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CMS Guide to Electric Vehicles

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CMS Guide to Electric Vehicles
Introduction
Interest in EVs has waxed and waned over the years, but the last ten years have seen a momentous surge in the market, which is set to transform the automotive industry.
The International Energy Agency (“IEA”) has examined this market growth in its recent report entitled “Global EV Outlook 2017: Two million and counting”.1 The IEA cites the following headline statistics:
  • The number of electric cars on the road globally surpassed 2 million in 2016, having reached 1m in 2015. A
    stark increase from 2005, when the figure was just over 1,000. China and the US account for more than half
    of electric cars in the world.
  • A new record of sales of EVs was achieved in 2016, with over 750,000 sales worldwide.
  • China was by far the largest market in 2016, accounting for almost half of the EV sales in 2016. This was more than double the number of registrations in the US, the second largest market.
  • In terms of market share, Norway is incontestably the global leader with 29% of its total passenger light duty vehicle (“PLDV”) sales in 2016 being registered as EVs. China’s vast EV stock constitutes only 1.5% of its total PLDV sales. These were two of only six countries to achieve an electric car market share of above 1% of their total PLDV sales.

However, there has been a slowdown in market growth rates in recent years which has been linked to the removal of government subsidies. Whilst it was expected that, in-line with all emerging markets, growth rates would ultimately inevitably decline, the EV market still seems a million miles away from the potential scale it could achieve, with EVs representing just 0.2% of the total number of PLDVs in circulation globally2.
Drivers of EV market growth
Tackling climate change
Global framework
Climate change is a significant driver in the development of EVs. The Paris Agreement, which came into force in November 2016, brings a large number of nations together in the pursuit of reducing greenhouse gas (“GHG”) emissions and limiting global warming to well below 2°C. The Agreement requires all parties to declare “nationally determined contributions” (“NDCs”), which embody efforts by each country to reduce national emissions and adapt to the impacts of climate change.
EVs have the potential to be instrumental in enabling countries to meet their NDC targets. Electric motors are more efficient than combustion engines and this, coupled with the transition to a lower-carbon electricity generation mix, is how EVs can contribute to the reduction of carbon emissions. The 2015 Paris Declaration on Electro-Mobility and Climate Change states that transport contributes to 23% of the current global energy-related GHG emissions and is growing faster than any other energy end-use sector. The IEA has estimated that EVs must represent 35% of new vehicle sales by 2035 to limit climate change to less than 2%. This is recognised and demonstrated in the EU’s transport-related measures outlined below, which have been put in place to help the EU achieve its NDC goals of reducing GHG emissions by 40% below 1990 levels by 2030 and 80% below 1990 levels by 2050:3
  • The 2009 Renewable Energy Directive requires member states to ensure that at least 10% of transport energy consumption is derived from renewable sources by 2020.
  • The 2009 Emission Performance Standards Regulation requires car manufacturers to achieve a certain average emissions level across the new vehicles they sell and to make available to consumers information about the emission performance of their vehicles.
  • The 2009 Clean Vehicles Directive requires public bodies in Member States to consider fuel consumption and pollutants when procuring road vehicles.
  • The European Commission’s 2011 Single European Transport Area white paper sets a target of a 60% reduction in transport GHG emissions by 2050 (by 1990 levels).
  • The 2014 Alternative Fuels Infrastructure Directive requires member states to put in place national policy frameworks for the development of the market for non-fossil fuels in the transport sector, including the provision of adequate EV charging infrastructure in developed areas.
  • The European Commission’s 2016 Strategy for Low-Emission Mobility summarises at a high level its focuses for legislative development and the application of support funding in relation to the transition to sustainable transportation. Such focuses include the efficiency of taxation and price signals, the evolution of emission performance standards and the improvement of vehicle emissions testing to regain consumer trust.
  • Building on this, more rigorous vehicle emissions testing standards, including testing in real driving conditions, were imposed in September 2017; in November 2017, the Commission proposed a 30% reduction of the EU’s mandatory average emissions levels for manufacturers of light vehicles by 2030.4

The NDCs of other major polluting nations demonstrate varying levels of ambition: China has committed to a 60% reduction in GHG emissions from 2005 levels by 2030, whereas India is targeting 33%, and Russia is aiming for a 25% reduction in GHG emissions from 1990 levels by 2030. The US has formally notified the UN of its intention to withdraw from the Paris Agreement, but the target it had previously set was a 26% reduction in GHG emissions from 2005 levels by 2025. China, India, Japan and the US (unlike the EU) included specific transport emissions measures in their NDCs, including fuel efficiency improvements and alternative fuel promotion.


The Bloomberg New Energy Finance report – Electric Vehicle Outlook 2017 predicts that by 2040 EVs will displace
million barrels of transport fuel per day, and add 5% to global electricity consumption.
Local policy implications
This global-level ambition to reduce emissions has trickled down to national-level government policies and initiatives. These have ranged from:
  • In 2009, the IEA’s Clean Energy Ministers set up the Electric Vehicle Initiative dedicated to accelerating the deployment of EVs worldwide. Its EV30@30 campaign launched in 2017 sets a collective “aspirational goal” for EV1 members of a 30% market share for EVs by 2030.4
  • Announcements from the UK5 and French6 governments followed suit that the sale of new conventional petrol and diesel vehicles will be banned by 2040, and a more ambitious deadline from India’s energy minister7 of 2030.
  • Measures that encourage take up of EVs in large cities (e.g. Paris, London, Mexico City, Stuttgart, Tokyo) including the banning or restricting of polluting vehicles, or imposing charges for such vehicles, entering specified city zones.
  • Financial incentives for the purchase of new EVs, along with a range of tax and access benefits for ownership, across larger European economies. Norway and the Netherlands are leading the way on incentives, with special measures including nationwide toll exemptions in Norway and an urban charging point development regime led by resident applications in Amsterdam.
  • The tightening of vehicle emissions standards. The EU is currently ahead of the rest in this respect, but the US and Canada are phasing in even more stringent standards. The standards in China and India are less demanding, though plans are in place in both jurisdictions to catch up to the EU.

China’s remarkable EV sales growth is largely attributable to promotional measures such as sizeable purchase subsidies, large-scale charging infrastructure funding and restrictions on registrations of combustion-engine vehicles. However, the market is already showing signs of over-reliance on subsidies, with a precipitous fall in sales linked to subsidy reductions in early 2017.
Consumer demand
Demand for electric vehicles is increasing due to factors including the following:
Increasing affordability
At present, EVs are generally more expensive to purchase than their conventionally powered counterparts, but the gap is closing. In May 2017, the Financial Times (“FT”) reported on a UBS analysis that forecast cost parity between EVs and conventional gas and diesel vehicles as early as 2018 in Europe, by 2023 in China and by 2025 in the US.8 In September 2017, the Bloomberg New Energy finance research that predicted “tumbling battery prices” would make EVs cheaper to buy than conventional vehicles in most countries by 2025–29, predicting that EVs would make more than half of new car sales worldwide by 2040.9

Consumers are also attracted by the comparative cheapness of EVs to run and maintain: while the price of diesel and petrol continue to increase, the cost of charging an electric car is negligible by comparison; EVs contain many fewer moving parts than combustion-engine vehicles.
Media attention
In terms of technology, the following were key milestones in the increase of public interest in EVs:10
  • The release of the Toyota Prius in Japan in 1997 and worldwide in 2000 which became the world’s first mass-produced (and subsequently best-selling) hybrid EV;

  • The announcement by Tesla in 2006 that it was starting production of luxury electric sports cars that could go more than 200 miles on a single charge following in 2017 with the launch of Tesla’s first mass-market model.

Spurred by Tesla’s first announcement, other automakers have begun rolling out their own EV models and it is reported that today there are now 23 plug-in electric and 36 hybrid models available. In 2017, many of the world’s largest automakers (including VW, Volvo, Toyota, General Motors, Renault-Nissan and Ford) announced ambitious targets for investment in and sale of electric models. Amongst these, Volvo, announced that every new car in its range would have an electric power train available from 2019.

Climate change is also ever-present in the headlines.
Challenges
While deployment of EVs could alleviate a number of environmental concerns, mass uptake and market saturation will bring with it its own set of challenges. Cost is also a significant issue.
Cost

EVs are heavily subsidised in many countries and whilst these subsidies are crucial to the success of a mass EV rollout
they may not be liable in the long-term. The Bloomberg New Energy Finance report forecasts that EVs will become
price competitive without reliance on subsidies by 2025.
Charging infrastructure
Range anxiety is one of consumers’ key fears when considering switching to an EV. Charging infrastructure will need to keep pace with the growing number of EVs. Businesses across electricity markets will need to take into account the impact of the additional capacity required from each country’s grid. A rapid increase in demand for electricity from the grid is not a foregone conclusion; it is possible that demand from the grid could decrease as businesses and domestic consumers forge their own charging solutions, whether by means of embedded generation or energy storage.
Batteries
Batteries have been a significant obstacle in the wider deployment of EVs to date and represent a large proportion of their cost. Battery characteristics including energy density, longevity and charge time impact greatly on the range and performance of EVs. Manufacturers have made significant improvements in these areas, but there is still a way to go to achieve value parity with vehicles with combustion engines, especially for heavier vehicles.
The table below sets out the types of batteries currently used in EVs:



Battery typeDescription and useAdvantagesDisadvantages
Lead-acid batteriesCommonly used in forklifts and golf carts. Rarely used in modern EVs.
  • Cheap to produce
  • Toxic
  • Volatile
  • Short lifespan
  • Low energy density
Nickel metal hydride [NiMH]Uses hydrogen ions to store energy around nickel and e.g. titanium. Currently used primarily in hybrids but rarely in BEVs.
  • Safer than Li-ion – fewer volatile materials.
  • Faster rate of self-discharge when not in use than Li-ion.
  • Semi-toxic – requires special handling to recycle.
  • Recharging early can diminish capacity.
Lithium ion batteries [Li-ion]Uses liquid electrolyte. Currently considered to have the most potential for mass-market EVs
  • Higher energy density than NiMH.
  • Versatile – greater scope for varying discharge currents, voltages, charge times etc.
  • High cost – especially the most advanced units.
  • Degrades with age at faster rate than NiMH.
  • Technology may have reached an energy density barrier.

Despite the various problems with current battery technologies, automakers have largely, so far, eschewed hydrogen fuel cells. Compared to batteries, fuel cells would have the benefits of being smaller, lighter and instantly rechargeable; but they are currently much further from economic viability than batteries. Instead, new battery types are in development, with both “solid state” and “lithium air” batteries promising further gains in the crucial variable of energy density.
Policy, regulation and other legal issues
As previously indicated, the EV market is heavily reliant on policy support in respect of both EVs and charging infrastructure. Policy tools currently in use include purchase subsidies, research, development and deployment measures, fuel economy standards, mandates for automakers to sell a set portion of zero-emission vehicles, and access restrictions. It is thought that policy support will remain indispensable, at least in the medium term; however, as EVs become more cost competitive and economics takes the driving-seat, policy adjustments may be required.

Cohesive regulatory frameworks for EVs are not yet well-established. To prepare for the universal electrification of roads, there is likely to be a need for national legislation on a broad range of issues, including vehicle licensing and taxation, vehicle and charging standards and the smart management of grid demand.
Opportunities
The increase in deployment of EVs creates a wealth of opportunities for investors, automotive manufacturers, electricity generators, supply chains, network operators, energy suppliers, consumers, infrastructure owners and developers, real estate developers and other electricity and automotive sector participants. In fact, the market potential is drawing in participants from other sectors too, including UK technology company Dyson, which has recently announced its £2 billion project to develop and build EVs from scratch, which it claims will bring more inventive designs to the market.11 This is a truly exiting space driving innovation.
About this guide
The CMS Energy group is passionate about developments that impact the EV industry. We strive to constantly be on top of R&D, engage in constructive dialogue and help our clients manage the challenges and opportunities brought by change. This e-guide is our approach to help our clients, whether they are battery or vehicle manufacturers, EV infrastructure providers, network or supply businesses, get acquainted with EV developments across the world. We started with a chapter on developments in the UK and continue to update this guide monthly with chapters from other jurisdictions across Europe, Asia, the Middle East and Latin America.
How we can help
Please contact your CMS contact in the relevant jurisdiction if you wish to discuss the impact of these changes for your business further or for more general enquiries please contact:



Marianne Anton Sarah A. King
Associate Partner
T +44 20 7367 2745 T +44 20 7367 2537
E marianne.anton@cms-cmno.com E sarah.a.king@cms-cmno.com

References
  • https://www.iea.org/publications/freepublications/publication/Globa1EVOutlook2017.pdf (accessed 15 February 2018)
  • As above in fn. 1
  • See the Commission Staff Working Paper at https://ec.europa.eu/transport/sites/transport/files/themes/strategies/news/doc/2016-07-20-decarbonisation/swd%282016%29244.pdf for a detailed summary of the existing EU measures on sustainable transportation.
  • https://ec.europa.eu/clima/policies/transport/vehicles /proposal_en#tab-0-1
  • https://www.gov.uk/government/news/plan-for-roadside-no2-concentrations-published
  • http://www.gouvernement.fr/en/climate-plan
  • http://www.independent.co.uk/news/world/asia/india-electric-cars-2030-fossil-fuel-air-pollution-piyush-goyal-climate-changea7711381.html
  • https://www.ft.com/content/6e475f18-3c85-11e7-ac89-b01cc67cfeec
  • https://www.ft.com/content/fbbc05b0-9c75-11e7-8cd4-932067fbf946. cf Nissan’s recent prediction of 2025 cost parity – https://www.ft.com/content/7bbd9a9a-1326-11e8-940e-08320fc2a277
  • https://energy.gov/articles/history-electric-car
  • https://www.ft.com/content/564aa742-0cac-11e8-8eb7-42f857ea9f09

Bulgaria
While Bulgaria’s business is exploring the EV market and the opportunities it offers, the Bulgarian Government faces a lot of changes if it is to make this segment attractive to the wider population.
1. What EVs have been deployed in your jurisdiction to date?
Number of “Ultra-low emission vehicles”
registered in the first quarter of 20171
Total number of vehicles registered in Bulgaria2
241 (2 plug-in hybrid electric vehicles + 239 hybrid electric vehicles) 3,300,000

EVs represent a small proportion (0.5%) of the vehicle fleet in Bulgaria, according to official data from the European Automobile Manufacturers’ Association (ACEA).
As there were no battery electric cars registered in the first quarter of 2017, the amount of “ultra-low emission vehicles” for this period comprises plug-in hybrids and hybrids only.
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
The National Plan for the Actions for the Promotion of the Production and Enhanced Implementation of Ecologic Motor Vehicles, including Electricity Mobility in the Republic of Bulgaria, was adopted for the period 2012-2014.
An inter-governmental work group was created last November to develop a national work programme together with a road map for developing electricity mobility in Bulgaria up to 2025, with an extended horizon of 2030.
A number of legislative changes were introduced to the primary and secondary legislation. These were aimed at providing tax and other benefits for the owners of EVs, developing the infrastructure and promoting investments in the sector.
The Acts and regulations affected include: the Local Tax and Fees Act3; the Road Traffic Act4; the Spatial Development Act5; and the Ordinance for the Design of the Communication-Transportation System of the Urbanized Territories6.
3. What measures promote EVs in your jurisdiction?
3.1 The National Trust Eco Fund manages the Climate Investment Project and the Promotion of the Use of Electric Vehicles Programme. The programme provides grants for projects connected to promoting the use of EVs by public authorities. The Minister of Environment and Waters distributes the funds to state and municipal institutions.

The focus is on vehicles that may be used for public service activities, including: cleaning; maintenance of parks; social services; inspections; and ensuring the provision of in-town public transport in small settlements with small passenger flows.

The list of EVs eligible for purchase under the programme has been significantly expanded.

The subsidies are:
  • per medium class M1 (vehicles with up to 8 seats) and N1 (cargo vehicles with a permissible maximum weight of up to 3,5 tons) EV – BGN 20,000
  • the small L7e – BGN 20,000
  • minibuses – BGN 40,000
  • class M1 and N1 (6+ 1 and 7+ 1 seats) – BGN 30,000
  • up to BGN 3,000 for the purchase of various types of superstructures for cleaning, cargo transportation, and watering the small L7e.

3.2 Incentives for EV owners (natural persons or legal entities) include: (i) preferential tax treatment and (ii) no fees for parking in paid areas.
The owners of electric cars, motorcycles and mopeds – as well as electric vehicles in categories L5e, L6e and L7e specified in art. 4 of Regulation (EU) No. 168/2013 – are exempt from paying annual local tax for these vehicles.
An electric vehicle is defined as a passenger vehicle with a purely electric powered motor that does not have an internal combustion engine.
EV owners do not pay for parking in the paid areas of the cities of Sofia, Plovdiv and Burgas.
3.3 The network of chargers and charging stations in the country has expanded rapidly in recent months.
Sofia’s municipality is planning to add 64 extra points in the capital for the placement of charging stations.
One of the major petrol station chains in the country recently announced that is planning to put 16 charging points for fast charging of EVs across its national network during the first quarter of 2018. The first two are already in operation.
4. Who are the main entities (e.g. developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
In addition to government, the following business organisations are leading players in Bulgaria’s EV market:
  • EVIC – Electric vehicles industrial cluster – its main aims include: establishing a national charging infrastructure for EVs; adapting legislation and the regulatory framework for promoting the use of EVs; and industrial investment projects for technological innovation and the introduction of innovations to reduce energy intensity of transport schemes.
  • Eldrive International – its goal is to develop a user-friendly infrastructure of charging stations, covering the city areas as well as the main road infrastructure in the Balkans (Bulgaria, Romania, Macedonia, Greece, Albania).
  • SPARK – the first fully electric car sharing company which provides affordable eco-friendly mobility solutions in Sofia. The SPARK car sharing system also includes a wide network of charging stations in Sofia to ensure the availability of the necessary infrastructure.

5. What are the main challenges to further deployment of EVs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
For Bulgarian consumers, obstacles to EV ownership include:
  • Price – EVs remain more expensive than combustion-driven vehicles – both the vehicles and the insurance premiums.
  • Freedom of travel – even though the charging system is growing rather rapidly, it is still not sufficient to ensure the unimpeded and easy charging of EVs throughout the country.

References
  • Number of registered vehicles for the first quarter of 2017
  • Approx. total amount of registered vehicles in Bulgaria according to Eurostat
  • State Gazette Issue No. 117 dated 10 December 1997, as amended;
  • State Gazette Issue No. 20 dated 5 March 1999, as amended;
  • State Gazette Issue No 1 dated 2 January 2001, as amended;
  • State Gazette Issue No 86 dated 1 October 2004, as amended;


Croatia
Croatia is increasingly interested in EV development. After a two-year break from granting incentives for the purchase of EVs, incentives for buyers will be reintroduced in 2018. Unofficial information suggests that EVs will be financed up to HRK 70,000 (approx. EUR 9,300).
1. What EVs have been deployed in your jurisdiction to date?
EVs represent a small proportion of Croatia’s licensed vehicles. Currently, there are 224 EVs, 1,843 hybrid vehicles, and 445 electric mopeds and bicycles registered in the country. However, during 2014 and 2015, subsidies of HRK 50m helped the purchase of 1,428 EVs on the Croatian market.. No incentives were available in 2016 and 2017 and EV sales slowed dramatically – only 9 EVs were registered in the first eight months of 2017. With new purchase incentives anticipated in 2018, a rise in the number of registered EVs is likely.
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
Croatia’s Act on Promotion of Clean and Energy Efficient Vehicles in Road Transport transposes into national legislation the provisions of EU Directive 2009/33/EC on the promotion of clean and energy-efficient road transport vehicles.
Key programmes include:
  • “Drive Economically” aims to stimulate the purchase of electric and hybrid vehicles – plug-in and with up to 90g CO2/km emissions – by citizens, companies and trades. The programme is implemented by the Environmental Protection and Energy Efficiency Fund (EPEEF).
  • “Green Public Transport” promotes the purchase of environmentally-friendly public transport vehicles, implemented by EPEEF.
  • An eco-driving training programme, implemented by EPEEF.
  • “Green Line”, a grants programme to enable county public institutions, national parks and nature parks to purchase electric vehicles, vessels and hybrid vehicles, implemented by EPEEF.
  • The Transportation Emissions Reduction Programme for 2013-2020, prepared by the Ministry of Environment and Energy (MEE).

3. What measures promote EVs in your jurisdiction?
  • Number of charging points – there are 201 charging points across the country with plans to increase the number to as many as 345.
  • Free charging points – currently, charging points are free. This makes the system economically unsustainable and charging points will soon have to commercialised.
  • EV purchase grants – new purchase grants should be approved in early 2018.

4. Who are the main entities (e.G. Developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
As this subject matter relates to traffic, energy and environmental protection and tourism, it falls within the remit of four government ministries: (i) MEE, (ii) Ministry of Economy, Entrepreneurship and Crafts, (iii) Ministry of the Sea, Transport and Infrastructure, (iv) Ministry of Tourism.
EPEEF co-finances the measures for enhancing energy efficiency in transportation through three programmes: co-financing the purchase of electric, plug-in hybrid and hybrid vehicles for citizens, companies and trades; co-financing eco-driving training programmes; and co-financing other measures for energy.
MENP prepared the Transportation Emissions Reduction Programme for 2013-2020, which complies with the Energy Strategy of the Republic of Croatia (“the Energy Strategy”). This programme outlines measures to reduce emissions from transport and aims to achieve a goal of 10% share of renewable energy sources in all modes of transport.
5. What are the main challenges to further deployment of evs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
There are three main challenges: the network of charging points, the price of electricity, and keeping up with international eco-standards and obligations.
The network of charging points is the key infrastructural problem – a good charging network is an important infrastructural prerequisite for further development and deployment of EVs. Most Croatian cities and municipalities have charging points, but there are almost no charging points on the motorways. In the years to come, tourists will be increasingly coming to Croatia with EVs, and if the infrastructure is underdeveloped, Croatia’s tourism may suffer.
A further problem with the existing charging point system is that it is economically unsustainable because, for now, it is free for users. A separate but related issue is that the price of the vehicles themselves is another important factor influencing the development of EVs in Croatia.
The price of electricity is a second major challenge. For electricity to compete with petrol, diesel and gas, the current tariff model should be redefined. Specifically, a more favourable green tariff for EVs should be introduced.
Meeting international environmental commitments is a major test for Croatia. Under the Energy Strategy, Croatia’s transport sector must use 10% renewable energy sources by 2020, up from only 3% today. By ratifying the Paris Agreement, Croatia committed to reducing greenhouse gas emissions by 40% by 2030. The EU goal is to completely exclude oil derivatives from road traffic by 2050. Despite these challenges, Croatian projections state that by 2030, about 35% of its vehicles will be electric.
Germany
Germany, Europe’s largest automobile market and world leader in vehicle exports, has immense po-tential for e-mobile development. Although the sales and manufacturing market for EVs is still se-cond to traditional combustion engines, e-mobility is one of the most widely discussed topics within the mobility debate and has been at the core of a number of official programmes. Ambitious climate goals and mounting confusion regarding the pollutant emissions of diesel engines have recently add-ed momentum to the debate.1
1. What EVs have been deployed in Germany to date?
As of January 2017, EVs represented a small but increasing proportion of vehicles registered in Germany. Out of a total of 45,804,000 registered passenger cars, 34,022 were electric cars.2 Renault led the EV sales market with close to 8,000 vehicles followed by Smart, Volkswagen and Tesla with approximately 4,500 cars each.3 Around 25,000 more electric passenger cars were registered during 2017, along with 6,595 electric trucks and 168 electric buses.4
Hybrid EVs are leading plug-in EVs with 165,405 passenger cars registered as of January 2017 and 84,675 new registrations during the year.5 Hybrid trucks account for only 126 vehicles,6 and there are 318 registered hybrid buses.7
2. Is there any specific legislation for/regulation of EVs in Germany?
The cornerstone of Germany’s mobility policy is the Act on E-Mobility (Elektromobilitätsgesetz) of 2015. It allows municipalities to create preferential parking options and apply reduced parking rates for EVs. It also creates new traffic signs and introduces special number plates indicating the vehicle’s electric engine and thus its eligibility for a special set of privileges. The act makes EVs eligible for exceptions to traffic restrictions, an aspect that may become significant in the current debate over pollutant thresholds.
The government has implemented a number of tax exemptions to promote the use of EVs. They are currently exempt from vehicle taxes during the first ten years after registration and are subject to re-duced tax rates thereafter. Taxes on electric company cars are already lower and will be lowered to half the regular tax according to the 2018 coalition agreement signed by the new government par-ties. Further tax advantages include exemptions for the supply of charging power or charging sta-tions by the employer.
Recently, the Federal Council (Bundesrat) reintroduced an older legislative project which could not be finalised in the last legislative period and that aims to facilitate the establishment of private charg-ing stations by tenants and apartment owners. The proposal grants substantial rights to landlords and co-owners in order to promote the installation of charging stations. It has not yet been subject to par-liamentary debate.
The Act on the Digitalization of the Energy Transition (Gesetz zur Digitalisierung der Energiewende) of 2016 introduced the possibility of reducing network access fees for power suppliers who contrib-ute to the integration of EVs as energy storage units in the electric grid, with the long-term goal of creating a “smart grid”.
The legal framework for the installation of public charging stations is set by the Decree on Charging Stations (Ladesäulenverordnung) of 2016, specifying the technical standards and aiming to ensure the interoperability of public charging stations. As of February 2018, there are 8,515 charging sta-tions in Germany providing a total of 25,264 charging ports – an increase of about 2,000 stations since the decree was implemented.8 Charging station operators are required to allow charging on a case-by-case basis without prior authentication (so called e-Roaming). The decree requires operators to report the positions of charging stations to the Federal Network Agency (Bundesnetzagentur) which publishes the data in a public map. The Act on the Further Development of the Electricity Market (Gesetz zur Weiterentwicklung des Strommarktes) of 2016 clarified that charging stations are to be treated as ultimate consumers under energy law and are therefore not subject to any operator obligations under the relevant regulations.
3. What measures promote EVs in Germany?
The Federal Government aims to establish Germany as the lead market with at least one million EVs by 2020 and 30,000 new jobs in the e-mobility sector. To achieve these goals, it established the Na-tional Platform for E-Mobility (Nationale Plattform Elektromobilität) in 2010, composed of repre-sentatives from industry, politics, science, associations and trade unions. The working groups exam-ine various key issues and present their reports to the public.
Starting with the National E-Mobility Development Plan (Nationaler Entwicklungsplan Elektromobilität) in 2009, the government has adopted a series of measures affecting the implementation of e-mobility. The aim of this programme is to promote research and development and the market intro-duction of EVs with batteries. As part of the economic recovery package, various ministries tendered funding totalling EUR 500m allotted to 15 projects, mainly relating to e-mobility research and test-ing. This was followed by the “Elektro Power” programme and the current “Elektro Power II”, which subsidises 13 programmes with total funding of EUR 25m to further innovation in the field of production systems and battery efficiency, establish standards and norms and reduce production costs.
To improve the infrastructure of the charging station network, the government has launched a EUR 300m subsidy programme. The government parties pledged in their coalition agreement to expand the charging infrastructure with the goal of reaching 100,000 charging stations by 2020, a third of which are to be direct current (DC) fast charging stations.
During the management of the “diesel crisis” in 2017, the Federal Government launched the Immedi-ate Action Plan Clean Air 2017-2020 (Sofortprogramm Saubere Luft 2017–2020). The programme is based on a government fund of EUR 1bn. It contains various incentive schemes. The plan allows municipalities and public transportation operators to obtain funding of up to 75-90 % of additional investment costs for the procurement of EVs. Additionally, commercial providers such as craftsmen, nursing services and car sharing operators can receive up to 60 % refund of additional costs if their purchase is integrated in a local mobility concept. The purchase of buses for public transportation services and related service and maintenance activities are eligible for subsidies of up to 80 % of the additional cost.
The Immediate Action fund also provides funding for research and development projects that exploit the potential of e-mobility and contribute to strengthening the competitive position of the German industrial sector.
For private citizens and entities, the Federal Government is cooperating with car manufacturers to offer an Environment Bonus (Umweltbonus). The programme is state funded with EUR 600m and allows participants to receive a federal contribution of EUR 4,000 for the purchase or leasing of a new EV or EUR 3,000 for plug-in hybrid cars, provided that the manufacturer offers a discount of the same amount. The funding started in 2016 and will end when the fund is used up, or at the latest in 2019. As of February 2018, 31,312 applications had been entered for EVs and 22,946 applications for hybrid cars. The impact of the programme is controversial, with studies showing limited influence on consumers’ decisions to invest in EVs9.
4. Who are the main entities (e.g. developers, government, System Operator) and what are their roles in the deployment of EVs in Germany?
  • Federal and local governments – The government provides legal framework for the develop-ment of technical standards as well as incentives to invest in EVs. The Federal Government and some local governments have declared to target a share of at least 20% of EVs in their own car fleets. Some regions, such as Baden-Württemberg, have set up their own subsidy programmes. Cities are exploring e-mobility funding as a way to reduce pollution. Munich, for example, has launched a EUR 60m investment programme accompanied by EV purchases for the city fleet and public transportation. The state of Berlin has tendered the implementation of a system of charging stations throughout the city and has commissioned the construction and operation to a consortium of Alliander/Allego and The New Motion.10
  • Automobile manufacturers – German car manufacturers traditionally rely on combustion en-gines and face strong competition from competitors from France, Asia and the US. Recent devel-opments indicate stronger involvement in EV projects. For example, Daimler AG has launched tests for electric city buses. Additionally, Chinese investor Li Shufu, known for pushing e-mobility in the Volvo Group, has acquired 10% of Daimler’s shares.
  • Researchers, developers and start-ups – Key issues to implement e-mobility include the longev-ity, range and charging time of batteries and need to be addressed by specialized industries. Even in EV production, beyond classic car manufacturers, niche companies have emerged that address specific needs. For example, Streetscooter, together with DHL, produces utility vehicles for par-cel delivery.
  • Car sharing operators and taxi companies – EVs account for about 10% of the vehicle pool of car sharing fleets in Germany11. However, the branch association Bundesverband CarSharing re-gards high procurement costs and reduced occupancy rates due to long charging cycles as obsta-cles to an economically profitable operation.
  • Operators of charging stations – The driving range of EVs remains one of the obstacles to their success; a broad network of charging stations is crucial. A group of German car manufacturers (BMW Group, Daimler AG and Volkswagen Group) have formed the joint venture “Ionity” to-gether with Ford Motor Company and vowed to create a High-Power-Charging network in Eu-rope with Autobahn Tank & Rast, operating around 360 motorway petrol stations and motorway 400 service stations in Germany, as on-site partner. Retailers such as ALDI SÜD provide charg-ing stations in their car parks and offer charging to their customers for free.
  • Associations and branch representations – The perception, promotion and acceptance of e-mobilty concepts also depends on the support of industry and other associations. A key player is the VDA (Verband der Automobilindustrie) representing German car manufacturers. Other spe-cific associations have been created, e.g. the Bundesverband eMobilität, uniting companies from business segments including vehicle construction, electrical engineering, transport and renewable energies.

5. What are the main challenges to further deployment of EVs in Germany? How have EV de-velopers sought to overcome these challenges to date?
Consumers refer to the high price and short range of EVs as well as the large distance to charging stations as the most common barriers preventing the purchase of an EV.12 The technical challenges of decreasing the production costs and charging time while increasing the range of EVs will be cru-cial for consumer acceptance. These demands, while challenging, offer an opportunity for the Ger-man motor industry which is already world leader in the number of automotive patent registrations.13
The battery manufacturing industry is struggling to enter the strongly competitive market with estab-lished competitors from Asia profiting from lower production costs. Bosch, one of Germany’s lead-ing innovators14, has cancelled a highly anticipated project to develop battery cells in Germany15 while German companies Siemens and Manz are partnering with Total’s Saft and Solvay to develop high-density lithium-ion and solid-state technology batteries.16
The development of e-mobility is still highly focused on cities. Although the network of charging stations has been growing in the recent past and promised legislatives steps to ensure a further in-crease of the number of stations have been taken, the charging infrastructure remains largely centred on urban agglomerations in the western part of Germany.17 In order to achieve a collective approach to e-mobility, it will be necessary to improve the infrastructure especially in structurally weak regions with long driving distances.
One of the main challenges will be to motivate automobile manufacturers to rely on the new tech-nologies available to them. The rise of companies like Streetscooter that are filling a void left by the lack of offerings from traditional car manufacturers shows that the latter have not adapted to the real-ity of e-mobility as fast as the demand requires. The creation of networks among the relevant indus-tries in joint associations such as the Bundesverband e-Mobilität is a first step. EU limits for pollutant emissions refer to average values of the overall fleet of car manufacturers. As a result, it will be nec-essary for manufacturers to increase the share of low-pollutant vehicles if other segments are to con-tinue to be served at the same time. A decision by the Federal Administrative Court of March 2018 allows German cities to establish restricted traffic zones to comply with EU pollutant regulations. These restrictions will mainly apply to vehicles with diesel engines and are, in the medium term, like-ly to lead to a reduction in the number of high-pollutant vehicles and an increase in the share of EVs.
References
  • For a detailed introduction to EV specific laws see Leutner, Gerd: “Die Förderung der Elektromobilität in Deutschland – Eine Bestandsaufnahme”, in: Recht/Automobil/Wirtschaft (RAW) March 2017, pages 31-37
  • Kfba Bestand an Pkw am 1. Januar 2017 nach ausgewählten Kraftstoffarten, https://www.kba.de/DE/Statistik/Fahrzeuge/Bestand/Umwelt/b_umwelt_z.html?nn=663524
  • Statista: Bestand der Personenkraftwagen mit Elektroantrieb in Deutschland nach Marken (Stand: 1. Januar 2017)
  • Bestand an Lastkraftwagen am 1.1.2017 gegenüber 1.1.2016 nach Nutzlast und Kraftstoffarten. In: kba.de. Kraftfahrt-Bundesamt, Mai 2017, S. 30; https://www.kba.de/SharedDocs/Publikationen/DE/Statistik/Fahrzeuge/FZ/2017/fz13_2017_pdf.pdf
  • Kfba Bestand an Pkw am 1. Januar 2017 nach ausgewählten Kraftstoffarten, https://www.kba.de/DE/Statistik/Fahrzeuge/Bestand/Umwelt/b_umwelt_z.html?nn=663524; Statista: Anzahl der Neuzu-lassungen von Pkw mit alternativen Antrieben in Deutschland im Jahr 2017
  • Bestand an Lastkraftwagen am 1.1.2017 gegenüber 1.1.2016 nach Nutzlast und Kraftstoffarten. In: kba.de. Kraftfahrt-Bundesamt, Mai 2017, S. 30; https://www.kba.de/SharedDocs/Publikationen/DE/Statistik/Fahrzeuge/FZ/2017/fz13_2017_pdf.pdf
  • Statista: Anzahl der Busse mit alternativen Antrieben in Deutschland (Stand: 1. Januar 2017)
  • Statista: Anzahl der Ladestationen und der Anschlüsse für Elektrofahrzeuge in Deutschland im Zeitraum 3. Quartal 2016 bis 1. Quartal 2018 (Stand: 01. Februar 2018)
  • Statista: Umfrage zu gesteigertem Interesse an E-Autos durch Kaufprämie in Deutschland 2016; statista Einfluss der Kaufprämie auf den Erwerb eines E-Autos in Deutschland 2016
  • https://cms.law/de/DEU/News-Information/Alliander-gewinnt-mit-CMS-Ausschreibung-fuer-Elektroladesaeulen-in-Berlin
  • Statista: Anteil der Elektrofahrzeuge an den Carsharing-Flotten in Deutschland im Jahr 2017
  • Statista: Umfrage zu negativen Aspekten von Elektroautos in Deutschland im Jahr 2016
  • Statista: Verteilung der Patentanmeldungen im Automobilsektor im Jahr 2016 nach weltweiten Regionen
  • Statista: Wichtigste Unternehmen nach Anzahl der eingereichten Patentanmeldungen beim Deutschen Patent- und Mar-kenamt im Jahr 2016
  • http://www.handelsblatt.com/unternehmen/industrie/elektromobilitaet-bosch-stellt-batteriezellen-forschung-komplett-ein/21013464.html
  • https://www.platts.com/latest-news/electric-power/london/totals-saft-joins-european-battery-alliance-with-26896561
  • Statista: Anzahl der Ladestationen für Elektrofahrzeuge je eine Million Einwohner in den deutschen Bundesländern (Stand: 31. Dezember 2015); Anzahl der Ladestationen für Elektrofahrzeuge je 1.000 Quadratkilometer in den deutschen Bundesländern im Jahr 2015

Iran
The Iranian government has been working on developing and implementing plans to facilitate and encourage the use of EVs in the country for several years. With air pollution in larger cities increasingly becoming a national crisis, the motivation to speed up these plans has increased. However, numerous challenges have meant that, with very few exceptions, plans to increase the share of EVs in the market or in the public transport fleet remain unrealised.
1. What EVs have been deployed in your jurisdiction to date?
Several models of hybrid passenger cars (most prominently from Toyota, Lexus and Hyundai) have been cleared for import into the country. There is no exact figure of all hybrid cars that have been registered to date. However, the overall share of imported vehicles has not been significant, with 5,500 announced as having been imported in the period between March and December 2017, equalling 0.05% of the total number of imports. Often cars that have been brought into the country have not been registered.
Electric motorcycles are slowly making their way into cities like Tehran and Esfahan following incentives offered by municipalities. In this case too, the exact number of registered vehicles is unclear. In some of these cities, pilot projects for electric vans and mini buses have also been launched.
Local manufacturers have introduced prototypes of domestically built EV cars and motorcycles, but none have begun mass production yet.
Plans to introduce EV taxis and buses have been announced, but are still not implemented.
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
Several pieces of legislation and directives contain provisions that directly or indirectly impact the importing, manufacturing and use of EVs, but there is no legislation that specifically deals with them.
The recently-adopted Clean AirAct (2017) mandates various ministries to work together on renewing the urban public transport fleet, including through incentives for hybrid and electric vehicles and electric motorcycles. It also exempts all locally-manufactured EVs from VAT.
The Cabinet of Ministers has requested the Ministry of Industry (MoI) to prepare an action plan for manufacturing and importing EVs. The MoI subsequently introduced a plan for manufacturing EVs that prioritised the public transport fleet, and set a three-phase project for passenger vehicles to be manufactured on new and existing platforms. The MoI also proposed an initiative to offer incentives to manufacturers and consumers of EVs, which is pending adoption by the Cabinet of Ministers.
EV import tariffs – are a significant factor as they are among the few incentives available – they are also set by the Cabinet. The most recent resolution increased the previously low tariffs from 5% to 45-100%.
3. What measures promote EVs in your jurisdiction?
For imports, the main incentive offered has been lower import tariffs compared to traditional vehicles. The Cabinet increased these tariffs in December 2017. The new resolution is currently pending a review by the Court of Administrative Justice.
In line with the emphasis put on local production in the auto industry, the Clean Air Act has laid the ground for offering incentives to domestically-manufactured EVs. As a first step, domestically-manufactured EVs are exempt from VAT. But, as local manufacturing is still in the early stages, concrete incentive packages are yet to be announced.
Some cities are taking the lead by offering incentives of their own. In Tehran, EVs are exempt from traffic restrictions in the central parts of the city. The municipality is also offering loans for electric motorcycles and is planning to designate zones in the city where non-electric motorcycles will not be permitted.
4. Who are the main entities (e.g. developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
There are several entities that play a role in the deployment of EVs:
  • Department of Environment – the organisation with the general mandate to promote environmental-friendly technology and improve air quality. It is responsible for setting emissions standards and for proposing and implementing financial incentives for EVs.
  • The MoI – plays a key role in regulating both the importing and manufacturing of EVs, including supporting and incentivising the major manufacturers.
  • The Ministry of Energy – along with its affiliates, is responsible for supplying and regulating the supply of power to EVs. Current projects include providing the infrastructure for charging stations.
  • Municipalities and city councils – can and in some cases have used their authorities and funds to offer incentives for EVs. They also play a role in increasing the use of EVs in the public transport fleet of urban areas.
  • Universities and research institutes – have been active in research and design projects for EVs. The Power Research Institute (overseen by the MoI) has established a department dedicated to EVs. The institute conducts and supports research, and has been working on standard guides for EVs and their parts – the lack of which is a contributing factor for not registering EVs – and charging stations. The institute introduced a 10-year projection that foresees 2,500 charging stations, 1.2m electric cars and 600,000 electric vehicles to be in use by 2025.
  • Local manufacturers – play a role by taking steps to design and manufacture EVs.

In addition, some committees and working groups have been established to facilitate coordination among various ministries and governmental organisations.
5. What are the main challenges to further deployment of EVs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
Price is a major challenge both for the use and manufacture of EVs in Iran. For imported EVs, the change in tariff incentives, in the absence of other incentives, would mean an upsurge in the price. Local manufacturing is also hampered by production costs that are unfeasible without significant government support.
In spite of years of research and several prototypes designed in Iran, mass production without the use of foreign technology and investment is still not a realistic goal.
Lack of infrastructure for charging EVs is a barrier. Plans to build charging stations in larger cities are under way, but apart from pilot projects the plans are not yet realised. The urban grid is also unable to support charging EV batteries.
Standardisation of EVs is a challenge that has prevented their registration. A national standard guide is being prepared to address this problem.
Administrative efficiency has also been a challenge. The fact that several governmental entities play a role in this area, some with overlapping authority, has slowed down the progress of legislation and its implementation.
Poland
1. What EVs have been deployed in your jurisdiction to date?
In the first quarter of 2017, 203 EVs and 3,781 hybrid vehicles were registered in Poland. Compared to the same quarter of 2016, this was an increase of 75% in sales of EVs and 57.8% in sales of hybrid vehicles1. Having said that, only around 0.1% of Polish citizens own an alternative fuel vehicle and only 12.4% are considering buying one2.
Nevertheless, in its Electromobility Development Plan adopted in September 2016, the Ministry of Energy proposed an ambitious target – it wishes to see 1 million EVs on Polish roads by the end of 2025. The Ministry plans to create an incentives scheme in order to promote EVs to this level.
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
The Polish authorities recently adopted the Act of 11 January 2018 on Electromobility and Alternative Fuels (“the Act”), which transposes Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the deployment of alternative fuels infrastructure. The Act provides a number of measures to facilitate e-mobility and establishes a framework for building a basic alternative fuels infrastructure (including electric energy, LNG, CNG and hydrogen). The Act is the first step into the full regulation of EVs in Poland, as it constitutes the only existing piece of binding legislation to date.
3. What measures promote EVs in your jurisdiction?
  • Administrative facilities – building permits are not required for charging stations and charging points. The Act exempts providers from the obligation to obtain a licence for trade in electricity in the case of charging services.
  • Tax benefits – excise exemption for EVs and hydrogen-powered vehicles; temporary excise exemption for hybrid vehicles (until 1 January 2021); depreciation write-offs will be more favourable for electric vehicles versus regular cars for natural and legal persons.
  • Parking spaces – dedicated parking spaces for EVs during charging in metered parking zones.
  • Installation of charging points – the Act sets specific goals to significantly expand the charging infrastructure in the coming years. It indicates a minimum number of charging points in communes that must be installed in charging stations by 31 December 2020 and the measures that local authorities shall undertake if this number is not met (they will prepare a plan to construct charging stations in cooperation with distribution system operators).
  • Clean transport areas – special areas dedicated for EVs, hydrogen vehicles and vehicles that run on CNG and LNG.
  • Bus lanes – EVs will be allowed to drive in bus lanes until 1 January 2026.
  • Exemption for public transport operators – temporary exemption (until 31 December 2028) from charges for driving on domestic roads for zero-emission buses.

4. Who are the main entities (e.G. Developers, government, system operator) and what are their roles in the deployment of evs in your jurisdiction?
  • Government – responsible for the deployment of the Electromobility Development Plan, which was prepared by the Ministry of Energy.
  • Local authorities – play a vital role in developing charging infrastructure. They have a number of tasks including preparing a plan for the construction of charging stations in the local area and establishing clean transport areas.
  • Electricity market participants – electricity generators, suppliers and, most importantly, distribution system operators that play a vital role in developing electromobility in Poland. To help the development of this new business activity in Poland, in its Electromobility Development Plan the Ministry of Energy recommended creating a company that will coordinate research in this area. Consequently, the four main Polish energy groups (PGE, Energa, Enea and Tauron) have established ElectroMobility Poland SA.
  • Charging station operators – entities responsible for the construction, management, security, operation, maintenance and renovation of public charging stations.

5. What are the main challenges to further deployment of evs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
  • Legal framework: The Act is the first piece of legislation in respect of electromobility in Poland. Although it provides basic regulations for the development of electromobility, the Ministry of Energy plans to observe the market and update and develop the legal framework governing electromobility.
  • Charging infrastructure: The infrastructure needs to be vastly developed. The Act provides ambitious targets regarding the number of charging points in Poland that are to be installed by 2020 (with the key role of the local authorities to develop the infrastructure when needed, as indicated above). Additionally, the General Directorate for National Roads and Motorways (GDDKiA) in cooperation with distribution system operators will draw up a plan of the locations of public charging stations along TEN-T roads.
  • Financial support: No purchase grants have been established for EVs in the Act yet, which is a big disadvantage, considering that the prices of EVs are still significantly higher than those of combustion-driven vehicles.
  • Education and promotion: In order to develop electromobility it is necessary to promote it and educate about its advantages. This issue is still quite new in Poland, so the Ministry of Energy has set some measures in the Electromobility Development Plan to raise awareness of this topic.

References
  • http://www.portalsamorzadowy.pl/gospodarka-komunalna/pierwszy-milion-aut-elektrycznych-w-ue-w-2018-roku,97572.html – last accessed on 14.02.2018.
  • http://www.orpa.pl/polacy-slyszeli-o-pojazdach-niskoemisyjnych-lecz-tylko-nieliczni-rozwazali-zakup/ - last accessed on 14.02.2018.

Portugal
EVs currently represent a small proportion of the total vehicles licensed in Portugal, but this is changing. EV sales increased significantly in 2017, mostly due to financial incentives, the expansion of charging points and environmental concerns which have led to global investment in the sector. However, Portugal still has a long way to go.
1. What EVs have been deployed in your jurisdiction to date?
The chart below shows the small proportion of EVs among total vehicles in Portugal. The figures are taken from information provided by the Portuguese authorities1 (published in 2016 and based on 2015 data).
Categories Electric and hybrid vehicles Total vehicles Share of electric and hybrid vehicles in the total of vehicles (%)
Passenger cars 25,386 4,722,963 0.5%
Heavy vehicles – passenger 99 14,717 0.6%
Light goods vehicles 188 1,224,821 0.01%
Heavy goods vehicles 17 88,398 0.01%

Despite the small proportion of EVs, sales are increasing. It is estimated that 2016 sales of EVs in Portugal reached more than 1,000 – double the 2015 number.
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
In line with EU policy, since 2009 the Portuguese government has taken several legislative steps to create, implement, develop and execute an electric mobility programme.
Two key measures govern the sector:
  • Resolution of Council of Ministers no. 20/2009 of 20 February – created the Programme for Electric Mobility
  • Resolution of Council of Ministers no. 81/2009 of 7 September – established the principles of the programme and approved the model and development stages.

Under this legal framework, the Decree-Law no. 39/2010 of 26 April (amended by Law no. 64-B/2011 of 30 December, Decree-Law no.170/2012, of 1 August and by Decree-Law no. 90/2014, of 11 June) approved the terms of the electric mobility programme – in particular its organisation, access and exercise of electric mobility activities – and the standards of an electric mobility network.
Among other provisions, the Decree-Law establishes:
  • the main principles applicable to the exercise of electric mobility activities, chiefly the principle of universal and equal access to services.
  • the standards applicable to operating electric charging points and the grounds for issuing licences (valid for ten years) by Directorate General of Energy and Geology (DGEG – Direcção-Geral da Energia e Geologia).
  • the provisions applicable to the supply of electricity for electric mobility, which can be only held by operators of electric charging points, duly licensed and registered to operate in the whole national territory.
  • the responsibilities of the managing entity of the electric mobility network.
  • the creation of an entity – the Office for Electric Mobility in Portugal (Gabinete para a Mobilidade Eléctrica em Portugal) – responsible for the preparation and implementation of the Programme for Electric Mobility.

Regulation no. 879/2015, approved by the Regulatory Authority (ERSE – Entidade Reguladora dos Serviços Energéticos) is also important. It establishes the legal framework applicable to the relationships between the electric mobility sector, the electricity sector and the protection of rights and interests of the users of EVs. It covers prices, service quality and information. The Regulation also sets out the methods for the tariffs to be applied by the managing entity of the electric mobility network.
In addition to the main legislative frameworks, various Ministry Orders cover complementary regulatory aspects. These include: requirements for implementing infrastructure and equipment (Ministry Order no. 221/2016); technical rules for charging installations of EVs in buildings and other urban facilities with parking areas (Ministry Order no. 220/2016); the terms governing licences for private use of the public domain for the installation of electric charging points for EVs in public places (Ministry Order no. 222/2016); the technical requirements for issuing a licence to operate EV charging points (Ministry Order no. 241/2015); and the fees that apply to electricity supply licences for electric mobility (Ministry Order no. 240/2015).
Several new political options for the sector were defined recently in the Great Plan Options (Grandes Opções do Plano), as approved by Law no. 113/2017 of 29 December. These new options include the opening of the market of supply for electric mobility.
3. What measures promote EVs in your jurisdiction?
In recent years the Portuguese government has supplemented the legislative framework by approving additional measures.
A major financial incentive – a total amount of EUR 2,659,000 – is now in place for the acquisition of electric vehicles in 2018. The Government approved the incentive through the Environmental Ministry in the context of the Environmental Fund created in 2016. (Order no. 1607/2018 in line with Ministry Order no. 468/2010 of 7 July.)
Tax incentives for EVs include exemption from the tax paid for the acquisition of a vehicle, and a reduction in the payment of circulation tax. Companies which have EVs are exempt from autonomous tax and benefit from a reduction in value added tax.
Under Decree-Law no. 140/2010 of 29 December, the Portuguese Government also promoted the obligation on public and government entities to acquire electric vehicles.
4. Who are the main entities (e.g. developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
The main Portuguese stakeholders in EVs are:

  • ERSE – responsible for regulation within the electricity and natural gas sectors. It supervises and assures compliance with applicable law, especially Regulation no. 879/2015.
  • EGME – managing entity of electric mobility (Entidade Gestora da Mobilidade Eléctrica) – incorporated under Decree-Law no. 39/2010 of April 26 with the subsequent amendments, this entity manages and monitors the electric mobility network in terms of the energy, information and financial flows necessary for its operation. EGME is responsible for developing and providing adequate information, communication and service systems and ensuring the fulfillment of the obligations and rights of operators of charging points and registration holders for electric mobility. MOBI.E. a public company, carries out these activities on behalf of EGME.
  • DGEG – a public administration entity whose mission is to contribute to the design, promotion and evaluation of policies on energy and geological resources, with a view to sustainable development and security of supply. DGEG is responsible for issuing operating licenses for EV charging points and for the registration of electricity sales for electric mobility.
  • UVE – Users of Electric Vehicles (Utilizadores de Veículos Elétricos), is a non-profit organisation with the mission of promoting electric mobility. It was created to represent the community of owners, users and supporters of EVs and plug-in hybrids in Portugal. UVE aims to boost electric mobility through the promotion of sales of electric vehicles in Portugal.

5. What are the main challenges to further deployment of EVs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
Portuguese consumers face several challenges requiring Government and stakeholder intervention, including:
  • lack of fast charging stations (there are only 51 fast charging stations in Portugal)
  • extension to other electric road vehicles (e.g. electric bicycles and heavy goods vehicles)
  • better integration of renewable energies
  • high EV acquisition prices (incentives such as those mentioned above are required to lower the price of acquisition)
  • better access to private access charging network in homes and office areas
  • increased financial incentives and not just tax incentives (e.g. free parking for EVs in regulated areas, as available in Lisbon)
  • more non-financial incentives (e.g. exclusive car parks for EVs and use of EVs on roads dedicated to public transport).

References
  • http://www.imt-ip.pt/sites/IMTT/Portugues/Observatorio/Estatisticas/OutrasInformacoes/Documents/2016/Ve%C3%ADculos%20eletricos%20matriculados_acumulado.pdf

Romania
Romania is increasingly interested in EV development. As part of its strategy to improve the quality of the environment, Romania plans to renew the national car fleet by offering substantial grants for the purchase of EVs.
1. What EVs have been deployed in your jurisdiction to date?
In the first quarter of 2017, 33 EVs and hybrid vehicles were registered in Romania1. The number of registered EVs and hybrid vehicles increased with 106.3% compared to the same quarter of 2016 when only 16 EVs and hybrid vehicles were registered.
The number of EVs increased significantly in 2017 as a result of Rabla Plus, a governmental programme that offers grants for the purchase of EVs. Although, only 33 EVs and hybrid vehicles were registered in Romania in the first quarter of 2017, the programme Rabla Plus succeeded to increase the number of EVs purchased in Romania, in 2017, to almost 500 EVs.
EV and hybrid vehicles represented 2% of the total sales of vehicles in the first 11 months of 2017 – double the share recorded in 2016 – according to statistics from the Automotive Manufacturers and Importers Association (APIA).
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
Romania’s Emergency Ordinance no.40 of 20 April 2011 (the “Ordinance”) transposed Directive 2009/33/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of clean and energy-efficient road transport vehicles. The Ordinance regulates the general obligation to promote clean energy by also promoting the market of non-polluting and energy-efficient vehicles.
Another legislative measure to encourage EVs is Law no. 34/2017 (the “Law”) on the deployment of alternative fuels infrastructure (it transposes Directive 2014/94/EU). The Law establishes a common framework of measures for deploying an alternative fuels infrastructure. The aim is to minimise dependence on oil and to mitigate the environmental impact of transport. It sets out minimum requirements for developing the alternative fuels infrastructure, including recharging points for electric vehicles and refuelling points for natural gas (LNG and CNG) and hydrogen.
Order no. 660/2017 of the Ministry of Environment introduced the Rabla Plus programme that offers grants of up to EUR 10,000 to qualifying applicants. The grant covers up to 50% of the EV purchase price, whilst the other 50% is born by the applicants. The programme aims to grow the number of EVs and hybrid vehicles in Romania in order to reduce the carbon emissions and to mitigate the environmental impact of transport.
3. What measures promote EVs in your jurisdiction?
To promote the purchase of EV, the Romanian Government offers benefits including
  • EV purchase grants – The Romanian EVs market is constantly growing. Between May and December 2017, the Rabla Plus programme2 approved grants for the purchase of 500 electric cars and hybrid plug-ins.
  • Tax benefits – Exemptions from the annual circulation tax (ownership tax).3
  • Charging points – There are 130 charging points across the country and there are ongoing plans to develop more at the initiative of both private and public actors.
  • Low cost energy – The cost of charging EVs is very low compared to refuelling traditional vehicles. There are also private initiatives which offer free of charge energy for the EVs at their charging points4.

4. Who are the main entities (e.g. developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
  • The Government – approved grants through the Rabla Plus programme for the purchase of electric cars and hybrid plug-ins. The Ministry of Environment and the Ministry of Energy are the competent authorities involved in this programme.
  • The local authorities – are also involved in the deployment of EVs. For example, the Municipal Company of Energy was set up in Bucharest –which aims to build 40 charging points in the city by spring 2018.
  • Electricity market participants – electricity generators, suppliers and distributors.
  • Charging station developers – existing developers of the new charging infrastructure.

5. What are the main challenges to further deployment of EVs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
While the EV field is starting to be strongly encouraged in Romania, there are still some obstacles to EV ownership, including:
  • Price – EVs are more expensive than combustion-driven vehicles. For example, the cheapest EV available on the Romanian market is the Volkswagen e-Up! that costs around EUR 25,838. On the opposite side, the cheapest non-EV car is Logan, which costs around EUR 7,000, almost four times less than the cheapest EV available on the Romanian market.
  • Limited offer: – The Romanian market has a limited range of EVs – only 11 models5 – and only 8 of these can be purchased through the Rabla Plus programme6.

Charging infrastructure: Romania has only 16 public charging points of 50kW capacity. The country has a total of 130 charging points7 including further 22kW public charging points.
References
  • http://www.apia.ro/wp-content/uploads/2017/09/20170907_AFV_Q2_2017_FINAL.pdf
  • https://www.afm.ro/vehicule_electrice.php
  • http://www.apia.ro/wp-content/uploads/2017/05/ACEAEV_incentives_overview_2017.pdf
  • For example, Rompetrol opened in March 2017 its first gas station with charging points for EV offering energy free of charge. In addition, the big retainer Kaufland opened in collaboration with Renovatio a chain of charging points offering energy free of charge for one year.
  • http://www.apia.ro/autovehicule-ecologice/autovehicule-electrice/
  • http://www.energynomics.ro/ro/8-modele-de-masini-electrice-disponibile-prin-programul-rabla-plus/
  • http://0-100.hotnews.ro/2017/09/27/un-nou-pas-pentru-dezvoltarea-infrastructurii-pentru-masini-electrice-11-noi-statii-au-primit-finantare-guvernamentala/


Slovenia
Green mobility in Slovenia has been a hot topic in recent years. Even though the share of EVs is relatively low, it has been growing rapidly, supported by infrastructure development. With relatively short distances within the country and a fuelling infrastructure in place, Slovenia is an ideal environment for the development of EVs.
1. What EVs have been deployed in your jurisdiction to date?
There are 1,064,000 registered passenger cars in Slovenia. EVs have a market share of 0.74%, with BEVs (battery electric vehicles) at 0.47% and PHEVs (plug-in hybrid electric vehicles) at 0.27%. EV market share has increased rapidly in recent years – BEVs rose from 0.21% in 2015 to 0.47% in 2017, and PHEVs grew from 0.06% in 2015 to 0.27% in 2017.1
In 2016, there were 178 new registrations of BEVs; this number almost doubled in 2017, reaching 336. Growth in PHEVs ownership shows a similar trend, up from 94 new registrations in 2016 to 192 in 2017.2
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
The Energy Act, adopted in 2014, is the main act in the field of energy. It includes provisions on the construction of EV public charging stations on motorways, and on the reporting on public charging stations and their energy consumption. Several other acts regulate EVs, including the Corporate Income Tax Act, the Motor Vehicle Charges Act and the Motor Vehicles Tax Act.
Slovenia transposed Directive 2014/94/EU on the deployment of alternative fuels infrastructure into national law by adopting the “Decree establishing the infrastructure for alternative transport fuels”, which came into force on 12 August 2017. Under this directive, the “Strategy for the development of the market as regards alternative fuels in the transport sector and the deployment of the relevant infrastructure” was adopted in October 2017.
3. What measures promote EVs in your jurisdiction?
Fuelling infrastructure – in 2017, there were 228 publicly available charging points for EVs in Slovenia (31 of them are high-power charging stations on the TEN-T network), one charging point for hydrogen, 115 points for liquefied petroleum gas and four for compressed natural gas.
Financial incentives – incentives for the purchase of EVs are granted by the Eco Fund, Slovenian Environmental Public Fund. Subsidies may be granted to individuals and legal persons. In 2017, the subsidy for an EV was EUR 7,500, and EUR 4,500 for a PHEV.

BEVs are exempted from payment of an annual fee under the Motor Vehicle Charges Act. A lower tax rate (0.5%) is applicable for EVs under the Motor Vehicles Tax Act.

Taxpayers under the Corporate Income Tax Act may claim a reduction of the tax base of 40% of the amount invested in passenger cars and buses (BEVs and PHEV), but not exceeding the amount of the tax base.
Soft measures – “The Strategy for the development of the market as regards alternative fuels in the transport sector and the deployment of the relevant infrastructure” provides several soft measures for the promotion of EVs, such as use of EVs in public transport and guidelines for municipalities. The Strategy recommends that local municipalities draft long-term plans that include: building charging points, particularly in residential areas; providing parking spaces at charging points; promoting urban transport and taxi transport by alternative fuels; providing yellow lanes for EVs and free parking. EV car sharing systems in several Slovenian cities have proven to be a successful model with major growth potential.
4. Who are the main entities (e.g. developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
Ministry for infrastructure – drafting of legislation, action plans, strategies.
Energy Agency – consultation process on electromobility with relevant stakeholders.
Electricity market participants (electricity generators, suppliers and distributors) – development of network.
Municipalities – drafting and implementation of measures for promotion of EVs at the local level.
Universities and research institutes – actively participating in R&D of EVs.
5. What are the main challenges to further deployment of EVs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
Slovenia’s main challenges to EV ownership and development, and efforts to combat them, include:
  • High prices of EVs – subsidies and soft loans.
  • Unevenly dispersed fuelling infrastructure and a lack of fuelling infrastructure in non-urban areas – further development of infrastructure.
  • Development of transmission and distribution network, smart grids – further investment.

References
  • http://www.eafo.eu/content/slovenia#summary
  • http://www.eafo.eu/content/slovenia#summary

Ukraine
Ukraine has an unexpectedly high ranking among the countries promoting the use of EVs. The main reason is the rapid growth in the share of EVs among new cars bought by Ukrainians over the last few years, along with the recent introduction of tax exemptions on EV imports and sales. Further development of the charging infrastructure and the global decrease in battery prices may result in an EV miracle for Ukraine, reducing its overall dependency on oil.
1. What EVs have been deployed in your jurisdiction to date?
According to the statistics of the Ministry of Interior of Ukraine, 1,602 EVs were registered in Ukraine in 2016. However, EV registrations reached 682 in the first quarter of 2017 alone, and unofficial market data indicates that around 2,700 EVs were registered in 2017. That is approximately 4% of the total car sales.
The market leader is the Nissan Leaf, with a share of about 78%. The remainder is shared between the Ford Focus, Tesla Model S, BMW i3 and Renault Fluence.
Used imports account for around 85% of the EV market. This is not surprising, considering the high price of EVs compared to their oil-burning alternatives and the relatively low buying power of Ukrainians. However, the used cars trend also demonstrates very high interest in the EV segment, which doubtless will continue to grow following the global EV price decrease and new tax incentives for 2018.
Apart from full EVs, there is also high interest in hybrids – representing a compromise between the technology and the current lack of charging infrastructure. The most popular cars in this segment are the Toyota RAV-4 Hybrid, Chevrolet Volt and Kia Niro, not counting the National Police’s fleet of Toyota Prius and Mitsubishi Outlander PHEVs.
Public transport plays a major role in promoting EV culture in Ukraine. Historically, electricity-powered trolley buses and trams were among the most used means of public transportation in the bigger cities. Today, these vehicles are manufactured by Elektrontrans, a Ukrainian-German JV. Since 2016, Elektrontrans has also focused on the manufacturing of battery-equipped electric buses.
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
Ukraine does not have separate legislation dedicated to the regulation of EVs (e.g. road and electrical safety-related regulations, specific registration requirements, etc.). Tax and customs incentives described below are part of general legislation – the Tax Code of Ukraine and the Law on Customs Tariff.
3. What measures promote EVs in your jurisdiction?
Use of EVs in Ukraine is motivated by tax and customs payments exemptions, including:
  • From 1 January 2016, vehicles equipped solely with an electric motor are exempt from import customs duty (8%/10%1)2.
  • From 1 January 2016, exemption from import surcharge (5%) is granted to EVs equipped solely with electric motors3.
  • From 1 January 2018 until 31 December 2018, imported and domestically-produced EVs will also be exempt from import/sales VAT (20%) and excise duty (EUR 109)4.

This means that until 31 December 2018, the only payment due on the import or domestic sales of EVs is a fee to the pension fund (3-5%). It is also likely that the temporary exemptions mentioned above will be extended after 2019.
However, apart from tax exemptions, the state has not yet developed other EV promotion strategies, which could include subsidies, grants, loans or other types of support granted to consumers, manufacturers or infrastructure developers.
4. Who are the main entities (e.g. developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
The Ukrainian EV market is mainly influenced by the following public and private actors:
  • The Parliament (Verkhovna Rada of Ukraine) – plays a key role in the regulation of any emerging market. As noted above, tax incentives are simple but highly efficient drivers of the Ukrainian EV market.
  • The Ministry of Infrastructure of Ukraine – the highest governmental body that initiates and supports legislative developments facilitating the deployment of EVs in Ukraine. The Ministry has set a target to increase the share of EV sales to 15% of all car sales in Ukraine by 2020.
  • The Ministry of Ecology and Natural Resources – another top governmental body, whose responsibilities include greenhouse gas emissions trading under the terms of the Kyoto Protocol. Funds received were used to buy EVs and hybrids for the National Police.
  • Vehicle and battery importers and manufacturers – currently, only a relatively small number of electric buses are manufactured in Ukraine. VAT and excise tax exemptions may, however, change this situation. EV importers are the main players on the market so far – the vast majority of the EVs now sold in Ukraine are used imports.
  • Charging station developers – the number of charging stations in big cities is more or less sufficient for the comfortable use of EVs. However, that is not the case for small towns and rural areas. In general, there is a substantial demand for EV charging stations in Ukraine.
  • Specialised service stations operators – service stations specialising in EVs are rare in Ukraine. However, this type of service is highly driven by demand and, given the number of motor vehicle services in place, the industry is expected to boom with the wider deployment of EVs.
  • NGOs and industry bodies – including the Ukrainian Association of EVs Market Participants and the Ukrainian Motor Vehicle Manufacturers Association.

5. What are the main challenges to further deployment of EVs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
From a customer’s perspective, obstacles to EV ownership include:
  • Price – EVs remain more expensive than combustion-driven vehicles. However, the price difference should be minimised by VAT and excise tax exemptions in 2018.
  • Absence of a unified nationwide charging infrastructure – even as the number of charging stations grows from year to year, especially in big cities like Kyiv, the absence of a unified nationwide charging infrastructure is an issue for prospective EV-purchasers. Some of the existing charging stations are private, designated for the use by employees of a certain company, and high-speed charging stations are rare. The vast majority of charging stations deployed are slow-speed, suitable only for overnight charging.

References
  • Preferential rate, applies for instance to imports from WTO countries / full rate.
  • Law No. 822-VIII dated 25 November 2015.
  • Law No. 912-VIII dated 24 December 2015.
  • Law No. 2245-VII dated 7 December 2017.

United Arab Emirates
The United Arab Emirates (“UAE”) is increasingly looking at ways to promote and utilise clean energy. With recent developers entering the UAE market, incentives to buy electric cars and a push towards these clean energy initiatives, the UAE is looking to establish itself as a leading regional and global player in the utilisation of electric vehicle technology. Of the seven Emirates, which form the UAE, Dubai is the most vocal and advanced in their support for this technology.
1. What EVs have been deployed in your jurisdiction to date?
As at August 2016, it was reported that there were 200 electric vehicles registered. Since the opening of the Tesla showroom in Dubai in June 2017, there has been an increasing governmental push to encourage individuals to buy electric cars over a conventional petrol model. A more recent development has been the introduction of “UberONE” service, which offers Uber customers an opportunity to be driven by one of 50 Tesla ModelX cars as well as some of the car rental companies offering electrical cars such as Renault Zoe with the added benefits of free charging and no road tolls. We are aware to date that other than Tesla, the main developer of electric cars in the UAE includes Renault, Mitsubishi and Toyota. The Emirates of Dubai has also set an ambitious target of having 40,000 electric vehicles registered by 2030.
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
The Emirates Authority for Standardisation and Metrology have recently prepared draft legislation to regulate the sale and use of electric vehicles. This has resulted in other GCC countries using this draft legislation as the basis of producing their own regulations.
The UAE has implemented the UAE Energy Strategy 2050, which aims to increase the contribution to clean energy by 50% by 2050. It will also aim to ensure there is an energy mix that combines renewable, nuclear and clean energy sources to meet the UAE’s economic requirements and environmental goals. This strategy will be implemented in three phases. Phase one will accelerate efficient consumption of energy, the second phase shall explore new solutions to integrate transportation solutions with energy and the final phase will focus on research and development to supply sustainable energy.
The Supreme Council of Energy issued in March 2017, the Dubai Administrative Decision No.1 of 2017 in respect of the establishment and installation of charging stations for electric vehicles in Dubai. This requires all organisations, whether private or public and any developers in Dubai to get approval from Dubai Electricity and Water Authority (“DEWA”) before they are permitted to install, operate or maintain any charging station. This decision was implemented to continue the ongoing commitment to the Dubai Clean Energy Strategy 2050, which aims to ensure Dubai, has the lowest carbon footprint in the world. This is also in parallel with the Dubai Carbon Abatement Strategy to reduce 16% of carbon emissions by 2021. Private owners of electric vehicle charging stations in Abu Dhabi must seek approval from the Abu Dhabi Distribution Company on the viability of facilities, which includes the Abu Dhabi Distribution Company inspecting the facilities prior to these being utilised.
We are aware that the following charging stations are available across the UAE:
Emirate Number of charging stations
Abu Dhabi As at July 2017 there are currently 22 charging stations in Abu Dhabi. These include 10 at Yas Mall and three at each amusement park.
Dubai As at December 2015, DEWA had installed 100 charging stations. Their aim is to have doubled this by 2018.
Sharjah, Ras Al Khamiah and Fujairah As at February 2017, there are currently 5 charging stations.

3. What measures promote EVs in your jurisdiction?
To entice individuals to purchase electric vehicles, Dubai has recently announced the following new incentives:
  • free parking in certain areas;
  • toll exemptions;
  • discounts on registration fees;
  • free charging stations; and
  • greenbank loans.

Individuals who purchase an electric vehicle in Dubai will be able to park free in designated areas including Madinat Jumeirah, Jumeirah Beach Residence and Dubai International Airport. There are currently 40 parking spaces designated for electric vehicles with more to be added in the near future. With the purchase of an electric car, each driver will be entitled to a fee exemption to each of the seven tollgates and to a 15% discount on all car registration and renewal fees. Greenbank loans were also implemented in May 2017 to make purchasing electric cars more accessible to both the public and private organisations.
At present, there are not Federal level incentives which apply UAE wide and it is for each individual Emirate to establish and implement their own plan.
4. Who are the main entities (e.G. Developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
As noted above, DEWA are responsible for the installation of charging stations in the Dubai. Green Parking work closely with DEWA and their role is to physically implement and develop such charging stations. RTA has played a key role in electric vehicles by already purchasing from Tesla a fleet of 200 electric vehicles to operate as part of their taxi fleet from Dubai Airport. In September 2017, RTA took delivery of 50 of the 200 electric vehicles, with another 75 expected in 2018 and a final 75 in 2019. Dubai Future Foundation are an organisation in the Dubai who are responsible for electric vehicles. One of their key initiatives is under the Dubai Autonomous Transportation Strategy, which aims to transform 25% of the transportation in Dubai to autonomous mode by 2030. The Dubai Future Foundation work closely with the Dubai Smart Government whose primary role is to look at implementing regulations on electric and self automated cars and driving initiatives on street planning for such vehicles.
5. What are the main challenges to further deployment of EVs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
The climate of the UAE proposes many challenges to the successful implementation of electric vehicles. Firstly, the extreme heat can greatly effect battery life. Tesla notes that their Model S can travel 632 kilometres on full charge, with Model X following closely at 565 kilometres. However, this is based on driving without air conditioning and does not account for the sandy conditions of the UAE. Although not expressed to be a way to overcome this challenge, solar vehicles or a hybrid design could enhance battery life. Developer will also need to work on developing efficient batteries and charges given the small number of charging stations currently placed around the UAE.
A second issue is being able to provide those who live in high-rise buildings with charging stations in the car parks of their buildings. For those owners of electric vehicles who may live in a villa, the installation and space should be available to install their own private charging station, which should therefore not be an issue, unless price of purchasing and installing one is prohibitively costly. High-rise residents will have to rely on the construction buildings taking into account the installation of enough accessible charging stations within the car park for all residents. Where the buildings are not new builds. Existing owners will need to be incentivised to have these installed. With the cost of electricity being high in the UAE, free charging stations would be one way to overcome this challenge.
Petrol prices in the UAE have historically been very low. In order to incentivise individuals to move away from traditional petrol vehicles, charging electric vehicles will need to compete with these low prices. DEWA’s managing director has stated that it would be 80% cheaper to charge an electric car than fill up the tank of a petrol vehicle. To charge a Tesla X it would cost AED 29 compared to AED 150 to fill up a similar petrol model.
Public charging stations will need to have an efficient system in place to prevent unnecessary delays to their customers. Petrol stations, particularly those on main transit routes, can face delays at peak times. For electric vehicles, the process of charging will take significantly longer than filling a traditional petrol or diesel vehicle. The creation of an efficient, publically accessible and user-friendly charging infrastructure will be essential. The government will need to ensure charging stations are located near retail spaces such as malls, supermarkets, banks, restaurants and fast food chains, and leisure facilities to allow drivers to go about their everyday lives whilst allowing their vehicles to charge at the same time.
United Kingdom
The UK shows significant potential in EV development. It is the second largest automotive manufacturing hub in Europe, with a comparatively large consumer base for road vehicles and a wealth of innovation from its world-class industry and universities.
1. What EVs have been deployed in your jurisdiction to date?
EVs currently represent a small proportion of the vehicles licensed in the UK:
“Ultra-low emission vehicles”
(Electric, hybrid & hydrogen)1
Total vehicles2
Cars108,00031,212,000
Vans6,0003,870,000
HGVs & buses679660,000
All vehicles119,00038,971,000

However, market share is increasing. In 2016, the UK was one of only six countries worldwide in which sales of electric PLDVs exceeded 1% of sales of all such vehicles.3 August 2017 was the first month in which electric cars represented over 2% of total UK new car registrations (with hybrids contributing a further 3%).4
2. Is there any specific legislation for/regulation of EVs in your jurisdiction?
The UK Government announced a new Air Quality Plan in July 20175, including a commitment to ban the sale of new petrol and diesel cars and vans by 2040. The plan also included GBP 255m in additional funding for local councils to produce and implement nitrate pollution reduction plans, funded through changes in tax treatment for new diesel vehicles. Further revisions to the plan are expected following a judgment of the High Court in February 20186: the current plan has been declared unlawful on the basis that it is “not sufficient” to bring the areas suffering from the worst nitrate pollution within EU law limits.
Vehicle manufacturers have been subject to tougher “real world” emissions testing requirements since 1 September 2017. The government has also had a Motor Fuel Greenhouse Gas Emissions Reporting regime in place since 2013, requiring large-scale suppliers of road transport fuel to report to the Department for Transport on the quantity and types of fuel it supplies and the greenhouse gas intensity of each type.
A key upcoming piece of legislation is the Automated and Electric Vehicles Bill7, which was considered by a public bill committee in November 2017. The Bill introduces powers for the government to issue regulations for the improvement of the country’s charging infrastructure by e.g. ensuring interoperability between all public EV charging points, requiring large fuel retailers to provide rapid charge points and requiring that all new public charging points be smart enabled.
Scotland has indicated its intention to lead the way on electric vehicles and achieve the phase out of new petrol and diesel cars and vans by 2032, well ahead of the UK target. Proposed new legislation for 2018 outlines plans to achieve this goal by measures including fast-tracking the development of a Scotland-wide charging network, converting the A9 into Scotland’s first ‘electric highway’ and procuring ultra-low emission vehicles to update public sector car, van and bus fleets.8
3. What measures promote EVs in your jurisdiction?
The government is investing in EV promotion and infrastructure. The Department for Transport and Department for Business, Energy & Industrial Strategy have set up a dedicated Office for Low Emission Vehicles (“OLEV”), which has been given a GBP 900m investment mandate to keep the UK at the forefront of ultra-low emission vehicle technology. The government also has a range of further investment programmes in place, including a GBP 246m investment in its “Faraday Challenge” to boost expertise in battery technology; a GBP 20m investment in “vehicle to grid” infrastructure (as part of the government’s July 2017 Smart Systems and Flexibility Plan); and a recent award of GBP 40m shared among four UK cities with innovative EV infrastructure proposals (as part of the government’s “Go Ultra Low” scheme).

The government’s Clean Growth Strategy on 12 October 2017 reaffirmed all these investments, while committing a further GBP 80m to investment in charging infrastructure. Further, in the 2017 Autumn Budget, the chancellor announced measures including a GBP 200m investment (to be matched by the private sector) into a new Charging Investment Infrastructure Fund. In his October 2017 Cost of Energy Review, Professor Dieter Helm observes that EV charging infrastructure is “a textbook example of the need for government coordination” and called for a framework to be included in the government’s Industrial Strategy. The strategy white paper published in November 2017 committed to the publication of a further “strategy on government support for the transition to zero emission road transport”, expected in March 2018.
The promotion of EVs is also coming from industry sources. Ofgem, the UK National Regulatory Authority for electricity and gas, administers a GBP 500m Low Carbon Networks Fund sponsored by distribution network operators. Projects proposed by DNOs in relation to EVs have included experimentation with charging point tariffs and extensive smart metering to determine how best to reinforce distribution networks.
The current financial incentives to own a low emission vehicle in the UK include:
  • EV purchase grants – the government will pay up to GBP 4,500 towards the cost of purchasing a low emission vehicle (based on factors including CO2 emissions and distance which can be travelled with zero emissions). Taxi drivers can obtain a grant of up to GBP 7,500 for the purchase of plug-in vehicles.
  • Charging point grants – OLEV will contribute GBP 500 towards the cost of installing a home charging point (the Energy Saving Trust offers a further GBP 500); local authorities can apply to OLEV for funding for up to 75% of the cost of installing an on-street charging point in areas lacking off-street parking.
  • Various tax benefits – for example, road tax is graded by CO2 emissions. The government has also announced that, from April 2018, electricity provided by employers to their employees to charge their EVs will not be taxed as a benefit in kind.
  • HGV licensing break – the weight threshold at which an HGV licence is required is higher for electric HGVs than for vans with combustion engines.
  • London Ultra Low Emission Zone – ultra-low emission vehicles already qualify for a 100% discount on the London congestion charge; this exemption will increase in significance in 2019 when Sadiq Khan’s pledged additional fee for certain petrol and diesel vehicles is introduced. All newly licensed taxis are to be zero-emission capable from 2018.

4. Who are the main entities (e.g. developers, government, System Operator) and what are their roles in the deployment of EVs in your jurisdiction?
In addition to government, stakeholders in the UK EV market include:
  • Ofgem – the electricity regulator will have a huge role in reviewing existing licence conditions for transmission, distribution, generation and supply to ensure the removal of any existing barriers to development of EVs and their supporting infrastructure. Ofgem will also have a key role in engaging with all stakeholders.
  • Vehicle and battery manufacturers – Nissan is already manufacturing its Leaf model, and the batteries for it, in Sunderland; BMW has announced that it will be making electric Minis in Oxford; and Jaguar Land Rover has pledged to electrify its entire range from 2020.
  • Network owners and operators – National Grid, as transmission system owner and operator, will have to work closely with distribution network operators to ensure that investment in developing and reinforcing the networks is deployed in the most efficient way. This is a particularly challenging task as EVs may not be predictable in terms of the points at which they call on the networks. In February 2018, the Financial Times reported that National Grid is examining plans to install a fleet of superfast charging points for electric vehicles along Britain’s motorways that would feed directly off the electricity transmission network across 50 strategic sites9.
  • Electricity market participants – electricity generators, suppliers and distributors will have to work together with the network owners to ensure that vehicular demand for electricity is managed; they may also have a part to play in the ownership, operation and marketability of charging infrastructure.
  • Charging station developers – existing developers of new charging infrastructure, including POD point, Chargemaster, EV Charging Solutions and Rolec, are likely to face increasing competition and a need to ensure a consistent level of compatibility and interoperability.
  • NGOs and industry bodies including Energy UK and the Energy Saving Trust.

5. What are the main challenges to further deployment of EVs in your jurisdiction? How have EV developers sought to overcome these challenges to date?
From a UK consumer perspective, a recent government survey on public attributed towards EVs10 indicates that obstacles to EV ownership include:
  • Cost – EVs remain more expensive than combustion-driven vehicles to purchase. Maintenance, charging costs, resale value and cost of insurance are also factors.
  • Freedom of travel – while a large proportion of the car-owning population is able to charge their cars at home every night, the shortage of nationwide charging infrastructure is a major issue for prospective EV-purchasers. The ratio of public charging points to registered EVs is currently 1:2,900 in the UK as compared with 1:350 in Norway. The Automated and Electric Vehicles Bill may go some way towards addressing this issue – although the introduction of vehicle-to-grid discharging measures could cause consumers concern if it leads to their being unable to control their vehicles’ charge levels. If National Grid’s plans for a fleet of superfast charging points is delivered, 90% of drivers heading in any direction from anywhere in the UK would be within 50 miles of an ultra-rapid charger.
  • Recharging – convenience is a concern. Lack of charging points in the immediate area, lack of knowledge of location of charging parts and time taken to recharge are all factors here. Only 5% of those surveyed said they were thinking about buying an EV.

One of the most significant challenges will be encouraging the various stakeholders listed in section 4 above to cooperate to take ownership of the necessary infrastructure and manage electricity demand. There are a number of plausible models for this, from bespoke power purchase arrangements to taking consumers entirely “off grid”.
Current regulation is also a challenge – e.g. weight-based vehicle licensing requirements discourage purchase of electric vans. Ofgem has often been overtaken by the pace of change, and there will need to be a level of flexibility and pragmatism in bringing forward changes to the licensing regime and to industry codes to open the doors to new participants in the energy sector.
Despite significant advances in battery technology in recent years, this component remains a significant limiting factor for vehicle manufacturers, especially in relation to heavy goods vehicles. Further, while it might be assumed that developments in autonomous and connected vehicles will naturally accompany the transition to EVs, they in fact present their own difficulties. Self-driving vehicles process a very large quantity of data, and consume a lot of power in the process; fully electrifying these vehicles will require further developments in battery technology to be economically viable.
The National Infrastructure Commission, in its October 2017 draft National Infrastructure Assessment, observes an additional issue for government. The transition to EVs will require a new model for taxing road use (to fund road maintenance), since fuel duty will become inapplicable and EVs benefit from vehicle excise duty exemptions.
These challenges present a broad range of opportunities for businesses across the electricity market. While the transition from petrol/diesel to EVs will inevitably have a significant impact on electricity demand, National Grid has published reassurance that the media is prone to overstate this. National Grid anticipates that increase in peak power demand is most likely to be between 6GW and 18GW by 2050, with the exact increase depending heavily on electricity market development as well as consumer behaviour. System stress can be minimised by the effective roll-out of smart charging infrastructure and the complementary development of smart energy networks to smooth out the impact of the additional demand. Grid strain could be avoided entirely if charging point owners and EV drivers invest in their own generation and storage facilities.
References
  • https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/644457/veh0101.ods
  • https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/644467/veh0130.ods
  • https://www.iea.org/publications/freepublications/publication/GlobalEVOutlook2017.pdf
  • https://www.smmt.co.uk/vehicle-data/evs-and-afvs-registrations/
  • https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/633270/air-quality-plan-detail.pdf
  • https://www.judiciary.gov.uk/wp-content/uploads/2018/02/clientearth-no3-final-judgmentdocx.
  • https://services.parliament.uk/bills/2017-19/automatedandelectricvehicles.html
  • http://www.gov.scot/Publications/2017/09/8468/8
  • https://www.ft.com/content/82859d36-14c1-11e8-9376-4a6390addb44
  • https://www.gov.uk/government/statistics/public-attitudes-towards-electric-vehicles-2016



Glossary of EV terms
  • AC Motor: an electric motor driven by an alternating current.
  • BEV: Battery Electric Vehicle: EVs that use electric motors powered by on-board batteries.
  • DC Motor: a rotary electrical motor that converts direct current electrical energy into mechanical energy.
  • EV: Electric Vehicle: uses one or more electric motors or traction motors for propulsion.
  • EVI: Electric Vehicles Initiative: a multi-governmental policy forum established in 2008 dedicated to accelerating the deployments of EVs worldwide. Members: Canada, China, France, Germany, Japan, the Netherlands, Norway, Sweden, the UK and the US.
  • GHG: greenhouse gas: a gas that contributes to the greenhouse effect by absorbing infrared radiation. Carbon dioxide and chlorofluorocarbons are examples of greenhouse gases.
  • HEV: Hybrid Electric Vehicle: combine a normal petrol or diesel engine with an electric motor – rely on combustion and electric propulsion fairly evenly.
  • ICE: Internal Combustion Engine: an engine which generates motive power by the burning of petrol, oil, or other fuel with air inside the engine, the hot gases produced being used to drive a piston or do other work as they expand.
  • IEA: International Energy Agency: an autonomous organisation which works to ensure reliable, affordable and clean energy for its 29 member countries and beyond.
  • NOC: Nationally Determined Contributions: a term used under the United Nations Framework Convention on Climate Change (UNFCCC) for reductions in greenhouse gas emissions that all countries that signed the UNFCCC were asked to publish in the lead up to the 2015 United Nations Climate Change Conference.
  • Paris Agreement: an agreement within the United Nations Framework Convention on Climate Change dealing with greenhouse gas emissions mitigation, adaptation and finance starting in the year 2020.
  • PEV: Plug-in Electric Vehicle: can be recharged from any external source of electricity and the electricity stored in the rechargeable battery packs drives or contributes to drive the wheels.
  • PHEV: Plug-in Hybrid Electric Vehicles: have a larger battery and fall back on a smaller combustion engine less frequently than a HEV.
  • PLDV: passenger light-duty vehicle.
  • R&D: Research and Development.
  • ULEV: Ultra-Low Emission Vehicle: a vehicle that emits extremely low levels of emissions compared to others. In some jurisdictions it is defined in law and may be given tax or other advantages, or avoid restrictions or taxations imposed on high emission vehicles.

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