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Memorandum
submitted by The Environmental Industries Commission (EIC) (AQ 26)
Thank for you for the opportunity to
input into this inquiry.
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 7-8 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[1] concluded that road transport
is the most significant source of
NOx (39.4 per cent of NOx emissions from all 27 Member States) and the second largest emitter of PM10 (15.9 per cent) 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 (2010-2015). 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:
Ø 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.
Ø 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.
Ø Local
authorities have failed to take a lead by retrofitting their captive fleets to
high standards - see Section 8.
Ø 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:
Ø Class A - Euro V vehicles and better
Ø Class B - Euro IV, or Euro II/Euro III plus approved
particulate filter
Ø Class C - Euro III, or Euro I/II plus approved particulate
filter
Ø 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[2] - 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 per cent 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:
Ø Announcing a National
Framework for Low Emission Zones supported by funding for retrofit of PM and/or NOx abatement
technologies - see Section 3.
Ø 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 per cent first-year capital allowance.
Ø 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 per cent 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 per cent.
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.
I trust you will find these comments
useful.
18 December
2009
[1] 'Annual
European Community
Long Range
Transboundary
Air Pollution Convention Emission Inventory Report 1990-2006'
[2] Paragraph
36 of Schedule 22 of Environment Act 1995 can include the pursuit of air
quality standards in Traffic Management Orders.
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