Vehicle Technology and Aviation Bill

Written evidence submitted by BD Auto (VTAB 05)

1. Introduction to BD Auto

1.1 Headquartered in the UK, BD Auto has been designing and manufacturing 100% electric light commercial vehicles (e-LCVs) from our factory in Turkey for over 8 years.

1.2 We are the only company in Europe offering serially manufactured e-LCVs with >6m3 capacity, which are the preferred vehicle for e-commerce deliveries.

1.3 We have supplied approximately 400 vehicles to trusted partners including DHL, TNT and FedEx, and have driven more than 20 million km across 7 European countries.

1.4 In order to offer the best possible electric vehicle solutions, we base our vehicles on existing LCVs from large Original Equipment Manufacturer (OEM’s), such as Fiat and Renault. All our vehicles are fully homologated and produced under ECWVTA (European Community Whole-Vehicle-Type-Approval).

1.5 We offer a highly cost effective solution for businesses wishing to switch to e-LCVs, with the total cost of ownership significantly lower than for a comparable traditional vehicle. For example, in London, a leased BD Auto e-LCV would be approximately £352 (23%) cheaper per month than its diesel equivalent. (See Annex)

2. Summary

2.1 Transitioning commercial fleets from diesel power to e-LCVs is the ‘low hanging fruit’ that will enable us to deliver meaningful and rapid results now.

2.2 One diesel fuelled LCV pollutes as least as much as nine diesel fuelled passenger cars, based on higher emissions and higher average annual mileage, making e-LCVs a very impactful way of reducing emissions.

2.3 e-LCVs fleets are not dependent on 3rd party charging infrastructure, as they have pre-determined routes allowing for scheduled charging at home base.

2.4 The key regulatory challenge to address is the fact that Category B driving licence holders are currently unable to drive the medium/large e-LCVs but are able to drive the equivalent diesel vehicles, as a result of heavier drivetrains. This acts as a significant disincentive for businesses looking to switch their fleet to electric.

3. Commercial vehicles on our roads

3.1 The number of vans (LCVs) on the road has increased rapidly in recent years, as a result of the increase in online retail sales, with over 4 million vehicles at the end of 2015. In 2014, LCVs accounted for 15% of all road traffic and covered 45 billion vehicle miles.

3.2 The medium/large sized vans segment (2.5-3.5t) is growing the fastest, with 220,000 new UK registrations in 2015 (59% of LCV registrations). In London, there are 27,000 unique medium/large LCV crossings of the London Congestion Charging Zone (CCZ) every day (65% of LCV crossings).

3.3 The average annual mileage of a LCV is at least three times that of a passenger car. CO2 emissions per mile are about 40% higher from an LCV than a passenger car, whilst NOx emissions are about 175% higher from an LCV. We, therefore, estimate that switching one diesel fuelled LCV to electric will have at least the impact of switching nine diesel fuelled passenger cars. This differential is even higher when the LCV in question is a refrigerated van, such as those used in food retail deliveries, which has even greater emissions per mile.

4. Third party charging infrastructure

4.1 Part 2 of the Bill exclusively relates to the provision of electric vehicle charging infrastructure, which the Government states "will be required to support mass market uptake of electric vehicles".

4.2 However, e-LCVs fleets are not dependent on 3rd party charging infrastructure, as they have pre-determined routes allowing for scheduled charging at home base.

5. Driving licence derogation

5.1 Instead, one of the key issues preventing the take-up of e-LCVs is the fact that Category B driving licence holders are currently unable to drive medium/large e-LCVs, but are able to drive the equivalent diesel vehicles. This acts a significant barrier for businesses looking to switch to LCVs, as they will have to either hire drivers with HGV licences, at significant extra cost.

5.2 The Government is currently developing proposals to seek an EU derogation that would allow Category B driving licence holders to operate alternatively fuelled vehicles up to 4,250 kg (the current limit is 3,500 kg). This would help achieve payload parity with conventional diesel vehicles and should therefore address a key barrier to the adoption of alternative fuels, which require heavier drivetrains.

5.3 The Government plans to consult on these proposals later this year. However, expediting this process could have a significant impact on the very near term growth in the electric vehicles market.

6. Conclusion

6.1 Whilst clearly ensuring that the electric vehicle charging infrastructure is crucial in the long-term to meet the Government’s target of making "almost every" vehicles zero emission by 2050, there is the potential to make significant impacts on the number of electric vehicles on our roads and, even more so, the levels of air pollution in our cities, in the short-term.

6.2 Transitioning commercial fleets from diesel power to e-LCVs is the ‘low hanging fruit’ that will enable us to deliver meaningful and rapid results now.

Annex

1. Monthly lease charges e-LCV vs Diesel, in London (£)

Component

Electric

Diesel

Leasing

999

385

Fuel

75

758

Maintenance

85

130

Road Tax

0

19

Congestion

1

220

Total

1,160

1,512

Based on the following assumptions:

Leasing:

· 60 months

· Electric: BD Auto rate (e-ducato)

· Diesel: Sprinter rate

Fuel and mileage:

· Mileage: 2,500 per month

· Diesel LCV consumption: 15 mpg

· Diesel cost: £1.00 per litre / £4.55 per gallon (exc. VAT)

· e-LCV consumption: 2 miles per KwH

· Electricity cost: £0.06 per KwH (exc. VAT)

Service, Maintenance and Repair

· Diesel: £0.0525 per mile

· e-LCV: 35% less than LCV (fewer moving parts, no oil/filter changes)

Congestion Charge

· £10.50 per day (£10 registration per year)

· 250 days in CC zone

March 2017

 

Prepared 16th March 2017