The consultation can be found here:
https://www.gov.uk/government/consultations/phasing-out-sales-of-new-petrol-and-diesel-cars-from-2030-and-supporting-the-zev-transition

It's not light reading. The response is to 17 questions. Please put the number of the question you wish to contribute to the answer of. The next post is a draft response, but we need your comments to drive it forward.

Question 1: Do you agree with the Government’s view that full hybrid and plug-in hybrid technologies only should be considered? Please explain your answer.
Answer.In the context in the document , yes, specifically Mild Hybrid shall be excluded. .
Mild hybrid is noy an adequate technology, offering very limited benefits, and no soley electric propulsion.

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.
Answer.The Association would clearly support BEV only. However, where compromise if required then PHEV only should be considered. PHEV will always offer greater autonomy with no emissions than HEV. Aligned with a minimum range specification, then for the vast majority of journeys with PHEV, emission shall be low to zero. As an additional point PHEV vehicles typically have greater carbon emissions than HEV when consuming fuel. This is a choice by the manufacturer. Q3 addresses this.

Question 3: Do you support no further CO2 requirements, a vehicle level CO2 cap, or a fleetwide CO2 requirement? Please explain your answer.
Answer.PHEV vehicles must clearly state their CO2 emmission per km when run soley on fuel, as well as when using maximum grid supplied energy. The PHEV CO2 rating for fuel only should match or better an equivalent HEV.
There is no point offering an improved ‘choice’ that will result in greater emissions if not utilised as intended. Many PHEV vehicles are simply a tax reducer. It will not be possible to monitor users, so the OEMs must meet appropriate targets at the factory gate. The threshold should be below the current cleanest ICE vehicles, preferable set to match in market sector at least the median for HEV.

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.
Answer.Yes, the minimum range should be sufficient for at least three days typical/average UK mileage. Allowing for winter impact on range, we estimate this would be equivalent to 100 miles WLTP. 20-30 miles per day, with a loss of 10-20% for urban use cases.

Question 5: Do you agree with the Government’s intention not to establish a technological definition for the specification of new non-ZE vans that may be sold from 2030? Please explain your answer.
Answer.The van market has shown greater signs of electrification since the consultation was written. As this is a dynamic area, any decision made here will be likely obsolete before 2030. However, a suitable CO2 figure will in effect define the the technological definition. A definition again of a PHEV with approximately 100 miles of range would provide a more certain and positive message.

Question 6: What are your views on establishing a CO₂ requirement for vans from 2030? What is your preferred measure, if any, and at what level should the target be set? Please explain your answer.
Answer.In light of a failure to set a technological definition, this is essential.
Question 7: What would be the impact to the economy and to UK society of any new or additional non-ZEV CO2 requirements in the van sector from 2030? Please explain your answer and provide evidence where possible.
Answer.The Association are not economists but recognise that there will be an impact to the economy. However, we support the view that this short-term pain is absolutely key for long term gain. Better health, less pollution and distinctly possible improvement in wellbeing and employment outcomes. The level of benefit is subject to a number of other outcomes, but the use of active travel delivery in cities has clear and obvious benefits as an example. Better understanding and regulation of the zero hour contract and gig economy are inevitably a part of this.

Question 8: What are your views on current measures to support demand for zero emission vehicles? What additional measures could further support the transition?
Answer.Many possible measures have been discussed openly in various spaces in the UK and globally. A simple starting point for the UK would be to set VAT at public charging at 5%.
A simple clear and unambiguous measure would be to end the freeze on fuel duty and use that fiscal nudge to significantly improve uptake.
Adjust the expensive car threshold for EVs to a more sensible level. The threshold is below the average cost of any vehicle, and impacts even relatively basic vehicles. Adjustment of this threshold to a value above £60,000, rising inline with CPI for EVs.
The Association is sympathetic to calls to remove VAT from EVs. However, this needs to be balanced with promoting vehicles better suited to the majority of UK journeys. Remove VAT on EVs with a pre tax price of below £30,000, again rising with CPI, with a review after 10 years. This will promote the uptake of smaller vehicles, as well as encouraging OEMs to manufacture smaller vehicles. For many this will also provide an incentive to use rail/public transport for longer journeys. (Requires vast improvement in rail ticketing to make it cheaper than air travel for families) A more forward thinking solution would be to include car club membership in the rail ticket service.
Remove VAT on L7e vehicles, as above.

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?
Answer. This is probably more complex than this question respects. How many of these low volume manufacturers already offer EV options. For many the EV drivetrain is simpler to adopt, easing issues around maintenance and warranty. More information is required. A simplistic initial approach would be to review the number of BEV sold in this sector, and create a criteria to increase this. SVMs would not be bound by the limits, but would need to apply for their exemption. Refusal would not happen, unless the SVM had not registered any non-BEV vehicles in the preceding three years.

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?
Answer.The Associations response MVMs is as for SVM.
For many the EV drivetrain is simpler to adopt, easing issues around maintenance and warranty. More information is required. A simplistic initial approach would be to review the number of BEV sold in this sector, and create a criteria to increase this. SVMs would not be bound by the limits, but would need to apply for their exemption. Refusal would not happen, unless the SVM had not registered any non-BEV vehicles in the preceding three years.

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

Question 12: What is your opinion on exemptions for kit cars from the 2030 requirements for cars and vans?
Answer.The Association concurs that at this juncture, SPVs need an exemtion however we note that some manufacturers of SPVs already have trials of EV versions. We would encourage policy that supports them in this.


Part 2: Vehicle Emissions Trading Schemes Updates
Question 13: Are the time limits on the current flexibilities in the ZEV Mandate for cars and for vans still appropriate? Please explain your answer.
Answer.

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

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

Question 16: Do you agree that VETS should be amended to account for the UF change? If so, do you agree with the proposal set out? Please explain your answer.
Answer.

Question 17: Do you agree with the proposal to allow UK derived or EU-derived WLTP-specific emission reference targets to apply from 2021-2023 in the United Kingdom, and in 2024 in Northern Ireland? If not, why?
Answer.