Consultation Response:
Creating a new Ultra Low Emission Discount
The Anaerobic Digestion and Biogas Association (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 and natural gas vehicles (both CNG and LNG) 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
improvement and reduction in noise pollution.
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, haulage operators, gas vehicle designers and conversion specialists,
consultants, financiers and supporting service companies. Anaerobic digestion can make a significant
contribution to reducing climate change, improving air quality and creating employment by producing clean
renewable energy, replacing chemical fertilisers, and preserving critical resource targets, subject to the right
policies being in place.
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 impurities and separating out the renewable CO 2
which can itself be used commercially. The biomethane can be used locally or injected into the gas grid or used
directly as a transport fuel. Biomethane is close to pure methane, so can be used in gas combustion engines
designed to run on natural gas without need for further modification.
Biomethane is one of the world’s most environmentally friendly fuels, with biomethane produced from slurry
providing a GHG emission saving of 174% compared to diesel as a vehicle fuel (see extract from Gallagher
report attached). Vehicle engines powered by biomethane are also quieter and more powerful than conventional
engines.
With the lowest well-to-wheel GHG emissions of any transport fuel as well as a cost-effective alternative to petrol
and diesel, biomethane is used in vehicles across the world. There are now approximately 17 million natural gas
vehicles operating across the world, a figure which is growing 20% each year, but only around 500 in the UK, far
lower than many other European countries. The air quality benefits, particularly in urban environments with high
air pollution from HGVs, buses and light vans, have been shown to be significant in Italy, Germany and Sweden.
As the following section suggests, this should also be recognised in London.
NOx and PM emissions
The emission of Nitrogen oxides (NOx) and Particulate Matter (PM) from road transport has been proven to
cause long term respiratory problems and shortened life expectancy. According to the World Health
Organization, average life expectancy in the EU is reduced by 8.6% due to exposure to PM emissions. Recent
statistics publicised by the Clean Air in London group also show that in 2010, long-term exposure to ‘man-made’
air pollution contributes to 5.6% of deaths in England, and almost one in ten deaths in the City of London.
As well as the terrible environmental impacts, on 7 March 2013 the UK’s Supreme Court will hear a case against
Defra brought by NGO ClientEarth on the UK’s failure to meet legally-binding standards for nitrogen dioxide
(NO2) in 35 of 43 zones across the country. With London having the worst air of any European capital and the
UK facing large ongoing fines for not complying with EU air quality standards, ADBA believes that tackling this
issue now is vitally important for both health and financial reasons.
There is a clear case for supporting biomethane and natural gas vehicles as part of the solution. As is shown in
the Coca-Cola case study below, the use of gas vehicles drastically reduces both NOx and PM emissions,
compared to diesel vehicles – with NOx emissions falling by 85.6% and PM emissions falling by 97.1%.
Case Studies
There are few short to medium term viable options for decarbonising the heavy goods transportation sector.
Biomethane vehicles have been proven to deliver significant air quality and GHG emission benefits in the large
number of trials carried out by both local authorities and businesses, which have led in many cases to a
permanent uptake of biomethane vehicles and fleets.
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 trialled biomethane powered refuse collection vehicles between May 2009 and July 2010,
achieving a lifecycle CO2 saving of 49% compared to its diesel equivalent.
Coca-Cola recently undertook a year-long trial of gas vehicles, orderjng a fleet of 14 gas vehicles at the
conclusion of the trial on the basis of the results. These showed 50% GHG emissions savings alongside
reduced fuel costs of nearly 15% and reduced NOx and PM emissions of 85% and 97% respectively, compared
to a diesel vehicle.
Role within ULED
ADBA believes that the key obstacle to the development of a mature biomethane and natural gas vehicle market
in the UK has been the lack of effective long term 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 and natural gas in vehicles.
Making biomethane and natural gas vehicles eligible for a 100% discount from the London Congestion Charge
would greatly improve the air quality in London by incentivising their use for businesses and individuals who have
to make frequent journeys within the Congestion Charge zone. As well as reducing vehicle noise and tackling the
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 by providing an incentive which would allow businesses to more easily
integrate gas vehicles into their transport fleets.
Extension to HGVs
We also believe it is vital that the ULED is extended to include larger commercial vehicles, rather than only cars
and light vans. The premium cost of purchasing a natural gas/biomethane HGV is far greater than that for a car
or van, and therefore a greater incentive is needed to support this vehicle category.
One of the key benefits of supporting biomethane/natural gas vehicles in London is the massive contribution that
can be made to cutting NOx and PM emissions from HGVs, and hence excluding this vehicle category would
prevent the sector from realising one of its most important benefits.
Dual Fuel vehicles
ADBA believes that alongside dedicated natural gas vehicles, duel fuel vehicles should also be supported under
the ULED. There is a lack of refuelling infrastructure in the UK at present which precludes many operators from
running dedicated natural gas fleets. Operators purchasing dual fuel vehicles are extremely unlikely to run them
on 100% diesel for cost reasons. The use of more dual-fuel vehicles will ultimately lead to the development of
more refuelling infrastructure and a growth in the biomethane and natural gas vehicle market.
Next steps
We would be happy to meet at a date of your convenience to further discuss the potential role of
biomethane/natural gas vehicles in the ULED criteria, as well as providing evidence on the number of vehicles
that we expect would benefit from being eligible under the 100% discount.