Automated and Electric Vehicles Bill

Written evidence submitted by Addison Lee (AEVB 11)

Automated and Electric Vehicles Bill

Summary

· As an operator of around 5,000 vehicles, Addison Lee recognises the importance of migrating to new and cleaner technologies, such as electric vehicles, we also recognise the challenges involved.

· The clauses contained in the Automated and Electric Vehicle Bill with regards to charging infrastructure lack the necessary ambition to support the migration of fleets, such as taxis and private hire vehicles, to electric models.

· In addition to the provision of rapid charge points at Motorway Service Areas and large fuel retailers, we believe Clause 10 should include a range of other locations, such as supermarket carparks, large carparks open to the public, and airports and large train stations.

· Further powers should be delegated to local transport authorities in order to provide them with the ability to place a requirement on local authorities to approve applications for rapid charge points.

· High intensity road users, such as taxis and PHVs, typically have the same vehicle mileage as ten privately owned cars. Therefore, there are significant benefits to be attained through an approach which supports their conversion above other, privately owned, vehicles.

· A comprehensive network of rapid charge points is prerequisite for the transition of such fleets to electric vehicles.

1. About Addison Lee

1.1. Addison Lee is Europe’s largest private hire car company. We use cutting-edge technology to dispatch a total of around 5,000 vehicles, of which 4,200 are passenger vehicles, to more than 10 million journeys per year. Operating in London for more than 40 years, we are a major employer in the capital and the biggest private sector employer in the London Borough of Camden.

2. Electric vehicles: charging (clauses 8-15)

2.1. The Automated and Electric Vehicle Bill (the Bill) has the potential to provide significant support to ensuring the UKs goal of leading the world in automated and electric vehicle technologies is accomplished. In particular, it represents a significant opportunity to ensure government, with the support of the private sector, sets out the necessary action and solutions to deliver the right investment needed to deliver a comprehensive network of rapid charge points.

2.2. In addition, by promoting a policy which supports the wider uptake of electric vehicles, the Bill’s wider impact could go a long way to back government action on air pollution, emissions and air quality, ahead of halting the sale of all diesel and petrol vehicles by the Government’s 2040 target.

2.3. However, the Bill, as presented, focusses on the uptake of electric vehicles amongst private car owners and the potential charging infrastructure needed to support this. It does not sufficiently take into account the requirements of fleet operators, such as Addison Lee, who have different usage patterns and make more extensive use of the road network than privately owned vehicles and as such have different needs in terms of an appropriate charging infrastructure.

2.4. As a responsible operator with a keen awareness of the issue of pollution and climate change, Addison Lee strongly welcome recent efforts to improve air quality across the country. We are acutely aware of the need to migrate from internal combustion engines to cleaner technology, such as electric vehicles. A comprehensive network of rapid charge points is prerequisite for this transition.

2.5. Air pollution costs the UK economy more than £20 billion a year which is just under 16% of the current annual NHS budget. [1] In London, the combined economic costs of poor air quality are estimated at around £3.6bn per year. [2] Pollutants from diesel cars and vans are the biggest contributor to pollution that causes 9,000 premature deaths a year in London and 40,000 nationally. Vehicular pollution has long been linked to heightened risk of cancer, heart and lung disease and stroke. Therefore, ensuring investment from both the private and public sector, so that a fully comprehensive charging network is in place, will have a significant impact in lowering the cost to the NHS, improving public wellbeing and boosting the UK economy.

2.6. Addison Lee commissioned Analytically Driven Ltd to produce an evidence based report into costs and benefits associated with improving the provision of rapid charging points in London, with a focus on supporting the conversion of taxis and private hire vehicles to electric models. The Provision of Rapid Charging Points in London: The case for government intervention report, written by the former Association of British Insurers chief economist, Dr Rebecca Driver, highlights the long-term cost savings and health benefits that would be achieved through further public investment in support primarily aimed at taxis and private hire vehicles. [3]

2.7. Dr Driver’s research found that if just 25% of the 108,700 taxis and private hire vehicles operating in London went electric, over 2,135 rapid charge points would be needed to keep them operational. At current usage patterns, and with today’s battery technology, when all taxis and PHVs are converted to electric then 8,540 rapid charge points will be required, this number does not take into account other types of fleet operators or private users. There are currently plans for 75 rapid charge points in London by the end of 2017, with a further 225 planned for installation by 2020.

2.8. Rapid chargers are more likely to be used by drivers that are high intensity users of the road network, such as taxis and PHVs. As detailed in Dr Driver’s report, a typical shift for an Addison Lee driver will see them travel on average 144 miles, whereas average commuting distances in London are 7 miles. This means a single charge by an Addison Lee vehicle at a rapid charge point would deliver the equivalent vehicle miles of 10 ordinary commuters traveling to and from work. Therefore, rapid chargers have the ability to deliver far greater reductions in pollution than spending the equivalent amount of money on low level chargers.

2.9. Low level charge points provide insufficient capacity to support taxis and private hire vehicles, which cannot afford to wait up to 8 hours to charge a battery. Rapid chargers, which can recharge a battery in 30 minutes, can support far more vehicles. Indeed, Dr Driver’s report showed that a low level charge point would support a maximum of 4 vehicles per day, whereas a rapid charge point would support a maximum of 120 vehicles per day. Rapid chargers’ usage patterns encourage multiple uses per day. Whereas low level chargers are likely to be blocked even after a vehicle has been fully charged, as the owner is likely to begin usage in the evening and unlikely to return to the vehicle until the morning, rapid chargers are less likely to be blocked for a considerable time.

2.10. Addison Lee cannot begin the process of migrating our entire fleet to EV and PiH technology until there is a comprehensive rapid charging network in place and at least some of these uncertainties are addressed. Reaching the full complement of 8,540 rapid charge points will take time, and given innovations in battery technology the requirements may reduce as the network is being developed, but we are clear that by 2020 an infrastructure of a few thousand in London, rather than 300, must be achieved. A more ambitious plan is therefore needed to support further uptake EVs so that we can immediately address this public health epidemic and achieve the Government’s 2050 target.

2.11. The Bill’s current proposal to ensure provision of charge points at Motorway Service Areas and large fuel retailers are insufficient in delivering a network of rapid charge points that would support the migration of fleets, such as taxis and private hire vehicles, to electric vehicles. Given such fleets make more intensive use of the road network there are significant benefits to be gained through their transition to electric models.

2.12. In order to move towards meeting these ambitions, Addison Lee recommends amending Clause 10 of the Bill to include a broadened list of the locations identified as being required to provide public rapid charging points. This should include, but is not necessarily limited to, requiring i) supermarkets with carparks with a capacity of over 100 cars, ii) private and public car parks with a capacity of over 100 cars, and iii) airports and large train stations.

2.13. Additionally, a clause should be added to the Bill in order to provide for delegating greater powers to transport authorities, such as TfL, so they can place a requirement on local authorities to approve applications for rapid charge points, unless there is a clear safety issue or other serious objections. The 2011 amendment to the Town and Country Planning Order, which sought to provide local authorities with the power to install on-street charge points, has failed to deliver and further action is required to overcome this barrier.

2.14. Evidence suggests that government has a role to play in the provision of funding for sufficient recharging infrastructure, to support the use of electric vehicles. Government would recognise clear and indisputable benefits to encouraging the adoption of electric and ultra-low emission vehicles. These include reduced emissions and the reduction in air pollution; helping the government to address the impact of climate change; increasing longevity; and reducing the number of costly hospital treatments that are needed to address conditions triggered by pollution.

2.15. Beyond these there are many additional benefits to be gained as a result of government policy, focussing on the provision of rapid charge points, which incentivises early adoption of electric vehicles. For example, the availability of rapid chargers will play an important role by addressing range anxiety, which is currently a key barrier to adoption. Furthermore, the availability of rapid chargers is a necessity for fleet operators planning on switching fleets to electric vehicles.

2.16. Given the scale of the air pollution crisis and the ambitious targets which have already been set, we strongly believe that the Bill must take a more determined approach to building a network of rapid charge points capable of supporting large scale uptake of electric vehicles. Dr Driver’s report estimates that the cost of providing a comprehensive rapid charging network in London is less than £0.5bn. The combined economic costs of poor air quality in London alone are estimated at £3.6bn per year, therefore there is a strong argument in favour of government investment in rapid charging infrastructure.

2.17. Beyond the content of the Bill, it is important to commit to greater public funding for electric vehicles and infrastructure that extends well beyond 2020. The Government’s commitment to funding EV infrastructure is welcome and will play an important part in encouraging uptake of EVs. However, given the scale of investment that is needed, the obligation cannot rest solely on the private sector. There must be further assurances and long-term spending commitments from Government that go beyond the £80 million that has been allocated if we are to increase the uptake of EVs in the short term and achieve the 2050 target for all cars and vans to be zero emission vehicles. Until there is a more detailed financing plan for an adequate and comprehensive EV charging network and extended powers to mandate the provision of these charging points, we will not achieve a mass market uptake of EVs in the UK.

2.18. Creating a network of this scale not only requires investment, it also needs a collaborative and joined-up approach from all interested stakeholders, including local government, town planners, transport authorities, energy companies, fleet operators, business, and the public. We are fully committed to participating and lending out knowledge and experience to achieving solutions.

November 2017