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CMS Guide to Electric Vehicles

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CMS Guide to Electric Vehicles
Interest in electric vehicles (“EVs”) has waxed and waned over the years but they are no longer a rarity just for enthusiasts. Public and media interest in EVs and global take up of registered EVs has surged over the last ten years, increasing exponentially since 2010. The rapid increase was examined by the International Energy Association (“IEA”) it its recent report, Global EV Outlook 2017: Two million and counting1, citing a new record of registrations of EVs in 2016, with over 750,000 sales worldwide. The IAE goes on to cite Norway as the world leader in EV deployment with a 29% market share, followed by the Netherlands with a 6.4% market share, Sweden with a 3.4% market share, and finally, China, France and the United Kingdom lagging behind with market shares close to 1.5%. Those figures can be deceptive, as China had the largest EV market, accounting for more than 40% of the electric cars sold in the world and more than double the amount sold in the United States.
What is driving the current surge of interest? A number of factors, including a range of government initiatives:
  • the UK2and French3 governments separately announced in July 2017 that the sale of new conventional petrol and diesel vehicles will be banned by 2040;
  • more ambitiously, all cars sold in India are to be powered by electricity by 2030, according to an announcement made by the energy minister in April 20174;
  • large cities (Paris, London, Mexico City, Stuttgart, Tokyo) are imposing measures to encourage take up of EVs, as reported by Bloomberg in May 20175 – such measures include banning or restricting polluting vehicles, or to imposing charges for such vehicles entering specified city zones.

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 2015 in the United States6. In September 2017, the FT reported on Bloomberg research that predicted “tumbling battery prices” would make EVs cheaper to buy than conventional vehicles in most countries by 2025–29, leading to EVs making up more than half of new car sales worldwide by 20407.
Deployment of EVs could address a number of concerns, but mass uptake and market saturation will bring with it its own set of challenges. What charging infrastructure will exist? Will demand on networks increase as more EVs need to be charged? Or will demand decrease as large businesses and domestic consumers forge their own charging solutions, whether that means an increase in embedded generation or investment in energy storage? In 2017, many of the world’s largest automakers (including VW, Toyota, General Motors, Renault-Nissan and Ford) announced ambitious targets for investment in and sale of electric models; but will EV demand keep pace with this production potential?
To enable large scale EV deployment, clarity will be required in terms of government policies, regulation, applicable laws, and the interactions between EVs and electricity networks. Solutions cannot come forward as long as different interest groups continue to work in silos. Government departments will have to work closely and collaboratively with each other and with the automotive and energy industries to ensure that future developments, regulation and legislation will be fit for purpose.
Why EVs?
The increase in deployment of EVs creates a wealth of opportunities for developers, investors, automotive manufacturers, electricity generators, supply chains, network operators, energy suppliers, consumers, infrastructure owners and developers, and other electricity and automotive sector participants.
EVs could be the key to developing solutions that have the potential to address a range of concerns and issues:
Types of EVs – technologies and terminology
Electric vehicles that use electric motors powered by on-board batteries are sometimes called Battery Electric Vehicles (“BEVs”) to distinguish them from hybrid engine vehicles, which combine a normal petrol or diesel engine with an electric motor. Conventional hybrids (such as the Toyota Prius) balance combustion and electric propulsion fairly evenly, whereas “Plug-in Hybrids” (“PHEVs”) have a larger battery and fall back on a smaller combustion engine less frequently.
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 long 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 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 currently in development, with both “solid state” and “lithium air” batteries promising further gains in the crucial variable of energy density.
Electric motors are more efficient than combustion engine propulsion – this, coupled with the transition to a lower-carbon electricity generation mix, is how EVs will contribute to the reduction of global air pollution. The table below sets out the types of motors currently used in EVs:
Motor type Advantages Disadvantages
Alternating-Current (“AC”) Motor
  • Greater efficiency and more reliable continuous power (this makes a difference uphill).
  • Can run at higher RPMs without overheating (and therefore able to move heavier vehicles).
  • Better suited to regenerative braking systems (which use braking power to re-charge the battery)
  • More expensive than DC motors.
  • Since battery output is DC, the EV must also house a DC/AC converter to power the motor from the battery.
Direct-Current (“DC”) Motor
  • More affordable than AC motors
  • Greater power.
  • Tendency to overheat.

Regulatory considerations – European legislative framework/policy
A key driver for the transition to electric vehicles is regulatory targets on carbon emissions. The Paris Agreement, which came into force in November 2016, brings a large number of nations together in the pursuit of containing climate change. Parties to the treaty are required to declare their best efforts in the form of “nationally determined contributions” (“NDCs”).
The EU’s NDC requires it to reduce greenhouse gas emissions to a level 40% below 1990 levels by 2030, and the EU has further committed to achieve an 80% reduction by 2050. The EU has put a range of transport-related measures in place to achieve this goal, including the following8:
  • 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 greenhouse gas 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 20309.

Financial incentives for the purchase of new EVs, along with a range of tax and access benefits for ownership, are present across the larger European economies. Norway and the Netherlands are international leaders in EV incentives, with special measures including nationwide toll exemptions in Norway and an urban charging point development regime led by resident applications in Amsterdam.
Regulatory considerations – global legislative framework/policy
The Paris Agreement’s NDC mechanism, giving individual countries discretion over their own targets, was designed to prevent undue burden on less economically developed nations. The NDCs of other major polluting nations are not closely aligned: China has committed to a 60% reduction in CO2 emissions from 2005 levels by 2030, whereas India’s target is 33%; Russia is aiming for a 25% reduction in greenhouse gas 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 greenhouse gas emissions from 2005 levels by 2025. China, India, Japan and the US (unlike the EU) also included specific transport emissions measures in their NDCs, including fuel efficiency improvements and alternative fuel promotion.
Few nations have stricter vehicle emissions standards than the EU, but the US and Canada are currently phasing in the world’s most 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 has achieved remarkable EV sales growth through such promotional measures 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.
Other legal issues
Cohesive regulatory frameworks for electric vehicles are not well-established. To prepare for the universal electrification of roads, there is likely to be national legislation on a broad range of issues, including vehicle licensing and taxation, vehicle and charging standards and the smart management of grid demand.
About the guide
The CMS Energy group is passionate about developments that impact the 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 to help with their investment and growth decisions. We are starting with a chapter on developments in the UK and will continuously update it 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

  • (accessed 15 September 2017)
  • See the Commission Staff Working Paper at for a detailed summary of the existing EU measures on sustainable transportation.

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?
Electric vehicles currently represent a small proportion of the vehicles licensed in the UK:
“Ultra-low emission vehicles”
(Electric, hybrid & hydrogen)1
Total vehicles2
241 (2 plug-in hybrid electric vehicles + 239 hybrid electric vehicles) 3,300,000

EVs represent 0.5% of the market share 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, and an extended horizon of 2030.
A number of legislative changes were introduced to the primary and secondary legislation. These 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.

  • 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;

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 electric vehicles.
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 the 22kW public charging points.
  • 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.

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 universities.
1. What EVs have been deployed in your jurisdiction to date?
Electric vehicles currently represent a small proportion of the vehicles licensed in the UK:
“Ultra-low emission vehicles”
(Electric, hybrid & hydrogen)1
Total vehicles2
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 passenger light-duty vehicles exceeded 1% of sales of all such vehicles.3 August 2017 was the first month in which pure 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 its Air Quality Plan in July 2017, 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. 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 Bill, 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, forcing 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.5
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.
Investments are also coming from industry sources. Ofgem, the UK National Regulatory Authority, administers a GBP 500m Low Carbon Networks Fund sponsored by distribution network operators. Projects proposed by DNOs in relation to electric vehicles have included experimentation with charging point tariffs and extensive smart metering to determine how best to reinforce distribution networks.
The current 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 vans 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 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 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 will not be predictable in terms of the points at which they call on the networks.
  • 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, obstacles to EV ownership include:
  • Price – EVs remain more expensive than combustion-driven vehicles.
  • 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 electric vehicles 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.

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 electric vehicles 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.

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.
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