Policy Paper Accommodating freight in Clean Air Zones Road Haulage Association 8 August 2017 V 2
Accommodating freight in Clean Air Zones 1. The RHA is urging caution in applying widespread Clean Air Zones to Heavy Goods Vehicles (HGVs) in the UK. The RHA s concern is based on the very limited impact some area-wide measures will have on improving health and local air quality, and the high cost that will be incurred as a result of poorly thought through measures. 2. Air quality is already improving. However, the RHA recognises that there is a need to deal with local air quality issues that impact on people s health. 3. If poorly executed, Clean Air Zones will add significant costs to local businesses and consumers, will put some businesses in financial peril and may not materially improve health or local air quality. 4. Clean Air Zones will differ in geographical extent, the nature of hot spots and sources of pollution so must focus carefully on local conditions to be effective. According to TfL, in London in 2013 HGVs were the source of 10% of NOx emissions. Buses and coaches accounted for 13%, Diesel cars 14%, Aviation 8% - Domestic and Commercial gas accounted for 19% of NOx emissions 1. 5. It is important that authorities implementing Clean Air Zones understand the impacts that will occur on freight movements made by HGVs in proposed zones. The annex to this paper provides information on HGV emission performance, how quickly Euro VI HGVs are taking over and transforming the NOx performance of the haulage industry, and how far NOx emission will be reduced in coming years. HGV emissions are improving 6. Euro VI has been the emission standard for HGVs since the beginning of 2014. The life of the most intensively used HGVs is about 10 years. For specialist vehicles the life span of the lorry can be much longer. 7. Euro VI emission standards for HGVs and buses should not be confused with the Euro 6 standards used in car and van emission testing. Euro VI engines fitted to HGVs (and buses) have been tested and shown to perform to standard in real-world operation in contrast to Euro 6 diesel engines fitted to cars and vans. Transport for London describes Euro VI HGVs and buses as ultra-low emission vehicles. 8. Between the introduction of Euro VI in 2014 and the end of 2016, the RHA estimates that the NOx emissions across Great Britain from HGVs reduced by about a third. This improvement will continue over coming years. By 2019, at current replacement rates, we estimate that two-thirds of road haulage will be undertaken by Euro VI vehicles. 1 Pg 77, Proposed changes to the ULEZ, April 2017 Page 1
9. Considering the effectiveness of Euro VI vehicles, the limited benefits of non-targeted early scrapping of older HGVs, and the opportunity that exists with various measures, the RHA makes the following recommendations to authorities considering local Clean Air Zones. Dealing with HGVs in Clean Air Zones RHA recommendations 10. The RHA believes Clean Air Zone proposals need to focus on areas of greatest public health risk. As has been demonstrated in London and elsewhere, these are often clearly defined areas where buses and taxis are subjected to high levels of congestion. 11. The RHA suggests that direct Local Authority action:- a. Should focus on vehicles creating the most pollution in pollution hot spots, in particular the worst performing buses and taxis (an example of a positive approach is the London low emission bus zones focusing Euro VI buses on pollution hot spots in London 2 ). b. Should reduce congestion in key areas of high pollution through better traffic management, smarter vehicle routing and improved roadworks management. c. Should encourage use of the road network outside peak periods. 12. Many new Clean Air Zones are considering limiting the type of large vehicle (by Euro standard) entering the Clean Air Zone to encourage the use of Euro VI HGVs and buses. The RHA recognises this as a reasonable approach, but we also understand that the costs on businesses and consumers will be grossly excessive if done across wide areas. 13. Having assessed this approach the RHA believes it is vital that a notice period of at least 18 months is given for any restrictions. Any restrictions in Clean Air Zones must be phased so vehicles less than 10 years old are not restricted. Vehicles with highest emissions are restricted first, an example phasing would be; a. To the end of 2019, only restrict Euro III or earlier HGVs and Buses, b. From the end of 2021, only restrict Euro IV or earlier HGVs and Buses, c. From 2023 restrict to Euro VI HGVs and Buses in hot spot areas. 14. We suggest that Local Clean Air Zone schemes consider exemptions for certain specialist vehicle activities. Examples could include gritting, snow ploughing, emergency vehicles and recovery vehicles these are limited activities where vehicle replacement costs are very high and the air quality impact is negligible. 2 https://tfl.gov.uk/modes/buses/improving-buses Page 2
15. Local Clean Air Zones also need to consider other emission sources. Focusing heavily on goods vehicles without addressing other transport and non-transport sources of pollution will result in no meaningful improvement to air quality where it is needed. Page 3
Annex - Accommodating freight in Clean Air Zones Information on the GB Lorry Fleet and Emission Standards 1. The below table shows the Euro standards for HGVs and buses by year with a summary of NOx standards. NOX standard* Euro VI 2014 on 0.4 Euro V 2009 to 2013 2.0 Euro IV 2006 to 2008 3.5 Euro III 2001 to 2005 5.0 Euro II 1997 to 2000 7.0 Euro I 1996 + older 8.0 *Nox emissions based on Maximim permitted for vehicle type This is a summary of the NOx standards only. 2. It is important to understand how the vehicle fleet has changed and will continue to change. The RHA assessment of the changes in the lorry fleet, by emission standard over time given stable rates of change is shown below. Dec 2013 Fleet Dec 2015 Fleet Dec 2016 Fleet * Dec 2019 Fleet** Dec 2020 Fleet** Dec 2025 Fleet** Euro VI 0 85,217 136,517 273,017 309,417 464,117 Euro V 180,000 171,832 162,732 135,432 126,332 35,332 Euro IV 108,600 94,685 85,185 56,685 47,185 23,435 Euro III 104,100 82,303 70,703 35,903 24,303 9,803 Euro II 34,800 26,360 22,160 9,560 5,360 2,357 Pre Euro II 30,800 24,078 20,878 11,278 8,078 3,021 * RHA estimate based on 11 months data ** RHA estimate with no new Clean Air Zones. 3. As can be seen in the above data, the fleet of modern Euro V vehicles remains substantial until after well after 2020. Undertaking limitation on the movement of Euro IV and V in the near term will be highly disruptive for operators. 4. However, it is worth noting that newer lorries are used more intensively, older vehicles less so. Given this, the below table shows the reduction in NOx from HGVs in GB for selected years between 2013 and 2025 (based on current expected replacement rates). Page 4
2013 = 100, RHA Emission Assessment May 2017 5. Across Great Britain the reduction in NOx emissions from lorries have reduced by about a third since 2013. This decline will continue over time as older lorries are retired and are replaced by Euro VI vehicles. 8 August 2017 Author: Duncan Buchanan, Policy Director Email: d.buchanan@rha.uk.net Page 5