Automated and Electric Vehicles Bill

Written evidence submitted by Daniel Scharf (AEVB 14)

House of Commons Public Bill Committee

Evidence from Daniel Scharf MRTPI

1. Introduction

1.01 I am a land use planner with over 40 years’ experience in public, private and voluntary sectors. Since 1995 I have also run GreenSpeed, lobbying for a reduction in the national speed limits.

1.02 I have a concern that the Bill conflates ‘Autonomous’ with ‘Electric’ vehicles. Whist these technologies are complementary in many ways, their costs and benefits are very different. It is possible if not probable that the electrification of the road transport system will develop faster than automation, being mostly technical in its character, driven by the need (and law) to reduce pollution, and having fewer challenges in terms of changing human behaviour. So these comments apply mostly to the development of an electrified road transport system.

1.03 This evidence will cover,

- the need to increase the rapid roll-out of EVs,

- the role that speed limits could or should play in the transition to EVs as part of ‘systemic’ change,

- the role that the land use planning system could play in speeding up the transition.

1.04 It should be clearly understood that the transport system is just that, a ‘system’ where all changes have knock-on effects. Government should always be looking to implement (by policy and/or statute) those changes that are most likely to trigger virtuous circles and avoid vicious circles or delay caused by incoherence arising from partial or insufficient analysis.

1.05 Serious consideration should also be given to the possibility that change can more easily and effectively be brought about through changes of policy (eg written ministerial statements) rather than changes to the law. There are powers and responsibilities which can be exercised by the Communities Secretary in respect of the development of the EV infrastructure that might avoid the need for unnecessary legislation.

2. Electric vehicles

Why the use of ICEs must be stopped and EVs encouraged

2.01 The London Mayor has announced that drivers of older fossil fuel cars can pay a fee to be allowed to kill people in central London (equivalent to the battle of the Somme) and continue to maim children (owed a special legal duty of care) in that and all other areas of the City. In its Air Quality Plan, the Government has refused to impose any other or more effective measures to mitigate one of the worst public health scandals/disasters of modern times that includes irrevocable damage to growing lungs and brains.

2.02 There are false claims being made that drivers of diesel cars were misled as to their health risks and environmental benefits. These vehicles were mostly bought for their relative fuel economy in order to save the owners’ money. There is a claim from Public Health England that the known problem of particulates and NOx from diesel engines obscures an similarly serious problem being caused by dust from brakes, roads and tyres that come equally from petrol engines. All car and van drivers would or should have been aware of the environmental harm being caused by their taking advantage of the ‘car economy’ and should only feel slightly aggrieved that the freedom to pollute (carbon, NOx and particulates, noise and dust from brakes, tyres and roads) and to kill and injure other road users (including pedestrians and cyclists) is coming to an end.

2.03 The use of ICEs in urban areas should be ended within a few years and the Government proposal to ban their sale by 2040 should be rejected. This is described as ‘ambitious’ in the Clean Growth Strategy’ where it can also be seen as less ambitious than is being proposed in other countries. Industry is likely to achieve a much faster phasing out of ICEs and should receive more encouragement to do so.

Why speed limits matter

2.04 The Environmental Audit Committee (Reducing carbon emissions from transport 2005/6) recommended that the national speed limit be reduced, primarily on the evidence of the VIBAT study commissioned from UCL/Halcrow that related to a 60% reduction in carbon from transport by 2030. That study and work by UKERC and CD Delft (and others) demonstrated that a road transport system based on petrol and diesel engine (ICEs) would be significantly cleaner and more efficient at lower speeds. The reasons why a lower speed limit would reduce carbon were that ICEs are most efficient at about 50mph and also that wasteful and polluting congestion would be reduced. A lower speed limit would also trigger a power-shift from those vehicles designed for up to twice the 70mph limit and which pollute more at 20mph than 30mph, to lighter and more efficient vehicles that would be cleaner at lower urban speeds. On trunk roads there would be modal shift to coaches allowed to travel at 70mph.

2.05 One of the greatest obstacles to the EV ‘roll-out’ has been ‘range anxiety’. Although this will be partly addressed by rapid charging points on the trunk road network (one section of this Bill), drivers of EVs are still likely to drive at the optimum speed that is around 50mph. Advances in batteries will take time and come at a cost. So a national speed limit of 50mph would remove the comparative advantage of ICEs of being able to drive faster than would be the sensible speed for EVs, as well as reducing their own emissions. So a lower speed limit would not only result in cleaner ICEs but trigger a move to EVs.

2.06 The DfT have long understood the analysis and conclusions behind the VIBAT study that a 50mph (or 60mph) speed limit would be necessary on carbon reduction grounds and to mange congestion (see Smart Motorways and variable limits on congested sections). However, the political resistance has come from the Treasury fearing a substantial loss of the tax revenue currently arising from wasteful driving practices. It has now become probable that this revenue will be lost to EVs and the Treasury should welcome the fact that other public costs of motoring (health, road building, import costs, public transport subsidies etc) would be reduced with the introduction of a 50mph limit.

The role of land use planning

2.07 The potential of using the controls already available through the control over the use and development of land and buildings by the Communities Secretary and delegated to local planning authorities is being overlooked.

2.08 All new development will generate traffic movements by a variety of modes. Attempts can be made to enable walking and cycling to be safer and more convenient. However, it is the private car (ICEs) that is causing the harm to the environment and human health that are material considerations in plan-making and decision-taking. Adding more cars to already congested road networks is making their use less sustainable for existing residents and businesses. This gives planners the responsibility to use their powers to mitigate the harm through requiring new development (buildings and changes of use) to form part of the transition to a low carbon future and not make the existing systems more polluting and less efficient.

2.09 All new residential development should have a proportionate number of charging points. Ideally theses should be associated with a bank of shared or club EVs. This would be consistent with a significant reduction in the space given over to private car parking. It is well known that car clubs can substantially reduce the level of both car ownership and use and that a change in travel behaviour can most easily occur when moving to a new home. This is one of the areas where a ‘systems’ approach shows a link to autonomous vehicles. Car dependency could go down, and sharing of EVs as a relatively high cost item would be attractive option for many if not most individual households. However, if and when EVs were also autonomous, then car use will become an option for all those not currently able to drive due to age or disability. In these circumstances there could be an even greater demand for individual transport resulting in even more vehicles on the road. Congestion might be managed by autonomy but there are likely to be substantial environmental costs (eg fuel and materials) associated with an expanded of the national fleet. This could reasonably be anticipated by Government and the infrastructure (ie car clubs and charging points) should be put in place now compatible with a sharing economy.

2.10 For similar reasons, conditions should be imposed on permissions for commercial developments (eg retail, office, R&D, storage, recreation) to require the installation of charging points and limit the number of private spaces for ICEs. This would enable charging to take place during the day to spread the load/demand for power that might otherwise peak at the end of the evening commute. In some cases businesses could be required to provide a fleet of pooled electric cars for journeys to and at work.

2.11 Local government should be using its control over town centre parking and roads to privilege EVs if not actually ban the use by ICEs. Oxford City Council has said that the city centre will be ICE free by 2030 and car owners/buyers are on notice that this will be party of a wider and accelerating trend.

3. Summary

3.01 Central and Local Government should be encouraging EVs as a separate issue from autonomous vehicles. Changes to the law should only be considered where the transition to an electrified road transport system could not be effectively managed through effective policies from the top (ie Treasury, BEIS and DCLG), including appropriate speed limit reduction, and regulation (traffic/parking orders) and planning decisions at local government level. These changes to and application of policy might be more expedient and effective than the changes being proposed in the Bill.

November 2017


Prepared 15th November 2017