Memorandum submitted by Johnson Matthey Catalysts (AQ 20)
1.
Summary of Key Points
· Central
government has a key role to play in incentivising and encouraging lower
emissions.
· It is important
to clean up public vehicle fleets (primarily buses and taxis) as soon as
possible, as these are the largest sources of emissions in our towns and
cities. Our company and Eminox have technology and the experience to provide
the retrofit systems for buses.
· Low emission
zones are an important part of any strategy to reduce emissions in towns and
cities.
· A national
framework for low emission zones should be established to ensure consistency
throughout the UK
in both standards and certification.
· DPF technology
is well proven on non-road mobile machinery and its use should now be mandated
on sites throughout the UK.
· Ensuring that
as many vehicles as possible have a DPF will reduce diesel particulate levels
and improve public health. It will also reduce black carbon emissions, thereby
reducing the global warming impact of the UK vehicle fleet. We have data
showing that the estimated climate impact of fitting a filter to a Euro III
double deck bus is equivalent to a fuel saving of 44%.
· Diesel rail
locomotives should be fitted with exhaust aftertreatment to remove PM and NOx.
2.
Background
Johnson Matthey
welcomes this inquiry into air quality, and would like to comment in particular
on the steps that need to be taken to ensure that air quality targets will be
met in the future.
As one of the
largest UK
companies in the chemicals sector, Johnson Matthey has been supplying catalysts
for the control of air pollution since the late 1960's and has supplied one
third of all autocatalysts made since production first started in 1974. Johnson
Matthey has 15 manufacturing sites and 9 technology centres supporting our
emission control technologies business around the world.
The technologies developed at Johnson
Matthey have made it possible to reduce oxides of nitrogen (NOx),
hydrocarbons (HC) and carbon monoxide (CO) from petrol powered vehicles by over
95% from pre-regulation levels.
Johnson Matthey has also developed
diesel particulate filter (DPF) technologies to reduce emissions of the mass of
particulate matter (PM) from diesel engines by over 90% and the number of
particles by over 99%. Johnson Matthey is the owner of CRT(r) and SCRT(r)
technology that is licensed to Eminox Ltd for supply to the UK retrofit
market.
The Johnson Matthey SCRT(r)
system combines CRT(r) DPF technology with selective catalytic
reduction (SCR) to reduce emissions of all four regulated pollutants from
diesel engines.
3. 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.
4. 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. This SCRT(r) technology is not only technically proven, but
commercially as well. Our partner Eminox has supplied more than 300 systems
throughout Europe.
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
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.
5. Low Emission Zones
As well as
implementing tighter emissions standards on the captive fleet, it is also
important to reduce emissions from other vehicles. This should be done by
specifying a minimum Euro emissions standard, in the way that London has already done. Aftertreatment
systems in the form of DPFs and/or SCR systems can be fitted to vehicles to
effectively increase their Euro standards.
We would
suggest a minimum level of Euro IV for heavy duty and Euro 4 for light duty
vehicles, moving to Euro V/5.
In order to
ensure consistency of zones throughout the UK, a national framework for local
low emission zones will be essential-see below.
6. National Framework for Low Emission Zones
A National Framework for Low
Emission Zones should establish a nationally recognised standard for emissions
and vehicle identification, supported by a national certification scheme of
retrofit technologies, as a matter of urgency.
This would make it much easier for a local authority to establish a local
'Low Emission Zone' and to prescribe what standard of vehicle would be allowed
to enter, providing that they operate
within the national framework.
In the development of the London
LEZ, TfL worked with authorities such as VOSA and VCA to develop certification
of approved retrofit particulate abatement technologies. This certification could become a nationally
recognised standard, which local authorities could use as part of their own
schemes under a National Framework.
We 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 concerns over failures to meet NO2 limit
values.
Since it has now been established that
the retrofit of particulate traps is cost-effective and cost-beneficial within
a short timeframe, we also believe that a National Framework for Low Emission Zones should be supported through government grant funding and/or other
financial incentives to encourage retrofit.
This approach
has helped to achieve excellent compliance rates in other countries such as Holland and Germany, both of which successfully
operate LEZ schemes within a national framework, supported through national
funding for retrofit technologies.
7. Reducing Emissions from Construction and Demolition Sites
Johnson
Matthey is the market leader for diesel particulate filter systems in Switzerland,
the largest market for aftertreatment systems for non-road mobile machinery
(NRMM).
It is
widely acknowledged that reducing emissions at construction sites will make an
important contribution to meeting the UK's obligations under the Ambient
Air Quality Directive. We are however disappointed that the part of the Best
Practice Guidance (BPG) related to reducing emissions from construction
machinery has not been enforced by the GLA, in spite of there being a number of
approved aftertreatment suppliers and systems, including Johnson Matthey, on
the list managed by the Energy Saving Trust.
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.
The BPG should now be mandated for all construction sites in London, and also nationwide, as construction
sites around the country suffer from the same poor air quality as those in the
capital.
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.
8. Climate Change
It is important
to ensure that as many diesel vehicles and machines as possible are fitted with
a DPF, for public health, air quality and climate change reasons.
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.
I hope you will find these
comments helpful, and will be happy to respond to any clarification you might
need.
14 December 2009
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