Building Scotland's Low Emission Zones - Environmental Industries Commission consultation response - Scottish ...

Building Scotland’s
Low Emission Zones
Environmental Industries Commission
consultation response

For more information please contact:

Sam Ibbott
Senior Policy Manager
sam.ibbott@eic-uk.co.uk
07786 321300

The Association is Registered as a company in England with the number 132142, it is limited by guarantee and has its registered office at the above address   1

About the Environmental Industries Commission (EIC)

EIC is the UK’s leading trade association representing the environmental technologies and services
sector. This includes a highly active Air Quality Working Group, and providing the secretariat for the
All Party Parliamentary Group on Air Pollution.

Our member companies have vast experience of designing and delivering diesel retrofit and pollution
abatement technologies both in the UK and internationally, and we have been heavily involved in the
development of Low Emission Zone policy at both central government and local authority levels.

In 2015 we published the report ‘A Clear Choice for the UK: technology options for tackling air
pollution’ (copy attached), and will shortly be launching a further report on air quality policy after
Brexit.

We welcome the opportunity to use this experience and expertise to ensure Scotland implements Low
Emission Zone best practice, which is consistent with a wider national framework.

Question 1: Do you support the principle of LEZs to help improve Scottish air quality?

Yes, we support the principles of LEZs. We have seen this approach drive actual vehicle replacement
or improvement, including the various phases of London low emission zones; TfL bus upgrade; and
DfT and Defra Clean Bus technology programmes. Whilst we should highlight that the technology
requirement to retrofit to the standards outlined in this consultation is somewhat more challenging
than for the existing LEZs referenced in the consultation, the proposed CVRAS accreditation scheme
will ensure risks are mitigated if implemented as part of a managed rollout.

Each Low Emission Zone should seek to reflect local priorities, within a national framework, wherever
possible and consider specific impacts made by differing vehicle segments, i.e. the impact caused by
private car owners, taxis, vans, HGVs, and public sector fleets.

Question 2: Do you agree that the primary objective of LEZs should be to support the
achievement of Scottish Air Quality Objectives?

Yes, to be effective LEZs need to be clearly focused on local air quality outcomes, specifically
reductions of NO2, NOx and PM (particularly as the limits for PM10 in Scotland go beyond the EU
ambient air quality directive requirements). There will be some win-win options, but these should not
be focused on exclusively. Any option which significantly increases CO2 should be avoided, though if
a particular technology or policy option will result in a significant improvement in local air quality
alongside a marginal rise in CO2, this may be an acceptable trade-off. The proposed implementation
of the CVRAS / CVRC process will prevent unacceptable increases in CO2 at the same time as
significantly improving air quality.

Question 3a: Do you agree with the proposed minimum mandatory Euro emission
criteria for Scottish LEZs?
Yes we do, and our member companies have demonstrated that Euro VI emission limits are
achievable through a programme of retrofitting buses and other heavy diesel engined vehicles.

Members are already achieving CVRAS certification, in addition to being actively engaged in the
development and accreditation of Coaches, HGV,s and Refuse / Utility vehicles.

It is expected that our members will have available CVRAS accredited technology ready for fleet roll
out in Scotland for buses in first quarter 2018; Coaches second quarter 2018; and HGV and more
challenging refuse and utility applications and Taxis before the end of 2018.

In principle, similar retrofit technology can be applied to other HGVs and LGVs. However, work would
need to be done to develop specific applications and establish what is achievable.

Fuel quality is also important, and in Scotland this is sufficient to enable satisfactory operation of Euro
VI level vehicles fitted with DPF and SCRt exhaust system technologies (i.e. retrofit technologies
which are based upon OEM technologies already in service operation).

Question 3b: Do you agree with the proposal to use NMF modelling in tandem with the
NLEF appraisal to identify the vehicle types for inclusion within a LEZ?
We would agree with this approach, but would add that engagement with the retrofit industry can help
to identify where retrofit solutions are readily available, providing an alternative to new vehicles for
those affected.

Question 3c: Should emission sources from construction machinery and/or large or
small van refrigerated units be included in the LEZ scope, and if so should their
inclusion be immediate or after a period of time?
We know that it is possible to retrofit construction equipment as this is already being done to meet the
requirements of the London LEZ for NRMM – and LPG provides a lower carbon, NOx and PM fuel for
outdoor machinery such as fork lift trucks over diesel alternatives.

In these cases, prevailing technology standards are currently low and more advanced technology
would still need to be adapted for many different types of equipment. A suitable accreditation process
is in place and operated by the Energy Savings Trust and various EIC members have accredited
products being rolled out in London and HS2 contracts. This should be acceptable and rolled out in
Scotland.

The main issue with retrofitting construction equipment is that it is more difficult to police and without
this enforcement becomes increasing more difficult. Local Authorities will need to be given the powers
to remove or fine contractors using non-compliant machinery.

Construction equipment is regulated to different standards to on road vehicles. Stage V (roughly the
non-road equivalent to Euro VI) is not even in place for new equipment until 2019/20. This needs to
be considered in setting standards and dates for inclusion of construction equipment although retrofit
technologies and products exist and are readily available from our members for roll out in Scotland.

On refrigerated units for trucks, all diesel-powered TRUs should be included in the LEZ scope
immediately due to the disproportionate pollution they emit. Stricter regulation will incentivise an
uptake of alternative zero emission engines that are already affordably available on the market.

Careful consideration will, however, need to be given to enforcement based on the use of ANPR
information. In terms of refrigerated units, for example, these can produce more pollutants than the
main engine, but a unit on a trailer would not be identified using ANPR.

Question 4: What are your views on adopting a national road access restriction
scheme for LEZs across different classes of vehicle?

We support this approach – it should lead to a quicker, more predictable impact on air quality and
provides more certainty for the supply chain of air pollution control technology companies.

Question 5: What are your views on the proposed LEZ hours of operation, in
particular whether local authorities should be able to decide on LEZ hours of
operation for their own LEZs?

We believe that LEZs should operate 24 hours a day, 7 days a week and be consistent across all
LEZs. Any other approach would lead to confusion amongst affected vehicle owners and difficulties in
enforcement, and the possibility that loopholes would be identified and exploited by some operators.

Question 6: What are your views on the Automatic Number Plate Recognition
enforcement of LEZs?

ANPR can be used but it is also important to be confident that vehicles are performing to the expected
emissions levels day to day. Retrofit exhaust systems for example may need maintenance to ensure
they are working effectively. Spot roadside checks should be used to supplement ANPR.

Although in the main retrofit technologies are well controlled via the CVRAS / CVRC process and the
UK already has a reasonably robust set of safeguards and processes enforced by DVSA (ie MOT
process etc), which will ensure conformance to standards.

ANPR would provide the most effective basis for monitoring and enforcement in terms of identifying
vehicles that are compliant via CVRAS approved retrofit. A UK wide national database would be an
efficient way to achieve this and would place less burden on affected vehicles owners.

However, ANPR implementation should not necessarily be a precursor to LEZ implementation. For
example, in the case that budgetary and lead time constraints meant fleet clean would be delayed
significantly, bus fleets could still be upgraded and enforcement monitored through Local Authority
Contracts.

A further issue would be the testing of fuel in vehicles for contamination. One option would be for
vehicle tests to include having the fuel in the tank being tested for quality or mis-fuel. This is now
relatively simple procedure, with UKAS tested tool box analysing kits being one method.

Question 7a: What exemptions should be applied to allow LEZs to operate more
robustly?

From experience of other schemes, exemption based on anything other than ‘hard evidence’
introduces confusion and can be open to abuse.

One option worth keeping in mind however is the London approach of allowing local authorities to
grant an extension of life to taxis through licensing if they are converted to run on LPG. Transport for
London currently provides a 5 year extension for LPG converted taxis which is an affordable option for
many taxi drivers as the pay back is less than two years due to difference in price of LPG to diesel.
Scottish local authorities might consider similar exemptions that would support retrofit as an
affordable solution for many taxi drivers.

Question 7b: Should the exemption be consistent across all Scottish authorities?
If there are any then yes but also all of the UK.

Question 8: What are your views on the LEZ lead-in times and sunset periods for
vehicle types shown in Table 2?

As the implementation deadlines are very close, we believe some form of ‘sunset period’ may be
appropriate. It is significant that many other schemes are being implemented on a similar timescale:

    •   London ULEZ April 2019
    •   Clean Air Zones (England) 2020/2021

This brings advantages in driving the development of retrofit solutions, but it must also be recognised
that the retrofit industry is relatively small and capacity will be limited when meeting all demands in
parallel.

However, it is apparent that Scotland may have an opportunity to at least implement a lead in of
retrofit technology to bus and municipal fleets to enable operators to gain fleet trial experience of
retrofit, and provide opportunities to enable municipal fleets to become ‘exemplars’ to private sector
fleets. This could commence first half 2018 as the retrofit sector has available technologies that meet
CVRAS that will be available to roll out in Scotland, and EIC members will have capacity through
2018 on the run up to English implementation deadlines.

Clear statements on sunset periods will also help the retrofit industry to plan capacity to support
implementation. It is very important for the Scottish Government to evaluate the level of market
demand to upgrade fleets to meet prospective LEZ plans so that forecasting and capacity planning
can take place in a timely manner. This has not been done in England, and Scotland could lead by
taking this approach.

Question 9: What are your views about retrofitting technology and an Engine
Retrofitting Centre to upgrade commercial vehicles to cleaner engines, in order to
meet the minimum mandatory Euro emission criteria for Scottish LEZs?

EIC cost-benefit research on different technology options for dealing with NOx and PM10 emissions
shows retrofit scoring highly. As shown in EIC’s 2015 report ‘A Clear Choice for the UK: technology
options for tackling air pollution’:

In addition to providing cleaner air for citizens, this approach can also create skilled jobs within the
Scottish economy. Current UK employment in the diesel engine pollution control retrofit industry
(including design, manufacturing, fitting and servicing) is approximately 500 people. Employment in
the sector has been growing in recent years due to bus retrofit schemes and the London Low
Emission Zone.

EIC, in conjunction with environmental consultants Temple Group, undertook research which shows
that:

We would be very happy to discuss this report and its findings with you in more detail.

Question 10: How can the Scottish Government best target any funding to support
LEZ implementation?

The highest value vehicles which cannot be excluded form city centres, such as buses, public
transport fleets and refuse collection vehicles, should be a priority target for such funding.

Further targeted funding to tackle specific issues warrants consideration. For example, through the
Department for Transport funded project in Birmingham, 63 black cabs have been repowered to run
on LPG and it has proven to be a huge success, not only helping to reduce emissions in the city – a
TX4 taxi repowered to run on LPG emits up to 99% fewer particulates, 80% less NOx and 7% less
CO2, exceeding Euro VI passenger vehicle emission standards under NEDC test cycles – but also
allowing taxi drivers to save around £200 a month on their fuel bills and experience an improved
vehicle operation.

If the Government is serious about improving air quality and reducing harmful emissions from
transport, meaningful policy measures are required in order to jump start the market and get drivers to

switch. This does not require subsidy and the industry can respond to increased demand instantly in
terms of expanding the already widespread infrastructure.

Experience in the rest of the UK has also shown that early partial grant assistance for private sector
fleet can ‘pump prime’ acceptance of retrofitting fleets by providing an ‘early adopter’ advantage, as
long as this can be justified from a state aid funding perspective.

Question 11: What criteria should the Scottish Government use to measure and
assess LEZ effectiveness?

Changes in actual air pollutant concentrations, monitored in real time within the LEZ, at roadside
locations, would seem to be the most appropriate criteria. Baseline data at the same location should
be established ideally one full year before the implementation of the scheme in order to avoid
seasonal bias.

This can lead difficulties as air pollution can vary day to day or even by the hour, so it would need to
be trended over probably a six month period by air quality sensors.

Investment justification and emissions reduction can also be objectively evaluated for a given fleet
profile by carrying out a ‘before and after’ Health Damage Cost Benefit analysis based on COPERT
emissions factors.

Question 12: What information should the Scottish Government provide to vehicle
owners before a LEZ is put in place, during a lead-in time and once LEZ enforcement
starts?

Communication is vital – there should be a lead in period where the Government explains the reasons
for the LEZs and how vehicle owners can reduce their vehicle’s emissions. Statistics should also be
provided on deaths caused by air pollution in Scotland, and the costs to Scottish Government.

Many drivers may struggle to understand what EURO classification their car may have, and there is a
role for the Government to ensure that vehicle owners, perhaps by utilising DVLA data, are aware of
their vehicle classification ahead of the LEZ roll-out.

More importantly the Government should find ways of implementing early adoption for proactive fleets
by enabling experience of operating retrofitted vehicles to be shared. This is very important for
municipal fleet operators and public service bus fleets i.e. influenced by regional government
influence such as SPT (Glasgow) and Edinburgh’s Lothian Bus (Council owned).

Question 13: What action should local or central government consider in tandem with
LEZs to address air pollution?

The role of low emission fuels (both as part of LEZs and as a separate issue); building emissions; and
modal shift are important – including the promotion of ‘active travel’ alternatives (cycling and walking)
for shorter journeys, and funding for the necessary infrastructure to support these alternatives.

Further, the benefits of alternative clean fuels/energy such as electric, hydrogen, and LPG. There may
also be a need to offer a scrappage scheme for the worst polluters which could be monitored by MOT,
or grants to allow vehicle owners to upgrade/improve their vehicle.

Question 14: How can LEZs help to tackle climate change, by reducing CO2
emissions in tandem with air pollution emissions?

Any reductions in exhaust emissions will help over time but the big issue is traffic movement – roads
need improving to keep traffic flowing and freight should be using rail and water more. Further,
alternative gaseous fuels such as LPG have a lower CO2 factor than diesel.

Question 15: What measures (including LEZs) would make a difference in addressing
both road congestion and air pollution emissions at the same time?

Primarily, the discouraging the use of single-occupancy private vehicles in densely populated urban
areas by providing, prioritising, and promoting safe and convenient active travel alternatives.

Question 16: Do you have any other comments that you would like to add on the
Scottish Government’s proposals for LEZs?
No comment.