Written evidence submitted by Transport Action Network (EVP0134)
Introduction
Transport Action Network (TAN) welcomes the opportunity to submit evidence on this important topic. The need to accelerate the shift to electric vehicles (EVs) is urgent but so is the need to consider wider impacts of doing this and whether there are negative consequences that we need to avoid.
Road user charging can also be contentious but there will be a need for some new form of income generation for the Government in the next decade. However, looking at a distance- based road user charging for heavy goods vehicles (HGVs) first, could help with the introduction of a wider charge for all vehicles.
Accelerating the shift to zero emission vehicles
This is something that needs to happen but we will confine our comments to the dangers of unintended consequences of measures that might be used to increase electric vehicle (EV) use.
Avoiding negative impacts
Increasing congestion and slowing down buses
In particular, we are concerned about suggestions of allowing EVs in bus lanes and to give them free parking. Once these incentives are given to drivers, they become extremely difficult to remove. They also have significant negative impacts, especially as EV numbers rise, increasing congestion generally, and undermining the value of bus lanes1. This negatively impacts on public transport, slowing bus services, making them more expensive (bus operators have to put on more buses to maintain service frequency) and reducing fare income as people abandon the slower services.
The biggest obstacles to EV uptake are their cost and concerns about range and the ability to recharge easily (lack of recharging facilities). While cheaper or free parking and giving access to bus lanes might add to the attractiveness of owning an EV, the negative consequences of these and the fact that they are likely to only have a marginal impact on increasing EV uptake, mean they should be avoided. It should not be forgotten that running an EV is already far cheaper than running a car on petrol or diesel. More giveaways on this front are not needed and are likely to be counterproductive, penalising more sustainable forms of transport and undermining other Government priorities.
1 Figure 1, Vehicle choices and urban transport externalities. Are Norwegian policy makers getting it right? Transportation Research Part D, September 2020
Undermining walking
The other significant issue connected with increasing EV use that we would like to highlight is the impact that charging facilities can have on people walking. In the rush to speed up the roll-out of EV chargers there is a risk that corners will be cut and care won’t always be taken as to where the chargers are sited. This could lead to extremely cluttered streets, impacting on the attractiveness of an area, but more worryingly narrowing pavements and making it less pleasant and possibly less safe to walk.
In order not to undermine walking, which the government wants to increase for public health and other reasons, siting stand-alone chargers on pavements should be prohibited on pavements unless these are very wide. Charging infrastructure should be placed on the road, between cars. That would reduce the amount of cable trailing across pavements and remove significant trip hazard.
Currently, on pavements with obstacles such as lamp columns, people walking have the ability to walk around the lamp column on both sides should there not be room for two parties to pass between the lamp column and the back of the pavement. With electric chargers and trailing cables, the space between the lamp column and the road can only be used when a car isn’t charging, so the pedestrian is faced with not just with another obstacle to negotiate but a significantly reduced pavement width.
Road pricing
Avoiding negative impacts
Increasing congestion and undermining buses and active travel
There is no doubt that some form of tax on road use or EVs will be required to replace road tax and fuel duty as these sources of central government revenue reduce with less petrol and diesel vehicles on the road. As with encouraging more people to take up EVs, the government needs to be aware of the unintended consequences of any charging proposals and needs to make sure that any scheme does not:
1. Lead to an increase in mileage and congestion
2. Undermine public transport viability or demand
3. Undermine active travel
4. Increase inequality by incentivising car use
All of these could happen were the charging levels (per mile) set too low, or people were given a ‘free initial mileage’ allowance which could encourage them, particularly those with a lower annual mileage, to use a car rather than walk or cycle for short distances.
Turning this around, road pricing has the very real ability of helping to manage demand and reduce the number of vehicles on our roads: to make places more attractive to live, improving health and well-being and attracting inward investment.
Shifting freight to rail and other modes
Currently, freight on rail is at an economic disadvantage compared to road freight because road freight pays so little of the actual costs it imposes on society. Research in 2018 by Campaign for Better Transport found that heavy goods vehicles (HGVs) only contributed, through taxation, to 32% of their external costs2. This proportion had fallen since
the original report published in 20143. Since 2018, with fuel duty frozen, tax revenues in real terms are likely to have fallen further, so the proportion of external costs paid by HGVs is now likely to be less than 30%.
Another consideration is that the Government recently consulted on allowing 48 tonne HGVs on our roads, up from the current limit of 44 tonnes. If this were to happen, a six axle HGV would have a load of 8 tonnes per axle over the current load of 7.33 tonnes per axle.
Applying the 4th power rule4, this approximate 10% increase in axle weight leads to an increase in structural road wear of 42%. Therefore, raising the maximum allowable vehicle weight is likely to lead to an increase in road maintenance costs caused by HGVs and further reduce the proportion of external costs that are covered by their taxation.
HGVs also take up a considerable amount of space on our roads, while research for Campaign for Better Transport found that HGVs are likely to be involved with far more fatal crashes per mile travelled than other vehicles5. They are one of the biggest factors for people feeling unsafe on our roads and consequently are a major suppressant of active travel.
Therefore, there are a good number of reasons, aside from the economic ones, for reducing the number of HGVs on our roads, through making them run more efficiently and through a modal switch to rail and water. The best way of achieving this would be through distance- based road user charging. This would incentivise more efficient operations and reduce empty running. By putting rail freight on more of an equal footing, it would encourage a modal shift which would also help deliver decarbonisation more quickly. This would also help alleviate another issue facing the freight industry which is the apparent shortage of HGV drivers6.
Distance based road user charging could be brought in more quickly and easily for HGVs, being less contentious than for private vehicles, but it could also be used as a way of raising
2 Table 1, page 3, MTRU addendum report prepared for Campaign for Better Transport, 2018
3 MTRU report: Heavy Goods Vehicles – do they pay for the damage they cause? June 2014
4 Page 6, Design Manual for Roads and Bridges, CD 224 Traffic Assessment, March 2020
5 MTRU note for Campaign for Better Transport, November 2017
6 Paragraph 9, Page 9, Longer Semi-trailer Trial Impact Assessment, November 2020
the money to provide better truck stops and services. This would not only help improve the acceptability of the charges but would also address a long-standing issue for drivers.
There are already a number of distance-based road user charging schemes for lorries in other countries, such as Germany, Poland, Austria and Switzerland so it should be relatively easy to learn from them in order to speed up implementation. Other countries, such as France, Italy and Spain, which operate motorway tolls, in effect, also have a form of distance-based road user charge.
Conclusion
While there is an undoubted need to accelerate the take up of EVs, care needs to be taken so that this does not undermine public transport and active travel. There is a real concern that some of the suggested ways of increasing EV take-up would do just that and if there is any doubt they should be actively discouraged.
Road user charging for cars will be needed within the next decade and there is a little time to get this right, but for HGVs there is no need to wait and every reason to look at bringing in a distance-based charging system as soon as possible. This would bring about an immediate reduction in carbon emissions, and through encouraging freight onto rail it would also reduce the wider costs associated with HGVs on our roads.
February 2021