UK Govt Consultation On Plans to Introduce a Zero Emissions Vehicle (ZEV) Mandate from 2030.

Thanks, Richard.

Here's the consultation page: 
"A zero emission vehicle (ZEV) mandate and CO2 emissions regulation for new cars and vans in the UK".

And here's the Government response to the previous consultation:
"Policy design features for the car and van zero emission vehicle (ZEV) mandate".

Jonathan

To respond, cut&paste the words below into a text document or an e-mail, fill in your answers, and send to zevmandate@dft.gov.uk.

I don't believe that you need to provide answers to all of the questions (or you can just say 'I have insufficient information to answer this question').

As Richard says above, the key question is Q5.

MattB

Consultation on a zero emission vehicle (ZEV) mandate and CO2 emissions regulation for new cars and vans in the UK – Response

I am responding to the UK Government’s Consultation on a zero emission vehicle (ZEV) mandate and CO2 emissions regulation for new cars and vans in the UK, as published on your website in March 2023.

I am responding as an individual.

Question 1:

(a) Do you agree or disagree with the UK Government’s preference to introduce a UK-wide regulatory framework?

(b) Or, do you agree or disagree with the introduction of different trading schemes with separate requirements in one or more of the nations, different from the rest of the UK?

Please explain your answer.

Question 2:

(a) Do you agree or disagree with the UK Government’s preference to introduce UK-wide annual targets?

(b) Or, do you agree or disagree with year-on-year targets having to be met within each nation of the UK annually?

Please explain your answer.

Question 3: Do you agree or disagree with the proposal for the central trajectory for new zero emission cars set out in Table 1?

Question 4: Do you agree or disagree with the proposal for the central trajectory for new zero emission vans set out in Table 2?

Question 5: Do you agree or disagree that the proposed derogations (thresholds and adapted trajectories) strike an appropriate balance between supporting small volume manufacturers while also ensuring that all manufacturers play a part in the transition to ZEVs?

Question 6: Do you agree or disagree with these proposals for the inclusion or exclusion of SPVs? If you disagree, please state your reasons for specific SPV categories.

Question 7: Do you agree or disagree with the proposals for banking during the 2024-2030 period?

Question 8: Do you agree with the proposed provisions for borrowing in the 2024–2026 period? If you disagree with the proposal, please provide alternative options and your rationale.

Question 9: What are your views on the proposed minimum requirements for ZEVs (emissions, minimum range and warranty)?

Question 10: Are there additional minimum requirements that should be added to the regulation (in the first year or at a later point)? Please provide your rationale.

Question 11: Do you agree or disagree with the proposal to provide additional credits to ZEVs used in car clubs? Are there any additional criteria or provisions that can increase the effectiveness of these incentives? Please explain your reasoning.

Question 12: Is the proposed incentive mechanism an appropriate and beneficial way to support the development of zero emission WAVs?

Question 13: What are your views on the proposed payment levels in the ZEV mandate?

Question 14: What are your views on the proposed methodology to set baseline CO2 emissions targets for manufacturers?

Question 15: Do you support the flat scenario, the tightening scenario, the lightweighting scenario or a different trajectory for the CO2 standard? Please explain your reasoning.

Question 16: Does the proposal for derogations under the non-ZEV CO2 standard strike an appropriate balance between supporting small volume manufacturers and minimising increases in emissions from combustion engine vehicles?

Question 17: What are your views on the proposed categories for exemptions from the non-ZEV CO2 standard?

Question 18: Do you agree or disagree with the proposal for how pooling would operate under the ZEV mandate and non-ZEV CO2 standard?

Question 19: What are your views on the proposed method for setting non-ZEV CO2 targets for new manufacturers entering the UK market?

Question 20: What are your views on this proposed mechanism to enable overcompliance with the ZEV mandate to help toward compliance with the non[1]ZEV CO2 regulation?

Question 21: What are your views on this proposed mechanism to enable overcompliance with the non-ZEV CO2 standard to help toward compliance with the ZEV mandate targets?

Question 22: What are your views on the levels and structure of the proposed payment system for the non-ZEV CO2 regulation?

Question 23: What are your views on the proposed timeline and process for reporting data and meeting compliance with the ZEV mandate and non-ZEV CO2 scheme?

Question 24: Do you support or oppose the proposal to keep the regulation under review?

Question 25: What are your views on the potential impact of the two proposed schemes on communities in the more rural and remote parts of the UK and to those businesses involved in the sale of vehicles in those areas?

Signature

Name

Date

Question 5: Do you agree or disagree that the proposed derogations (thresholds and adapted trajectories) strike an appropriate balance between supporting small volume manufacturers while also ensuring that all manufacturers play a part in the transition to ZEVs?

Without reading the whole document, what is that in plain English please?

While I do not accept that the new regulations appear to cater for the needs or support the business model of small volume, niche manufacturers, what is meant by "derogations (thresholds and adapted trajectories)"?  It seems that the is UK going it alone whereas the EU (sensibly) has deemed low-volume as out of scope for the entire process - ironic given the number of small companies in-scope are UK based.

these relevant paragraphs are from the consultation document...

21. Micro volume manufacturers (selling fewer than 1,000 cars or vans per year) will continue to receive exemptions from the CO2 emissions standard. All manufacturers selling at least 1,000 cars or 1,000 vans (within the respective schemes) will receive targets using the above method. SPVs, including WAVs, will be exempted from the non-ZEV CO2 emissions standard, as they are exempted under current UK legislation and therefore cannot be considered when determining the baseline emissions data.

2.50  Kit cars, or vehicles purchased as a set of components to be assembled by the buyer, are within the scope of the ZEV mandate if they are new vehicles which go through the type approval process (including individual type approval). Kit cars which are of mixed or indeterminate age (i.e., those having a “Q” registration plate) are not in scope.

2.51  In practice, those obtaining type approval for new kit cars would likely be considered SVMs or MVMs registering fewer than 2,500 vehicles and receive an automatic derogation and no ZEV target to 2029. If the manufacturer produces a kit car which meets ZEV requirements, they would have an extra allowance which could be traded to other manufacturers.

This quite clearly states that manufacturers like Caterham, as a Micro Volume Manufacturer (MVM), selling fewer than 1000 cars per year, will continue to be exempt! Although for how long is not clear. For companies like Caterham, this is actually a benefit because they will be able to sell credits to other manufacturers for every EV car they make. Bonus.

So whats all the fuss about?

#7 It's very clear how long the MVM automatic derogation will be in place.  As para 2.51 of the government's document says "...to 2029".

This is the key issue discussed in the article at #1.

The EU will allow MVMs to build ICE vehicles from 2030 onwards. The UK will not, unless the findings of the government's consultation change their minds. Hence the request that 7 owners respond to the consultation.

MattB

Replying to #7

"This quite clearly states that manufacturers like Caterham, as a Micro Volume Manufacturer (MVM), selling fewer than 1000 cars per year, will continue to be exempt! Although for how long is not clear. For companies like Caterham, this is actually a benefit because they will be able to sell credits to other manufacturers for every EV car they make. Bonus."

Well, not quite right I think - and missing the main point of potential concern. 

Writing from memory, so excuse me if any of this is wrong, but as drafted this UK proposal 'excuses' the MVMs from having to follow the same progressive ramp-up in ZEV output that the major OEMs are subject to, through to 2030.  But, from that point on, the MVMs suddenly become subject to the 'standard' ZEV rules.

For the MVMs, this would mean an easier ride until 2030 but then, overnight, they will be required to ensure that 80% of their UK sales are ZEV compliant.  This requirement then tightens further over the following few years to satisfy the mandated 'zero' non-ZEV sales by 2035 - whether the manufacturer is a major OEM or an MVM. 

This proposal is in stark contrast to EU proposals where MVMs will enjoy non-ZEV sales exemptions in perpetuity.

James

Ah yes I see and the following clarifies that...

Derogations

3.24  As discussed previously, the smallest vehicle manufacturers, those selling fewer than 1,000 cars or vans each year, are responsible for a very small share of the overall new vehicle market and generally produce only one or a few models for specialist markets. These manufacturers are currently exempted from targets under the UK CO2 emissions standard.

3.25  We propose that these micro volume manufacturers (MVMs) also receive a derogation from the non-ZEV CO2 standard (in addition to the ZEV mandate, as described above). MVMs would not be participants in this trading and would therefore face no mandatory CO2 average target until the end of 2030. This derogation would be applied automatically by the scheme administrator each year.

3.26  Under the central proposal, the CO2 emissions standard will not require year-on-year improvements, only that their new non-ZEVs do not become more polluting over time. Therefore, we propose that all manufacturers selling at least 1,000 new cars or vans per year (separately for each scheme) be included under the non-ZEV CO2 scheme and have the same requirement, relative to their own new vehicles’ average emissions in 2021. This would eliminate the small- and niche-volume derogations that currently exist within the CO2 emissions standards.

Replying to #8

"Hence the request that 7 owners respond to the consultation"

To be clear, neither the Club nor Richard as Chair are 'requesting' that members respond to the consultation document. 

We are simply drawing members' attention to the consultation document and the opportunity it represents for members, as private individuals, to consider making a response in whatever way they may feel is appropriate.