Automated and Electric Vehicles Bill

Written evidence submitted by Matthew Roberts (AEVB 15)


Written evidence submitted by a private individual and electric vehicle owner

I am writing as a private individual who owns an electric vehicle in regards to the Automated and Electric Vehicles Bill, which is currently before the Public Bill Committee.

Thank you for making such forward-thinking proposals on the future of our transport.

I have a few suggestions on items I believe to be integral to the success of the bill.

All the following points are concerning Part 2 ("Electric Vehicles: Charging") Section 10 Subsection 2 of the bill:

1. I have specific concerns that large fuel retailers will if mandated to provide public charging points may make the cost per kilowatt of energy supplied deliberately expensive as to reduce demand for the infrastructure to then suggest that there is not relevant demand for further charging infrastructure.

In California when the California Air Resources Board passed legislation to mandate a minimum percentage of cars sold in that state should be zero emissions the car companies initially complied but then challenged in court the legislation suggesting that CARB were promoting electric cars where there existed no sufficient demand for them. We are seeing the same technique deployed within the US in 2017[1]. My concern is the fuel retailers with prohibitive pricing will leave consistently empty chargers on the forecourt and they may do the same unless the legislation particularly imposes restrictions on the maximum price that can be charged for the unit of electricity.

As a lot of EV owners may already charge at home and with ranges of EV batteries increasing (meaning owners can choose when and when not to charge), the price being anything sufficiently larger than what it would cost to charge at home would sufficiently limit the intentions of this bill in my opinion. I suggest that large fuel retailers are not able to charge much more than the average domestic price per kWh of electricity.

Shell have recently started to install charging stations and are doing so at a cost of 49p per kWh (with a current temporary discount to make it 25p per kWh)[2] whereas the Energy Saving Trust calculates the average price at 14.37 pence/kWh for standard rate electricity[3]. I accept that some profit needs to be made to fund the charger installation and support but 49p per kWh is an excessive cost for a service nearly 4 times over the average cost of domestic energy. While I also do not profess to be a company tax expert I am sure a VAT registered business’ purchase of electricity is potentially VAT exempt so will unlikely be paying close to 14.37 pence for the electricity in the first place.

2. I would like to see the legislation specifically forbid exclusivity deals with charging providers as I believe is currently happening [4][5] and has as the Telegraph recently reported reached monopoly status[6] in most motorway services. As there is little infrastructure near the motorways apart from motorway services I believe exclusivity deals to be particularly damaging and anti-competitive and would like to see these specifically banned.

3. I could see no mention of the minimum charge rate the additional charging posts or plugs/connectors that they should support. I would like to see an increase in the common "Type 2" plug chargers of either 43kWh or 22kWh speed (meaning around 1 hour 38 minutes to 80% charged in my current vehicle) but believe 7kWh (around 5 hours to charge to the same amount) to be the absolute minimum to be useful. I would worry anything less would undermine what this bill sets out to achieve and could be another way that the bill is undermined. I understand that 22kWh requires 3 live wires from an electricity supplier ("triple phase") and while most businesses are already supplied with it there may be remote areas where it is not practical to provide anything more than 7kWh speed chargers. May I suggest the bill mandates something like 80% of chargers are 22kWh or above speed?

4. I would appreciate if the bill could include large nationwide retailers and supermarkets and not just large fuel retailers (although fortunately most large fuel retailers will also be supermarkets).

5. Where a large fuel retailer is also owned by a large supermarket in close proximity, having the charger as part of the parking near the main store instead of the fuel station and therefore more easily accessible to pedestrians (electric vehicles owners of course become pedestrians when they leave their vehicles) would improve the experience as it would allow the vehicle owner to easily purchase items within the main store rather than confining them to a smaller garage store and increasing the risk to their safety as they are walking around the garage forecourt.

6. Information about where the chargers are, their capabilities etc, I would like to be made publicly available via a site such as and in a machine readable format accessible to third parties such as "Zap-Map"[7] can easily include them on their site such that vehicle owners can easily locate them.

Thank you for your time and consideration,

November 2017









Prepared 15th November 2017