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Supplementary memorandum from South West Region of Chartered Institute of Logistics and Transport (SWT 62B)
(Invited response to an issue unresolved in oral evidence 26 October 2009) Competency The parties giving evidence did not develop a discussion of the inappropriate use of figures drawn from Traction Energy Metrics see1 demonstrated their concern about competencies in assessing transport alternatives. The rail industry, its consultants, its partially funded bodies (such as Travel Watch South West) and the DfT, quote Traction Energy Metrics to illustrate the implications of modal transfer without discussing the report's clear indication that the figures are not relevant to the consequent increase or decrease in demand for electricity. This omission illustrates how far the competency deficiency referred to by many witnesses is a deficiency of awareness of factors contributing to carbon intensity. Traction Energy Metrics As discussed on pages 9 and 10, the figures presented do not consider what impact increased demand for electricity for rail traction has on the consumption of the most adverse fuel in the generation mix. (The relevant part of pages 9 and 10 are reproduced for convenience in the attachment.) In pages 9 and 10 Traction Energy Metrics does outline a realistic argument that changes in demand due to increases or decreases of electrical demand for rail traction increase or decrease the use of the most climate change adverse fuel, coal. No counter argument to this logic is offered. What is offered is an opinion, "that looking at the whole network" neither the extreme of treating electricity as low carbon because it is purchased from nuclear generators not the extreme of regarding it as high carbon is justified. This is outside the context of changes in demand and is simply stated as an opinion; it is not argued. Traction Energy Metrics goes on to say that use of emissions due to the average of generation fuels is DEFRA policy for transport. DEFRA of course is not a transport department, what is referred to is a policy for Company reporting of Greenhouse gases including those emitted by company transport. The context of company reporting does not address increases or reductions of electricity demand on the fuel mix that would have been if the changes had not occurred. That is the responsibility of the DECC. The Secretary of State for Energy
and Climate change has very recently explained that any shortage of generating
capacity in the 2017 period will be met by burning more coal. His department confirms
that it is the intention to retain coal as a generation fuel beyond 2050 but to
introduce Carbon Capture and Storage as soon as possible in order to render the
emissions harmless to climate. Following the argument in TEM, it is not
sufficient to introduce CSS for the Traction Energy Metrics gives figures for the carbon intensity of coal as a generating fuel. These can be applied to the figures given for electricity consumption by rail vehicles to show that increases in electric traction that involve increasing the use of coal are more climate change adverse than increases in rail diesel traction. This calculation is a matter of arithmetic not judgement and also shows that increases in electric traction as a result of modal transfer from road represent an adverse effect on climate change. The Network Electrification RUSsee2 referred to in oral evidence does not analyse the impact of increased coal burning due to extending rail electrification. It does however refer to other papers from which an calculation can be made of the significant reduction in Benefit Cost Ratio due to the adverse climate change effect caused by additional coal burning. An example of this calculation can be given as further evidence if required. Some examples of other calculations illustrating the lack of evidence base for some current assumptions about the relative impacts of modal transfer are also available. Developing Competencies The "carbon led" planning required by the DfT in their letter accompanying the RFA see3 is only possible if planning staff at all levels have available a common competency for assessing the carbon intensity of alternatives. A competency gap in this area is clearly shown by the out-of-context use of the TEM figures and the wide acceptance of the Network Electrification RUS, despite its omission of the issue of how increased electrical demand inevitably increases the level of coal burning above what it would otherwise be is a clear demonstration of this competency gap. The gap in competence tends to lead to polemical debate about the relative virtue of modal transfer rather than the consideration of objective evidence recommended by CILT SW through a process of focussed audit. The concern expressed in other parties' evidence about the role of LA Environmental directors seems due to lack of process and incompatible top-level objectives rather than organisational deficiencies. Environmental directors are especially important because they report to locally elected councillors. At this democratic level methods of implementing national policy without unintended adverse impact must devised. Also at this democratic level conflicts in the aspirations of different groups of local electors must be resolved. Any development of regional aspirations which is not fully responsive to expertise at local authority level is dangerous and may be especially so if there is only a dilute democratic process at regional level. Consequently the most practical way forward is to develop the new competencies needed primarily at local authority level through a process of audit at that level.
Note 1 Traction Energy Metrics published by the Rail Safety & Standards Board http://www.rssb.co.uk/pdf/reports/Research/T618_traction-energy-metrics_final.pdf Note 2 RUS is the acronym for Rail Utilisation Strategy. Note 3 Letter from the Department of transport dated 22 July 2009 giving the Department of Transport's response to transport aspects of the South West region's regional funding advice. Extract from Traction Energy Metrics Published by the Rail Standards and Safety Board. "It is sometimes argued that, because Network Rail currently purchases electricity from British Energy, a predominantly nuclear power generator, the electricity can be treated as "low carbon". It is interesting to compare this line of argument with the debate
in The opposite, and equally credible, way of looking at the situation is that, were the whole of the GB railway to be closed tomorrow, the nuclear stations would continue to operate at their normal power and some fossil fuelled power stations would be instructed to reduce load. Thus the avoidable energy use can be thought of as being entirely carbon based. When looking at the whole GB rail network neither of these extreme
ways of looking at energy consumption is appropriate. In this report, we have
taken the view that, unless there is a unique supply to a railway completely
isolated from the rest of the electricity supply (as used to be the case with
the 16.7 Hz supplies in parts of Northern Europe), where a railway purchases
electricity is purely a business decision and consequently does not materially
affect the associated national carbon emissions in the short to medium term.
For this reason, we have used the average carbon emissions for
November 2009 |