Automated and Electric Vehicles Bill

Written evidence submitted by Hugo Spowers of Riversimple Movement Ltd (AEVB 32)

Introducing Riversimple

1. Riversimple is a sustainable car company based in Llandrindod Wells, Wales. Its Purpose is to pursue, systematically, the elimination of the environmental impact of personal transport. The company is developing hydrogen fuel cell electric vehicles (FCEVs). After a series of research vehicles, our first car designed for Type Approval is on the road, the Riversimple Rasa¸ as in Tabula Rasa, and starting beta trials in 2018.

2. We carry the baton of a proud Welsh inventor, William Robert Grove, who invented the fuel cell in Swansea in 1842, close to where we are based. From 1939, this technology was further developed by another British engineer, Francis Thomas Bacon, who developed the first practical fuel cell. Bacon's fuel cell technology was taken up by NASA for the Mercury and Apollo space programmes, because it was a lighter way of delivering electricity in space than taking up batteries.

3. We are the only independent hydrogen fuel cell vehicle company in the world although we are not betting against the industry; all the major manufacturers have hydrogen fuel cell vehicle programmes.

Executive Summary

4. We use fuel cells in cars for the same reason, weight. Efficiency of cars is critically dependent on weight and batteries are heavy so, although Battery Electric Vehicles (BEVs) can be very efficient for short range, they rapidly become heavy and inefficient if designed for longer range; nothing can come close to the efficiency of a hydrogen fuel cell vehicle for the range to which we have become accustomed. The Riversimple Rasa weighs less than the battery in a top of the range Tesla.

5. Hydrogen FCEVs are on the roads today and are zero emission, emitting only water at the tailpipe. They provide drivers with a very familiar driving experience comparable with equivalent diesel and petrol cars. They can be refuelled with hydrogen in a few minutes, from refuelling stations that can be retrofitted into existing forecourts.

6. Delving into the forthcoming bill, hydrogen refuelling is mentioned but it is nonetheless weighted heavily towards battery charging and the term 'charging' is dominant; 'Part 2 Electric Vehicles: Charging'. If this is meant to include refuelling with hydrogen, it will be widely misunderstood.

7. We believe the UK has the potential to be the home of a burgeoning hydrogen industry that is on the cusp of taking a leadership role on the world stage, with the expertise, jobs and skills to match but to do so, support for BEVs and FCEVs must be more balanced. While the key manufacturers in Germany, Japan, Korea and China in particular are committed to hydrogen, the UK operations of the multi-national manufacturers are only running BEV programmes. Consequently, the UK is in danger of assuming this state of affairs is universal and getting left behind. We hear a lot about technical neutrality but this bill does not demonstrate such neutrality.

BEV’s cannot provide the whole solution

8. We have to move on from combustion engines for numerous reasons – air quality, carbon emissions, decoupling from fossil fuels and the fundamental inefficiency of combustion engines. The one point of agreement is that we are moving from mechanical powertrains to electric powertrains. The two key candidates for the future are hydrogen fuel cell electric vehicles (FCEVs) and battery electric vehicles (BEVs).

9. If we are going to develop a sustainable transport system, the key metric we need to pursue is energy efficiency. Supporting ourselves on renewable energy rather than fossil reserves is akin to living off revenue rather than capital; we therefore have to switch from managing supply to meet demand to managing demand to meet supply. Reducing demand by increased efficiency allows a greater degree of economic utility and quality of life.

10. Efficiency is also the key to our other critical environmental issues – carbon emissions and local air pollution. More efficient cars will generate less carbon if using electricity from fossil sources AND they will enable a swifter transition to supporting our transport with renewable energy. Both hydrogen and electricity eliminate local NOx production but the most significant source of particulates have already become tyres and brakes, through the mandated use of effective particulate filters, and these particulate emissions are pro rata to weight of the vehicle – which is very tightly correlated to efficiency.

11. FCEVs and BEVs have very different characteristics and we need them both but for different applications. Vehicle efficiency is dependent on weight and batteries are heavy and always will be, unless we discover a new element in the periodic table between Lithium and Hydrogen. Therefore, although a BEV for short range is very efficient, a BEV rapidly becomes very inefficient for any range over 100 miles.

12. Whilst BEVs currently have the lion's share of attention in this emerging market, the majority of automotive OEMs have been consistent about FCEVs as the end game and they all have FCEV programmes. Toyota are considered the thought leaders in the industry and their commitment to FCEVs is already more than $8bn.

13. As well as efficiency, FCEVs have significant advantages for customers; range and refuelling time are comparable to conventional cars so they do not demand any behaviour change.

14. BEVs can be useful in smoothing demand by charging overnight to stabilise the grid, although about 50% of housing stock does not have the option of practical overnight charging. However, if used for long distance travel with rapid charging, BEVs do precisely the opposite. Rapid chargers at motorway services typically consume 120kW and long distance travel is predominantly in daytime, thus putting a spike on the grid at times of high demand, destabilising the grid.

15. Rapid charging also reduces battery life and increases charging losses.

16. Whilst charging a single BEV is easy and refuelling a single FCEV is hard, as we scale the infrastructure, this situation completely reverses. An electric charging point can only serve a handful of users but a hydrogen refuelling station, like a petrol station, can support thousands of users.

17. At scale, hydrogen refuelling infrastructure is significantly cheaper. To replace 20 petrol pumps at a typical motorway services with superchargers would require c.120 charging points, as fast charging takes approximately six times as long (30 minutes) as refuelling with petrol (5 minutes). A Tesla supercharger consumes 120kW so a 14.4MW substation would be required. This is equivalent to the average energy consumption of 32,000 homes [1] , so replacing our 30m vehicles and thousands of petrol stations to BEVs and charging stations is simply not practical and unnecessarily capital intensive.

18. To reduce the capital intensity of vehicle energy infrastructure, to maximise the economic utility of limited renewable energy supplies and to develop solutions for the range of vehicle applications currently met by combustion engines, we need a more complex mix of fuels and powertrains, principally FCEVs and BEVs – it is not a case of 'either or'. But we do need to match these applications with the characteristics of each technology.

19. We do not use different forecourts for petrol and diesel and the forecourt of the future should be dispensing both hydrogen and electricity. At present, battery charging and hydrogen refuelling programmes are run quite separately. We need a higher degree of collaboration between these two complementary energy vectors and a level playing field of support for both, which is currently not the case. In preparation for a forthcoming trial of 20 cars in Monmouthshire, Riversimple is installing an electric charging point beside the hydrogen refuelller to signal the complementarity of both systems and presage the 'forecourt of the future'.

20. Electricity and hydrogen are both energy carriers rather than fuel. Electricity can be made more efficiently than hydrogen from some sources and hydrogen more efficiently from others; for instance, 85% of the world’s industrial hydrogen, millions of tonnes, is made from natural gas at an efficiency of 75% whereas electricity for natural gas, considered our cleanest form of fossil-generated electricity, is only 49% efficient on the UK grid. Hydrogen and electricity can also each be used more appropriately for different demands; hydrogen is more efficient for longer range vehicles but electricity will always be better for toasters and fridges.

21. If there are efficiency gains in supply and efficiency gains in use, these gains compound and we can deliver much greater economic utility than we ever could with only a single energy vector. They are complementary energy vectors and we need them both.

22. Investment in FCEVs and infrastructure is an investment in the long term rather than an interim solution. We can migrate from fossil sources of hydrogen to renewable sources incrementally without any further investment in vehicle technology or infrastructure. This allows us a great deal of flexibility that we badly need in the energy transition.

23. Using hydrogen for transport also allows us great flexibility geographically; hydrogen can be made from any energy source so investment in FCEVs and hydrogen infrastructure allows us to collaborate globally on technical standards whilst every region uses whatever their local mix of renewables – and these are distributed much more evenly than oil.

Policy neutrality

24. BEVs have been around for a hundred years whereas FCEV technology is genuinely new technology and is still maturing, meaning there is plenty of scope for cost reductions in both the vehicles and the fuel; however, it does explain why BEVs are coming to market quicker than FCEVs.

25. Government policies should be aimed at driving private and public investment towards EVs in a balanced way. This includes language that is technology neutral and doesn’t, for example, refer to hydrogen refuelling as "charging" (a misnomer), which sends a message to markets and investors that Government supports one technology over another. Clearly Government policies must be fair.

26. There are currently a much greater range of policies and monies committed to support BEVs, notably the Faraday Challenge, and intentions are phrased in a way that signals Government support for BEVs. This includes "plug-in" grants (you do not plug in an FCEV), 'public charging points' in the Automated and Electric Vehicles Bill, and money for Highways England to invest in 'charging' infrastructure.

27. A range of private sector companies investing in infrastructure already, but the Government plays an important role in creating the appropriate investment climate. Policies that sound or seem biased towards BEVs sends a signal to the market that they should invest in charging infrastructure. A more balanced approach of Government signalling intent to move forward with both technologies will indicate that investment in hydrogen infrastructure is prudent.

UK leading the way

28. Countries like Japan and Germany are currently world leaders on hydrogen refuelling stations (HRS).

29. Japan is planning for 40,000 hydrogen-powered cars on its roads by 2020, with plans for a 20-fold expansion to 800,000 by 2030. Prime Minister Shinzo Abe has committed to turn Japan into a 'hydrogen society' with 80 hydrogen stations either operating or 'soon to operate', doubling to about 160 by the time the fiscal year ends in March 2021, with 320 in the following five years. [2]

30. Germany has been the trailblazer for HRS. Its H2 Mobility initiative is funded by car manufacturers, gas companies, and fuel retailers, and enjoys government support. It has committed to building 100 HRS by the end of 2019, independent of the number of FCEVs sold in the country. After this initial phase, it aims to build another 300 stations to provide full coverage of the country, contingent on FCEV sales.

31. The UK’s H2 Mobility UK has the intention of building 1,150 HRS by 2030, which would be enough to provide national coverage, due to the greater range of FCEVs.

32. Under Riversimple’s business model, customers would only pay a simple, single monthly fee that covers the entire cost of the car – including the vehicle itself, the maintenance, the insurance and the fuel – and at the same total cost of ownership as an equivalent combustion-engined car.

33. At Riversimple, we believe that the UK can leapfrog into the lead with this automotive technology, with low cost, convenient, clean cars, if we encourage the inclusion of hydrogen refuelling pumps into existing petrol forecourts. We can do this at lower cost and with less disruption than scaling charging infrastructure for BEV’s to mass market levels.

November 2017

[1] World Energy Council, 3,941kWh/household in 2014, equals 449W average over year

[2] The Japan Times/Bloomberg "Japan eyes 40,000 fuel-cell cars, 160 hydrogen stations by 2020":


Prepared 16th November 2017