Memorandum submitted by the Environmental
Industries Commission (EIC) (AQ 26)
1. ENVIRONMENTAL
INDUSTRIES COMMISSION
(EIC)
EIC was launched in 1995 to give the UK's environmental
technology and services industry a strong and effective voice
with Government.
With over 280 Member companies, EIC is the largest
trade association in Europe for the environmental technology and
services (ETS) industry. It enjoys the support of leading politicians
from all three major parties, as well as industrialists, trade
union leaders, environmentalists and academics.
EIC's Transport Pollution Control Working Group
(TWG) represents over 40 Member companies including world leaders
in the supply of exhaust aftertreatment, suppliers of clean and
low greenhouse gas fuels, suppliers of catalysts and catalysed
components and consultants covering transport and the environment.
2. INTRODUCTION
The Government's National Air Quality Strategy
concludes that poor air quality is estimated to reduce the life
expectancy of every person in the UK by an average of seven to
eight months-impacting particularly on children, the elderly and
those in poor health. A recent report from the Committee on the
Medical Effects of Air Pollutants increased estimates of the mortality
rate from long-term exposure to particulate pollution. It concluded
that a 10-microgram-per-cubic-metre increase in fine particulate
matter (PM2.5) increases overall mortality rates by 1-12%. According
to recent estimates, poor air quality caused 5,000 premature deaths
in 2005 in London alone.
Particulate matter (PM) in particular has major
health implications-the National Air Quality Strategy states that
"both short-term and long-term exposure to ambient levels
of PM are consistently associated with respiratory and cardiovascular
illness and mortality as well as other ill-health effects".
However, the finest particles of particulate matter are known
to be the most damaging to health.
The new Ambient Air Quality Directive sets new
targets for PM2.5. This includes an average annual exposure reduction
target and, to ensure a minimum degree of health protection everywhere,
a limit value, which is to be preceded in a first stage by a target
value. Whilst more work is required to understand the UK situation
on PM2.5, the initial view is that the UK should meet the limit
value of the Ambient Air Quality Directive but may struggle to
meet exposure reduction targets.
EU air quality limits for particulate matter
were breached in London in each of 2005, 2006 and 2007. Current
projections show that these laws will still be breached in London
in 2011 and beyond.
Road transport is one of the most significant
contributors to poor air quality. For example, a recent European
Environment Agency report[44]
concluded that road transport is the most significant source of
NOx (39.4% of NOx emissions from all 27 Member States) and the
second largest emitter of PM10 (15.9%) and PM2.5.
Under the Ambient Air Quality Directive, deadlines
for complying with PM10 standards can be postponed for three years
(mid-2011) and for a maximum period of five years for nitrogen
dioxide and benzene (2010-15). To qualify for a postponement,
emissions of the pollutant have to be within a "margin of
tolerance". If emissions are above the "margin of tolerance"
Member States face infraction proceedings from the Commission
for failure to comply.
In addition to meeting the "margin of tolerance,"
Member States have to be able to demonstrate that "all appropriate
measures have been taken at national, regional and local level
to meet the required limit values".
EIC does not accept that this is the case in
the UK for the following reasons:
— Nationally the Government has failed
to sufficiently support the introduction of Low Emission Zones
across the UK. Our Members welcome the Local Air Quality Management
Guidance but believe that it should be supported through the urgent
introduction of a National Framework of Low Emission Zones—see
section 3.
— The Government has also failed to sufficiently
incentivise retrofit of the most polluting vehicles. This is despite
retrofitting diesel vehicles being highly cost-effective. For
example, the US Environmental Protection Agency has concluded
that retrofit generates US$13 of health benefits for every US$1
spent.
— Local authorities have failed to take
a lead by retrofitting their captive fleets to high standards—see
Section 8.
— In London—which has "presented
the greatest challenge"—Phase III of the Low Emission
Zone is currently under threat, with potentially major implications
for the UK's ability to meet the PM10 limit values, and the `Best
Practice Guidance on the Control of Dust and Emissions From Construction
and Demolition' has so-far been ignored, despite commitments to
its full implementation—particularly on the Olympic site—see
Section 5.
Despite this, and following consultation, Defra
recently submitted a request to the Commission to postpone the
deadline for meeting the PM10 targets under the Directive. The
UK's application concerned 8 zones/agglomerations (out of 43 in
the UK), most notably London. The application was rejected by
the Commission on 11 December 2009.
A similar requirement to postpone the deadline
for meeting the NO2 target is also expected—the UK currently
has NO2 exceedences along 3,500km of road. From current measures,
Defra expect about 850km of road to still exceed the NO2 limit
value in 2015.
In rejecting the UK's application to postpone
the deadline for meeting the PM10 targets, the European Commission
concluded that there are important elements missing from the Mayor
of London's draft Air Quality Strategy—see Section 5—"such
as a clear timetable for the implementation of the abatement measures
envisaged, as well as an estimate of the improvement of air quality
which can be expected by 2011".
The Commission also concluded that:
"The notification also includes references
to a number of local air quality action plans relevant for the
zone. However, several of those local plans have not been updated
for the purpose of demonstrating how compliance will be achieved
by 2011 and can, therefore, not be considered relevant for assessing
the notification. In view of the significant uncertainty regarding
the contents and objectives of the draft strategy and the absence
of up-dated local air quality action plans, the Commission considers
that an air quality plan demonstrating how compliance with the
limit values will be achieved by the new deadline as required
in Article 22(1) of Directive 2008/50/EC has not been provided
for zone 1. The Commission therefore considers that the United
Kingdom has not provided all relevant information necessary for
the Commission to assess the notification".
Action to improve air quality is, therefore, an
urgent priority
The area of interest that we shall address in
this submission is the steps that need to be taken to ensure that
air quality targets will be met in the future.
3. NATIONAL FRAMEWORK
FOR LOW
EMISSION ZONES
EIC believe that one of the most effective ways
to meet the UK's air quality obligations is through targeted programmes
focused on cleaning up the most polluting vehicles. These areas
will continue to suffer from poor air quality unless measures
are implemented at a local level.
The Low Emission Strategies Group convened by
Sheffield City Council is clear evidence that local authorities
are keen to adopt Low Emission Zones as a measure for improving
air quality. However, little progress has been made in areas other
than London.
EIC welcomed the recent Defra Local Air Quality
Management Guidance as an important tool for helping local authorities
improve the management of air quality in their areas, including
providing guidance for the introduction of Low Emission Zones.
However, the guidance provides insufficient Government support
for local authorities to adopt these measures cost effectively.
It also fails to facilitate consistency between any new Low Emission
Zones.
EIC acknowledge that vehicle classification
for any new Low Emission Zone is a decision for local authorities,
however a situation whereby vehicle operators have to comply with
different vehicle restrictions in different parts of the country
is undesirable.
EIC believe that the Local Air Quality Management
Guidance should be supported through the urgent introduction of
a National Framework of Low Emission Zones. A similar scheme operates
very successfully in Germany (EIC would be pleased to provide
further information on this scheme if required).
This would leave local authorities with the
decision on whether, when and where to have a Low Emission Zone—providing
that they operate within the national framework.
3.1 How Would a National Framework for Low
Emissions Zones Work?
A National Framework should establish a nationally
recognised standard for emissions and vehicle identification—supported
by a national certification scheme of retrofit technologies (see
section 4).
3.1.1 Emission Standards
A National Framework would set a nationally
recognised emission standard for light and heavy duty vehicles.
Using the heavy-duty vehicle classifications,
the standards should be set as follows:
— Class A—Euro V vehicles and better.
— Class B—Euro IV, or Euro II/Euro
III plus approved particulate filter.
— Class C—Euro III, or Euro I/II
plus approved particulate filter.
— Class D—Euro II and lower.
The terminology `approved particulate filter'
refers to the databases held by EST for the RPC and LEC approvals
which have formed the basis of the London LEZ categorisations
for phases 1, 2 and 4.
Equivalent emission standards should cover light
duty vehicles, as again defined for the London LEZ Phase 3.
3.1.2 Vehicle Identification
A window sticker could be used to indicate the
emission standard of the vehicle—this would be valid nationally.
Local authorities would then decide the minimum emissions standard
that is allowed into the Low Emission Zone.
The Low Emission Zone could then be enforced
manually by local authorities[45]—as
in Germany—simply checking whether there is a sticker in
the windscreen or not.
3.1.3 Facilitating Consistency
Without a National Framework, if local authorities
adopted their own Low Emission Zone—even under the new Local
Air Quality Management Guidance—vehicle operators could
be forced to comply with different vehicle restrictions in different
parts of the country.
Inconsistency between Low Emission Zones would
increase the cost and complexity of compliance and place a significant
burden on vehicle operators.
3.1.4 Creating New Jobs.
EIC believe that a National Framework for Low
Emission Zones would help create many new jobs in the UK's environment
industry.
Approximately 3,500 people are currently employed
in the UK by the retrofit market. Furthermore, an estimated 80%
of the UK's retrofit market is supplied by UK owned companies.
The UK's share of this market could increase significantly through
effective Government support for the introduction of Low Emission
Zones across the UK—helping create many new jobs.
4. National Certification Scheme of Retrofit
Technologies
A National Framework for Low Emissions Zones
should be supported with the introduction of a National Certification
Scheme of retrofit technologies.
In the development of the London Low Emission
Zone, Transport for London worked alongside authorities such as
VOSA and VCA to develop a list of approved retrofit particulate
abatement technologies for compliance with the scheme across the
full range of heavy-duty vehicles. A vehicle fitted with an approved
technology is issued with a Reduced Pollution Certificate or Low
Emissions Certificate to confirm compliance. EIC believe that
this certification could become a nationally recognised standard,
which local authorities could use as part of their own schemes
under a National Framework.
EIC believe that it is feasible to extend a
National Certification Scheme for retrofit of PM abatement technologies
to also cover NOx—given appropriate Government support.
This would greatly facilitate technologies that will also help
address future concerns over failures to meet NO2 limit values.
In his draft Air Quality Strategy, the Mayor
of London proposed that by 2015, subject to central Government
support in establishing a suitable certification and testing regime,
London introduce an emissions standard for NOx (Euro IV) into
the London Low Emission Zone for HGVs, buses and coaches.
EIC fully support this proposal and urge the
Committee to include amongst its recommendations the urgent introduction
of a National Certification Scheme of retrofit technologies to
cover PM and NOx abatement technologies.
One basis for such a scheme might be chassis
dynamometer testing for initial approval of the NOx abatement
technology, plus a requirement for an on-board datalogger which
could be interrogated at the annual vehicle test to confirm that
the system has been operational in service. We would be pleased
to expand on this proposal if required.
5. London Air Quality Strategy
EIC generally welcomes the set of policies and
proposals contained in the Mayor's draft Air Quality Strategy,
which seems to acknowledge the role of retrofit technologies in
reducing vehicle emissions from the existing vehicle parc. The
new proposals for a further phase for the London Low Emission
Zone (LEZ) in 2015, coupled with the retrofit of PM and NOx abatement
technologies to diesel-powered buses remaining in the fleet at
that time, are particularly welcome.
Our major concerns are two-fold: (1) a greater
degree of urgency is needed if these policies are to be transformed
into practice; and (2) the funding gap that needs to be filled
to deliver the more ambitious (and arguably the more effective)
of the proposals to proceed in a timely and effective manner,
which is expected to be in the region of £70—100 million.
EIC is very concerned that unless this is funding gap filled,
the Strategy cannot be implemented properly.
6. Funding for Retrofit
Barack Obama's American Recovery and Reinvestment
Act of 2009 provides US$300 million of funding through the Diesel
Emissions Reduction Act to heavy-duty diesel vehicle and equipment
owners to retrofit their fleets—at a time when the US Environmental
Protection Agency has concluded that retrofitting diesel vehicles
is highly cost-effective and generates US$13 of health benefits
for every US$1 spent.
In Germany, up to €2,000 is available to
contribute to the capital costs of a particulate filter. In Holland,
funding available on a sliding scale depending on the size of
the engine and emission reduction performance of the technology—up
to €11,000 is available per vehicle.
This could be focussed initially on London in
order to fill the funding gap identified in the Mayor's draft
Air Quality Strategy.
EIC believes that the Government should incentivise
the uptake of transport pollution control measures by:
— Announcing a National Framework for Low
Emission Zones supported by funding for retrofit of PM and/or
NOx abatement technologies—see Section 3.
— Introducing an equivalent "Enhanced
Capital Allowance" for retrofit technologies. Similar to
the existing Enhanced Capital Allowance scheme, EIC believe that
vehicle operators purchasing retrofit technologies to clean up
polluting vehicles should be entitled to 100% first-year capital
allowance.
— Incentivise the early uptake of Euro
VI vehicles through the continued use of the Reduced Pollution
Certification (RPC) scheme.
In advance of the 2009 Budget, EIC called for
the extension of the Reduced Pollution Certification (RPC) scheme
from 1 October 2009 for all heavy-duty vehicles that meet the
Euro VI levels before they become mandatory. We welcomed, therefore,
the announcement in the Budget that the Government would introduce
measures to incentivise the early uptake of Euro VI vehicles before
the standard becomes mandatory.
The Reduced Pollution Certification (RPC) scheme
offers reduced rates of vehicle excise duty to heavy goods vehicles
and public service vehicle operators who take action to reduce
the emissions of their vehicles to a certain level—before
the corresponding mandatory requirements come into force. Since
October 2007, RPCs have been available for lorries and buses that
meet Euro V standards before they become mandatory in October
2009. This is similar to the scheme that existed prior to October
2006 for Euro IV vehicles.
The RPC scheme is an excellent example of Government
policy helping to commercialise new technologies ahead of regulatory
requirements. This helps create a "lead market" for
emission reduction technologies, which can be exported across
the EU once mandatory standards come into force.
7. Promoting Technological Change and Cleaner
Vehicles
Central Government has a key role to play in
incentivising low emission vehicles through further changes to
vehicle excise duty and other tax regimes, with a focus on air
quality as well as CO2. Grants for retrofitting abatement equipment,
targeted directly at reducing tailpipe emissions from heavy duty
vehicles (HDVs), were introduced very effectively in the UK in
the mid 1990s and are now used in other European countries. There
is further scope for increasing the differentials between vehicles
conforming to different emissions standards.
We would also welcome measures that would promote
the uptake of cleaner freight vehicles through green procurement
standards. Such measures would have a beneficial effect across
the UK.
8. Reducing Emissions from the Public Transport
Fleet
Some towns and cities have already made strenuous
efforts to ensure that their buses in particular are as clean
as possible, and have embarked on programmes to fit diesel particulate
filters (DPFs). This includes London, which was at the forefront
of this movement but is now in danger of being left behind by
other UK and European cities, which have already started retrofitting
combined DPF and SCR (selective catalytic reduction) systems to
reduce NOx as well as PM.
The Mayor of London's Air Quality Strategy draft
does propose retrofitting the remaining Euro III buses in the
London fleet with NOx abatement equipment by 2015. This is welcome,
but should be started next year instead of waiting. Technology
has been proven in a two-year trial, which TfL has stated was
a success. The technology enables a Euro III (and indeed a Euro
II) bus to meet emissions levels equivalent to Euro V.
In addition, other local authorities should
be encouraged to do this, as it is a cost-effective way of reducing
fleet emissions and improving air quality in town and city centres,
where the greatest number of inhabitants will be affected.
We would welcome acceleration of the take up
of cleaner vehicles into taxi fleets, including introducing age-based
limits for taxis. London's introduction of a requirement for all
newly-licensed PHVs to meet a minimum Euro 4 standard for PM emissions
from 2012 should not overlook the option for retrofitting older
vehicles to meet this standard; full wall-flow filter systems
can reduce the particulate matter emissions of Euro 3 taxis to
better than Euro 4.
We would encourage all local authorities to
develop low emissions strategies for all of their public sector
vehicles, to include minimum emissions requirements for these
fleet vehicles. We believe that public sector captive fleets can
and should comply with Euro IV standards immediately. In this
context, we would ask that specific encouragement be given to
promoting retrofit (of DPF+SCR) as a cost effective option for
achieving this standard.
9. Reducing Emissions from Construction and
Demolition Sites
Dust and emissions from demolition and construction
sites can have a significant impact on air quality, not only on
the site itself but also on the health of people living and working
in the surrounding area.
Construction sites are often located in areas
of high air pollution, such as London—adding a further health
burden on those living close to these sites.
A significant proportion of these emissions
come from non-road mobile machinery used on demolition and construction
sites. For example, the City of Westminster's draft Air Quality
Strategy estimates that construction sites are responsible for
16% of road transport emissions of particulate matter.
It is widely acknowledged that reducing emissions
at construction sites in London and across the UK will make an
important contribution to meeting the UK's obligations under the
Ambient Air Quality Directive.
Whilst the London Low Emission Zone ensures
that heavy-duty vehicles over 3.5 tonnes used on major construction
sites in London, including the Crossrail site, meet EU emission
standards for particulate matter, equivalent standards for the
construction machinery used on site do not exist.
Emission standards for construction machines
are much lower than the equivalent on-road vehicle. The Non-Road
Mobile Machinery Directive sets emissions standards for new engines
but this does not have any impact on existing machinery. Furthermore,
even new construction equipment cannot achieve equivalent emission
standards to on-road vehicles.
In 2006, the Mayor of London published `Best
Practice Guidance On the Control of Dust and Emissions From Construction
and Demolition' to assist architects, consultants, developers
and local authority officers in establishing best practice for
reducing emissions across all aspects of managing a demolition
or construction site, including from non-road mobile machinery.
The London Best Practice Guidance states that
non-road mobile machinery with power outputs of over 37kW should
be fitted with suitable after-treatment devices listed on an approved
list managed by the Energy Saving Trust. Fitting suitable after
treatment devices to existing machinery—in line with the
`Best Practice Guidance'—can reduce emissions by at least
85%.
We are disappointed, however, that this part
of the Best Practice Guidance has not been enforced by the GLA,
in spite of there being a number of approved aftertreatment suppliers
and systems on the list managed by the Energy Saving Trust.
Whilst it is encouraging to see that the Mayor
of London, in his draft Air Quality Strategy, intends to address
this, albeit three years after the launch of the Guidance, air
quality in London has suffered for the reasons given below:
— To-date, there has been a total failure
to enforce the section of the guidance relating to non-road mobile
machinery on any major construction site in London, so air quality
is not being protected.
— The construction for the Olympic Games
represented an enormous opportunity to demonstrate the `green
credentials' of the ODA, but the implementation of DPF retrofit
on diesel plant over 37kW has been delayed (by lack of ambition
and lack of will) to the stage where much of this opportunity
has passed—see Section 9.1.
— The Crossrail project represents the
next opportunity for positive action in this area, but there are
already signs that the implementation of DPF retrofit will not
be pursued. As GLA has direct control over this project as a division
of TfL, we would expect a robust implementation programme.
EIC also recommend that the BPG, or equivalent,
is rolled out nationwide, as construction sites around the country
suffer from the same poor air quality as those in London
At the heart of this must be consistent emission
standards for non-road mobile machinery, including a recommendation
that local authorities introduce a requirement to fit suitable
after-treatment devices to all non-road mobile machinery operating
over a specified power output threshold in line with the London
`Best Practice Guidance.'.
Government departments and local authorities
should in particular include full implementation of the BPG in
procurement policies, and ensure that strategic applications require
implementation of the BPG.
9.1 London 2012
The Olympic Delivery Authority's Sustainable
Development Strategy includes a commitment to full implementation
of the `London Best Practice Guidance.'
Furthermore, Lord Sebastian Coe, Chairman of
the London Organising Committee of the Olympic Games, has recently
stated:
"... during the development of our Olympic
facilities, all works will be carried out in accordance with the
Olympic Park Code of Construction Practice. This will be published
on the London 2012 website shortly and sets out a series of measures
the ODA (Olympic Delivery Authority) will apply throughout the
construction and legacy transformation phases to control and minimise
dust and emissions from construction activities. This includes
ensuring works are carried out in accordance with the [London]
Best Practice Guidance: The Control of Dust and Emissions from
Construction & Demolition"..
Despite these commitments, the Olympic site
has failed to implement the Guidance. Construction started on
the Olympic site in April 2006, yet I was recently informed in
writing that the ODA "haven't retrofitted any plant on site".
EIC recently submitted a Briefing Paper to the
ODA which clearly demonstrated that fitting suitable after treatment
devices to existing construction machinery is cost effective,
has huge environmental benefits and does not jeopardise fuel efficiency,
machine functionality or the safety of vehicle operators.
It is disappointing that the ODA appears to
have disregarded this expert input in reaching its decision to
hold a "pilot study" of after-treatment devices on the
Olympic site.
It remains EIC's firm belief that starting a
"pilot study" now is unacceptable when there has been
a commitment from day one to comply with all aspects of the London
Best Practice Guidance. However, we have tried to cooperate with
the ODA to ensure that the abatement of construction plant in
line with the Best Practice Guidance occurs as an urgent priority.
Despite this we remain seriously concerned at
the apparent lack of urgency the ODA has shown to fulfilling its
commitment to comply in full with the London Best Practice Guidance.
Over the last two years the ODA has highlighted
"a number of issues" that have been raised regarding
the commitment to fitting suitable after-treatment devices to
construction machinery in line with the Best Practice Guidance.
Every one of these "issues" have either
been addressed through the Precis forum or through the strict
accreditation process established by the Energy Saving Trust to
ensure after-treatment devices for construction machines operate
properly and fully comply with the requirements of the Best Practice
Guidance.
The Energy Saving Trust provides an independent
certification and register service for pollution control technologies
to ensure that it satisfies the requirements of the London Best
Practice Guidance. Conformity testing is carried out on approved
technologies to ensure an ongoing high level of performance and
upholding of Energy Saving Trust certification standards.
As part of the accreditation process, each aftertreatment
device is required to comply with strict standards concerning
warranties; functionality; safety and emission control. EIC remains
extremely concerned that the ODA's "pilot study" is
proposing to address exactly the same issues.
Furthermore, in response to a recent question
by Darren Johnson in the London Assembly, Boris Johnson, Mayor
of London, recognised "that the work carried out in the development
of the BPG, as well as EST's certification process for after treatment
devices, provide overwhelming evidence of their environmental
benefits. It is also clear that devices certified by EST meet
minimum standards for a range of factors, including emissions
reductions, noise, safety and engine efficiency". EIC is
extremely concerned that the ODA's "pilot study" is
proposing to address these issues despite this "overwhelming
evidence".
The Mayor went on to state in his response that
"as yet, there has been very little use of these devices
on actual construction sites in London, or indeed elsewhere in
this country". However, diesel particulate filters (DPFs)
have been fitted successfully to construction machinery for many
years. For example, fitment was mandated in Switzerland for tunneling
equipment in 2000, and for other construction machines in 2003.
To date, around 10,000 filter systems have been fitted. Filters
can be fitted to ensure that the machine's operation is unaffected
and the operator's visibility is not impaired.
The Mayor's response also called for a "quick
pilot study". The Mayor went on to state that his "officials
are pressing for the trial to be as short as possible, and assuming
it is successful, that this leads to immediate rollout".
It is disappointing that the ODA appears to have ignored the Mayor's
request.
I am pleased to attach a copy of EIC's recent
paper `Comments on the Olympic Delivery Authority's Proposed Study
Plan for Reducing PM10 from Non-Road Mobile Machinery' as supplementary
evidence to the Committee's inquiry.
9.2 Crossrail
Crossrail is the most significant construction
site in Europe.
EIC welcomes Crossrail's commitment to "implement
measures to control and limit emissions which will affect some
residents and other sensitive receptors as far as reasonably practicable"..
We believe that Crossrail could demonstrate
environmental leadership by extending this commitment to full
implementation of the Best Practice Guidance. Full implementation
of the Best Practice Guidance will ensure that this work has a
minimal impact on the health of local people.
10. CLIMATE CHANGE
The effects of PM on health and air quality
are well documented, but there is a growing body of evidence confirming
that black carbon, emitted from diesel engines, is a significant
contributor to climate change. Black carbon has been estimated
to be the second largest contributor to global warming, with emissions
from diesel vehicles comprising nearly a quarter of total black
carbon emissions.
DPF fitment is the most appropriate action to
take to reduce black carbon emissions. Using a Euro III double
deck bus as an example, we estimate that the black carbon savings
from fitting a DPF could be 30% of the total climate impact, equivalent
to a 44% improvement in fuel consumption. Fitting DPF technology
to diesel engines such as trucks, buses, construction machines,
emergency generators and trains will not only improve air quality
and public health, but will be highly beneficial to short term
climate change and local urban warming in London.
18 December 2009
44 `Annual European Community Long Range Transboundary
Air Pollution Convention Emission Inventory Report 1990-2006'. Back
45
Paragraph 36 of Schedule 22 of Environment Act 1995 can include
the pursuit of air quality standards in Traffic Management Orders. Back
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