Consultation Response:
Creating a new Ultra Low Emission Discount
The Anaerobic Digestion and Biogas Association (“ADBA”) is the trade association that represents the range of
interests and matters related to the anaerobic digestion of organic materials (“AD”) across the UK, including the
collection of waste for use as feedstock. ADBA understands the complex range of skills required by developers
of new AD plants, from feedstock management through technology to energy production, markets and resource
to land.
The organisation has 300 members from across the AD industry, including farmers, local authorities, waste
management companies, supermarkets, food processors, plant operators, energy and water companies,
equipment manufacturers and suppliers, consultants, financiers and supporting service companies. Biogas from
anaerobic digestion can make a significant contribution to renewable energy, climate change, and critical
resource preservation targets, subject to the right policies being in place.
ADBA is grateful for the chance to input into amendments to the London Congestion Charge, and particularly
with regard to the Ultra Low Emission Discount (ULED) where we believe biomethane vehicles should be
included as an eligible vehicle category, based on the very low lifecycle emissions such vehicles emit, as well as
the significant air quality benefits.
Biomethane as a transport fuel
Biogas is a renewable gas produced through the anaerobic digestion (AD) process. AD is the natural breakdown
of organic material such as municipal solid waste, farm wastes, purpose grown crops and sewage sludge in the
absence of oxygen. Biogas (approximately 60% methane and 40% carbon dioxide) can be used for electricity
and heat, or it can be upgraded to biomethane by removing the CO2 and other impurities and injected into the
gas grid or used as a transport fuel. Biomethane is close to pure methane, so can be used in gas combustion
engines designed for natural gas without need for further modification.
With the lowest well-to-wheel GHG emissions of any transport fuel as well as being a cost-effective alternative to
petrol and diesel, biomethane vehicles are used across the world. There are now approximately 13 million
natural gas vehicles operating across the world (growing 20% each year), but only around 500 in the UK, far
lower than many other European countries including Italy, Germany and Sweden. Natural gas vehicles can be
converted to run on biomethane, leading to important CO2 and air quality benefits, particularly in urban
environments where air pollution from HGVs, buses and light vans is difficult to take.
Environmental and economic benefits
Biomethane vehicles have been proven to deliver significant air quality benefits in the large number of trials
implemented by both local authorities and businesses, which have led in many cases to a permanent uptake of
biomethane vehicles and fleets. Some figures from these are below. There are few short-medium term viable
options for decarbonising the heavy goods transportation sector, and trial results have demonstrated the
economic and carbon savings that can be delivered through the use of biomethane vehicles.
In 2009 Camden trialled a biomethane street cleansing vehicle, comparing its performance to a gas vehicle
operating on natural gas, with the biomethane vehicle achieving a 56% well-to-wheel emission saving.
Leeds City Council also trailed biomethane powered refuse collection vehicles between 09-10, achieving a
lifecycle CO2 saving of 49% compared to its diesel equivalent.
Coca-cola also recently undertook a year-long trial of 14 gas vehicles, achieving 50% GHG emissions savings
alongside reduced fuel costs of nearly 15% and reduced NOx (Nitrogen oxides, which damage lung tissue)
and PM (Particulate matter, tiny solid or liquid particles which cause a range of respiratory and health problems)
which create emissions of 85% and 97% respectively, compared to a diesel vehicle. With London having the
worst air of any European capital and facing a large fine for not complying with EU air quality standards, tackling
this issue now is vitally important for both health and financial reasons. According to the World Health
Organization, average life expectancy in the EU is reduced by 8.6% due to exposure to PM emissions.
Role within ULED
The key obstacle to the development of a mature biomethane vehicle market in the UK has been the lack of
effective government incentives to stimulate investment in infrastructure and vehicles. Although there have been
some encouraging developments, particularly with regard to Defra funding for the development of a gas vehicle
hub and air quality funding which is supporting a large number of low emission zone studies across English local
authorities, more can be done to realise the benefits of biomethane in vehicles.
Exempting biomethane vehicles from the London Congestion Charge would greatly incentivise their use for
businesses and individuals who have to make frequent journeys within the Congestion Charge zone. As well as
helping to tackle air pollution and GHG emissions in London, this would provide a broader benefit for the industry
in terms of demonstrating the viability of the vehicles and allowing businesses to more easily integrate them into
their transport fleets.