Response of the Road Haulage Association to Leeds City Council. Air Quality Public Consultation August August 2018

Similar documents
Response of the Road Haulage Association to Southampton City Council. Southampton Clean Air Zone Consultation

Response of the Road Haulage Association to Leeds City Council. Air Quality Public Consultation Feb 2018

Response of the Road Haulage Association to Transport for London s Consultation. Changes to the Ultra Low Emission Zone and Low Emission Zone.

Intelligent Phasing for freight in Clean Air Zones

Accommodating freight in Clean Air Zones

RHA NOx Emission Assessment 2018

Proposals for an Ultra Low Emission Zone

ULTRA LOW EMISSIONS ZONE CONSULTATION LONDON COUNCILS RESPONSE

Improving the air we breathe A Clean Air Zone for Birmingham. Birmingham City Council

L O W E M I S S I O N CITY

We note the range of possible interventions identified in the consultation paper.

London Transport Policy, Planning and Strategies

Innovation in London. Policy approaches to mobility management and sustainable travel. Transport for London

Introduction to the Ultra Low Emission Zone

GUIDE FOR VAN DRIVERS

Response of the Road Haulage Association to Transport for London. New proposals to improve Air Quality.

Newcastle/Gateshead Low Emission Zone Feasibility Study

Central London Congestion Charging Scheme. 17 March 2005 Impacts - 9 th Annual Conference. Michele Dix Director Congestion Charging Division

The Central London Congestion Charge

LoCITY Low Emission Commercial Vehicle programme

Response of the Road Haulage Association to the Scottish Government. Removal, Storage & Disposal of Vehicles Regulations.

Reducing CO 2 emissions from vehicles by encouraging lower carbon car choices and fuel efficient driving techniques (eco-driving)

Clean Air Zones: An Approach for Local Authorities

Low Emission Vehicle Policy Development in London

THE CHARGING OF THE USE OF ROAD INFRASTRUCTURE

The Low Emission Zone

London 2050 Infrastructure Plan

The London Low Emission Zone. Nick Fairholme Head of the LEZ Transport for London

London s Congestion Charge. Introduction to the Scheme and its Principal Impacts

Low Emissions Towns and Cities Programme

PROMOTING THE UPTAKE OF ELECTRIC AND OTHER LOW EMISSION VEHICLES

Department for Transport. Transport Analysis Guidance (TAG) Unit Values of Time and Operating Costs

Natasha Robinson. Head of Office for Low Emission Vehicles Office for Low Emission Vehicles. Sponsors

1. How has traffic congestion changed in London in recent years? Are there differences in the amount, time, type and/or location of congestion?

WATFORD LOCAL PLAN PART 2. Review of Car Parking Policy and Standards. Evidence Base. February 2012

CNG as a Transport Fuel - Economic Benefits 17 th November 2011

Brexit time for politics to grow up. The reality of 30 March no deal

Response ID ANON-K85H-GTWT-6

Weight Allowance Reduction for Quad-Axle Trailers. CVSE Director Decision

Vehicle Online Services

Congestion Charging in London

FREQUENTLY ASKED QUESTIONS

Risk Management of Rail Vehicle Axle Bearings

EU initiative for CO2 emissions reduction in Europe

Future Funding The sustainability of current transport revenue tools model and report November 2014

Submission on the Electricity ( Disconnections and Low Fixed Charges) Amendment Bill

Caltex Australia comments on Carbon Pollution Reduction Scheme White Paper February 2009

Operating bus or coach services abroad if there s no Brexit deal

SUMMARY OF THE IMPACT ASSESSMENT

Aging of the light vehicle fleet May 2011

Submission to Select Committee on Electric Vehicles - inquiry into the use and manufacture of electric vehicles in Australia

CONSULTATION DOCUMENT

ONE YEAR ON: THE IMPACTS OF THE LONDON CONGESTION CHARGING SCHEME ON VEHICLE EMISSIONS

RE: Comments on Proposed Mitigation Plan for the Volkswagen Environmental Mitigation Trust

Fuels Roadmap for 2020 and beyond - implications for future strategy

Commissioning Director for Environment. Appendix A - Car Club Strategy: Technical Appendix Jamie Cooke, Strategic Lead for Effective Borough Travel

Response to the Department for Transport & Department for Infrastructure, Northern Ireland Consultation Paper

TfL Managing London s Roads. Glynn Barton, Head of RSM Outcomes Delivery, Transport for London. Copyright 2016 TRL Ltd

Engaging with the taxi tradethe switch to electric vehicles

Respecting the Rules Better Road Safety Enforcement in the European Union. ACEA s Response

Commissioning Director for Environment. Officer Contact Details Lisa Wright; Summary

Bus The Case for the Bus

A comparison of the impacts of Euro 6 diesel passenger cars and zero-emission vehicles on urban air quality compliance

Modernising the Great Western railway

Steve Rubin, Managing Director, Finance and Support Services. It is requested that the Board or Harbor Commissioners approve the following actions:

The Introduction of Euro 5 and Euro 6 Emissions Regulations for Light Passenger and Commercial Vehicles

1. Mobility Scooter storage policy

Electric Vehicle Adoption in the South African Context

Reducing deaths and injuries in the home

Terms of Reference (ToR) Trade & Traceability Standing Committee (T&T SC)

Ministry of Environment and Forests. Ministry of Communication

Public Transport Proposals including: Subsidised Bus Services, Concessionary Travel and Community Transport Draft Passenger Transport Strategy 2016

Procurement notes for councils (Scotland)

Upgrading City Buses to Reduce NOx Emissions

Welcome to the Birmingham Clean Air Roadshow

Fiji Bus Industry: improving through greening

RE: Regulatory Proposal under the Condominium Act, 1998 (17-MGCS021)

Poppy Lyle Greater London Authority

Tackling Transport Emissions National information hub to support local action

Hybrid and Retrofitted SCRT bus fleets. Simon Carlisle Engineering Director First West Yorkshire

committee report General Permitted Development Order SPT response to consultation

Road safety time for Europe to shift gears

Transportation Electrification: Reducing Emissions, Driving Innovation. August 2017

Review of the SMAQMD s Construction Mitigation Program Enhanced Exhaust Control Practices February 28, 2018, DRAFT for Outreach

Gateshead Care Call. Gateshead Council, Regent Street Gateshead NE8 1HH Tel: How are we doing? April March 2013

Utility Operator Model

Emissions Legislation

Three ULTra Case Studies examples of the performance of the system in three different environments

LOGISTICS CASE STUDY

WEST YORKSHIRE BUS STRATEGY 2040

APP/P2.3 Neil Chadwick Economic Case/Value for Money Proof of Evidence Appendices

COMMISSION OF THE EUROPEAN COMMUNITIES

Urban vehicle access regulations. Brussels, 5 September, 2017 Karen Vancluysen, Polis Secretary General

! " # $ % # & " ' % ( ' ) "

City Transfer Stations: Loading Services and Fees

MEDIA RELEASE. June 16, 2008 For Immediate Release

Agreement with Enbridge for the Installation of Compressed Natural Gas Refuelling Stations at City Facilities

CIVITAS SMILE Introduction of a Low Emission Zone in Norwich. Andy Watt Head of City Development Services

MEMORANDUM. Proposed Town of Chapel Hill Green Fleets Policy

London s residential EV Charging Future

Transcription:

Response of the Road Haulage Association to Leeds City Council Air Quality Public Consultation August 2018 10 August 2018 Summary 1. Leeds City Council is asking businesses, both regionally and nationally, commuters and those living in the wider Leeds region to let them know their thoughts on the proposals for a Clean Air Zone in the city. 2. Leeds City Council believes that if it is to meet air quality standards, it may need to introduce a charging Clean Air Zone scheme. According to government frameworks, this has to happen as soon as possible, with the end of 2019 being the absolute deadline. The proposed Clean Air Zone would charge buses, HGVs, taxis and private hire vehicles that fail to meet the latest emissions standards for entering the city. The proposed standard for the heavy vehicle sector has been set at Euro VI all lorries not meeting that standard will be charged a proposed 50 per day. Background about the RHA 3. The RHA is the leading trade association representing road haulage and distribution companies, which operate HGVs as profit centres. Our 7,000 members, operating near to 250,000 HGVs, range from single-truck firms to those with thousands of vehicles. These companies provide essential services on which the people and businesses of the UK depend. 4. We proactively encourage a spirit of entrepreneurism, compliance, profitability, safety and social responsibility. We do so through a range of advice, representation and services, including training. 5. We would like to thank Leeds City Council for the consultation and the opportunity to comment on the issues raised. 6. The current second consultation online survey limits the ability to provide information that reflects our members views in full, or the impacts upon them. We have therefore replied in two ways, through the online survey and in this written response. Page 1

RHA view 7. The RHA supports clean air but has concerns over the timing of this proposal and other Clean Air Zone proposals being developed around the country; Euro VI technology is superb but there is insufficient numbers of Euro VI lorries to keep pace with the unrealistic time frames set by this consultation. Compliance with the changes will be impossible for many businesses due to the lack of Euro VI Lorries, the absence of a lorry retrofit option, and the limited opportunity for redeployment of Euro IV and V vehicles outside Leeds. Implementing a tax in this way on the sector will destroy some businesses and will make no material difference to air quality. 8. The current proposal will be a catastrophe for many, mostly smaller, road haulage businesses. We have members who have told us and Leeds Council representatives at recent public meetings that they will need to cease trading if the Clean Air Zone is introduced as currently proposed for lorries. 9. This view highlights that the proposal fails one of Leeds own critical success factors 1, that is to Minimise the economic impact with no one group overly affected more than any other by the CAZ plans. 10. We believe that Leeds City Council have underestimated the negative impacts of the proposals on the haulage sector in several key areas and had made a number of errors in its assessments. 11. A key assumption (based on JAQU guidance) regarding the switch to Euro VI compliance by road haulage operators before the start of the CAZ is not credible. The guidance used claims that in period between the decisions when it is finally taken, and the start of 2020 that 83% of the journeys that would be non-euro VI without the CAZ will shift to Euro VI with a CAZ. This is not credible. We believe this being this behavioural change guidance is out of date, based on London only introducing a CAZ and based on longer lead times for changes to be made. 12. At the beginning of 2020 just over 50% of lorries will be Euro VI (see table 1 below), around 25% will be Euro V. We do not believe that the increase in the Euro VI share of lorry journeys stated by the Leeds consultation from 66% in the do nothing to 94% in the CAZ option is achievable. The lorry fleet cannot support the 94% share claimed. 13. Another assumption used 2 is that there will be zero shift from lorries to large vans. This is simply wrong, as the large vans are excluded from daily charging there will be some operations that will shift away from lorries. As vans carry less, more vans will be used to deliver a given amount of goods adding to congestion and emissions. 14. The impact on vehicle values (increased depreciation on non-euro VI and inflated values for second hand Euro VI lorries) is totally overlooked. This is of critical 1 Page 4, Leeds City Council Outline Business Case, v2.2 dated 17 July 2018 2 Paragraph 5.3.3, page 42, Emission and Nitrogen Dioxide Concentration, Modelling Methodology Report. Page 2

importance for businesses who wish to upgrade their fleets, something that is impeding some businesses already from being able to upgrade. 15. The assessment looking at the affordability of the scheme is derisory and for SME s is totally absent 3. This is on top of a total lack of quantified financial assessment that is explainable throughout all the information provided to support the CAZ proposal. There is no credible number given for the cost to business. 16. Leeds is still promoting the myth that retrofit for lorries is available. We have solid evidence that retrofitting in our sector is not available, there is no CVRAS approval for any lorries, nor is any likely before 2020. We see the offer to consider funding for this by Leeds as lacking credibility (lack of any approvals, the impact on competition, the affordability of any scheme that could make a meaningful impact). 17. Euro VI vehicles are in very high demand and there is insufficient in the market place to meet current demand. The HGV second hand market for Euro VI HGV s is highly inflated due to the insistence of Euro VI being the only acceptable lorry allowed within all CAZ proposals without charge. This impact has been acknowledged in the Outline Business Case (page 44), but it is then dismissed and ignored as an effect because of myth of retrofit. This dismissal of the lack of Euro VI lorries is a fundamental flaw the approach being taken by Leeds City Council. 18. It is very disappointing that Leeds has disregarded phasing the introduction of the CAZ so that modern high value vehicles, many just half way through their economic life, could continue in use for longer thus minimising that significant financial penalties for many smaller businesses. 19. The RHA would like to make some important general points about air quality and the road haulage sector. 20. Over recent decades UK air quality has improved significantly thanks to concerted action at all levels. Total UK emissions of nitrogen oxides (NOx) fell by almost 70% between 1970 and 2015 and by over 19% between 2010 and 2015. Poor air quality is a serious environmental risk to public health in the UK and investing in cleaner air and doing even more to tackle air pollution are priorities for the RHA membership. 21. Road haulage is not discretionary, goods have to move for the wellbeing of people and businesses. Every home built requires tonnes of furniture, bricks, concrete and wood. All Leeds residents need feeding and resupplying and their waste dealing with on a daily basis, and this has to be done by road vehicles. 22. Our view, and feedback from members, is that many of the smaller operators cannot afford to upgrade to Euro VI. The RHA position has been that any Clean Air Zones need to be phased in a way that supports clean air objectives without major disruption to small businesses and their customers. In particular that we need to accommodate newer Euro V lorries for longer than is currently planned (either 3 Appendix 2 Affordability for business Leeds City Council Outline Business Case, v2.2 dated 17 July 2018 Page 3

exempting Euro V from charges initially or having a much lower or no charge, to the end of 2024). 23. There are 143 road haulage operators based within the proposal zone, with the majority of these having less than 5 vehicles. It is well known to us that these operators will have vehicles that are non-compliant at Euro VI and will therefore will have to pay on a daily basis irrespective of whether delivering into the city. We do not have the ANPR data to review the amount of HGV s entering the zone, however the bulk will again be small operators and thus unable to avoid any charge through redeployment of vehicles. 24. It will not be a viable option for many of these small operators to pay the charge as the cost cannot be passed on; there are slim profit margins in the Road Haulage Sector many small businesses operating HGV s will have no alternative to but to cease to trade. 25. The RHA believe that congestion around the 4 non-complaint locations is the main cause of air pollution, and imposing a charge on trucks and busses which are essential movers of people and freight is the wrong direction for the authority to take. 26. Cars and vans make significant contributions to congestion; the data provided by Leeds confirms this, it shows that 69% of transport Nox emissions come from these sources. Tackling congestion during rush hours and school start and end times will have a major impact, free school transport and even more radical a free public transport zone would mitigate car use and may have the required impact on Air Quality. 27. We do not believe a charging CAZ for lorries will have the desired impact on air quality. Uptake of Euro VI will be less than predicted and congestion is being overlooked. It can be seen from the London example that implementing a charge is not having the desired effect on air quality when congestion is not tackled. 28. We do not believe that Leeds have taken into account business impact on operators of HGV s that move through numerous cities on a daily basis and in fact could be charged three or more times a day. 29. Due to the fact that a lorry in most cases will have an economic life span of over 10 years 4 (longer for specialist vehicles), 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 in table 1. 4 Department for Transport vehicle statistics VEH0511 confirm this Page 4

Table 1. Changes in the lorry fleet, by emission standard over time 30. 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. 31. At the beginning of 2020 approximately 50% 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. Recommendations of the RHA 32. In the context of just 4 sites of modest non-compliance is 2020 5, the disproportionate and significant costs that will be imposed by the CAZ on many haulage businesses, the absence of any viable retrofit, the high daily charge and the cliff-edge nature of the Euro VI only approach we strongly oppose the proposal. 33. The RHA has recommend, if any CAZ is introduced, that an Intelligent Phasing of the charges is applied. One example would be charging older more polluting Euro III vehicles a full charge, Euro IV half of the Euro III charge and Euro V no charge until the end of 2022 then half charge until 2024. Alternatively, simply use the year of first registration as a proxy for the Euro standard and phase on that basis. (e.g. 14 year old vehicles full charge, 11-14 year old vehicles half charge, 10 year or less no charge). C.T. Snape Deputy Policy Director Date: 10 August 2018 5 Paragraph 5.2.1, page 35, Emission and Nitrogen Dioxide Concentration, Modelling Methodology Report Page 5