Apologies for another longer than normal post. This arises from recent publications (not intended as 'consultations') from the Department for Transport to which the following comments have been sent.The main questions to the DfT is why there has been no Strategic Environmental Assessment on the alternative measures being proposed? and an explanation of the absence of any reference to or consideration of the impact on carbon emissions of reducing the national speed limit? The Government does not seem to recognise a role for regulation in supporting desirable change and proscribing the least desirable changes that could be expected to arise from automation and electrification. Ideology is again getting in the way of systems analysis.
Transport Energy Model
Moving Britain Ahead July 2018
(comments in italics)
1.8 For each vehicle, results are given for a specific representative duty cycle. For example, a mixed urban / extra-urban duty cycle (average speed 34 km/h) is used for cars and vans whereas a long haul duty cycle (average speed 79 km/h) is used for a 44 tonne HGV. The duty cycles used for each vehicle type are specified in the model outputs and were chosen to represent the typical use for that vehicle type. Emissions will be different when assessed at other speeds. In general, energy consumption and tailpipe emissions per kilometre are higher at lower speeds. This is limited to existing conditions and not the potential of conditions more conducive to efficient driving of both ICEs and EVs.
2.1 A medium car (similar to a Ford Focus or Vauxhall Astra) was selected for inclusion in the TEM because it is representative of a large proportion of the car fleet. In 2017 sales of cars in the ‘lower medium’ segment – which the ‘medium car’ is based upon - accounted for 29% of total car sales. The emissions from the vehicle will vary depending on the average driving speed. For the purposes of the modelling, the emissions data reflects a mixed urban and extra-urban duty cycle, which has an average speed of 34 km/h. The figures would be very different for vehicles designed for a lower maximum speed and not for nearly twice the legal limit.
The modelling included nothing for the emissions attributable to congestion that reduces the representative speeds. The 34k/hr is a blend of over fast speeds between urban areas and too slow speeds in urban areas. Both would change for the better with lower speed limits.
The Road to Zero
Next steps towards cleaner road transport and delivering our Industrial Strategy (comments in italics)
..and to put the UK at the forefront of the design and manufacturing of zero emission vehicles. Using Japan as a yardstick would improve the Strategy
Long term ambition:… or all new cars and vans to be effectively zero emission by 2040. But cars last 20 years? and deliberately allowing hybrids is not a significant improvement over existing.
We will reduce emissions from vehicles already on our roads by: 4. Taking steps to accelerate the adoption of fuel-efficient motoring by company car drivers, businesses operating fleets, and private motorists.
All this is based on individual car ownership (eg charging points for all new dwellings). The Strategy seems to have avoided engagement with the possibilities raised under ‘Future of Mobility’ regarding the possible transition from individual ownership to mobility as a service.
As set out in the NO2 plan, we will end the sale of new conventional petrol and diesel cars and vans by 2040. By then, we expect the majority of new cars and vans sold to be 100% zero emission and all new cars and vans to have significant zero emission capability. By 2050 we want almost every
car and van to be zero emission. This level of ambition puts the UK at the
forefront of the global transition to cleaner road transport. Really!?
As a result, transport is now the largest sector for UK greenhouse gas emissions (27%), of which road transport accounts for over 90%. That puts even more pressure on the Government to expedite the change to a zero carbon transport system. All the carbon emitted during the transition will affect the chances of meeting internationally agreed targets.
By setting long-term ambitions, we want to send a clear signal of the UK’s direction of travel to provide industry and consumers with certainty. There is significant uncertainty over some of the key drivers of the transition – including battery technology and new mobility services. So we will review progress towards our ambitions by 2025. The targets should be higher and earlier to make the transition easier rather than ‘over a cliff –edge’ in 2040. The space created by delaying the necessary changes is also a space for changes in undesirable directions and cumulative emissions.
The Future of Mobility
The move to zero emission road transport will not be the only shift in the way we move goods, people and services around our towns, cities and countryside over the coming decades. Significant investments are being made in the automation of road vehicles, while new business models, such as ride-hailing services, ride sharing and new mobility services are challenging our assumptions about how we travel. The way we travel and who owns vehicles in the coming years will affect the trajectory of ultra low emission vehicle uptake, the infrastructure these vehicles will need and emissions from conventional vehicles. Relevant trends include: connectivity and automation, new business models and changing travel demand –these are all trends that are also opportunities to ensure the changes could be beneficial and mutually supportive if captured by regulation.
Action to support modal shift – no mention of stimulating the modal shift ie lower speed limits that would cancel the competitive advantage of the ICE over the EV
Current UK road vehicle market – average age of car 8.1 years suggests about 2m that are 15/16 year old. Many of the existing fleet will be driveable for 20 years.
Improving Air Quality
We know that there are no safe levels of the particulate matter that petrol, diesel and other internal combustion engine vehicles emit, and that the UK still has more to do to reduce emissions of all major air pollutants to meet longer-term legal limits. The measures set out in this strategy and the transition to zero emission road transport are therefore vital parts of any long-term solution to the poor air quality in our towns and cities. The delayed action on ICEs is placing the convenience of the motorist above the lives and health of its citizens including the poisoning of the brains and lungs of the very young.
Today, transport is the largest greenhouse gas-emitting sector in the UK, accounting for 27% of greenhouse gas emissions. Road transport accounts for 91% of this. Average laboratory-test based CO2emissions from new cars have fallen by over one third since 1997.However, in the real world, total greenhouse gas emissions from road transport have fallen only slightly (by around 2%) since 1990. Over the last three years greenhouse gas emissions from domestic transport have started to rise. We urgently need to reverse this trend and reduce road transport emissions. Is there a graph showing how carbon emissions expected from implementation of the Strategy compare with the reductions implied by the Paris Agreement?
The Energy Saving Trust estimate that efficient driving alone could save drivers up to 5-10% of their annual fuel bill – on average around £95. Does the Government regard this as sufficient in the road to zero? These measures are the very lowest hanging fruit and do not amount to a purposeful strategy.
Cleaner quieter cities
In England alone, the annual social cost of urban road noise is estimated to be £7–£10 billion. Although the noise of vehicles travelling above 12 mph is principally due to tyres and road surface noise, at the lower speeds typically found in town and city centres engine noise is the main contributor.
The potential reduction in noise should be transformative for those living close to busy roads and city centres. A reduction of urban noise levels by 3dB can reduce annoyance effects by 30%. At average central London speeds, the reduction in vehicle noise is approximately 8dB. Why is there no mention of the fact that on inter-urban roads the noise is caused by engines (about 50%) and tyres/wind (about 50%). Both would be substantially reduced at an enforced lower speed limit.
We will also launch a call for evidence on the Future of Mobility shortly. As part of this, we would welcome views and evidence on the right role for government in helping to ensure that future transport technologies and services are developed in an inclusive manner. The ‘transport system’ is a system and the changes implied by AIs and EVs must be considered through systems analysis.
Fuel efficient motoring
Driving with good anticipation and smooth acceleration and braking saves fuel and cuts emissions. Correctly inflated tyres, avoiding carrying unnecessary weight and removing carriers and racks when not needed increases these benefits. The emphasis on greater anticipation brings safety benefits, and the resultant reduced tyre and brake wear delivers further cost savings and reduced pollution… gave an average 15% saving of fuel and CO2. For electric vehicles range increased by 20%.
But nothing on the measure with the greatest potential; lower national speed limits, or the obvious conclusion that speed limits would remove the competitive advantage of the ICE over the EV. And that the 20% increase in range would stimulate the take up of EVs and benefit both the roll out of the charging infrastructure and scale of power generation.
Driving uptake of the cleanest cars and vans
Regulation : regulation is one of the most important levers to ensure manufacturers deliver cleaner and more fuel-efficient vehicles to the market and help provide a stable environment for industry investment. As we leave the EU, we will pursue a future approach to vehicle emissions regulation that is at least as ambitious as current arrangements. But lacks the ‘ambition’ that would be reflected in reducing the national speed limit that would incidentally reduce congestion in and between urban areas.
Cleaner diesel cars and vans can play an important part in reducing CO2
emissions from road transport during the transition to zero emission vehicles whilst meeting ever more stringent air quality standards. There is no evidence for that statement. The Strategy is discredited by pretending that the political expediency of protecting diesels (and other ICEs) will maintain and not reduce carbon emissions. Diesels bought today will be emitting and accumulating carbon during a twenty year period that should see emissions very quickly reach zero.
Reducing C02 emissions
Relying on incremental improvements in internal combustion engine efficiency, reducing the gap between real world emissions and lab tests, and extending standards to heavier vehicles is not enough to meet our long-term ambitions. As that is clearly correct it follows that there should be some transformative changes being proposed in the Strategy.
Government leading the way
We want central government to lead the way on ultra low emission vehicles. But this actually means A requirement within these standards is to electrify 25% of the central government car fleet, meaning that one in every four cars will be ultra low emission by 2022. ‘Leading the way’ would be more effective through regulation (ie the real purpose of government) rather than by example. The speed of transition is crucial (ie limiting injury and death from ICEs) and securing the efficient use of resources (eg lithium, cobalt, nickel).
Part 3a: Developing one of the best electric vehicle infrastructure networks in the world is a pointless and very irritating boast as all the charging takes place locally and not globally. Inviting international comparisons might not be a good idea when Norway, Japan and the Netherlands are ahead in most respects.
- ensure the houses we are building over the coming years are EV ready. It is our intention that all new homes should have a chargepoint available. We plan to consult as soon as possible on introducing a requirement for chargepoint infrastructure for new dwellings in England where appropriate and will look at how to achieve this in the most cost effective way, mindful of the Government’s Housing supply objectives. Hopefully this includes shared chargepoints (for shared vehicles). Requiring Individual chargepoints would be counter to the Future of Mobility debate about the potential of personal ownership and use morphing into a shared service. These are development/transition paths in which the Government should be fully engaged. And no equivalent planning powers are being suggested for workplaces but only a possibility under Building Regulations?
If range is extended by 30% by reducing the speed limit from an un-enforced 70mph to an enforced 50mph, so would be the need for and use of recharging points and electricity generation. And the level of EV ownership and use would not be constrained by the apparent lack of charging points.
CAZs aim to address all sources of air pollution, including NOX and PM, and reduce public exposure to them using a range of specially tailored local measures. These measures can include charges for vehicles which do not meet defined minimum emission standards. Should the Government be supporting a system that allows drivers to pay for the privilege of killing and maiming its citizens – including its very young.
There does not appear to be any reference to the VIBAT study, UKERC Quick Hits or Why slower is better by CE Delft? Or recommendations of the Committee on Climate Change, or to Environment Audit Committee ‘Reducing Carbon Emissions from Transport 2005/6’ which has become more rather than less relevant over the last twelve years. (or, for US readers, Sustainable Transportation by William R Black 2010.)