-in Taxi Grant beyond March 2024 will impact the take up of ZEC taxis in London without additional financial support to reduce the high cost of new taxis. We also call on the government to lower the VAT on public charging so that it is consistent between public charge points and home charging use, making it more affordable for drivers without access to home charging.

TfL is currently engaging with commercial vehicle operators and businesses to better understand their decarbonisation plans and charging infrastructure requirements. Early issues raised include:

• Recognising the specific requirements of vans and heavier freight vehicles when it comes to the transition to EVs and use of charging infrastructure.
• Ensuring that charging bay design allows adequate space for commercial vehicles, including turning space.
• Booking charge points to ensure availability for commercial vehicle users.
• Better provision of information, including identifying charge points that are accessible to commercial vehicles.
• Uncertainties around the lack of a second-hand market, uncertainty on battery life and the guarantees associated and the price of charging.

Experience of using an EV

The questions ask specifically about the draft Public Charge Point Regulations 2023 which were recently laid before Parliament. We welcome the Regulations and their focus on standardising data and making the charging experience easier and more reliable for drivers. Our EV Infrastructure Strategy recognises that improving access to real-time availability and location of charge points is vital to improve user experience and the lack of open data for charge points is one of the key challenges that EV drivers face. The Regulations give more certainty that this information will become more readily available, through private sector applications.

In the absence of these Regulations, in our EV Infrastructure Strategy, TfL had committed to developing a real-time and open application platform interface covering all charge points in London to improve the user experience and provide more reliable information on individual charge points, subject to Government funding being made available. We welcome the different mapping and app services, such as Zapmap, that now provide access to real-time location and availability data to drivers and continue to increase their coverage of charge points.

Whether charge points are working is also a concern for many drivers. Maintenance and reliability of infrastructure are imperative to keeping confidence in the network. TfL’s contracts for delivery of infrastructure mandate a minimum of 97 per cent reliability with charge point operator. We welcome the reliability requirements set out in the Public Charge Point Regulations and continue to take an interest in the public charge point reliability technical working group as to how this requirement will be achieved by operators and enforced.

National and regional issues

The questions focus on grid capacity and distribution networks in relation to national and regional issues. Our EV Infrastructure Strategy identifies cost and complexity of energy grid upgrades as a challenge to the delivery of rapid and ultra-rapid charging infrastructure by the private sector. The cost of the enabling work to upgrade grid capacity and the time required to deliver new connections both remains key barriers, continuing to make many sites commercially unviable. Ongoing engagement with the government and Distribution Network Operators (DNOs) is required to consider ways to overcome this significant barrier.

UK Power Networks, the main DNO for London, produced online mapping in response to a commitment in our 2019 EV Infrastructure Delivery Plan. Further refinement of heat mapping would help eliminate unviable sites and improve efficiency.

GLA has a regular dialogue with UK Power Networks (UKPN) and Ofgem about pursuing the Mayor’s 2030 net zero target for London. The Mayor of London has identified a preferred “accelerated green” pathway to reach net zero by 20302.

GLA’s dialogue with UKPN’s most recent business plan included the ability to invest more, if necessary, to meet accelerated regional net-zero targets, such as the London 2030 target.