Transport Committee - Plug-in vehicles, plugged in policy?Written evidence from the Campaign to Protect Rural England (CPRE)

Summary of Key Points

Government strategy for plugged-in vehicles should ensure that economic, social and environmental gains are pursued simultaneously, despite this it currently only focuses on carbon, which is not the only environmental issue.

While we agree plugged-in vehicles should have a growing role to play, the current strategy is not likely to deliver the significant reduction in carbon emissions required due to the “rebound effect” from increased traffic.

The focus of the Plugged-in Places funding on urban and suburban areas effectively disadvantages rural areas, where there are fewer alternatives to driving and where increases in the cost of fuel are felt the most.

The Plugged-in Car Grant is likely to be socially regressive. It should instead focus on car sharing rather than car purchase, which would also help ensure subsidies are targeted on vehicles that would be used most, rather than those parked in a driveway or office car park for most of the day.

China and Germany have far greater use of electric bikes (e-bikes) than the UK and there are strong arguments for treating them equally with electric cars, such as by subsidising the cost of buying them.

Underlying these concerns is a general failure to consider behaviour change—such as people switching to electric car clubs and e-bikes. The focus is on technological change, despite the fact behaviour is likely to change too and this should be encouraged.


The strategy for plugged-in vehicles should be grounded in a wider long-term national transport strategy, particularly in order to tackle the “rebound effect” and ensure that it decreases rather than increases social inequality.

Transport and planning policy, in particular the definition of “sustainable transport mode” in the National Planning Policy Framework (NPPF), need to be amended to ensure that the carbon savings from low emission vehicles are locked in and that other costs, such as increased congestion, do not arise.

The 2013 revision to the Plugged-in Vehicle strategy should cover behaviour change as well as technological change and be rural-proofed, to ensure rural areas are not left behind.

A minimum of 25% of the Plugged-in Car Grant should be reserved for car club vehicles and this should be accompanied by charging infrastructure. A proportion of funding should be ring-fenced for rural areas.

Subsidies for purchasing Plugged-in Vehicles should be extended to e-bikes, which should be fully incorporated into the revised strategy. Government action may be needed to facilitate insurance for e-bike pools.


1. We welcome the opportunity to submit evidence to the Transport Committee’s inquiry into Low Carbon Vehicles. As a leading environmental charity, the Campaign to Protect Rural England (CPRE) has worked to promote and protect the beauty, tranquillity and diversity of rural England since 1926.

2. With the recent rise in fuel costs particularly affecting rural areas, where there is greater dependency on cars, and the growing future challenges of decarbonising transport in rural areas,1 we recognise the need for a rapid increase in penetration of plugged-in vehicles (PIVs) in the vehicle fleet. We believe that this needs to be planned much more carefully, however, if it is to lead to economic, environmental and social benefits.

3. In the Ministerial Foreword to Making the Connection: The Plug-In Vehicle Infrastructure Strategy (Office of Low Emission Vehicles, 2011) it was stated that: “it is the carbon that is the problem, not the car. The idea that the only way to achieve our environmental goals is to force people out of their cars is pessimistic, outdated dogma.”

4. Besides the fact that many people in the countryside feel that they are being forced into cars due to the lack of affordable, convenient public transport or safe conditions for walking and cycling, these assertions are inaccurate and unnecessarily divisive. PIVs do not address congestion, in fact could make it harder to manage, while in central London over half of transport related particulate pollution comes not from the tail pipe but from tyre and brake wear2 and this proportion is growing.

Inquiry Questions

The contribution of plug-in vehicles to decarbonising transport

5. The starting point is often the claim that an electric vehicle would emit 15–40% less carbon on today’s grid and this advantage will increase as the grid is decarbonised. This focus on emission of individual vehicles fails, however, to consider the likely wider impacts on traffic patterns and modal share (let alone tax take by the Treasury) if there is a significant increase in the penetration of such vehicles.

6. The latest Department for Transport (DfT) Road Traffic Forecasts, derived National Transport Model (NTM) 2011, predict a 9% reduction in greenhouse gas emissions from road transport between 2010 and 2035. This assumes that cars will become 46% more efficient, so reducing the cost of driving by 30%. But the carbon savings from these efficiency gains are eaten up by the “rebound effect” that is predicted to lead to a 44% increase in traffic miles. It is this “rebound effect” which reduces the real world potential of plug-in vehicles to decarbonise transport.

7. The Climate Change Act 2008 requires a reduction of UK emissions by at least 80% from 1990 to 2050 and effectively this will require a 90% reduction in surface transport emissions due to the difficulty in reducing aviation and shipping emissions. Surface transport emissions rose slightly between 1990 and 2010, so were the NTM predictions to turn out to be true, effectively a 90% cut would be required in road traffic emissions between 2035 and 2050.

8. The NTM did not model the impact of wholly electric vehicles or improvements to fuel efficiency3 after 2020. These could be expected to increase the rebound effect even more. Although the Committee on Climate Change (CCC) has highlighted “the necessity of developing over the long term the policies which ensure that the reduction in supply side emissions is not offset by rebound effects”,4 the DfT does not have any long term strategy5 and so has been unable to lock in carbon savings from more efficient vehicles. A particularly important but controversial issue will be how to replace fuel duty as use of hydrocarbons per mile travelled decreases and, until this is answered, traffic forecasts will at best be highly speculative.

9. The planning system has played a key role in helping manage traffic levels and their impacts, such as through maximum parking standards, guiding the location and scale of development, and through setting conditions. The National Planning Policy Framework (NPPF) now defines sustainable transport mode as “[a]ny efficient, safe and accessible means of transport with overall low impact on the environment”, explicitly including low emission cars.

10. It is not just the simple equation of the environment with low carbon that is so concerning to CPRE, it is the NPPF’s fundamental failure to apply all three dimensions of sustainable development (paragraph 7), to its definition of sustainable transport modes. With EU emissions standards set to become more stringent over the next decade, the definition will effectively be uninterpretable and unworkable over the thirty-plus lifetime of development.

11. The CCC has emphasised the importance of better land use planning to reduce transport emissions in future carbon budgets but CPRE believes the NPPF represents a big step backwards in this regard. The Irish experience, where development sprawl caused by a lax planning system was the major cause of a 170% increase since 1990 in emissions from transport, should sound a note of caution.6

Electric bikes

12. Although electric bikes (e-bikes) are not considered in Making the Connection, they have enormous potential to improve people’s mobility choices. They can take the effort out of cycling for longer journeys, journeys in hilly areas, the carrying of goods and indeed make cycling easy for the elderly and the less able. E-bikes therefore offer significant potential to increase the modal split of cycling even beyond the best performing continental countries. Unlike PIVs, they do not cause issues such as congestion or indeed air pollution from brake and tyre wear, an increasing problem.

13. CPRE launched a trial of e-bikes in a village in Hampshire in 2011, which was highlighted in the 2011 Local Transport White Paper at paragraph 5.7, which was the first mention of e-bikes in a Government White Paper. A study following the end of the trial showed that although very popular and much cheaper than buying a PIV, many of the participants felt that e-bikes were currently “prohibitively expensive”.7

14. Around 200,000 e-bikes are sold annually in Germany compared to 30,000 in UK, while in China more e-bikes are sold than private cars. Just as with PIVs, the Government needs to help generate a critical mass by helping reduce the initial cost and consumer acceptance of this new technology. If e-bikes were to receive a subsidy equivalent to that of the Plugged-in Car Grant, it would be about £250. Assistance should also be provided to help communities set up e-bike pools and a key barrier identified in the pilot is securing suitable insurance.

Uptake of plug-in vehicles and how this can be improved

15. Making the Connection proposes focusing investment in charging infrastructure where it will be “most used” (paragraph 1.7) but fails to apply this principle in relation to plugged-in vehicles. It is an inefficient use of public subsidy to pay towards private vehicles that are likely to spend as much as 23 hours per day parked in a drive way or workplace car park. Car clubs or car sharing offers a much better way to increase the proportion of vehicle mileage driven by PIVs, which is more important than penetration of such vehicles. It also helps allow those who cannot afford such vehicles a more equal opportunity to use them.

16. There is a higher degree of transport poverty in rural areas, where a significant proportion of the household budget is spent on transport, often just to keep an older car on the road. In such cases, buying a new car, let alone an expensive PIV is simply not an option. There is a growing social divide between those who have an efficient, cheap-to-run car and those who have an “old banger” that drinks fuel.

17. The Plugged-in Car Grant should be prioritised for car clubs with at least 25% of it being reserved for this purpose and rural areas should be prioritised as up to now most car clubs have focused on cities. In addition, tax advantages should encourage businesses to make their plugged-in vehicles available for car sharing in the local community in the evenings and weekends. As noted above, subsidies should also be extended to e-bikes. Charging infrastructure should be prioritised for car club spaces, as car club operators should not have to shoulder the cost of an emerging technology.

The effectiveness of the Plugged-in Places scheme

18. It is too early to judge conclusively the impact of the Plugged-in Places funding as it has been used to fund a variety of different charging infrastructure schemes in different locations, though focused on urban and suburban areas. A particular challenge is that a “critical mass” of charging opportunities and PIVs will be needed to be able to judge properly which approach works best but that this critical mass is unlikely to be achieved while there are a range of different approaches.

19. Although Making the Connection aspires to an increasing proportion of rural journeys (paragraph 2.11) undertaken by PIV, it fails to rural-proof its recommendations in any way and rural areas are at risk of being left behind. The lack of focus on rural areas runs the risk that the approaches being piloted in urban areas will not transpose well to the countryside. We believe that a special fund for charging infrastructure should be made available for rural areas, in the same way that the DfT’s bus strategy now, following years of lobbying by CPRE, includes a fund to help roll out smart ticketing to smaller bus operators, which operate predominantly in rural areas.

The role of plug-in vehicles alongside other technologies to reduce carbon emissions from road transport

20. PIVs are most effective for shorter trips and, although they can work well for vans, are not appropriate for large goods vehicles. There are growing sustainability concerns around biofuels, which will need to be prioritised for aviation and shipping, for which there are even fewer alternatives. Hydrogen is still a long way off as an energy source and, in any event, its production is not an efficient use of energy.

21. For these reasons, CPRE believes that significant modal shift to electrified rail will be essential for passenger and freight transport. A national transport strategy would be a key opportunity to embed the Government’s vision to make rail the longer distance mode of choice.

April 2012

1 For example see Commission for Rural Communities, Rural Life Without Carbon, 2009

2 Although regenerative braking could reduce the impact of this, the greater acceleration offered by Plugged-in Vehicles could make it worse, unless the benefits are locked in through widespread 20 mph speed limits.

3 Hybrid vehicles could generally be modelled as the same as more efficient conventional vehicles, whereas electric vehicles would be somewhat different.

4 Page 285 in Building a low-carbon economy—the UK’s contribution to tack ling climate change, 2009

5 A point rightly raised by the Transport Committee in a number of its recent reports on the economy and on High Speed Rail.

6 Page 20 in An Taisce—The National Trust for Ireland, State of the Nation: A Review of Ireland’s Planning System 2000–11, 2012

7 Report available from CPRE Hampshire at

Prepared 20th September 2012