Automated and Electric Vehicles Bill

Written evidence submitted by LEVC (AEVB 13)

Automated and Electric Vehicles Public Bill Committee

ABOUT LEVC

1. LEVC (formerly LTC) manufactures the world’s only purpose-built, mass-market range extended electric taxi. The electric taxi draws on decades of automotive heritage, having built the iconic London taxi in Coventry for almost 70 years.

2. LEVC’s electric taxi is manufactured at a new facility at Ansty, near Coventry, purpose-built with a £325m investment by LEVC’s parent company Geely. Ansty is the first new car plant to be built in the UK in over 10 year, the only car plant in the UK dedicated to electric vehicles (EVs) and will also house Geely’s global research and development (R&D) hub for EV technology, exporting innovation worldwide.

3. The company recently relaunched as LEVC (London EV Company), marking the next stage in the company’s transformation. LEVC has the ambition to be the urban commercial vehicle provider of choice for cities around the world.

4. LEVC’s taxi will be built on an adaptable platform which will pave the way for it to manufacture other electric commercial vehicles following the taxi’s UK launch. The electric taxi will also be sold in cities across Europe and beyond, meeting the global demand for safe, clean, accessible taxis and demonstrating UK leadership and advantage in the commercial vehicle segment.

ABOUT THE NEW ELECTRIC TAXI

5. LEVC’s electric taxi is called the TX. The TX uses eCity technology which combines a small petrol generator (known as a range-extender) with a class leading battery and proven electric powertrain.

6. eCity technology will give drivers a zero emissions range of 80 miles, and a combined range of over 400 miles with its small petrol generator. This means that the TX is not a hybrid but is 100% electric driven, with the generator running efficiently, minimising overall emissions.

7. The technology is purposely designed for commercial operators that face demanding and unpredictable daily usage cycles and increasingly require zero emissions operations in city centres where noise and air pollution is most acute. Over time as battery costs reduce and infrastructure develops there may be the opportunity to remove the range extender completely but currently this is the best technology for commercial operators.

8. LEVC does not separate out the cost of the battery – so called battery leasing – instead giving drivers a simple and clear weekly cost of £177 on a five-year PCP financing arrangement with an initial deposit of £3,250. The retail price is £55,599 OTR, net of the expected OLEV Plug in Taxi Grant (PITG) of up to £7,500 which is subject to European Whole Vehicle Type Approval and European Commission state aid notification.

EXECUTIVE SUMMARY

9. LEVC welcomes the opportunity to submit evidence to the Automated and Electric Vehicles Public Bill Committee. LEVC is a direct beneficiary of successive governments’ investment in the development, production and sale of commercial electric vehicles (EVs) in the UK.

10. We are delighted that the Automated and Electric Vehicles Bill sets out much needed regulatory powers to improve the UK’s charging infrastructure and will help to pave the way for a smart and interoperable charge point network.

11. By requiring large fuel retailers and service area operators to provide public charge points, to make key information about their charge points available to the public and to install only smart charge points, the Bill will help to encourage the uptake of ultra-low emission vehicles by creating a visible and extensiv e charging network.

12. However, at this crucial time in the development of the EV ma rket LEVC believes there are three k ey issues which the Bill should address in order to create a sustainable charging network that works for road users. These are:

1. Ensuring legacy charge points meet the latest standards

2. Requiring new residential and commercial developments to provide charge points

3. Availability of taxi-only charge points

13. Please find LEVC’s position on these key issues below.

1. Ensuring legacy charge points meet the latest standards

14. LEVC welcomes the government’s continued investment in deploying charge points across the UK to encourage the uptake of ultra-low emission vehicles.

15. However, there are currently more than 14,000 charge point connectors in the ground which, due to continuous advances in technology, can be very different from one another. For example, the communication protocols which connect a vehicle to a charge point are software-based and therefore need to be upgraded in order for new electric vehicles that come to market to successfully charge. It is often the case that providers and network operators do not maintain or upgrade their software which creates significant difficulties for drivers who need to charge their vehicle. Similarly, some charge points can be upgraded via wireless networks but others will need a physical upgrade or a physical replacement.

16. This problem is further exacerbated by the lack of definition regarding ‘smart charging’. If a type of smart charging progressed by government requires a fundamental technical change to the current specification of charge points or additional hardware or software to the vehicle then LEVC would urge the government to allocate funding to providers and original equipment manufacturers to ensure both charge points and vehicles are compatible with each other. Does the government define ‘smart charging’ as transmitting charge point data (such as availability, health status, usage data, etc.) as they are capable of now or does ‘smart charging’ refer to charging technology that supports grid management?

17. We would therefore urge the Committee to amend the Bill to define ‘smart charging’ and the agreed standards and require charge point providers and/or network operators to upgrade or replace their legacy charge points to ensure they meet the latest standards. Failing to do so could result in a significant number of charge points being made redundant, hindering the government’s continued investment in charge points across the UK and aim for the sale of internal combustion engine vehicles to stop after 2040.

2. Requiring new residential and commercial developments to provide charge points

18. LEVC welcomes the Automated and Electric Vehicles Bill’s provision to require large fuel retailers and service area operators to provide public charge points. This will help to encourage the uptake of ultra-low emission vehicles by creating a visible and extensive charging network.

19. However, LEVC believes that the Bill should also include provisions to require new residential and commercial developments to provide charge points so road users can charge their vehicles at home and at work. This is an initiative many European member states are already mandating and would give drivers the confidence to go electric when they purchase their next vehicle.

20. We would therefore urge the Committee to amend the Bill to require at least 20% of parking spaces at new residential and commercial developments to be designated and fitted with EV charging points with an electrical provision to support the installation of an additional 20% of charge points in the future once the EV parc has increased. This measure would not include a financial cost to the government.

3 . Availability of taxi-only charge points

21. In London , new regulations come into effect on 1 January 2018 which require all newly licensed taxis to be zero emissions capable. LEVC anticipates that other cities will introduce similar regulations on taxis and commercial vehicles in order for the UK government to meet its legal obligations to improve air quality and lower CO2 emissions. Indeed Bristol will follow suit from April 2018 and Oxford from the end of 2018.

22. LEVC strongly supports this approach and believes that both local and national government has a responsibility to ensure adequate charging infrastructure is in place by the time new regulations are introduced.

23. As self-employed drivers who need to be on the road to earn a living, we believe taxi drivers should have access to dedicated charge points where possible - on EV-only taxi ranks, at taxi dealerships, rest stops or on-street residential charge points if drivers do not have off-street parking. The availability of an extensive charging network will be crucial to the successful roll out of electric taxis by drivers and small business owners in light commercial vehicles.

24. We would therefore urge the Committee to ensure the Bill includes provisions for the allocation of taxi-only charge points at large f uel retailers in order to encourage them to go electric. This would also help to incentivise local authorities to set ambitious zero emissions transportation policies , creating greener taxi fleets and improving air quality across the UK.

25. Charge points should also be interoperable with other networks across the country. The nature of the taxi trade is such that drivers need to charge quickly and conveniently anywhere in or outside a city. It is not acceptable for drivers to be unable to use charge points because they are not a member of a private/subscription network.

26. Electricity is a vehicle fuel and taxi drivers expect to pay for it as long as the terms of payment are clear, simple and transparent at point of sale. LEVC would however state that for drivers to realise the full economic and environmental benefit the cost must be competitive against conventional fuels such as petrol and diesel.

November 2017