Autocar's view on the planned 2030 ICE phase-out

Question 2: Do you prefer a technological definition that permits both HEVs and PHEVs, or a technological definition that permits PHEVs only? Please explain your answer.

We would prefer a definition that sets standards, rather than enforcing specific solutions. For example, as the legislation is written at the moment range-extender electric vehicle technology that is rapidly taking off in China, a kind of halfway house between plug-in hybrids and full electric vehicles, is effectively banned in the UK before it even has a chance to launch. It should not be down to legislators to prescribe the solution to the problem, as has happened with a legislative path now that only leads to battery electric vehicles. While the goal may ultimately be zero emissions, to facilitate that the focus should be on reducing CO2 emissions and the more technologies that can contribute to that the better.

Question 3: Do you support no further CO2 requirements, a vehicle level CO2 cap, or a fleetwide CO2 requirement? Please explain your answer.

We would favour a fleetwide CO2 scheme, because it allows some flexibility for firms to offer a more diverse line-up of vehicles to meet consumer demand. This must also include vans. The climate does not discriminate about emissions and where they have come from, so it is nonsensical to treat a manufacturer’s van emissions as a separate entity to its car ones. 

Question 4: Should a minimum range be required for new PHEVs and, if so, at what level should it be set? Please explain your answer.

We do not believe a minimum range should be set for PHEVs because we do not believe that figure is truly meaningful. While a PHEV vehicle might be capable of extending zero-emission running and manufacturers should be encouraged to increase this where possible, if it is not charged regularly and used correctly that figure is essentially meaningless. 

Question 8: What are your views on current measures to support demand for zero emission vehicles? What additional measures could further support the transition?

While the current tax benefits for fleet and business buyers of zero-emission vehicles have proven effective, at present, there is no support to drive demand for zero-emission vehicles for private buyers. That has created an unbalanced car market with business buyers accounting for the vast majority of EV sales. That needs to be addressed with increased support from private buyers, either through incentives or tax benefits - particularly for more affordable EVs that are now arriving on the market. Even a small incentive can serve as a strong push to consumers and help address the price gap that remains between ICE vehicles and EVs.

This must too be joined up with the wider policy to road transport taxation. In the most recent budget, VED rates were raised on new internal combustion engined cars while fuel duty was frozen. Throw in the lack of incentives to buy electric cars, and together these three things simply encourage people to stay in their existing cars for longer and opportunities are missed to lower CO2 and increase the amount of zero emissions vehicles on the road.

Question 9: What are your views on whether small volume manufacturers (between 1,000 and 2,499 registrations) should be subject to the 2030 requirements for cars and/or vans?

Question 10: What are your views on whether micro-volume manufacturers (fewer than 1,000 annual registrations) should be subject to the 2030 requirements for cars and/or vans?

Question 12: What is your opinion on exemptions for kit cars from the 2030 requirements for cars and vans?

We have grouped these questions together because we have the same answer for each of them. Autocar strongly believes that small, micro-volume and kit cat manufacturers should be exempt from the 2030 requirements. Such firms are a key part of the wider British manufacturing industry, helping to drive technical innovation and employee skills development that benefit the wider economy.

Due to their low volume and the use case of most vehicles they produce, their overall impact on the UK’s CO2 emissions is negligible, while subjecting them to cost-prohibitive electrification requirements could prove insurmountable for many. Most of these vehicles will stay on the roads for decades and do minimal mileage each year. We do recognise that many of these firms are already looking at electrification solutions, so we would welcome incentives and support for them to pursue innovative and cost-effective emission-reduction technology that could ultimately benefit the wider industry.

Question 11: What is your opinion on exemptions for Special Purpose Vehicles from the 2030 requirements for cars and vans? 

Current electrification technology is both costly and has limitations in certain use cases. Therefore, we feel it is important that any requirements for Special Purpose Vehicles are carefully crafted to ensure that there is no impact on the effectiveness of such machines in their intended usage.

It is worth noting that road transport of all kinds is on a trajectory of lowering emissions. Many of these vehicles will be sourced from or based on major OEM vehicles and technologies that have lower emissions regardless. 

Part 2: Vehicle Emissions Trading Schemes (VETS) Updates

Question 14: What are your views on the proposal to implement a van-car transfer in VETS? Please explain your answer.

Answer. We would welcome any flexibility here for reasons outlined in question three: the climate does not discriminate about emissions and where they have come from, so it is nonsensical to treat a manufacturer’s van emissions as a separate entity to its car ones. 

Question 15: Are there other flexibilities that should be considered within VETS for cars and vans?

Answer. We think it is unfair that CO2 trading is currently frozen at 2021 levels. This gives a car manufacturer no incentive to lower CO2 emissions across its whole fleet, only to sell a set number of EVs. The goal must be to reduce CO2 emissions on the way to zero emissions, and the way VETS is written at the moment doesn’t offer much encouragement for a car manufacturer to do so.