EST AQ Consultation Response Oct 2015

Transcription

1 EST AQ Consultation Response Oct 2015 Question 1: Do you consider that the proposed plan set out in the overview document strikes the right balance between national and local roles? Due to the inherently complex nature of air quality, it is essential that any response to exceedances involves a fully integrated effort from both national and local government.. National leadership from central government is necessary to ensure consistency of policy interventions, while local government involvement in designing and carrying out solutions is required in order to properly grasp the local challenges of tackling exceedance. Encouraging the adoption of low emission vehicles will be most efficiently achieved through national incentives and fiscal measures. EST would strongly recommend that there are clear, long-term policy levers in place at a national level to provide confidence to both the fleet and consumer markets when choosing vehicles. These should include the plug in vehicle grant, EV charging infrastructure support and incentives, VED rates, company car tax and write down allowances. A wide range of incentives and funding schemes are already in place. Ensuring these are coordinated and consistent, for instance to ensure that levels of support are the same across the UK, is key to facilitating the adoption of low emission vehicles. Managing fleet operations better could bring air quality benefits quickly during the transition to low emission vehicles, but are not currently suggested within National or Local plans. Nationally coordinated local interventions supporting the reduction of fleet mileage will positively affect air quality. Whilst a focus on the future use of ULEVs and more active travel are an important part of the mix, a more short term focus on better organisational travel management (such as minimising use of grey fleet) within both the public and private sector could bring short-term benefits. Local incentives and support can also result in inefficiency and waste if they are not mandated to utilise existing nationally funded services and IP in their implementation. EST would urge Government to instead fund a suite of national services for fleets and consumers (detailed in our answer to question 2), allowing nationally coordination to avoid duplication of services and consumer confusion across the UK. One such local idea being considered in several of the Go Ultra Low City submissions is the use of a diesel scrappage scheme. EST supports the concept as an effective timelimited scheme to encourage ULEVs by offering an incentive to replace older, dirtier diesel vehicles. EST would recommend that if multiple areas considering this are approved under the GUL city scheme, then the design and management of the scheme is separately supplied by a single provider to maximise efficiency and effectiveness. With our experience of designing and running the successful Boiler Scrappage scheme for DECC in 2011, EST can to advise on the key success criteria of any such scheme. The keys factors to consider will be early engagement with the supply chain of vehicles and

2 the simplicity of the scheme in terms of applicability and fulfilment. A well-implemented scheme should be based around intelligent vehicle choice criteria which encourage the right ultra-low emission vehicle for the drive cycles of applicants. Question 2: Are you aware of any other action happening in your area which will improve air quality and should be included in the plan? If yes, please identify as far as you are able: a. What the additional actions are; b. The zone(s) in which they are being taken; and c. What the impact of those actions might be (quantified impacts would be particularly useful). There are a range of interventions not specifically mentioned that EST feel should be included as part of the toolbox to improve local air quality. These relate to the area of fleet operations nationally, but which have a marked impact in localities suffering from poor air quality. EST has been providing services to fleets for the past 15 years primarily to reduce fuel use and therefore carbon emissions, but have impacts on local air quality. These DfT supported schemes still offer wide scale opportunities to influence vehicle choice and organisational travel behaviour. Whilst the list below is not exhaustive, through building in air quality considerations into existing national advice and support for organisations on the following topics, short term benefits can be realised at scale: - Grey fleet. Many millions of business miles are driven every year in grey fleet vehicles with an average age of 8 years. With a generous HMRC-approved reimbursement rate of up to 45p per mile, there is a strong financial incentive for grey fleet mileage, much of which takes place in urban areas where air quality is an issue. Provision of advice to organisations on how to manage down grey fleet mileage and improving the quality of vehicles driven by grey fleet drivers should be placed at the top of the list of priorities. - Driver behaviour While there is disagreement over the air quality benefits of some eco-driving techniques (particularly changing up at lower engine revs), training and educating drivers to ensure they adopt best practice in driving style will support the air quality agenda. In particular, greater anticipation to avoid stopstart driving and anti-idling measures are essential in reducing excess fuel use and NO 2 creation in urban areas where there is congestion, or in areas where large vehicles are confined by buildings and are close to pedestrians such as bus stations, taxi ranks or HGV service areas. EST can support this through strong relationships with the driver training industry which could facilitate greater awareness of the air quality impacts of driver behaviour. - Mileage Management - Fleets can save money and reduce emissions by driving less. Effective mileage management policies will reduce the need for journeys that will save money, improve productivity and reduce emissions. - Route planning For many fleets operating light commercial vehicles, route planning and optimisation services can help drivers avoid areas of congestion,

3 reducing journey times and tailpipe emissions. With greater engagement and data-sharing between local traffic management and route optimisation providers, fleet vehicles could better avoid air quality hotspots to avoid creating additional emissions. EST would also urge policy makers to build on existing work with fleet operators to demonstrate the benefits of ULEVs. This has become a priority now that air quality has risen up the agenda. In recent years, EST has provided fleets with compelling evidence based on whole life cost analysis of the benefits of ULEVs. This support has encouraged fleets to acquire demonstration vehicles and experience how they operate in practice and whether they would be a viable alternative to their existing conventionally fuelled vehicles. The uptake of ULEVs has increased following these demonstrations because they strengthened fleets confidence about integrating ULEVs into their fleet. In addition, EST has been providing support to cities to site new charging infrastructure through surveying user journey types and mapping potential locations (covering groups such as taxis, car clubs and commercial vehicle operators). Local areas need this support to be sure infrastructure is effectively utilised, financially viable and able to attract private investment. We would recommend that national government considers funding the wider application of this approach to ensure charging infrastructure growth is carried out in an informed and integrated way that ensures maximum utilisation.

4 Question 3: Within the zone plans there are a number of measures where we are unable to quantify the impact. They are included in the tables of measures. Do you have any evidence for the impact of these types of measures?. No response to specific local zone plans. Question 4: Do you agree that a consistent framework for Clean Air Zones, outlined in section of the UK overview document, is necessary? If so, do you think the criteria set out are appropriate? There is a strong requirement for a local framework to ensure that any measures considered are consistent. This is important for fleet operators using vehicles in multiple towns and cities on a daily basis. A situation where access control systems are different in every city is not viable and EST would strongly recommend that a consistent approach is adopted across the UK. Also with regards to the criteria set for the Clean Air Zones proposed, it would be useful if Defra provided the background information on which the criteria were based. Question 5: What do you consider to be the barriers that need to be overcome for local authorities to take up the measures set out in section 4 of the UK overview document? How might these be overcome? Are there alternative measures which avoid these barriers? Local authorities will require funding and expert support to design and implement the right solutions to improve air quality in their areas. There are barriers in individual s perceptions of air quality issues. Whilst dirty air is seen as an important issue impacting on public health and the environment, individuals do not understand the major causes of poor air quality and how their actions contribute to the

5 problem. Car buyers and fleet purchasers are confused by press coverage of the VW emissions affair, where CO 2, NO X, PM and even MPG figures are used interchangeably. More needs to be done to underpin local air quality mitigation activities with clear and authoritative facts and advice on air quality issues and how vehicle purchasing choices and driving behaviours affect it. EST is working on how to present simple advice to consumers and fleet purchasers about choosing the right vehicle for their journeys. This involves helping them to match their common journeys with the most appropriate vehicle fuel type. For longer extraurban, out of town driving, a clean diesel vehicle may well be still the most suitable choice, but for lower mileage, mixed driving we would recommend considering efficient smaller capacity petrol engines or mild hybrid vehicles. For shorter, primarily urban or suburban trips a plug-in hybrid or battery electric vehicle is ideal. There remain mixed signals from HM Treasury on key fiscal incentives for private and company car users. The Vehicle Excise Duty was until recently based on CO 2 and thus incentivised lower CO 2 diesel vehicles. Equally, this kind of regime remains in place for BIK taxation for company car users. Whilst it is essential that CO 2 is not overlooked in future decisions on tax, there needs to be a balanced approach to encourage the right vehicle choice. In a recent roundtable event for representatives from the fleet industry facilitated by EST, there was overwhelming support for a long term, balanced policy for fleet drivers to avoid perversely incentivising employees to swap a clean, efficient company car for cash allowance grey fleet vehicles that are more likely to less efficient and larger contributors to lower air quality standards. EST has good evidence through our consumer tracking report UK Pulse that only 15% of consumers felt the Government is doing sufficient work to combat poor air quality. In the same study, we found a low level of basic knowledge of the factors affecting air quality such as which types of fuel emit higher air quality emissions. Tackling this confusion is essential to help overcome the mistrust that exists, particularly in the light of the VW scandal, if fleets and consumers are to make the best choices to improve local air quality. Question 6: Are you aware of any additional action on nontransport sources to improve air quality that should be included in the plans? From recent emission inventory studies, it is apparent that there are other non-transport related emissions within an urban environment that can only be tackled by a coordinated national approach delivered at a local level. One such air pollution impact relates to emissions from demolition and construction activity and in particular emissions from non road-mobile machinery (NRMM). These machines are generally diesel powered and subject to emission regulations that are somewhat behind on-road regulations, combined with the long service life of machinery, air pollution is sometimes overlooked when in fact there can be significant contribution.

6 A policy approach that has been taken in London is to introduce a LEZ for NRMM which stipulates that NRMM working on developments need to meet specific emission levels. In order to implement this policy to full effect, there needs to be a harmonised national approach that can be rolled out across local authorities and involving planning, environmental and health officers. The requirements placed on the construction industry will mean a number of options to meet compliance are needed and one such route to compliance would be to retrofit machinery. For this measure to work nationally there needs to be a national register of retrofit suppliers and systems that gives assurance to the industry that the systems actually reduce emissions and are fitted in a safe and reliable manner. EST has been running such a programme in support of local London policy and could be easily do so a national basis. Another aspect within the area of NRMM is that there is no existing machinery database that lists the emission level of individual machines as there is with on road vehicles, so enforcement for local authorities is very difficult. Again in support of the London policy a register of NRMM has been set up linking machines with developments sites to aid enforcement, this approach needs to be made national to help local authorities implement similar policy and due to the fact that NRMM can be moved around the country. The aim of any LEZ policy should be to encourage the cleanest vehicles or machinery to operate in the areas where air pollution causes the biggest health issues Government departmental support for an industry led construction partnership that helps disseminate the latest best practice, information, case studies, product and service certification or endorsement and industry networking would help raise the profile of the issue and lead to appropriate action being taken. Approximately 7% of London s NO 2 emissions are attributable to domestic gas use, to help reduce this EST can run awareness campaigns for consumers to insulate their homes so that gas fired domestic boilers operate for less time resulting in lower emissions. This will help people understand that making their home more energy efficient for heating will not only lead to energy cost savings and CO 2 emission reductions but also local air quality improvements.