Written evidence from Calor Gas Ltd (AQU 08)

 

Introduction

  1. Calor welcomes this opportunity to provide written evidence to the EFRA Committee on its inquiry into air quality. Our response focuses on the contribution of air quality pollutants from transport and the role LPG autogas could have to reducing these emissions.

LPG and air quality

  1. Calor is a joint venture partner with Shell in Autogas Ltd, the UK’s leading provider of automotive LPG.

 

  1. LPG is cleaner than traditional transport fuels (CO2, NOx & PM). Calor has quantified the impact on UK air emissions from substituting 40,000 LPG passenger cars for diesel cars between 2016 and 2029. The study shows that it is possible to achieve a 90% reduction in NOx and PM by such a displacement.

 

  1. Importantly, this is a solution that can be deployed quickly and cheaply. The supply infrastructure for LPG is already in place at more than 1400 outlets and can be expanded without the use of public money.

 

  1. Furthermore, our renewable fuel, biopropane, which Calor will start importing to the UK in 2016, can be deployed via existing infrastructure and offers a carbon saving of 90% to petrol and diesel.

 

  1. An independent report carried out by Element Energy (consultants used by the DfT) has found that in a high-uptake LPG scenario (i.e. LPG sales reaching 29,000 vehicles by 2020):

i)        Up to 219,000 tonnes of CO2 could be displaced annually

ii)       An annual reduction of 2.258 tonnes of NOx could be achieved

iii)     Over 256 tonnes of PM10 could be displaced per year by 2029

Defra’s role

  1. We are encouraged by DEFRA’s consultation on air quality and the level of engagement between departments such as Transport, Energy and Climate Change, HM Treasury and the Cabinet Office on its approach to this important issue in relation to transport emissions.

 

  1. DEFRA’s consultation places a significant emphasis on local authorities and the role of local air quality plans to meeting the national objective. We are pleased with their approach which does not champion one technology at the expense of others, however, It is vital that local authorities develop consistent approaches as prescribed by DEFRA so that:
  1. Each Clean Air Zone (CAZ) has the same Euro level limits (we support Euro 4 for petrol and LPG, and Euro 6 for diesel)
  2. Consumers (ordinary drivers, taxi drivers, self-employed, and small business) need to be assured that the same stipulations for entry exists in all CAZs.

 

 

Biomass for heating

  1. However, one area of concern which seems to have gone under the radar is the damage to local air quality being caused by the increased use of biomass for heating. The particulates it emits damage human health by attacking lungs, hearts and brains. Studies have calculated the percentage of total mortality attributable to particulates in England at over 5.0%. We have worked out the damage in terms of lives shortened and lost from an Impact Assessment published by DECC on standards designed to cut down on the current level of mortality from biomass combustion for heating systems. The quantum of mortality caused by biomass boilers currently being sold can be calculated from the assessment at £4,343m. The new limits cut this reduction in life years lost to an equivalent of £1,399m. However, the new limits apply only to the larger particulates, and evidence is growing that the smaller particulates are more harmful than the large. No sum of the mortality caused by smaller particulates from biomass has been given. One must assume nonetheless that the impact from these smaller particulates in reducing human life-spans will be considerable.

 

  1. The problem is that as biomass boilers age they pollute more. The last Labour Government’s Renewable Strategy read as follows in 2008: “Given that equipment deteriorates over time and needs to be operated properly, we may need to update regulations to ensure that installed equipment continues to be run in a way that meets emissions standards. A type of approval scheme may therefore need to be implemented by arrangements to ensure that emission standards are maintained. In other countries, including Austria, Germany, Denmark and the United States, concerns over air quality deterioration caused by older style biomass boilers has led to the introduction of an MOT-type scheme, whereby the owners are required to have their boilers serviced on a regular (for example, annual) basis.”

 

  1. No MOT-type scheme has been introduced so the envisaged deterioration in equipment and emissions is inevitable. This is an area DEFRA should address in conjunction with DECC.

Transport emissions

  1. In order to move away from diesel and petrol vehicles quickly a transitional option needs to be developed. At the moment, there are significant incentives on offer to move toward electric vehicles, but the initial capital cost is high and the charging infrastructure is far from ubiquitous, which is required before a significant number of vehicles can be deployed. Until this happens electric vehicles will have a limited early impact on air quality levels. Greater use of autogas and the future use of biopropane offer this transitional route, giving drivers an affordable option to drive more environmentally friendly vehicles, comply with proposed CAZs and keep their costs down.

 

Below, we have outlined some recommendations across different vehicle types:

 

Taxi fleets

  1. We are encouraged by early recognition in the draft plan of the potential LPG represents to taxi fleets for tackling local air pollution (section 4.3.4. point 128). Taxis are a major source of urban air pollution.

 

  1. Autogas Ltd converted a TX4 diesel taxi to run on LPG to demonstrate the emissions saving potential of LPG. The converted taxi delivers a reduction in NOx of 80%, PM of 99% and CO2 of 7% meeting Euro 6 standards under real world testing.

 

  1. A large part of the UK’s existing diesel taxi fleet can be cost-effectively and quickly converted to LPG via an £8,000 conversion - a fraction of the cost of buying a new electric ULEZ model (c£45,000) as proposed by Transport for London’s plans. Furthermore, the taxi driver will achieve 20% reduction in fuel costs compared with a diesel taxi, giving a payback of less than 2 years.

 

  1. LPG is also future proof. Toyota has a right-hand drive zero emission capable (zec) Electric/LPG hybrid, the JPN Taxi, which will be sold to Tokyo’s taxi drivers from 2018 for only ¥3m (c£16,000). At present, 90% of Tokyo’s taxis run on LPG. In addition, biopropane will be available in the UK, at scale, from next year.

 

  1. Recommendation: The DfT £0.5m grant to Birmingham City Council will facilitate the conversion of 80 black cabs to LPG. However, in order to fully exploit the potential of LPG taxi fleets, LPG taxis need to be deployed on a much larger scale:
  1. Government could send a clear signal to vehicle suppliers and operators by removing the fuel duty escalator on LPG at the Autumn Statement.
  2. Whilst the cost of a taxi conversion from diesel to LPG is only £8,000, many drivers may not be able to afford this, so a modest incentive to convert to LPG could be considered to encourage uptake.
  3. Government should encourage vehicle manufacturers to offer LPG models (taxis and vans) to the UK market. Sufficient scale could be achieved via public sector and local authority procurement, which the Government could facilitate. NB OEMs indicate that orders for right hand drive LPG models could be made available in the UK with as few orders as 200 vehicles.

 

LPG HGVs and Vans

  1. Every large van in the UK runs on diesel, contributing substantially to harmful transport emissions. However, there is a current lack of practical and cost effective non-diesel solutions.

 

  1. Calor has proven the viability of diesel/LPG hybrid heavy good vehicles with real world testing at Millbrook. This was done using a converted Euro 5 diesel DAF 40 tonne which showed significant reductions in levels of CO2 and NOx - in the urban scenario, the tractor cab achieved a NOx saving of 34.1% and CO2 of 2.6%. This shows that significant air quality improvements can be achieved utilising this technology with no carbon penalty. In addition carbon emissions are also reduced. We will have a Euro 6 LPG/diesel truck included in the Government’s gas truck testing programme at the end of this year.

 

  1. Recommendation: Calor can confirm that it is possible to convert a van engine in a similar way that Autogas Ltd converted the TX4 black cab i.e. LPG/new petrol engine. It is also possible to convert vans in the same way that Calor has converted the DAF tractor cab for HGVs i.e. LPG/diesel retrofit. The conversion cost for diesel/LPG would also be much lower than a complete re-engine and provides another technical option for vehicle operators. Alternatively major vehicle manufacturers could reintroduce LPG vans onto the UK market – as existed only a decade ago.

 

Public Sector and Non-Public Sector Fleets

  1. Conversion of public sector and non-public sector fleets to LPG offers an affordable way for local and national government organisations to expeditiously meet air quality targets in light of tight public sector funding and the high cost of alternative vehicles and refuelling infrastructure. In fact the increased use of LPG could significantly reduce local authority fuel bills due to the lower running costs.

 

  1. We would point to a recent BBC Scotland news story which reported the reluctance of council workers in Dumfries and Galloway to drive its small fleet of electric vehicles due to range fears. The BBC found that the 4 electric Nissan Leafs had only covered 26,000 miles between them since 2011 at a cost of over £57,000 to the taxpayer.

 

  1. Recommendation: Conversion of public sector fleets can be easily and cheaply carried out by approved UKLPG converters. Case studies indicate the savings that can be achieved:

 

  1. Isle of Anglesey Council has reduced its carbon emissions whilst making running cost savings. Since 2000, the council has 73 LPG vehicles in their fleet of 172 road vehicles. Not only are the cost savings high on their average of 12,000-15,000 miles per year on each vehicle, but NOx, PM and CO2 emissions have been reduced.
  2. Humberside Police Force began using LPG in 1997. Six years later, with 300 vehicles using it, the Force had achieved annual savings of £200,000 on their road fuel bills, allowing greater resources to be invested into front line policing.

 

Privately owned vehicles

  1. In June 2015, Calor commissioned Atlantic Consulting to quantify the air-emissions impacts of one of the Low Carbon Vehicle Partnership’s Transport Energy scenarios. As a baseline, this report assumes the LowCVP roadmap’s version of the future: 40,000 LPG cars per year would be sold in the UK from 2016-29, a total of 560,000 LPG cars. These would substitute existing cars, as the latter reach their 14-year average end of life.

 

  1. The absolute reductions by 2029 in tonnes emitted are significant not only for the target pollutants NOx and PM, but also for carbon dioxide. Reductions relative to the 2015 baseline for NOx and PM are 90% and greater. Carbon dioxide is cut by 16%. Avoided Disability Adjusted Life Years (DALYs) amount to nearly 40 per year in 2016, rising throughout the forecast period to nearly 400 per year by 2029.

 

  1. Recommendation: To encourage the uptake of LPG by consumers will require the following support mechanisms:
  1. Introduction of parking exemptions for LPG vehicles
  2. Embed consideration for alternative fuel infrastructure into local development plans;
  3. Inclusion within the DEFRA’s CAZ framework and discounts for LPG vehicles to operate in CAZs
  4. Send a strong signal to OEMs to manufacture LPG-ready vehicles for the UK market by, for example, implementing a cohesive fuels policy which provides parity for LPG i.e. through removal of the existing fuel duty escalator for LPG.
  5. Reinstate Powershift grants to OEMs to produce LPG cars in the short term.

December 2015