Environment analysis: As part of a series of environmental analyses preceding the 26th UN Climate Change Conference of the Parties (COP26), this analysis looks at decarbonising transport.

Addleshaw Goddard Infrastructure Projects & Energy Partners Paul Dight and Suzanne Moir discuss how achievable the government’s transport decarbonisation targets are, what can be done to speed up the decarbonisation process, the Ultra-Low Emission Zone (ULEZ) measure in London and the UK’s role in driving climate change conversation globally.

The government has created an ambitious plan to phase out new polluting vehicles by 2030—ten years earlier than initially planned. To support the acceleration of the plan, the Prime Minister has announced funding for the following:

  • £1.3bn for developing electric vehicle (EV) infrastructure, particularly speeding up the rollout of EV chargepoints in homes, streets and on motorways across England
  • £582m in grants to incentivise more people to buy a zero or ultra-low emission vehicle
  • almost £500m to be invested in the development and mass-scale production of EV batteries

Further, in its ten-point plan for the ‘green industrial revolution’, the government has indicated its aim to make cycling and walking more attractive ways to travel and commitment to continue to invest in zero-emissions public transport. Creating better public transport and providing a safer environment for cycling and walking can have a significant impact on changing behaviour and therefore encouraging a switch from private vehi-cles entirely.

Paul Dight and Suzanne Moir outline their views on the government’s plans, including its strengths and shortcomings, below.

Do you think the government’s targets are achievable given the current lack of supporting infrastructure?

There is no shortage of people willing to fund and install charge points. We are seeing new ones springing up all the time. Public perception around ‘range anxiety’ is also improving as batteries become more efficient and cars can travel further on a single charge. Many believe we are at the start of an ‘S curve’ where uptake of EVs will start increasing exponentially. Car manufacturers are gearing up, with Volvo announcing they will sell only electric cars from 2030 and Jaguar going for a date five years earlier than that.

There are some obvious challenges that still need overcoming. There is no regulation in England and Wales of where charge points can be sited. This means many charge points in some areas, none in other—mainly remote, areas where it does not make financial sense to install a commercial charge point as not enough people will use it. The government has powers in section 11 of the Automotive and Electric Vehicles Act 2018 to require charge points to be installed at major fuel retailers but so far has chosen not to exercise those powers but to leave it up to industry to roll out public charge points.

Then there is the problem of making sure landlords are sufficiently incentivised to allow a charge point to be installed on their land. The government consulted in 2019 on proposals to mandate the provision of EV charging points in new residential and non-residential buildings and any building undergoing a major renovation. This will involve changing the Building Regulations. So far, the outcome of that consultation is still awaited. But a gentle nudge in the right direction for landlords wouldn’t be the worst thing.

Last, but certainly not least, there needs to be sufficient electrical capacity in the location to allow a grid connection, particularly for the rapid and ultra-rapid charge points. In 2020 the government launched a £500m Rapid Charging Fund to meet a portion of electricity connection and upgrade costs at strategic sites across the road network where it would otherwise be ‘prohibitively expensive and uncommercial’ to install EV infrastructure. The aim is to have at least six high-powered open access charge points at every motorway service station and 2500 high-powered charge points across the road network by 2030. But query whether this is enough. To deliver the capacity that will ultimately be needed, will surely need significant investment in the networks. And we hope that Distribution Network Operators can be sufficiently agile over the next two price control periods to respond quickly to the inevitable surge in EVs and consequent demand for capacity for chargepoints.

What actions do you think the government, industry and consumers need to take to speed up the decarbonisation of transport in the UK?

The Department for Transport issued a Call for Evidence in 2020 to inform its Transport Decarbonisation Plan. This Plan was expected in 2020 but has been delayed due to the coronavirus (COVID-19) pandemic. It is expected within the next few months. Once it is published, industry and consumers will have a clearer idea of the pathway to decarbonise transport and the government support that may be available. So a clear policy direction from government would help to speed up transport decarbonisation. The outcome of the Future of Transport Regulatory Review will also help, with regulations on hail and ride services and e-scooters set to be relaxed to allow these services to increase.

The transport industry is already taking action to decarbonise. Network Rail published its Traction Decarbonisation Network Strategy in September 2020, focusing on electrification of the rail network where possible and the use of hydrogen or battery-powered trains in the remoter areas.

The real change needs to come with how we use transport. Shifting to zero emission vehicles at the expense of public transport is not the answer. Consumers need to use the car less and public transport more. That means public transport has to be an attractive and cost-effective option. The Bus Strategy hopes to achieve this for buses, which are the backbone of public transport. But with the phasing out of vehicle excise duty (which is a tax on emissions) as cars get cleaner, a parliamentary committee is looking at a potentially unpopular option—road pricing. Transport is a devolved matter so the administrations and governments in Westminster, Wales and Scotland would need to work together to design and implement a national road pricing scheme.

Looking at the ULEZ measure in London, do you think more cities in the UK should take a similar approach? Are there any measures that the government should implement to allevi-ate the disproportionate impact that these zones will likely have on specific businesses and workers?

If a city was to implement a ULEZ measure implemented by a road pricing charge under the Transport Act 2000, it would involve hefty public consultation (the process in London is less arduous in terms of public consultation as it’s under different legislation). Edinburgh and Manchester wanted to implement such a charge, but they held local referendums as part of the public consultation process which killed the initiative as it was overwhelmingly voted against.

However if the public consultation was done differently (collaboratively, getting the message across about how less traffic in the city would produce more benefits than hardship) it will likely produce recommendations to address these very issues, and even better, these recommendations would be specific to the region. Transport for the North has, for example, just issued its draft decarbonisation strategy for consultation, on how the region can reach near net zero emissions by 2045.

As for the impact a ULEZ may have on specific businesses and workers, climate change and air quality is an issue that affects us all. London originally allowed an exemption from the congestion charge for private hire vehicles but later removed it. This disproportionately affected BAME drivers but when challenged, it was considered a necessary and appropriate course of action in order to achieve the strategic aim of reducing congestion. [Independent Workers Union of Great Britain v Mayor of London [2020] EWCA Civ 1046].

What do you think the UK government can do to encourage and support other nations in achieving a zero emissions future in transport?

The UK needs to lead by example and show what can be done. The transport sector in the UK is the only sector whose emissions have increased in recent years and it is the economic sector with the highest emissions. The 2030 ban on the sale of new petrol and diesel cars puts the UK on course to be the fastest G7 country to decarbonise cars and vans and we don’t want to lose this momentum.

Interviewed by Anna Rylik. This analysis was first published by LexisNexis.

Key Contacts

Paul Dight

Paul Dight

Partner, Energy and Utilities
United Kingdom

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Suzanne Moir

Suzanne Moir

Partner, Infrastructure, Projects and Energy

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