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