The Executive Summary of our response to the consultation on a New Heavy Goods Vehicle CO₂ Emissions Regulatory Framework for the United Kingdom, says the following
- Evidence shows that vehicles that run on 100% Renewable and Low Carbon Fuels (LCFs), have equivalent (if not better) GHG savings than zero tail pipe vehicles, when viewed on a lifecycle basis. If the Government’s objective is decarbonising HGVs, it is not logical to take this option off the table as a long-term solution for the very hardest to electrify HGV vehicles and use cases.
- The RTFA supports the transition to electrification, but there are many challenges making it highly likely that it will take longer than anticipated. Therefore, more effort should be made to achieve the near-term carbon savings that LCFs can deliver. The RTFO is not sufficiently ambitious, and LCFs get overlooked as the government’s focus is almost entirely on electrification.
- We disagree with the two reasons given, for not considering LCFs in the eligibility criteria for the CO₂ Emissions Regulatory Framework for the United Kingdom:
- “the need for LCFs in other hard to decarbonise modes such as aviation and maritime”. Using LCFs in road transport today is not constraining their use in aviation and maritime. LCF feedstock supply chains need to be further developed, and feedstocks will transition into aviation and maritime as electrification progresses.
- “LCFs generally still contribute significantly to air pollution”. The air quality emissions performance from ICEs has improved dramatically as a consequence of successive tightening of vehicle emission standards, and the introduction of clean air zones. We object to this broad-brush statement that takes no account of the substantial improvements to emissions technology in diesel engine / exhaust systems; and overlooks the contribution to air pollution from tyre and brake wear that applies to electric vehicles just as much as to ICE vehicles.
- LCFs are not an alternative to electrification, or a threat to progress which might delay electrification, but complimentary.
- A pragmatic and holistic approach is needed to decarbonise HGVs.
Click the following link for the full (4 page) response: –new-hgv-co2-emissions-regulatory-framework-uk
