Written evidence submitted by Country
Land and Business Association (CLA)|
The Country Land and Business Association (CLA) represents
some 35,000 members who between them own and manage half the rural
land in England and Wales. We have long taken a deep interest
in energy policy, as our members manage a large proportion of
the resources that may be brought to address climate change.
In the course of this work we have investigated the
development and use of biogas from Anaerobic Digestion, have undertaken
international study trips and supported the work of Task 37 (energy
from biogas and landfill gas) of the International Energy Agency.
Biogas when upgraded to bio-methane is an almost
perfect renewable transport fuel.
We are disappointed and confused that UK policy has
so far missed the huge potential for biogas to address both arms
of air quality: reducing the emissions of GHG in transport, while
at the same time delivering improved air quality through significant
reductions in particulants and noxious tailpipe emissions.
role of "dirty" diesel transport in poor air quality
(particularly in urban areas).
poor performance of electrification in road transport, particularly
for buses and HGVs, especially taking into account current grid
average GHG and emissions from conventional electricity generation.
EU comparisons between hybrid and CNG.
"stepping stone" and security of supply back up provided
by full switchability between natural gas and bio-methane.
flexibility of dual fuel vehicles and the low costs of switching.
clear and obvious example of significant benefits shown in Sweden.
failure of UK policy to address the role of biomethane in transport.
The role of "dirty" diesel transport
in poor air quality (particularly in urban areas)
1. The CLA does not claim expert knowledge of
the relative air quality impacts of different transport fuels,
but notes that where air quality has been found a problem elsewhere
in the world, changes to transport policy has delivered benefits.
For example many cities across the world have limited entry by
vehicles to reduce pollution. In India, some authorities have
required "tuk tuk" taxis to switch to running on gas
to reduce emissions.
2. It is clear that even modern "cleaner"
diesels produce significant disbenefits to air quality, and rather
than restrict the use of such vehicles, with significant effects
on the economy and society, alternative fuels may offer a better
The poor performance of electrification in road
transport, particularly for buses and HGVs, especially taking
into account current grid average GHG and emissions from conventional
3. We have noted that Transport for London has
invested significant sums in new hybrid electric buses. These
are recharged with grid average electricity, at 0.57098kg/kW (taken
from 2010 Guidelines to Defra / DECC's GHG Conversion Factors
for Company Reporting.
4. However, these buses are extremely expensive:
Transport for London states "Hybrid buses currently cost
approximately £110,000 more than a conventional diesel bus.
For example, a hybrid double deck bus for London would cost £300,000
compared with £190,000 for the diesel equivalent. Initial
indications are that maintenance costs are about the same as a
conventional diesel bus, although replacement of batteries after
about five years will require further capital investment".
5. Transport for London claims "Compared
with diesel buses, hybrid buses deliver environmental benefits,
30% reduction in fuel use.
30% reduction in carbon dioxide.
[dB(A)] reduction in perceived sound levels.
oxides of nitrogen and carbon monoxide".
6. In contrast, recent research
for the Baltic Biogas Bus partnership undertakne by the VTT technical
research centre of Finland states that:
new (EEV certified) methane buses clearly outperform new (EEV
certified) diesel vehicles for NOx as well as PM.
vehicles provide true EEV performance over time.
methane fuelled vehicles deliver very low PM emissions.
vehicles deliver lower NOx and lower fuel consumption.
benefit for methane also for unregulated emissions (PM numbers,aldehydes,
PAH, direct NO2 emission etc).
drawback of spark-ignited methane compared to diesel is higher
The lower energy yield of methane in engines means
that CO2 emissions are roughly equivalent between diesel
and methane power, but this has been fixed in Sweden by switching
from natural gas to bio-methane.
THE EU COMPARISONS
7. ComPro, the EU common procurement office undertook
a comparative study of bus technologies, with a side by side comparison
of the costs and benefits of the alternatives, based on CNG buses.
This is précised below:
Comparative cost/effectiveness analysis between CNG
bus and DEhybrid technology
in Europe CNG technology is much more experienced, while DE-hybrid
is only partially experienced.
infrastructure CNG needs an extra natural
gas filling station to be built; for already existing filling
station, the possibility of saturating its capacity represents
DE-hybrid can assure an higher range,
while CNG provides a reduced range depending on the availability
of a natural gas filling station.
DE-hybrid technology strongly reduces Pm, NOx and CO2
emissions, while CNG technology is responsible for higher CO2
and no PM emissions.
consumption is concerned: DE-hybrid strongly
reduces fuel consumption.
cost diesel cost is rapidly increasing
(in Italy one litre diesel costs so much as one litre gasoline,
that is 1,5 euro), while natural gas costs almost half so much
cost is concerned: DE-hybrid buses cost
about 120.000 euros each more than CNG ones.
is concerned: DE-hybrid buses are less noisy than CNG ones.
source dependence is concerned: there
is a reduced dependence on energy import by DE-hybrid technology,
while CNG technology depends on natural gas import.
8. The key issue for urban transport is whether
hybrid is the way forward, or to adopt CNG as a stepping stone
to a renewable future based on bio-methane.
9. The capital costs of replacing bus fleets
with hybrids (at least an additional £100,000 per vehicle)
together with the slow progress (waiting for existing buses to
be retired) may be considered to be less advantageous than an
early conversion of existing buses to dual fuel.
The "stepping stone" and security of
supply back up provided by full switchability between natural
gas and bio-methane
10. Bio-methane (produced from Anaerobic Digestion)
is identical to natural gas, being almost completely methane.
Current supplies of natural gas are available wherever fuel supply
is required through the national gas grid (save in the rural areas).
11. Vehicles converted to run on natural gas
require no further work to switch to use of bio-methane, and should
renewable supplies run short natural gas is available.
12. Pending decisions on the environmental performance
and regulatory framework, supplies of shale gas may well contribute
to security of supply.
13. The development of gas filling stations and
the conversion of vehicles is relatively cost effective.
The flexibility of dual fuel vehicles and the
low costs of switching
14. Hardstaff is the leading supplier of "dual
and can readily supply conversion for buses fitted with electronic
fuel injection systems, at cost effective prices. They currently
supply a range of heavy good vehicles (Mercedes Benz and Volvo)
and have over 80 million kilometres of dual fuel operation.
15. Many cities around the world have switched
to gas for bus transport - the UK is almost unique in seeking
more expensive hybrid technology.
16. The ComPro report suggests that the additional
costs of GNG buses is only 30,000 Euro per vehicle.
17. Duel fuel offers opportunities for more extensive
air quality benefits as it is also suitable for long distance
transport fleets of HGV and smaller lorries.
The clear and obvious example of significant benefits
shown in Sweden
18. In 2010, with sponsorship from the FCO, CLA
joined with Task 37 to take two DfT officials on a fact finding
visit to Sweden to explore the use of gas as a vehicle fuel.
19. It was clear to all that in Malmo the use
of biogas to fuel buses has lead not only to significant air quality
benefits but also to meeting renewable energy targets and reducing
20. Sweden has a well regulated and highly developed
bio-methane transport policy, which currently delivers significant
quantities of sustainable clean fuel.
21. During 2006, almost 24 million normal cubic
metres of biogas were used as vehicle fuel in Sweden, which is
equivalent to 26 million litres of petrol. 2006 was the first
year in Sweden when more biogas was sold as vehicle fuel than
natural gas (biogas comprised 54% of the total volume).
22. Swedish regulations require low sulphur and
particulate content in the fuel, leading to very low tailpipe
The failure of UK policy to address the role of
biomethane in transport
23. Hybrid technologies cannot themselves deal
with the air quality agenda.
24. However, concentration on hybrids and liquid
biofuels has led to the under-development of biomethane as transport
25. The use of biomethane is not adequately supported
in the UK, compared to other countries like Sweden.
26. DfT should consider the necessary policy
actions required to ensure a large scale switch of the UK bus
fuel (gas and diesel).
27. Once buses and HGV are capable of running
on gas, it is a short step to switch over to bio-methane as soon
as supplies are available.
28. Operators of dual fuel vehicles have evidence
to show cost savings may be achieved as well as improved air quality.
DfT should take time to talk to Hardstaff (a leading British Company)
to learn what is needed to widen the use of dual fuel buses.
29. CNG and LNG buses are widely available across
the world. UK lags behind the adoption of this beneficial fuel
use which is rapidly growing in other countries.
30. Bio-methane is a direct replacement for natural
gas, and enables climate change benefits to be added to the air
quality benefits of running buses on gas.
31. The supply of bio-methane is limited at present,
but should grow as more AD plants install upgrading and connect
to the gas grid with support from the recently announced Renewable
Heat Incentive. In order to drive the uptake of bio-methane in
the transport sector, the Renewable Transport Fuel obligation
should be amended so that the number of certificates awarded per
litre reflect the GHG savings achieved (on a whole life cycle
basis) of the fuel
32. There is an obvious and relatively inexpensive
route to better air quality, which does not depend on re-equipping
bus fleets with expensive and short life battery powered hybrid
vehicles (batteries have a relatively short life compared to internal
33. Equally, wider air quality benefits would
be delivered by better incentives to take up CNG and bio-methane
in transport fleets.
34. DfT should require and work with bus operators
to ensure they adopt gas, and rapidly move them up the scale towards
a bio-methane powered sustainable bus transport system for urban
areas - as is demonstrated in Malmo, Sweden.
24 May 2011
1 Annex 3 at http://archive.defra.gov.uk/environment/business/reporting/pdf/100805-guidelines-ghg-conversion-factors.pdf