Intelligent Phasing for freight in Clean Air Zones

Transcription

1 Policy Paper Intelligent Phasing for freight in Clean Air Zones Road Haulage Association Revised 10 July 2018 V 3.

2 Intelligent Phasing for freight in Clean Air Zones 1. The RHA is asking Local Authorities who are considering applying Clean Air Zones to only apply them to Heavy Goods Vehicles on a phased basis. 2. The RHA s call is based on the massive impact the Euro VI only approach will have on businesses (mostly SME s) and the very limited impact, if any at all, applying Clean Air Zones to lorries will have on improving local air quality. 3. Feedback from operators indicates that for many, current plans will have a devastating impact on their businesses. Some operators have told the RHA that they expect to be put out of business if current proposals are implemented. 4. The RHA recognises that there is a need to deal with local air quality issues. But authorities need to take account of the small amount that lorries contribute to the air quality problems in most places where problems occur. 5. The Euro VI only approach for lorries in Clean Air Zones promoted by the Government has failed to recognise several fundamental points. There are insufficient Euro VI lorries to meet the demand for movement of goods in Clean Air Zones, nearly 50% of the lorry fleet will be pre Euro VI at the end of 2019;- There is no retrofit option that operators can buy to upgrade older lorries;- Individual lorries usually spend limited time, and travel limited distances in Clean Air Zones;- The policy undermines confidence to invest in new vehicles (as it artificially shortens the economic lifespan of lorries for non-specialist lorries is about 12 years);- The level of charges proposed are excessive far more than needed to encourage the use of cleaner vehicles; and, Charging Euro V and Euro II lorries the same misses the chance to improve air quality quickly and will encourage the use of many more smaller vans adding to congestion and local air quality problems. 6. The RHA has assessed 16 major European Cities to see how lorries are handled regarding Clean Air Zone restrictions. Except for two roads in Hamburg, no European City assessed limits lorry use to Euro VI only before (see paragraph 19 for more information). 7. Having considered the these factors, the RHA had developed an alternative Intelligent Phasing approach that will support air quality objectives in greater harmony with haulage operators. (To be clear, the RHA does think Clean Air Zones for lorries is unnecessary at all). Page 1

3 RHA Proposal 8. There is no retrofit option available for lorries. None have been tested or approved for use. Therefore, in early 2020, about 48% of the lorry fleet will still be pre Euro VI. 9. The use of non-euro VI vehicles in Clean Air Zones cannot be avoided. They must be used to meet demand for freight services, it makes sense that the use of the cleanest of these non- Euro VI lorries is encouraged. 10. Given this, the RHA proposal is that radically lower Clean Air Zone charges should be applied to the newer Euro V and Euro IV lorries initially, and charges should be phased only as the proportion of Euro VI vehicles in the lorry fleet increases between 2020 and Table 1 gives an example of an approach that could be taken by a local authority. Table 1. RHA Example Intelligent Phasing of Charges Euro V Euro IV Euro III & Earlier This approach will make it much cheaper and quicker for operators working in Clean Air Zone areas to remove higher emitting older lorries, such as Euro II, to much cleaner Euro V lorries. 12. We believe this approach is in line with the requirement to clean our air quickly as it encourages the use of ever cleaner vehicles over time. The current Euro VI approach does not do this because it does not distinguish between a Euro II and a much cleaner Euro V. 13. There is no evidence that charges as high as 100 are needed to promote change in the way the lorry fleet is used the market is highly competitive with very low margins; even modest charges will impact operator behaviour and choices. 14. The RHA also proposes that no lorry should be charged twice in a day to enter Clean Air Zones. We have a situation where it is common for lorries to enter multiple cities in a day. Charging the same lorry 2 or 3 times in a day when the lorry spends limited time in each zone is unfair, so only one charge per day should apply. Page 2

4 Supporting Information 15. More detailed information on how the lorry fleet is evolving and how emissions are changing over time can be found on the link here Table 2 shows the European emission standards that apply to lorries. Euro VI lorries are clearly the best. However, the table also highlights the improvements achieved over time through the various emission standards showing the substantial improvements achieved by Euro V (and Euro IV) over earlier iterations. Table 2. Summary of HGV NOX Euro Standards NOX standard* Euro VI 2014 on 0.4 Euro V 2009 to Euro IV 2006 to Euro III 2001 to Euro II 1997 to Euro I older 8.0 *Nox emissions based on Maximim permitted for vehicle type This is a summary of the NOx standards only. 17. In the early years of new Clean Air Zones there will not be sufficient Euro VI lorries to meet the demand for freight services. Use of non-euro VI lorries will be substantial and inevitable. Table 3 below shows the fleet make up between 2013 and Table 3. Market Share Lorries by Euro class over time 2 Year End * 2021* 2023* 2025* Euro VI 0 18% 36% 52% 64% 74% 82% Euro V 39% 36% 29% 25% 19% 14% 10% Euro IV 24% 19% 14% 10% 7% 4% 3% Pre Euro IV 38% 27% 20% 13% 10% 7% 4% Data to 2017 extracted from DfT Statistics - VEH0511, published April 2018 * RHA Data generated from long-term fleet profile information derived from VEH April At the end of % of lorries will fall in scope of Clean Air Zone charging if a Euro VI only approach is adopted. As non-euro VI lorries will have to be used in substantial numbers the Clean Air Zone charges will in effect be a tax on many freight movements, a tax that will impact most severely on smaller and medium sized businesses. 1 Full web address for RHA Emission Assessment published in July 2018: 2 Based on Department for Transport table veh figures extrapolated forward to 2025 details in RHA Emission Assessment. Page 3

5 19. The RHA reviewed how lorries are treated across 16 major European Cities 3. We reviewed any Clean Air Zone restrictions where they apply now and going forward. Many of the wellestablished Clean Air Zones have progressively tightened the standards over time. Table 4. Summary of approaches taken to Clean Air Zones across Europe This summary only deals with how lorries are treated. In most cases other non-public transport diesel fuelled vehicles are treated in the same way as lorries in the Clean Air Zones. (This contrasts with the approach taken by many English local authorities who have targeted only large vehicles and taxis for Clean Air Zone charges. 4 cities have no Clean Air Zones. 1 City has Clean Air restrictions that apply to two individual roads rather than a zone (about 2 miles). This new restriction in Hamburg requires all diesel vehicles to be Euro VI. 2 have Emergency only Clean Air Zones- based on Euro IV as the minimum standard. 1 City has a permanent Clean Air Zone based on Euro IV, but limits to Euro V in an emergency. Later this year Euro V will be the full time standard. 8 cities have permanent zones based around Euro III or Euro IV. One of these, Antwerp, will move to Euro VI in July Berlin, Frankfurt, Hamburg, Amsterdam, Rotterdam, Brussels, Antwerp, Paris, Marseilles, Rome, Milan, Madrid, Barcelona, Vienna, Copenhagen, Warsaw. Page 4