Memorandum submitted by British Vehicle
Rental and Leasing Association BVRLA
Thank you for inviting us to comment on your
recent inquiry into how the UK Government is working to reduce
carbon emissions from transport.
We do have concerns with the work being done
by the Government regarding reducing emissions as there appears
to be a lack of clarity and commitment being shown which does
not provide encouragement for people to commit to cleaner vehicles.
We cannot continue to emphasise just how imperative it is to offer
clear signals to vehicle end users and the fuel industry to offer
them confidence to invest in vehicles, technology and refuelling
In particular, significant damage has been done
to people's confidence in alternative fuel programmes following
the disbandment of the previous incentives and subsidies for early
adopters of "LPG". The Powershift programme was administratively
cumbersome and onerous for our Members, this does not help Government
attract people to alternative fuel vehicles. Other issues with
previous programmes have included price practicality and sustainability,
together with ease of access to service repair and maintenance
were key factors missing that fleet purchasers and users take
into consideration when selecting a vehicle.
The Committee may be aware of the powerful and
influential role tax and other fiscal incentives have been proven
to play in encouraging a greater use of technology that delivers
reduced vehicle emissions. This to date has helped deliver a notable
improvement in the environmental performance of both road fuel
gases and conventionally fuelled vehicles.
For example, based on the figures from the Inland
Revenue's evaluation report the benefit in kind regime for company
cars introduced in 2001 has reduced emissions considerably.
In the light of this we are surprised that Government
is not doing more to encourage take up of EURO IV commercial vehicles.
Following the success of the tax incentives offered to car drivers
to encourage take up of EURO IV cars we thought it would make
sense for equivalent incentives to be offered for commercial vehicles.
Especially given the complex technology required for commercial
vehicles running on EURO IV. Given the complicated nature of EURO
IV we have recently been advising our Members to avoid this technology
due to the lack of incentives as there is no way for Members to
recoup their costs in investing in EURO IV.
Our view is that more could be done to encourage
take up of cleaner vehicles through low emission zones and future
road charging schemes. It appears that all these proposals only
penalise the worst offending vehicles rather than offer incentives
to the drivers of the cleaner vehicles. By offering incentives
to the drivers of the cleanest vehicles this will encourage drivers
to go beyond the minimum standard.
We believe the following factors should be taken
into consideration when Government looks at how to ways of reducing
carbon emission from transport:
Most of our Member's customers
will be tied into long-term vehicle hire contracts and will find
it financially punitive to terminate an agreement early. Thus,
a clear strategy on the fiscal incentives and support is imperative
for any such long term planning and investment.
Fleet policies and budgets are
also medium to long term issues and key influencers need the confidence
and stability to make long term proposals and decisions.
Dependant on the introduction
of low emission zones and changes to both congestion charging
and road user-charging rules, we may see a greater movement or
even renewed interest in these programmes.
The continuance of the fiscal
environmental message of the "less you pollute, the less
you pay" principle is likely to result in the disposal of
older vehicles. However, it must be noted that such vehicles may
not be replaced due to the cost of replacement with a newer vehicle.
We hope our comments prove helpful and provide
a useful overview as to how Government could look to reduce carbon
emissions from road transport.