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					Digest Report – October 2009




LOW CARBON VEHICLES:
DIGEST REPORT
      DIGEST REPORT




            Atkins Ltd




Scottish Government Social Research
               2009
                         Table of Contents

1   INTRODUCTION                             1
2   CONSULTATION RESPONSES                   2
1 INTRODUCTION

1.1   The Scottish Government‟s Consultation document on Low Carbon Vehicles
      was issued on 29th June 2009. The consultation sought the views of
      stakeholders in order to inform the development of a policy framework for the
      development and uptake of LCVs and alternative fuels and to identify the
      potential role of targets in the process.

1.2   This Digest Report collates and presents the responses that have been
      received and should be read in conjunction with the Consultation Analysis
      Report.




                                          1
2 CONSULTATION RESPONSES
   2.1   Table 2.1 gives a summary of the responses received, and the type of
         responder. The full responses can be seen from page 4 onwards.

                             Table 2.1 – Summary of Responses

Reference   Name                                 Responding on behalf of   Page No
    R1      Aberdeenshire Council                Group / Organisation         4
    R2      Angus Council                        Group / Organisation          *
            Convention of Scottish Local
    R3                                           Group / Organisation           8
            Authorities
   R4       Dundee City Council                  Group / Organisation           11
   R5       East Ayrshire Council                Group / Organisation            *
   R6       East Dunbartonshire Council          Group / Organisation           13
   R7       City of Edinburgh Council            Group / Organisation           15
   R8       Fife Council                         Group / Organisation           18
   R9       Glasgow City Council                 Group / Organisation           20
   R10      Highland Council                     Group / Organisation           22
   R11      Inverclyde Council                   Group / Organisation           24
   R12      South Lanarkshire Council            Group / Organisation           26
   R13      West Lothian Council                 Group / Organisation           28
   R14      Nestrans                             Group / Organisation           30
   R15      SEStran                              Group / Organisation           31
            Strathclyde Partnership for
   R16                                           Group / Organisation           33
            Transport
   R17      Swestrans                            Group / Organisation           35
   R18      TACTRAN                              Group / Organisation           37
   R19      Allied Vehicles                      Group / Organisation           39
   R20      Axeon                                Group / Organisation           41
   R21      Clean Air Power                      Group / Organisation           44
   R22      Jaguar Land Rover                    Group / Organisation            *
   R23      EDF Energy                           Group / Organisation           46
   R24      Energy Savings Trust                 Group / Organisation           49
   R25      Scottish and Southern Energy         Group / Organisation           51
            British Vehicle Rental and Leasing
   R26                                           Group / Organisation           54
            Association
   R27      Cairngorms National Park             Group / Organisation           56
            Chartered Institute of Logistics
   R28                                           Group / Organisation           58
            Transport
            Confederation of Passenger
   R29                                           Group / Organisation           61
            Transport
   R30      Environmental Protection UK          Group / Organisation           63
   R31      First Group                          Group / Organisation           65
   R32      Freight Transport Association        Group / Organisation           67
   R33      Guide Dogs                           Group / Organisation           69
   R34      Highlands and Islands Enterprise     Group / Organisation           71
   R35      Institute of Mechanical Engineers    Group / Organisation           73
            Association of Chief Police
   R36                                           Group / Organisation           75
            Officers in Scotland
   R37      Living Streets                       Group / Organisation           77
   R38      RAC                                  Group / Organisation           79
            Scottish Council for Development
   R39                                           Group / Organisation           81
            and Industry
   R40      Scottish Engineering                 Group / Organisation           86



                                             2
Reference    Name                                 Responding on behalf of   Page No
             Scottish Environmental Protection
    R41                                           Group / Organisation         89
             Agency
    R42      Scottish Natural Heritage            Group / Organisation        91
    R43      Tayside Police                       Group / Organisation        93
    R44      World Wildlife Fund                  Group / Organisation        95
    R45      Barry Hutton                         Individual                  99
    R46      Derek Halden                         Individual                  101
    R47      Ian Souter                           Individual                  103
    R48      Irene Brandt                         Individual                  105
    R49      Gordon MacLean                       Individual                  107
    R50      Anonymous                            Individual                  109
    R51      Shanwen Tao                          Individual                   *
   *These respondents have chosen to keep their responses confidential.




                                             3
R1 - Aberdeen Council


 RESPONDENT INFORMATION DETAILS
 Name:
 Organisation:                                           Aberdeenshire Council
 Address:                                                Woodhill House, Westburn Road, Aberdeen
 Postcode:                                               AB16 5GB
 Email:
 Telephone Number:                                       01224 664 809
 Responding as:                                          On behalf of a group or organisation
 Individual Permission:                                  Not Supplied
 Confidentiality:                                        Not supplied
 Group or Organisation:                                  Yes
 Share Response Permission:                              Yes
 Question 1: Which low carbon technologies and fuels     Aberdeenshire Council believes that each of the technologies and fuels outlined in section 4 of the
 do you envisage will be first to be influential in      consultation paper have a role to play in reducing GHG emissions from the transport sector. The
 reducing GHG emissions from the transport sector?       development of Low Emission Vehicles (LEVs) through improvements in the efficiency of internal
 Why?                                                    combustion engines may be the most likely measure to influence reductions in GHG emissions in the
                                                         immediate future given that consumers will not necessarily have to change their own travel behaviour.

                                                         In addition it would appear that the industry has already identified electric hybrid technology as one that has
                                                         a potential market place. Almost all significant car manufactures now include at least one electric hybrid
                                                         option within their range. It would appear that there is already a market acceptance of the technology and it
                                                         is fully expected that this will be developed further in the short term.

                                                         Significant incentives also already exist to promote the adoption of LEVs, such as through lower vehicle
                                                         taxes for LEVs. When coupled with drives to improve air quality, and the creation of further Low Emission
                                                         Zones (LEZs) in cities around Scotland, it is clear that there is potential for a shift in the public perception to
                                                         alternative transport technologies.

                                                         However, as previous research(1) undertaken for the Government has shown, the delivery of carbon
                                                         dioxide reduction targets will not only be dependent on strong technological innovation but also requires
                                                         strong behavioural change. As the research suggested, changes in the built environment will become
                                                         effective in the medium term (10-15 years) and the major contribution of technological innovation will only
                                                         become effective after 2020. Therefore, the development of technologies and fuels associated with LCVs
                                                         should not detract from our efforts to encourage
                                                         travel behavioural change as this is where the real change must take place as soon as possible if rates of
                                                         traffic growth are to be reduced
 Question 2: Which low carbon technologies and fuels     Aberdeenshire Council considers that, ultimately, the greatest emissions abatement impact will follow from
 do you believe will ultimately have the greatest        fuels for which the life cycle carbon impacts can be minimised. The development of electrical vehicles
 emissions abatement impact? Why?                        powered by low carbon sources, such as renewables (wind and hydro), is one example which could have
                                                         very low emissions over its life cycle.

                                                         For alternatively fuelled vehicles to make a major impact on the overall transport sector they will have to
                                                         provide the level of service which has now become expected from conventionally fuelled vehicles. At the
                                                         present time there appears to be fundamental issues with all proposed alternatives that affect their real
                                                         world applicability. However from the information available it would appear that either Plug in Electric
                                                         Vehicles or Hydrogen Fuel cell vehicles would offer the greatest long term impact.

                                                         There are significant issues still to be resolved with refuelling practicalities, of both options, and of “fuel”
                                                         production. However it would appear that there is potential for “fast charging” of batteries, and also
                                                         hydrogen production and storage advances that will overcome the current barriers.
 Question 3: What timescales do you believe are          It is likely that the development of low carbon transport will be incremental. Already there are various LCVs
 feasible for the development of specific low carbon     available in the market place. Consumer demand is growing for these alternatives and this will drive further
 technologies and fuels? Are there any important         research. It is worth noting that battery/fuel cell technology is still some way off for Light Goods Vehicles
 intermediate milestones within these timescales?        (LGVs), possibly 20 years away, so will not be commercially available before 2020.

                                                         Having said that, it is unlikely that a paradigm shift will occur unless significant encouragement is given for
                                                         the required Research and Development investment. It is important that the full impact of developing
                                                         technologies is understood before rushing to deliver mass market solutions. The haste with which biofuel
                                                         technology was “adopted” as a solution is a case in point. It is now widely accepted that the unintended
                                                         consequences of this technology can be
                                                         extreme, and fundamentally undermine the perceived benefits. It is essential that as technologies are
                                                         developed that they are evaluated in a “whole life” manner.

                                                         Given the current situation it is difficult, with any certainty, to put a timescale on development. Various
                                                         factors will be important, such as funding assistance, economic trading conditions, fuel price, and consumer
                                                         attitudes. However for us to meet the ambitious targets set by the Scottish Government significant advances
                                                         need to happen within the next 5-7 years.
 Question 4: What timescales do you believe are the      It is difficult to consider this question in isolation to the one above. Without demand there is no driver for
 feasible for the uptake of specific low carbon          innovation, and without innovation the “consumer” does not have confidence in new technologies. It is
 technologies and fuels? Are there any important         entirely likely that the uptake of new technologies and/or fuels will require significant investment in delivery
 intermediate milestones within these timescales?        infrastructure. This will undoubtedly lag behind the development of the technology itself. It is likely that there
                                                         will not be a significant uptake of new low carbon technologies or fuels within a decade.
 Question 5: Are there other barriers to the             Aberdeenshire Council believes that the main barriers related to the different fuel types and technologies
 development of such fuels and technologies that are     identified in the consultation paper are correct. With regards to biofuels for instance, it will be important that
 not mentioned in this document? If so, what are         their development does not contribute to a loss of biodiversity nor contribute to rising prices for some
 they?                                                   commodities (e.g. oilseeds), which can have wider detrimental socio-economic impacts. Other factors, such
                                                         as the significantly higher costs of LCVs, such as hybrids, over standard combustion engine vehicles are
                                                         also key barriers to promoting the uptake of LCVs, especially in the current economic climate. For this
                                                         reason, the Council believes that the public sector has a key role to lead by example and create the
                                                         economies of scale necessary to make LCVs more accessible in the longer term. However, having said
                                                         that, it is also essential that public sector agencies are given the necessary support to allow them to lead by
                                                         example. Within the current economic climate it is crucial that investment decisions are taken in the spirit of
                                                         Best Value, in its widest sense. Where Electric Vehicles (EVs) are concerned, the key barrier obviously
                                                         relates to a lack of infrastructure necessary to charge them and the battery capacity they can offer. As the
                                                         consultation paper correctly identifies, the greatest opportunities to introduce EVs will be in urban areas
                                                         where vehicles traditionally travel shorter distances and where it is more efficient to provide a cluster of
                                                         charging points. In rural areas, such as Aberdeenshire, opportunities will be more limited.
 Question 6: Are there other barriers to the uptake of   As alluded to earlier in our response, Aberdeenshire Council strongly believes that in order to encourage
 such fuels and technologies that are not mentioned      the uptake of LCVs, travel behaviour change is essential. The benefits of LCVs should be promoted through
 in this document? If so, what are they?                 the travel planning process, along with other more sustainable modes of transport such as walking, cycling
                                                         and public transport use.
                                                         Transportation and storage of alternative fuels is not really considered within the consultation document.
                                                         There is a real need to consider how sufficient quantities of any new fuel can be created, transported, and
                                                         stored efficiently, allowing it to be accessible to all communities. A further barrier would be the relative
                                                         efficiency of the alternatives in that initially many of the new products are inferior to existing technologies




                                                                              4
                                                          e.g. in power output. The potential for several different alternative fuels to emerge is also a cause for some
                                                          concern, and not mentioned in the consultation document. Too much variety in new fuels will add
                                                          significantly to the efficient delivery to users. There is a real potential for this to negatively affect smaller,
                                                          more remote, communities resulting in them having to travel greater distances for “refuelling”. The adoption
                                                          of LCVs will also be dependent on corporate leadership, and requires a champion to take the first step and
                                                          lead by example. It is felt that the public sector, and particularly the Scottish Government, therefore has an
                                                          important role to play here.
Question 7: Are there any negative social impacts         On the whole it is believed that the benefits of adopting LCVs far outweigh any potentially negative social
associated with either the development or uptake of       impacts. A potential negative social impact relates to unemployment in the car manufacturing industry
such technologies/fuels? If so, what are they?            although as the consultation paper mentions, Scotland possesses a wealth of industrial skills and the
                                                          academic base to support the research and development of LCVs.

                                                          Aberdeenshire Council fully understands the opportunities that come from developing our existing
                                                          technology base into the renewable energy sectors. With a range of partners, within the Aberdeen City and
                                                          Shire Economic Forum (ACSEF), we are fully committed to the development of the Energetica energy
                                                          corridor. This long term aspiration seeks to develop an energy related corridor from Aberdeen to Peterhead,
                                                          providing a world class environment to
                                                          foster the necessary research and development to make the area a world leader in energy technology.

                                                          More specifically, as part of the Energetica project, Aberdeenshire Council, along with partners including
                                                          Scottish Enterprise, is investigating the development of a hydrogen corridor along the A90 between
                                                          Aberdeen and Peterhead. The hydrogen corridor will be an early adopter area which will see renewably
                                                          generated hydrogen deployed to power homes, industrial processes, commercial premises farm vehicles
                                                          and road transport using hydrogen to fuel internal combustion engined vehicles and fuel cell power packs. A
                                                          feasibility study on this initiative, which will consider infrastructure issues, is about to start and will provide a
                                                          more detailed insight into the scale of the investment necessary to establish the hydrogen corridor on a long
                                                          term sustainable basis. Aberdeenshire Council will be happy to share findings from the feasibility works as it
                                                          emerges. A final potentially negative social impact that requires consideration is that of social inclusion. It is
                                                          likely that only the wealthier sections of society will be able to afford to purchase LCVs in the short term
                                                          future, and subsequently gain from the benefits offered by running an LCV as well as the incentives that can
                                                          be put in place to support LVC use. Therefore, it could be argued that the promotion of LCVs will be
                                                          discriminatory and will marginalise those sectors of society that cannot afford LCVs.
Question 8: What, if any, technical challenges would      Aberdeenshire Council has lobbied for distributed generation i.e. local rather than national reconciliation of
the grid reinforcement upgrades be likely to present?     supply and demand in relation to heat and electricity. The Council also supports removing heat load from
How might these be overcome?                              the grid as thermal power stations have such a low efficiency compared to boilers.

                                                          One of the problems we have with the grid is that it tends to be strong between large points of generation
                                                          (for example, Peterhead) and large points of consumption (cities). On shore wind energy is generally
                                                          available in areas that have small populations and so, small grid capacity. Increasing the share of on shore
                                                          wind generated electricity will depend on addressing this point and the planning issues of visual or other
                                                          impacts of large scale wind developments. There are clear linkages in this area to the commitments set out
                                                          in the National Planning Framework
                                                          (NPF) and it is hoped that the linkages will be made in this respect. Given the importance given to wind in
                                                          government generation policy, the need for a charging system that does not penalise generation that is
                                                          remote from large cities or users is important, as is the need to reinforce the grid to allow for such
                                                          generation to be developed commercially. There must also be clearer regulation on grid access which
                                                          takes deliverability (of generation)
                                                          into account and on planning, where there is a lack of guidance leading to uncertainty on what criteria will
                                                          be applied to applications whether above or below 50Mw capacity.
Question 9: Who would fund any grid upgrades?             The grid is a strategic national resource and this should be taken into account in planning its future role,
And, how might these costs be recovered?                  capacity and reach. As alluded to in the response to Q8, it is not reasonable to penalise "remote" on shore
                                                          wind generators given their role in delivering UK targets. Access charges to the grid should be uniform and
                                                          the costs borne universally. Electric vehicles will only make sense if the power to recharge them is
                                                          generated from renewable resources. Also refer to the point in Q8 regarding NPF.
Question 10: Do any of the technologies present any       As alluded to in our response to Q5, the lack of a critical mass population means that it will be difficult to
specific challenges or opportunities to island            provide the infrastructure necessary to power LCVs in remote rural areas. An under development of the
communities and sparsely populated rural areas in         necessary infrastructure will result in longer travel distances for residents in remote, rural regions. Due to
Scotland? If so, how might these challenges by            the travel patterns in rural areas it is difficult to see how the current range of Electric Vehicles can be
addressed, and by whom?                                   usefully deployed in these remote areas. However with advances in battery technology, leading to greater
                                                          range capabilities and the potential for fast charging at their
                                                          destination, it may well be that these limitations can be removed or a system of sharing charged batteries
                                                          for „plug in‟ electric vehicles can be implemented. For example, going to a petrol (energy) station to change
                                                          batteries instead of having to „plug in‟/charge the batteries. This could be done in the same way that people
                                                          currently go to a petrol station to fuel their vehicle. This is likely to depend on vehicle manufacturers using
                                                          the same/similar fuel cell batteries that
                                                          were compatible with all vehicles. However, Aberdeenshire Council believes that our remote rural
                                                          communities are often the most enterprising due to the conditions that they face. Our remote regions also
                                                          tend to benefit from
                                                          weather conditions conducive to the creation of renewable energy, which in turn can be used to power
                                                          LCVs. One particularly innovative example of which Aberdeenshire Council is aware is the Pure (Promoting
                                                          Unst Renewable Energy) Energy Centre2 in Unst, Shetland. As you may know, Pure is leading the way in
                                                          the development of renewable energy and were responsible for the creation of the UK‟s first road licensed
                                                          hydrogen car. In addition to the development of renewable energy, the Pure project has played a key role
                                                          in the socio-economic vitality of the Unst (a community which has suffered numerous setbacks in recent
                                                          years due to the closure of RAF Saxa Vord). Diverse and unique initiatives which make use of local
                                                          resources and offer wider community benefits are vital for the future socio-economic development of remote
                                                          areas and should be supported across Scotland. Indeed, given that fuel
                                                          costs are often the highest in our remote areas, it goes without saying that there are great opportunities and
                                                          benefits to be grasped through harnessing renewable energy through local projects. Given that local
                                                          residents are more likely to benefit from the success of the project, they are more likely to take on
                                                          responsibility for the project and ensure that it is a success. Therefore, it is believed that going forward there
                                                          will be a role for local communities to play in advancing LCV development.
Question 11: Do you think that having a twin              There is a very strong argument to the setting of different targets for public sector fleet up take of LCVs. By
approach for the public sector and other users is         setting targets for such a reasonably large and regular purchase,r the required critical mass can hopefully
appropriate? If so, why? If not, why not?                 be created to ensure that new products are brought to market. The range and type of vehicles that public
                                                          sector organisations require to deliver services may of course dilute this effect to some extent.

                                                          Furthermore, it must be realised that public sector agencies do not operate in a financial vacuum. It is
                                                          broadly accepted that the adoption of any new technology comes with a financial overhead. It is not realistic
                                                          for public sector agencies, such as Local Authorities, to bear the full financial penalties that will undoubtedly
                                                          result from the more ambitious targets proposed in the consultation.

                                                          Central and Local Government has a valuable role to play in “mainstreaming” new and emerging low carbon
                                                          technologies. However in the current, and future, financial settlement conditions it is ever more important
                                                          that investment decisions lead to improved customer service. While it is true that the “greater good” is
                                                          served by a quick transition to low carbon vehicles, Local Authorities have to protect front line service
                                                          delivery. Central Government is quite right to attempt to harness the purchasing power of all public sector
                                                          agencies, but must appreciate that the financial “overhead” that comes with this must not be taken from
                                                          current financial settlements, but should be delivered through additional targeted funding.
Question 12: If so, should targets relate to the uptake   Aberdeenshire Council believes that targets set should be based on outcome indicators rather than inputs.




                                                                               5
of low carbon vehicles (either as a percentage of the     At the end of the day, while inputs (e.g. the percentage of fleet that is low carbon emitting) can be useful as
fleet or an absolute number), or a reduction in total     a performance milestone, the most important target to deliver on will be the overall reduction in carbon
emissions across the fleets or another format of          dioxide emissions from transport.
target? Why?
Question 13: If we follow a target relating to the        Since our answer to Q12 is that we should not base targets on the percentage of plant that meets LCV
public sector uptake of LCVs, what percentage of the      targets then it is not appropriate to answer this question. Indeed at this stage in the development of LCVs it
fleet should be LCVs by 2020? Please give reasons         is difficult to see how a percentage target can be accurately set for 2020. The transition towards a LCV fleet
for your answer.                                          will be dependant on the ability of
                                                          the market to deliver the wide range of vehicles that are required by the public sector, from front line
                                                          emergency vehicles to specialist snow clearing plant. Further detailed investigation will be required to fully
                                                          understand the available options, the range of vehicles that are available, and the cost overhead that will
                                                          result from early adoption of
                                                          technology. It is too simplistic to set an arbitrary figure without full consideration of the broad range of inputs
                                                          that all have to be in place.
Question 14: If we follow a target relating to the        The concerns expressed above in relation to the availability of LCVs and the speed of development also
uptake of LCVs across all road users, what                apply to the percentage uptake across all road users.
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        As outlined in answers to Q11 and Q13, the range of vehicles in operation across the public sector fleet is
should be excluded from the public sector target? If      extensive. There are undoubtedly a range of specialist vehicles, such as snow clearing equipment, that is
so, what are they and why should they be excluded?        not mass market and it is difficult to see how manufacturers can be encouraged to develop alternatives.
If not, why not?                                          The difficulty of developing these alternatives is another reason why the input based percentage target is
                                                          felt to be inappropriate. The important issue is the reduction in emissions from the public sector transport
                                                          fleet, and measurement of the inputs required to achieve this is a somewhat limited approach.
                                                          Aberdeenshire Council feels that while measuring inputs is a useful management tool it is less appropriate
                                                          for national targets. Serious consideration should be given to the development of output based targets.
Question 16: As LCVs may have higher upfront costs        As outlined in our response to Q11, we believe that the public sector has a key role to play in the adoption
than traditional vehicles (albeit with a smaller          of LCVs. As the consultation papers states, through public sector procurement of LCVs, economies of scale
discrepancy between lifecycle costs) do you               in production could result, which in turn should lower production costs. In the longer term, this may reduce
consider it to be efficient use of public resources to    the price of LCVs for consumers and consequently lead to further increases in demand. However, as stated
devote a greater short-term budget towards the            previously, it is not realistic for the public sector to shoulder the full financial burden for early adoption.
purchase of LCVs? If so, why? If not, why not?            Further detailed investigation is required to fully understand the full benefit that can be delivered by early
                                                          adoption and how this can be balanced against the
                                                          potential short term impacts on service delivery through the diversion of limited funds.
Question 17: Are there any opportunities or barriers      Aberdeenshire Council generally believes that the opportunities and barriers presented in the consultation
to public sector procurement of LCVs that are not         paper are appropriate.
mentioned in this document? If so, what are they?
Question 18: What are the individual roles of different   This is a serious issue, particularly for the more rural, less populated areas. If the development of
groups and organisations in ensuring the provision        infrastructure is left entirely to private industry there is a real possibility of creating further social exclusion.
of any infrastructure required for low carbon             The high capital investment costs of any infrastructure delivery programme will result in a concentration on
vehicles?                                                 highly populated areas, potentially with high demand. It is important that mechanisms are put in place to
                                                          ensure that new networks are delivered across the country in a uniform manner. A defined minimum level of
                                                          service must be put in place to ensure that new technology is available to all, and that rural areas do not
                                                          become “no go” areas as they do not have the required infrastructure. Already there are instances across
                                                          Scotland where communities are hugely constrained in their development through lack of access to fuel.
                                                          Having said that, private industry should be encouraged to develop these networks. For example the
                                                          provision of charging points in a supermarket car park provides the user with benefits, and gives the
                                                          supermarket an additional attractor. Community entities have been successful in assisting in the
                                                          development of renewable energy, such as wind farm development, producing local community benefits
                                                          and meeting national
                                                          targets. It is possible that this model can be used to further the provision of the necessary infrastructure to
                                                          ensure the success of LCVs.
Question 19: Are there other supply side/capacity         See response to Q6. Specifically, it is felt that the transportation and storage of alternative fuels is an
constraints impacting on LCV development and              important supply issue which is not fully considered within the consultation document. There is a real need
uptake? If so, what are they?                             to consider how sufficient quantities of any new fuel can be created, transported, and stored efficiently,
                                                          allowing it to be accessible to all communities.
Question 20: Are there barriers to the development of     Presently skills shortages still exist in some of the specialist engineering fields and this continues to be a
an indigenous low carbon vehicle industry in              concern for future development of the low carbon industry in Scotland.
Scotland? If so, what are they and how might they be
overcome?                                                 The Aberdeen City and Shire region has a long history of delivery in the conventional energy sector,
                                                          specifically in the offshore oil industry. The specialist companies, and their highly skilled workforces,
                                                          associated with this industry hold the skills necessary to assist in the development of Scotland‟s low carbon
                                                          vehicle industry. Indeed anchoring expertise in all energy technologies in the North East and Scotland is a
                                                          key aim.

                                                          As well as the existing industry base, Scotland‟s education system is well developed in the necessary
                                                          sectors to assist in the retraining of existing workers, and the development of the new generation of skilled
                                                          staff. Strategic partnerships already exist across academia and industry and these should continue to be
                                                          encouraged at all levels.
Question 21: Should Scotland’s industry focus on          Currently Scottish businesses have focussed on the bus and small van sectors. It would appear that current
particular vehicle types? If so, what are they and        business models have justified this investment. It would make sense for the Scottish industry to focus on
why? If not, why not?                                     specialist vehicles, such as buses, mini buses, and small vans given that they are already developed in
                                                          these fields.

                                                          However there are many parts within the supply chain and companies such as Axeon have already
                                                          demonstrated an ability to provide parts for a wide range of vehicles. It is therefore essential that existing,
                                                          new, and emerging industry sectors do not limit their aspirations.
Question 22: Are there gaps in the supply chain? If       The supply chain must be thought of in terms of smarter vehicles and capacity exists to build these, albeit
so, what are they and how might these be overcome?        perhaps not within currently recognised mass manufacturers of road vehicles. The supply chain requires
                                                          stimulation, however, as the alternative technologies discussed in the consultation paper remain expensive
                                                          compared to internal combustion engines and without a move to volume demand costs will remain high. A
                                                          step change in demand can only be effected through a combination of government policies to promote the
                                                          technologies involved and a commitment to keep incentives in place until the market is well established. At
                                                          present, costs for hydrogen internal combustion engined or hydrogen fuel cell vehicles are so high that a
                                                          carbon tax alone will not promote demand – clear long term commitment from the government and
                                                          accompanying financial incentives are both needed to create demand. For example, the costs of converting
                                                          a panel van of UK origin to burn hydrogen instead of petrol is over £40,000 when small numbers are looked
                                                          at. This is more than twice the retail price of the van before conversion. As well as conversion costs being
                                                          so high it is only possible to convert petrol engines. Since 95% plus of Local Authority fleets are typically
                                                          diesel this is not an area of significant potential benefit. No realistic price or tax on carbon is going to offer a
                                                          payback on this cost but volume demand would reduce the price of the conversion and fuel demand would
                                                          likewise reduce the refuelling infrastructure costs.
Question 23: Do we have the required skills base for      The technical knowledge exists but will not be applied without a financial support scheme to promote
the development of this market? If not, where are the     demand for hydrogen vehicles or other alternatives to petrol and diesel internal combustion engined
gaps?                                                     vehicles.
Question 24: How could the various stakeholders           Aberdeenshire Council believes that, as an initial task, it would be useful to establish an LCV Industry
collaborate to stimulate the development and uptake       Forum, which would bring together public and private stakeholders with an interest in developing LCVs.
of LCVs?                                                  Such a Forum is viewed as essential to establish the knowledge exchange culture which will be critical to
                                                          the ongoing development of LCV fuels and technologies. It also goes without saying that central to the




                                                                               6
                         development of LCVs will be partnership working
                         by academic experts in this field, along with relevant stakeholders from industry and the public sector. To
                         promote the uptake of LCVs, the full range of benefits that LCVs can deliver must be conveyed to the wider
                         public through a range of media. In addition to the environmental benefits, the longer term economic
                         benefits should also be heavily promoted if consumers are to be encouraged to purchase LCVs over
                         cheaper alternatives.
Additional Information
1                        Hickman, R and Bannister, D (2006), Looking Over the Horizon – Visioning and Backcasting for
                         UK Transport Policy. Department for Transport – Horizons Research Programme 2004/05.
                         London.




                                             7
R3 – Convention of Scottish Local Authorities


 RESPONDENT INFORMATION DETAILS
 Name:                                                        Kristen Miller
 Organisation:                                                Convention of Scottish Local Authorities
 Address:                                                     Rosebery House, 9 Haymarket Terrace, Edinburgh
 Postcode:                                                    EH12 5XZ
 Email:
 Telephone Number:                                            0131 474 9247
 Responding as:                                               On behalf of a group or organisation
 Individual Permission:                                       Not Supplied
 Confidentiality:                                             Not supplied
 Group or Organisation:                                       Yes
 Share Response Permission:                                   Yes
 Question 1: Which low carbon technologies and fuels do       Hybrid vehicles seem to have taken the strongest hold in the marketplace to date, however we should
 you envisage will be first to be influential in reducing     be exploring all the different options for different types of vehicles, distances, uses. Only consumer
 GHG emissions from the transport sector? Why?                use can determine which technology will be the most viable in the long term and it may be that we will
                                                              find ourselves with a mix of technologies being used to go forward.
 Question 2: Which low carbon technologies and fuels do       It is difficult to say whether the most promising technology is full electric vehicles, hydrogen or
 you believe will ultimately have the greatest emissions      perhaps some other point of use power source, such as compressed air. All these technologies
 abatement impact? Why?                                       require large amounts of low carbon electricity supply if they are to deliver overall reductions in
                                                              greenhouse gas emissions. Bearing this in mind, the UKCCC suggestion that de - carbonisation of
                                                              electricity supplies requires early focus and action seems fully justified.
 Question 3: What timescales do you believe are feasible      It is likely that the development of low carbon transport will be incremental. Already there are various
 for the development of specific low carbon technologies      LCVs available in the market place. Consumer demand is growing for these alternatives and this will
 and fuels? Are there any important intermediate              drive further research. It is worth noting that battery/fuel cell technology is still some way off for Large
 milestones within these timescales?                          Goods Vehicles (LGVs), possibly 20 years away, so will not be commercially available before 2020.

                                                              Having said that, it is unlikely that a paradigm shift will occur unless significant encouragement is
                                                              given for the required Research and Development investment. It is important that the full impact of
                                                              developing technologies is understood before rushing to deliver mass market solutions. The haste
                                                              with which biofuel technology was “adopted” as a solution is a case in point. It is now widely accepted
                                                              that the unintended consequences of this technology can be extreme, and fundamentally undermine
                                                              the perceived benefits. It is essential that as technologies are developed that they are evaluated in a
                                                              “whole life” manner.

                                                              Given the current situation it is difficult, with any certainty, to put a timescale on development. Various
                                                              factors will be important, such as funding assistance, economic trading conditions, fuel price, and
                                                              consumer attitudes. We agree that the public sector has a leadership role to play in encouraging take
                                                              up of proven technologies, but assistance will be needed.
 Question 4: What timescales do you believe are the           This question is closely linked to the one above. If the public sector is to lead uptake then it is crucial
 feasible for the uptake of specific low carbon               that appropriate incentives are in place. Expenditure is likely to be constrained over the next few
 technologies and fuels? Are there any important              years. Local authorities could explore the possibility of using prudential borrowing to fund the
 intermediate milestones within these timescales?             purchase of low emission electric vehicles on the basis of lower whole life costs. It is desirable for the
                                                              Scottish Government to provide local authorities with regular updates of whole life cost information. If,
                                                              in the early years, there are no savings, then the Scottish Government should consider grants to
                                                              assist the uptake of Low Carbon Vehicles.

                                                              It is hard to put a timeline on this but appropriate milestones would include the introduction of
                                                              incentives and the provision of supply and suitable infrastructure.
 Question 5: Are there other barriers to the development      The barriers to development have largely been covered in answers to the questions above but include
 of such fuels and technologies that are not mentioned in     higher upfront costs and the current lack of infrastructure for use of some technologies. Also doubts
 this document? If so, what are they?                         about the “whole life” carbon cost of biofuels still exist.
 Question 6: Are there other barriers to the uptake of such   Barriers to uptake at the moment include the lack of availability of places to charge electric vehicles
 fuels and technologies that are not mentioned in this        and perhaps an uncertainty about the availably of other alternative fuels when/where consumers
 document? If so, what are they?                              would need them. In the short term the only way to encourage uptake is to convince consumers that
                                                              using a low carbon vehicles is as convenient and effective as using a traditional vehicle.

                                                              For this reason there is, as stated earlier, a leadership role to be played by the public sector, but in
                                                              these tight financial times this is not an exercise that can be undertaken by local government without
                                                              additional support.
 Question 7: Are there any negative social impacts            The benefits of moving to low carbon vehicles in the long term should outweigh any negative impacts,
 associated with either the development or uptake of such     however we do need to be mindful of these – especially in the shorter term.
 technologies/fuels? If so, what are they?
                                                              One potential negative social impact is social inclusion in light of the cost of LCVs. It is likely that only
                                                              the wealthier sections of society will be able to afford to purchase LCVs in the short term future, and
                                                              subsequently gain from the benefits offered by running an LCV as well as the incentives that can be
                                                              put in place to support LCV use. Therefore, it could be argued that the promotion of LCVs will be
                                                              discriminatory and will marginalise those sectors of society that cannot afford LCVs – at least until
                                                              such time as the markets for these vehicles have fully developed and there economies of scale allow
                                                              for price reductions.

                                                              There is also a risk to the fuel poor should a rising demand for electricity, be it through EVs or
                                                              electrolysis to create hydrogen result in increased electricity prices.
 Question 8: What, if any, technical challenges would the     Many of our members feel strongly about the need to reinforce the grid. In the context of low carbon
 grid reinforcement upgrades be likely to present? How        vehicles, and especially electric vehicles, it is essential the energy supply used is low carbon as well –
 might these be overcome?                                     so this means the grid needs to be able to handle the large scale generation of renewable energy,
                                                              from whichever area of the country it is produced. It also means the grid needs to be able to handle
                                                              the demand for charging from wherever in the country it arises.

                                                              Given the importance of wind power in government generation policy, the need for a charging system
                                                              that does not penalise generation that is remote from large cities or users is important, as is the need
                                                              to reinforce the grid to allow for such generation to be developed commercially.

                                                              There must also be clearer regulation on grid access which takes deliverability (of generation) into
                                                              account and on planning, where there is a lack of guidance leading to uncertainty on what criteria will
                                                              be applied to applications whether above or below 50Mw capacity.
 Question 9: Who would fund any grid upgrades? And,           The grid is a strategic national resource and this should be taken into account in planning its future
 how might these costs be recovered?                          role, capacity and reach. It is not reasonable to penalise "remote" on shore wind generators given
                                                              their role in delivering UK targets. Access charges to the grid should be uniform and the costs borne
                                                              universally. Electric vehicles will only make sense if the power to recharge them is generated from
                                                              renewable or nuclear resources.

                                                              Given its national importance this can only fall to energy producers or the UK Government to fund.
                                                              This should be seen as falling into the category of spending that needs to take place to mitigate
                                                              against climate change as outlined by Stern in order to avoid the longer term costs to society of
                                                              increased climate change.




                                                                              8
Question 10: Do any of the technologies present any            There are likely to be challenges in terms of distances between charging points for, and the time it
specific challenges or opportunities to island                 takes to charge the cells of, electric vehicles in rural areas. This could also apply to the availability of
communities and sparsely populated rural areas in              other types of alternative fuels/energy. A significant issue will be the range of low carbon vehicles.
Scotland? If so, how might these challenges by                 We are aware of a rural demonstration project using an electric vehicle by Badenoch & Strathspey
addressed, and by whom?                                        Community Transport Company. We are interested in the findings from this project in terms of the
                                                               viability of such vehicles in rural settings.

                                                               In order to avoid social disparities created by the introduction of low carbon vehicles on a wider scale
                                                               it is important that the government take into account any structural disadvantages to uptake in rural
                                                               areas and make suitable accommodation for continued effective transport in rural areas.
Question 11: Do you think that having a twin approach for      There is a very strong argument to the setting of different targets for public sector fleet up take of
the public sector and other users is appropriate? If so,       LCVs. By setting targets for such a reasonably large and regular purchaser the required critical mass
why? If not, why not?                                          can hopefully be created to ensure that new products are brought to market. The range and type of
                                                               vehicles that public sector organisations require to deliver services may of course dilute this effect to
                                                               some extent.

                                                               Furthermore, it must be realised that public sector agencies do not operate in a financial vacuum. It is
                                                               broadly accepted that the adoption of any new technology comes with a financial overhead. It is not
                                                               realistic for public sector organisations, such as Local Authorities, to bear the full financial burden that
                                                               will undoubtedly result from the more ambitious targets proposed in the consultation.

                                                               Central and Local Government has a valuable role to play in “mainstreaming” new and emerging low
                                                               carbon technologies. However in the current, and future, financial settlement conditions it is ever
                                                               more important that investment decisions lead to improved customer service. While it is true that the
                                                               “greater good” is served by a quick transition to low carbon vehicles, Local Authorities have to protect
                                                               front line service delivery.

                                                               Central Government is quite right to attempt to harness the purchasing power of all public sector
                                                               agencies, but must appreciate that the financial “overhead” that comes with this must not be taken
                                                               from current financial settlements. Central Government needs to be prepared to take an appropriate
                                                               share of risk and/or additional costs incurred.
Question 12: If so, should targets relate to the uptake of     The consultation document does not currently contain a single definition of what constitutes a „low
low carbon vehicles (either as a percentage of the fleet or    carbon vehicle‟ and what is included within the fleet. Any targets adopted need to be clearly defined
an absolute number), or a reduction in total emissions         and capable of implementation. There are certainly arguments on either side of this question around
across the fleets or another format of target? Why?            measuring outputs (%LCVs in the fleet) or outcomes (total emissions) as well as the cost
                                                               effectiveness of action and the marginal abatement cost curve.
                                                               Given the wide range of different carbon emissions that appear to potentially fall within the description
                                                               of a low carbon vehicle, if the targets relate to uptake, consideration should be given to targets for
                                                               different emission groups. This is an approach that follows logically from the projections discussed in
                                                               section 4.7 of the consultation.

                                                               Secondly, it may be that different targets are appropriate for different purposes. The outcome sought
                                                               from the use of Low Carbon Vehicles (LCVs) is a contribution to Scotland‟s emissions of greenhouse
                                                               gases by 80% by 2050. Reduction in total emissions across the fleet is unambiguous and is clearly
                                                               the outcome ultimately sought. Therefore it would seem important that the total reduction in the
                                                               emissions from fleets is covered by a target, probably one relating to the whole Scottish Vehicle Fleet.
                                                               Otherwise, depending on the definition of LCVs, even if the LCV proportion of the Scottish fleets is
                                                               100%, an increase in fleet size/mileage could mean that total emissions reductions may not be
                                                               sufficient to meet transport„s contribution to overall targets (or, in extremis, could even increase).

                                                               Care will need to be taken in calculating the emissions from the fleet, a figure for emissions at point of
                                                               use would disguise the generation of electricity by means that themselves produce greenhouse
                                                               gases. If practical, it would be desirable to consider emissions based on a source to wheel basis for
                                                               Scotland‟s fleet. As noted in the document the crucial issue of life cycle emissions will also need to be
                                                               tackled sooner rather than later (this clearly needs to take account of average vehicle life).

                                                               However it may well be appropriate to set uptake targets for the public sector, or possibly more
                                                               widely, in the short to medium term when the main focus will be on building the market and
                                                               infrastructure for LCVs rather than necessarily delivering large emissions reductions. (As noted in the
                                                               consultation and above these will be heavily dependent on achieving low carbon electricity).
Question 13: If we follow a target relating to the public      At this stage in the development of LCVs it is difficult to see how a percentage target can be
sector uptake of LCVs, what percentage of the fleet            accurately set for 2020. The transition towards a LCV fleet will be dependent on the ability of the
should be LCVs by 2020? Please give reasons for your           market to deliver the wide range of vehicles that are required by the public sector, from front line
answer.                                                        emergency vehicles to specialist snow clearing plant and refuse collection vehicles. At the moment
                                                               many of our members do not believe that a 100% target as proposed in the document is achievable,
                                                               and would argue that this either reduced or wholesale exemptions offered (see below).
                                                               Further detailed investigation will be required to fully understand the available options, the range of
                                                               vehicles that are available, and the cost overhead that will result from early adoption of technology. It
                                                               is too simplistic to set an arbitrary figure without full consideration of the broad range of inputs that all
                                                               have to be in place and the potential incentives/assistance that may be put in place to facilitate uptake
                                                               by the public sector.
Question 14: If we follow a target relating to the uptake of   The concerns expressed above in relation to the availability of LCVs and the speed of development
LCVs across all road users, what percentage of all new         also apply to the percentage uptake across all road users.
vehicles should be LCVs by 2020? Please give reasons
for your answer.
Question 15: Are there any vehicle categories that should      Examples of vehicles that would need to be excluded from any target include emergency vehicles
be excluded from the public sector target? If so, what are     such as ambulances, fire engines and coastguard vehicles, where the need for reliability, based on
they and why should they be excluded? If not, why not?         proven technologies, is very important. While awaiting the development of electric fast charging
                                                               technology, it may be necessary to exclude vehicles used for gritting roads and other emergency
                                                               response vehicles. These vehicles need a quick turn around, whilst in use in keeping roads open and
                                                               safe. Refuse collection vehicles are intensive energy users, as are snow ploughs, and there appears
                                                               to be no alternative other than using high carbon fuels for them. Obviously alternatives to fossil fuels
                                                               can be found.

                                                               In short, any service vehicle where efficiency of the service offered is adversely effected by change
                                                               should be excluded until such time as technology is sufficiently advanced not to effect service.
Question 16: As LCVs may have higher upfront costs             We believe that the public sector has a key role to play in the adoption of LCVs. As the consultation
than traditional vehicles (albeit with a smaller               papers states, through public sector procurement of LCVs, economies of scale in production could
discrepancy between lifecycle costs) do you consider it        result, which in turn should lower production costs. In the longer term, this may reduce the price of
to be efficient use of public resources to devote a greater    LCVs for consumers and consequently lead to further increases in demand.
short-term budget towards the purchase of LCVs? If so,
why? If not, why not?                                          However, as stated previously, it is not realistic for the public sector to shoulder the full financial
                                                               burden for early adoption. Further detailed investigation is required to fully understand the full benefit
                                                               that can be delivered by early adoption and how this can be balanced against the potential short term
                                                               impacts on service delivery through the diversion of limited funds.
Question 17: Are there any opportunities or barriers to        Initial availability of appropriate vehicles for the public sector could potentially pose a barrier.
public sector procurement of LCVs that are not                 Even more important is the anticipated constraints on budgets as a result of the current economic
mentioned in this document? If so, what are they?              recession and the intention of the UK Government to reduce public expenditure over the coming
                                                               years. Without financial support from the Scottish Government and or other mechanisms to




                                                                               9
                                                             overcome the current cost disadvantages of LCVs, uptake of LCVs by the public sector is likely to be
                                                             low.

                                                             Infrastructure issues will also likely come into play. Local authority staff may initially need to start
                                                             using a battery electric vehicle from their homes. If these vehicles are charged from their domestic
                                                             electricity supply, a means of metering the amount used for charging their employer's vehicle will be
                                                             required in order to permit the accurate reimbursement of staff expenses incurred in vehicle charging
                                                             for work purposes. Smart charging, ensuring that all cars don‟t start to recharge at points of
                                                             maximum demand will become another matter requiring technical advances.
Question 18: What are the individual roles of different      The European Commission, or the European Investment Bank, could provide financial contributions
groups and organisations in ensuring the provision of        towards LCV demonstration projects, as well as opportunities for the exchange of information on best
any infrastructure required for low carbon vehicles?         practice and strategy development. It is desirable that the United Kingdom and Scottish Governments
                                                             continue to support the introduction of LCVs through awards by the Technology Strategy Board,
                                                             Alternative Fuels Infrastructure Grants Programme and Low Carbon Vehicles Demonstration Project.

                                                             Local authorities, as partners in such projects or with external funding from the above sources, could
                                                             provide areas or sites for demonstrations of infrastructure. They could use conditions of planning
                                                             consent to ensure that developers provide LCV infrastructure at new developments. Although rather
                                                             than approaching the climate change interface with planning in a piecemeal way, it may be better that
                                                             in the current overhaul of planning guidance the opportunity of providing a level playing field between
                                                             authorities is taken.

                                                             Separately, local authorities could co-operate with other public sector bodies on the joint purchase of
                                                             LCVs for their fleets to benefit from any economies in bulk buying. Commercial suppliers would have
                                                             the role of providing the infrastructure and fuels.
Question 19: Are there other supply side/capacity            The transportation and storage of alternative fuels is an important supply issue which is not fully
constraints impacting on LCV development and uptake?         considered within the consultation document. There is a real need to consider how sufficient
If so, what are they?                                        quantities of any new fuel can be created, transported, and stored efficiently, allowing it to be
                                                             accessible to all communities. In the case of electric vehicles the same concerns hold for the supply
                                                             of charging points. See suggestions in answer to Q18.
Question 20: Are there barriers to the development of an     Barriers to the development of a Scottish LCV industry might include skills shortages in appropriate
indigenous low carbon vehicle industry in Scotland? If       specialisations, the potential need (and time lag involved) to retrain workers, and issues with the grid
so, what are they and how might they be overcome?            as discussed above.

                                                             Partnership working with the education sector including universities should be helpful in moving
                                                             forward with regards to skills issues. Concerns over the grid capacity should be addressed by the
                                                             UK/Scottish Governments in consultation with local authorities and other stakeholders.
Question 21: Should Scotland’s industry focus on             Currently Scottish businesses have focussed on the bus and small van sectors. It would appear that
particular vehicle types? If so, what are they and why? If   current business models have justified this investment. It would make sense for the Scottish industry
not, why not?                                                to focus on specialist vehicles, such as buses, mini buses, and small vans given that they are already
                                                             developed in these fields.

                                                             However there are many parts within the supply chain and companies such as Axeon have already
                                                             demonstrated an ability to provide parts for a wide range of vehicles. It is therefore essential that
                                                             existing, new, and emerging industry sectors do not limit their aspirations.
Question 22: Are there gaps in the supply chain? If so,      One gap is that of a refuelling infrastructure. It is likely that there will be a time lag before the number
what are they and how might these be overcome?               of low carbon vehicles in use means that new refuelling infrastructure is commercially viable. The
                                                             Scottish Government should consider grants for installation of this infrastructure or revenue support
                                                             that declines over time with the growing demand from low carbon vehicles.
Question 23: Do we have the required skills base for the     The technical knowledge exists but will not be applied without a financial support scheme to promote
development of this market? If not, where are the gaps?      demand.
Question 24: How could the various stakeholders              To promote the uptake of LCVs, the full range of benefits that LCVs can deliver must be conveyed to
collaborate to stimulate the development and uptake of       the wider public through a range of media. In addition to the environmental benefits, the longer term
LCVs?                                                        economic benefits should also be heavily promoted if consumers are to be encouraged to purchase
                                                             LCVs over cheaper alternatives.

                                                             The Scottish Government could work with the United Kingdom Government to agree tax based
                                                             incentives and disincentives to promote the use of low carbon vehicles.

                                                             Establishing specifications for LCV charging or fuelling points, to ensure the maximum compatibility
                                                             between vehicles and their energy supplies would also be helpful. Local authorities and the business
                                                             community could then develop commercial re-charging points for business and leisure vehicle use,
                                                             knowing that they are compatible with the existing and future fleet of low carbon vehicles.




                                                                            10
R4 – Dundee City Council


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Alex Stephen
 Organisation:                                             Dundee City Council
 Address:                                                  21 City Square, Dundee
 Postcode:                                                 DD1 3BY
 Email:
 Telephone Number:                                         01382 434201
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Those fuels currently either in general supply or being trialled are likely to be the first influencers of GHG
 do you envisage will be first to be influential in        emissions (e.g. Electric Vehicles (EVs), biofuels, and hybrids).
 reducing GHG emissions from the transport sector?
 Why?                                                      For EVs, any true reduction in emissions will only be gained provided that the source of power for
                                                           recharging the batteries is via a renewable source whereby the emission levels of the power regenerator do
                                                           not compromise that of the vehicle. It is likely that the limitations in practical application are going to be the
                                                           main barrier for this to have any major impact on GHG reduction. Whilst biofuels do have the potential to
                                                           make a significant contribution towards
                                                           reducing emissions from the transport sector, wider environmental and social issues relating the sustainable
                                                           production of the crop are having concerns at national level. Although the current commonly used 5%
                                                           biofuel mix is seen to provide no noticeable change in vehicle performance, other difficulties arise when
                                                           increasing this percentage. Maintenance of the vehicles become more frequent and vehicle manufacturers
                                                           may look to reduce the warranty. It is also doubtful whether there is enough domestic (Le. national)
                                                           commercial waste oil available in the sector to make this a viable fuel against collection issues and
                                                           reprocessing costs.
 Question 2: Which low carbon technologies and fuels       The low carbon technology andlor fuel that may have the greatest GHG abatement impact is likely to result
 do you believe will ultimately have the greatest          from a combination of many factors. Most important to this may the advancement of the technology to such
 emissions abatement impact? Why?                          as state that it
                                                           becomes financially viable to manufacture and at the same time has a large economy of scale.

                                                           The key driver will be public demand for the most consumer-friendly options where purchase cost and local
                                                           supply of readily available fuels may play key roles in any consumer spending decision.

                                                           Ultimately, Electric and Hydrogen fuel cell technology may provide the greatest impact. Where the
                                                           production of electricity can be sourced from renewable energy sources then any impact on GHG will be
                                                           minimal. As far as hydrogen is concerned, marked reductions may only be achievable if the technology can
                                                           be developed to produce it viably. Current production of hydrogen is consuming more power to produce
                                                           than it will ultimately produce through its use and therefore countering any gains that can be made.
 Question 3: What timescales do you believe are            It is difficult to identify timescales for the development of specific low carbon technologies and fuels due to
 feasible for the development of specific low carbon       factors such as political influence and financial support that are likely to determine the level and speed at
 technologies and fuels? Are there any important           which LCVs are
 intermediate milestones within these timescales?          developed.
 Question 4: What timescales do you believe are the        Likely to be dependent upon factors such as cost to the end user, effectiveness and reliability. Whichever
 feasible for the uptake of specific low carbon            technology/fuel becomes available has to be sustainable as previous initiatives have been short lived and
 technologies and fuels? Are there any important           the support infrastructure whittled away to the point of collapse. Cost to the end user is likely to be the
 intermediate milestones within these timescales?          major factor, as current costs within the public and private sectors for fossil fuels are of great financial
                                                           concern as well as increasing burden. The introduction of new technology would therefore have to come
                                                           with reduced costs or other incentives for it to be palatable to both sectors. The technology will also have to
                                                           be reliable to inspire confidence and affect uptake. In the current financial climate, the general public may
                                                           be more won over more on the financial incentives rather than their personal impact on GHG.
 Question 5: Are there other barriers to the               Securing long-term funding is likely to be a major factor in the advancement of any technological research
 development of such fuels and technologies that are       and development. Targeting those technologies/fuels that are identified as having the greatest impact on
 not mentioned in this document? If so, what are           the reduction of GHG, securing funding and then supporting them to ensure they are achievable in the
 they?                                                     shortest timeframe may produce the greatest results.
 Question 6: Are there other barriers to the uptake of     Public confidence and acceptability will be crucial. Without this, a sustainable and rapid uptake of any new
 such fuels and technologies that are not mentioned        technology, whether it reduces GHG or not, is unlikely.
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         With battery driven technology currently at the forefront of LCV development, the environmental impacts of
 associated with either the development or uptake of       pursuing the raw materials required to produce them and end of life disposal are important factors that need
 such technologies/fuels? If so, what are they?            to be considered.
                                                           Questions remain over the recycling and disposal of Lithium-ion batteries at end of life and the
                                                           environmental impacts of the whole life cycle of any new technology needs to be a major part of the
                                                           equation, as this may have a
                                                           negative impact. What may be gained in one area may be to the detriment in others. Increased costs to be
                                                           borne by all will invariably have a negative impact on disposable income within any household. Potential
                                                           adverse effects could be created for those living on low incomes if green taxes or levies were to be
                                                           introduced. It is therefore suggested an
                                                           equality impact assessment be undertaken for the proposed policies.
 Question 8: What, if any, technical challenges would      No comment to make.
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             No comment to make.
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any       As long as any island or sparsely populated area has a similar level of access to that of their mainland
 specific challenges or opportunities to island            counterparts then this should not be a problem. In some cases it may transpire that access/requirement in
 communities and sparsely populated rural areas in         rural areas is greater.
 Scotland? If so, how might these challenges by            Historical data on consumption per head of population within these areas should identify whether this is the
 addressed, and by whom?                                   case or not.
 Question 11: Do you think that having a twin              A twin approach from the public sector is appropriate but would require financial support from central
 approach for the public sector and other users is         government as the initial cost of LCVs is difficult to justify by any local authority. It is appreciated that
 appropriate? If so, why? If not, why not?                 someone has to take a leap of faith. Local authorities must however ensure the provision of best value to
                                                           the public and with continued budget savings, additional funding and support from central government
                                                           would be required. Even if every local authority within Scotland committed completely to LCV, purchase of
                                                           this magnitude may not have a sufficiently marked effect on price reduction to a level of acceptability for the
                                                           public at large to follow suit.
 Question 12: If so, should targets relate to the uptake   It is suggested that a target for the uptake of LCVs within the public sector should be measured by an
 of low carbon vehicles (either as a percentage of the     overall reduction in fleet emission levels within specific timeframes. This would allow each local authority to
 fleet or an absolute number), or a reduction in total     structure their fleet accordingly to suit their specific requirements for service delivery to the public. Fleet
 emissions across the fleets or another format of          managers could then identify the percentage of LCVs required to meet the emissions targets. This approach
 target? Why?                                              would have the added advantage of being an incentive to work more efficiently and use fewer vehicles
                                                           where possible.
 Question 13: If we follow a target relating to the        Setting a percentage of the fleet to be LCVs by 2020 may not achieve the GHG reductions as desired. It is




                                                                               11
public sector uptake of LCVs, what percentage of the      suggested that a target for the uptake of LCVs within the public sector should be measured by an overall
fleet should be LCVs by 2020? Please give reasons         reduction in fleet emission levels within specific timeframes. This would allow each local authority to
for your answer.                                          structure their fleet accordingly to suit their specific requirements for service delivery to the public. Fleet
                                                          managers could then identify the percentage of
                                                          LCVs required to meet the emissions targets. This approach would have the added advantage of being an
                                                          incentive to work more efficiently and use fewer vehicles where possible.
Question 14: If we follow a target relating to the        It is suggested that trying to quantify the percentage levels of LCVs by 2020 is not the way to approach or
uptake of LCVs across all road users, what                achieve the level of GHG reduction by that date. Dependant on how fleets are structured, set targets can
percentage of all new vehicles should be LCVs by          only be achieved by the
2020? Please give reasons for your answer.                level of GHG reduction each manufacturer claims their vehicles are capable of. This factor will govern what
                                                          the percentage level will be within any given fleet. It would not be appropriate to speculate what the level of
                                                          percentage would be as technology advances and related cost to the purchaser within the next 10 years will
                                                          stimulate and dictate the level of LCVs that will be on the roads at that time.
Question 15: Are there any vehicle categories that        All vehicle categories should be included in the public sector target otherwise a two tier system may
should be excluded from the public sector target? If      emerge. The push toward GHG reduction should also apply equally across the board for all manufacturers.
so, what are they and why should they be excluded?        It is acknowledged that
If not, why not?                                          some will have a greater contribution toward GHG reduction than others due to the size, type and
                                                          application of vehicle each manufacturer produces. If this is not all encompassing then how are the
                                                          public/private sectors able to achieve GHG reduction to the levels set for 2020.
Question 16: As LCVs may have higher upfront costs        It is not a case of LCVs may having upfront costs than traditional vehicles, they do have and by a large
than traditional vehicles (albeit with a smaller          margin, doubling if not trebling the cost. Short term investment of public resources may send out the wrong
discrepancy between lifecycle costs) do you               message and not
consider it to be efficient use of public resources to    promote a confident incentive for the public at large to embrace this. Sustained investment will promote
devote a greater short-term budget towards the            confidence for others to come on board. Once a high level of acceptance and sustainability is evident in the
purchase of LCVs? If so, why? If not, why not?            market place then public investment could be reviewed and tempered accordingly.
Question 17: Are there any opportunities or barriers      There are opportunities, however the barriers to these are mainly financial especially so in the current
to public sector procurement of LCVs that are not         economic climate and local authority budget reductions.
mentioned in this document? If so, what are they?
Question 18: What are the individual roles of different   LCV manufacturers will be looking for public/private investment for the product. This would be in the
groups and organisations in ensuring the provision        support infrastructure Le. prioritised parking places with vehicle recharging points for EVs and PHEVs,
of any infrastructure required for low carbon             alternative fuel refuelling facilities at service stations etc. Without the infrastructure in place to enable LCV
vehicles?                                                 users a easy and efficient recharging/refuelling process, then manufacturers will not be able to sell the
                                                          desired quantity of LCVs. Promotion of LCVs to potential purchasers must create confidence within the
                                                          market place to ensure a robust and acceptable residual value of these vehicles when they go into the
                                                          second hand market as initial investors will be looking for a fair return on their purchase. Without this, it
                                                          may be difficult to achieve the uptake rate required to meet any targets.
Question 19: Are there other supply side/capacity         It is suggested that further consultation within the appropriate research and development sectors be
constraints impacting on LCV development and              undertaken on this question. Uptake would be only constrained if demand were to outstrip supply through
uptake? If so, what are they?                             capacity expansion and
                                                          planning delays.
Question 20: Are there barriers to the development of     No. Any barriers to any development are likely to be financial. Investors, government grants and incentives
an indigenous low carbon vehicle industry in              that would make it attractive for an indigenous LCV industry would have to be available.
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          Yes, initially. Those LCV that would be the quickest to develop and get into production and have the
particular vehicle types? If so, what are they and        greatest impact in GHG reduction should be targeted. Once it was seen that Scotland had the technology
why? If not, why not?                                     and capability this should
                                                          stimulate further investment and research leading to future manufacture and production.
Question 22: Are there gaps in the supply chain? If       No comment to make.
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      Further investment and development of the Scottish skills base in both R&D and manufacture is essential to
the development of this market? If not, where are the     meet the national climate change targets. In Axeon, Dundee already has an EV battery systems
gaps?                                                     manufacturer that supplies two of the UK's leading electric vehicle suppliers.
Question 24: How could the various stakeholders           If the public sector is to take the lead in stimulating further uptake by the private . sector and the public' at
collaborate to stimulate the development and uptake       large, a positive and confident approach to the introduction of LCVs within fleets would be the best
of LCVs?                                                  approach. LCVs could be
                                                          made available through the Scotland Excel procurement framework with greater development and
                                                          promotion of available LCV leasing options to the public and private sectors. This may in turn stimulate the
                                                          initial investment and uptake of LCVs within company fleets.




                                                                              12
R6 - East Dunbartonshire Council


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Paul Curran
 Organisation:                                             East Dunbartonshire Council
 Address:                                                  Hilton Depot, Balmuildy Road, Bishopbriggs, Glasgow
 Postcode:                                                 G64 3QW
 Email:
 Telephone Number:                                         0141 5745781
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Efficiency improvements to the internal combustion engine and vehicle technology will be most effective in
 do you envisage will be first to be influential in        reducing the GHG emissions.
 reducing GHG emissions from the transport sector?
 Why?                                                      This is consequential to the fact that the vast majority of vehicles in operation run on fossil fuels which is
                                                           unlikely to change significantly in medium term. If the 30% fuel efficiency saving identified in the king report
                                                           is achievable it would have a major impact across the entire transport sector, not just in a small
                                                           percentage of the car market as would be the case for other technologies.
 Question 2: Which low carbon technologies and fuels       Hybrid vehicle technology of all guises coupled with internal combustion efficiency savings. This technology
 do you believe will ultimately have the greatest          is already available within sectors of the transport industry and will generate savings across all sectors of
 emissions abatement impact? Why?                          road transport with varying carbon reduction results.

                                                           Whilst still expensive to introduce, it is likely to be a more affordable and realistic option over fully electric,
                                                           plug-in hybrid or hydrogen fuelled vehicles.

                                                           Loss of payload on commercial and light commercial vehicles is a significant hurdle which would require to
                                                           be overcome prior to hydrogen or electric vehicles taking a major share of the road transport market.
 Question 3: What timescales do you believe are            In general terms vehicle technology is advancing year on year at a steady pace with the introduction of
 feasible for the development of specific low carbon       diesel particulate filters (DPF), continuous regeneration traps (CRT), selective catalytic reduction (SCR)
 technologies and fuels? Are there any important           and exhaust gas recirculation (EGR) all playing a major part in reducing emissions and meeting ever
 intermediate milestones within these timescales?          changing European emission standards Euro 3, 4 ,5 etc.

                                                           More specifically, hybrid vehicle technology will continue to improve and develop over the next 5 – 10 years
                                                           along with advances in vehicle technology.

                                                           Improvements in battery power, storage and weight technology will be key in rolling this technology out to
                                                           the light commercial and larger commercial vehicle sectors where range and payload are major
                                                           considerations.
 Question 4: What timescales do you believe are the        Due to a range of factors it is likely to be 5-10 years for both private customers and industry to embrace low
 feasible for the uptake of specific low carbon            carbon technologies and fuels. Economic conditions, personal and business finances will prevent major
 technologies and fuels? Are there any important           spend in this area. Consumers and business are keeping vehicles for longer which will slow down the shift
 intermediate milestones within these timescales?          to newer technology. The necessary infrastructure will be required to support the uptake of the new
                                                           technologies and fuels. Cost premium over existing technology will influence consumers and the road
                                                           transport industry decision makers.
 Question 5: Are there other barriers to the                None at this time.
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     None at this time.
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts          Production of bio-fuels required to be harvested from sustainable sources. Need for infrastructure to
 associated with either the development or uptake of       support various different fuel technologies on a national scale.
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would      The main challenges would come from ensuring the future development and upgrading of the grid to
 the grid reinforcement upgrades be likely to present?     include more efficient energy production methods.
 How might these be overcome?
                                                           Low carbon technology energy production sources including renewable such as wind, wave & hydro would
                                                           be required to match the most efficient and effective grid configuration otherwise there would be no actual
                                                           benefit over existing technology.
 Question 9: Who would fund any grid upgrades?             It is likely that due to the vast sums of money involved a partnership arrangement between the UK
 And, how might these costs be recovered?                  government and the national grid / energy suppliers would be required.

                                                           The cost would likely be recovered over a longer term period and potentially though taxation on fuels and
                                                           electricity.
 Question 10: Do any of the technologies present any       Electric vehicles would pose a significant challenge for island and rural communities due to current range
 specific challenges or opportunities to island            limitations with this technology, these areas are generally undulating and hilly terrain which further reduces
 communities and sparsely populated rural areas in         the vehicles range.
 Scotland? If so, how might these challenges by            Regardless of the technology used the cost of providing an infrastructure for these communities is likely to
 addressed, and by whom?                                   expensive.

                                                           There is the potential for utilising renewable energy sources through the use of wind, wave and hydro
                                                           power stations.
 Question 11: Do you think that having a twin              It is entirely appropriate that local government should lead the way in the move towards a low carbon
 approach for the public sector and other users is         vehicle fleet. This however must be matched by sufficient funding to ensure other essential services do not
 appropriate? If so, why? If not, why not?                 suffer in order to meet the increased costs of procuring this technology.
 Question 12: If so, should targets relate to the uptake   In order to ensure parity across all Council fleets it would be better to set a percentage target for all
 of low carbon vehicles (either as a percentage of the     councils. This would be the most straight forward method.
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        A figure of 20%-25% should be achievable if technology continues to advance within the car and light
 public sector uptake of LCVs, what percentage of the      commercial vehicle sector.
 fleet should be LCVs by 2020? Please give reasons
 for your answer.                                          Mainstream manufacturers currently produce cars and light vans producing sub 100g/km CO2 which are
                                                           exempt from vehicle excise duty.
 Question 14: If we follow a target relating to the        A figure of 10% - 15% could be achieved.
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by          This figure is likely to be lower than local government due to the fact that personal choice and lifestyle
 2020? Please give reasons for your answer.                factors will play a far greater part in influencing the decision process.

                                                           Additionally, private vehicles are changed less frequently than most local authority and fleet vehicles
                                                           therefore any improvement is likely to take longer to have an impact on the figures.




                                                                                13
Question 15: Are there any vehicle categories that        High value specialised commercial vehicles and plant.
should be excluded from the public sector target? If
so, what are they and why should they be excluded?        Whilst there is a desire and requirement to reduce the impact of road transport emissions, it is essential that
If not, why not?                                          best value and full useful asset life is considered in the process.
Question 16: As LCVs may have higher upfront costs        At present, the cost differential is too great and as such would not be considered efficient use of public
than traditional vehicles (albeit with a smaller          resources. This is more clearly demonstrated with the 3.8 million pound investment for 40 vehicles in the
discrepancy between lifecycle costs) do you               Glasgow Electric Car Pilot over a three year period.
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      A major barrier to the procurement of LCVs within the public sector is the need to remain competitive whilst
to public sector procurement of LCVs that are not         carrying additional costs not bourn by private industry. This is compounded by reduction in budgets and
mentioned in this document? If so, what are they?         increasingly onerous legislation within the transport sector.

                                                          Some local authority premises infrastructure is aging beyond useful life and is not fit for purpose. Such
                                                          properties would not be capable of meeting the requirements of some of the LCV technologies going
                                                          forward.
Question 18: What are the individual roles of different   Energy and fuel suppliers will be required to ensure infrastructure is developed at a pace in line the relevant
groups and organisations in ensuring the provision        fuel technologies in order to meet demand.
of any infrastructure required for low carbon
vehicles?                                                 It is likely that significant funding and government support will be required as the technology moves forward.
Question 19: Are there other supply side/capacity         Given the major skills shortage of technicians, engineers and mechanics within this sector at present, it is
constraints impacting on LCV development and              likely that the introduction of this technology will provide further challenges to the industry going forward.
uptake? If so, what are they?
                                                          Specialist training specific to the various systems will be required along with familiarisation and induction for
                                                          staff working with the new technology.

                                                          The recent economic downturn has had a major impact on both the vehicle and truck industry.
                                                          Manufacturers may struggle to meet the major costs associated with the development and tooling for
                                                          production of this technology.
Question 20: Are there barriers to the development of     Whilst Scotland has good coverage of Manufacturers‟ main dealer networks, there are no car or truck
an indigenous low carbon vehicle industry in              manufacturing plants in Scotland.
Scotland? If so, what are they and how might they be
overcome?                                                 This is unlikely to change due to the additional costs associated with transporting raw materials and
                                                          component parts from suppliers within the UK and beyond
Question 21: Should Scotland’s industry focus on          No firm view on this.
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If       No firm view on this.
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      No - As identified earlier, there is a significant shortage of skilled technicians and engineers within the Road
the development of this market? If not, where are the     Transport Industry.
gaps?
Question 24: How could the various stakeholders           Collaboration across all sectors of the road transport industry should be specific to what is practical and
collaborate to stimulate the development and uptake       achievable for each sector whilst achieving best use of the public purse. The focus should be on what will
of LCVs?                                                  work and deliver the best results.

                                                          In order to deliver real benefits in reducing carbon emissions across the Road Transport industry, there
                                                          needs to be a realisation that all methods of reducing carbon are of benefit. This includes advances in
                                                          internal combustion engine efficiency and associated technology, which is, in reality where the majority of
                                                          savings will be made within the light and heavy Commercial vehicle fleet including buses and coaches.

                                                          Hybrid, plug-in hybrid, Electric and hydrogen technology is simply too expensive and present major hurdles
                                                          to be overcome before ever being considered mainstream in the commercial vehicle and bus coach sectors.
                                                          In addition to this the percentage savings expected are not that far removed from the King report saving of
                                                          around 30% through advances in internal combustion engine and vehicle technology efficiency savings over
                                                          the next 5-10 year period.




                                                                              14
R7 – City of Edinburgh Council


 RESPONDENT INFORMATION DETAILS
 Name:                                                   Clive Brown
 Organisation:                                           City of Edinburgh Council
 Address:                                                City Development, City Chambers, 249 High Street, Edinburgh
 Postcode:                                               EH21 7SP
 Email:
 Telephone Number:                                       0131 469 3630
 Responding as:                                          On behalf of group or organisation
 Individual Permission:                                  Not supplied
 Confidentiality:                                        Not supplied
 Group or Organisation:                                  Yes
 Share Response Permission:                              Yes
 Question 1: Which low carbon technologies and fuels
 do you envisage will be first to be influential in      Hybrid vehicles are likely to be amongst the first technologies to make a contribution, due to applying
 reducing GHG emissions from the transport sector?
                                                         proven technology currently used in cars and buses. However the simplicity (so potential for lower capital
 Why?
                                                         costs) and low running costs of full electric vehicles may mean that these technologies are the first to make

                                                         a major impact.
 Question 2: Which low carbon technologies and fuels     Ultimately emissions need to reduce dramatically, beyond the 30% the consultation notes for full hybrids.
 do you believe will ultimately have the greatest        The UK Government‟s Committee on Climate Change (UKCCC) envisages very wide scale adoption of zero
 emissions abatement impact? Why?                        emission vehicles by 2030 in the scenario which meets the recently set 80% by 2050 greenhouse gas
                                                         reduction targets .

                                                         It is difficult to say today whether the most promising technology is full electric vehicles, hydrogen or
                                                         perhaps some other point of use power source, such as compressed air. All these technologies require
                                                         large amounts of low carbon electricity supply if they are to deliver overall reductions in greenhouse gas
                                                         emissions. Bearing this in mind the UKCCC suggestion that de - carbonisation of electricity supplies
                                                         requires early focus and action seems fully justified. Public sector operators run large fleets that, by and
                                                         large, have predictable patterns of use; they should be in a strong position (with appropriate support - see
                                                         below) for the early introduction of technologies such as full electric vehicles. The operation of electric
                                                         vehicles in urban areas will clearly assist other objectives, notably in reducing emissions of local air
                                                         pollutants, such as particulates and Nitrogen Oxides.
 Question 3: What timescales do you believe are          Many low carbon technologies, as identified in the consultation document, are already available and have
 feasible for the development of specific low carbon     been utilised in demonstrations or small scale service. Hybrid cars, such as the Toyota Prius are
 technologies and fuels? Are there any important         commercially available, battery electric cars have been trialled, as with the Th!nk @bout Edinburgh project
 intermediate milestones within these timescales?        and fuel cells successfully demonstrated in European projects such as Clean Urban Transport for Europe
                                                         (CUTE). The key issues are affordability, range and ability to chargehefuel. For some vehicle types (e.g.
                                                         refuse lorries) weight and other factors relating to the degree to which vehicles are „fit for purpose‟ are
                                                         issues.
 Question 4: What timescales do you believe are the      Many low carbon technologies, as identified in the consultation document, are already available and have
 feasible for the uptake of specific low carbon          been utilised in demonstrations or small scale service. Hybrid cars, such as the Toyota Prius are
 technologies and fuels? Are there any important         commercially available, battery electric cars have been trialled, as with the Th!nk @bout Edinburgh project
 intermediate milestones within these timescales?        and fuel cells successfully demonstrated in European projects such as Clean Urban Transport for Europe
                                                         (CUTE). The key issues are affordability, range and ability to chargehefuel. For some vehicle types (e.g.
                                                         refuse lorries) weight and other factors relating to the degree to which vehicles are „fit for purpose‟ are
                                                         issues.

                                                          A key issue, as identified in the consultation document, is affordability. If the public sector is to lead the
                                                         uptake then it is crucial that appropriate incentives are in place. Expenditure is likely to be constrained over
                                                         the next few years. Local authorities could explore the possibility of using prudential borrowing to fund the
                                                         purchase of low emission electric vehicles on the basis of lower whole life costs. It is desirable for the
                                                         Scottish Government to provide local authorities
                                                         with regular updates of whole life cost information. If, in the early years, there are no savings, then the
                                                         Scottish Government should consider grants to assist the uptake of Low Carbon Vehicles.
 Question 5: Are there other barriers to the             There are numerous issues around biofuels that need to be fully addressed if these fuels are to play any
 development of such fuels and technologies that are     part in carbon reduction strategies. Doubts exist over net emissions reductions (for complex reasons
 not mentioned in this document? If so, what are         including fuel use during production and greenhouse gas emissions from land being turned over to biofuel
 they?                                                   use), air quality impacts and displacement of food crops, among other issues. Some studies have reported
                                                         that bio diesel results in increased emissions of nitrogen oxides and that the use of bioethanol indirectly
                                                         increases ozone concentrations, via the formation of aldehyde. Biomethane is promising as a transport fuel
                                                         in terms of air quality and greenhouse gases. However, the supply and use of biomethane carries the risk of
                                                         releasing methane, which is a far more potent greenhouse gas than carbon dioxide. There numerous other
                                                         issues around biofuels Extending the adoption of biofuels should be approached cautiously. Impacts on
                                                         food production, vulnerable ecosystems and species, local air quality, health need to be addressed.
                                                         Furthermore, and crucially, it must be clear that the net impact on
                                                         Greenhouse Gas emissions is positive to a worthwhile degree.
 Question 6: Are there other barriers to the uptake of   One of the advantages of current fleet of internal combustion engined vehicles is that there is compatibility
 such fuels and technologies that are not mentioned      between fuelling systems and vehicles. A barrier to the uptake of battery electric vehicles is the current lack
 in this document? If so, what are they?                 of convenient charging points. Many residential properties have garages or drives where domestic electricity
                                                         supplies could be used. However, in urban areas with flats or tenement properties, kerb side charging at
                                                         parking spaces for residents will be essential, unless numerous fast charging stations are available eg at
                                                         petrol filling stations. A number of electric vehicle charging points have been installed in London and
                                                         elsewhere in the UK, but are designed to charge vehicles from 13 amp sockets. This may set a de facto
                                                         standard for charging points, without covering fast chargers that can be used with lithium - ion batteries. To
                                                         assist the development of low carbon vehicles it would be very helpful if the specification of recharging and
                                                         fuelling points and their matching vehicle receptors could be made at a national or international level. This
                                                         would provide a common standard for vehicle manufacturers and suppliers of charging equipment, to allow
                                                         compatibility of their equipment and generate consumer confidence in buying low carbon vehicles. For
                                                         example, to charge battery electric and plug - in hybrid vehicles it may be necessary to initially specify
                                                         separate slow and fast charging equipment. The slow chargers could be deployed mainly in locations where
                                                         vehicles are likely to be stationary for some time, such as off - street car parks, residential parking bays and
                                                         park and ride sites. Fast charging equipment could be sited where a rapid turnaround is required, as at
                                                         electric filling stations, bus layover points and fleet depots.
 Question 7: Are there any negative social impacts       We are not aware of any such impacts other than as a secondary effect of environmental issues mentioned
 associated with either the development or uptake of     elsewhere.
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would    We have no response on this issue.
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?           We have no response on this issue, other than that the Government needs to ensure that, given the
 And, how might these costs be recovered?                urgency and critical importance of tackling climate change, it does all that it can to facilitate necessary
                                                         changes.
 Question 10: Do any of the technologies present any     We have no response on this issue other than to note that it is important that challenges in such areas do
 specific challenges or opportunities to island          not delay adoption of low carbon vehicle technology elsewhere. Government should put in place




                                                                            15
communities and sparsely populated rural areas in         appropriately flexible policies/grant regimes etc to facilitate this.
Scotland? If so, how might these challenges by
addressed, and by whom?
Question 11: Do you think that having a twin              We agree that a twin approach to the public sector and other users is appropriate. Public sector fleets
approach for the public sector and other users is         operate in a non - commercial environment and are therefore in a better position to cope with the risks of
appropriate? If so, why? If not, why not?                 introducing new designs of low carbon vehicles (assuming that central government is prepare to take an
                                                          appropriate share of any risk and/or additional costs). Public sector fleets also tend to operate in defined
                                                          areas. As mentioned above, this is likely to be helpful in dealing with the range issues of electric vehicles. In
                                                          addition any financial assistance from the Scottish Government will be retained in Scotland. Clarification is
                                                          needed as to whether “arm‟s length” companies owned by local authorities, such as Lothian Buses plc,
                                                          should be counted as part of the public sector fleet.
Question 12: If so, should targets relate to the uptake   This question raises major issues.
of low carbon vehicles (either as a percentage of the
fleet or an absolute number), or a reduction in total     Firstly, the document does not currently opt for a single definition of what constitutes a „low carbon vehicle‟.
emissions across the fleets or another format of          It is imperative that any targets adopted are clearly defined, otherwise they will be ineffective. Given the
target? Why?                                              wide range of different carbon emissions that appear to potentially fall within

                                                          the description of a low carbon vehicle, if the targets relate to uptake, consideration should be given to
                                                          targets for different emission groups. This is an approach that follows logically from the projections
                                                          discussed in section 4.7 of the consultation. Secondly, it may be that different targets are appropriate for
                                                          different purposes. The outcome sought from the use of Low Carbon Vehicles (LCVs) is a contribution to
                                                          Scotland‟s emissions of greenhouse gases by 80% by 2050. Reduction in total emissions across the fleet is
                                                          unambiguous and is clearly the outcome ultimately sought. Therefore it would seem important that the total
                                                          reduction in the emissions from fleets is covered by a target, probably one relating to the whole Scottish
                                                          Vehicle Fleet. Otherwise, depending on the definition of LCVs, even if the LCV proportion of the Scottish
                                                          fleets is loo%, an increase in fleet size/mileage could mean that total emissions reductions may not be
                                                          sufficient to meet transport„s contribution to overall targets (or, in extremis, could even increase). Care will
                                                          need to be taken in calculating the emissions from the fleet, a figure for emissions at point of use would
                                                          disguise the generation of electricity by means that themselves produce greenhouse gases. If practical, it
                                                          would be desirable to consider emissions based on a source to wheel basis for Scotland‟s fleet. As noted in
                                                          the document the crucial issue of life cycle emissions will also need to be tackled sooner rather than later
                                                          (this clearly needs to take account of average vehicle life) However it may well be appropriate to set uptake
                                                          targets for the public sector, or possibly more widely, in the short to medium term when the main focus will
                                                          be on building the market and infrastructure for LCVs rather than necessarily delivering large emissions
                                                          reductions. (As noted in the consultation and above these will be heavily dependant on achieving low
                                                          carbon electricity).
Question 13: If we follow a target relating to the        Please see the response to question 12 in relation to the definition of LCVs. We note that the United
public sector uptake of LCVs, what percentage of the      Kingdom Committee on Climate Change has modelled potential uptake rates across a number of scenarios,
fleet should be LCVs by 2020? Please give reasons         including:
for your answer.
                                                                        „Current Ambition‟; measures that would cost less per tonne than the forecast carbon price,
                                                                        and/or which are covered by policies already in place.

                                                                        „Extended Ambition‟; more ambitious assumptions on the penetration of energy efficiency
                                                                        improvements and measures that would cost appreciably more per tonne of carbon abated
                                                                        than the predicted carbon price.



                                                                        „Stretch Ambition‟; adds further feasible abatement opportunities for which no policy
                                                                        commitment is in place, including more radical new technology deployment and more
                                                                        significant lifestyle adjustments.

                                                          Given the urgency of tackling Climate Change it would seem appropriate to set targets based around the
                                                          „stretch ambition‟ scenario for technology uptake rates in table 3 of the consultation document. Of course
                                                          adoption of such targets would need to be backed up by a package of measures designed to achieve them.
Question 14: If we follow a target relating to the        Please see the responses to questions 12 and 13.
uptake of LCVs across all road users, what
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        Emergency vehicles such as ambulances, fire engines and coastguard vehicles, where the need for
should be excluded from the public sector target? If      reliability, based on proven technologies, is very important. While awaiting the development of electric fast
so, what are they and why should they be excluded?        charging technology, it may be necessary to exclude vehicles used for gritting roads and other emergency
If not, why not?                                          response vehicles. These vehicles need a quick turn around, whilst in use in keeping roads open and safe.
Question 16: As LCVs may have higher upfront costs        In principle yes, with the provisos that:
than traditional vehicles (albeit with a smaller
discrepancy between lifecycle costs) do you               a. The vehicles being purchased have the potential become commercially viable
consider it to be efficient use of public resources to    in the reasonably near future.
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?            b. They have potential to significantly reduce greenhouse gas emissions.

                                                          Application of short - term budgets towards the purchase of LCVs could create demand that leads to
                                                          economies of scale and increases their commercial viability. It could also help to increase familiarity with the
                                                          technologies and start to get the necessary support infrastructure in place. See also answer to Q4 in relation
                                                          to prudential borrowing.
Question 17: Are there any opportunities or barriers      A potential barrier to public sector procurement is the anticipated constraints on budgets as a result of the
to public sector procurement of LCVs that are not         current economic recession. Without financial support from the Scottish Government and or other
mentioned in this document? If so, what are they?         mechanisms to overcome the current cost disadvantages of LCVs, uptake of LCVs by the public sector is
                                                          likely to be low. Some local authority staff, in the course of their duties, may need to start using a battery
                                                          electric vehicle from their homes. If these vehicles are charged from their domestic electricity supply, a
                                                          means of metering the amount used for charging their employer's vehicle will be required. This will permit
                                                          the accurate reimbursement of staff expenses incurred in vehicle charging for work purposes.
Question 18: What are the individual roles of different   The European Commission could provide financial contributions towards LCV demonstration projects, as
groups and organisations in ensuring the provision        well as opportunities for the exchange of information on best practice and strategy development. It is
of any infrastructure required for low carbon             desirable that the United Kingdom and Scottish Governments continue to support the introduction of LCVs
vehicles?                                                 through awards by the Technology Strategy Board, Alternative Fuels Infrastructure Grants Programme and
                                                          Low Carbon Vehicles Demonstration Project. Local authorities, as partners in such projects or with external
                                                          funding from the above sources, could provide areas or sites for demonstrations of infrastructure. They
                                                          could use conditions of planning consent to ensure that developers provide LCV infrastructure at new
                                                          developments. Local authorities could co-operate with other public sector bodies on the joint purchase of
                                                          LCVs for their fleets to benefit from any economies in bulk buying. Commercial suppliers would have the
                                                          role of providing the infrastructure and fuels.
Question 19: Are there other supply side/capacity         We have no response on this issue.
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of     We have no response on this issue
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?




                                                                              16
Question 21: Should Scotland’s industry focus on        Electric vehicles could be the principle focus in Scotland, as they can be powered by renewable energy and
particular vehicle types? If so, what are they and      have zero emissions at point of use. It may make sense to focus on buses as there is already bus
why? If not, why not?                                   manufacturing capacity in Scotland.
Question 22: Are there gaps in the supply chain? If     Response: One gap is that of a refuelling infrastructure. It is likely that there will be a time lag before the
so, what are they and how might these be overcome?      number of low carbon vehicles in use means that new refuelling infrastructure is commercially viable. The
                                                        Scottish Government should consider grants for installation of this infrastructure or revenue support that
                                                        declines over time with the growing demand from low carbon vehicles
Question 23: Do we have the required skills base for    We have no response on this issue.
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         The Scottish Government could work with the United Kingdom Government to agree tax based incentives
collaborate to stimulate the development and uptake     and disincentives to promote the use of low carbon vehicles. As suggested in our response to question 6,
of LCVs?                                                by establishing specifications for LCV charging or fuelling points, to ensure the maximum compatibility
                                                        between vehicles and their energy supplies. Local authorities and the business community could then
                                                        develop commercial re-charging points for business and leisure vehicle use, knowing that they are
                                                        compatible with the existing and future fleet of low carbon vehicles.




                                                                           17
R8 - Fife Council


 RESPONDENT INFORMATION DETAILS
 Name:                                                 Tom C Robertson
 Organisation:                                         Fife Council
 Address:                                              Fire and Rescue Service HQ, Strathore Road, Thornton
 Postcode:                                             KY1 4DF
 Email:
 Telephone Number:                                     08451 55 55 55
 Responding as:                                        On behalf of a group or organisation
 Individual Permission:                                Not Supplied
 Confidentiality:                                      Not supplied
 Group or Organisation:                                Yes
 Share Response Permission:                            Yes
 Question 1: Which low carbon technologies and fuels   The first technologies to reduce GHG emissions will come from efficient diesel technology. This can already
 do you envisage will be first to be influential in    be seen as car, van and truck manufacturers are reducing the carbon emissions from their vehicles. This
 reducing GHG emissions from the transport sector?     will happen because at this stage it won‟t require major re-tooling of factories, etc. The technology is well
 Why?                                                  proven therefore will easily be accepted by the public and there are not fuelling or infrastructure issues.
                                                       There could be an increase in the use of biofuels e.g. ethanol, biodiesel and biogas provided Government
                                                       incentives are in place.

                                                       Camden Biomethane Trial Results
                                                       The trial compared two Iveco Daily dedicated gas vehicles operating on a street cleansing cycle. One Iveco
                                                       Daily was fuelled with biomethane and the other by natural gas. The trial sought to compare the vehicles
                                                       with respect to performance, emissions, reliability and usability.

                                                       Leeds City Council Biomethane Trial
                                                       Currently, Leeds City Council is leading the way in testing out two biomethane-powered refuse vehicles.
                                                       The refuse vehicles consist of a Mercedes Benz Econic-M906 LAG natural gas engine running on
                                                       compressed biomethane gas (CBG) and a Dennis Eagle dual fuel diesel / biomethane-powered unit fitted
                                                       with a Hardstaff fuel injection system. Both vehicles are supported by Gasrec who produce the liquid
                                                       biomethane and provide the fuelling infrastructure. The six month trial sets out to assess the performance
                                                       of Compressed Biomenthane Gas (CBG) powered refuse vehicle, collecting domestic and recyclable waste
                                                       in a typical Council environment. The trial aim is to demonstrate that biomethane is a technically competitive
                                                       and environmentally sound fuel that can be directly substituted for natural gas and diesel. Environmental
                                                       performance will be assessed through quantifying CO2 reduction. Leeds City Council has got to be
                                                       congratulated in taking this initiative as a large number of Councils in Scotland are considering this option
                                                       but due to lack of hard fact information are not willing to take the plunge. It is interesting to note that natural
                                                       gas is used extensively throughout the world as a transport fuel. There are circa 7,296,595 gas vehicles
                                                       operating in the world which breaks down to 7,000,000 light duty vehicles, 164,000 buses and 134,000
                                                       HGVs.

                                                       Glasgow Electric Car Pilot
                                                       Glasgow City Council is currently trialling 40 electric vehicles produced by Allied Vehicles Glasgow.
                                                       Dundee-based Axeon will supply the batteries for the cars. The results of the pilot will be shared with APSE
                                                       Scottish Group Members.

                                                       Nissan
                                                       Currently Nissan is in the process of unveiling a new electric car capable of carrying 5 passengers up to
                                                       100miles prior to recharge. A boost battery re-charge takes approximately 30minutes and a full recharge
                                                       takes 8 hours. The EV can be charged through your household mains 240v. If the vehicle is competitively
                                                       priced and funding is in place to support the battery charge point infrastructure we foresee a market for this
                                                       product.
 Question 2: Which low carbon technologies and fuels   Hydrogen fuel cell vehicles could have the greatest benefit, however this will only work if the hydrogen
 do you believe will ultimately have the greatest      required to operate these vehicles can be produced efficiently and with a low carbon impact. Fuel cell
 emissions abatement impact? Why?                      vehicles don‟t require a long recharge or refill time therefore will be popular with the public, who should be
                                                       able to operate them in the same way as a conventional ICE vehicle. Large Commercial Vehicles powered
                                                       by natural gas could also have a major impact. The current economic and environmental climate has
                                                       increased the interest for alternative road fuels e.g. Liquid Natural Gas (LNG), Compressed Natural Gas
                                                       (CNG) and Compressed Biomethane Gas (CBG).

                                                       Biomethane is created during the anaerobic digestion process. Anaerobic digestion is a process where
                                                       organic matter naturally breaks down in the absence of air. The gas produced during this process is known
                                                       as biogas and mainly consists of carbon dioxide (CO2) and methane (CH4) at a mix of approximately 35%
                                                       and 65% respectively. The combustion of biogas produced from the anaerobic digestion of recently
                                                       composed organic matter such as waste, biomass and manure is said to be carbon neutral. The Camden
                                                       Biomethane Trial Results concluded that there was no reduction in performance, reliability and usability and
                                                       claim a 70% reduction in CO2 emissions.
 Question 3: What timescales do you believe are        Low carbon vehicles will probably take a number of years to develop. The industry is currently in the
 feasible for the development of specific low carbon   development stages moving from lower carbon diesel vehicles to hybrids to full electric and then eventually
 technologies and fuels? Are there any important       an efficient hydrogen fuel cell. Examples of hybrids tested to date, consist of LPG/ petrol and Compressed
 intermediate milestones within these timescales?      Natural Gas (CNG) / diesel. The problem with hybrids is that they are inevitably retrofits and hence not
                                                       covered by full manufacturers‟ warranty. This progression through the various technologies is important and
                                                       it will create a gradual culture change.
 Question 4: What timescales do you believe are the    Legislation will probably drive change, as an example the Clean Vehicles Directive introduces a requirement
 feasible for the uptake of specific low carbon        for public sector bodies under contractors, by 1st January 2012, to take account of energy and
 technologies and fuels? Are there any important       environmental impacts when purchasing vehicles. The Directive provides choices in the way in which public
 intermediate milestones within these timescales?      sector bodies comply with the latter. Scotland Excel are currently leading with this regard and their influence
                                                       together with Local Authorities could accelerate the process.



                                                       People will start to move towards low carbon technologies; however there will need to be incentives such as
                                                       the current reduced road fund licence for cars. Important milestones will be when we see manufacturers go
                                                       into greater production of low carbon vehicles, the technologies are proven / affordable and the
                                                       infrastructure to support these vehicles is widely available.


 Question 5: Are there other barriers to the           The main barriers to the development of such fuels and technologies are a) the initial capital cost and b) the
 development of such fuels and technologies that are   supporting infrastructure costs. There are also some issues in terms of whole-life costing and reliability to
 not mentioned in this document? If so, what are       consider.
 they?                                                 With reference to the fleet procurement strategy of Councils, there needs to be adequate funding to support
                                                       the changes. Contact has been made with Energy Saving Scotland Advice Centre South East Changeworks
                                                       who have advised us that (up to 50%) funding could be available for storage tanks, dispensers and civil
                                                       works for the production of Biomethane for vehicles.

                                                       We are led to believe that the Department for Transport funds the Infrastructure Grant Programme. This is
                                                       facilitated by Cenex Centre of Excellence for low carbon and fuel cell technologies www.cenex.co.uk




                                                                           18
                                                          Alternative (i.e. alternatives to diesel or petrol) road fuels offer a means of cutting carbon dioxide and air
                                                          pollutant emissions, as well as reducing dependence on fossil fuels. Examples of alternative fuels include
                                                          hydrogen, electricity for electric vehicles and natural gas/biogas. For fleet operators the cost of installing
                                                          refuelling or recharging infrastructure represents a barrier to switching fuel use. As part of the UK
                                                          Government‟s strategy to decrease carbon emissions from road transport, grants are available to encourage
                                                          organisations to install refuelling or recharging stations for alternative fuels. Funding is available for
                                                          hydrogen, electric, natural gas/biogas stations and other non traditional fuels.
Question 6: Are there other barriers to the uptake of     Getting major manufacturers to change their products will be a key barrier. Although the document
such fuels and technologies that are not mentioned        highlights some small manufacturers who are either producing or adapting vehicles, this won‟t be enough to
in this document? If so, what are they?                   make a significant impact to the vehicle supply chain.

                                                          In terms of vehicles running on Natural Gas the quality of the gas is a real concern to Fleet Transport
                                                          Managers and Engineers. Continuous fuel analysis is required to ensure that the fuel calorific value is
                                                          maintained and that all water and moisture is removed from the methane during processing of the fuel. If
                                                          this quality control is not adhered to the engine wear on pistons and valves etc can become very expensive.

                                                          Currently there is no UK standard for Biomethane road fuel and clearly there is a requirement that these
                                                          new fuels are regularly monitored by trading standards or a similar body.
Question 7: Are there any negative social impacts         Unless low carbon vehicles have a similar look and performance to that of an ICE vehicle, there is a high
associated with either the development or uptake of       probability that people won‟t want them.
such technologies/fuels? If so, what are they?
Question 8: What, if any, technical challenges would      Nil response
the grid reinforcement upgrades be likely to present?
How might these be overcome?
Question 9: Who would fund any grid upgrades?             Grid upgrades would need to be funded by the supplier and the costs recovered through the supply rates.
And, how might these costs be recovered?
Question 10: Do any of the technologies present any       It may be that some of the technologies might be less suitable to small island communities due to supply
specific challenges or opportunities to island            issues. It may therefore be best for the people or authorities who live and work in these areas to consider
communities and sparsely populated rural areas in         what technologies are best supported by that type of environment.
Scotland? If so, how might these challenges by
addressed, and by whom?                                   Locally produced and used fuel could be a major plus for isolated Scottish communities. The most likely
                                                          solution would be the production of Biomethane from a sustainable source.
Question 11: Do you think that having a twin              The public sector should be leading by example, therefore it is important that the technologies they pick for
approach for the public sector and other users is         their fleet should encourage members of the public to follow their example and consider low carbon
appropriate? If so, why? If not, why not?                 transport options.
Question 12: If so, should targets relate to the uptake   Targets should relate to the uptake of LCVs rather than a reduction in carbon across the fleet. Doing it this
of low carbon vehicles (either as a percentage of the     way ensures a reduction in carbon emissions that can easily be checked, whereas it could be very difficult
fleet or an absolute number), or a reduction in total     to actually measure any carbon reductions if it was based on total emissions.
emissions across the fleets or another format of
target? Why?
Question 13: If we follow a target relating to the        At least 75% of public sector vehicles should be LCVs by 2020 rather than the 100% mentioned. The
public sector uptake of LCVs, what percentage of the      technologies should be widely available by then and even with tight financial restrictions; most public bodies
fleet should be LCVs by 2020? Please give reasons         will have replaced their poorest performing vehicles by this time.
for your answer.
Question 14: If we follow a target relating to the        Around 50% across the board. Some of this may happen naturally as vehicles meet higher emission
uptake of LCVs across all road users, what                standards. However, hopefully the major manufacturers will have embraced the idea of low carbon
percentage of all new vehicles should be LCVs by          technologies – government initiatives / penalties may also help achieve this level.
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        No vehicle should be excluded from low carbon technology, however it can be difficult to get vehicles to
should be excluded from the public sector target? If      operate efficiently if they are require to be driven at very slow speeds or operate when stationary. These
so, what are they and why should they be excluded?        vehicles would include, but would not be limited to, refuse collection vehicles, gully cleaners and gritters.
If not, why not?
Question 16: As LCVs may have higher upfront costs        The Public Sector must lead by example, otherwise it will be difficult to obtain “buy in” from the general
than traditional vehicles (albeit with a smaller          public. It is therefore very important that budget is made available for low carbon technology.
discrepancy between lifecycle costs) do you
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      We would say that the main barriers would be getting high volumes of vehicles into the public sector,
to public sector procurement of LCVs that are not         particularly given that most of the companies mentioned in this document are relatively small in terms of
mentioned in this document? If so, what are they?         vehicle production/ adaptation. This can also lead to potential issues relating to product support and
                                                          reliability.
Question 18: What are the individual roles of different   A key role of the government will be to encourage and financially support the development of an
groups and organisations in ensuring the provision        infrastructure which can be available to all. Certainly to kick start the programme the public sector should
of any infrastructure required for low carbon             look at depot based infrastructure to support their LCVs and use the experience gained from that to feed
vehicles?                                                 back into the system to develop a better and more efficient infrastructure.
Question 19: Are there other supply side/capacity         It is our opinion, as previously stated, that to move this forward more quickly, major manufacturers need to
constraints impacting on LCV development and              get involved in the supply of LCVs. The companies mentioned in this document will have limited supply
uptake? If so, what are they?                             capacity.
Question 20: Are there barriers to the development of     There are no real barriers to the development of LCVs in Scotland other than the fact that there is no major
an indigenous low carbon vehicle industry in              car, van or truck manufacturer in Scotland. As an example Allied vehicles with Axeon batteries appear to be
Scotland? If so, what are they and how might they be      able to provide such a vehicle – our question would be “what is their supply capacity as a percentage of
overcome?                                                 vehicles supplied in Scotland?”
Question 21: Should Scotland’s industry focus on          Probably best to focus on the industries, such as Allied that already exist in Scotland and can provide a
particular vehicle types? If so, what are they and        range of cars and vans. Encouraging new manufacturers into the country could be difficult and may require
why? If not, why not?                                     some financial incentives
Question 22: Are there gaps in the supply chain? If       One issue in the supply chain may relate to EVs. In these vehicles the battery will possibly need to be
so, what are they and how might these be overcome?        replaced once it drops below the performance criteria of the end user.

                                                          This creates a problem in that one company may need to sell you the vehicle and another the battery. This
                                                          type of arrangement can make it difficult to put lease costs against a vehicle or work out a residual value.
Question 23: Do we have the required skills base for      Yes – We believe we have the skills to develop this type of market.
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           If the various stakeholders could agree on a number of generic specifications and also then commit to
collaborate to stimulate the development and uptake       volumes, this would give the supplier the confidence to invest in their product and negotiate better deals on
of LCVs?                                                  parts supply, which should in turn make the vehicles less expensive.




                                                                             19
R9 - Glasgow City Council


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Patti MacLeod
 Organisation:                                             Glasgow City Council
 Address:                                                  Development and Regeneration Services, 229 George Street, Glasgow
 Postcode:                                                 G1 1QU
 Email:
 Telephone Number:                                         0141 287 9372
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       It is likely that the first technologies to reduce greenhouse gas (GHG) emissions will come from efficient
 do you envisage will be first to be influential in        diesel technology. This can already be seen as car, van and truck manufacturers are reducing the carbon
 reducing GHG emissions from the transport sector?         emissions from their vehicles with this technology.
 Why?


                                                           In the car market, electric vehicles (EVs) look the most likely to be market ready in large numbers and,
                                                           therefore, will shortly also be able to make significant reductions. At a later stage, in the larger vehicle
                                                           market, biogas technology is likely to be utilised to reduce GHG emissions.


                                                           To contribute to the air quality targets it is important that Low Carbon technologies and fuels for buses are
                                                           advanced at an early stage.


 Question 2: Which low carbon technologies and fuels       Ultimately, hydrogen fuel is likely to have the greatest impact. However in the short to medium term (the
 do you believe will ultimately have the greatest          next decade) EVs will probably have the greatest emissions impact. For larger vehicles, biogas offers
 emissions abatement impact? Why?                          significant potential.


 Question 3: What timescales do you believe are            Electric vehicles: the technology is developed and ready and mass production is likely to take 2 years.
 feasible for the development of specific low carbon       For viable hydrogen vehicles, the key enabler will be an improved turnaround efficiency of hydrogen
 technologies and fuels? Are there any important           production.
 intermediate milestones within these timescales?          For Biogas, the technology already exists.


 Question 4: What timescales do you believe are the        As reply to question 3 above but with a 3 year „lag time‟ for uptake of vehicles.
 feasible for the uptake of specific low carbon            The milestones would be the incentives and provision of supply and suitable infrastructure.
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               For biogas, the infrastructure needed to capture gas needs to be developed and incentives are needed to
 development of such fuels and technologies that are       stimulate use of biogas for transport. For the other technologies there are no known barriers to
 not mentioned in this document? If so, what are           development. However subsidy or support of some sort may be needed to stimulate development.
 they?

                                                           Social barriers will also require to be addresses. The misconceptions about the use and efficiency of Low
                                                           Carbon Vehicles will require to be overcome through effective demonstration of the products.


 Question 6: Are there other barriers to the uptake of     Need to provide incentives for the public to encourage use of biogas to make costs comparable to fossil
 such fuels and technologies that are not mentioned        fuels. Encouragement should be offered to major manufacturers to help meet market demand.
 in this document? If so, what are they?

 Question 7: Are there any negative social impacts         Sufficient electrical generation is important when dealing with rising demand for electricity, be it through EVs
 associated with either the development or uptake of       or electrolysis to create hydrogen. This may be necessary to prevent the price of electricity rising which
 such technologies/fuels? If so, what are they?            could penalise people who are in fuel poverty.


 Question 8: What, if any, technical challenges would      From a local authority perspective challenges would occur from the management of disruption caused by
 the grid reinforcement upgrades be likely to present?     excavation of roads and footways.
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             Given that it is a Government initiative to promote the use of E.V. it would appear reasonable that
 And, how might these costs be recovered?                  Government would fund appropriate infrastructure.


 Question 10: Do any of the technologies present any       Given the opportunities for renewable generation, either on a large- or micro-generation scale, technologies
 specific challenges or opportunities to island            such as EVs and hydrogen present opportunities for these remote communities. As remote areas are
 communities and sparsely populated rural areas in         already charged more for fossil fuels as a result of their location, the financial case to bring forward these
 Scotland? If so, how might these challenges by            technologies may be more favourable in these parts of the country.
 addressed, and by whom?
                                                           This has already been demonstrated through the PURE (Promoting Unst Renewable Energy) project on
                                                           Unst.


 Question 11: Do you think that having a twin              A twin approach may be wise in the short term to stimulate demand, but as the private market is important,
 approach for the public sector and other users is         in the longer term a single approach for all vehicles may be better.
 appropriate? If so, why? If not, why not?
                                                           The public sector should be lead by example, to encourage members of the public to consider low carbon
                                                           transport options.


 Question 12: If so, should targets relate to the uptake   Targets should relate to a reduction in carbon emissions across the fleet.
 of low carbon vehicles (either as a percentage of the     Targets are a good way to drive LCV takeup and benchmark progress, however sufficient incentive is
 fleet or an absolute number), or a reduction in total     required to ensure the targets set do not incur too great a financial burden on each authority
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        At least 75% of public sector vehicles should be LCV‟s by 2020 rather than the 100% mentioned. The
 public sector uptake of LCVs, what percentage of the      technologies should be widely available by then and even with tight financial restrictions; most public bodies
 fleet should be LCVs by 2020? Please give reasons         will have replaced their poorest performing vehicles by that time.
 for your answer.
 Question 14: If we follow a target relating to the        At the moment around 50% would appear realistic. However major manufacturers need to embrace the idea
 uptake of LCVs across all road users, what                of low carbon technologies and to this end government initiatives / penalties could help achieve a higher
 percentage of all new vehicles should be LCVs by          level.
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        Any service vehicle where efficiency of the service offered is adversely effected by change should be




                                                                               20
should be excluded from the public sector target? If      excluded until such time as technology is sufficiently advanced not to effect service.
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        The Public Sector should be seen to lead by example, otherwise it will be difficult to obtain “buy in” from the
than traditional vehicles (albeit with a smaller          general public. It is therefore very important that funding is made available for the development of low
discrepancy between lifecycle costs) do you               carbon technology.
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      Before targets are set, the government should be confident that a sufficient number of LCVs will be
to public sector procurement of LCVs that are not         available to allow public sector bodies to procure these vehicles. Furthermore, the costs must be
mentioned in this document? If so, what are they?         understood so that unacceptable costs do not occur for public sector bodies.


Question 18: What are the individual roles of different   Government will have to encourage and financially support the development of an infrastructure which can
groups and organisations in ensuring the provision        be available to all. The public sector should look at depot based infrastructure to support their LCV‟s and
of any infrastructure required for low carbon             use the experience gained from that to feed back into the system to develop a better and more efficient
vehicles?                                                 infrastructure.
Question 19: Are there other supply side/capacity         A major constraint would be a lack of available vehicles and related infrastructure to meet demand.
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of     In addition to companies such as Allied and Axeon, Scotland already has a high proportion of renewable
an indigenous low carbon vehicle industry in              energy, vital to make the emissions impact of LCVs (in the case of EVs) more significant. Grid support and
Scotland? If so, what are they and how might they be      other related issues could be further examined by universities.
overcome?

Question 21: Should Scotland’s industry focus on          For cars, EVs appears to be the technology to focus on in the short term, but it is difficult to exclude any
particular vehicle types? If so, what are they and        technology. For larger vehicles, biogas and related technology currently appears to be the most relevant.
why? If not, why not?                                     Therefore, where possible, all technologies should be considered.
Question 22: Are there gaps in the supply chain? If       For EVs, supply appears to be increasing; however co-ordination needs to be developed with regard to the
so, what are they and how might these be overcome?        supply chain. For example, in E.V.s the battery will possibly need to be replaced once it drops below the
                                                          performance criteria of the end user. Therefore one company may need to sell you the vehicle and another
                                                          the battery. This type of arrangement can make it difficult to put lease costs against a vehicle or work out a
                                                          residual value. For biogas, infrastructure development needs to be expanded to capture gas.


Question 23: Do we have the required skills base for      Yes the skills exist to develop this type of market, however to meet demand, investment in terms of
the development of this market? If not, where are the     resources and training are needed to develop a „critical mass‟.
gaps?

Question 24: How could the various stakeholders           Glasgow City Council is helping stimulate development of EVs through Ultra Low Carbon Vehicle
collaborate to stimulate the development and uptake       Demonstrator Programme and Procurement Programme for vans. More involvement in these types of
of LCVs?                                                  programmes should be encouraged to stimulate the market in the country.




                                                                             21
R10 - Highland Council


 RESPONDENT INFORMATION DETAILS
 Name:                                                     William MacPherson
 Organisation:                                             Highland Council
 Address:                                                  Glenurquhart Road, Inverness
 Postcode:                                                 IV3 5NX
 Email:
 Telephone Number:                                         01463 702665
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       An initial shift from petrol to diesel / bio-diesel will show an immediate saving on carbon emissions but this
 do you envisage will be first to be influential in        will need to be balanced against the perceived health issues surrounding particulate matter. Hybrid
 reducing GHG emissions from the transport sector?         petrol/electric vehicles is likely to provide the biggest influence but as this technology is found mainly in the
 Why?                                                      car market some encouragement needs to be given to manufacturers to include this in the commercial
                                                           sector. All electric vehicles will also have a significant influence but there will need to be a large investment
                                                           in the infrastructure for recharging and financial support to people to encourage uptake.
 Question 2: Which low carbon technologies and fuels       Hydrogen power will ultimately provide the greatest reduction in emissions for light vans and cars. Within
 do you believe will ultimately have the greatest          the proposals for electric vehicles, the cost of lithium-ion for battery power will, in the short term, however
 emissions abatement impact? Why?                          make costs prohibitive for the general market place, together with the increased costs of waste disposal.
                                                           Consideration should also be taken of the expansion into the heavy vehicle market of CNG and LNG power.
                                                           Account should also be taken of the short term benefits of LPG power against petrol vehicles.
 Question 3: What timescales do you believe are            Timescales have been set by the EC for the reduction of carbon for light vans to a maximum of 175
 feasible for the development of specific low carbon       grammes by 2012 - 2015. These are feasible targets, although at a likely cost of £1,400 to £1,700 per
 technologies and fuels? Are there any important           vehicle. A further reduction to 160 grammes is proposed for 2015 and this will only be achieved is the car
 intermediate milestones within these timescales?          and commercial sector reduction limits are merged. Even here costs are likely to rise by a further 16% to
                                                           18% per vehicle. Within these timescales hybrid and electric vehicles will have improved sufficiently to be
                                                           viable although the question on initial costs and refuelling infrastructure will remain.
 Question 4: What timescales do you believe are the        Volume trials are only now being carried out on a range of commercial vehicles suitable for public sector
 feasible for the uptake of specific low carbon            use. The timescales for the trails and then the decision making on the best way forward are unlikely to be
 technologies and fuels? Are there any important           made before 2012. At this stage the EC reduction levels will have commenced. Manufacturers will then
 intermediate milestones within these timescales?          have to take account of this and gear up production to meet the target dates of 2020.
 Question 5: Are there other barriers to the               The size of the public sector vehicle fleet in Scotland is small in comparison to the overall market, and is
 development of such fuels and technologies that are       unlikely to influence manufacturers to speed up development.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     The major barrier will be the increased cost of LCV‟s and the refuelling infrastructure at a time when
 such fuels and technologies that are not mentioned        budgets are being reduced.
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         Many areas of Highland are sparsely populated, and local communities rely on rural filling stations for fuel
 associated with either the development or uptake of       supplies. Many rural filling stations are already struggling to be viable, with volumes of sales being at the
 such technologies/fuels? If so, what are they?            low end of viable. Any transition programme from current fuel types to new technology should take account
                                                           of rural filling stations, and the communities they serve.
 Question 8: What, if any, technical challenges would      Scottish demand in 2003 was 35 TWh and an output of around.43 TWh would be required in order to meet
 the grid reinforcement upgrades be likely to present?     demand in 2020. If the expected uptake of EVs is realised then according to the consultation document
 How might these be overcome?                              there could be considerable additional burden on the transmission grid. The planned grid upgrades
                                                           contained within Scottish Planning Framework II (SPF II) are actively being progressed by SHETL (SSE)
                                                           and Scottish Power. These improvements are expected to allow an additional 6.3 GW of installed capacity.
                                                           This is only sufficient to accommodate the expected growth, and does not take account of any additional
                                                           demand. For Highland the physical challenge so far relates to the civil engineering work involved with re-
                                                           routing and replacing the Beauly-Denny line and the sub-sea/under grounding of the Western Isles-Beauly
                                                           line. Other lines will be upgraded through re-stringing only (Dounreay-Beauly and Beauly-Keith).

                                                           The key technical challenge for the grid – and the distribution network as a whole – relates to predicting and
                                                           managing peak demand. As EVs are likely to be charged at off-peak times – perhaps overnight – the
                                                           technology may not have quite the impact anticipated. A sensible pricing policy may be a reasonable way
                                                           forward as suggested in the document – this could encourage off-peak charging. If demand was to be as
                                                           anticipated then of course the prospect of increasing grid capacity would need to be looked at. This may
                                                           mean additional grid networks rather than simply upgrades. A key variable is Govenment policy. This should
                                                           be trying to reduce demand or to put it another way encourage energy conservation. At present we are
                                                           anticipating a 1% increase year on year in demand but action should be taken to significantly reduce
                                                           demand and reverse this predicted increase through direct measures such as increasing the thermal
                                                           efficiency of houses, providing grant assistance for alternative technologies etc i.e. interfering with the
                                                           market. This is beginning to happen but perhaps too slowly.
 Question 9: Who would fund any grid upgrades?             There may be different models to follow but ultimately it is the consumer who pays for the upgrades. Where
 And, how might these costs be recovered?                  the demand is consumer led you would expect the grid companies to pay for the upgrades recovered at the
                                                           consumer‟s expense. Where demand is artificially driven by intervention by Government, i.e. through
                                                           incentives, the costs could be recovered through increases in tax/duty on older technologies/fuels but the
                                                           net result is the same – the consumer pays
 Question 10: Do any of the technologies present any       Regardless of the final technology selected the refuelling infrastructure will pose significant problems. With
 specific challenges or opportunities to island            the distances covered in the Highlands coupled with the sometimes severe weather conditions make the
 communities and sparsely populated rural areas in         electric option less feasible than say a hybrid. However the farming and crafting communities have a
 Scotland? If so, how might these challenges by            requirement for 4x4 types of vehicles and at this stage there is no indication that these types of vehicles are
 addressed, and by whom?                                   in development.
 Question 11: Do you think that having a twin              The public sector vehicle fleet is relatively small in real terms and it will need the merging of the private
 approach for the public sector and other users is         sector to make the vehicles cost effective to produce. In addition Scotland as a whole can have little
 appropriate? If so, why? If not, why not?                 influence and the market will be driven by European targets. It is correct that the public sector should be
                                                           looking to take a lead on this but they alone should not be expected to take on the additional cost burden of
                                                           development and refuelling infrastructures.
 Question 12: If so, should targets relate to the uptake   Targets should be set so that uptake is progressive and matches the development of LCV‟s. Initially there
 of low carbon vehicles (either as a percentage of the     are a range of targets set such as the Euro-5 and 6 emission levels for heavy vehicles, although these
 fleet or an absolute number), or a reduction in total     relate more to reduction in pollutants rather than carbon, and the introduction of low resistant “green” tyres,
 emissions across the fleets or another format of          improved aerodynamics, etc. which will all contribute to reductions. Driver training can have a positive effect
 target? Why?                                              and consideration must also be taken of replacement programmes, especially for the more specialised
                                                           vehicles where these have service lives in excess of 10 years.
 Question 13: If we follow a target relating to the        In the car and light van fleet it is entirely feasible to set a target of 25% for 2015 rising to 50% by 2020 in
 public sector uptake of LCVs, what percentage of the      addition to other measure. In the heavier market this will be more difficult as manufacturers have not yet
 fleet should be LCVs by 2020? Please give reasons         really looked into developing low carbon trucks and the technology will take a considerable time to be
 for your answer.                                          introduced. Here a target of 25% by 2020 may be possible but this will need to be monitored as
                                                           technological advances are made.
 Question 14: If we follow a target relating to the        See response to Q13.
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by




                                                                              22
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        The more specialised vehicles should be excluded. These are vehicles such as refuse collection, gully
should be excluded from the public sector target? If      emptiers, access towers, etc. where for reasons of operating mounted equipment reducing carbon
so, what are they and why should they be excluded?        emissions will pose significant difficulties. Allied to this is the replacement life cycle of specialised vehicles
If not, why not?                                          that can exceed 10years.
Question 16: As LCVs may have higher upfront costs        LCV‟s currently can be 3 to 4 times more expensive to purchase than conventional vehicles. This allied to
than traditional vehicles (albeit with a smaller          reduced operating range may result in an increased fleet to compensate. At a time of budgetary constraint
discrepancy between lifecycle costs) do you               this does not seem as an efficient use of resources which, if it does go ahead, will impact on service
consider it to be efficient use of public resources to    delivery.
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      None not previously mentioned.
to public sector procurement of LCVs that are not
mentioned in this document? If so, what are they?
Question 18: What are the individual roles of different   Until the type of technology to be used is identified the infrastructure cannot be put in place.
groups and organisations in ensuring the provision
of any infrastructure required for low carbon
vehicles?
Question 19: Are there other supply side/capacity         Public perception and awareness will play a significant role in encouraging the uptake of LCV‟s. Unless
constraints impacting on LCV development and              there is a willingness on all sides to participate and financial incentives offered uptake will be limited.
uptake? If so, what are they?
Question 20: Are there barriers to the development of     None, apart from the need for long term incentives and lack of trained personnel in the engineering sector.
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          Until all the current trials are reported it is difficult to envisage which vehicles will provide the solution.
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If       The shortage and high demand of relatively low cost Lithium –ion for batteries will result in the continuing
so, what are they and how might these be overcome?        high cost of electric vehicles.
Question 23: Do we have the required skills base for      No. Significant investment in training will be required.
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           Partnership programmes between the public and private sector is seen as the best way forward allied to
collaborate to stimulate the development and uptake       leadership and commitment to long term strategies from central government.
of LCVs?




                                                                              23
R11 – Inverclyde Council


 Name:                                                     John McWilliams
 Organisation:                                             Inverclyde Council
 Address:                                                  Environmental Services, Pottery Street, Greenock
 Postcode:                                                 PA15 2UH
 Email:
 Telephone Number:                                         01475 714 773
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Electric Vehicle and Bio-fuel technology will be the first to be influential in reducing GHG emissions. Electric
 do you envisage will be first to be influential in        vehicle technology is at a more advanced stage and it will also be easier to develop the infrastructure as
 reducing GHG emissions from the transport sector?         uptake increases Bio-fuel maybe more of an option in specific area but as mentioned in the document may
 Why?                                                      have to be part of a longer term strategy.
 Question 2: Which low carbon technologies and fuels       Electric Vehicles produce no exhaust emissions therefore it should have the greatest abatement impact on
 do you believe will ultimately have the greatest          emissions, however how the electricity is produced should also be looked at to ensure its increased
 emissions abatement impact? Why?                          requirement is produced by a source that also helps reduce Greenhouse Gases.
 Question 3: What timescales do you believe are            The Climate Change (Scotland) Bill target of 80% in 40 years is a bit ambitious albeit not impossible if
 feasible for the development of specific low carbon       everyone gets onboard and are willing to invest in research (especially the manufacturers). I also believe
 technologies and fuels? Are there any important           that not only in these difficult times but as a matter of self interest, manufacturers will not invest significantly
 intermediate milestones within these timescales?          in research until they are forced to adopt change.
 Question 4: What timescales do you believe are the        As mentioned in the previous question, uptake of Electric Vehicle technology can be achieved in the
 feasible for the uptake of specific low carbon            timescale targets identified, but these targets should be constantly reviewed and changed if required but
 technologies and fuels? Are there any important           only if there are sound reasons for the change. A few major cities could have a good infrastructure to fully
 intermediate milestones within these timescales?          support the use of this technology within 30 years.
 Question 5: Are there other barriers to the               Public Support could be one of the main barriers if Council Service provision is not maintained at the
 development of such fuels and technologies that are       expense of funding development of such fuels and technology. Company self preservation interest in
 not mentioned in this document? If so, what are           difficult financial climates and other Government priorities higher on the political agenda may also affect
 they?                                                     development.
 Question 6: Are there other barriers to the uptake of     The document covers all the barriers, public support if infrastructures are not progressed enough to keep up
 such fuels and technologies that are not mentioned        with the uptake of Low Carbon Vehicles could be one of the biggest barriers.
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         The Investment, Development and subsequent uptake of new technologies must be shared across the
 associated with either the development or uptake of       whole country (UK and locally in Scotland). No specific area should have a better knowledge and expertise
 such technologies/fuels? If so, what are they?            in the new technologies than others; this will ensure a national wider skill base and local area job protection
                                                           and ensure there is no more social division caused by Investment only in certain areas.
 Question 8: What, if any, technical challenges would      It would depend on how technology develops as this may be the biggest technical challenge to how the
 the grid reinforcement upgrades be likely to present?     plans for infrastructures of the different rural and built up areas are developed. Locations of charge points
 How might these be overcome?                              and available parking space, also their visibility (impact on environment) and the safety of the public will
                                                           also provide technical difficulties.
 Question 9: Who would fund any grid upgrades?             All parties involved should provide funding from the Government to Energy suppliers, private business and
 And, how might these costs be recovered?                  site developers.

                                                           The costs would be recovered from the normal motorist who uses the new technology but more recovered
                                                           from those who do not, also from companies who do not reach targets set for emissions. Supermarkets
                                                           chains, Leisure facilities (large theme parks), shopping malls should be charged to help recover costs but
                                                           these companies should be monitored to ensure the cost is not passed as a direct charge onto the motorist
                                                           who uses the facilities.
 Question 10: Do any of the technologies present any       The Government needs to address the challenges faced by island communities and sparsely populated
 specific challenges or opportunities to island            areas by ensuring that before it embarks on the development of these areas, research (Funded Pilot
 communities and sparsely populated rural areas in         Schemes) to identify the best /cost effective option are carried out.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              A twin approach is more appropriate. As the biggest Fleet operator the public sector must take the lead role
 approach for the public sector and other users is         to prove to the private sector that targets being set can be achieved. The setting of private sector targets
 appropriate? If so, why? If not, why not?                 can then be gauged and enforced by timescales in which the public targets were achieved. The targets
                                                           should be reasonable, reviewed and phased with the appropriate funding made available.
 Question 12: If so, should targets relate to the uptake   The make up of each individual fleet must be taken into consideration when targets are being set; it has to
 of low carbon vehicles (either as a percentage of the     be fair so that no fleet operators have unfair difficulties in reaching the set targets. A target of reducing
 fleet or an absolute number), or a reduction in total     emission levels should be set so emissions are reduced by a set amount over a given period based on
 emissions across the fleets or another format of          individual fleet make up.
 target? Why?
 Question 13: If we follow a target relating to the        The 100% in the public sector Fleet by 2020 is a target which is achievable but only if the funding is made
 public sector uptake of LCVs, what percentage of the      available and the infrastructure is in place to support the changes required. In the present climate this target
 fleet should be LCVs by 2020? Please give reasons         does not seem achievable but it can be something to work towards with a review within a few years to
 for your answer.                                          identify what target can actually be achieved.
 Question 14: If we follow a target relating to the        The 30% target for private sector should also be achievable again only if manufacturers are willing to invest
 uptake of LCVs across all road users, what                in and promote LCV‟S without passing on this cost to the motorist by making them much more expensive.
 percentage of all new vehicles should be LCVs by          The infrastructure has to be in place to encourage the private sector to meet targets, and if it is, then 30% of
 2020? Please give reasons for your answer.                new vehicles will be an achievable target. In the present climate this target maybe unachievable but it
                                                           should remain as a target but reviewed when the current economic climate improves.
 Question 15: Are there any vehicle categories that        All vehicles should be included but individual targets should be set for each vehicle group/type.
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        In order to stimulate interest the use of public resources must be used, it will only be identified as efficient
 than traditional vehicles (albeit with a smaller          use if the public purchase does stimulate private interest.
 discrepancy between lifecycle costs) do you
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      Financial support for the public sector must be made available if they are to be the leaders in LCV
 to public sector procurement of LCVs that are not         procurement. If the infrastructure is not there to support Councils who are being forced into LCV
 mentioned in this document? If so, what are they?         procurement to meet targets then service provision could be affected and this would have a negative
                                                           impact.
 Question 18: What are the individual roles of different   The different groups and organisations must show their willingness to take part in the discussions by
 groups and organisations in ensuring the provision        promoting the uptake of Low Carbon Vehicles. They should also provide assistance by providing
 of any infrastructure required for low carbon             information as required; this information should include their achievable targets for putting in place their part
 vehicles?                                                 of the infrastructure.
 Question 19: Are there other supply side/capacity         LCV Development depends mainly on the funding availability and manufacturers willingness to participate in
 constraints impacting on LCV development and              production, they must ensure availability if the demand for uptake grows.
 uptake? If so, what are they?




                                                                               24
Question 20: Are there barriers to the development of   Investment in a Scottish LCV industry must coincide with developments within the rest of the UK so that the
an indigenous low carbon vehicle industry in            infrastructures are in place around the UK to support LCV‟s. Investors may want to see a more UK national
Scotland? If so, what are they and how might they be    approach. Scottish companies who invest in LCV technology but operate UK wide could suffer if the
overcome?                                               infrastructure is not there to support them.
Question 21: Should Scotland’s industry focus on        Scotland should focus on what vehicle types are best placed in the market at the moment to allow an
particular vehicle types? If so, what are they and      infrastructure to be built which allows them to operate successfully. However technology changes constantly
why? If not, why not?                                   and we shouldn‟t put all our eggs in the one basket, we must ensure that the infrastructures required to be
                                                        put in place have a reasonable life span so not to look as if money has been put into something which
                                                        quickly becomes out of date.
Question 22: Are there gaps in the supply chain? If     There is a gap in selling LCVs to potential buyers due to the lack of infrastructure and the cost
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for    Scotland has the required skills base for developing this market.
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         The Scottish Government should chair a group of various stakeholders to encourage them to buy into the
collaborate to stimulate the development and uptake     development of LCVs. The Scottish Government should also listen to each of the stakeholders and focus on
of LCVs?                                                their individual particular strengths and expertise so that there is a unified approach in promoting the use of
                                                        LCVs to stimulate development and uptake.




                                                                           25
R12 - South Lanarkshire Council


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Dave Gibson
 Organisation:                                             South Lanarkshire Council
 Address:                                                  Land and Fleet Services, Forrest Street, Blantyre, Lanarkshire
 Postcode:                                                 G72 0DT
 Email:
 Telephone Number:                                         01968 717802
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Biofuels could be used first as the current fleet is able to accept this fuel type within the existing
 do you envisage will be first to be influential in        infrastructure without significant adoption costs. However, the percentage of biofuel within the diesel mix
 reducing GHG emissions from the transport sector?         would have to meet the engine specifications of the existing fleet. Failure to do this would affect the
 Why?                                                      warranties supplied by the vehicle manufacturers. The Scottish Government should liaise with relevant
                                                           bodies to determine an appropriate percentage mix of Biofuel and diesel and apply a common standard to
                                                           all users.
 Question 2: Which low carbon technologies and fuels       Electric vehicles, due to the current infrastructure arrangements, potentially have the greatest impact on
 do you believe will ultimately have the greatest          lowering emissions from vehicles. However, this would only be the case if there was a reduction in the
 emissions abatement impact? Why?                          carbon intensity at the source of the electricity production in future years. This would either need to happen
                                                           through the national grid or via renewable generation which would require financing in the local government
                                                           context.
 Question 3: What timescales do you believe are            Biofuel - 10+ years, however an improved source of sustainable biofuel still has to be agreed upon. The
 feasible for the development of specific low carbon       public sector must be careful to ensure that the production of biofuels does not lead to destruction of rain
 technologies and fuels? Are there any important           forests and consequent release CO2. This is an issue for public procurement which should be co-ordinated
 intermediate milestones within these timescales?          nationally. Electricity - 20+ years, there is a need to ensure that this is integrated with the government‟s
                                                           renewable energy targets. However, this is unlikely to be an option for heavy fleet such as refuse collection
                                                           vehicles. Other energy solutions would need to be found.
 Question 4: What timescales do you believe are the        Biofuel could be feasible for immediate uptake for 95% of our Local Authority fleet which currently operates
 feasible for the uptake of specific low carbon            on diesel. For the petrol vehicles this uptake would be dependant on the current leasing Biofuel - 10+ years,
 technologies and fuels? Are there any important           however an improved source of sustainable biofuel still has to be agreed upon. The public sector must be
 intermediate milestones within these timescales?          careful to ensure that the production of biofuels does not lead to destruction of rain forests and consequent
                                                           release CO2. This is an issue for public procurement which should be co-ordinated nationally. Electricity -
                                                           20+ years, there is a need to ensure that this is integrated with the government‟s renewable energy targets.
                                                           However, this is unlikely to be an option for heavy fleet such as refuse collection vehicles. Other energy
                                                           solutions would need to be found.
 Question 5: Are there other barriers to the               The social acceptability of nuclear produced electricity. Technologies relevant to traditional technologies
 development of such fuels and technologies that are       have not yet generated strong enough market forces.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     Also, more detail is also required on the re-charging aspects related to EVs, such as the network capacity
 such fuels and technologies that are not mentioned        and infrastructure creation. Current costs for low carbon vehicles, uncertainty about the technology in the
 in this document? If so, what are they?                   intermediate and long-term are also major barriers to such fuels. The accessibility to different fuel types is
                                                           extremely important. When looking at the roll out of LPG as a fuel type over the last 10 years, there has
                                                           been limited uptake, potentially due to the limited number of re-fuelling points across the country. It would
                                                           be essential to ensure that any new fuel type, e.g. hydrogen, promoted for use by the mass market would
                                                           have the appropriate numbers of supply points in place to ensure success. There will be a strong
                                                           requirement for the existing fuel providers to finance the transition to new fuel types.
 Question 7: Are there any negative social impacts         As highlighted in our response to question 5, the acceptability of nuclear power generation. Also, the social
 associated with either the development or uptake of       and environmental issues surrounding of the production of biofuels in areas that may conflict with food
 such technologies/fuels? If so, what are they?            production or in areas of environmental risk.
 Question 8: What, if any, technical challenges would      No Comment
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             No Comment
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any       The costs involved in supplying new fuel types to remote rural areas will be significant. Partnership
 specific challenges or opportunities to island            arrangements between the fuel providers and local governments may provide opportunities to develop this
 communities and sparsely populated rural areas in         supply.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              Yes in principle, but would need more information on the financial implications and government support
 approach for the public sector and other users is         framework established to manage the transition in the public sector.
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake   Any target set should ensure that an absolute reduction in overall emissions is achieved. This would allow
 of low carbon vehicles (either as a percentage of the     each Local Authority flexibility in determining the right vehicles, LCV or otherwise, to meet its level of service
 fleet or an absolute number), or a reduction in total     required and the overall emission target while allowing flexibility to promote internal targets and to
 emissions across the fleets or another format of          encourage innovation. There may also be difficulty in providing targets on uptake of LCVs at present as
 target? Why?                                              there is not yet agreement on the definition of an LCV. A baseline year, possibly linked to carbon reporting
                                                           practices, could be used to establish the year at which targets are set against.
 Question 13: If we follow a target relating to the        See response to question 12
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the        See response to question 12
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        No, research in all LCV engine types is needed to ensure that all are provided the opportunity to be fully
 should be excluded from the public sector target? If      tested/costed etc. Perhaps more research should be applied to the heavy vehicle market where the most
 so, what are they and why should they be excluded?        significant fuel usage is recorded.
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        Yes, investment is needed to create and stimulate markets, fund continuing research and development in
 than traditional vehicles (albeit with a smaller          this area, and investment is needed to create a second hand market for such vehicles. The Scottish
 discrepancy between lifecycle costs) do you               Government would need to ensure sufficient funding was available to support this investment.
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      The main barrier is the additional funds required to procure the more expensive LCV technologies,
 to public sector procurement of LCVs that are not         especially against the current financial position of local authorities, for example the consultation document
 mentioned in this document? If so, what are they?         highlights the cost of £100K in addition to the cost of a normal HGV. Grants or other financial incentives are
                                                           needed to ensure the switch to this type of fuel. There may be opportunities for local authorities to generate
                                                           methane based fuel from their municipal waste collections and ultimately operate their own vehicle fleets.




                                                                               26
                                                          This would support the national targets in the reduction of waste to landfill.
Question 18: What are the individual roles of different   The vehicle manufacturers and academic institutions are critical in providing research into all LCV vehicle
groups and organisations in ensuring the provision        types. Demonstration projects of LCVs for different industry types will be needed to ensure that the correct
of any infrastructure required for low carbon             investments are made. The requirements of a logistics organisation and a local authority will be significantly
vehicles?                                                 different and consequently will require different LCV types to meet their needs.
Question 19: Are there other supply side/capacity         Perhaps currently the capacity to manufacture the vehicles on a larger scale if demand increases. Also
constraints impacting on LCV development and              market forces are currently insufficient to generate such investment.
uptake? If so, what are they?
Question 20: Are there barriers to the development of     No comment.
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          No, currently there is a need to carry out further research in all LCV technologies. Also, it is imperative that
particular vehicle types? If so, what are they and        Scotland look at the global vehicle industry to ensure that it obtains the best product.
why? If not, why not?
Question 22: Are there gaps in the supply chain? If       We do not believe there is currently a robust supply chain in place.
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      No comment. We are unsure of the current level of skills required in this market.
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           For Local Authorities, COSLA and the Scottish Government have the opportunity to provide a co-ordinated
collaborate to stimulate the development and uptake       approach to the research and procurement of LCVs. COSLA has the power to recommend that Local
of LCVs?                                                  Authorities give a commitment to invest in such technology. Also, the national vehicle fleet
                                                          procurement/leasing contract, operated by Excel, has the buying power for approximately th e local
                                                          authorities in Scotland. This has the potential to encourage the development of the LCV market and could
                                                          provide a cost effective method of procuring LCVs.
Additional Comments                                       Although we are supportive of ambitious targets, as detailed within section 2.3.2 of the consultation
                                                          document, we believe the targets are unrealistic in terms of funding pressure within Local Authorities and in
                                                          terms of the alternative power vehicle availability. i.e. to meet our targets our Council will have to start the
                                                          procurement of heavy fleet in 2012 due to lead times and operational life, when currently there is no
                                                          alternative heavy vehicle fuel type.




                                                                              27
R13 - West Lothian Council


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Joe Drew
 Organisation:                                             West Lothian Council
 Address:
 Postcode:
 Email:
 Telephone Number:
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Hybrid vehicles such as the Toyota Prius are currently commercially available therefore given this is proven
 do you envisage will be first to be influential in        technology it could be envisaged that this would be the first low carbon technology to influence the reduction
 reducing GHG emissions from the transport sector?         in GHG emissions. However Biofuel technology is also at an advanced stage and could prove to be a better
 Why?                                                      solution than electricity. There are other non-technology based and cheaper options, which could be used in
                                                           the interim such as the fitting of speed limiters.
 Question 2: Which low carbon technologies and fuels       Ultimately hydrogen, however electricity has the potential to make a large impact, This is dependent on the
 do you believe will ultimately have the greatest          production at an early stage of de carbonised electricity This also requires further development to increase
 emissions abatement impact? Why?                          the distance vehicles can travel on a single charge and consideration has to e given to the effect heavy
                                                           batteries have on vehicle payloads. Affordability is also a consideration as currently electric vehicles are
                                                           expensive to buy and their residual value is variable or virtually unknown at this stage. Best value is a
                                                           consideration for Local Authorities running large fleets especially in the current economic climate. There is
                                                           also an issue regarding end of life vehicle disposal costs including the batteries
 Question 3: What timescales do you believe are            Electricity is available now albeit on a small scale (as there are very few electric or hybrid vehicles being
 feasible for the development of specific low carbon       used) Biofuel technology specially from sustainable sources should be available within the next 5 years
 technologies and fuels? Are there any important           However key issues such as affordability, range and ability to have sufficient refuelling points at handy
 intermediate milestones within these timescales?          locations need to be addressed. Again it has to be stressed that payload of commercial vehicles remains a
                                                           key issue to be addressed especially with larger HGV s such as refuse collection vehicle. There is also an
                                                           issue concerning the ability of the Grid to supply sufficient electricity to meet the expected demand.
 Question 4: What timescales do you believe are the        See Answer to Q3 plus local Authorities are amongst the largest fleet users and will in all possibility be
 feasible for the uptake of specific low carbon            expected to be at the forefront of trialling these new technologies. Given the current economic climate
 technologies and fuels? Are there any important           (which will possibly last for the next decade) affordability will be a key issue. Central Government assistance
 intermediate milestones within these timescales?          to Local Authorities to help kick start the use of low emission vehicles would be welcomed. It is appreciated
                                                           the the whole life running costs of these vehicles will be lower than conventional diesel vehicles and this can
                                                           be taken into account with any grant aided assistance from the Government.
 Question 5: Are there other barriers to the               Affordability, payload and range as indicated above are current barriers in relation to electric vehicles while
 development of such fuels and technologies that are       further work needs carried out on the use of Biofuels. We really need to understand the net emission effects
 not mentioned in this document? If so, what are           of these types of fuel. Public perception could be a barrier in that they could perceive electric vehicles to be
 they?                                                     based on “milk float “ technology whilst their may be resistance to turning areas of land over to growing
                                                           biomass at the expense of food production. A key issue is would the public really buy them as they have
                                                           limited range. There are more obstacles in the way of the public buying them than LA s as LA s work in a
                                                           defined area and tend not to do long distances.
 Question 6: Are there other barriers to the uptake of     The whole re-fuelling infrastructure needs reviewed whether it is LPG, CNG, Electricity or other., For
 such fuels and technologies that are not mentioned        example LPG first came on the scene in the mid 70s. It is only in the last 10 years that some filling stations
 in this document? If so, what are they?                   now offer this fuel. Currently petrol and diesel engines have a compatability between vehicles and fuelling
                                                           systems and refuelling points are readily available and simple to use. Where will electric vehicles recharge
                                                           ie will it be at the outside of residential properties (what about flats,terraced properties etc) or will it be at
                                                           bespoke stations. There is also an issue around the time taken to recharge an electric vehicle. Obviously a
                                                           fast charging system would be preferable but will the batteries be designed in such a way that this will be
                                                           possible? A national or indeed International standard needs agreed in relation to refuelling points and such
                                                           points need to be readily accessible to users.
 Question 7: Are there any negative social impacts         As previously stated there could be an issue around crop growing for fuel vs food. However bio fuel
 associated with either the development or uptake of       produced from Waste would be positive social impact
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would      It is difficult to comment on this issue as it is one for the Grid operators who are the experts in this area
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             Again it is difficult to comment on this but given the importance of Climate Change and Carbon reduction it
 And, how might these costs be recovered?                  is hoped Government would do it‟s best to offer help to facilitate any changes required.
 Question 10: Do any of the technologies present any       No specific comments to make in this area except to repeat that given the overall importance of Carbon
 specific challenges or opportunities to island            reduction it is hoped the Government will react appropriately to facilitate the changes required
 communities and sparsely populated rural areas in
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              Local authorities are the largest fleet users and therefore seems reasonable that there should be a twin
 approach for the public sector and other users is         approach. They also operate in a non profit making sector and thus are better able to take a share of the
 appropriate? If so, why? If not, why not?                 risks associated with in the introduction of low carbon vehicles. They also operate in defined areas with a
                                                           mix of vehicles from small to very large however we must repeat that LAs are facing severe budget
                                                           restraints and Government support will be needed as already highlighted.
 Question 12: If so, should targets relate to the uptake   At the outset we need a definition of exactly what constitutes a “low carbon vehicle” before any targets are
 of low carbon vehicles (either as a percentage of the     set. It is essential that any targets set are clearly defined. We consider that the target should apply to
 fleet or an absolute number), or a reduction in total     Council fleets Scotland wide as there is a recognition that council areas vary and there is not a one fit all
 emissions across the fleets or another format of          solution. Targets are generally welcomed as long as they are not too prescriptive and allow leeway for
 target? Why?                                              Councils to do what best suits their needs set against the need to deliver Public services. Targets need to
                                                           be affordable or supported financially.
 Question 13: If we follow a target relating to the        The UK committee on Climate Change has modelled potential of uptake rates using a number of Scenarios
 public sector uptake of LCVs, what percentage of the      including:
 fleet should be LCVs by 2020? Please give reasons
 for your answer.                                                       Current Ambition,
                                                                        Extended Ambition and
                                                                        Stretch Ambition.

                                                           Given the urgency of this our view is that the targets are based on the Stretch Ambition scenario for uptake
                                                           rates in Table 3 of the Consultation Document. These targets will need back up and support from
                                                           Government if they are to be achieved.
 Question 14: If we follow a target relating to the        Please see response to Q12 and Q13
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        There are specialist vehicles in the fleet which respond to life and limb scenarios eg Gritters, ambulances,
 should be excluded from the public sector target? If      Fire Engines etc which depend on proven technology at this stage as they have an urgent need to respond.
 so, what are they and why should they be excluded?        They must be available when needed therefore during the development stage they should be exempted.
 If not, why not?                                          Some Authorities still have and depend on Recovery Vehicles which tend to be old but are essential and




                                                                               28
                                                          they should also be exempted
Question 16: As LCVs may have higher upfront costs        Basically the answer is Yes in principal. Application of short term budgets towards the purchase of LCVs
than traditional vehicles (albeit with a smaller          could create demand therefore leading to greater economies of scale whilst increasing their commercial
discrepancy between lifecycle costs) do you               viability. It would also hopefully help start to get the required support infrastructure in place. These short
consider it to be efficient use of public resources to    term budgets should be funded from Scottish Government
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      Budget constraints especially at this time in the Public sector is a real barrier and will require Government
to public sector procurement of LCVs that are not         support to kick start the introduction of LCVs into LA fleets. Increased purchase costs will mitigate against
mentioned in this document? If so, what are they?         Las purchasing LCV vehicles. More and more homeworking is becoming the norm in Las not only for staff
                                                          but also in relation to Tradesmen. They will have to have facilities for recharging their vehicles at home and
                                                          how will they be able to recharge their domestic electricity used in an accutate manner.
Question 18: What are the individual roles of different   It is the role of Government to set targets for carbon reduction but manufacturers and users need
groups and organisations in ensuring the provision        encouraged to produce these vehicles and secondly for the large fleet users and the public to buy them..
of any infrastructure required for low carbon             This needs a European dimension as the climate is similar and the bulk of HGVs are built in Europe.
vehicles?
Question 19: Are there other supply side/capacity         At present the current market for new vehicles is depressed and ,this must impact on LCVs. Should
constraints impacting on LCV development and              consider a Vehicle scrappage scheme for LCV s
uptake? If so, what are they?
Question 20: Are there barriers to the development of     We have no comment on this
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          I believe the industry should focus on what their needs are and not be restricted by types. It should not be
particular vehicle types? If so, what are they and        restricted to Specific types of vehicles
why? If not, why not?
Question 22: Are there gaps in the supply chain? If       Yes, all manufacturers are at different stages with LCVs and all using different technologies. Furthermore
so, what are they and how might these be overcome?        there is no current refuelling infrastructure
Question 23: Do we have the required skills base for      We have no comment at this time
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           Scottish Government need to consult with all stakeholders to identify areas which when developed would
collaborate to stimulate the development and uptake       stimulate the development of LCVs. E.g. Refuelling infrastructure.
of LCVs?




                                                                              29
R14 - Nestrans


 RESPONDENT INFORMATION DETAILS
 Name:                                                                                     Kirsty Morrison
 Organisation:                                                                             Nestrans
 Address:                                                                                  Archibald Simpson House, 27-29 King Street, Aberdeen
 Postcode:                                                                                 AB24 5AA
 Email:
 Telephone Number:                                                                         01224 625524
 Responding as:                                                                            On behalf of a group or organisation
 Individual Permission:                                                                    Not Supplied
 Confidentiality:                                                                          Not Supplied
 Group or Organisation:                                                                    Yes
 Share Response Permission:                                                                Yes




Dear Sir/Madam

Consultation on Low Carbon Vehicles


Our Ref KM/N 1/9
Your Ref

Thank you for the opportunity to respond to your consultation document.

Nestrans is the North East of Scotland Regional Transport Partnership, covering Aberdeen City and Aberdeenshire. Our comments on this consultation document
primarily relate to the setting of targets and to the role of the public sector in increasing the take up of low carbon vehicle technology. This response was agreed by the
Nestrans Board at our meeting on 3rd September2009.

It is our view that LCVs have to become an important part of the transport network if the ambitious carbon reduction targets that have been set are to be achieved.
Measures to encourage behaviour change and encourage mode shift away from travel by private car to more sustainable modes of transport have an important role to
play but they cannot, on their own, meet these ambitious targets.

It is our view that having a twin approach for the public sector and other users is appropriate. As identified in the consultation document, the actions of the public sector
have a major impact on society and in its strategic role of government and policy setting and a significant fleet owner in itself, it should be setting an example and leading
the way in the adoption of LCV technology.

The public sector should have significant opportunities to specify the types of vehicles it uses, both through purchasing vehicles of its own and through specifications of
vehicle standards when procuring contracts from external suppliers. To rely on existing rates of turnover for replacing vehicles and contract renewals will however, on its
own, be unlikely be enough to meet ambitious targets. A strategy for renewal and replacement above and beyond the existing rate of vehicle replacement would therefore
be required.

In terms of setting targets, it would seem reasonable to set targets that relate to reductions in total emissions across the fleet as this relates directly to the overall desired
outcome. This would however be dependent on identifying appropriate and reliable means of monitoring such a target. It may therefore be appropriate to set long term
targets for overall emissions reductions from the fleet with interim targets relating to the uptake of LCVs.

The consultation document recognises the cost implications of increasing the uptake of LCVs and whilst we agree that the public sector should take the lead in this,
incentives to encourage the significant uptake that is required will likely be needed. It is possible that such support could come from initiatives to trial a range of
infrastructure provision options and technologies and from case studies to look at better understanding behavioural impacts.

Work is about to get underway in Aberdeen to investigate the benefits of a Low Emission Zone for Aberdeen City Centre which will seek to restrict or deter access by
specific polluting vehicles or only allow low or zero emissions vehicles, with the aim of improving the air quality. Although this project is restricted to the city centre zone, it
does provide opportunities to explore options involving low carbon vehicles.

I hope these comments are helpful in developing policy for low carbon vehicles. If you require any further information or would like to discuss any aspect of this letter,
please do not hesitate to contact me.

Yours faithfully

Kirsty Morrison
Transport Executive (Strategy & Delivery)




                                                                                       30
R15 - SEStran
 RESPONDENT INFORMATION DETAILS
 Name:
 Organisation:                                             SEStran
 Address:
 Postcode:
 Email:
 Telephone Number:
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Initially it is probably most viable to proceed with continuing to improve the efficiency of the combustion
 do you envisage will be first to be influential in        engine and the development of hybrid vehicles. This should not preclude the development and
 reducing GHG emissions from the transport sector?         infrastructure provision for the
 Why?                                                      introduction of more widespread use of electric and hydrogen vehicles. It should be recognised we already
                                                           have well developed low carbon vehicle technology in the form of trolley buses, trams using overhead
                                                           cables.
 Question 2: Which low carbon technologies and fuels       Ultimately the greatest impact will be through the large scale introduction of electric vehicles and the
 do you believe will ultimately have the greatest          introduction of hydrogen fuelled vehicles. There are currently problems with these technologies i.e. carbon
 emissions abatement impact? Why?                          free generation of
                                                           electricity/ current distance constraints on battery powered vehicles along with high energy use for hydrogen
                                                           generation. It is anticipated that these issues will addressed through time and development. The stored
                                                           nature of battery and hydrogen power source generation is ideal for renewable energy generation, i.e. wind,
                                                           tidal, wave generation can be used off peak.
 Question 3: What timescales do you believe are            The technology is available and improving rapidly. The timing issues relate to the practical application of
 feasible for the development of specific low carbon       technology and commercial availability of vehicles and support infrastructure. Ten years seems to be a
 technologies and fuels? Are there any important           reasonable time
 intermediate milestones within these timescales?          period. The main issue is the provision of resources to develop lightweight batteries, efficient hydrogen
                                                           conversion plants and frequent, cost effective refuelling points
 Question 4: What timescales do you believe are the        Although it is appreciated that there is a timing issue in relation to vehicle replacement, the most crucial
 feasible for the uptake of specific low carbon            issue is generating customer demand for low carbon vehicles either through developing desirable and
 technologies and fuels? Are there any important           affordable low carbon
 intermediate milestones within these timescales?          vehicles and user facilities, and/or through carbon fuels becoming prohibitively expensive. Provision of
                                                           requisite infrastructure is also required.
 Question 5: Are there other barriers to the               Issues relating to the economic low carbon generation of electricity and hydrogen have to be urgently
 development of such fuels and technologies that are       addressed. Investment in renewable electricity generation and transmission is required.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     Customer acceptability of the new technology mainly through cost and the provision of supporting
 such fuels and technologies that are not mentioned        infrastructure i.e battery recharging/ replacement and hydrogen fuelling centres and the willingness of
 in this document? If so, what are they?                   manufacturers to make new
                                                           generation vehicles incorporating such drive systems.
 Question 7: Are there any negative social impacts         The generation and transmission of electricity is becoming an environmental/social issue. The acceptability
 associated with either the development or uptake of       of nuclear power generation, extensive wind farms and overhead transmission are significant issues. The
 such technologies/fuels? If so, what are they?            availability of new technology facilities in remote areas of Scotland will have to be considered.
 Question 8: What, if any, technical challenges would      The social unacceptability of large pylon networks especially in the more scenic/populated areas of Scotland
 the grid reinforcement upgrades be likely to present?     needs to be recognised. Undergrounding should be the norm rather than the exception although the
 How might these be overcome?                              practicality of this
                                                           and the cost would have to be considered.
 Question 9: Who would fund any grid upgrades?             A combination of the government, the transmission companies and the consumer.
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any       The viability of providing adequate charging and refuelling facilities has to be considered and supported.
 specific challenges or opportunities to island            There is potential for local community generation schemes to provide the local fuel requirements either
 communities and sparsely populated rural areas in         through localised electricity generation or through local hydrogen generation.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              Although local authorities do have large fleets of vehicles, they are operated in a cost effective manner.
 approach for the public sector and other users is         Therefore they are not going to invest in new technology if there are increased costs and operational risks.
 appropriate? If so, why? If not, why not?                 No doubt if the government were prepared to underwrite additional costs and risks, local authorities would
                                                           be able to significantly contribute to the targets. Therefore unless given preferential treatment, local
                                                           authorities should be considered on
                                                           the same grounds as the private sector.
 Question 12: If so, should targets relate to the uptake   Unless support/incentives are given to local authorities/private operators in achieving the targets I would
 of low carbon vehicles (either as a percentage of the     suggest targets are not particularly useful.
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        N/A
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the        N/A
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        N/A
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        There needs to be a convincing financial case made to local authorities on the costs and reliability of these
 than traditional vehicles (albeit with a smaller          new vehicles before a decision can be made on a whole life basis. This could be achieved by funded trials
 discrepancy between lifecycle costs) do you               to initially cover
 consider it to be efficient use of public resources to    front end loading of costs.
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      Providing the financial incentives are there, there is no barrier to the procurement of vehicles other than the
 to public sector procurement of LCVs that are not         availability of suitable and reliable vehicles and refuelling costs.
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different   There is a hierarchical approach required with government/private sector supplying the initial investment
 groups and organisations in ensuring the provision        and incentives, regional transport partnerships providing the practical regional management of the
 of any infrastructure required for low carbon             implementation of facilities and local authorities/private sector being responsible for the provision of on
 vehicles?                                                 street facilities and implementation through the planning process.
 Question 19: Are there other supply side/capacity         The initial impression is yes but not really in a position to pass informed comment. There are not enough
 constraints impacting on LCV development and              suppliers of appropriate vehicles at an attractive price or refuelling points to encourage purchase.
 uptake? If so, what are they?




                                                                              31
Question 20: Are there barriers to the development of   Scotland has not got a significant vehicle construction industry and historical experience (e.g. Linwood)
an indigenous low carbon vehicle industry in            seems to indicate the economics of large scale vehicle manufacture in Scotland are not good. We do
Scotland? If so, what are they and how might they be    however have a
overcome?                                               large bus construction company in Alexander of Falkirk on which we could base development of low carbon
                                                        buses (initially). The availability of sufficient development capital is questionable. To increase the potential
                                                        for
                                                        development, the government might consider tax breaks and rating allowances during the establishment
                                                        period.
Question 21: Should Scotland’s industry focus on        There is potential for specialised vehicle development in Scotland but potentially more viable is the
particular vehicle types? If so, what are they and      development and production of power sources and generation. (see above re buses)
why? If not, why not?
Question 22: Are there gaps in the supply chain? If     Not aware of any significant supply chain in Scotland!
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for    The academic community in Scotland is very adaptable to demand and will provide the required skills, if
the development of this market? If not, where are the   students have the confidence of a long term future of this emerging industry. At the moment most expertise
gaps?                                                   is non Scottish.
Question 24: How could the various stakeholders         The government needs to take a lead in ensuring the required level of collaboration and resource is
collaborate to stimulate the development and uptake     provided.
of LCVs?




                                                                           32
R16 – Strathclyde Partnership for Transport


 RESPONDENT INFORMATION DETAILS
 Name:                                                     John Macdonald
 Organisation:                                             Strathclyde Partnership for Transport
 Address:
 Postcode:
 Email:
 Telephone Number:                                         0141 333 3137
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Currently there are various barriers which constrain the development of biofuels, hydrogen and hybrid
 do you envisage will be first to be influential in        technologies. These barriers include high production costs, limited technological advancement and
 reducing GHG emissions from the transport sector?         uncertainties regarding long term sustainability. Electric vehicles are at a more advanced stage in terms of
 Why?                                                      the technology available, the infrastructure in place and the costs which are more commercially viable
                                                           compared with the aforementioned technologies. Indeed SPT is joining with fellow stakeholders in the
                                                           Glasgow Electric Car Pilot to take on electric vehicles within its fleet and take lead in reducing its GHG
                                                           emissions.
 Question 2: Which low carbon technologies and fuels       Hybrid technology by definition still makes use of internal combustion engines that release GHG emissions
 do you believe will ultimately have the greatest          from oil based fuels. Hydrogen technology emits nothing more than water vapour yet lifecycle emissions in
 emissions abatement impact? Why?                          producing hydrogen are significantly high. The production of biofuels could lead to a net increase in GHG
                                                           emissions. Electric vehicles produce no „tail-pipe‟ emissions. If the electricity to run these vehicles was
                                                           sourced from renewable sources this could further reduce emissions from electric vehicles to the extent that
                                                           they may be negligible over their lifecycle. Therefore electric vehicles coupled with renewable sources could
                                                           offer the greatest emissions abatement impact.
 Question 3: What timescales do you believe are            The Scottish Government‟s Climate Change Delivery Plan puts forward an ambition to “decarbonise road
 feasible for the development of specific low carbon       transport by 2050 with significant progress made by 2030 through wholesale adoption of electric cars and
 technologies and fuels? Are there any important           vans.” These timescales are ambitious yet feasible provided that support is provided from Government in
 intermediate milestones within these timescales?          terms of funding and research. Intermediary milestones could be set for instance within the public sector,
                                                           which owns the largest vehicle fleet, to decarbonise its fleet and prompt leadership ahead of other sectors.
                                                           SPT believe that an intermediary milestone to the 2030 timescale would significantly aid the development of
                                                           low carbon technologies and fuels.
 Question 4: What timescales do you believe are the        Answer as question 3.
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               The current economic downturn could as a barrier to companies or organisations that look to manufacture
 development of such fuels and technologies that are       or develop low carbon fuels and technologies. Economic uncertainty can force companies to reduce their
 not mentioned in this document? If so, what are           research and development and stick to recognised activities that ensure their long term security. Reductions
 they?                                                     in public sector spending can discourage leadership from the sector and force the importance of low carbon
                                                           technology development down the agenda. Other high-level policies or priorities that may arise such as new
                                                           energy or environmental policies may also conflict with the development of low carbon technologies. If early
                                                           leadership is not shown on the development of low carbon technologies; there is a danger that empathy
                                                           may set in which in itself will act as a barrier.
 Question 6: Are there other barriers to the uptake of     Answer as question 5.
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         There may be a threat that the development of such technologies/fuels is led out with Scotland. This could
 associated with either the development or uptake of       in turn threaten Scottish businesses and employees whose expertise are under-utilised and their future
 such technologies/fuels? If so, what are they?            securities are jeopardised. Strong leadership must be shown to ensure Scotland is best placed to develop
                                                           and uptake low carbon technologies and that business and employment are safeguarded and indeed
                                                           enhanced by new developments.
 Question 8: What, if any, technical challenges would      For electric vehicles in particular, electricity demand would increase and new infrastructure would be
 the grid reinforcement upgrades be likely to present?     required – charging points for example. It may be easier to introduce charging points within city centre
 How might these be overcome?                              environments and built up areas such as out of town developments. Challenges may arise in installing new
                                                           charging points in more rural areas. SPT is not best placed to answer how such challenges may be
                                                           overcome but believes that close collaboration would be required between all concerned stakeholders.
 Question 9: Who would fund any grid upgrades?             The Scottish Government is committed to decarbonising road transport and making significant progress in
 And, how might these costs be recovered?                  electric vehicle adoption by 2030. In order to meet these targets the Scottish Government will be required to
                                                           fund any grid upgrades to some extent. Other concerned stakeholders such as energy suppliers and
                                                           manufacturers will also need to fund some level of investment. These costs may be recovered through fiscal
                                                           policies aimed at sectors who do not embrace low carbon technologies/fuels within their operations.
 Question 10: Do any of the technologies present any       Specific low carbon technologies will be more suitable in certain areas. For instance, electric vehicles may
 specific challenges or opportunities to island            not be suitable for use in rural communities due to their limited distance range as well as the upgrades to
 communities and sparsely populated rural areas in         grid infrastructure that would be required. These challenges may however provide opportunities for other
 Scotland? If so, how might these challenges by            technologies such as hybrid or hydrogen to be developed for use in rural areas. It would be beneficial for the
 addressed, and by whom?                                   Scottish Government to commission research to be carried out that determine what low carbon technologies
                                                           would be best suited to meeting the needs of rural areas.
 Question 11: Do you think that having a twin              A twin approach by the public and private sectors is an appropriate method as both can play to their
 approach for the public sector and other users is         strengths thereby influencing the increase of LCVs. The public sector may not be able to meet the level of
 appropriate? If so, why? If not, why not?                 investment required to upgrade their fleets to incorporate LCVs. However if financial instruments are made
                                                           available to subsidise the cost variances in adopting LCV technologies; the public sector can show
                                                           leadership through setting uptake targets and reducing the emissions levels from its fleet. As a
                                                           consequence the public sector will create a market demand thereby stimulating the private sector to invest
                                                           in research and development of LCV technologies.
 Question 12: If so, should targets relate to the uptake   Fleets across public and private sectors comprise of different vehicle compositions; some are predominantly
 of low carbon vehicles (either as a percentage of the     cars and LGVs whist others are predominantly HGVs. This could make meeting a percentage of fleet target
 fleet or an absolute number), or a reduction in total     difficult for predominantly HGV fleets; as LCV technology is limited here; in comparison to predominantly car
 emissions across the fleets or another format of          and LGV fleet, where LCV technology is more advanced. Similarly a target of reduced total emissions
 target? Why?                                              across a fleet again may benefit particular fleets that may only need to change a small amount of vehicles in
                                                           comparison to other fleets that need to change a larger amount in order to meet the same emissions target.
                                                           A target that focuses on reducing fleet emissions by x amount annually against a given fleet baseline would
                                                           be more apt at enabling organisations to tailor the approach they take that best meets their fleet
                                                           requirements.
 Question 13: If we follow a target relating to the        In its 2007 manifesto commitments, the Scottish Government looked to begin a discussion on a target of
 public sector uptake of LCVs, what percentage of the      100% use of alternative powered vehicles within the public sector by 2020. SPT believe that this target may
 fleet should be LCVs by 2020? Please give reasons         be achievable however difficulties may arise in ensuring that 100% of public sector fleet are LCVs.
 for your answer.                                          Intermediary targets to 2020 should also be set to ensure that the transition to LCV uptake is staggered and
                                                           gradually progressive.
 Question 14: If we follow a target relating to the        In its 2007 manifesto commitments, the Scottish Government looked to begin a discussion on a target of
 uptake of LCVs across all road users, what                30% use of alternative powered vehicles across all road users, excluding the public sector, by 2020. This
 percentage of all new vehicles should be LCVs by          target may be difficult due to the amount of existing vehicles in circulation but could be well placed against
 2020? Please give reasons for your answer.                all new vehicles. During this time it is anticipated that the public sector would be leading the way in LCV




                                                                              33
                                                          uptake, thereby creating market demand and encouraging further development. This should encourage
                                                          manufacturers to exploit this demand and increase their LCV output. The challenges will come in ensuring
                                                          that any necessary infrastructure is installed and that LCVs are competitively priced so as private uptake is
                                                          encouraged.
Question 15: Are there any vehicle categories that        No vehicles should be excluded; however it may be appropriate that different vehicle categories have their
should be excluded from the public sector target? If      own realistic targets.
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        Initially there will be little incentive for the uptake of LCVs. in order for the Government to achieve their
than traditional vehicles (albeit with a smaller          Climate Change targets, particularly those that fall within the transport sector, then action will be required
discrepancy between lifecycle costs) do you               that encourages LCV uptake. Incentives such as subsidies or a lower tax regime could encourage the
consider it to be efficient use of public resources to    uptake of LCVs in the short-term. The creation of other incentives over time would ensure that uptake of
devote a greater short-term budget towards the            LCVs continues and that it doesn‟t languish as a short-term measure.
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      Barriers to public sector procurement may come down to making funding available for the purchase and
to public sector procurement of LCVs that are not         maintenance of LCVs. In pressured economic times it will be vital that funding is made available for the
mentioned in this document? If so, what are they?         public sector to lead on the uptake of LCVs.
Question 18: What are the individual roles of different   The utilities companies will need to take lead in ensuring that power supply and charging points are installed
groups and organisations in ensuring the provision        in adequate locations across urban areas. This will require close collaboration with local authorities and land
of any infrastructure required for low carbon             owners to ensure that infrastructure is located in areas of greatest accessibility for potential users.
vehicles?
Question 19: Are there other supply side/capacity         The Sustainable Transport Group comprised of industrial stakeholders should act as a leading forum to
constraints impacting on LCV development and              drive the development and uptake of LCVs. This partnership between industry, research and development
uptake? If so, what are they?                             centres, academia and the public sector will be key to identifying and tackling any constraints that may
                                                          arise. This group will need to focus on delivering results and may be required to be public sector led with
                                                          Scottish Government support.
Question 20: Are there barriers to the development of     Current economic conditions may have a divisive impact on the growth of a Scottish LCV industry.
an indigenous low carbon vehicle industry in              Organisations may be forced to retract investment in LCV research and technology thereby jeopardising the
Scotland? If so, what are they and how might they be      development of such an industry. The Scottish Government should encourage organisations to invest in
overcome?                                                 LCV research and technology through installing supportive measures and releasing funding that will
                                                          stimulate a new low carbon industry. This should be aligned with the annual emissions reduction targets that
                                                          will be set by Scottish Ministers under the Climate Change (Scotland) Act 2009.
Question 21: Should Scotland’s industry focus on          Organisations should focus on their areas of strength. Development of a range of LCV technologies should
particular vehicle types? If so, what are they and        help to create a low carbon industry that is not solely focused on one technology. It will however be
why? If not, why not?                                     beneficial to concentrate on the vehicle types that are best placed to break into the market in the first
                                                          instance; hybrid and electric in this case. This initial concentration should help to create demand and raise
                                                          awareness after which other LCV technologies should benefit from increased development.
Question 22: Are there gaps in the supply chain? If       The only potential gap in supply chain may be in getting LCVs to end user. If costs are set high in
so, what are they and how might these be overcome?        comparison to similar vehicles and if infrastructure is not readily available; uptake of LCVs may be
                                                          hampered. LCVs will need to be competitively priced.
Question 23: Do we have the required skills base for      Scotland does have the research and development capacity required for LCV technology as well as the
the development of this market? If not, where are the     industry to manufacture new technologies.
gaps?
Question 24: How could the various stakeholders           The individual strengths of stakeholders will need to be brought together to create a joined up approach for
collaborate to stimulate the development and uptake       the development and uptake of LCVs. A working group could be established, led by Scottish Government,
of LCVs?                                                  thereby providing a means for stakeholders to share their expertise and develop shared actions which will
                                                          stimulate LCV development and uptake.




                                                                              34
R17 - Swestrans


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Eddie Glover
 Organisation:                                             Swestrans
 Address:                                                  Militia House, English Street, Dumfries
 Postcode:                                                 DG1 2HR
 Email:
 Telephone Number:                                         01387 260372
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Lower emission engines in conjunction with bio-fuels are already established and having a significant
 do you envisage will be first to be influential in        impact. Energy from bio-fuels is renewable, at least in principle, and the tail-pipe carbon emissions are
 reducing GHG emissions from the transport sector?         balanced by absorption in fuel production related agriculture. Hybrid vehicles have the benefit of a
 Why?                                                      combustion engine but with lower localised emissions.
 Question 2: Which low carbon technologies and fuels       Hybrid technology will be important in the medium term. Electric technology and Hydrogen have zero tail
 do you believe will ultimately have the greatest          pipe emissions and will be most significant in the long term, especially where electricity is generated from a
 emissions abatement impact? Why?                          renewable source.
 Question 3: What timescales do you believe are            Increasing the ratio of bio-fuel in standard fuel is achievable in the short to medium term. Increasing the
 feasible for the development of specific low carbon       ratio further is achievable in the medium term through engine technology development. Development of
 technologies and fuels? Are there any important           robust electric technology will be longer term.
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        Increasing the ratio of bio fuel is achievable within the short term. Achieving agreed progressive industry
 feasible for the uptake of specific low carbon            standards, and road tax exemption for LCVs will be important milestones.
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               The transport manufacturing industry will require political encouragement to roll out existing technology
 development of such fuels and technologies that are       capabilities to the market. Government investment in research and development of electric technology is
 not mentioned in this document? If so, what are           essential.
 they?
 Question 6: Are there other barriers to the uptake of     The long refuelling cycle for electric vehicles is likely to continue to be an issue. They cannot be recharged
 such fuels and technologies that are not mentioned        in minutes, as one might fill up with petrol at a service station. Although this might be mitigated by battery
 in this document? If so, what are they?                   swap stations. This would require battery standardisation. Higher NO2 and particulate emissions from
                                                           biofuels may cause
                                                           localised air quality issues.
 Question 7: Are there any negative social impacts         There is a recognised issue with bio-fuels production, that high value fuel production will divert agriculture
 associated with either the development or uptake of       away from food production. This is likely to have a severe impact on food security, mainly in poorly
 such technologies/fuels? If so, what are they?            developed parts of the world. There is also likely to be pressure on forestation, which it is vital to retain as a
                                                           carbon sink.
 Question 8: What, if any, technical challenges would      The transfer of transport energy dependence towards electric power will require increased generation. The
 the grid reinforcement upgrades be likely to present?     shift towards renewables should be continued and accelerated, with further opportunities for consumer
 How might these be overcome?                              micro-generation linked to the grid enabled.
 Question 9: Who would fund any grid upgrades?             Costs might be shared between the industry itself, government, and users (funding micro-generation
 And, how might these costs be recovered?                  capacity). Some costs might be recovered through a transport (electric) fuel duty.
 Question 10: Do any of the technologies present any       With vast unpopulated areas, and a traditional forestry industry, Scotland has a particular opportunity in the
 specific challenges or opportunities to island            bio-fuels sector. In South West Scotland, brash (produced as a by-product of timber production) which used
 communities and sparsely populated rural areas in         to be discarded, is now used a bio-fuel for power generation at Stevens Croft. Care must be taken that if this
 Scotland? If so, how might these challenges by            option is developed its negative environmental impacts are minimised.
 addressed, and by whom?
 Question 11: Do you think that having a twin              Yes. It is appropriate for the public sector to demonstrate leadership in this area by accelerated introduction
 approach for the public sector and other users is         of LCVs.
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake   The most appropriate target would be one which reflected the wider (whole of life) environmental impacts of
 of low carbon vehicles (either as a percentage of the     vehicle replacement. Targets can be linked to organisation‟s Environmental Management policies.
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        In principle, the target should be approaching 100%. However, it should be recognised that it may be
 public sector uptake of LCVs, what percentage of the      inappropriate to include some types of vehicle, including those which would normally have a long
 fleet should be LCVs by 2020? Please give reasons         operational life. The target for uptake should not require vehicles to be decommissioned where the
 for your answer.                                          environmental cost of their decommissioning would be greater than the benefit gained in their replacement.
                                                           A wider environmental impact needs to be kept in mind than just the tailpipe emissions of the vehicle.
                                                           Vehicle carbon intensity is greatest during production (taking assessment of carbon lifecycle, extending use
                                                           of existing vehicles lowers carbon emissions). Extending vehicle life may be the most sustainable option for
                                                           existing fleet with LCV as a requirement for replacement
 Question 14: If we follow a target relating to the        As with the previous questions, the target should reflect the wider environmental impacts and costs/benefits
 uptake of LCVs across all road users, what                of vehicle replacement.
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        There may be vehicle categories that should be excluded from the public sector target. This may typically
 should be excluded from the public sector target? If      include vehicles with a high asset value and long operational life.
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        Yes. The Stern Review highlighted that the potential economic cost of ignoring climate change was far
 than traditional vehicles (albeit with a smaller          higher than the cost of investment to tackle it. Public sector leadership is vital to inspire investment
 discrepancy between lifecycle costs) do you               confidence in the private sector.
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      The additional costs associated with introducing a LCV fleet will be very challenging at a time when public
 to public sector procurement of LCVs that are not         sector budgets are being cut in the wake of the global economic downturn. There is a risk that investment in
 mentioned in this document? If so, what are they?         this area will be perceived by the public as a poor use of public finance when they see vital services
                                                           struggling. Politicians may be tempted to make decisions for short-term political approval rather than longer
                                                           term essential outcomes.
 Question 18: What are the individual roles of different   Transport Scotland and Regional Transport Partnerships should provide key strategic leadership. Private
 groups and organisations in ensuring the provision        sector industry will have a front-line role in providing infrastructure. Central Government will need to provide
 of any infrastructure required for low carbon             investment. Local Authorities will need to ensure that infrastructure needs are acknowledge in future
 vehicles?                                                 structure/development plans.
 Question 19: Are there other supply side/capacity         Consideration must also be given to servicing needs of the fleet. Will there be sufficient capacity in the
 constraints impacting on LCV development and              vehicle servicing industry to support the introduction of large volumes of LCVs?
 uptake? If so, what are they?
 Question 20: Are there barriers to the development of     The cost of manufacturing in Scotland compared with developing regions may be a barrier. The Scottish




                                                                               35
an indigenous low carbon vehicle industry in            Government must consider how to make Scotland attractive for manufacturers.
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on        The established strength in EVs, and Scotland‟s renewable power generating potential, should be
particular vehicle types? If so, what are they and      supported. The potential for biofuel production makes this another area where Scotland could be strong.
why? If not, why not?
Question 22: Are there gaps in the supply chain? If     Supply of biofuels will need to be increased. Development of technology to manufacture biofuels from
so, what are they and how might these be overcome?      biomass and waste needs to be supported. Support infrastructure (refuelling technology) for EVs and
                                                        hydrogen will need to be developed.
Question 23: Do we have the required skills base for    The skill base exists, but needs further investment and development.
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         Common specifications shared across the public sector for vehicle types would encourage and enable
collaborate to stimulate the development and uptake     manufacturers to bring products to the market for a lower unit cost.
of LCVs?




                                                                          36
R18 - TACTRAN


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Eric Guthrie
 Organisation:                                             TACTRAN
 Address:                                                  Bordeaux House, 31 Kinnoull Street, Perth
 Postcode:                                                 PH1 5EN
 Email:
 Telephone Number:                                         01738 475775
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels
 do you envisage will be first to be influential in
 reducing GHG emissions from the transport sector?
 Why?
 Question 2: Which low carbon technologies and fuels
 do you believe will ultimately have the greatest
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts
 associated with either the development or uptake of
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any       The implications of a Low Carbon Vehicles policy for rural and remote areas needs detailed consideration.
 specific challenges or opportunities to island            Supply of alternative fuels, except electricity, could be difficult in areas with low demand and widely
 communities and sparsely populated rural areas in         dispersed filling stations. This has been experienced with the supply of LPG for vehicles which is not widely
 Scotland? If so, how might these challenges by            available outside urban areas. The need to travel and costs of travel due to longer distances are critical and
 addressed, and by whom?                                   such areas should not be disadvantaged as a result.

                                                           tactran can foresee difficulties with the future use of electric vehicles in terms of the demand that this would
                                                           place on the electricity transmission infrastructure. Also, there are practical difficulties in recharging vehicles
                                                           parked remotely from properties, such as residential flats. Pre-1950s flats rarely have off-street parking
                                                           available and therefore there are concerns how vehicles can be recharged safely and free from vandalism
                                                           or interference on-street.
                                                           In terms of the application of fast charging technology tactran has identified a partner that potentially would
                                                           be interested in a demonstration project in a park and ride car park. We would be happy to discuss this
                                                           further with the Government.

                                                           tactran considers that it is important to consider all options for Low Carbon power sources and that while
                                                           emphasis is being given to electric powered vehicles, other technologies that offer significant reductions in
                                                           carbon output, particularly through the use of hydrogen, should also be pursued.
 Question 11: Do you think that having a twin
 approach for the public sector and other users is
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake
 of low carbon vehicles (either as a percentage of the
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs
 than traditional vehicles (albeit with a smaller
 discrepancy between lifecycle costs) do you
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different
 groups and organisations in ensuring the provision
 of any infrastructure required for low carbon
 vehicles?




                                                                               37
Question 19: Are there other supply side/capacity
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         Tactran supports the development of an indigenous low carbon vehicle industry in Scotland and the use of
collaborate to stimulate the development and uptake     such vehicles generally as these would generate wider economic as well as environmental benefits.
of LCVs?
                                                        It is noted that the Government is committed to facilitating the upgrading of the public sector bus fleet by
                                                        2020. The consultation document indicates that the average age of such vehicles is four years and therefore
                                                        the average life is likely to be around eight years. Setting a target for 2020 therefore means that the public
                                                        sector will be into the second round of vehicle renewal. It is believed that the time scale should be shortened
                                                        and that it should aim for this fleet to be entirely Low Carbon by 2015/2016.

                                                        It is noted also that the Government is committed to reducing freight emissions. While accepting there may
                                                        be some specialist vehicles that may need to be excluded tactran suggests setting a target of 2020 for most
                                                        if not all public sector vehicles (including cars and freight) to be Low Carbon emitting.

                                                        Financial support will be needed from Scottish Government to meet the cost difference between Low
                                                        Carbon and conventional vehicles and recognition by Audit Scotland of procurement of vehicles that offer
                                                        low carbon emissions but are not necessarily optimal in purely financial terms. Consideration may also be
                                                        given to the use of taxation to discourage the use of high carbon emitting vehicles and to satisfy
                                                        sustainability aims generally.

                                                        There will be benefits to achieving a greater proportion of Low Carbon Vehicles earlier as many public
                                                        sector vehicles are sold for further use and therefore this will influence the second hand market as well.

                                                        tactran is undertaking a study into the feasibility of freight consolidation centres in Dundee and Perth. Any
                                                        introduction of such a centre would enable the substitution of low carbon for existing delivery vehicles in the
                                                        city centres. It is unlikely that such an initiative would be self-financing and therefore tactran would urge the
                                                        government to consider financial support in such circumstances.

                                                        In Section 6.4 reference is made to the Scottish fleet. This raises an issue with UK-wide operations and
                                                        measures may be needed to discourage operators from registering vehicles elsewhere in the UK to avoid
                                                        more stringent requirements in Scotland.

                                                        Finally, there is a need to recognise that the most effective means to reduce carbon emissions is not to
                                                        undertake travel, for example through substituting video conferencing. A Low Carbon Vehicles policy should
                                                        sit alongside other initiatives including travel planning. Where journeys are essential “eco-safe driving”
                                                        techniques should be promoted.




                                                                            38
R19 - Allied Vehicles


 RESPONDENT INFORMATION DETAILS
 Name:
 Organisation:                                                    Allied Vehicles
 Address:
 Postcode:
 Email:
 Telephone Number:
 Responding as:                                                   On behalf of a group or organisation
 Individual Permission:                                           Not Supplied
 Confidentiality:                                                 Not Supplied
 Group or Organisation:                                           Yes
 Share Response Permission:                                       Yes




1. About Allied Vehicles Ltd
,
Allied Vehicles Ltd is a vehicle manufacturer and adaptor based in Balmore Road in North Glasgow. Allied employ 350 people and produce just over 3000 specialised
vehicles each year including hackney taxis, minibuses, wheelchair adapted vehicles and electric vehicles and distribute these vehicles across the UK under the brand
names of Cab
Direct, Allied Mobility and Allied Electric. Electric vans produced by Allied are available under the Department for Transport's Low Carbon Vehicle Public Procurement
Programme and Allied are also leading a Technology Strategy Board Project to demonstrate 40 electric cars in Glasgow.

2. Response to Consultation.

2.1 Technology Options

2.1.1 The technology that has the largest potential to make an impact in GHG emissions in the short term is the battery electric vehicle (EV). The technology is available
now and with the implementation of renewable and low carbon electricity generation is the cleanest technology available. In particular at point of exhaust electric vehicles
have no emissions at all. Other technologies like efficient diesels and hybrid electric vehicles (HEV) continue to emit not only carbon but also particulates and other gases
like Nitrous Oxide which are more damaging to the environment.

2.1.2 Scotland has a high (16%) and rising proportion of renewable energy production. It is therefore well placed to reduce GHG emissions by introducing EV's where
possible.

2.1.3 EV's will offer a long term development path as new cell chemistries lead to higher energy density, reduced weight and faster charging. The King Review of 2007
identified EV's as the lowest carbon emissions route to clean transportation even taking into account differing methods of electricity generation.

2.1.4 Electric vehicles are ideal for city driving with battery ranges of 100 to 180 km.

2.1.5 Vans or Light Goods Vehicles (LGV) are the majority of the public sector Heet and their emissions are rising in contrast to other road transport vehicle types.
replacement EV's are available from a number of sources including Allied now. Moving these vehicles to electric drive systems would reduce C02 emissions significantly.

Recommendation
Electric vehicles represent the most easily accessible route to reducing GHG, particularly in Scotland with its high proportion of renewable energy. Scottish Government
should focus on maximising EV uptake in Scotland.

2.2 Ambition

2.2.1 It is not unreasonable to expect that all (100%) of purchases for Scotland's public sector fleet should be low or zero emission EV or hybrid vehicles by 2020. The
technology is available now. Scotland, with its leading role in renewable energy production, should be setting this demanding and ambitious target for the introduction of
EV's.

Recommendation
Scottish Government should set a target for all new public sector vehicles to be below 75g/km by 2020.

2.3 Support
2.3.1 At present EV's are significantly more expensive to purchase than ICE equivalents. eg a £20,000 van would cost in the region of £50,000. This cost is distorted by
the Battery which costs c.£20,000. These costs are expected to fall as vehicle numbers increase but are a significant hurdle for the uptake of these vehicles.

2.3.2 The running costs of EV's are significantly lower than equivalent ICE vehicles with fuel (electricity/diesel some 9-11.5p/km cheaper), no road fund licence and no
congestion charges.

2.3.3 UK Government support for electric vehicles has been mainly in the form of the Low Carbon Vehicle Public Procurement Programme. This was announced in 2007
but and at the time of writing has not put a vehicle on the road. There is a danger that programmes of this type which are restricted to a small number of Government
departments and local authorities could distort the market with non supported departments and authorities putting off the investment decision.

2.3.4 The Technology Strategy Board has recently committed to a project (the Ultra Low Carbon Car Demonstrator Programme) across the UK. The Scottish consortium
led by Allied and containing Axeon, Scottish Power, Strathclyde University and Glasgow City Council will be putting 40 vehicles on Glasgow's streets for trial in 2010.

2.3.5 Allied have committed to a programme of development of a range of light commercial vehicles from 1.8 tonne to 4.5 tonne. All of these vehicles have passenger car
equivalents. These developments have been fully funded by Allied without specific support from Scottish or UK governments.

2.3.6 Scotland with companies like Allied and Axeon is well positioned to take advantage and to create commercial advantage from the move to EV's. Initially as EV's are
more niche market there could be hundreds of jobs created but as EV's become mainstream there is the opportunity for the economy that has invested in EV production
to benefit significantly.

Recommendation
Scotland is well placed to be at the forefront of electric vehicles benefiting not only the environment but also the economy. The Scottish Government should set
aggressive targets for the public fleet and put in place support structures for public and private operators who wish to move in this direction. Scottish Government
and its agencies should prioritise support for development and job creation in these sectors. Support service tenders should include requirements to utilise
electric vehicles.

2.4 Infrastructure

2.4.1 EV's have a ready available method for refuelling through the National Grid which reaches to the vast majority of homes and businesses
throughout the country.

2.4.2 EV's currently charge by connecting a charger to the Grid at either 230v (synchronous or single phase) or 415 v (asynchronous or three phase). 230v systems are
typically available in homes and circuits providing up to 30 amps are available. 415v systems are typically found in industrial environments and will charge vehicles at up
to 9kw/hr. This means that charging on three phase will be up to twice as quick as single phase.

2.4.3 Developments in batteries will mean that EV's will be able to charge quicker by accepting fast or rapid charges. These chargers may require a transformer but could
result in charge times of less than five minutes. They have the advantage of being able to be dispersed and readily available.




                                                                                      39
2.4.4 Hot swapping of batteries is not regarded as practical given the wide variation of electric vehicles and their battery sizes, construction and composition. Hot
swapping stations would put a huge centralised drain on the grid rather than using the grid's ability to disperse power.

Recommendation

Government should increase the number of available charging points both 230v and 415v to give EV users confidence that they can plug in at their destination. Future
development should be concentrated on fast or rapid charging systems and infrastructure rather than hot swapping.

Allied Vehicles Ltd

28th September, 2009




                                                                                    40
R20 - Axeon


 RESPONDENT INFORMATION DETAILS
 Name:                                                                   Rebecca Trengove
 Organisation:                                                           Axeon
 Address:                                                                Nobel Court, Wester Gourdie, Dundee
 Postcode:                                                               DD2 4UH
 Email:
 Telephone Number:                                                       01382 400040
 Responding as:                                                          On behalf of a group or organisation
 Individual Permission:                                                  Not Supplied
 Confidentiality:                                                        Not Supplied
 Group or Organisation:                                                  Yes
 Share Response Permission:                                              Yes




1 About AG Holding Ltd (Axeon)

1.1 Axeon is a leading technology developer, designer and manufacturer of complete lithium-ion battery systems for electric and hybrid electric vehicles (EVs and HEVs).

To date there are well over 150 production EVs on the roads of Europe powered by Axeon lithium-ion battery systems. Axeon currently produces batteries in production
volume for two of the UK's leading EV suppliers, Modec (Coventry) and Allied Vehicles (Glasgow). In addition, we have designed, produced and delivered several
prototype batteries for a very diverse range of other vehicles:

• High performance sports car for Ruf GmbH, Germany
• Highway-capable electric scooter, USA
• Materials handling truck, Germany
• City buses, Italy & USA
• HEV heavy plant vehicle, Scandinavia

We believe that we have to date made more lithium-ion electric vehicle batteries than any other company globally. We continue to invest in R&D to make better batteries,
improve battery technology, reduce cost and increase performance. Axeon is fully owned by AG Holding Ltd, which is backed by funds managed by Ironshield
Capital Management LLP. It is headquartered in Dundee, Scotland, with operations in the UK, Switzerland, Germany and Poland.

Technologies to reduce GHG emissions


2.1 In response to Q1 we believe that electric and hybrid electric vehicles have the greatest potential in the short term to reduce GHG emissions. These vehicles are
available now and lend themselves particularly well to the commercial and public sector fleet. 2.2 It might be helpful to explain the difference between electric vehicles
(EVs), hybrid electric vehicles (HEVs) and plug-in hybrid electric vehicles (PHEVs):

2.1.1         Electric Vehicles (

• These are already available (e.g. from Modec, Allied Vehicles, Smiths Electric Vehicles)
• EVs are all-electric, powered solely by batteries and with an electric motor
• The battery is recharged by plugging into the mains supply (3 phase is required in the
case of larger vehicles)
• They have an 70 to 130 mile range
• 10 kWh to 75 kWh capacity, and can be charged overnight
• EVs produce zero CO2 emissions at the point of use

2.1.2 Hybrid Electric Vehicles (HEVs)

• These are already available (e.g. Prius, HEV buses)
• Internal combustion engine (ICE) is main drive, 400 mile range
• Electric motor and battery provide power boost – typically 0.5 to 1.5 kWhr
• The battery is recharged by the internal combustion engine only. Uptake of HEVs will therefore not impact on demand on the grid.
• HEV bus probably delivers 20 to 40% CO2 emissions reduction • However, an efficient diesel engine can deliver better CO2 emissions reduction than an




HEV car



2.1.3 Plug-in Hybrid Electric Vehicles (PHEVs)


• All the main car manufacturers are now developing PHEVs (e.g. GM Volt) and these should be available in 2011
• These have a battery/electric motor drive, which will cover most day-to-day driving, particularly in an urban context. They can switch to an internal combustion engine for
longer journeys.
• Battery is recharged by plugging into mains supply (3 phase in the case of larger vehicles)
• 10 kWh to 15 kWh battery, 30 mile range on battery, 400 mile range on ICE
• Car - 85% CO2 emissions reduction

2.3 It can be seen that of the various types of electrically-propelled vehicles pure EVs can make the biggest reduction in carbon emissions. This is of course also
dependent on how the electricity is generated, but the King Review (October 2007) identified electric vehicles as the lowest carbon emissions route to clean
transportation, even taking into account various mixes of electricity generation.

2.4 EVs are ideal for urban driving as their range (70-130 miles on a single charge) would cover all likely journeys. A range of vehicle types is already available, including
light goods vehicles (under 3.5 tons), box vans (3.5 to 7.5 tons), taxis and minibuses, which offer the capability of both delivery and passenger transport of varying
capacities.

2.5 Light goods vehicles (LGVs) constitute the majority of the public sector fleet, emitting 28.3 ktCO2 in 07/08. In contrast with other road transport vehicle types,
emissions from LGVs are forecast to continue rising in the medium- to long-term. As such vehicles tend to be used for urban transport and thus have a limited journey
range they are ideally suited to conversion to electric vehicles; conversion of a significant proportion would reduce GHG emissions considerably.

2.6 Independent analysis (Ricardo 2009) has demonstrated that the probable take-up of EVs in the short-term will place no additional load on the grid. Scotland already
generates 16% of its gross electricity consumption from renewable sources; if Scotland can increase its proportion of renewable energy it will ensure that the widespread
introduction of EVs makes a significant contribution to carbon emission reduction overall.

Recommendation:
• Widespread take-up of EVs, HEVs and PHEVs is likely to have the most impact in
reducing GHG emissions in the short to medium term.




                                                                                     41
3 Targets

3.1 The potential take-up rates suggested by the UK Committee on Climate Change (page 24 of the consultation document) lack ambition. We would strongly recommend
that to stimulate the market for LCVs and encourage their take-up the Scottish government should set ambitious targets for public sector fleets. By 2020 EV, HEV or
PHEV versions of almost all types of municipal vehicles should be available (with the possible exception of HGVs) so it would be reasonable to set a target of 95% of all
2020 new vehicle purchases to be LCV. However, the government should note that LCVs are more expensive than ICE-powered vehicles and likely to remain so for the
foreseeable future. Therefore the government should provide financial support to local authorities (LAs) to enable them to purchase LCVs.

3.2 If the key aim is to reduce CO2 emissions, then the target should relate to the total emission reduction across the entire public sector fleet. How this is met will differ,
depending on the location of the LA and the composition of its fleet. For example metropolitan areas, for which a more limited vehicle range would suffice, should be able
to achieve significant LCV penetration in a short timescale through conversion to electric LGVs and hybrid buses. These vehicles may be less suitable for more rural LAs.
The government should therefore look at overall targets for the country, with a bias towards urban areas.

3.3 UK government subsidies have been very slow to be implemented. The Low Carbon Vehicle Procurement Programme (LCVPP: managed by Cenex) has so far taken
two years from inception and has yet to deliver a single vehicle. We are concerned that it may have already distorted the market; there is evidence that local authorities
have delayed purchasing decisions while awaiting the launch of the programme. Restricting the LCVPP both to a trial programme and to a limited number of public sector
bodies has had, we believe, a negative impact on a market that was already being addressed by existing British EV manufacturers. We therefore recommend that any
scheme that supports private/public sector fleets should be implemented quickly so as not to distort the market.

3.4 A demonstration project of 40 EVs will start running in Glasgow next year, involving Axeon, Allied Vehicles, Glasgow City Council, Scottish Power and Strathclyde
University. While this should produce useful information on behavioural impacts, which the Scottish government should acquire and consider, further demonstration
projects may delay wider take-up of EVs (as above).

3.5 Government-backed uptake of EVs by the public sector would demonstrate the viability of such vehicles and potentially create a secondary market for older vehicles
with either new batteries or reduced range and therefore cheaper batteries.

3.6 Currently it appears to be the case that larger fleet managers (including major retailers and delivery companies) are buying EVs faster than the public sector. At
present this is driven by the desire to reduce CO2 emissions, rather than economics. For wider uptake across the private sector fleet, targets for private sector fleets are
likely to be required. This could perhaps be achieved by mandating permissible levels of CO2 emissions rather than particular vehicle types; however, the government
should note that if Scottish private fleet managers are required to use particular types of LCVs without any compensation for doing so, this could reduce their
competitiveness by increasing their costs. Therefore financial support is likely to be required.

Recommendations:
• The Scottish government should set ambitious targets for public sector fleets and provide financial support to enable them to convert to more expensive but
lower carbon-emitting vehicles.
• We believe that 95% of all 2020 new vehicle purchases being LCV will be achievable, if a high proportion of these are EV, HEV or PHEV.
• Any scheme that supports private/public sector fleets should be implemented quickly so as not to distort the market.

4 Overcoming barriers to uptake of LCVs

Charging

4.1 For significant uptake of EVs a comprehensive charging infrastructure will be required. This is less of an issue for commercial vehicles, which typically would return to
a depot where 3- phase charging facilities can be installed, than it will be for passenger vehicles. Although much media attention has focused on the desirability of
increasing the battery range of the latter, it may be more cost-effective overall to install a dense coverage of charging points rather than spending huge sums on
increasing battery range.

4.2 Standardisation of charging infrastructure is critical to ensuring that consumers are not locked out of certain chargers. It is instructive to note that in the US three levels
of charging are coalescing into a de-facto infrastructure standard:

Level 1: 110V, 15 or 20A. This is the standard US household service, available anywhere and everywhere. Lowest-common denominator solution, not fast, but can
charge almost anything to a usable state in 24 hours. It is expected that the vehicle will come with its own charging cord for plugging in.

Level 2: 220V, single-phase, 30A. The so-called "preferred" method for EV cars. A J1772 connector is likely.

Level 3: 480V three-phase, 60-150 kW. This will probably be used only for commercial installations, not for general public. It may use inductive leads or dedicated /
bespoke connectors.

In the UK some charging post manufacturers offer the choice of single or three-phase connection in the same facility, determined by the charging pin configuration. We
recommend that the government should seek to establish a charging infrastructure but in consultation with private sector providers, European governments and standards
agencies over the standardisation of charging points (reference Q18).

4.3 The consultation document mentions the possibility of battery swapping stations. This technology is still unproven and there is much scepticism in the industry that it
will work effectively, as car manufacturers are unlikely to make batteries that are compatible across all models of vehicles. We do not believe that this would be an
effective substitute for a broad network of charging points.

4.4 Fast charging is a much-discussed topic, but we do not believe that the current speeds of charging should be a major deterrent to uptake of EVs, particularly
commercial EVs with relatively fixed runs and overnight storage at depots. Current battery and charging technologies permit rapid charging using a 3-phase 32A source
and slower charging using single-phase 13A (3kW). This would enable a full charge within 6-10 hours, depending on battery size, or faster top-up charging. As the
majority of vehicles have significant down time during any 24-hour period, overnight re-charging is suitable for most users. A point often ignored is that to charge a battery
quickly requires a very large power supply and this has the potential to limit severely the practical uptake of fast charging. For example, to charge a 300Vdc, 50kWh
battery in 15 minutes a user would require a 200kW supply. The size and cost of the grid infrastructure will make this impractical for most domestic and light commercial
applications. Battery technology is improving, and the introduction of newer chemistries is likely to speed up charging times, but we do not foresee that charging times will
be comparable to that of filling a petrol tank in the short to medium term.

Smart EV Grid

4.5 There is potential for Scottish companies to develop smart grid functionality to lessen the impact on the grid of the introduction of electric vehicles. If electric vehicle
users all begin charging at peak time in early evening the load on the grid will increase significantly at the existing period of heaviest demand. However, it is possible to
develop technology that would allow a user to set charging preferences, for example, selecting the most economic tariffs, greenest sources or simply a time of next use.
This has the potential to reduce significantly the cost of new grid infrastructure and to use electrical supply sources that were previously
under-utilised. Companies such as Scottish Power, Scottish and Southern Energy, Allied Vehicles and Axeon have the necessary experience to develop this technology if
encouraged to work in partnership. This would enable Scotland to take the lead in developing and introducing standards that could be licensed and sold to other
countries.

Cost

4.6 EVs cost more than conventional ICE-powered vehicles, due largely to the significant cost of the batteries. Over the medium-term the whole-life running costs of EVs
are likely to be lower than conventionally-powered vehicles, partly due to lower prices for electricity than for carbon fuels and partly because electric engines are more
efficient than internal combustion engines. However, the high capital cost of EVs is a significant deterrent to potential purchasers. Some of Axeon‟s customers (the vehicle
manufacturers) offer the vehicles on a leased basis so that there is reduced up-front cost. A current issue with battery leasing is the lack of information on the residual
values of the batteries – they simply haven‟t been running long enough for us to have a clear idea of how much life they will have left beyond the 3 year warranty. As time
goes on and there is a larger base of installed EVs, it will become possible to make these
calculations.

Consumer knowledge

4.7 There is, understandably, widespread ignorance about EVs and PHEVs among the public. Education is needed to raise awareness of potential purchasers of the
benefits of EVs. We recommend that an education campaign focuses on fleet managers first as likely first adopters of such technology. Axeon plans to run seminars
specifically on EVs for fleet managers, and we would welcome government support for this.




                                                                                      42
Recommendations:

The government should
• work with local councils to ensure an extensive coverage of consumer charging points;
• establish a charging infrastructure, in consultation with private sector providers and other European governments and standards agencies over the
standardisation of charging points;
• provide support and incentives for Scottish companies to work together to develop smart grid technology;
• support an education campaign on the benefits of EVs, focusing first on fleet managers.

5 Technology development

5.1 Given current battery technology developments, it is likely that within two to three years EV batteries will be smaller, lighter and with extended range. These
technology developments are costly however, and it is critical that government funding continues at all level of the innovation chain, from fundamental scientific research
through to product development.

5.2 The market pull is much weaker for EVs because of their increased cost compared with installed technology, therefore government intervention is needed till a later
stage of the innovation chain than might otherwise be the case.

Recommendations:

• The government should continue to support R&D into more advanced battery
technologies at all stages of the innovation chain.

6 Scottish capabilities

6.1 Scotland already has a technological lead in EV batteries and vehicles, with companies operating in most of the related fields, including power generation (Scottish
Power, Scottish and Southern Energy), fleet transport operators (Stagecoach, First Group), specialist vehicles (Allied Vehicles, Alexander Dennis, Johnson Sweepers)
and batteries (Axeon Holdings). Given the range of major energy and transport companies headquartered in Scotland, it is well placed to drive this technological
development for the UK and become a leader in lowcarbon transport.

Recommendations:
• The Scottish Government has a unique opportunity to act at a relatively low cost and
position Scotland as a global leader in sustainable, low-carbon transport.

7 Other considerations

7.1 In August 2009 the US government announced that it would accelerate the introduction of EVs by handing out $2.4 billion to the US EV battery sector in the form of
grants. This has placed non-US companies at a competitive disadvantage – these grants may allow our competitors to overtake our technology, undercut our prices, and
offer US-made solutions to US customers for whom “Buy American” is an increasing consideration. Significantly it also makes us an acquisition target for cash-rich US
companies. Because of the availability of these grants the US has become a very attractive potential manufacturing base for Axeon (it is now as straightforward for us to
set up a facility in the US as in Scotland) and the probable need to provide a US-made solution to US customers is likely to reinforce that attraction.

7.2 At the recent Low Carbon Vehicle show at Millbrook Proving Ground several senior industry commentators (including John Wood, the former head of MIRA) made the
point that given the importance of the battery to an EV, the UK needs a battery industry. Axeon is virtually unique in this regard, both from a Scottish or UK perspective,
and therefore support for the company will help to ensure the continuation of a UK battery industry.

7.3 There are potential negative social impacts related to the charging of consumer vehicles (reference Q7). Charging of consumer vehicles will be much easier for those
with drives or garages; on-street overnight charging is likely to trigger major health and safety concerns (such charging points may be at risk from vandalism or
pedestrians tripping over charging cables). This may make it more difficult for those living in areas of high-density housing to run EVs.

7.4 Island communities (reference Q10) might well prove suitable for electric transport, particularly those which generate their own renewable energy. Lewis may be a
case in point, with the development of the UK‟s first commercial wave power station. Indeed, if electricity is generated locally from renewable sources, the overall costs of
buying and running an EV might compare favourable to ICE vehicles that rely on expensive fuel. The range of the vehicles would be the limiting factor; EVs are not suited
to situations where long distances have to be driven. In these situations HEVs or PHEVs would be more suitable.

7.5 There is a dearth of skilled automotive engineering talent in Scotland. The government may wish to consider an initiative to retrain engineers currently working in
declining industries and thus enhance the skills base (reference Q 23).

Recommendations:
• The government should view EVs and PHEVs fuelled by renewable energy sources as a means of overcoming fuel poverty in remote areas;
• The government may wish to consider an initiative to enhance automotive-related engineering skills.




                                                                                    43
R21 - Clean Air Power
 RESPONDENT INFORMATION DETAILS
 Name:                                                     Sean O'Kane
 Organisation:                                             Clean Air Power
 Address:                                                  Aton Way, Leyland, Lancashire
 Postcode:                                                 PR26 7UX
 Email:
 Telephone Number:                                         07894 621 460
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       The use of natural gas or bio-methane as an alternative fuel for commercial vehicles. Clean Air Power‟s Dual-
 do you envisage will be first to be influential in        Fuel system is available now and can deliver 12% CO2 emissions savings. This is increased to a 28% saving
 reducing GHG emissions from the transport sector?         if bio-methane is used instead of natural gas. Figures are based on 50% gas substitution achieved by Clean
 Why?                                                      Air Power‟s current Genesis product. HGV CO2 emissions account for 21% of total transport emissions
                                                           according to the consultation document. To put these savings into perspective, a HGV produces 917 g/km of
                                                           CO2. Fitting a Genesis Dual Fuel system and using Bio-Methane as a fuel reduces this by 257 g/km. (Total
                                                           CO2 emissions from a car are 204 g/km.) A customer is successfully using this technology at their distribution
                                                           site. The bio-methane fuel is produced from landfill waste. Natural gas and bio-methane can also be used as a
                                                           fuel for buses cars and vans and light trucks fitted with dedicated gas engines.
 Question 2: Which low carbon technologies and fuels       For cars and light vehicles, electric vehicles powered either by hydrogen or batteries will produce zero
 do you believe will ultimately have the greatest          emissions - provided the electricity used to produce the hydrogen or charge the batteries is from a zero
 emissions abatement impact? Why?                          emissions source (nuclear, hydro etc). For public transport and light freight, dedicated gas engines running on
                                                           bio-methane or for some applications, electric vehicles. CNG powered busses are already used in many parts
                                                           of the world. For HGVs, the options are limited. Bio-fuels used in diesel engines will probably be the only
                                                           alternative. Bio-fuels such as bio-methane which can be manufactured from waste will play a part in this.
 Question 3: What timescales do you believe are            Dual-Fuel technology for commercial vehicles. Clean Air Power‟s Genesis product is available now and can be
 feasible for the development of specific low carbon       fitted to some HGVs including Euro III (Mercedes Axor, DAF CF) and Euro V Volvo FM13 and FH13.
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        There is already limited uptake of Dual-Fuel technology by Wiseman Dairies, Warburtons Bakery, United
 feasible for the uptake of specific low carbon            Utilities and Sainsbury among others in the UK. A significant milestone will be the launch of the Volvo Dual-
 technologies and fuels? Are there any important           Fuel product.
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               There is a general uncertainty in the market about alternative fuels. This is based on a lack of infrastructure
 development of such fuels and technologies that are       and a scarcity of data on reliability, performance etc.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     Current price differential between natural gas and diesel provides only a marginal incentive for hauliers to
 such fuels and technologies that are not mentioned        adopt Dual-Fuel technology. The infastructure for re-fuelling is limited. There is a small network of public LNG
 in this document? If so, what are they?                   filling stations run by Chive Fuels. Dedicated LNG or CNG filling stations on customer premises require
                                                           substantial investment. There is also uncertainty about government policy regarding fuel duty on gas.
 Question 7: Are there any negative social impacts         No. As well as lower CO2 emissions, soot and particulate exhaust emissions are reduced using Dual-Fuel
 associated with either the development or uptake of
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would      Not sure
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             It would be inevitable that the cost of upgrading the grid would fall with the electricity distribution companies
 And, how might these costs be recovered?                  who would pass the cost on to the consumer.
 Question 10: Do any of the technologies present any       Availability of gas supply would be a challenge at the moment. However, opportunities for local production of
 specific challenges or opportunities to island            bio-methane from waste to compress and use as CNG for vehicle fuel exists. LNG can be distributed by road
 communities and sparsely populated rural areas in         tanker.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              Yes. Private sector transport is purely cost driven. Public sector transport is subject to cost constraints but is
 approach for the public sector and other users is         also subject to political influence.
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake   Reduction of total emissions across fleets is the correct approach. It ensures that the LCVs are used
 of low carbon vehicles (either as a percentage of the     effectively if the analysis is done on actual fuel used. It will also remove arguments about what an LCV is.
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        80% Based on assumption that entire fleet will be replaced in the next ten years and that suitable LCVs may
 public sector uptake of LCVs, what percentage of the      not be available for all vehicle applications.
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the        50%. This target may be optimistic. It will be met only if the solutions available are cost effective.
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        Not sure
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        Not sure
 than traditional vehicles (albeit with a smaller
 discrepancy between lifecycle costs) do you
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      Knowledge about what LCV options are available?
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different   UK Government - sympathetic adjustment of fuel duty Scottish Government - assistance for infrastructure
 groups and organisations in ensuring the provision        development Pioneer operators - putting enough vehicles in service to support an infrastructure Manufacturers
 of any infrastructure required for low carbon             - making the products available
 vehicles?
 Question 19: Are there other supply side/capacity         Current capacity of LCV producers. OEM involvement such as Volvo with Clean Air Power should overcome
 constraints impacting on LCV development and              this.
 uptake? If so, what are they?
 Question 20: Are there barriers to the development of     No more than anywhere else.
 an indigenous low carbon vehicle industry in
 Scotland? If so, what are they and how might they be
 overcome?




                                                                               44
Question 21: Should Scotland’s industry focus on        No. But all should be assessed objectively in terms of well to wheel emissions so that CO2 from electricity
particular vehicle types? If so, what are they and      generation etc is taken into account
why? If not, why not?
Question 22: Are there gaps in the supply chain? If     As far as Dual-Fuel technology is concerned the supply chain is well established.
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         Suppliers of LCVs and alternative fuel companies could work together to provide a complete package for the
collaborate to stimulate the development and uptake     customer. This could be coupled with incentives with reduced fuel duty on alternative fuel or grants / loans
of LCVs?                                                from government towards purchase of LCVs or fuelling infrastructure.




                                                                           45
R23 - EDF Energy


RESPONDENT INFORMATION DETAILS
Name:                                                    Diego Sanchez-Lopez
Organisation:                                           EDF Energy
Address:                                                40 Grosvenor Place, London
Postcode:                                               SW1X 7EN
Email:
Telephone Number:                                       07875 110702.
Responding as:                                          On behalf of a group or organisation
Individual Permission:                                  Not Supplied
Confidentiality:                                        Not Supplied
Group or Organisation:                                  Yes
Share Response Permission:                              Yes
Question 1: Which low carbon technologies and fuels     EDF Energy believes that electric vehicle technology offers the most potential for an early roll out of low
do you envisage will be first to be influential in      carbon transport. It is our view that in the short term plug-in hybrid electric vehicles (PHEV) offer the
reducing GHG emissions from the transport sector?       greatest potential for early roll out with pure electric vehicles taking over in the medium to long term.
Why?
                                                        Current technology can meet the requirements of the vast majority of road users today and therefore the
                                                        key barriers are the charging infrastructure and ensuring that local networks (substations) are investigated
                                                        to identify whether reinforcing is required. In addition, it will be essential to ensure that the general public
                                                        are confident of the benefits of Electric Vehicles (EVs) and that any perceptual barriers to take up are
                                                        mitigated. These are both issues which are within the Scottish Government‟s remit to mitigate, working with
                                                        a number of key stakeholders.

                                                        In addition to the reduction of harmful Green House Gas (GHG) emissions, EVs also offer a number of
                                                        advantages over current or alternative fuel arrangements such as current availability of technology and
                                                        products and cost effectiveness. This includes but is not limited to security of supply by reducing imports,
                                                        reduction in noise pollution and retaining a full range of vehicles to satisfy consumer choice.

                                                        EDF Energy does not believe that the uptake of EV technology will lead necessarily to a significant increase
                                                        in the requirement of generated electricity demand. This additional electrical load could be met be ensuring
                                                        it occurs at times of low demand, for example through charging overnight, through the use of demand
                                                        management technology such as smart meters and financial and other incentives such as variable tariffs.
                                                        With the increase in intermittent electrical generation through renewable resources moving forward such
                                                        demand management will be required.
Question 2: Which low carbon technologies and fuels     Overall: Electric vehicles will offer the greatest emission abatement impact when linked to demand
do you believe will ultimately have the greatest        management technologies and incentives.
emissions abatement impact? Why?
                                                        Currently: Electric vehicle technology is now proven with vehicles developed across the full range of road
                                                        transport from motorcycles to 12t HGVs. There is no other technology which can truly deliver low carbon
                                                        transport which has been definitely proven and established in such a way as electric vehicles.
                                                        Long term: EVs will continue to deliver a decrease in emissions – as efficiencies improve and the electricity
                                                        grid is decarbonised.
Question 3: What timescales do you believe are          PHEVs and pure EVs are proven technologies which should now be rolled out at an increased level, being
feasible for the development of specific low carbon     commercially manufactured and available. If this takes place then EDF Energy is confident that the market
technologies and fuels? Are there any important         will be able to further increase efficiencies from this technology.
intermediate milestones within these timescales?
Question 4: What timescales do you believe are the      The two key barriers to the uptake of electric vehicles are the roll out of a suitable recharging infrastructure
feasible for the uptake of specific low carbon          and ensuring that local networks (substations) have sufficient capacity to meet the additional electricity
technologies and fuels? Are there any important         demand. In addition, public awareness of the benefits and rigour of such technology should be a key
intermediate milestones within these timescales?        strategy to ensure that uptake levels are increased.

                                                        All of these barriers could be overcome by the Scottish Government and will ensure that EV penetration
                                                        rates are significantly increased in the short-term. Therefore the timescales for the uptake of this technology
                                                        are within the Scottish Government‟s remit to influence.

                                                        The uptake of EV technology will also be increased through further developments in relation to „fast
                                                        charging‟ technology. Today, most electric vehicles are charged using a 240V/13A or 16A connection which
                                                        is common in a domestic property. This is often referred to as „slow charging‟.

                                                        The technology required for faster charging posts, and batteries that can accept higher levels of charge
                                                        without loss of performance is already available. However, these are still expensive and could have
                                                        negative impacts upon the electricity distribution networks, and location of this infrastructure must be
                                                        carefully planned.

                                                        Therefore, in the short term we see „slow charging‟ as the preferred model as the main source of charge but
                                                        that there is a case for locating some fast charging points in key areas and that further work to identify these
                                                        areas is required.
Question 5: Are there other barriers to the             EDF Energy is concerned that too much focus has been placed on the development of new fuels and
development of such fuels and technologies that are     technologies and that this could delay the uptake of proven low carbon transport technologies. Therefore,
not mentioned in this document? If so, what are         we would reiterate that the Scottish Government should focus upon the uptake of technologies which are
they?                                                   already proven and have the potential to be implemented rapidly.
Question 6: Are there other barriers to the uptake of   EDF Energy is not aware of other barriers which have not been discussed in the consultation document or
such fuels and technologies that are not mentioned      our response.
in this document? If so, what are they?
Question 7: Are there any negative social impacts       An issue which has been raised previously in relation to electric vehicles is that the lack of noise from
associated with either the development or uptake of     engines could result in an increase in traffic accidents. However, EDF Energy believes that this can easily
such technologies/fuels? If so, what are they?          be mitigated as the uptake of this technology is increased and that manufacturers already have solutions to
                                                        this issue, and are therefore best able to comment on this.
Question 8: What, if any, technical challenges would    There are three key aspects to this: a) when vehicles are charged, b) where vehicles are charged and c)
the grid reinforcement upgrades be likely to present?   what type of charging is used (i.e. slow or fast charging).
How might these be overcome?
                                                        The worst case scenario (in terms of impact on the network) would be a large number of vehicles,
                                                        concentrated in a particular geographical area, using fast charging at peak electricity times. It is in this
                                                        scenario that EDF Energy thinks that there is a real risk that total demand could exceed the capacity of the
                                                        network.

                                                        However, EDF Energy does not believe that the uptake of EV technology and the associated increased
                                                        electricity demand would necessarily lead to a significant increase in the requirement of electricity
                                                        generation capacity. Careful planning and use of incentives to manage the times when vehicles are charged
                                                        can be used to minimise this requirement. For example, owners can be encouraged, via the use of tariffs, to
                                                        charge overnight through „slow charging methods‟. In addition, publicly available „fast charging‟ stations
                                                        (which may be used most often during the day), should be strategically located near electricity substations,
                                                        in areas where capacity is available, or where networks can be most easily reinforced.

                                                        However, some local networks may need reinforcing and further work is required to identify such impacts so




                                                                           46
                                                          that these can be mitigated.
Question 9: Who would fund any grid upgrades?             As stated above EDF Energy believes that any required grid upgrades will be localised in nature. EDF
And, how might these costs be recovered?                  Energy would recommend that detailed discussions take place with DNO‟s to discuss how any such
                                                          associated costs can be mitigated most efficiently.
Question 10: Do any of the technologies present any       EV technology is ideally suited to island communities as the majority of journeys are likely to be relatively
specific challenges or opportunities to island            short.
communities and sparsely populated rural areas in         For other transport users it is not their geographical location but their transport requirements, and
Scotland? If so, how might these challenges by            specifically the length of journeys they require, which will impact on the most effective technology to meet
addressed, and by whom?                                   their low carbon transport needs. For most rural residents their transport requirements are within the
                                                          mileage range currently provided by EV technology.
Question 11: Do you think that having a twin              Public sector transport has a higher turn-over rate than other forms of transport and how this transport is
approach for the public sector and other users is         used is within the public sectors‟ control. Therefore EDF Energy believes that public sector transport should
appropriate? If so, why? If not, why not?                 be early adopters of low carbon transport solutions. This will demonstrate leadership, commitment and the
                                                          learning required to increase uptake from the wider population.
Question 12: If so, should targets relate to the uptake   EDF Energy has no strong view on which approach is adopted, as long as the targets set are ambitious and
of low carbon vehicles (either as a percentage of the     ensure that low carbon transport uptake is significantly increased. EDF Energy also believes that any such
fleet or an absolute number), or a reduction in total     targets should be technology neutral to ensure that the most cost-effective technologies are adopted, of
emissions across the fleets or another format of          importance at a time of restricted public expenditure budgets.
target? Why?
Question 13: If we follow a target relating to the        EDF Energy would support the most ambitious target achievable within the confines of public expenditure
public sector uptake of LCVs, what percentage of the      being adopted.
fleet should be LCVs by 2020? Please give reasons
for your answer.
Question 14: If we follow a target relating to the        EDF Energy would support the most ambitious target achievable within the confines of public expenditure
uptake of LCVs across all road users, what                being adopted. For wider road users of more importance than the level of target set is the incentives
percentage of all new vehicles should be LCVs by          provided to ensure that the barriers which prevent early adoption of LCV are mitigated.
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        No comment.
should be excluded from the public sector target? If
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        No comment.
than traditional vehicles (albeit with a smaller
discrepancy between lifecycle costs) do you
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      EDF Energy is not aware of any such barriers. In contracts, the great purchasing power of public sector
to public sector procurement of LCVs that are not         procurement could help to drive down the costs of LCV technologies and mitigate a number of barriers
mentioned in this document? If so, what are they?         which could limit the uptake by the general public.
Question 18: What are the individual roles of different   Broadly speaking, electric vehicle charging infrastructure falls into one of two categories; „on street‟ which
groups and organisations in ensuring the provision        refers to charging points located on public roads; and „off street‟ which refers to charging points located on
of any infrastructure required for low carbon             private property, such as homes, work places and car parks.
vehicles?
                                                          In our opinion, the majority of vehicle charging will take place off street, where it will be a commercial
                                                          decision for owners of suitable locations such as car parks as to whether they wish to install charging
                                                          infrastructure. Provision of Scottish Government incentives to encourage investment would be useful.

                                                          We also believe that there is a role for on street infrastructure; particularly in densely populated urban areas
                                                          like Glasgow where on street parking is more common. The fact that infrastructure is required on public
                                                          property raises two key questions which are discussed below.

                                                          First, who should be permitted/ required to install this infrastructure? Several possible options exist, ranging
                                                          from allowing full competition (i.e. any organisation is permitted to install infrastructure), to more co-
                                                          ordinated approaches, where local councils or perhaps electricity DNO‟s have responsibility for rolling out
                                                          the infrastructure. Second, to what extent should this be solely a commercially driven activity? For example,
                                                          organisations could decide when and where to install infrastructure when they see a positive business case
                                                          for doing so. Or there could be „investment ahead of need‟ with the belief that this will encourage more
                                                          drivers to adopt electric vehicles.

                                                          There are a number of benefits for „investment ahead of need‟ and for this to happen, Scottish Government
                                                          will need to either obligate a certain body to deploy the infrastructure (for example local councils, or
                                                          electricity DNO‟s) or tender for the role, with costs paid for by the public, either through national taxation,
                                                          local taxation, or electricity charges.
                                                          We do not currently have a definitive view on which option offers the greatest long term benefits at lowest
                                                          cost, and suggest that further work is carried out in this area. In our view, a „local council led‟ solution is
                                                          appealing on the grounds that councils already have responsibility for existing street furniture such as street
                                                          lighting, parking meters etc. However, in principle we are not opposed to the idea of electricity DNO‟s being
                                                          required to roll out the infrastructure, but do have concerns, which are detailed below.

                                                          First, it must be noted that installation, maintenance and operation of street furniture is not a standard,
                                                          regulated DNO activity. On street charging devices would therefore not simply be an additional activity that
                                                          a DNO could „tag on‟ to existing operations with little additional cost.

                                                          In addition, having responsibility for this infrastructure would require DNO‟s to deal with new risks – these
                                                          assets will be actively used by the public, with significant risks arising from attempted illegal abstraction,
                                                          vandalism, damage from vehicle impact etc.

                                                          Second, we cannot ignore the fact that electricity DNO‟s already have significant capital investment
                                                          obligations. Consideration will need to be given to the cost at which DNO‟s are able to raise the additional
                                                          capital, and to the long term implications for their financial stability (i.e. levels of debt).
Question 19: Are there other supply side/capacity         EDF Energy is not aware of any such supply side/capacity constraints at this time.
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of     EDF Energy is not aware of any such barriers.
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          EDF Energy has no set views on this issue.
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If       EDF Energy has no set views on this issue.
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      EDF Energy has no set views on this issue.
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           To stimulate uptake, the Scottish Government has a clear leadership role to provide long term direction and
collaborate to stimulate the development and uptake       incentives to ensure sufficient levels of uptake of LCV technology. Once this is provided then it will be




                                                                             47
of LCVs?   essential that all stakeholders are fully engaged working in collaboration to remove barriers and ensure
           significant levels of uptake are achieved.

           However, it is not possible for other stakeholders to fully understand the role they can play in increasing
           such levels of uptake without clear direction from the Scottish Government.




                              48
R24 - Energy Savings Trust


 RESPONDENT INFORMATION DETAILS
 Name:                                                 Ian Murdoch
 Organisation:                                         Energy Savings Trust
 Address:                                              2nd Floor, Ocean Point 1, 94 Ocean Drive, Edinburgh
 Postcode:                                             EH6 9GH
 Email:
 Telephone Number:                                     0131 5557902
 Responding as:                                        On behalf of a group or organisation
 Individual Permission:                                Not Supplied
 Confidentiality:                                      Not Supplied
 Group or Organisation:                                Yes
 Share Response Permission:                            Yes
 Question 1: Which low carbon technologies and fuels   There are still a lot of carbon savings that can come from making more efficient petrol and diesel cars.
 do you envisage will be first to be influential in    Maximising savings from diesel and petrol by buying best in class can deliver 25% fuel savings. Average
 reducing GHG emissions from the transport sector?     CO2 emissions of new cars in the UK have come down from 154g/km in August 2008 to 146g/km CO2 in
 Why?                                                  August 2009. This demonstrates the ability for fuel savings from traditional fossil fuels if consumers choose
                                                       lower carbon cars. There had also been an influx of lower carbon cars onto the market due to new car CO2
                                                       legislation and European countries introducing CO2 based taxes. A number of manufacturers are now either
                                                       offering or have launched new cars that are less than 100g/km CO2. Stop-start technology is expected to be
                                                       on all cars by 2018 and will offer CO2 savings of around 5%.
                                                       Eco-driving can also significantly reduce fuel use from conventional technologies. By driving more efficiently
                                                       a driver can reduce their fuel use by up to 15% and this is a key opportunity for rapid low cost carbon
                                                       savings in the transport sector.



                                                       The new car CO2 target for 130g/km by 2012 can be met with more efficient internal combustion engine
                                                       (ICE) petrol and diesel cars. However, the 95g/km target for 2020 and any longer term target will rely on the
                                                       uptake of newer technologies such as hybrids, plug-in hybrids (PHEVs) and electric vehicles (EVs).



                                                       Of new technologies EVs and PHEVs are the lowest carbon and closest to market. First generation biofuels
                                                       raise too many sustainability issues at the current time to be close to mainstream market. Developments in
                                                       second and third generation biofuels (such as those from waste or non-food crops) may enable biofuels to
                                                       offer a genuine low carbon solution. Both liquid hydrogen and hydrogen fuel cells are both far from market.
                                                       Our recent report „Revolution: the Road to a Low Carbon Future‟ (copy enclosed) modelled the uptake of
                                                       low carbon technology cars out to 2030. Our results show that hydrogen is so expensive that none of the
                                                       policy packages we modelled showed any uptake in the technology out to 2030.



                                                       Our report does show that with the right package of policy measures there could be mainstream uptake of
                                                       hybrids, PHEVs and EVs. However, this relies on policies that bring down the cost of the electric battery and
                                                       make the technologies more attractive such as consumer grants, higher oil prices, robust penalties for not
                                                       meeting EU CO2 targets, and taxes that make lower carbon technologies less expensive relative to
                                                       traditional fossil fuel cars. Of course there should be no automatic assumption that EVs and PHEVs will
                                                       deliver our low carbon future. There are a number of issues that will need to be addressed for this to
                                                       happen. For instance, although electric cars are generally more efficient than current petrol or diesel it is
                                                       important that EVs and PHEVs are held to the same CO2 targets as conventional ICE cars, so that all
                                                       emissions reduce. EVs may be zero emission at the tail pipe but it is important that they use energy
                                                       efficiently so that they do not put a unreasonable burden on the electricity grid and pose a challenge for our
                                                       national renewable targets.


                                                       It is also critical that as uptake of EVs and PHEVs occurs re-charging takes place during times of low
                                                       demand on the grid, such as during the night, and that electricity tariffs offer an incentive for this to happen.
                                                       This should also be considered when building infrastructure, for instance drivers must be able to access re-
                                                       charging infrastructure during the night. If most people relied on re-charging their vehicle when they were
                                                       working, ie during office hours, this could have devastating consequences on the grid and electricity
                                                       demand. It is an unlikely scenario but one to consider in infrastructure plans. Therefore, infrastructure
                                                       should be predominantly targeted at encouraging over night re-charging, but also should be accessible
                                                       during the day at stations, supermarkets, work places, and anywhere people leave their cars for any length
                                                       of time, so that drivers do not suffer from „range anxiety‟.
 Question 2: Which low carbon technologies and fuels   EVs can be zero emissions if the electricity they use is sourced from renewables. This will rely on
 do you believe will ultimately have the greatest      decarbonising the grid. Therefore, a lot of joined up policy is necessary between government departments,
 emissions abatement impact? Why?                      power companies and consumers. Tariffs will be needed to manage demand and ensure that cars are
                                                       recharged at the right time when demand is low (overnight). Our renewables targets are already very
                                                       challenging. It is therefore very important to make sure that increased demand for zero-carbon electricity
                                                       does not impact our renewables targets. The target is UK/Scotland wide and not just for one sector so it
                                                       makes little sense for EVs merely to push the burden onto another sector. Every sector will need to seek
                                                       CO2 reductions and transport is one area where there is a lot of potential for CO2 savings.

                                                       Advanced biofuels can offer significant carbon savings. Fuels developed from agricultural and forestry
                                                       waste can offer a sustainable low carbon fuel. Biomethane from waste can potentially actually have a
                                                       negative CO2 contribution in that methane from landfill is saved and fossil fuels are also replaced.
 Question 3: What timescales do you believe are        There are a number of manufacturers who have announced an EV or PHEV to come onto the market over
 feasible for the development of specific low carbon   the next two years. The Tesla Roadster and Citroen C1 are both available now, and the Mitsubishi iMiev,
 technologies and fuels? Are there any important       the Nissan Leaf and the GM Volt will all be available to purchase in the UK by April 2011, in time for the UK
 intermediate milestones within these timescales?      government‟s grant programme. The technology is ready but the costs are still very high and there are limits
                                                       to the range they can deliver.

                                                       Therefore, there needs to be policies to reduce the cost of the batteries and upfront cost of the technology
                                                       as well as deal with familiarity issues. People do not want to pay more for a car that has less utility.
 Question 4: What timescales do you believe are the    Our report Revolution: the Road to a Low Carbon Future shows that with high fuel costs of 141 pence per
 feasible for the uptake of specific low carbon        litre from 2016, a 10% year on year decrease in Lithium Ion battery costs and a £250 million grant
 technologies and fuels? Are there any important       programme of £2,500 per vehicle, EVs and PHEVs will not penetrate the mainstream market until after
 intermediate milestones within these timescales?      2020. In 2030 EV sales reach a total of 261,000, PHEVs 160,000 and diesel and petrol hybrids reach
                                                       combined sales of approximately 1 million. In this scenario there are more sales of low carbon technologies
                                                       than there are sales of conventional fossil fuel cars.
 Question 5: Are there other barriers to the           The provision of renewable energy is a potential barrier to the development of mainstream electric vehicles.
 development of such fuels and technologies that are   The consultation says that if all vehicles were electric then a 15% increase in electricity production would be
 not mentioned in this document? If so, what are       needed. This 15% would need to be renewable for the vehicles to be truly low emission – Scotland‟s current
 they?                                                 target of 50% of electricity to come from renewable sources by 2020 could therefore potentially be
                                                       impacted. Realistically, while all vehicles will not be electric by 2020 (according to even the most ambitious
                                                       estimate), there will still be around 2-8% more renewable electricity needed.




                                                                           49
Question 6: Are there other barriers to the uptake of     A key barrier to the uptake of EVs and PHEVs is consumer demand. Unless consumers want to buy electric
such fuels and technologies that are not mentioned        and plug-in hybrids there will never be mainstream uptake. The challenge is for manufacturers to make
in this document? If so, what are they?                   these cars attractive and affordable to consumers. But also there is a role to play for consumer facing
                                                          organisations such as the Energy Saving Trust to help drivers become familiar with the technologies and
                                                          help them understand and test the cars. The Green Fleet Reviews that we currently undertake aim to
                                                          increase such familiarity with low carbon vehicles and promote the advantages of low emission technology
                                                          to both the public and private sectors. Our five Energy Saving Scotland Advice Centres are more focussed
                                                          on the individual and our Sustainable Transport Advisors are involved in events around the country to
                                                          engage the public in sustainable travel. A key part of this is the focus on low carbon vehicles.

                                                          There is little incentive for most people to be an early adopter of technology, while the 2011 financial
                                                          incentive (grant programme) will make these technologies more affordable they will still be more expensive
                                                          than traditional diesel and petrol equivalents and there will be a natural wariness to hold off until better
                                                          models come along. Any further policies that can make new technologies more attractive such as free
                                                          parking, free re-charging, etc can be an incentive to consumers. Also, just allowing drivers to see and drive
                                                          the cars will be an opportunity to dispel any myths they may have about the capabilities of the cars as well
                                                          as allow them to feel familiar with the technology. The recent GreenFleet Scotland event at Ingliston,
                                                          sponsored by the Energy Saving Trust, gave business users the opportunity to test drive such vehicles and
                                                          talk to manufacturers about the latest low carbon vehicle technology. Additionally, a November 2009 event
                                                          co-hosted by ourselves and Axeon (manufacturers of vehicle battery packs) will aim to educate further as to
                                                          the advantages of electric vehicles.
Question 7: Are there any negative social impacts         There are a number of sustainability issues around biofuels. The UK has already revised its 10% biofuel
associated with either the development or uptake of       target. Concerns will remain until carbon saving benefits are clear and proven and sustainability issues
such technologies/fuels? If so, what are they?            addressed.
Question 8: What, if any, technical challenges would      Maximum load could be exceeded, though this may only be the case in busy urban centres or at remote
the grid reinforcement upgrades be likely to present?     points at the end of the grid. The variable tariffs or battery storage methods mentioned in the consultation
How might these be overcome?                              would help. A report by the Department for Trade and Industry in October 2008 on the scope to switch to
                                                          electric vehicles estimates a 2-8% increase in demand and that wholescale grid upgrades would not be
                                                          necessary.
Question 9: Who would fund any grid upgrades?             Ofgem are planning a £6.5bn upgrade of the grid over the next 5 years to aid decentralised energy
And, how might these costs be recovered?                  generation. Power companies could fund further work as they should be gaining revenue from increased
                                                          demand. This may raise issues over equity if costs were passed onto consumers e.g. those consumers with
                                                          no electric vehicle could be subsidising those that do with having to pay increased tariffs.
Question 10: Do any of the technologies present any       Remote areas may need grid reinforcement if there is extra demand for EVs and PHEVs. Due to the issues
specific challenges or opportunities to island            of limited range of electric vehicles, they may however not suit remote locations. There are opportunities in
communities and sparsely populated rural areas in         remote areas to combine local renewable generation and transport initiatives, for example the hydrogen fuel
Scotland? If so, how might these challenges by            cell electric vehicle project in Shetland.
addressed, and by whom?
                                                          Algal research for biofuel is underway in Oban. The coastal nature of Scotland benefits such research and if
                                                          successful the research could lead to a viable alternative fuel source – though this would be currently some
                                                          way off.
Question 11: Do you think that having a twin              We agree that there is a definite need for an approach to address both public and private sectors. However,
approach for the public sector and other users is         we would suggest that there should be a far greater emphasis on procurement divisions in the public sector.
appropriate? If so, why? If not, why not?                 Scotland Excel are becoming the central procurement agency for the public sector and we would like to see
                                                          them have strict environmental criteria such as a maximum threshold for CO2 reviewed and reduced on a
                                                          yearly basis for procuring vehicles.
Question 12: If so, should targets relate to the uptake   In addition to a target for average CO2 we would suggest that a separate target for Low Carbon Vehicles
of low carbon vehicles (either as a percentage of the     (sub-75g/km CO2 or EV in line with UK Government‟s definition under the Ultra Low Carbon Car grant
fleet or an absolute number), or a reduction in total     programme) be set as a means to stimulate the market for these new technologies. This should be set as a
emissions across the fleets or another format of          percentage of the fleet for number of LCVs purchased but also an overall cap on total CO2 emissions from
target? Why?                                              the fleet by 2020 to ensure that industry has a clear market for LCVs, and to safeguard that however many
                                                          vehicles are sold emissions reductions are ensured.

                                                          In the short term it is important to have a CO2 target for low carbon conventional technologies. The UK
                                                          central government has a fleet average procurement target of 130g/km CO2 by 2010/11. This target is line
                                                          with the European Commission‟s Green Public Procurement Toolkit. It is anticipated that Member States
                                                          will be encouraged to adopt this target in their own action plans and in their procurement guidance.
                                                          Therefore, we would suggest that the Scottish Government adopts this target for its own vehicle
                                                          procurement.

                                                          The vast majority of Scottish local authorities have taken part in the Energy Saving Trust‟s benchmarking
                                                          exercise for vehicles so the template should be there to report on total emissions and relate targets to that.
                                                          We are currently rolling this out this benchmarking approach to NHS fleets and university/colleges as well.
                                                          Emission caps for vehicles could also help complement a target of reducing total emissions and a reduction
                                                          in total emissions as a target could help to encourage eco-driving as complementary to LCVs.

                                                          Often ignored in relation to emissions is the area of the grey fleet where private vehicles are used for
                                                          business purposes e.g. one council alone pays mileage on over 5,000 grey fleet vehicles. Many
                                                          organisations may struggle to accurately record such vehicle detail where it does not come under their
                                                          ownership; however the carbon dioxide contribution can be significant. Whether targets can include the grey
                                                          fleet may be a challenging question but could have a large impact with regard to environmental savings.
Question 13: If we follow a target relating to the        We would suggest that by 2020 100% of all new vehicle purchases is a feasible target for the public sector.
public sector uptake of LCVs, what percentage of the      With the younger average age of public sector vehicles, this timeframe should give plenty of time for an
fleet should be LCVs by 2020? Please give reasons         adequate strategy to be formed and would provide a strong indication to industry that there is a market for
for your answer.                                          vehicles.
Question 14: If we follow a target relating to the        With the right mix of policies it is possible to shift the market towards low carbon cars. However, financial
uptake of LCVs across all road users, what                incentives are the key mechanism for doing this such as company car tax, VED and fuel duty are the
percentage of all new vehicles should be LCVs by          strongest levers that the UK government can pull to ensure people chose the lowest carbon cars. EU CO2
2020? Please give reasons for your answer.                legislation is also a very strong driver and currently there is a target for 95g/km CO2 for all new cars by
                                                          2020. This will need to be enforced with robust penalties for manufacturers for this to be met. For a
                                                          significant take up of ultra low carbon cars (sub-75g/km CO2 and EVs) policies aimed to reduce the cost of
                                                          the technology are needed. Our research shows that combined sales of PHEVs, EVs and conventional
                                                          hybrids will only overtake total sales of traditional petrol and diesel cars by 2030 in a policy scenario with EU
                                                          legislation, high fuel prices (141 pence per litre), £2,500 grant per EV and PHEV capped at £250 million,
                                                          and a lithium ion electric battery price of £100 kWh.
Question 16: As LCVs may have higher upfront costs        It may not be feasible to include HGVs in the target because of large investment needed. We would also
than traditional vehicles (albeit with a smaller          suggest that certain specialised emergency and defence vehicles should not be subject to the same targets
discrepancy between lifecycle costs) do you               as they may one-offs or little used and replaced less frequently. We are however aware that other
consider it to be efficient use of public resources to    emergency vehicles could be replaced.
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 16: As LCVs may have higher upfront costs        The Stern Review‟s conclusion is relevant in that investment is needed now to mitigate climate change and
than traditional vehicles (albeit with a smaller          to prevent far greater costs being incurred in the future to deal with the consequences of climate change. In
discrepancy between lifecycle costs) do you               these times of limited public spending there may be a potential for public backlash if the sector is making
consider it to be efficient use of public resources to    large investment in LCVs. However, we do not see this as a serious risk if the communications of this
devote a greater short-term budget towards the            spending is handled sensitively and the fuel and any cost savings are emphasised.
purchase

Question 17: Are there any opportunities or barriers      Procurement divisions within organisations may not all be aware of the advantages of LCVs. Also




                                                                             50
to public sector procurement of LCVs that are not         responsibilities can be spread out, for instance, we know of one council that has six individuals with
mentioned in this document? If so, what are they?         separate procurement responsibilities. This type of decentralised implementation could be a significant
                                                          barrier to uptake.
Question 18: What are the individual roles of different   The potential for profits to be made should ensure that with the right incentives the proper infrastructure can
groups and organisations in ensuring the provision        be put in place. Global organisations such as Tesco and McDonalds are already setting up electric charging
of any infrastructure required for low carbon             points on their premises. Glasgow Council‟s involvement in electric vehicle trials should be capitalised on
vehicles?                                                 and if successful replicated elsewhere. Similar to London‟s desire for a prominent electric vehicle presence
                                                          for the Olympics, the Commonwealth Games in Glasgow 2014 could provide a target for a visible electric
                                                          presence.
Question 19: Are there other supply side/capacity         Presently there is no route to maintain some makes of electric vehicles in Scotland. As established on one
constraints impacting on LCV development and              occasion, a vehicle manufacturer was willing to supply vehicles to be located in Scotland but required them
uptake? If so, what are they?                             to be returned to base for annual maintenance which would have necessitated vehicles being transported
                                                          back to southern England.
Question 20: Are there barriers to the development of     There is the historical barrier of a lack of car industry. Similar support to that which the UK government is
an indigenous low carbon vehicle industry in              giving to encourage manufacturers to remain in England is needed in Scotland to attract manufacturers and
Scotland? If so, what are they and how might they be      incentivise current Scottish based companies like Allied and Axeon to remain here.
overcome?
Question 21: Should Scotland’s industry focus on          It might be wise to keep options open while technologies are still developing; however mainstream take up
particular vehicle types? If so, what are they and        will not occur unless commitment is made to infrastructure. Global developments should be monitored as
why? If not, why not?                                     this will also have an impact on mainstream take up and cost of technologies.
Question 22: Are there gaps in the supply chain? If       There is a gap in the supply chain regarding the maintenance of electric vehicles. One could assume that
so, what are they and how might these be overcome?        the industry would provide the required training for technicians but we have identified elsewhere in this
                                                          response a potential issue of vehicles possibly having to be returned to base (in southern England) for
                                                          annual maintenance.
Question 23: Do we have the required skills base for      This is not an area where the EST has expertise.
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           An overarching group of representatives from interested parties would ensure effective communication and
collaborate to stimulate the development and uptake       knowledge sharing takes place such as the New Automotive Innovation and Growth Team (NAIGT) that has
of LCVs?                                                  been developed in co-operation with the UK government.
                                                          [1]
Additional Information                                        Energy Saving Trust, Revolution: Road to a Low Carbon Future, August 2009
                                                          [2]
                                                              These figures are based on a model that looked at C/D market segment (such as a Ford Focus only to extrapolate
                                                          findings out to the wider market. Therefore, figures do not assume a shift towards smaller A/B segment cars (such as
                                                          Ford Ka) or larger cars. Therefore, the figures are only indicative.
                                                          [3]
                                                              BERR, 2008. Investigation into the Scope of the Transport Sector to Switch to Electric Vehicles and Plug-in Hybrid
                                                          Vehicles.
                                                          [4] http://www.berr.gov.uk/files/file48653.pdf
                                                          [5] http://www.pure.shetland.co.uk/html/pure_project1.html
                                                          [6]
                                                              http://ec.europa.eu/environment/gpp/pdf/toolkit/transport_GPP_product_sheet.pdf




                                                                              51
R25 - Scottish and Southern Energy


 RESPONDENT INFORMATION DETAILS
 Name:                                                     David Densley
 Organisation:                                             Scottish and Southern Energy
 Address:                                                  200 Dunkeld Road, Perth
 Postcode:                                                 PH1 3AQ
 Email:
 Telephone Number:                                         01738 456586
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Initially there will be incremental improvement through efficiency gains of conventional vehicles in all vehicle
 do you envisage will be first to be influential in        sectors. In the longer term we believe that there will be different solutions for different transport
 reducing GHG emissions from the transport sector?         requirements. For cars and light vehicles, we believe electric vehicles, both pure electric and plug in hybrid,
 Why?                                                      will become more influential. This is because EVs have greater potential for GHG emission reduction, and
                                                           also tend to reduce dependency on fossil fuels, the price of which is expected to become more volatile as
                                                           demand continues to increase and reserves become depleted. For heavy vehicles, we believe that pure
                                                           electric vehicles are unlikely to meet the performance requirements of the sector. Therefore hybrids,
                                                           hydrogen and biogas appear to be the most likely technologies to be deployed
 Question 2: Which low carbon technologies and fuels       We believe that, ultimately, fully electric vehicles will have the greatest emissions abatement potential. This
 do you believe will ultimately have the greatest          is because as energy production is sourced increasingly from renewables (and nuclear) the well to wheel
 emissions abatement impact? Why?                          emissions will drive even lower. Even with the present grid mix, EVs produce fewer emissions than
                                                           conventionally fuelled vehicles
 Question 3: What timescales do you believe are            Current EVs do not have the range of conventional fuelled cars, but battery technology is continuing to
 feasible for the development of specific low carbon       evolve, particularly in terms of power density. We expect that over the next ten years, significant progress
 technologies and fuels? Are there any important           will be made across all low carbon technologies and fuels. An important intermediate review point would be
 intermediate milestones within these timescales?          2015 in terms of state of development of batteries (price, power density, charge rate) and range
                                                           expectations of EV users based on the experience of large scale trials. The relative costs of pure EV and
                                                           plug-in hybrid should also be kept under review.
 Question 4: What timescales do you believe are the        We believe uptake along similar time scales is feasible but depends upon consistent government policy in
 feasible for the uptake of specific low carbon            support of the lower carbon technologies. It is also dependent on customer attitudes and expectations on
 technologies and fuels? Are there any important           the price and performance of LCVs. Hydrogen is a more challenging technology but there may be
 intermediate milestones within these timescales?          opportunities for demonstration of a hydrogen corridor or extension of the pilot schemes already under way
                                                           in some Scottish Islands
 Question 5: Are there other barriers to the               The key barriers mentioned in the report are the initial purchasing costs of batteries and the range of the
 development of such fuels and technologies that are       pure EVs. While it is true that both of these elements are barriers, we believe that a range of 100 miles
 not mentioned in this document? If so, what are           would be acceptable for most types of use, particularly as the second car, provided the costs of the car
 they?                                                     could be brought down. Range extension in the short to medium term might be more readily achievable
                                                           through plug in hybrid technology so that most daily short trips could be achieved on battery power, with
                                                           only longer trips needing the internal combustion engine to recharge the battery.
 Question 6: Are there other barriers to the uptake of     Apart from cost, uptake will depend on suitable infrastructure for refuelling, whether EV charging points or
 such fuels and technologies that are not mentioned        biogas / hydrogen refuelling stations. A key barrier to the installation of infrastructure, particularly for EV, is
 in this document? If so, what are they?                   the lack of a standard (apart from slow charging at 13A) for both the charging requirement of the vehicles,
                                                           and for the electrical connectors
 Question 7: Are there any negative social impacts         Changing the vehicle technology or fuel alleviates CO2 and security of fuel supply issues, but does not
 associated with either the development or uptake of       mitigate the wider impacts of mass car ownership. These include congestion, road traffic accidents,
 such technologies/fuels? If so, what are they?            environmental impacts of road building and car manufacture etc. Attention should continue to be paid
                                                           towards more sustainable modes of transport such as public transport
 Question 8: What, if any, technical challenges would      We believe that the higher voltages of the electricity grid would be unlikely to require reinforcement even
 the grid reinforcement upgrades be likely to present?     with large uptake of electric vehicles. We would expect domestic users of electric vehicles to recharge them
 How might these be overcome?                              predominantly overnight through the use of currently available off-peak tariffs such as economy seven. This
                                                           would mean that in most cases, no reinforcement would be required. The key exceptions will be where there
                                                           is clustering of EVs, and where the EV is plugged into a household which already has a high electrical load
                                                           or is supplied through a less resilient network. In both cases this could result in power quality problems for
                                                           both the EV user and neighbouring properties. It will therefore be important for network operators to be
                                                           aware of purchases of EVs and the home addresses where they will be kept. This may require registration
                                                           data to be provided to network operators so that network capacity can be assessed beforehand.
 Question 9: Who would fund any grid upgrades?             The regulatory framework provides for capital expenditure programmes to be funded through “use of
 And, how might these costs be recovered?                  system” (UOS) charges from all users. The energy supplier pays the network operator its UOS charges and
                                                           recovers the costs from customers within the bundled tariff that also covers the energy costs. EV users will
                                                           have to buy their electricity from an energy supplier and so will automatically provide additional use of
                                                           system revenue to the network operator.

                                                           To illustrate the principle, assume that the annual cost of investing in and operating the Scottish distribution
                                                           system is £500m and that 30TWh of electricity is distributed . The network operators charge electricity
                                                           suppliers for “use of system” to recover these costs. This equates to 1.67p/kWh as an overall average. The
                                                           consultation indicates that if 20% of Scottish cars were fully electric, an additional 1 TWh of electricity would
                                                           flow over the network. If the network operators did not face any additional costs from EVs, the average use
                                                           of system charge would have to decrease to keep revenues at £500m. Conversely, keeping the average
                                                           use of system charge at 1.67p, the annual revenue would increase to 31/30 x 500 = £517m, generating an
                                                           additional annual revenue of £17m which could be used to fund infrastructure for EVs without impacting the
                                                           costs for other customers. Since this annual revenue only represents operating costs plus the financing
                                                           costs of capital expenditure, this additional £17m could fund well over £100m of capital expenditure.
 Question 10: Do any of the technologies present any       One of the challenges for rural areas is the relatively weak electricity distribution system. These areas also
 specific challenges or opportunities to island            have little mains gas and so rely on electric heating in many cases. With the additional load of electric
 communities and sparsely populated rural areas in         vehicles, this could cause local loading problems. However, there is also an opportunity, particularly on
 Scotland? If so, how might these challenges by            island areas where weak connections to the mainland have prevented the development of local renewable
 addressed, and by whom?                                   generation. In these cases electric vehicles could be combined with local generation to absorb any excess
                                                           generation and reduce the need for reinforcement.
 Question 11: Do you think that having a twin              We think it is appropriate for the public sector to lead in LCV technology because a target based approach
 approach for the public sector and other users is         has the capability to overcome the initial adverse economic position of some technologies, and provide a
 appropriate? If so, why? If not, why not?                 path to scaling up production towards full commercialisation
 Question 12: If so, should targets relate to the uptake   We believe that a reduction in total emissions would be the most appropriate target because this is the
 of low carbon vehicles (either as a percentage of the     ultimate policy aim. It is also technology neutral and will allow the most cost-effective solutions to evolve.
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        As a long term aspiration for 2020, it may be appropriate to target 100% usage of low carbon vehicles so
 public sector uptake of LCVs, what percentage of the      that clear leadership can be demonstrated. Also, signalling the intention to manufacturers will facilitate
 fleet should be LCVs by 2020? Please give reasons         scaling up to fully commercial production
 for your answer.
 Question 14: If we follow a target relating to the        A target based approach for all road users would have to have lower aspirations because the take up will
 uptake of LCVs across all road users, what                depend on the incentives (or disincentives for conventional vehicles) that are in place. That said, a target of




                                                                               52
percentage of all new vehicles should be LCVs by          50% seems achievable, given that fleets turn over every thirteen years or so.
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        In principle, all sectors should be included. The initial focus is expected to be on electrification of light goods
should be excluded from the public sector target? If      vehicles and cars, but heavier vehicles could be converted to biogas etc as the technology develops
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        We do believe it is efficient use of public resources to target low carbon vehicles. The public sector ahs
than traditional vehicles (albeit with a smaller          sufficient volume requirements to drive the technology costs downward and show leadership in this area
discrepancy between lifecycle costs) do you
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      Government has to take a leading role in setting the procurement objectives for the public sector, and
to public sector procurement of LCVs that are not         developing the incentives for private sector migration to LCVs. Energy Utilities have a role of developing and
mentioned in this document? If so, what are they?         installing standardised open access infrastructure and the billing arrangements in conjunction with charging
                                                          post manufacturers, electrical equipment manufacturers and software companies
Question 18: What are the individual roles of different
groups and organisations in ensuring the provision
of any infrastructure required for low carbon
vehicles?
Question 19: Are there other supply side/capacity         A key supply side constraint is in the manufacture of lithium battery packs for electrical vehicles. It will take
constraints impacting on LCV development and              some time to scale up the manufacturing facilities and there is a technology risk attached in that there are
uptake? If so, what are they?                             several competing cell chemistries in development
Question 20: Are there barriers to the development of     Scotland does not have a high volume vehicle producer, but has a number of companies active in the LCV
an indigenous low carbon vehicle industry in              area that are key in developing the industry in Scotland. A potential barrier is the small scale of these
Scotland? If so, what are they and how might they be      companies, and Government should be prepared to support product development and upsizing.
overcome?
Question 21: Should Scotland’s industry focus on
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           Collaborative projects such as the Technology Strategy Board‟s Ultra Low Carbon Vehicle Demonstration
collaborate to stimulate the development and uptake       (ULCVD) Project help in both the development of LCVs and the initial deployment of supporting
of LCVs?                                                  infrastructure. More and larger projects can help with public perceptions of practicality of LCVs




                                                                              53
R26 – British Vehicle Rental and Leasing Association


    RESPONDENT INFORMATION DETAILS
    Name:
    Organisation:                                                                   British Vehicle Rental and Leasing Association
    Address:                                                                        River Lodge, Badminton Court, Amersham, Buckinghamshire
    Postcode:                                                                       HP7 0DD
    Email:
    Telephone Number:                                                               01494 434747
    Responding as:                                                                  On behalf of a group or organisation
    Individual Permission:                                                          Not Supplied
    Confidentiality:                                                                Not Supplied
    Group or Organisation:                                                          Yes
    Share Response Permission:                                                      Yes




Executive Summary
The BVRLA and its members welcome the opportunity to comment on the Scottish Government‟s consultation on „Low Carbon Vehicles‟. In particular we welcome the
opportunity to provide our thoughts on how our industry is able to support the government‟s long term plans for low carbon vehicles.
As our members own and manage in excess of 2.6 million vehicles, the detail of the Scottish government‟s thinking on delivering low carbon transport is of specific
interest to
us. We have in our response outlined the key belief that our industry has a key role to play in assisting the government‟s long term target in reducing CO2 emissions and
congestion. Through experience and research by our members we can provide sufficient evidence that rental and leasing can play a key role in helping getting low carbon
vehicles on the roads of Scotland. We sincerely hope this will prove to be of value when drafting proposals for incentives to encourage take up and consideration is being
given
to targets. It is vital that government does not introduce initiatives which would erode the excellent work achieved by our industry to date.
The BVRLA members‟ play a key role in promoting the right for all to enjoy cost effective road transport that is operated in a socially responsible manner. We remain
proud to be able to support solutions that help to deliver the operation of greener and fuel efficient vehicles.

The role of rental and leasing
Over the past year our members have undertaken extensive research on the attitudes to car ownership. A recent study1 by one of our members has found that 1 in 3
drivers
(34%) now think that people are trapped into car ownership by their location, work and family commitments. And, around 1 in 4 thinks that the cost of ownership
outweighs the
benefits. Further research suggests that, in the pursuit of short-term cost cutting measures, drivers could be missing the bigger picture because they don‟t have a clear
understanding of the true costs of running one or two cars. In a bid to cut costs, 68% of drivers have cut the number of journeys they are making and 46% have changed
the way they drive to conserve fuel. Plus motorists are cutting costs for servicing, maintenance and roadside assistance, this could have serious implications for their
safety and could also affect re-sale values. In reality public transport is not providing the solution and there is an opportunity for car clubs and car rental as a viable
alternative.

Our members are seeing an increase in rental for day to day needs and as an alternative to multiple car ownership. 54% of the cost of running a car is fuel and over 70%
of that cost is fuel tax and VAT. By renting a car they can eliminate all the other costs - insurance, maintenance and roadside assistance and also reduce fuel
consumption by as much as a third by driving a nearly new car in a more efficient way. Research has shown that 23% have either used or are considering using car rental
as an alternative to
car ownership. Research indicates that each car rental can replace up to 20 privately owned vehicles on the capital's roads, and members reduce their car use by more
than a third (36%). In addition to this Transport for London (TfL) statistics have shown that 20% of car club users gave up their car in 2006 and 30% have deferred from
purchasing a car. On average former car owners who join car clubs or use car rental can see their annual mileage decrease by around 25% while the use of public
transport and cycling increases by 40%. In the UK former car owners increase their use of non-car transport modes by 40% after joining a car club. The Scottish
Government can also look towards vehicle leasing to help achieve its goal of reducing transport emissions. The Government has explained that it wants to ensure that the
tax system properly reflects and supports business activity, in addition to promoting fairness and environmentally friendly travel. Leasing companies offer a range of
products and services to help fleet operators reduce their carbon footprint. There are a number of tax incentives for customers who choose to lease a vehicle, over the
past few years the government has introduced a number of new initiatives to encourage people to choose cleaner vehicles.

The company car tax rules introduced by government have altered the behaviour of not just our members‟ customers but the behaviour of our members as well. It is
patently
evident that the current CO2 banding system introduced by the government has provided an incentive for company car drivers to reduce emissions. This key behavioural
influencer has resulted in the average tailpipe CO2 emissions from the fleet of cars provided by our leasing members to decline. With the tax incentives in place this has
persuaded many customers and our members to choose lower CO2 vehicles. HM Revenue and Customs evaluation of the company car tax system showed that the
company car tax reform has encouraged substantial numbers of people to choose cars with lower CO2 emissions figures. Average CO2 emissions figures from company
cars
were around 15g/km lower in 2004 than would have been the case if the reforms had not taken place. In addition, their evaluation shows that around 60% of company car
drivers who were given a choice of company car by their employers were influenced by the company car tax reform and as a result chose cars with lower CO2 emissions
figures. The company car sector is already reducing CO2 emissions more quickly than the overall general UK car market, and the new tax rules will accelerate this trend.
According to figures from BVRLA member fleets, average company car CO2 emissions have fallen 6% since 2003, to 157.4g/km. This compares to 164.9g/km, the
average new car CO2 figure given by the Society of Motor Manufacturers and Traders (SMMT).

Incentives for the take up of low carbon vehicles
As we have worked closely with the Department for Transport on shaping their latest proposals for encouraging the take up of ultra low carbon cars we thought it would be
beneficial to share our thoughts with the Scottish Government on the role of rental and leasing companies in such an incentive approach.

Vehicle standards
We agreed with the Department‟s proposals for vehicle criteria but suggested that a staggered approach to the incentive could be taken so that a full electric vehicle with
zero emissions receives a larger incentive than a vehicle emitting 75 g/km CO2. We also suggested that the vehicle should be capable of doing the national speed limit of
70mph for motorway journeys and the safety standards should be 5 star or equivalent EuroNCAP rating. Our view was that the incentive should be available for light
commercial vehicles as well given the developments taking place in that market.

Grant option
Our members welcomed a grant option to help offset the initial high purchase cost of an electric vehicle and are pleased that government have recognised that it should
be open to private individuals and business users. We would recommend that for business customers it should be possible to put forward a proposal to purchase a
number of vehicles using one simple approach and then a lump sum from the grant is issued to the commercial buyer. This would be welcomed by our rental members as
it would provide them with an opportunity to select a branch to establish as an electric vehicle location, potentially in line with one of the winning cities of the „plugged in
places‟ programme and use the subsidy to assist them with the vehicle purchase or adaptation of the branch. Our leasing members also see this as beneficial as again
they could work with their fleet customer to apply for the grant and reduce the risk in terms of the cost. The key message from our members in terms of the grant is that
the department should ensure that the grant is simple to apply for many of our members and their customers have experience of the Powershift grant which was
particularly burdensome in terms of the application process.

Plugged in places
We welcomed the proposals for plugged in places and envisage our rental members will be working closely with those cities which have successfully been awarded funds
to
become a low carbon city. We suggested that the role of rental and car clubs will be vital in helping those low carbon cities achieve their goals in terms of delivering and
facilitating an early market for electric vehicles. Rental branches in cities, at airport and railway stations will be able to provide a simple alternative where public transport
is unable to fit the bill. They ideally bridge the gap between public transport and the specific needs of individuals whilst supporting the wider integrated transport solution.



1
  This was a survey conducted by one of our rental members between 23rd and 25th September 2008. 1,563 UK Adults who own or use a car were surveyed – a
representative sample of all UK adults.




                                                                                      54
Other areas for consideration
There are a few other areas which we feel the Scottish Government may wish to consider in helping to encourage take up and perhaps determine where future budgets
would be best used. Firstly with regards to tax incentives, it is vitally important that any tax incentives, such as reduction in VAT, free road fund tax, no fuel duty etc is
given
longevity. This will help to ensure take up by first purchasers of the vehicles and provides real incentives to the second and third buyer.
In terms of other incentives for the second hand buyer our members felt that the following should be given careful consideration: insurance reduction, no cost parking,
second life battery support, on congestion charges and VAT incentive on disposal. These incentives should be harmonised across all authorities in Scotland so an electric
vehicle owner will know wherever they are travelling that they are exempt from parking charges.

Closing Comments
We hope our comments add value and help shape and develop the Scottish Governments thinking on setting objectives and developing a realistic action plan to help
deliver low carbon vehicles in Scotland. We are more than happy to discuss any aspect of our submission and hope to be further involved as the proposals are finalised.
We hope the Government will recognise the needs of our members and also the vital role we can play in encouraging the take up of low carbon vehicles.

Leasing Members
In general, vehicle leasing, sometimes referred to as long term rental, is an arrangement where the user (the hirer) simply hires the use of the vehicle and assumes
operational
responsibility for a predetermined period and mileage at fixed monthly rental from the owner (the leasing company). Legal ownership is, in the majority of cases, retained
by
the leasing company.

Short Term Rental Members
Rental Members offer daily, weekly and monthly rental of vehicles to corporate and retail customers. As explained above, the contract hire and daily rental Members are
the owners of the vehicle.

Bona-fides BVRLA, the Industry and its Members
The BVRLA is the trade body for companies engaged in the leasing and rental of cars and commercial vehicles. Its Members provide rental, leasing and fleet
management
services to corporate users and consumers. They operate a combined fleet of 2.6 million cars, vans and trucks, buying 44% of all new vehicles sold in the UK.
· Through its Members and their customers, the BVRLA represents the interests of more than two million business car drivers and the 10 million people who use a rental
vehicle each year. As well as informing the Government and policy makers on key issues affecting the sector, the BVRLA regulates the industry through a mandatory
code of conduct




                                                                                    55
R27 - Cairngorms National Park
 RESPONDENT INFORMATION DETAILS
 Name:                                                     John Thorne
 Organisation:                                             Cairngorms National Park
 Address:                                                  14 The Square, Grantown-on-Spey
 Postcode:                                                  PH26 3HG
 Email:
 Telephone Number:                                         01479 870520
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       The best low carbon energy is the one that allow us to change the fuel origin without requiring a change in
 do you envisage will be first to be influential in        vehicle fleets as circumstances and availability of fuels change. Electric and hydrogen vehicles allow for this
 reducing GHG emissions from the transport sector?         change, being the medium for storing energy that has been generated by a wide possible variety of fuel
 Why?                                                      types. Through connection to a local supply of fuel, or the National Grid, energy can be stored in batteries or
                                                           in hydrogen. There are concerns however that conversion of energy into hydrogen for use in transport is the
                                                           most efficient use for hydrogen technology (concerns that it is good or bad??). Bio-fuels are still an option,
                                                           but our technology and knowledge must increase before their wide-spread use. At present their extensive
                                                           use would impact excessively on other land uses. Their use may remain niche, for areas where electric or
                                                           hydrogen options are not viable, for example in aviation or shipping if such engines can be adapted for their
                                                           operation.
 Question 2: Which low carbon technologies and fuels       The future will be a mix of solutions. Some modes of transport will be best suited to electric, hydrogen, bio-
 do you believe will ultimately have the greatest          fuels or transfer of the need altogether, for example in moving long-distance road freight onto rail. The
 emissions abatement impact? Why?                          CNPA is helping to run a demonstration project on electric vehicles in the Cairngorms National Park. Part of
                                                           an EU programme to help communities adapt to the effects of climate change, the Northern Periphery
                                                           Programme‟s Clim-ATIC project is funding the electric vehicle. It is being given to a local community car
                                                           group to trial up to 2011. A converted Vauxhall Astra, it has a range of 140km, a top speed of 80kph and
                                                           can handle hills much like a petrol car. It will be assessed by the drivers and lessons learned from the use of
                                                           an electric car in a remote, rural environment.
 Question 3: What timescales do you believe are            What timescales do you believe are feasible for the development of specific low The market is best for
 feasible for the development of specific low carbon       delivering LCVs (do you mean the „it is best to let the open market determine the best means for delivering
 technologies and fuels? Are there any important           LCVs‟?). When fuel prices spiked there was a sudden resurgence in the interest in LCVs, driven by
 intermediate milestones within these timescales?          economic necessity. It does however rely on government incentives and policy to be delivered quickly and
                                                           effectively. There is market failure in the research and re-tooling of vehicle manufacturers, the fuel delivery
                                                           systems such as the national grid, and refuelling stations which need to be adapted from petrol to biofuels,
                                                           hydrogen, LPG or electric battery recharging. Timescales will depend on the will for change, but
                                                           technologies exist to deliver electric vehicles now, and hydrogen within five years.
 Question 4: What timescales do you believe are the        LCVs cannot solve everything. Some issues such as freight require us to give up long-distance road
 feasible for the uptake of specific low carbon            transport and deliver via rail and onward via LCV local delivery vehicles. Further uptake will depend on the
 technologies and fuels? Are there any important           tax regimes and incentives delivered by government, which will set the timetable.
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               The market needs to be utilised so that it makes economic sense for vehicle manufacturers and users to
 development of such fuels and technologies that are       make and use LCVs.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     We need to address the infrastructure around Scotland to ensure that users have a choice of re-fuelling
 such fuels and technologies that are not mentioned        options in rural and urban areas. The status quo is at present the easiest option. Changes in the market are
 in this document? If so, what are they?                   required through taxation and incentive schemes.
 Question 7: Are there any negative social impacts         New technologies can leave vulnerable groups left behind and isolated. On the other hand not developing
 associated with either the development or uptake of       these technologies will leave the poorer in society unable to afford vehicle transport, or the products
 such technologies/fuels? If so, what are they?            delivered by them. We need to work with organisations representing those on low incomes, disabled people,
                                                           elderly and young people to ensure no-one gets left without access to appropriate, affordable transport.
 Question 8: What, if any, technical challenges would      Local generation of power should be considered alongside strengthening the grid. We need to balance our
 the grid reinforcement upgrades be likely to present?     need for energy alongside our natural heritage. Generating energy on a local basis, especially within cities,
 How might these be overcome?                              can help alleviate the effects on rural areas. At the same time, smaller units and community owned power
                                                           generation can be a powerful enabler and revenue generator within rural areas.
 Question 9: Who would fund any grid upgrades?             The grid will become part of the transport infrastructure, so could be part-funded through vehicle/fuel
 And, how might these costs be recovered?                  taxation.
 Question 10: Do any of the technologies present any       They present opportunities. Previous petrol stations could be transformed to supply hydrogen and swapping
 specific challenges or opportunities to island            of batteries for electric vehicles. Rural areas, dependent on imported fuel, could generate their own fuel for
 communities and sparsely populated rural areas in         transport.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              The public sector need to audit their vehicle use and establish the best vehicle for each role, taking into
 approach for the public sector and other users is         account cost/payback periods over the estimated life of the vehicle. Policy should allow for more expensive,
 appropriate? If so, why? If not, why not?                 but environmentally friendly choices to be made if the effect is better in the long-term. The public sector
                                                           have a chance to lead on this issue, and could do so immediately.
 Question 12: If so, should targets relate to the uptake   A requirement to audit vehicle use would be more effective than just a target. Any target should be set
 of low carbon vehicles (either as a percentage of the     around the total reduction in emissions, and an annual decrease could be linked to each area of
 fleet or an absolute number), or a reduction in total     government. Every requirement would then be met by a suitable vehicle. For example, short van runs would
 emissions across the fleets or another format of          suit electric; inner city use would suit hybrid; longer runs, diesel. The default should be the lowest carbon-
 target? Why?                                              emitting vehicle and any higher carbon vehicle justified by the audit process. This could weed out a lot of
                                                           4x4s and other higher emission vehicles, and is a process the CNPA has already gone through with its own
                                                           pool car fleet.
 Question 13: If we follow a target relating to the        The public sector is the ideal place to trial new technologies such as electric and hybrids. There could be a
 public sector uptake of LCVs, what percentage of the      target for each area of government to demonstrate a percentage of their fleets as ultra-LCV, allowing them
 fleet should be LCVs by 2020? Please give reasons         to off-set any additional higher start-up cost to future savings.
 for your answer.
 Question 14: If we follow a target relating to the        Market and government incentives and tax regimes would be more effective than simply setting a target. By
 uptake of LCVs across all road users, what                2020 new technologies, if given the proper market environment to grow, should mean an end to petrol and
 percentage of all new vehicles should be LCVs by          diesel car manufacture. This is important for the economy as a whole, as oil is likely to be too expensive for
 2020? Please give reasons for your answer.                transport use after that time. Targets should also include switching from road use altogether, for example
                                                           moving passenger and freight journeys onto rail.
 Question 15: Are there any vehicle categories that        No.
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        At present, „best value‟ often means buying higher carbon vehicles, when a more expensive LCV could save
 than traditional vehicles (albeit with a smaller          money in the long-term. We need to link capital and revenue budgets to provide the best long-term saving to
 discrepancy between lifecycle costs) do you               the environment and monetary cost, and require budget-holders to consider the environmental and long-
 consider it to be efficient use of public resources to    term aspects of purchasing.
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      The status quo is easier than looking at change in fleets.
 to public sector procurement of LCVs that are not




                                                                              56
mentioned in this document? If so, what are they?
Question 18: What are the individual roles of different   Government should lead on LCVs and provide the taxation and incentive infrastructure to create the market
groups and organisations in ensuring the provision        to make LCVs happen.
of any infrastructure required for low carbon
vehicles?
Question 19: Are there other supply side/capacity         There is a demand issue which can be alleviated by the public sector taking a lead and demonstrating best
constraints impacting on LCV development and              practice.
uptake? If so, what are they?
Question 20: Are there barriers to the development of     We need to expand and link academic research to industry, raising the priority of transport and fuel
an indigenous low carbon vehicle industry in              research. We have an outstanding resource in the oil industry, much of which could be adapted to new
Scotland? If so, what are they and how might they be      technologies given the right incentives and tax breaks, much as the North Sea was developed in the 1970s.
overcome?                                                 We need to use assets such as our National Parks to demonstrate and lead change.
Question 21: Should Scotland’s industry focus on          No. The future is unclear as to which technology and vehicle types will become important. It is possible to
particular vehicle types? If so, what are they and        foresee a future where long-distance passengers move onto high-speed rail leaving older lines open for
why? If not, why not?                                     mass freight transit, but this lies some way ahead. Government should help the private sector fill the market
                                                          failure gap caused by this uncertainty about which technology will become dominant but assisting research
                                                          and pilot projects in as wide a range of fuel options as possible.
Question 22: Are there gaps in the supply chain? If       Yes. Greater demand from areas such as the public sector could lessen the gaps in the supply chain.
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      Universities and colleges need to work more closely with industry to make sure graduates have the required
the development of this market? If not, where are the     practical skills.
gaps?
Question 24: How could the various stakeholders           There could be a national infrastructure to ensure academia, industry, the public sector and legislators are
collaborate to stimulate the development and uptake       learning from each other. On a regional level RTPs could develop larger demonstration schemes. On a local
of LCVs?                                                  level, individual councils and agencies could work together to stimulate local demand and infrastructure.




                                                                             57
R28 – Chartered Institute of Logistics and Transport


 RESPONDENT INFORMATION DETAILS
 Name:                                                 Keith Evans
 Organisation:                                         Chartered Institute of Logistics and Transport
 Address:                                              Earlstrees Court, Earlstreet Road, Corby, Northants
 Postcode:                                             NN17 4AX
 Email:
 Telephone Number:                                     0131 3193048
 Responding as:                                        On behalf of a group or organisation
 Individual Permission:                                Not Supplied
 Confidentiality:                                      Not Supplied
 Group or Organisation:                                Yes
 Share Response Permission:                            Yes
 Question 1: Which low carbon technologies and fuels   Reduced emission internal combustion engines, bio-fuel and vehicles with all or partial electrical power are
 do you envisage will be first to be influential in    likely to be the first to come on stream because the technologies are most advanced. Other technologies
 reducing GHG emissions from the transport sector?     such as reducing vehicle weight and aerodynamic drag should also be pursued as the techniques are well
 Why?                                                  developed. There has to be a combination of increased energy efficiency (less fuel = less emissions)
                                                       combined with alternative fuel sources (cleaner fuel = cleaner emissions) to impact GHG emissions. In the
                                                       freight sector, research and prototypes of improved efficiency engines has continued over the last 20 years;
                                                       as a result of increased fuel efficiency in conjunction with increased load capability, there has been a
                                                       decrease in fuel consumption of over 50% since 1975, with Euro 5 engines having significantly less GHG
                                                       emissions than Euro 0 (89% less CO2, 87% less HCs, 89% less NOx and 98% less particulates than Euro 0
                                                       engines (source: Volvo Trucks)). More over, improved aerodynamics in trailer technology is increasing,
                                                       along with potential to increase payloads for the less emissions – for example the European Modular
                                                       System for 25.25 m long vehicles, which would reduce HGV traffic by 1/3 compared to current EU standards
                                                       and reduce fuel per 1000/tonne km by 10 – 15%. Truck manufacturers continue to invest in r&d to improve
                                                       performance and these improvements will continue to impact on GHG over the coming years; improved
                                                       automatic gearboxes and hybrid vehicles are 2 examples. Similar efficiencies and technologies need to be
                                                       reflected across all modal forms of transport – cars, vans, trains and ships.

                                                       The industry needs to ensure that total GHG emissions are reduced (i.e. over the life cycle of the technology
                                                       from „well to wheel‟), not just at „tail pipe‟. Fuel research in road freight has focussed on a range of
                                                       alternatives including biofuels, synthetic diesel, gas and dimethyl ether (DME). There needs to be a broad
                                                       range of criteria considered in the true sustainability of alternative fuels which includes climate impact, land
                                                       use, energy efficiency, availability of fuel production and distribution, cost, safety and adaptability of the
                                                       existing vehicle fleets. There needs to be an
                                                       emphasis on a balance between all these criteria to establish the true impact of alternative views, not just
                                                       the climate impact, otherwise there is a danger of diverting the issue from the tailpipe to elsewhere in the
                                                       supply-chain. The largest climate impact can be delivered by synthetic diesel, bio-DME and biogas but there
                                                       would need to be significant investment in infrastructure for any fuels other than bio / synthetic diesel.

                                                       Battery technology will make a significant impact on emissions if the efficiency and range can be improved.
                                                       R&D continues in this area for a range of uses, including road freight transport. There are excellent
                                                       commercial examples of companies, like TNT, converting their fleets of local delivery vehicles to electric
                                                       ones; these companies should be engaged and encouraged by Government to share experiences and
                                                       supported to extend their pioneering approach further. In a broader sense of the word technology,
                                                       investment in driver training and knowledge through provision of programmes like Freight Best Practice and
                                                       driver monitoring systems will also increase efficiency and reduce emissions. Furthermore, increased
                                                       interest in more efficient logistics through consolidation centres, portcentric
                                                       logistics and increased inland water and rail freight capability could also contribute to a technologically-led
                                                       emission reduction by reducing vehicle road miles.

                                                       These programmes have a place in the overall target of emission reduction. Further, creative thinking in the
                                                       field of fuel efficiency would include how to make inter-modal transportation easier to access and use, how
                                                       can near-shore waterways be effectively used to reduce vehicle tonne/km and can dedicated freight lanes
                                                       on motorways reduce congestion and increase vehicle efficiency through more uniform speed regulation.
 Question 2: Which low carbon technologies and fuels   Vehicles using full or partial electric propulsion are likely to have the greatest impact because they can use
 do you believe will ultimately have the greatest      renewable sources of energy. Furthermore, Battery vehicles were relatively common 40 or more years ago
 emissions abatement impact? Why?                      on local delivery duties. Battery technology has moved on significantly in the intervening period so such
                                                       vehicles today should have significantly greater performance that their predecessors. For road freight
                                                       transport, as noted above, the greatest climate impact can come from synthetic diesel, bio-DME and biogas.
                                                       However, availability and cost will be key drivers in the development and dissemination of any new fuel
                                                       technology, which will require investment, private and possibly public, to create and support the necessary
                                                       infrastructure.
 Question 3: What timescales do you believe are        Given that some of the technologies are already available such as improved efficiency engines, stop/start
 feasible for the development of specific low carbon   technologies in cars, bio-fuels, hybrid vehicles and battery development, there is no reason why there
 technologies and fuels? Are there any important       should not be increasing use within 5 years, assuming that is the timescale for vehicle development. There
 intermediate milestones within these timescales?      will need to continue to be developments which will reduce carbon emissions through the wide scope of
                                                       opportunities presented by efficiency and nascent technologies. Clearly, provision of the necessary
                                                       infrastructure, whether for bio-fuels or their
                                                       derivative, or battery charging, will encourage as to opposed to inhibit operator specific use of lower
                                                       emission and electrically powered vehicles respectively, and this is particularly important and pertinent to
                                                       private vehicle users that live in homes without individual or communal access to charging points (e.g. in a
                                                       garage). Important milestones would also include the ability to „smart meter‟ electricity use and off-grid
                                                       capability to re-charge vehicles.
 Question 4: What timescales do you believe are the    See 3 above. Given the possible financial penalty in first cost for low carbon vehicles, some incentives may
 feasible for the uptake of specific low carbon        be requires to persuade users to look at life time costs at least in the early years until a critical mass of
 technologies and fuels? Are there any important       operators/vehicles is reached. Whilst subsidies or lower taxation on more efficient and lower emitting fuels
 intermediate milestones within these timescales?      should be
                                                       encouraged to allow faster conversion of new and existing fleets, care should be used in ascertaining true
                                                       LCA costs (including environmental impact), which might vary across technologies and fuels. To emphasise
                                                       the point, it would be meaningless and counter-productive if a zero-carbon/GHG emitting vehicle was very
                                                       tax efficient and cheap to purchase and run for the user if the emissions created in producing and disposing
                                                       of the product were greater than the whole life time emissions of a vehicle that still produced GHG at the
                                                       tailpipe. However, complexity remains in identifying and quantifying other sustainable interfaces such as
                                                       local air quality, which could detrimentally impact health and result in a greater need for resources
                                                       throughout the healthcare system. Similar issues could include congestion and its impact on economic
                                                       output or (alternatively) the positive contribution to GDP that job creation
                                                       and operation of alternative technology products and infrastructure might deliver.
 Question 5: Are there other barriers to the           The safety concerns that accompany the use, storage and distribution of some alternative fuels – for
 development of such fuels and technologies that are   example hydrogen and DME are both highly flammable - may be a significant inhibiter in technology
 not mentioned in this document? If so, what are       uptake.. The cost, both financially and in energy terms may also stop this line of development, especially in
 they?                                                 the need to provide a level of infrastructure that allows no barriers to use of those technologies / fuels
                                                       identified to meet a balanced set of environmentally beneficial criteria. As an example already quoted,
                                                       charging infrastructure for electrically powered vehicles is and needs to be recognised as a strategically
                                                       important issue that incorporates government, local and national, as well as private investment: for the




                                                                          58
                                                          occupants of a tenement building or block of flats, charging infrastructure would have to be provided
                                                          conveniently, locally and cost effectively. Similarly, the use of alternative logistics infrastructure to reduce
                                                          emissions and increase effectiveness, such as consolidation centres, needs local government support for
                                                          such schemes in addition, where necessary, to barriers for existing technologies (e.g. congestion or road
                                                          charging) to ensure uptake and acceptability of alternative ways of reducing GHG emissions.
Question 6: Are there other barriers to the uptake of     See 5 above.
such fuels and technologies that are not mentioned
in this document? If so, what are they?
Question 7: Are there any negative social impacts         Uptake has to be socially acceptable in economic, environment and personal terms. As mentioned, any
associated with either the development or uptake of       incentives used to encourage development and uptake of LCV needs to ensure that a balance is reached
such technologies/fuels? If so, what are they?            between reduction of GHG, economic stimulus and an equality of availability for all users. For example, how
                                                          are those that live in apartments not disadvantaged from ownership of vehicles that required charging from
                                                          the electrical grid in some form. Distribution to remote areas may be a problem and resistance to renewable
                                                          energy generating plants and distribution may also be seen by some as a negative. Use of arable land to
                                                          produce bio fuel can be seen as impacting on food production.
Question 8: What, if any, technical challenges would      Grid reinforcement should not present too many challenges, but phase control for a multitude of micro
the grid reinforcement upgrades be likely to present?     generators may be difficult.
How might these be overcome?
Question 9: Who would fund any grid upgrades?             The electricity generators have an interest in selling their power and surely must have an interest in funding
And, how might these costs be recovered?                  the means of delivering it to the consumer. They would be expected to fund it and recover the costs from
                                                          the additional electricity sold.
Question 10: Do any of the technologies present any       Remoter areas may well be those with the greatest potential for renewable generation by means of wind
specific challenges or opportunities to island            wave tide or micro hydro schemes. Suitable combinations of these may allow them to be self-sufficient in
communities and sparsely populated rural areas in         power and even
Scotland? If so, how might these challenges by            generate a surplus. At the same time, there would need to be a commercial requirement for the providers of
addressed, and by whom?                                   other alternative fuels to provide supplies in romote communities if these need to be sold alongside existing
                                                          fuel stocks (and the vehicles that use them); it should also be recognised that many different fuel mixes
                                                          supplied to remoter areas could actually result in additional vehicle km to provide them. This means that it
                                                          could take a long time for remote communities to „catch up‟ assuming the use of fossil fuel powered vehicles
                                                          is eventually completely phased out (perhaps through legislation or prohibition) in the long term when
                                                          alternatives are readily and easily available. Government may have a need to facilitate early transition, but
                                                          as before, LCA would need to be considered to establish the overall cost in environment, social and
                                                          economic terms of providing full access to alternatives to remoter communities (and their corresponding
                                                          uptake in those communities).
Question 11: Do you think that having a twin              Over the longer term, say, up to 2020, it would be reasonable to have the same approach to both the public
approach for the public sector and other users is         and private sector. However, in the shorter term, it is appropriate for the public sector to take the lead in
appropriate? If so, why? If not, why not?                 creating the demand which should lead to costs coming down. Additional costs to the public sector and the
                                                          resulting tax implications have to be recognised but also the additional benefits and impacts in terms of
                                                          safety, efficiency, health, economy etc need to be assessed to establish how uptake of new technologies
                                                          will actually affect public finances.
Question 12: If so, should targets relate to the uptake   A progressive target based on a percentage reduction in fleet emissions is probably the most appropriate
of low carbon vehicles (either as a percentage of the     target. This avoids the possibility of a significant number of relatively low emission vehicles being replaced
fleet or an absolute number), or a reduction in total     without a commensurate percentage reduction in total emissions. EU legislation may move in this direction
emissions across the fleets or another format of          as a further
target? Why?                                              incentive to industry to develop the necessary vehicles. In other words, a combination of increased fuel
                                                          efficiency and increasingly cleaner fuel is required, which results in an overall reduction in the total
                                                          emissions. Yet again, Life Cycle
                                                          costs, including economic, social and environmental impacts, would need to be taken into account.
Question 13: If we follow a target relating to the        It is likely that most (say 95%) of vehicles will have become life expired at least once in eleven years.
public sector uptake of LCVs, what percentage of the      Recognising that all vehicle types may not be available in LCV form in that timescale, it is probably
fleet should be LCVs by 2020? Please give reasons         reasonable to look to 90% of LCVs by 2020, with 100% of cars, LGVs and vehicle like pavement sweepers.
for your answer.                                          Battery technology is likely to increase the range of such vehicles such that overnight charging should be
                                                          sufficient in most cases, or alternative fuels available in a readily distributed form. However, appropriate
                                                          appraisal of the replacement policies should be carried out
Question 14: If we follow a target relating to the        Using the same reasoning as in 13 above, similar targets would be appropriate for many fleet users.
uptake of LCVs across all road users, what                However, companies using mainly HGVs or long distance coaches may not have appropriate vehicles
percentage of all new vehicles should be LCVs by          available or the ability to use off-peak charging due to night time use of vehicles. Consideration will have to
2020? Please give reasons for your answer.                be given to targets relating to these sectors of the transport market. Targets need to recognise the wide
                                                          diversity of LCV‟s that may become available, but those that are commercial viable and „user friendly‟ may
                                                          win over technologies that are not as accessible or cost too
                                                          much in the short term for uptake to increase. In addition, targets have to be backed up by an appropriate
                                                          (and funded) action plan to increase the availability of LCV and any necessary infrastructure.
Question 16: As LCVs may have higher upfront costs        It is recognised above that HGVs and long distance coaches may have such a high energy requirement that
than traditional vehicles (albeit with a smaller          technology will not give them sufficient range in true LCV form. However, in hybrid form, with further
discrepancy between lifecycle costs) do you               refinements to engine technology and other developments such as regenerative breaking, their emissions
consider it to be efficient use of public resources to    should reduce. It
devote a greater short-term budget towards the            would, therefore, be sensible to keep them within the target.
purchase of LCVs? If so, why? If not, why not?
Question 16: As LCVs may have higher upfront costs        Given the urgency to deal with the potential effects of climate change and the depletion of fossil fuels, it is
than traditional vehicles (albeit with a smaller          probably a necessary use of public resources since it may help to oil the wheels of the development and
discrepancy between lifecycle costs) do you               production processes. As stated in 11 above, the taxation implications need to be considered.
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase
Question 17: Are there any opportunities or barriers      The loss of tax revenue as use of conventional petrol and diesel vehicles reduces, and the potential need to
to public sector procurement of LCVs that are not         tax incentivise other fuel types to encourage fast uptake. However, the long term view of real cost
mentioned in this document? If so, what are they?         associated with climate change and the continued use of fossil fuels also needs to be off set against any
                                                          recognised and immediate reduction in revenues.
Question 18: What are the individual roles of different   It is to be expected that the energy producers will have an interest in increasing the quantity of renewable
groups and organisations in ensuring the provision        energy produced since there is profit to be made from it. Planning regulations must not erect impossible
of any infrastructure required for low carbon             barriers to this development. The same organisations will also have an interest in a suitable distribution
vehicles?                                                 network. They may also wish to make charging facilities available for general use. It is also to be expected
                                                          that multiple uses such as public bodies and companies carrying out local distribution will provide their own
                                                          charging facilities but it should be recognised that local and national government support for infrastructure
                                                          provision will be key for the commercialisation of alternative fuel vehicles in any form. This support may not
                                                          necessarily be financial but could be in terms of planning applications or land availability (e.g. local
                                                          overnight charging parking areas for tenement dwellers). Clearly tariffs for use, particularly off-peak will be
                                                          an important factor in take up.
Question 19: Are there other supply side/capacity         Standardisation of charging connections is important and the EU has an important role in this respect.
constraints impacting on LCV development and              Bespoke equipment of this type from each manufacturer could be a disincentive to uptake of the technology.
uptake? If so, what are they?                             This is particularly true of public facilities where different users may wish to avail themselves of the
                                                          equipment. There will also
                                                          be location issues for such equipment in the built environment. An effective distribution network for other
                                                          alternative views would need to be created where these are not readily replacing existing fuels (e.g. can an
                                                          alternative fuel for
                                                          HGV‟s be provided through existing diesel pumps at filling stations ?). Any requirement for biomass needs
                                                          to be facilitated without detrimentally affecting the food supply chain; creation of fuel through waste biomass
                                                          would require segregation and sortation of waste into a useable format.




                                                                              59
Question 20: Are there barriers to the development of   The UK has not had a good record in recent decades in converting new ideas into new products due to low
an indigenous low carbon vehicle industry in            research and development spend. Pump priming may be required to overcome this problem. Major barriers
Scotland? If so, what are they and how might they be    would include workforce technological experience and capability, and the provision of the right skills to mass
overcome?                                               produce low carbon vehicles. In addition, any Scottish industry would rely on the ability to export many more
                                                        vehicles than it would sell on the local market, so excellent access to world class infrastructure in roads and
                                                        ports would be critical for
                                                        both inbound component parts and outbound finish product.
Question 21: Should Scotland’s industry focus on        Building on what is being produced in Scotland currently with R&D getting these products to be best in class
particular vehicle types? If so, what are they and      would seem to be the best starting point. Should any niche markets be identified where product supply is
why? If not, why not?                                   weak would be a further area for development.
Question 22: Are there gaps in the supply chain? If     A mismatch between battery and vehicle supply and the availability of adequate power supply/charging
so, what are they and how might these be overcome?      facilities is seen as a risk to rapid uptake within the private car market. In addition, research into alternative
                                                        fuels and the required infrastructure is required to establish local capability jn the supply-chain.
Question 23: Do we have the required skills base for    There seems to be a lack of people willing to take up engineering as a discipline both at the graduate and
the development of this market? If not, where are the   artisan level. Appropriate training at all levels may have to be stepped up to ensure that adequate resources
gaps?                                                   are available to service a new technology.
Question 24: How could the various stakeholders         There are many potential groups which could usefully collaborate in getting the new technology accepted
collaborate to stimulate the development and uptake     and taken up. Education and training has to be taken on board by most of the stakeholders who should be
of LCVs?                                                collaborating with the appropriate institutions to ensure that course material and trainers are available. Co-
                                                        operation between local authorities and energy suppliers to ensure that charging facilities can be built in
                                                        suitable locations.
Additional Comments                                     Care will be required when taking action to ensure proper regard to responsibilities which are devolved and
                                                        those reserved to the UK government. In particular action by the Scottish government should not prejudice
                                                        initiatives taken
                                                        by the UK government and vice versa. There is also a need to ensure consistency with the EU, particularly
                                                        regarding standards and implementation timescales. Consequently while Scottish devolution often means
                                                        more action
                                                        can be taken faster careful consideration is required to ensure a consistent end product. Close continuing
                                                        liaison is clearly essential with the UK and EU to ensure this; for example with vehicle standards, supply and
                                                        availability of the
                                                        different energy sources, including electrical charging mechanisms and the various fiscal measures such as
                                                        grants and subsidies.

                                                         The proposed approach whereby public bodies would take a lead is strongly supported. In addition to
                                                        directly operated vehicles this should extend to general administration and public sector employers. For
                                                        example car allowances for employees should be more generous for those using LCVs and car loans could
                                                        be restricted to such vehicles. There should also be emphasis on use of smaller, less powerful vehicles with
                                                        these provisions also applying to MSPs to give a lead. In addition, consideration of life cycle analysis and
                                                        the need to ensure energy already embodied in existing vehicles is not wasted by early or unnecessary
                                                        replacement. In addition, heavy goods vehicles – and the development of alternative power sources and / or
                                                        fuels – will need the involvement of private firms and investors who run fleets; these are generally outwith
                                                        the direct influence of the public sector but have a major role to play in the reduction of GHG emissions from
                                                        transportation modes. However, there are excellent examples of commercial firms taking the initiative in
                                                        conversion to electric fleets – for example TNT now run a UK-wide electric delivery fleet. Government
                                                        should actively engage with these stakeholders and seek opportunities to establish how their initiatives can
                                                        be encouraged and extended, with, where appropriate, Government support.

                                                        The approach put forward in the consultation paper, with the public sector taking a lead regarding vehicles
                                                        under its control is likely to be the most productive. Care is required regarding progressive introduction of
                                                        the various measures with a mechanism to ensure effective dissemination of results to the general public
                                                        highlighting potential benefits to each individual. A command and control approach is unlikely to gain public
                                                        support and should be avoided.

                                                        Opportunities should also be taken to influence change by others where there are contracts or other
                                                        agreements. For example with bus quality partnerships, operator grants and tendered services where use of
                                                        LCVs could be given preferential treatment, if not insisted upon. Similarly where infrastructure provision or
                                                        maintenance contracts are awarded similar provisions might apply. Further, other mechanisms to
                                                        encourage the conversion of fleets and private vehicles – at a local and national level – should be
                                                        considered, and could include congestion charging, provision of consolidation centres to enable non-
                                                        polluting vehicles to supply retailers and services within city centre boundaries, workplace parking charging
                                                        etc. A system of tiered charges would encourage less polluting
                                                        vehicles.

                                                        More generally greater use should be made of Planning Powers. The various business incentives and grant
                                                        mechanisms should encourage use of LCVs whilst the built environment should enable their easy use. For
                                                        example provision of green spaces and pedestrianisation should avoid conflict and provide opportunities for
                                                        LCV use,with more off-road residential parking spaces to facilitate electrical charging and readily available
                                                        commercial points for such charging and battery change.
                                                        In the financial arena taxation policies should encourage more than at present both a transfer to LCVs and
                                                        where petrol/diesel still applies a movement to less energy using vehicles. This should apply to heavy and
                                                        light goods vehicles and PCVs as well as cars and consideration should be given to extending the UK
                                                        government‟s car scrappage scheme to this end. Fiscal measures could also be used with vehicle renting
                                                        and leasing to encourage greater use of smaller vehicles and LCVs.

                                                         With all of the action suggested above care is required to ensure that the emphasis on early direct action
                                                        does not prejudice easy subsequent acceptance by the general public. For example widespread availability
                                                        of electrical charging points and other LCV energy sources will be essential if drivers are to be persuaded to
                                                        change from petrol/diesel power. Significant investment will be required, perhaps utilising parts of existing
                                                        filling stations and the financing and timing of this could be problematic. The rate of movement towards use
                                                        of LCVs will require careful consideration in the context of the 2020 and 2050 targets.

                                                        Even with the most optimistic assumptions it is clear that by 2020 and for many years thereafter there will be
                                                        continued use of fossil fuelled power stations for part of the electricity supply. Any increased use of
                                                        electricity at periods of peak demand will require additional use of such power stations. The emphasis for
                                                        electrically driven vehicles should therefore be on electrical charging at off peak demand times. A pricing
                                                        structure to encourage this is essential with provision for charging at peak demand times, whilst necessary
                                                        to permit flexibility subject to a significant surcharge.

                                                         A common and consistent charging mechanism is necessary throughout Scotland, the UK and EU. Initially
                                                        off peak trickle, charging through the household 240v supply should be facilitated but as soon as a sufficient
                                                        base load of demand is established a higher voltage direct charging system is required. Common attributes
                                                        should permit direct use by all vehicles as well as easy interchange of run down and newly charged
                                                        batteries. As referred to above interchange points could be located similarly to existing filling stations.
                                                        During the transition period parts of filling stations might be converted for such use.


                                                        Implementing the necessary changes will be difficult bearing in mind the various public and private sector
                                                        interests. A realistic action plan is required with development of consistent planning policies and allowing for
                                                        the progressive loss of fuel tax revenue. Sensible fiscal policies to embrace the necessary grant, subsidy
                                                        and taxation regimes will also need to be developed.




                                                                            60
R29 – Confederation of Passenger Transport


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Paul White
 Organisation:                                             Confederation of Passenger Transport
 Address:                                                  29 Drumsheugh Gardens, Edinburgh
 Postcode:                                                 EH3 7RN
 Email:
 Telephone Number:                                         0131 272 2150
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Reduced emission internal combustion engines, bio-fuel and vehicles with all or partial electrical power
 do you envisage will be first to be influential in        (hybrids) are likely to be the first to come on stream because the technologies are most advanced. Other
 reducing GHG emissions from the transport sector?         technologies such as reducing vehicle weight and aerodynamic drag should also be pursued as the
 Why?                                                      techniques are well developed.
 Question 2: Which low carbon technologies and fuels       Hybrid vehicles are likely to have a large impact because they can use renewable sources of energy and
 do you believe will ultimately have the greatest          are probably the most visible of the potential solutions to reduce emissions. However, alternative solutions
 emissions abatement impact? Why?                          such as biofuels and even improving the performance of current diesel engines should continue. A
                                                           breakthrough in any of these areas, or the discovery of a new potential solution could alter this picture at
                                                           any time.
 Question 3: What timescales do you believe are            It is not for CPT to comment on the research and development timescales for these technologies. However,
 feasible for the development of specific low carbon       the first generations of these technologies are in existence and are being trialled and tested so will
 technologies and fuels? Are there any important           doubtless improve over the coming years.
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        With regards to the bus industry, the timelines for introduction of accessible low floor bus fleets as set out in
 feasible for the uptake of specific low carbon            the Disability Discrimination Act 2005 (2016 for single deckers, 2017 for double deckers and 2020 for
 technologies and fuels? Are there any important           coaches) will doubtless inform the investment in new vehicles and more recent technologies over the next
 intermediate milestones within these timescales?          decade.
 Question 5: Are there other barriers to the
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     CPT members are fully committed to supporting the Scottish Government‟s targets for reducing emissions
 such fuels and technologies that are not mentioned        and will consider all new fuel and technologies as they become available. However, there are several
 in this document? If so, what are they?                   factors that must be considered before the adoption of such advancements. There is a financial premium to
                                                           the purchase cost for low carbon vehicles. Additionally, there are the unknowns over the reliability of new
                                                           technologies, the lifetime maintenance costs and the actual environmental benefits/fuel savings of the
                                                           technology when in use.

                                                           The business case for the adoption of new technologies has to be sound. No bus or coach operator wants
                                                           to invest heavily in a particular technology only to find that the next iteration is far more effective, reliable or
                                                           affordable. Should the Scottish Government want public transport operators to invest in low carbon vehicles
                                                           then dialogue has to continue between CPT, the Scottish Government and vehicle manufacturers to discuss
                                                           industry concerns and to identify the best method to encourage/incentivise their purchase. Likewise, the
                                                           Scottish Government and CPT should continue to work together to revise the Bus Service Operators Grant
                                                           so that the scheme encourages investment in lower emission vehicles at a rate that is realistically
                                                           achievable.

                                                           CPT hopes that any revision of the BSOG scheme will also address concerns regarding operators using
                                                           biofuels.
                                                           Under the present scheme Bio-diesel attracts 36.91ppl of fuel duty, which includes a 20ppl reduction on
                                                           normal road fuel awarded under the renewable transport fuels obligation (RTFO). Of this, 98% is claimable
                                                           under the current BSOG scheme. In April 2010 the RTFO states that 3.5% of road transport fuel should
                                                           come from renewable sources. This date also see the abolition of the 20ppl reduction in fuel duty applied to
                                                           Bio fuel and replaced by the cash equivalent achieved by trading carbon credits or RFO certificates.
                                                           However these certificates have no value at present and the increase of fuel duty of 20ppl will render the
                                                           use of bio-fuels within the road transport industry economically unviable.

                                                           This will have a catastrophic effect on bio-fuel in Scotland, effectively removing one of the key low carbon
                                                           options from the marketplace, which will clearly impact upon the bus industries‟ ability to assist in achieving
                                                           the climate change targets set out by the Scottish Government.
 Question 7: Are there any negative social impacts         The use of arable land to produce bio fuel can be seen as impacting on food production. Additionally, the
 associated with either the development or uptake of       testing of hybrid vehicles has mainly centred on their performance in urban areas. The particular geographic
 such technologies/fuels? If so, what are they?            and demographic profile of Scotland presents different challenges and warrants trials in the type of long-
                                                           distance and rural/urban routes that exist in Scotland.
 Question 8: What, if any, technical challenges would
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any
 specific challenges or opportunities to island
 communities and sparsely populated rural areas in
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              CPT supports the concept of using the public sector to lead the way by making the public sector bus fleet
 approach for the public sector and other users is         consist entirely of LCVs by 2020. As well as setting a good example, this would also provide further
 appropriate? If so, why? If not, why not?                 evidence of the performance level and reliability of the vehicles.

                                                           The adoption of measures to influence the travel choices of public sector employees should also be
                                                           considered; such as salary sacrifice schemes.
 Question 12: If so, should targets relate to the uptake   The Scottish Government should remain relatively technology blind and not encourage the uptake of a
 of low carbon vehicles (either as a percentage of the     particular technology over another. Therefore, it would seem that the best method to achieve the aims of the
 fleet or an absolute number), or a reduction in total     Climate Change (Scotland) Act would be to set a target for the reduction of total emissions across the fleet.
 emissions across the fleets or another format of
 target? Why?                                              However, CPT would hope that the public sector would take the opportunity to invest in low carbon vehicles
                                                           to provide evidence of their performance level and reliability – as stated in the previous answer.
 Question 13: If we follow a target relating to the        This is a question for the public sector to answer. However, CPT would hope that if the Scottish
 public sector uptake of LCVs, what percentage of the      Government plans to set targets for local authorities it provides funding to enable the Local Authorities to
 fleet should be LCVs by 2020? Please give reasons         achieve them. The cost of reaching new targets should not come from what are already overstretched local
 for your answer.                                          authority transport budgets.
 Question 14: If we follow a target relating to the        CPT can only comment on the vehicles owned and operated by the Scottish bus and coach sector and is
 uptake of LCVs across all road users, what                already working with the Scottish Government to examine how best to encourage/incentivise the purchase




                                                                               61
percentage of all new vehicles should be LCVs by          of LCVs through methods such as a revised BSOG scheme.
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that
should be excluded from the public sector target? If
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs
than traditional vehicles (albeit with a smaller
discrepancy between lifecycle costs) do you
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers
to public sector procurement of LCVs that are not
mentioned in this document? If so, what are they?
Question 18: What are the individual roles of different
groups and organisations in ensuring the provision
of any infrastructure required for low carbon
vehicles?
Question 19: Are there other supply side/capacity
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders
collaborate to stimulate the development and uptake
of LCVs?
 Additional Comments                                      The UK bus manufacturing industry is at the forefront of hybrid technology. Hybrid trials in London have
                                                          already recorded results of fuel savings up to 40% and current bus manufacture uses modern materials,
                                                          construction methods and maintenance techniques that have much in common with aviation engineering.
                                                          Government must support the bus manufacturing industry‟s endeavours to improve existing technologies
                                                          and develop innovative ideas. It should also incentivise the purchase of new vehicles to counter the risks
                                                          inherent in the production and the purchase of new technologies.

                                                          All emerging technologies carry a financial risk - initially to the manufacturer through research, development
                                                          and manufacture and subsequently to bus operators in the form of the initial price, unexpected costs and
                                                          the ongoing costs of maintenance.

                                                          The Department for Transport recently established a £30m fund „Green Fund‟ to stimulate the introduction
                                                          of low carbon and hybrid vehicles in England and to protect jobs in the bus manufacturing industry. The
                                                          scheme takes the form of gap funding covering the difference in cost between a conventional bus and a
                                                          hybrid vehicle.

                                                          A similar scheme in Scotland to subsidise the purchase and maintenance costs of hybrid vehicles could
                                                          increase investment from operators in such vehicles, improve the age and emissions levels of buses in
                                                          Scotland as well as protect Scottish bus manufacturing jobs and should be considered under the remit of
                                                          the Climate Change Delivery Plan.
                                                          Only through the proper funding of the bus industry can the Scottish Government support and encourage
                                                          further advancements in vehicle technology progressing from the drawing board to Scotland‟s roads.

                                                          However, it should not be forgotten that a standard diesel engine bus is still a low carbon vehicle in
                                                          comparison to the private car. Around 63% of carbon dioxide emissions from cars arise from journeys of
                                                          less than 25 miles. If those journeys were made by bus there would be a significant reduction in transport
                                                          based CO2 emissions. If every bus took just one more car driver we could save up to 1.2 million tonnes
                                                          CO2 per year.

                                                          Additionally, there are several factors that impact upon the performance and efficiency of a vehicle beyond
                                                          its fuel and engine type. Factors that influence the fuel consumption of buses also include the weight of the
                                                          vehicle, average speed, driver technique, nature of route and the number of passengers on the bus. Most
                                                          fuel is used during acceleration. Reducing the number and severity of acceleration events will improve fuel
                                                          efficiency considerably. Bus lanes, automatic priority at traffic lights and acceleration and top speed limiters
                                                          are all effective tools. Alternative technologies are such as hybrid vehicles can provide marked
                                                          improvements to fuel efficiency and emissions reductions but their impact is greatly reduced if their
                                                          operating conditions are unfavourable.

                                                          Putting people on public transport takes cars off the road. Reducing congestion will increase the average
                                                          speed of buses which will in turn improve fuel efficiency and lower carbon emissions from vehicles.
                                                          Measures such as well-positioned park and ride sites, accessible and comprehensive travel information and
                                                          journey plans - and even car parking charges that realistically reflect the true cost of motoring to the
                                                          environment - all encourage people to choose public transport rather than the car. The Scottish
                                                          Government, Local Authorities and other transport stakeholders will need to use all possible tools at their
                                                          disposal to reach the government‟s climate change targets and not rely on technological advances in
                                                          vehicle and fuel technology.

                                                          Undoubtedly, new technologies such as hybrids can often provide the impetus or wow factor to make
                                                          people consider the switch to public transport. However, as stated, there is currently no support for bus
                                                          operators willing to run these vehicles in Scotland.

                                                          By its nature, the bus will always be an environmentally sound method of transport. However, with the
                                                          continued efforts of bus operators to improve services and the support of Scottish Government, Local
                                                          Authorities and Regional Transport Partnerships, among others, it may prove possible to make a marked
                                                          improvement in the buses green credentials, increase modal shift, reduce emissions and tackle congestion.




                                                                             62
R30 - Environmental Protection UK


 RESPONDENT INFORMATION DETAILS

 Name:                                                     Iain McClellan
 Organisation:                                             Environmental Protection UK
 Address:                                                  c/o Glasgow City Council, Land and Environmental Services, 231 George Street, Glasgow
 Postcode:                                                 G1 1RX
 Email:
 Telephone Number:
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Discussion on which low carbon technology and fuels will be the first to influence the emissions of GHG
 do you envisage will be first to be influential in        may be somewhat premature simply because the costs for the various technologies are still expensive. It is
 reducing GHG emissions from the transport sector?         likely though that biofuels and hybrids are likely to be the first as these are further ahead in terms of
 Why?                                                      research and development than electric and hydrogen vehicles.
 Question 2: Which low carbon technologies and fuels       No comment
 do you believe will ultimately have the greatest
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are            No comment
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        No comment
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               The use of biofuels will depend on food security and whether or not the United Kingdom has sufficient
 development of such fuels and technologies that are       agricultural land remaining to grow crops for biofuel production.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     A 100% public sector target and a 30% of other road users 2020 timescale for the development and uptake
 such fuels and technologies that are not mentioned        of any low carbon technologies is hugely challenging. The technology is only now becoming available to
 in this document? If so, what are they?                   produce LCVs on a small scale, increasing this to meet full-scale public demand will be difficult in 10 years.
                                                           Likewise, the British public need to be shown successfully that they can get just as many benefits from
                                                           LCVs than they can from the car they drive just now; the education for this change needs to start now if the
                                                           2020 target is to be met.
 Question 7: Are there any negative social impacts         No comment
 associated with either the development or uptake of
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would      No comment
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             Grid upgrades would need to be funded by Government if there is to be serious public uptake in LCVs; the
 And, how might these costs be recovered?                  costs of low carbon vehicles must be within the budget of all, asking industry to finance both technological
                                                           development and grid upgrade will push prices up.
 Question 10: Do any of the technologies present any       The Scottish Government must take responsibility for providing island communities and rural areas with the
 specific challenges or opportunities to island            means to run a low carbon transport system.
 communities and sparsely populated rural areas in
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              The document acknowledges that existing technology is easier to implement in cars than HGVs, LGVs and
 approach for the public sector and other users is         buses yet the Scottish Government would like the entire public service – predominately HGVs, LGVs and
 appropriate? If so, why? If not, why not?                 buses – to be LCVs by 2020. With the Single Outcome agreement in place it will take a large amount of
                                                           public money set aside specifically for the uptake of LCVs, this document states that at present there is an
                                                           increased cost of approximately £100K per hybrid HGV – this works out at an extra cost to the public of
                                                           £290million based on the number of LA HGVs in 2008. For cars this figure would be up to £10million.
                                                           Making the public sector the leader in uptake of LCVs is laudable however if the technologies aren‟t cost
                                                           effective the LA would need to balance its environmental objectives against cost to the tax payer. With
                                                           regards to the targets listed within Section 6.3, we are concerned that making the public sector buy “best in
                                                           class” would result in LAs purchasing best in class for carbon but not in other aspects. We would suggest
                                                           that the either the public sector has to meet their emissions share as defined within the Climate Change
                                                           (Scotland) Act 2009 or has a certain percentage of their fleet as LCVs by a certain date. We would support
                                                           the target of 95% of all new vehicles purchased by 2020 be LCV provided they also meet other air quality
                                                           criteria.
 Question 12: If so, should targets relate to the uptake   See response to Q11
 of low carbon vehicles (either as a percentage of the
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        See response to Q11
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the        No comment
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        No comment
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        See response to Q11
 than traditional vehicles (albeit with a smaller
 discrepancy between lifecycle costs) do you
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      No comment
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different   No comment
 groups and organisations in ensuring the provision




                                                                              63
of any infrastructure required for low carbon
vehicles?
Question 19: Are there other supply side/capacity       No comment
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of   No comment
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on        No.
particular vehicle types? If so, what are they and
why? If not, why not?                                   Scotland cannot go it alone on this matter to ensure that one particular type of car is not rendered useless at
                                                        the border i.e. Scotland goes ahead and develops the infrastructure for hydrogen cars whilst England and
                                                        Wales go for electric cars. The United Kingdom must act as a whole. Likewise, Scotland must also look at
                                                        any future infrastructure development in Europe as there are cross-border car and haulage journeys.
Question 22: Are there gaps in the supply chain? If     Biofuels – will the UK have sufficient agricultural space to grow crops for biofuels as well as having food
so, what are they and how might these be overcome?      security?
Question 23: Do we have the required skills base for     No comment
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         No comment
collaborate to stimulate the development and uptake
of LCVs?




                                                                           64
R31 - First Group


 RESPONDENT INFORMATION DETAILS
 Name:                                                     John Birtwistle
 Organisation:                                             First Group
 Address:                                                  c/o First, Boyle St, Queens Rd, Manchester
 Postcode:                                                 M8 8UT
 Email:
 Telephone Number:                                         07900 405410
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       First believes that the single most effective means of reducing GHG emissions from the transport sector is
 do you envisage will be first to be influential in        tackling traffic congestion. Vehicle engines are at their least efficient when in stop-start conditions and bus
 reducing GHG emissions from the transport sector?         operators are affected by this more than most. Congestion the principal cause of bus service punctuality
 Why?                                                      problems, which are an oft-cited reason for people not using public transport, so should also have modal
                                                           shift benefits thereby instigating a “virtuous circle”. Anything that assists bus operators in maximising their
                                                           fuel efficiency will also have beneficial effects on operating costs, enabling a better service to be provided to
                                                           the public. Whilst the move from Euro3 to Euro 4 has seen some improvements in fuel efficiency, these
                                                           come at the end of a gradual worsening of fuel efficiency from pre Euro standards to Euro 3 as engines
                                                           exhibited reduced emissions of Nox, particulates etc at the expense of fuel consumption. Increasing
                                                           proportions of bio fuel are exacerbating this problem as bio fuel itself has a lower energy content and is
                                                           more variable in this. Therefore there is a trend towards increasing fuel consumption, and a move away
                                                           from bio fuels would redress this. Whilst diesel hybrid systems offer the opportunity for increased fuel
                                                           efficiency their initial capital costs are considerably higher and, to date, evidence suggests that their whole
                                                           life costs will also be higher. Retrofit of hybrid technology (mechanical or electrical) appears to offer a more
                                                           cost effective long term solution.
 Question 2: Which low carbon technologies and fuels       This depends on where you measure the effect. Hydrogen fuel cell vehicles give nil harmful emissions
 do you believe will ultimately have the greatest          output at the point of use, but production of the gases required for their fuel is itself an energy intensive
 emissions abatement impact? Why?                          process. More realistically should purchase and lifetime costs of hybrids decrease if they are adopted more
                                                           widely, these should yield the greatest benefit. First has experience of operating CNG, LPG, battery, and
                                                           hybrid vehicles and to date all have exhibited problems with availability, reliability and cost that outweigh
                                                           their (in some cases) potential for reduced atmospheric pollution. CNG and LPG vehicles now lag behind
                                                           their conventional diesel powered equivalents in that respect.
 Question 3: What timescales do you believe are            The key issue with development of low carbon technology is critical mass, rather than timescales. The
 feasible for the development of specific low carbon       technology is available now, and wider adoption of hybrid vehicles is likely in itself to stimulate greater
 technologies and fuels? Are there any important           interest in and take up of retrofit options. In all cases, critical mass is required to achieve the unit cost
 intermediate milestones within these timescales?          savings that would make such solutions economically attractive.
 Question 4: What timescales do you believe are the        As far as the uptake of such technologies is concerned, this will in the bus and coach industry be largely
 feasible for the uptake of specific low carbon            dictated by the need for operators to comply with the PSV Accessibility Regulations for DDA standards,
 technologies and fuels? Are there any important           which have to be met by 2016 for single deck and 2017 for double deck buses.
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               Hybrid buses have to date only been tested under intense urban operating conditions. There is a need for
 development of such fuels and technologies that are       their performance to be trialled and proven in a wider variety of circumstances. The only significant barrier
 not mentioned in this document? If so, what are           for hybrid technology is the need to sponsor a trial of the retrofit option in a real world operational setting.
 they?                                                     For hydrogen fuel cell vehicles, any local prejudice against the location of fuelling sites/depots (on a bad
                                                           neighbour basis) will need to be overcome.
 Question 6: Are there other barriers to the uptake of     The key barriers to uptake are availability for service, reliability, and operational flexibility, all of which need
 such fuels and technologies that are not mentioned        to be at least favourably comparable with diesel powered equivalent vehicles. There is also a commercial
 in this document? If so, what are they?                   consideration, of the initial purchase price and whole life costs of such vehicles. First is firmly supportive of
                                                           initiatives to reduce carbon emissions and other pollutants, and is already trialling diesel-electric hybrid
                                                           buses in service. First welcomes the continuing development of such vehicles and is keen to continue with
                                                           such trials, subject to financial considerations.
 Question 7: Are there any negative social impacts         The negative social impacts must be considered in terms of the method of production of the fuel and costs,
 associated with either the development or uptake of       both monetary and environmentally, that this imposes. In the case of options that impose a high capital,
 such technologies/fuels? If so, what are they?            whole life or operating cost on their operators, this will need to be passed on to the end user in the form of
                                                           higher fares, reduced services or both.
 Question 8: What, if any, technical challenges would      First does not have sufficient relevant knowledge to comment meaningfully on this issue.
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             First does not have sufficient relevant knowledge to comment meaningfully on this issue.
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any       There would be no specific challenges or opportunities for island or sparse rural communities from the
 specific challenges or opportunities to island            adoption of hybrid technology. Alternative fuels may be problematic in terms of the supply chain and
 communities and sparsely populated rural areas in         fuelling station availability.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              It is appropriate to set targets for the public sector to better address the problems faced by all bus operators,
 approach for the public sector and other users is         in particular the problems caused to bus service punctuality and variation in journey times through traffic
 appropriate? If so, why? If not, why not?                 congestion and other highway obstructions.
 Question 12: If so, should targets relate to the uptake   From a practical perspective it will be very difficult and potentially expensive to measure against targets set
 of low carbon vehicles (either as a percentage of the     on any basis other than percentage of fleet composition, so this is First‟s recommended approach.
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        First does not consider that it is necessarily appropriate to predict a figure for 2020. By that time both the
 public sector uptake of LCVs, what percentage of the      nature of the LCV definition and the technologies available to achieve it are likely to be different from today.
 fleet should be LCVs by 2020? Please give reasons         The definition of an LCV should be outcome driven, such that it is defined through the emissions the vehicle
 for your answer.                                          produces rather than anything driven by its design or technological characteristics.
 Question 14: If we follow a target relating to the        First does not consider that it is necessarily appropriate to predict a figure for 2020. By that time both the
 uptake of LCVs across all road users, what                nature of the LCV definition and the technologies available to achieve it are likely to be different from today.
 percentage of all new vehicles should be LCVs by          The definition of an LCV should be outcome driven, such that it is defined through the emissions the vehicle
 2020? Please give reasons for your answer.                produces rather than anything driven by its design or technological characteristics.
 Question 15: Are there any vehicle categories that        First sees no reason to exclude any particular vehicle type, other than response vehicles of the emergency
 should be excluded from the public sector target? If      services, on the basis that whilst alternative technology vehicles are in their infancy, vehicle availability and
 so, what are they and why should they be excluded?        reliability is likely to be lower than their conventionally powered equivalents and public safety should not be
 If not, why not?                                          compromised by this.
 Question 16: As LCVs may have higher upfront costs        There is a need to stimulate the market to adopt LCVs and, to this end, First would welcome such an
 than traditional vehicles (albeit with a smaller          initiative. However for the reasons set out elsewhere in this consultation response it is important to address
 discrepancy between lifecycle costs) do you               not just the initial purchase price issue but the whole life cost of ownership, which at present appears also to
 consider it to be efficient use of public resources to    be at a considerable premium by comparison with conventionally fuelled vehicles (due to the need to
 devote a greater short-term budget towards the            replace battery packs, etc).
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      First would prefer to purchase vehicles directly rather than for these to be purchased by the public sector, as




                                                                               65
to public sector procurement of LCVs that are not         in this way First can retain a high degree of control of the specification of the vehicles. If the public sector is
mentioned in this document? If so, what are they?         to purchase the vehicles, care will be required to ensure that they are equally available to all through the
                                                          adoption of some form of competitive bidding process.
Question 18: What are the individual roles of different   As far as local bus operation is concerned the principle roles and responsibilities are: 1. Bus operator:
groups and organisations in ensuring the provision        operate service, maintain vehicle, 2.Manufacturer: provide warranty and service assistance, 3.Local
of any infrastructure required for low carbon             authority: provide appropriate bus priority infrastructure to keep the vehicle out of congestion. 4.Fuel
vehicles?                                                 supplier: supply fuel to a consistent energy content standard 5. National government: provide appropriate
                                                          assistance with capital and whole life cost differentials; mandate a standard for fuel energy content
Question 19: Are there other supply side/capacity         Other than the general downturn in economic conditions, First is not aware of any such restrictions
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of     First is not aware of any such barriers
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          It would not be appropriate for First to suggest that Scotland‟s industry should focus on particular vehicles
particular vehicle types? If so, what are they and        types. However for LCVs to achieve any significant overall reduction in GHGs they will need to be in
why? If not, why not?                                     operation in significant quantities, and to achieve this in a short time period (bearing in mind for instance the
                                                          typical design life of a bus of 15-20 years) this will require the application of retrofit technology. First
                                                          therefore urges that this is given a high degree of priority.
Question 22: Are there gaps in the supply chain? If       First is not aware of any gaps in the supply chain, at least not as far as buses are concerned
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      First believes that all the requisite skills are available in the market
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           The collaboration of stakeholders to specify a shared set of objectives and actions as specified in the
collaborate to stimulate the development and uptake       answer to Q18 would help stimulate the development and uptake of LCVs.
of LCVs?




                                                                              66
R32 – Freight Transport Association


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Gavin Scott
 Organisation:                                             Freight Transport Association
 Address:                                                  Hermes House, Melville Terrace, Stirling
 Postcode:                                                 FK8 2ND
 Email:
 Telephone Number:                                         01786 457 503
 Responding as:                                            On behalf of a group or organisation
 Indvidual Permission:                                     Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Some immediate CO2 savings could result from the use of alternative fuels –bio fuels (bio diesel and bio
 do you envisage will be first to be influential in        methane etc). However, this would need to be balanced against the sustainability issues related to Bio
 reducing GHG emissions from the transport sector?         diesel production. Also, bio methane infrastructure, availability and lack of proven track record means that
 Why?                                                      take up is likely to be slow. Hybrid vehicles are likely to provide the biggest influence but purchase costs are
                                                           high. Electric vehicles will also have significant influence, but will require large investment in infrastructure
                                                           for re-charging, and purchase costs are very high, financial support would be required.
 Question 2: Which low carbon technologies and fuels       Probably hydrogen. Costs of lithium for battery power are a barrier to this technology, and this technology is
 do you believe will ultimately have the greatest          some way off yet.
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are            Important milestones will be the EC requirement for reductions in CO2 for light commercial vehicles.
 feasible for the development of specific low carbon       (175g/km by 2012-15, 160g/km by 2015). The 175g/km seems feasible but the latter is challenging and is
 technologies and fuels? Are there any important           likely to increase vehicle costs considerably (figures around 16-18% on vehicle price have been mooted.
 intermediate milestones within these timescales?          Within this timescale hybrid and electric vehicles will have developed and be a more viable option, but
                                                           purchase cost may still be significant.
 Question 4: What timescales do you believe are the        No specific comment to make.
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               This depends on whether the public sector fleet in Scotland is a significant enough proportion of the overall
 development of such fuels and technologies that are       fleet to make a significant influence on manufacturers to develop LCV technology?
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     High cost of LCV technology and lack of infrastructure for alternative fuelling etc is major barrier particularly
 such fuels and technologies that are not mentioned        in the current financial climate.
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         It is difficult to say. Filling stations in rural areas who are already struggling to make a living will not benefit
 associated with either the development or uptake of       from a requirement to provide alternative sources of power for vehicles.
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would      Can the grid cope with the expected demand? If demand exceeds expectation, what happens then? How is
 the grid reinforcement upgrades be likely to present?     demand going to be predicted and managed?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             Inevitably, as with all commodities, ultimately the customer will pay.
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any       It is unlikely that, in the short term because of the distances involved that electric vehicles will be an option.
 specific challenges or opportunities to island            Any technology will pose significant problems with re-fuelling infrastructure.
 communities and sparsely populated rural areas in
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              We expect that the public sector will take the lead on this as there is already legislation on its way to force
 approach for the public sector and other users is         LAs and contracting entities to consider lifetime vehicle and emission costs in procurement procedures.
 appropriate? If so, why? If not, why not?                 However private operators are also making advances as part of their sustainability strategies. The current
                                                           economic climate must, however be borne in mind.
 Question 12: If so, should targets relate to the uptake   Ideally targets should be set probably as a percentage of the fleet so that the uptake is progressive and is in
 of low carbon vehicles (either as a percentage of the     line with the development and cost of LCVs.
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        For the car and light van fleet it is probably feasible to set targets as CO2 data on new vehicles is available
 public sector uptake of LCVs, what percentage of the      and low carbon vehicles are available in reasonable numbers. FTA does not find it possible to comment on
 fleet should be LCVs by 2020? Please give reasons         what percentage figure to put on this. For large commercial vehicles, however, manufacturers are in the
 for your answer.                                          infancy of low carbon technology.
 Question 14: If we follow a target relating to the        We find it impossible to comment on this question.
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        Consideration should be given to specialist vehicles within fleets such as gritters and the like which can
 should be excluded from the public sector target? If      have a replacement life cycle in excess of 10 years
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        Current budgets are being reduced. LCVs cost anything from 2 to 4 times more than conventional vehicles,
 than traditional vehicles (albeit with a smaller          operating ranges may be reduced. All of these factors will have a potential impact on business and services.
 discrepancy between lifecycle costs) do you               Devoting greater resource to LCVs will squeeze budgets in other areas
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      No comment.
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different   This will depend on which of the technologies turns out to be most viable, and the levels of uptake. We have
 groups and organisations in ensuring the provision        a classic catch 22 situation here. If infrastructure is provided and not used there will be complaints. If LCVs
 of any infrastructure required for low carbon             are purchased and the refuelling infrastructure is absent or patchy there will be complaints.
 vehicles?
 Question 19: Are there other supply side/capacity         Unless financial incentives are brought to bear it is likely that uptake will be patchy with only the more
 constraints impacting on LCV development and              responsible and probably larger operations willing to invest resource.
 uptake? If so, what are they?
 Question 20: Are there barriers to the development of     WE feel unable to comment on this point.
 an indigenous low carbon vehicle industry in
 Scotland? If so, what are they and how might they be
 overcome?
 Question 21: Should Scotland’s industry focus on          The main current restraint on electric vehicles is operational radius. Until this problem has been solved by
 particular vehicle types? If so, what are they and        whatever means it is unlikely that operations outwith urban areas will be willing to invest in this technology.




                                                                               67
why? If not, why not?
Question 22: Are there gaps in the supply chain? If     No comment
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for    No comment
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         No comment.
collaborate to stimulate the development and uptake
of LCVs?




                                                                      68
R33 – The Guide Dogs for the Blind Association


 RESPONDENT INFORMATION DETAILS
 Name:                                                   Jane Horsburgh, Public Policy Manager
 Organisation:                                           The Guide Dogs for the Blind Association
 Address:                                                24d Milton Road East, Edinburgh
 Postcode:                                               EH15 2NJ
 Email:
 Telephone Number:                                       0845 372 7395
 Responding as:                                          On behalf of a group or organisation
 Individual Permission:                                  Not Supplied
 Confidentiality:                                        Not Supplied
 Group or Organisation:                                  Yes
 Share Response Permission:                              Yes
 Question 1: Which low carbon technologies and fuels
 do you envisage will be first to be influential in
 reducing GHG emissions from the transport sector?
 Why?
 Question 2: Which low carbon technologies and fuels
 do you believe will ultimately have the greatest
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts       Guide Dogs has raised concerns about the implications of hybrid and electric vehicles or „quiet vehicles‟.
 associated with either the development or uptake of     Due to the almost silent operation of hybrid vehicles when running on electric power at lower speeds, the
 such technologies/fuels? If so, what are they?          independent travel of blind and partially sighted people is put at risk as they cannot hear these quiet
                                                         vehicles as they approach, making crossing the road hazardous.

                                                         Blind and partially sighted people use the noise of oncoming traffic as a cue for when it is safe to cross a
                                                         road – if a „quiet‟ hybrid electric vehicle is approaching then they will no longer have this cue and are
                                                         immediately put at risk.
                                                         Blind and partially sighted people travel by using the sense of touch and of hearing to tell them about the
                                                         environment. Canes or guide dogs help them to identify and avoid objects in their path and to anticipate
                                                         steps or kerbs. But only the sense of hearing can inform them about the traffic flow and when it is safe to
                                                         cross a road. The sound a vehicle makes informs them whether a vehicle is coming towards them or away
                                                         from them, slowing down, speeding up, or turning to the left or to the right.

                                                         Guide Dogs recognises the environmental benefits of these vehicles however more consideration needs to
                                                         be given to the safety implications for blind and partially sighted pedestrians. There may also be implications
                                                         for other disabled people, older people and young children.

                                                         The Joint Committee on Mobility of Blind and Partially Sighted People, - an independent umbrella body
                                                         comprising the principle organisations representing blind, deafblind and partially sighted people with an
                                                         interest in mobility issues has considered this issue. An electric vehicle was demonstrated at a meeting of
                                                         the committee. The vehicle was driven past members waiting on the footway several times but members
                                                         were unable to hear the vehicle approaching.
                                                         A University of California study found that a petrol/diesel car could be heard 36ft (11 metres) away, but an
                                                         electric Toyota Prius was not heard until it was 11ft from blindfolded volunteers.

                                                         Guide Dogs has called for research to be carried out into the safety implications for blind and partially
                                                         sighted and other pedestrians, before there are a high number of electric and hybrid vehicles on our streets.
                                                         We believe that minimum sound requirements for electric and hybrid vehicles needs to be implemented by
                                                         legislators to encourage the adoption of such technologies which will ultimately increase pedestrian safety
                                                         for everyone.
                                                         Industry current work
                                                         Guide Dogs has been working with Lotus Engineering to develop an external sound technology for use on
                                                         hybrid electric vehicles to enhance pedestrian safety. Lotus Engineering, the automotive consultancy
                                                         division of Lotus, has simulated a real engine sound for use on its „Safe & Sound‟ Hybrid technology
                                                         demonstrator vehicle, with its pitch and frequency helping to identify the vehicles distance and speed as
                                                         normal. When the car is operating on the electric motor only, throttle and speed dependent synthesised
                                                         sound projects a realistic engine sound in front of the vehicle. Once the vehicle has passed, the sound is not
                                                         heard, and the driver hears almost none of the additional sound. What has resulted is the same
                                                         environmentally conscious hybrid vehicle, without the potential risk to pedestrians and cyclists.

                                                         Other countries
                                                         USA
                                                         In January 2009, a bill titled „Pedestrian Safety Enhancement Act of 2009‟ (2) was introduced into the
                                                         Senate and House of Representatives of the USA in Congress. The bill has instructed the Secretary of
                                                         Transportation to study and establish a motor vehicle safety standard that provides for a means of alerting
                                                         blind and other pedestrians of motor vehicle operation.
                                                         The Bill is at an early stage and as yet has not reported.

                                                         Europe
                                                         ANEC is the European consumer voice in standardisation. They represent the European consumer interest
                                                         in the creation of technical standards, especially those developed to support the implementation of
                                                         European laws and public policies. The European Union is funding ANEC to establish a task-working group
                                                         to research and make recommendations.
                                                         Guide Dogs has been invited to participate in this task-working group. The European Disability Forum is
                                                         also participating.

                                                         Westminster
                                                         The issue has been raised with the Minister for Transport and with officials at the Department for Transport.
                                                         It was agreed that the Department of Transport would set up a working group, however this has not
                                                         happened as yet, despite request to do so.




                                                                            69
Question 8: What, if any, technical challenges would
the grid reinforcement upgrades be likely to present?
How might these be overcome?
Question 9: Who would fund any grid upgrades?
And, how might these costs be recovered?
Question 10: Do any of the technologies present any
specific challenges or opportunities to island
communities and sparsely populated rural areas in
Scotland? If so, how might these challenges by
addressed, and by whom?
Question 11: Do you think that having a twin
approach for the public sector and other users is
appropriate? If so, why? If not, why not?
Question 12: If so, should targets relate to the uptake
of low carbon vehicles (either as a percentage of the
fleet or an absolute number), or a reduction in total
emissions across the fleets or another format of
target? Why?
Question 13: If we follow a target relating to the
public sector uptake of LCVs, what percentage of the
fleet should be LCVs by 2020? Please give reasons
for your answer.
Question 14: If we follow a target relating to the
uptake of LCVs across all road users, what
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 16: As LCVs may have higher upfront costs
than traditional vehicles (albeit with a smaller
discrepancy between lifecycle costs) do you
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 16: As LCVs may have higher upfront costs
than traditional vehicles (albeit with a smaller
discrepancy between lifecycle costs) do you
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase
Question 17: Are there any opportunities or barriers
to public sector procurement of LCVs that are not
mentioned in this document? If so, what are they?
Question 18: What are the individual roles of different
groups and organisations in ensuring the provision
of any infrastructure required for low carbon
vehicles?
Question 19: Are there other supply side/capacity
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of     Scotland does not traditionally have large vehicle manufacturing. If niche low carbon vehicle research and
an indigenous low carbon vehicle industry in              industry was to develop then it cannot work in isolation of other research and initiatives. If Scotland is to be
Scotland? If so, what are they and how might they be      at the cutting edge of low carbon technologies, then industry, researchers, and the Scottish Government will
overcome?                                                 be required to participate and take cognisance of similar work elsewhere around the world. This is relevant
                                                          in taking forward the issue of ensuring that electric and hybrid vehicles have the external sound technology
                                                          necessary so as not to put the publics‟ safety at risk, particularly blind and partially sighted people.
Question 21: Should Scotland’s industry focus on
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders
collaborate to stimulate the development and uptake
of LCVs?




                                                                             70
R34 - Highlands and Islands Enterprise


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Sandy Brady
 Organisation:                                             Highlands and Islands Enterprise
 Address:                                                  Cowan House, Inverness Retail and Business Park, Inverness
 Postcode:                                                 IV2 7GF
 Email:
 Telephone Number:                                         01463 244204
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       No response
 do you envisage will be first to be influential in
 reducing GHG emissions from the transport sector?
 Why?
 Question 2: Which low carbon technologies and fuels       No response
 do you believe will ultimately have the greatest
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are            No response
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        No response
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               No response
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     A potential barrier to the uptake of fuels and technologies mentioned in the document is the local availability
 such fuels and technologies that are not mentioned        or otherwise of servicing, maintenance and repair skills and costs for the vehicles and associated fuel
 in this document? If so, what are they?                   infrastructure.
                                                           A fundamental issue to Highlands and Islands Enterprise is the challenge of technology uptake in remote
                                                           rural and island areas with low population density. We recognise the visionary and groundbreaking
                                                           hydrogen and LCV projects underway on Unst and in the Outer Hebrides, and look forward to sustainable
                                                           models being developed from these that can be deployed throughout the Highlands and Islands.
 Question 7: Are there any negative social impacts         The current strategic focus is, understandably, on urban take up, but future policies and strategies need to
 associated with either the development or uptake of       avoid the long term creation of a 2-tier transport network placing further differential between urban and rural
 such technologies/fuels? If so, what are they?            technology take up and associated fuel costs. Failure to roll out fuel infrastructure availability on a wholly
                                                           national basis would have a major adverse impact on the core viability of remote and island communities. In
                                                           addition to the transportation needs of the indigenous businesses and communities, the vital tourism sector
                                                           could be badly affected if visitors were, or even perceived they might be, unable to satisfy their fuel
                                                           requirements in remote or island areas.
 Question 8: What, if any, technical challenges would      No response
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             We recognise that grid upgrades in remote and island areas will be of above average cost. We also
 And, how might these costs be recovered?                  recognise that the economic and social fragility of such areas suggest that cost recovery will require special
                                                           case dispensation or subsidy.
 Question 10: Do any of the technologies present any       Our responses to previous questions address some of the issues surrounding islands and remote
 specific challenges or opportunities to island            communities. The challenges to these locations should ease as technologies are further developed that
 communities and sparsely populated rural areas in         increase the range and endurance of LCVs, allied perhaps to local or regional fuel production. However,
 Scotland? If so, how might these challenges by            many such communities depend on small fishing and marine work boats whose small inboard and outboard
 addressed, and by whom?                                   engines may not be a priority for up take of new technology and fuels. Similarly, there may be a danger that
                                                           vehicle design and future manufacture may concentrate on 'city' cars for short commuting and shopping
                                                           trips. There will still be a requirement in rural areas for modem rugged, 4 wheel drive, off-road load carrying
                                                           vehicles. Lead responsibility for identifying and resolving challenges, along with optimising opportunities,
                                                           requires to be clarified between the Scottish Government, local authorities, Highlands and Islands
                                                           Enterprise, and other agencies.
 Question 11: Do you think that having a twin              No response
 approach for the public sector and other users is
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake   No response
 of low carbon vehicles (either as a percentage of the
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        No response
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the        No response
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        No response
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        A key function of the public sector is to address market failure. In this context, there is no established
 than traditional vehicles (albeit with a smaller          market. To stimulate the market and provide confidence for the private sector to invest in the technologies, it
 discrepancy between lifecycle costs) do you               is necessary for the public sector to take the lead in guaranteeing that a minimum number of units will be
 consider it to be efficient use of public resources to    purchased. The long term benefits to the economy and the environment greatly outweigh the short term
 devote a greater short-term budget towards the            additional financial cost. These long term benefits could be quantified if necessary to suspend normal
 purchase of LCVs? If so, why? If not, why not?            procurement criteria.
 Question 17: Are there any opportunities or barriers      No response
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different   No response
 groups and organisations in ensuring the provision
 of any infrastructure required for low carbon
 vehicles?




                                                                              71
Question 19: Are there other supply side/capacity       As previously mentioned, a potential constraint may be the lack of servicing, maintenance and repair skills
constraints impacting on LCV development and            and facilities.
uptake? If so, what are they?
Question 20: Are there barriers to the development of   No response
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on        No response
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If     No response
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for    No response
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         No response
collaborate to stimulate the development and uptake
of LCVs?




                                                                           72
R35 – Institute of Mechanical Engineers


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Jonathan Levack
 Organisation:                                             Institute of Mechanical Engineers
 Address:
 Postcode:
 Email:
 Telephone Number:                                         020 7973 1293
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Vehicles powered by internal combustion engines (ICE) and to a lesser extent ICE / electric hybrid vehicles
 do you envisage will be first to be influential in        will be extremely important in reducing emissions; vehicle technology is well proven and highly reliable and
 reducing GHG emissions from the transport sector?         ICE powered vehicles are likely to remain the dominant road vehicle propulsion system for at least the next
 Why?                                                      10 to 20 years. At present however, only about 20% of the energy in the fuel is converted to useful forward
                                                           motion. There is considerable potential for new technologies to improve efficiency and reduce emissions
                                                           from both petrol and diesel engines. Further, vehicle manufacturers have in the past prioritized features
                                                           other than emissions efficiency; safety, passenger comfort for example. They now recognise the reduction
                                                           of emissions as a priority of engineering design as well as its potential as a saleable benefit to the customer.
                                                           Accordingly we have seen recent improvements in fuel economy and reductions in tailpipe emissions.

                                                           Improvements in fuel consumption can also be made through vehicle design. The use of lightweight
                                                           materials such as plastic, carbon fibre and aluminium to replace steel will lessen the amount of fuel needed.
                                                           Advances in computer modelling are also allowing engineers to improve the aerodynamics of both cars and
                                                           planes, meaning less friction and therefore fuel use.

                                                           In the short term, IC petrol engines will be able to deliver an overall feet average close to 100g/km and by
                                                           2020 cars should be able to achieve close to 70g/km.
 Question 2: Which low carbon technologies and fuels       Electric vehicles. Electricity uses existing delivery infrastructures and can be generated using renewable
 do you believe will ultimately have the greatest          energy sources such as waste, wind hydro etc as well as low carbon sources such as nuclear fission.
 emissions abatement impact? Why?                          Therefore it uses the most mature low carbon energy sources available with a minimum of infrastructure
                                                           changes making the most immediate impact.

                                                           Fuel cells are an emerging technology and there is a long way to go before they will be able to offer a high-
                                                           volume, economic and affordable alternative. They can be powered by a variety of fuels, but there are
                                                           continuing difficulties with the storage and transport, particularly with hydrogen, due to its atomic weight (the
                                                           atoms are so small that the gas leaks away through most materials, including metals).

                                                           Depending on its source, using hydrogen as a fuel could potentially give zero emissions, and there is no
                                                           reason why it cannot be burned in low-cost IC engines. However, after ten years of development the
                                                           technology still only just matches the efficiency of an IC engine but with a major on-cost. Currently the
                                                           biggest concern is providing low-cost, efficient hydrogen storage and distribution in either its gaseous or
                                                           liquid form.
 Question 3: What timescales do you believe are            Near Term (next 30+ years):
 feasible for the development of specific low carbon                    Advanced Gasoline Internal Combustion Engines; delivering around 105g/km CO2: low cost,
 technologies and fuels? Are there any important                         reliable, familiar, uses existing capital & refuelling infrastructure
 intermediate milestones within these timescales?
                                                           Near to Mid Term: (next 40+ years)
                                                                       Modern Clean Diesel Internal Combustion Engines; delivering around 90g/km CO2;
                                                                        challenges include fuel quality and emissions levels
                                                                       Hybrid Powertrains; delivering around 85g/km CO2; market penetration of 10-15%; most
                                                                        beneficial in urban driving, combine with advanced fuels

                                                           Mid Term: (Bridging technology)
                                                                       Hydrogen Internal Combustion Engines; delivering 0g/km CO2; bridging action / enabler for a
                                                                         Hydrogen economy

                                                           Long Term
                                                                     Fuel Cells; delivering 0g/km CO2; impact in 20–30 years and beyond; endgame for the
                                                                       hydrogen economy, environmentally neutral powertrain
 Question 4: What timescales do you believe are the        No comment at this time.
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               No.
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     No.
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         No.
 associated with either the development or uptake of
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would      No comment at this time.
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             No comment at this time.
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any       Electric vehicles are likely to work best in urban areas due to their relatively short range and to the relative
 specific challenges or opportunities to island            ease of creating appropriate infrastructure in built up areas. If appropriate infrastructure was available in
 communities and sparsely populated rural areas in         rural areas however electric vehicles could play a significant role, particularly as manufacturers increase
 Scotland? If so, how might these challenges by            vehicle ranges over time. In particular, electrification presents an opportunity through integrating renewable
 addressed, and by whom?                                   energy sources into locally generated electricity; this would harness the value of combusting local waste,
                                                           along with the use of local sources of wind and wave energy. This would also reduce the wastage that
                                                           occurs through long distance transmission of electricity. Locally produced energy could also encourage
                                                           community ownership of the energy „problem‟ and thus could help reduce demand.
 Question 11: Do you think that having a twin              Yes. The public sector is a major purchaser and operator of vehicles and should take a lead in
 approach for the public sector and other users is         developments and uptake.
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake   Emission targets are set in terms of emission; hence vehicle fleet targets should also be set using the same
 of low carbon vehicles (either as a percentage of the     metrics. In order to set a lead and help drive positive change (leveraged through example and fleet size)
 fleet or an absolute number), or a reduction in total     targets for the public sector should be set at the most stringent possible levels.




                                                                              73
emissions across the fleets or another format of
target? Why?
Question 13: If we follow a target relating to the        We do not agree with this premise (see 12, above). A percentage of fleet is, potentially, a red herring. If, for
public sector uptake of LCVs, what percentage of the      example, 20% of the vehicle fleet was electric but the other 80% of vehicles were high emitters, no net
fleet should be LCVs by 2020? Please give reasons         overall decrease in emissions would be achieved.
for your answer.
Question 14: If we follow a target relating to the        We do not agree with this premise (see 12, above).
uptake of LCVs across all road users, what
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        No vehicle categories should be excluded.
should be excluded from the public sector target? If
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        Yes. The Scottish government‟s stated aim is to achieve sustainable economic growth; to do this it should
than traditional vehicles (albeit with a smaller          set the standard required and take a lead in proving that LCVs can be used in this way.
discrepancy between lifecycle costs) do you
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      No.
to public sector procurement of LCVs that are not
mentioned in this document? If so, what are they?
Question 18: What are the individual roles of different   A key issue that is likely to rise to prominence in the next 5 to 10 years is the supply of an appropriate skills
groups and organisations in ensuring the provision        mix to support new infrastructure development. It is anticipated that government support may be needed to
of any infrastructure required for low carbon             encourage and enable companies to train employees in the specific skills needed in these new applications
vehicles?                                                 of technologies. Companies will have to take some responsibility through, for example, operating suitable
                                                          Apprenticeship frameworks.
Question 19: Are there other supply side/capacity         A key constraint is the need for batteries to be more efficient (to extend vehicle range and reduce
constraints impacting on LCV development and              emissions), have a greater working life and to be more „environmentally friendly‟ before they are widely
uptake? If so, what are they?                             used. In addition questions still remain about the viability of Lithium, widely used in batteries. There are
                                                          concerns about the amount of Lithium available and political problems with gaining economic access to it;
                                                          some of it is in remote areas and in Bolivia which has stated its reluctance to allow widespread mining.
                                                          Alternatives are in development but are not yet proven.
Question 20: Are there barriers to the development of     Scotland has no current indigenous vehicle industry and the potential to develop one from the ground up is
an indigenous low carbon vehicle industry in              limited. There is greater potential in developing industries that form part of the vehicle parts supply chain,
Scotland? If so, what are they and how might they be      particularly in emerging low carbon technologies. The distance between any new Scottish manufacturing
overcome?                                                 sites and the likely UK based vehicle manufacturers (e.g. Nissan in Sunderland) may well prove to be a
                                                          problem; similarly the supply of sufficient employees with the appropriate skills in the new technologies may
                                                          be a barrier to entry.
Question 21: Should Scotland’s industry focus on          Attempting to pick technology winners is fraught with problems and is unlikely to prove successful.
particular vehicle types? If so, what are they and        Stringent targets, set by governments, will force the hand of innovation and winners will emerge through
why? If not, why not?                                     market forces.
Question 22: Are there gaps in the supply chain? If       We have insufficient local knowledge to comment.
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      See, also, our response to 20, above. The answer to this depends to some extent on which technologies
the development of this market? If not, where are the     emerge through appropriate market forces (see 21, above). However, a supply of people with good
gaps?                                                     science, technology, engineering and mathematics (STEM) skills at all levels will be vital; the key is to
                                                          ensure we have a workforce with the ability to adapt and transfer their STEM skills into various areas as
                                                          they develop.
Question 24: How could the various stakeholders           No comment at this time.
collaborate to stimulate the development and uptake
of LCVs?




                                                                             74
R36 - Association of Chief Police Officers in Scotland


 RESPONDENT INFORMATION DETAILS

 Name:                                                    Caroline Scott
 Organisation:                                           Association of Chief Police Officers in Scotland
 Address:                                                26 Holland Street, Glasgow
 Postcode:                                               Caroline Scott
 Email:
 Telephone Number:                                       0141 435 1230
 Responding as:                                          On behalf of a group or organisation
 Individual Permission:                                  Not Supplied
 Confidentiality:                                        Not Supplied
 Group or Organisation:                                  Yes
 Share Response Permission:                              Yes
 Question 1: Which low carbon technologies and fuels     At present the vehicle manufacturers are researching and developing several alternate fuels technologies.
 do you envisage will be first to be influential in      However, the momentum appears to be in the direction of electric or hybrid vehicle technology.
 reducing GHG emissions from the transport sector?
 Why?                                                    The development of 2nd generation Bio-fuels and Hydrogen fuel cells will also have an impact on the motor
                                                         industry but with the “quick fix” that electric cars give, it is possible that the 2nd generation bio-fuel and
                                                         hydrogen fuel cell alternatives will take time to gather momentum.

                                                         Taking this into consideration, it is suggested that the electric powered vehicle will have the greatest short
                                                         term influence. The biggest issue with this technology and the barriers to it appear to centre on the
                                                         longevity of battery charge, life cycle, the battery re-charging time allied with the performance of the vehicle.
                                                         Lithium Ion battery technology has improved the battery lifetime and charge cycle issue but the performance
                                                         and recharging cycle remains an area of concern.

                                                         Consideration should be given to alternatives to improve performance for longer journeys. There may be a
                                                         case for examining the road network itself to assist with the development of electric vehicles. The possibility
                                                         of roads carrying a mobile charge system is one area for potential consideration. An electric vehicle could
                                                         be capable of taking a charge from the road by some means. This in turn could be used to regulate speeds
                                                         in areas that hold a possible accident risk.
 Question 2: Which low carbon technologies and fuels     Electrically powered vehicles will be the most effective way to reduce emissions produced by road vehicles.
 do you believe will ultimately have the greatest        As technology advances, the re-charging of the vehicle battery will have less of an impact on the
 emissions abatement impact? Why?                        environment with the development of regenerative braking and solar recharging as examples of this.
                                                         Further advances in this technology will assist with the reduction of the environmental impact that the main
                                                         stream electricity production currently has. Any further technological advance in the electrical energy
                                                         production or capture should be encouraged.
 Question 3: What timescales do you believe are          Low carbon technology is advancing with the introduction of regenerative braking in hybrid and electric
 feasible for the development of specific low carbon     vehicles as one example. However there must be an acceleration of the research and development to allow
 technologies and fuels? Are there any important         advances in efficient technology to impact on the vehicle industry.
 intermediate milestones within these timescales?
                                                         As well as the investment of time and money being employed to ensure a reduction in emissions for fossil
                                                         fuelled internal combustion engines, vehicle manufacturers should be given incentives to drive the low
                                                         carbon fuel alternatives forwards.

                                                         The private sector‟s current low uptake of the alternative fuel vehicle does not encourage the vehicle
                                                         manufacturer to invest heavily in this area. The main emphasis presently on technology coming to market is
                                                         reduced emissions and better fuel consumption in fossil fuelled vehicles. This helps reduce the emissions in
                                                         the short term but it is not a long term solution to the problem.

                                                         The main driver for the motor industry is the creation of an infrastructure for re-fuelling of vehicles as the
                                                         current fuel stations infrastructure may become redundant. It is suggested that until this area is developed
                                                         there will be a resistance to the manufacturer mass producing any alternate fuel vehicle other than electric,
                                                         which benefits from the resilience of the national grid network.

                                                         It is therefore a concern that the manufacturers will be driven down a route that may or may not be the best
                                                         long term solution, due to the fact that it is the path of least resistance from the consumer‟s point of view.
 Question 4: What timescales do you believe are the      The uptake of low carbon technology and fuel from the consumer‟s point of view will be driven by the
 feasible for the uptake of specific low carbon          production of a re-fuelling network. This structure must be in place to encourage the development, by the
 technologies and fuels? Are there any important         vehicle manufacturers, of mass production of low or no carbon emission vehicles.
 intermediate milestones within these timescales?
                                                         There may be a perception by the general public that severe limitations exist regarding the range of
                                                         alternative fuel vehicles. There must be clarity and understanding by the consumer that they can make
                                                         longer journeys in low or no carbon vehicles and have the security and piece of mind that there is a re-
                                                         fuelling network available to use.
                                                         If the electricity network could be adapted to provide a system where vehicles can be charged from
                                                         designated re-charge points at e.g. car parks, workplaces and homes etc this would encourage uptake of
                                                         the technology from the consumer‟s point of view. This in turn could provide a relatively quick solution
                                                         measured in years as opposed to decades that an alternative re-fuelling network may take to establish and
                                                         operate.
 Question 5: Are there other barriers to the             The only barrier would be assuming a blinkered approach to the development. Options should be kept open
 development of such fuels and technologies that are     and every possibility investigated thoroughly.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of   The market for various low carbon emission vehicles (primarily hybrid at this time) is currently limited since
 such fuels and technologies that are not mentioned      the number of vehicles ordered is proportionally very small. This means there are a finite number of "spare"
 in this document? If so, what are they?                 or "replacement" components for each vehicle which ultimately results in much higher costs per item. The
                                                         foregoing would make it an unattractive proposition for potential buyers. Further the more educated the
                                                         consumer becomes, the more readily they will embrace the roll out of the new technology as and when it
                                                         happens.
 Question 7: Are there any negative social impacts       There is likely to be a dramatic change in the way that we currently use vehicles to travel around if low
 associated with either the development or uptake of     carbon vehicles become the norm. There needs to be a greater uptake of public transport to make extended
 such technologies/fuels? If so, what are they?          journeys as I feel there may be vehicle range and re-fuelling time issues that impact on journeys. This will
                                                         cause an initial resistance to the change from traditional fossil fuelled vehicles as the inconvenience will be
                                                         felt heavily by vehicle users until they become used to the change in pattern.
 Question 8: What, if any, technical challenges would    Unknown, this is for the energy supply industry to establish. However, if rolled out throughout the UK, the
 the grid reinforcement upgrades be likely to present?   programme of roadside work is likely to cause major disruption on a scale previously unseen.
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?           As the profit from the energy sale will be made by the energy companies, it is suggested that the cost of
 And, how might these costs be recovered?                providing the network should be borne by them. Alternatively, to encourage the set up of the network, could
                                                         central government share the cost of set up with a profit share then being returned as a form of repayment
                                                         over a set period?
 Question 10: Do any of the technologies present any     All of these technologies present a problem for the island communities and sparsely populated areas.
 specific challenges or opportunities to island          However these are to some extent, no different to the current challenges that are encountered for fossil fuel
 communities and sparsely populated rural areas in       distribution.




                                                                            75
Scotland? If so, how might these challenges by            An opportunity for island/rural communities would be the readily available sources of energy via wind and
addressed, and by whom?                                   wave power, with the obvious employment gains to local residents.
Question 11: Do you think that having a twin              Yes a twin approach is appropriate as this should encourage the manufacturers of LCV‟s to accelerate the
approach for the public sector and other users is         move to market for the products with the technology to make a difference.
appropriate? If so, why? If not, why not?
                                                          However consideration has to be given to the role that these initial vehicles undertake and in certain
                                                          environments, (e.g. emergency service blue light roles), there is no room for trialling and testing unproved
                                                          technology. The product and technology must be suitable and fit for purpose prior to any consideration
                                                          being given. Therefore the 100% target by 2020 for Local Authority uptake is unachievable for emergency
                                                          service vehicles without a dramatic acceleration in the advance of technology.
Question 12: If so, should targets relate to the uptake   It is the responsibility of the organisation to measure their carbon footprint. Within this there should be
of low carbon vehicles (either as a percentage of the     targets set that show a reduction in the tonnage of CO2 emissions from the fleet over a set period.
fleet or an absolute number), or a reduction in total
emissions across the fleets or another format of          Each fleet is different with differing mileages, fuel usage and vehicle make up. If is therefore very difficult to
target? Why?                                              set broad brush targets. The responsibility should lie within the fleet managers remit to ensure that there are
                                                          inroads made annually to the ultimate target of reducing emissions by 80% in 2050.
Question 13: If we follow a target relating to the        This depends upon individual fleet policy and change cycle. Within the Scottish Police Forces there are
public sector uptake of LCVs, what percentage of the      differing opinions on replacement criteria, so it may be difficult to enforce a target relating to the overall fleet.
fleet should be LCVs by 2020? Please give reasons         It would seem unlikely that any Fleet Manager would want to replace vehicles that are still current and fit for
for your answer.                                          service without a financial incentive.

                                                          The targeting should relate to areas of the fleet that can readily accommodate the change to LCV‟s. Initially
                                                          targets should be set as a lower percentage to allow proving and ratification for roles that are to be
                                                          considered.
Question 14: If we follow a target relating to the        The answer to this is dependant again on technology advances. It is difficult to determine a percentage
uptake of LCVs across all road users, what                without a clear understanding and direction of where this technology is moving to. We are still in the infancy
percentage of all new vehicles should be LCVs by          of these advances and it is extremely difficult to gauge public reaction to such a dramatic shift from the
2020? Please give reasons for your answer.                dependence on fossil fuelled internal combustion engines to relatively untried LCV technology.
Question 15: Are there any vehicle categories that        Generally speaking Operational Emergency Services vehicles can not operate with new unproven
should be excluded from the public sector target? If      technology. These services have a duty of care to the population that can not be compromised. Any targets
so, what are they and why should they be excluded?        set for non-public sector vehicles, specifically Emergency Vehicle Sector, must take into account the unique
If not, why not?                                          requirements and demands of specialist fleets. Efforts to reduce carbon output within police fleets are
                                                          proving successful but do rely on the availability of appropriate vehicles from suppliers. With much of the
                                                          country covered by rural and upland terrain many options in the hybrid, plug-in or electric vehicle market are
                                                          not yet considered suitable. ACPOS would therefore recommend specific consultation prior to fixing targets
                                                          in the emergency service sector.
Question 16: As LCVs may have higher upfront costs        Yes, fleet size in this organisation as an example can not be reduced to allow the purchase of more
than traditional vehicles (albeit with a smaller          expensive replacement vehicles without impinging upon operational resilience. There would have to be
discrepancy between lifecycle costs) do you               funding to allow the uptake of the first life cycle of the LCV alternative.
consider it to be efficient use of public resources to
devote a greater short-term budget towards the            The reduction in revenue spend with the savings of running these LCV vehicles would then have to be
purchase of LCVs? If so, why? If not, why not?            diverted to allow the capital funding of the 2nd change cycle for these vehicles when they reach the end of
                                                          their life.
Question 17: Are there any opportunities or barriers      The general public will expect that this reduction in CO2 should happen at no cost to them in any way.
to public sector procurement of LCVs that are not         However the funds will have to be found from somewhere, either increased revenue generation via taxation
mentioned in this document? If so, what are they?         or alternatively a reduction in the costs of the services currently provided to ensure that we meet the targets
                                                          that are set.
Question 18: What are the individual roles of different   The role of Scottish police forces is to take a lead in the procurement and operation of a low carbon fleet
groups and organisations in ensuring the provision        that suits the purpose of an operational police force. The issues and advances should be shared via liaison
of any infrastructure required for low carbon             between forces and the National Association of Police Fleet Managers to ensure best practice is shared.
vehicles?
Question 19: Are there other supply side/capacity         The biggest issue is confidence in the technology. Once there is sufficient confidence that the technology is
constraints impacting on LCV development and              sustainable and operates efficiently and that there is a refuelling infrastructure the uptake will face little or no
uptake? If so, what are they?                             objection.
Question 20: Are there barriers to the development of     The low carbon vehicle industry is set for a period of major growth. If Scotland is to be at the forefront of this
an indigenous low carbon vehicle industry in              evolution the country must become involved at the grass roots level now. If there are any barriers
Scotland? If so, what are they and how might they be      encountered in the progression of this new industry they should be addressed and broken down as soon as
overcome?                                                 is possible without exception.
Question 21: Should Scotland’s industry focus on          Focus, should be at present, on electric vehicle development as it is going to be the fastest moving
particular vehicle types? If so, what are they and        technology in the short term. However research and development in all forms of LCV technology should be
why? If not, why not?                                     encouraged.
                                                          Scotland has a long and proud history of leading the way and developing new technology. There are many
                                                          examples of this that are well known worldwide. Low carbon vehicle technology should be the next major
                                                          breakthrough for Scottish industry.
Question 22: Are there gaps in the supply chain? If       Consideration should be given to the after sales service provided by the vehicle manufacturer and their
so, what are they and how might these be overcome?        dealer network. There is going to be a massive re-training of vehicle technicians required to ensure that
                                                          there is a sufficient service and repair network established.
Question 23: Do we have the required skills base for      The skill base is in place in the motor trade but radical changes in vehicle technologies will undoubtedly
the development of this market? If not, where are the     require a massive amount of re-training to ensure that the service levels are maintained.
gaps?
Question 24: How could the various stakeholders           It is in everyone‟s interest to ensure that the development and uptake of LCV‟s is progressed at the earliest
collaborate to stimulate the development and uptake       opportunity in the shorter term. Communication between all stakeholders is the key. This must be driven
of LCVs?                                                  centrally to ensure that best value is gained.

                                                          At the moment there are far too many interested parties operating individually. This can and will lead to
                                                          delays in the research, development, demonstration, commercialisation and uptake of LCV‟s.

                                                          A central body should be empowered to ensure that there is communication between all stakeholders to
                                                          accelerate the process, thus ensuring that Scotland is at the forefront of future developments




                                                                              76
R37 - Living Streets


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Keith Irving
 Organisation:                                             Living Streets
 Address:                                                  Thorn House, 5 Rose Street, Edinburgh
 Postcode:                                                 EH2 2PR
 Email:
 Telephone Number:                                         0131 243 2645
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels
 do you envisage will be first to be influential in
 reducing GHG emissions from the transport sector?
 Why?
 Question 2: Which low carbon technologies and fuels
 do you believe will ultimately have the greatest
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         Low carbon vehicles will be a welcome technological development but this must not divert attention from the
 associated with either the development or uptake of       need to stabilise rising road traffic levels. There would be a negative social impact from dependence on cars
 such technologies/fuels? If so, what are they?            even if they were all low carbon. Key negative impacts include road casualties, congestion, community
                                                           severance, air pollution, for example nitrogen dioxides, and reduced physical activity and related health
                                                           problems.
 Question 8: What, if any, technical challenges would
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any
 specific challenges or opportunities to island
 communities and sparsely populated rural areas in
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin
 approach for the public sector and other users is
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake
 of low carbon vehicles (either as a percentage of the
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs
 than traditional vehicles (albeit with a smaller
 discrepancy between lifecycle costs) do you
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different
 groups and organisations in ensuring the provision
 of any infrastructure required for low carbon
 vehicles?
 Question 19: Are there other supply side/capacity
 constraints impacting on LCV development and
 uptake? If so, what are they?
 Question 20: Are there barriers to the development of
 an indigenous low carbon vehicle industry in
 Scotland? If so, what are they and how might they be
 overcome?
 Question 21: Should Scotland’s industry focus on
 particular vehicle types? If so, what are they and
 why? If not, why not?
 Question 22: Are there gaps in the supply chain? If




                                                                              77
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         Stakeholders should be collaborating to achieve the goals laid out in the National Transport Strategy,
collaborate to stimulate the development and uptake     especially to: “reduce emissions, to tackle the issues of climate change, air quality and health improvement”.
of LCVs?
Additional Comments                                     We welcome the acknowledgement in this consultation that action on low carbon vehicles must be part of a
                                                        wider package of measures and that technology alone cannot deliver the emission reductions required
                                                        under the Climate Change (Scotland) Act. We therefore believe that this statement in the consultation
                                                        document must be included in the final low carbon vehicle strategy, with further details of the package of
                                                        measures:

                                                         “The significant uptake of low carbon vehicles will be part of a wider package of measures to mitigate
                                                        against climate change, including those aimed at increasing walking and cycling, smarter travel choices and
                                                        making better use of public transport.”




                                                                           78
R38 - Royal Automobile Club Foundation


 RESPONDENT INFORMATION DETAILS

 Responding as:                                          Luca Lytton
 Organisation:                                           RAC
 Address:                                                Royal Automobile Club Foundation, 89-91 Pall Mall, London
 Postcode:                                               SW1Y 5HS
 Email:
 Telephone Number:                                       020 7747 3487
 Responding as:                                          On behalf of a group or organisation
 Individual Permission:                                  Not Supplied
 Confidentiality:                                        Not Supplied
 Group or Organisation:                                  Yes
 Share Response Permission:                              Yes
 Question 1: Which low carbon technologies and fuels     Reducing GHG emissions from the transport sector will only be achieved through economies of scale, i.e. a
 do you envisage will be first to be influential in      significant number of a certain type of low carbon vehicle. Although they offer the least reduction potential
 reducing GHG emissions from the transport sector?       out of all the options listed, hybrid electric vehicles are likely to be the first type of vehicle to reduce
 Why?                                                    emissions from the transport sector, simply because their numbers are far greater than vehicles running on
                                                         biofuels, let alone pure electric or hydrogen vehicles. Hybrids‟ reduction potential is likely to be increased
                                                         much further over the next few years if there are improvements in the internal combustion engine, battery
                                                         technology and if vehicles are downsized through the use of light-weight materials. Furthermore, hybrids are
                                                         currently the only viable technology that are able to deliver reductions in emissions from heavy vehicles
                                                         such as buses and HGVs. Pure electric vehicles as of yet cannot deliver the necessary power. Although
                                                         heavy vehicles are amenable to large hydrogen tanks, mass scale production of hydrogen currently still is
                                                         carbon-intensive and will therefore not deliver significant GHG reductions in the short to medium term. The
                                                         impact of hydrogen in the long-term is still uncertain. Effort should not only be put into developing new low
                                                         carbon technologies. Encouraging the uptake of „best in class‟ within the current vehicle mix will have a
                                                         beneficial impact on reducing GHG emissions, at least in the short term.
 Question 2: Which low carbon technologies and fuels     While hydrogen is often quoted as the ultimate form of clean transport, it is an energy carrier, the generation
 do you believe will ultimately have the greatest        of which on a mass scale is carbon-intensive, and is likely to continue to be so in the foreseeable future.
 emissions abatement impact? Why?                        Similarly, the reduction potential of biofuels is negated by the fact that its production currently involves
                                                         deforestation and crops that could otherwise be utilised for food production. Finally, the fact that hybrids and
                                                         even cleaner plug-in hybrids run an internal combustion engine means that they will always emit CO 2.

                                                         Ultimately, it is therefore pure electric vehicles that are likely to offer the greatest emissions reduction
                                                         potential. This is because EVs can at least in theory run on 100% carbon-free electricity generated by
                                                         renewable resources (e.g. wind turbines running over night). EVs‟ abatement impact will therefore increase
                                                         proportionally to an increase in the share of renewable energies in the UK‟s energy mix. Even on the current
                                                         energy mix that produces 500 gCO2/kWh, it is estimated that EVs can deliver CO2 reductions of up to 40%
                                                         compared to the average UK vehicle.
 Question 3: What timescales do you believe are          Hybrids are already well developed and will be further refined over the next couple of years. Part of this will
 feasible for the development of specific low carbon     be the development of plug-in hybrids, as for example the new Toyota Prius which is currently being
 technologies and fuels? Are there any important         developed and to be made available as of 2012. Although pure electric vehicle technology is proven, battery
 intermediate milestones within these timescales?        technology and its price are still said to be the main impediment for the development of such vehicles.
                                                         However, batteries are expected to develop rapidly within the next decade. The rate of innovation and
                                                         progress is higher than it has ever been before, largely because of the demand and political imperative for
                                                         such technologies. Key milestones are therefore precisely developments around improving battery capacity,
                                                         recharging and eliminating inefficiencies. The development of efficient, carbon neutral hydrogen fuel cells on
                                                         a mass scale is still a long way away, at least at a viable economic cost.
 Question 4: What timescales do you believe are the      Hybrids are already available in showrooms today and their numbers will increase steadily over the next
 feasible for the uptake of specific low carbon          years. Widespread market penetration can therefore be expected by the middle of the next decade. This will
 technologies and fuels? Are there any important         be accompanied by a slightly slower uptake of plug-in hybrids, perhaps starting around 2015. A large-scale
 intermediate milestones within these timescales?        uptake of pure electric vehicles, on the other hand, is more likely to occur around 2020, simply because
                                                         battery technology is and will continue to undergo significant improvements in the next decade. Due to
                                                         storage problems and inefficiencies as mentioned above, hydrogen vehicles are likely to be available on the
                                                         market in the long-term only (if at all). An important milestone for both hybrids and electric vehicles is the
                                                         £230m consumer incentive package that will be provided by government between 2011 and 2014. Given
                                                         the likely availability of electric vehicles on a mass scale only by about 2020, this intervention could be too
                                                         early to yield substantial benefits.
 Question 5: Are there other barriers to the             Not answered
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of   The availability of lithium for the more powerful Li-ion batteries has been mentioned as a potential barrier to
 such fuels and technologies that are not mentioned      the development/uptake of battery-powered vehicles, but according to specialists lithium reserves will in any
 in this document? If so, what are they?                 case be able to meet future demand.

                                                         However, given that reserves are finite, this might be a problem in the long term, which will necessitate the
                                                         development of alternative technology, or resorting to slightly inferior NiMH batteries. Rare Earths such as
                                                         lanthanum and neodymium, on the other hand, which are central to batteries and electronics, might pose a
                                                         problem earlier. It is therefore advisable to undertake an analysis of the availability of these resources in
                                                         order to evaluate the potential of LCVs.
 Question 7: Are there any negative social impacts       Although the main barriers to an uptake of new technologies were mentioned, further barriers include safety
 associated with either the development or uptake of     concerns and congestion. Battery-powered vehicles tend to be quieter than conventional Internal
 such technologies/fuels? If so, what are they?          Combustion Engine (ICE) vehicles, and are therefore more difficult to notice for pedestrians and cyclists at
                                                         low speeds where rolling resistance is especially low. Moreover, low carbon vehicle technologies as of
                                                         today are for the most part small vehicles made of light materials.

                                                         An example is the G-Wiz which is classified as a quadri-cycle and therefore does not have to meet the
                                                         same safety requirements as ordinary cars. This could pose a problem in accidents involving light, lower
                                                         carbon vehicles and heavier ICE vehicles.Also, new vehicle technologies do not by themselves solve the
                                                         problem of congestion, which brings with it considerable CO2 emissions – LCVs take up as much space as
                                                         any other vehicle. Linked to this is the so-called “rebound effect” whereby efficiency improvements in terms
                                                         of CO2 may simply be overwhelmed by an increase in vehicles on the road. In any case, a push for LCVs
                                                         must be viewed in conjunction with solving the problem of ever more congested roads.
 Question 8: What, if any, technical challenges would    There is undoubtedly the potential for future demand on the electric grid to be higher than supply in light of
 the grid reinforcement upgrades be likely to present?   the requirements from a number of industries. Overloading existing infrastructure with new and emerging
 How might these be overcome?                            capacity requirements will need to be addressed by the power generation industry.
 Question 9: Who would fund any grid upgrades?           Grid upgrades in the current regulatory framework will most likely be paid by utility companies, although
 And, how might these costs be recovered?                there maybe some State intervention.
 Question 10: Do any of the technologies present any     As recognised in the document, electric vehicles in particular are, at least as of today, first and foremost
 specific challenges or opportunities to island          suited for use in cities because of their limited range. In rural areas, it might therefore be best to push hybrid
 communities and sparsely populated rural areas in       or plug-in hybrid EVs due to the fact that they can resort to the power of the ICE to deliver extended range.
 Scotland? If so, how might these challenges by          The fact that rural Scotland is sparsely populated also raises questions as to the economic viability of
 addressed, and by whom?                                 providing a sufficient coverage of charging infrastructure, since only with a certain minimum density does it
                                                         become economically and socially viable to provide such infrastructure.




                                                                             79
Question 11: Do you think that having a twin              A twin approach for both the public sector and end users is appropriate, given the strong need for curbing
approach for the public sector and other users is         CO2 emissions and projections about ever increasing traffic over the next decades. It would be sensible for
appropriate? If so, why? If not, why not?                 the public sector to be subject to higher abatement targets than end users because it has a responsibility to
                                                          provide a showcase. However, it would also be appropriate to set standards and targets for vehicle
                                                          manufacturers since they are the real drivers of technological innovation in this sector.
Question 12: If so, should targets relate to the uptake   Where possible, it is generally advisable to employ a policy mix which addresses the problem where it
of low carbon vehicles (either as a percentage of the     occurs in a variety of ways. It would, for example, be advisable to complement EU targets of reducing total
fleet or an absolute number), or a reduction in total     emissions across fleets with regulations that spell out a minimum percentage of vehicles that must be low
emissions across the fleets or another format of          carbon. This is likely to be necessary because the scale, i.e. number of vehicles, will increase to such an
target? Why?                                              extent that a target of 95 gCO2/vkm will be insufficient for reducing overall CO2 emissions. A minimum
                                                          percentage could be combined with setting minimum quantities for companies exceeding a certain threshold
                                                          in terms of the number of cars they produce. Overall, it is not advisable to mandate a specific technology but
                                                          rather to set out feasible and sufficiently ambitious GHG reduction targets that must be met, leaving it to
                                                          manufacturers how to achieve them.
Question 13: If we follow a target relating to the        Given that governments should take a lead on the issue and provide a showcase, targets for public sector
public sector uptake of LCVs, what percentage of the      procurement of LCVs should be sufficiently ambitious. It would be perfectly feasible for public authorities to
fleet should be LCVs by 2020? Please give reasons         green at least half of their vehicle fleets, if not more. In fact, if the Scottish government is serious about
for your answer.                                          curbing CO2 emissions by 42% by 2020, this would necessitate turning the entire public sector fleet into low
                                                          carbon vehicles, both in terms of actual emissions and symbolically.
Question 14: If we follow a target relating to the        Not answered
uptake of LCVs across all road users, what
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        There is a case for aiming public sector target at all vehicles. As the report illustrates HGVs and LGVs make
should be excluded from the public sector target? If      up the bulk of emissions from public fleet vehicles. It is therefore necessary to set targets for these vehicle
so, what are they and why should they be excluded?        categories in order to reduce their environmental impact. Although in comparison cars emit far less GHGs,
If not, why not?                                          setting targets for cars and moving to low carbon alternatives is important since cars send out messages to
                                                          every-day car users that such technologies are proven and work well.
Question 16: As LCVs may have higher upfront costs        In order to stimulate an uptake of LCVs, it is advisable to commit short-term public resources. These could
than traditional vehicles (albeit with a smaller          take the form of consumer incentives, e.g. tax breaks and direct funding, which stimulate demand and
discrepancy between lifecycle costs) do you               eventually also supply. However, it is necessary to design such policies carefully, especially in terms of
consider it to be efficient use of public resources to    timing. Although incentives must be made available to consumers as early as possible (so as to stimulate
devote a greater short-term budget towards the            demand and eventually supply), it does not make sense to provide them when there is only a very limited
purchase of LCVs? If so, why? If not, why not?            range of LCVs for consumers to choose from. Poor policy design runs the risk of holding back resources
                                                          that could otherwise be used elsewhere, such as providing additional transport capacity.
Question 17: Are there any opportunities or barriers      Opportunities could include the exploitation of high-profile events such as the Commonwealth Games 2014
to public sector procurement of LCVs that are not         in Glasgow. These events provide excellent settings for LCVs to be marketed and demonstrated to the
mentioned in this document? If so, what are they?         wider public.
Question 18: What are the individual roles of different   Firstly, actual infrastructure manufacturers must ensure that the charging points are of high quality, but must
groups and organisations in ensuring the provision        also undertake the necessary maintenance and servicing. Energy companies must ensure that there is
of any infrastructure required for low carbon             reliable electricity provision, and should aim to decarbonise generation so as to maximise the CO2 reduction
vehicles?                                                 impact. Moreover, these companies could for example trial the vehicle-to-grid concept whereby unused
                                                          electricity stored in a vehicle‟s battery is fed back into the grid to meet other demand. An obvious link
                                                          between the charging infrastructure and energy companies is National Grid, which must make sure that the
                                                          grid can cope with the increased demand and burden that is placed on the electricity grid. In order for these
                                                          organisations and companies to work collaboratively and effectively, national and local governments must
                                                          provide funding and seek to create a regulatory framework that provides certainty for the future.
Question 19: Are there other supply side/capacity         Not answered
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of     Not answered
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          Not answered
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If       Not answered
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      Not answered
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           Firstly, it would be advisable to set up a central platform for all the stakeholders to engage in, much like the
collaborate to stimulate the development and uptake       London Electric Vehicle Partnership. This would enable close collaboration through information sharing and
of LCVs?                                                  would provide a framework through which problems and concerns relating to specific technologies could be
                                                          resolved. Moreover, in order to stimulate development and uptake, it would be advisable to set up
                                                          competitions, trials and demonstration projects such as those set up by the Technology Strategy Board.
                                                          This brings forth innovation champions that drive the LCV agenda forward through innovation, but also
                                                          proves such technologies on the ground. These competitions should not only aim at bringing together the
                                                          public sector, infrastructure providers, car manufacturers and energy companies but also end users in order
                                                          to better understand their needs and to facilitate learning about such vehicle technologies.




                                                                             80
R39 – Scottish Council for Development and Industry


 RESPONDENT INFORMATION DETAILS
 Name:                                                 Gareth Williams
 Organisation:                                         Scottish Council for Development and Industry
 Address:                                              Ballantyne House, 84 Academy Street, Inverness
 Postcode:                                             IV1 1LU
 Email:
 Telephone Number:                                     01463 231 878
 Responding as:                                        On behalf of a group or organisation
 Indvidual Permission:                                 Not Supplied
 Confidentiality:                                      Not Supplied
 Group or Organisation:                                Yes
 Share Response Permission:                            Yes
 Question 1: Which low carbon technologies and fuels   It took decades before, first, petrol and, then, diesel, emerged as the dominant fossil fuels in the transport
 do you envisage will be first to be influential in    sector. It may, again, take decades before the market determines the most influential alternative low carbon
 reducing GHG emissions from the transport sector?     power technology.
 Why?                                                  Biofuels will clearly be important if the EU Renewable Directive for the transport sector is to be met. Evidence
                                                       has been presented that use of first generation biofuels would reduce agricultural production for food and
                                                       biodiversity in Europe and the developing world and increase food prices. SCDI believes that more biofuels will
                                                       be needed over time and in Scotland biodiesel from the waste oil market or straight vegetable oil may offer
                                                       particular environmental benefits. But appropriate environmental safeguards need to be introduced and the
                                                       Gallagher Review was correct to conclude that 4.5 – 8% for biofuels is a more appropriate target at this stage,
                                                       but that it could be raised later if sufficient controls are enforced globally and new evidence gives more
                                                       confidence on sustainability. The approach should be to find way to solve problems which arise rather than
                                                       change the policy, which would be confusing and undermine investment by businesses.

                                                       The number of natural gas vehicles in the world has more than doubled since 2004 and there are now more
                                                       than 9.1m on the road, including cars, heavy good vehicles and buses. In Germany, CNG-generated vehicles
                                                       are expected to increase to two million units of motor-transport by the year 2020. There are currently 90 CNG
                                                       filling stations available to the public in Sweden, with another 70-80 CNG filling stations are under construction
                                                       or in a late stage of planning. New CNG models are being introduced which offer higher performance engines,
                                                       improved range and further carbon emission reductions. Government could provide fiscal incentives and
                                                       financial support for CNG vehicles and filling stations, and promote the conversion of local government
                                                       vehicles and buses.

                                                       Sales of Electric Vehicles (EVs), Hybrid Electric Vehicles (HEVs) and Plug-in Hybrid Electric Vehicles (PHEVs)
                                                       are still low. Last year, EVs and HEVs accounted for less than 1% of the total. Just 179 electric passenger
                                                       cars were sold in the UK in the last 12 months. EVs and HEVs are currently available and all the major car
                                                       manufacturers are currently working on PHEV models. There are still significant challenges. The latest reports
                                                       suggest that GM‟s PHEV Volt, which should be available in 2011, may cost twice as much as the equivalent
                                                       petrol car and may not be commercially viable. First Group has recently cancelled an order for 10 electric and
                                                       diesel-powered buses for Glasgow and Manchester as a result of concerns over the 50% higher purchase
                                                       price and running costs, and doubts that they will save the anticipated 30% in fuels costs. Bosch says for EVs
                                                       to become universally popular there is a need for a threefold increase in energy density and a reduction of
                                                       two-thirds in the price of batteries. However, progress is being made. The popularity of EVs and HEVs is
                                                       growing. The Energy Technologies Institute and ScottishPower have announced plans to develop and
                                                       implement plans for the installation of re-charging points in Glasgow from 2011, and Glasgow City Council,
                                                       Allied Vehicles, Axeon Holdings and the University of Strathclyde have been picked by the Technology
                                                       Strategy Board to receive £1.8m to trial EVs in the city over the next two years. This pilot will accelerate
                                                       technological development, help encourage the take up of alternative fuel vehicles and identify and resolve
                                                       issues that may arise in the production and use of this type of vehicle in a daily-use environment. The capacity
                                                       of EV batteries is expected to improve by 8% per year and to double in a decade.

                                                       The King Review identified EVs as the lowest carbon emissions route to clean transportation. This was true for
                                                       every potential scenario for the electricity mix. Even if their power comes from coal-fired power stations, the
                                                       overall emissions produced by EVs could be half of today‟s combustion engine cars. However, SCDI‟s study
                                                       The Future of Electricity Generation in Scotland found that Scotland is on course to generate a high level of
                                                       power from renewable sources of over 50% by 2020. SCDI therefore believes that EVs will be first to be
                                                       influential in reducing GHG emissions from the transport sector, especially if the growth in biofuels has to slow,
                                                       and make an even more significant contribution post-2020.The influence of EVs can be accelerated by
                                                       converting Light Goods Vehicles (LGVs). These constitute the majority of the public sector fleet and are
                                                       forecast to generate rising GHG emissions in contrast with other road transport vehicles. Axeon Holdings has
                                                       calculated that the introduction of 5000 electric LGVs would result in a reduction of carbon emissions of 43,585
                                                       tons per year in Scotland. Research for Mitigating Transport‟s Climate Change Input in Scotland suggests that
                                                       if the electricity for EVs was generated from lower carbon energy sources (producing half of the level of CO2
                                                       per KWh assumed in the main tests), the abatement potential would actually slightly reduce by 2%. This is
                                                       said to reflect that more of the abatement potential in the main scenario test is derived from reducing travel by
                                                       EVs than is derived from increasing the proportion of travel undertaken by EVs. However, lower carbon
                                                       electricity generation would increase the abatement potential of the national measures, reducing the size of
                                                       the gap to be met by devolved action. Greater abatement is projected from 2030 onwards.
 Question 2: Which low carbon technologies and fuels   There is no single, simple solution to the global energy challenge. In the transport sector, the UK Climate
 do you believe will ultimately have the greatest      Change Committee and King Review have both suggested that EVs could feasibly be standard by 2050.
 emissions abatement impact? Why?                      However, in SCDI‟s view, it is probable that there will be a diverse range of fuel and vehicle options, with the
                                                       preferred set of options varying by market. As a result, cars in the future will be more mission-specific than all
                                                       purpose. All these options will be needed and all will have a place in addressing the challenge of sustainable
                                                       mobility.

                                                       The consultation is weak in its discussion of the potential of hydrogen. Hydrogen fuel cell cars are presently
                                                       unproven and too costly for the mass market, with commercial production years away, hydrogen is currently
                                                       commonly produced from fossil fuels, overall carbon emissions may be higher than from a conventional
                                                       engine, and the development of a hydrogen grid would be very expensive, although storage may make this
                                                       less critical. However, hydrogen fuel cell cars are being developed and the technology has huge potential.
                                                       Converting surplus or off-peak green electricity into hydrogen fuel for transport is completely carbon neutral
                                                       and 1 MW wind turbine could produce enough hydrogen to power over 150 cars per year. With integrated
                                                       production, the price of the fuel can also be controlled. While SCDI is not convinced that they will make a
                                                       significant contribution to the 2020 GHG emissions target, but, in light of the longer term potential, government
                                                       should support their development with financial support and the procurement of hydrogen fuel cell public
                                                       transport and fleet vehicles.

                                                       One of the biggest obstacles is the lack of hydrogen fuelling stations. As part of the Energetica project, a
                                                       hydrogen corridor is planned between Aberdeen and Peterhead, with hydrogen fuelling stations at Bridge of
                                                       Don, Ellon and Peterhead, and it is proposed to extend this corridor to Inverness via Findhorn in Moray. This
                                                       highway will employ a diversity of renewable energy solutions in different locations with hydrogen refueling
                                                       stations placed at strategic locations along the route to service a range of users including public transport
                                                       providers, local authority vehicles, Royal Mail vans and ultimately private car users. In the proposals, this first
                                                       phase would then be extended south down the east coast, west to East Kilbride and Glasgow and north to the
                                                       Western and Northern isles. One of the applications selected for the use of hydrogen produced and stored at




                                                                          81
                                                        the Hedridean Hydrogen Park is a fleet of hydrogen vehicles and a fuelling station has been installed. CO2
                                                        emissions of 6.5 tonnes will be saved per year. The roll-out of infrastructure for these corridors, such as
                                                        electrolyser plants and hydrogen filling stations, could be offered financial support and tax allowances.

                                                        Biomethane vehicles are being produced in increasingly large numbers and it has by far the highest fuel yield
                                                        of any biofuel as a diesel equivalent. There is sufficient organic waste in Scotland to produce 3tWh of
                                                        biomethane per annum, which, if it was all used as a transport fuel, would provide 5.5% of Scotland‟s transport
                                                        energy from renewables by 2020. Financial support for biomethane and financial support and tax allowances
                                                        for Anaerobic Digestion plants would be required. The Scottish Government could also encourage local
                                                        authorities to divert organic waste to Anaerobic Digestion, and put pressure on the Department for Energy and
                                                        Climate Change to set a firm date for when biomethane can be injected into the grid and for fiscal incentives. It
                                                        is estimated that biomethane would require financial support of 4p/kWh to be comparable to natural gas.

                                                        SCDI would like further support for R&D of second and third generation biofuels, especially non-crop based
                                                        biofuels. Growing and processing of these requires extracting exactly the same amount of carbon from the
                                                        atmosphere that the biofuel emits. While marine biomass is unlikely to make a significant contribution in the
                                                        period to 2020, Scotland has a good resource and is at the forefront of research. The Scottish Association for
                                                        Marine Science (SAMS) is investigating the potential and practicality of using micro- and macroalgae, and the
                                                        possibility that the excess electricity which will eventually be generated from marine renewables in the
                                                        Pentland Firth could be used to produce renewable fuel from micro-algae. SAMS is committed to considering
                                                        the potential economic and environmental impacts of these fuels at the same time, which is important.
                                                        Another possibility is hybrid vehicles which use compressed air power instead of electricity. SCDI understands
                                                        that these would not require serious redesigns of vehicles because every car already has a makeshift air
                                                        compressor in the form of the engine itself. Building a pneumatic car would thus be relatively cheap. It has
                                                        been claimed that these vehicles have the potential to reduce fuel consumption by 32% and could offer 80% of
                                                        fuel savings of a HEV and at a lower price. It is also important to consider options for public transport. The
                                                        development of the trams network in Edinburgh will, with the growing generation of renewable energy, reduce
                                                        GHG emissions. Norway is currently allowing hydrogen-powered engines on ferry vessels as part of a joint fuel
                                                        system. Hybrid or hydrogen-fuelled trains may become an option for rural and local rail lines in Scotland where
                                                        electrification cannot be economically justified. Personal Rapid Transit systems - driverless four-seater pods
                                                        which run on rails powered by electricity rather than fossil fuels – could also prove a cost-effective way of
                                                        improving public transport.
Question 3: What timescales do you believe are          EV and HEV vehicles are available. PHEVs and are probably 3 to 5 years away. All the major car
feasible for the development of specific low carbon     manufacturers are currently working on PHEV models.
technologies and fuels? Are there any important
intermediate milestones within these timescales?
Question 4: What timescales do you believe are the      The Society of Motor Manufacturers and Traders do not expect that EVs will be mass-market products by
feasible for the uptake of specific low carbon          2015-20. However, the Renault-Nissan Alliance thinks 10% of new cars bought in 2020 will be EVs and a
technologies and fuels? Are there any important         report by the IDTechEx consultancy says a third of the cars made in 2025 will be electrically powered.
intermediate milestones within these timescales?
                                                        The UK Government has announced £250m to offset the premium on the expected higher purchase prices of
                                                        EVs and PHEVs as they become available in the next 3 to 5 years which will improve their viability. The
                                                        subsidy to be offered is expected to be between £2000 and £5000 per vehicle. In addition, up to £20m will be
                                                        available to develop an electric vehicle charging infrastructure framework.

                                                        An important milestone will be the EU requirement for reductions in CO2 for light commercial vehicles, which
                                                        will be 175g/km by 2012-15 and 160g/km by 2015. The latter is likely to be very challenging and may increase
                                                        conventional fuel vehicle costs by around 16% to 18%. This may lead to increased uptake of EVs, HEVs and
                                                        PHEVs, if they are a more commercially competitive option by 2015.
Question 5: Are there other barriers to the             Barriers to development of EVs, HEVs and PHEVs include battery cost, durability and disposal. Petrol and
development of such fuels and technologies that are     diesel engines have an energy intensity up to 50 times that of current lithium ion batteries. There is still major
not mentioned in this document? If so, what are         uncertainty about the costs per vehicle. For vans, the difference could be as high as £35k per vehicle and for
they?                                                   cars up to £10k. Ford has said that the industry should move towards a common standard of battery packs in
                                                        order to cut costs. This could support another proposal which is for EV service points where batteries may be
                                                        swapped.
Question 6: Are there other barriers to the uptake of    Barriers to the widespread uptake of such vehicles in the UK are:
such fuels and technologies that are not mentioned      • Cost
in this document? If so, what are they?                 • Proof of reliability and durability – Studies show that drivers currently do not have confidence in battery
                                                        powered cars for longer journeys.
                                                        • Lack of known residual values – See below• Lack of public charging infrastructure – See below
                                                        • Lack of local availability of servicing, maintenance and repair skills
                                                        • Need for three phase supply for most vehicle chargingAn SCDI member in the light commercial vehicle rental
                                                        business has highlighted that the biggest issue for them is the significant increase in holding costs for such
                                                        vehicles.

                                                        This is due almost exclusively to the lack of a premium in the resale market in line with the original purchase
                                                        price. These vehicles therefore have to carry a far higher depreciation charge during the 12-30 months they
                                                        are held. This makes them unattractive, as an option, for their 'regular' fleet users. Unless there is a general
                                                        'push' on all vehicle users, the demand for such vehicles from their public sector customers will inevitably
                                                        attract premium rates, when supply is available. In practice this will mean that they are able to provide long
                                                        term hires, albeit at a price, but will have much greater difficulty in meeting the short term needs of local public
                                                        sector users. In addition they are in the hands of the manufacturers regarding fuels which can be used.
                                                        Manufacturers decide the extent of any limits in level of warranty they will provide, and this in turn becomes
                                                        their base line e.g. they are reluctant to extend the levels of biofuel which can be used in light commercial
                                                        vehicles at present.SCDI has been informed that many fleet managers, for instance in local government, do
                                                        not have a full understanding of the opportunities. It is said that previous experiences with poorly performing
                                                        LPG vehicles are hindering interest in renewable technologies. Decisions on fleets are long-term
                                                        commitments, but it would appear that they are only considered when the next contracts are about to be
                                                        negotiated and that environmental sustainability has been a minor factor. There is a need to change attitudes
                                                        before these decisions are being considered. Insufficient progress has been made by Government in sorting
                                                        out the regulatory issues which would help uptake.

                                                        Clarity is required urgently on a range of points:
                                                        • How the electricity supply infrastructure will be developed and charged for e.g. public ownership/ public good
                                                        or competitive market
                                                        • Planning policy and a built environment for charging of private vehicles
                                                        • Smart metering requirements to get best value from current electricity generation
                                                        • Support for consumer confidence when purchasing EVs and PHEVs e.g. standards for safe electricity
                                                        connections to vehicles

                                                        Lack of information, misinformation, and a lack of incentives are also barriers to uptake. A programme of
                                                        education and inducements to attract consumers, perhaps linked to traffic management, are required. This
                                                        could include:
                                                        • LCVs could be integrated into local business travel plans and car clubs
                                                        • Public support for product development and reliability/ durability proving
                                                        • Allowing electric vehicles to drive in bus lanes, free parking for EVs and PHEVs in city and town centres
                                                        where parking is traditionally metered or ticketed, free parking for residents who own an EV or PHEV
                                                        • Exemption from congestion or road-user taxes
Question 7: Are there any negative social impacts       If EV and PHEV infrastructure displaces much of the conventional fuelling infrastructure in urban areas and yet
associated with either the development or uptake of     EVs and PHEVs remain more expensive than combustion engine vehicles, this would increase the cost of




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such technologies/fuels? If so, what are they?          mobility and potentially make it unaffordable for some people on lower incomes. If cars become more mission-
                                                        specific than all purpose in the future, those who cannot afford vehicles for all the journeys they want to make
                                                        may be socially limited.If fuel infrastructure is not rolled-out to rural areas, a two-tier transport network would
                                                        be created, with low carbon technologies in cities and towns, and conventional technologies and higher costs
                                                        in remote and island communities. This would also create negative economic and social impacts, for example
                                                        making it less attractive for tourists with low carbon vehicles to visit rural areas.

                                                        The environmental impacts also have to be weighted up. Rigorous analysis is required of the whole-life
                                                        environmental costs of HEV technology in comparison with the fuel efficient internal combustion engine cars in
                                                        development. The evidence is disputed. At present, conventional vehicles have the advantage of more shared
                                                        parts, greater economies of scale, production closer to the point-of-sale and longer lives. Some studies claim
                                                        that established technologies use much less energy in manufacture, transport, replacement and disposal,
                                                        making the environmental costs lower than HEV over the whole life-cycle. Zero emission vehicles are actually
                                                        said, at present, to generate the equivalent of 80g of carbon per 100 kilometres, not much better than the most
                                                        efficient small diesel engines. The evidence is also disputed on biofuels. Friends of the Earth say biofuels
                                                        could lead to twice the carbon emissions of the fossil fuels they replace – 1.3m tones of CO2 extra – due to
                                                        cutting down on forests for food production which has been displaced for ethanol or biodiesel crops. However,
                                                        the industry says supporters that it has been demonstrated that biofuels can come from sustainable sources.
Question 8: What, if any, technical challenges would    HEVs do not place any demand on the grid. This technology is most suitable for buses, in which it can reduce
the grid reinforcement upgrades be likely to present?   exhaust pollutants and greenhouse gases by 30%. These vehicles are produced in Falkirk for global export by
How might these be overcome?                            Alexander Dennis.

                                                        Axeon Holdings has calculated that the introduction of 5000 electric LGVs increase electricity demand by
                                                        29,190 mWh (or 54,987mWh for heavier box vans). The roll-out of EVs will probably not cause electricity
                                                        supply problems in the short term. Early adopters like LGVs can be charged overnight which would result in no
                                                        significant extra demand on the grid and, indeed, smooth demand.

                                                        If 100% of Scottish cars were full EVs it would require an additional 5TWh of electrical energy per annum
                                                        (equivalent to approximately 15% of projected Scottish demand by 2020). If the uptake of EVs is more rapid
                                                        than expected, flexible smart metering and new tariffs, which encourage charging overnight or when
                                                        renewables output is at peak production, could be needed to make efficient use of electricity and avoid
                                                        overloading the grid, especially if PHEVs prove popular following their introduction. Local grid reinforcement
                                                        may be required.

                                                        Ways would need to be found to provide on-street infrastructure for garage-less owners. While charging points
                                                        at supermarkets and offices could address the lack of them in some areas, they would use more expensive
                                                        daytime electricity.

                                                        Some of these challenges can be overcome by investing in demand-side measures which reduce the reliance
                                                        on technology to deliver GHG emission reductions and offsets the increased demand for grid reinforcement
                                                        upgrades.
Question 9: Who would fund any grid upgrades?           Grid upgrades in remote and island areas will be of above average cost. Given their economic and social
And, how might these costs be recovered?                fragility and unlikelihood that the market will deliver, this suggests that cost recovery will require special case
                                                        dispensation or subsidy.
Question 10: Do any of the technologies present any     The extent of the challenge to island communities and sparsely populated rural areas depends on whether low
specific challenges or opportunities to island          carbon vehicle technologies remain aimed at journeys in or between urban areas or they are developed to
communities and sparsely populated rural areas in       increase their range and endurance, and also on the creation of local or regional fuel production.Even with a
Scotland? If so, how might these challenges by          phased roll-out of these vehicles, the fossil fuel fleet will take many years to become obsolete and 4 wheel
addressed, and by whom?                                 drive, off-road, load-carrying vehicles and rural filling stations will still be needed. But as volumes fall, this will
                                                        put more pressure on the viability of these filling stations, and may result in fuel deserts.

                                                        These pressures will be further increased by the advent of bioethanol as a petrol replacement which will add
                                                        real costs to them and further put into question some of their viability. A report by Experian for HITRANS, the
                                                        regional transport partnership for the Highlands and Islands, has found that the increased use of biogasoline in
                                                        conventional petrol as a result of the Renewable Transport Fuel Obligation may have unintended
                                                        consequences in the Highlands and Islands. INEOS has been due to end production of conventional gasoline
                                                        at the Grangemouth refinery once its new biogasoline facility is completed. Due to its character, biogasoline
                                                        cannot be shipped north from Grangemouth because the existing marine vessels are unable to handle it. Nor
                                                        can it be stored in forecourt tanks at petrol stations without modifications costing up to £3,000, which is outwith
                                                        the resources of smaller operators. It is also likely that it will be too expensive to construct blending plants on
                                                        the islands or even in the Highlands. A new distribution network would therefore be needed and in
                                                        consequence a “green” policy would result in significantly increased carbon emissions from Grangemouth-
                                                        based tankers travelling around the Highlands and Islands, with implications for security of supply and
                                                        congestion on the roads. The region could, uniquely in the UK, also face much higher costs for fuel. The
                                                        Gallagher Review has recommended that the introduction of biogasoline is delayed. Before it is introduced,
                                                        there is a need to ensure that the infrastructure is put in place in the Highlands and Islands.

                                                        The Scottish and UK Governments, and the fuel supply industry, must find a workable solution to the issues
                                                        surrounding the introduction of biogasoline in the region before the national introduction of biogasoline, to
                                                        remove uncertainty for the industry and consumers, and provide sufficient time for industry to make the
                                                        investments required to ensure continuity of supply.EVs are ideal for urban driving, but even with advances in
                                                        technology, it‟s hard to see them as an ideal solution in the Highlands and Islands due to the geography and
                                                        travel distances involved. On the other hand, Scotland‟s island authorities are developing major onshore and
                                                        offshore renewable electricity projects and until such a point as subsea cables are constructed to the mainland
                                                        will have excess capacity for their own demands. Assuming that they are not taken to the Mainland, given the
                                                        confines of the island, EVs may not range as far. It may, therefore, be worth testing charging infrastructure
                                                        there, for example on Lewis.There are other opportunities for island communities and sparsely populated rural
                                                        areas. As previously mentioned, Comhairle nan Eiliean Siar‟s H2 SEED project will install an electrolyser in
                                                        the Creed Waste Management facility to produce hydrogen from biogas. This received a £250,000 grant from
                                                        the Hydrogen & Fuel Cells Support Scheme which provided £1m between seven projects to deploy and
                                                        demonstrate renewable hydrogen and fuel cell technology.
Question 11: Do you think that having a twin            On current trends and without specific incentives, Scotland is unlikely to reach even 4.5% of transport fuel
approach for the public sector and other users is       from renewable energy and it will lag well behind the rest of the UK. Speeding up deployment is therefore a
appropriate? If so, why? If not, why not?               key challenge. The uncertain oil price, recession and increasing cost of finance, have seriously affected
                                                        technology companies and the economics of investment in renewable transport fuel. In view of the economic
                                                        and climate change policy objectives, government intervention is required. Risk and reward will need to be
                                                        shared with the private sector to provide a more conducive climate for low carbon transport.

                                                        In Mitigating Transport‟s Climate Change Input in Scotland, an Ambitious Scenario is put forward which
                                                        assumes that Scotland goes beyond UK/ EU plans. The policy consists of a total of £5m made available to the
                                                        Scottish public sector to offset the additional costs of purchasing low carbon vehicles. For private vehicles,
                                                        £100m will be made available to allow grants of £5000 to private motorists purchasing low carbon vehicles.
                                                        The combination of initiatives has the effect of accelerating the rate at which the fleet of cars and vans in
                                                        Scotland changes beyond that envisaged by the Climate Change Committee in their extended ambition
                                                        scenario by 2 years from 2015 for cars and 3 years for vans.

                                                        SCDI has been informed that, at present, some large fleet managers are purchasing EVs faster than the public
                                                        sector in an attempt to reduce their carbon footprints. SCDI would agree that the public sector is likely to have
                                                        to take more of a lead, especially as EU legislation will oblige local authorities and contracting entities to
                                                        consider lifetime vehicle and emissions costs in procurement practices. The Climate Change (Scotland) Act




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                                                          sets tough targets for all public bodies. Local government can play a major role in promoting the use of zero-
                                                          emission electric vehicles, by adopting such vehicles for their own fleets. Such fleets, if powered by renewable
                                                          energy, could significantly reduce regional carbon emissions. However, as previously mentioned, in order that
                                                          LGV rental businesses can reduce their rates for and increase the availability of LCVs, this will have to be part
                                                          of a general 'push' on all vehicle users, which increases LCVs‟ resale prices.
Question 12: If so, should targets relate to the uptake    A total emissions target across the fleets would create a level playing field for all the technology option which
of low carbon vehicles (either as a percentage of the     allows them to compete fairly in the market. Any targets would need to be progressive, recognise the greater
fleet or an absolute number), or a reduction in total     challenges in rural areas and not get too far ahead of the development stage and costs of LCVs.
emissions across the fleets or another format of
target? Why?
Question 13: If we follow a target relating to the        By 2020, it should be possible for 95% of purchases for Scotland‟s public sector fleet to be LCVs. For
public sector uptake of LCVs, what percentage of the      example, the public sector bus fleet is predominately minibuses and it is possible for this fleet to entirely
fleet should be LCVs by 2020? Please give reasons         consist of LCVs by 2020. However, LCV technologies for HGVs are unlikely to be made available by 2020.
for your answer.
                                                          It is important that all public bodies with fleets take part in programmes, albeit the different opportunities and
                                                          challenges they face must be taken into account. Programmes should also be introduced without unnecessary
                                                          delays. There is a risk that programmes which are restricted to only some public bodies or incentives which
                                                          are announced for some point in the future encourage public bodies which are not immediately involved to
                                                          delay LCV investment decisions.
Question 14: If we follow a target relating to the        Progress needs to be made across all road users. SCDI understands that for cars and LGVs it would feasible
uptake of LCVs across all road users, what                to set targets as CO2 data on new vehicles is available and LCVs are available in reasonable numbers.
percentage of all new vehicles should be LCVs by          However, for large commercial vehicles it would not as low carbon technologies are in their infancy.
2020? Please give reasons for your answer.
                                                          While a Scottish target would be feasible, SCDI believes that a UK or European target would be more
                                                          appropriate. Consistency would help manufacturers and the private sector support the uptake of LCVs, and
                                                          ensure that businesses based in Scotland do not face higher costs which make them less competitive. The
                                                          Scottish Government should, therefore, seek to influence UK and EU policies.
Question 15: Are there any vehicle categories that        It has been suggested to SCDI that specialist vehicles which have a replacement lifecycle in excess of 10
should be excluded from the public sector target? If      years, like gritters, should be excluded from the target.
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        This approach of expanding the market through public sector procurement is endorsed at EU and UK levels.
than traditional vehicles (albeit with a smaller          The EU Energy Services Directive and forthcoming Cleaner and More Efficient Vehicles Directive will require
discrepancy between lifecycle costs) do you               public authorities and certain public transport providers to take into account energy efficiency and
consider it to be efficient use of public resources to    environmental impacts when purchasing road transport vehicles. In the UK Low Carbon Transport Innovation
devote a greater short-term budget towards the            Strategy, the UK Government announced funding of an initial £20m to develop a new programme of financial
purchase of LCVs? If so, why? If not, why not?            support for the public procurement of lower carbon vehicles, especially vans.

                                                          Procurement capitalises on the substantial buying power of the public sector. By establishing a market which
                                                          is able to absorb the initially higher costs of new carbon vehicle technology, it can contribute to the expansion
                                                          of the market through the economies of scale needed to reduce overall costs. In this case, it is necessary for
                                                          the public sector to stimulate private sector investment in LCVs and address market failure to meet
                                                          government economic and GHG targets.

                                                          Building critical mass would accelerate adoption by enabling the supply chain to gain scale, prove reliability,
                                                          durability and reduce costs. It would encourage investment by infrastructure providers in charging stations. It
                                                          would also enable fleet and private vehicle operators to buy with certainty of being able to operate vehicles,
                                                          charge vehicles, get replacements and have expectation of residual value for older vehicles with new batteries
                                                          or reduced ranges but cheaper costs.

                                                          Public sector spending is likely to be squeezed over the next decade and while LCV costs remain higher it will
                                                          need to be adequately resourced for this purpose.
Question 17: Are there any opportunities or barriers      SCDI has previously highlighted evidence from a light commercial vehicle rental business that unless there is
to public sector procurement of LCVs that are not         a general 'push' on all vehicle users, the demand for LCVs from their public sector customers will inevitably
mentioned in this document? If so, what are they?         attract premium rates and it will remain difficult to meet the short term needs of local public sector users.
Question 18: What are the individual roles of different    In Mitigating Transport‟s Climate Change Input in Scotland it is assumed that larger towns with more than
groups and organisations in ensuring the provision        40,000 people will be covered by the market as electricity companies and motor manufacturers are
of any infrastructure required for low carbon             incentivised to invest in the infrastructure by national and EU carbon reduction commitments. Competition in
vehicles?                                                 the wider private sector to attract early adopters of LCVs to their businesses could also incentivise the
                                                          provision of infrastructure at supermarkets, shopping centres, motorway services, car parks, offices, leisure
                                                          destinations and hotels. Major transport interchanges such as airports and stations are also likely sites.
                                                          Overnight charging of 6-10 hours will be suitable for most EVs, but developments in battery technology should
                                                          lead to EVs being able to charge more quickly.

                                                          However, Government will have a critical role in ensuring the provision of a nationwide infrastructure for low
                                                          carbon vehicles. Mitigating Transport‟s Climate Change Input in Scotland suggests that Scottish Government
                                                          support should be initially focused on recharging points in areas in small to medium-sized towns, of 25,000 to
                                                          40,000 people, and recommends that households living in flats or accommodation rented from the local
                                                          authority require priority assistance as they are the least likely to have domestic charging points. Under its
                                                          ambitious scenario, 50% of these towns are covered which has the effect of increasing the projected number
                                                          of EVs or PHEVs by one third from 12% to 16% by 2022. Scottish Government support for this infrastructure
                                                          should be provided in consultation with private sector providers, the UK and European governments and
                                                          standards agencies, especially over the standardisation of charging points. Charging infrastructure for larger
                                                          vehicles is readily available in commercial and council depots, but a grant or rebate scheme could be offered
                                                          for organisations buying more than a certain number of vehicles to pay for their recharging station.For
                                                          domestic vehicles, especially in small to medium-sized towns, there could be a grant or rebate scheme for
                                                          purpose built charging points on streets where requested, and publicly-subsidised charging points on streets
                                                          and in car parks.

                                                          The Scottish and local government could also introduce more flexible planning rules for the installation of
                                                          street furniture, including charging points. Local authorities could grant public land for the development of
                                                          charging stations and require charging stations on new roads, and new retail or leisure developments.Nissan
                                                          is working on a programme where people lease the cars or buy the cars and lease the batteries. If the
                                                          ownership of the battery is separated from the ownership of the car the battery becomes a running cost like
                                                          petrol and the price of the car falls. As the consultation notes, US-company Better Place has been scouring
                                                          the world for car markets which are “islands” and offering to fit them with networks of car-charging and battery
                                                          swapping stations that will use robots to exchange exhausted batteries for fully charged ones in seconds.
                                                          Israel and Denmark are among the countries which have already signed up.

                                                          However, there are difficulties in adopting these approaches. As in the rest of Europe, consumer preference in
                                                          Scotland is to own rather than lease their cars. The practicality of “hot-swapping” of batteries is questionable
                                                          given the differences in EVs and batteries, with concerns over the costs, processes and safety of the
                                                          technology. Better Place is also tied to a small number of specific vehicle manufacturers.
Question 19: Are there other supply side/capacity         There is a lack of servicing, maintenance and repair skills and facilities.
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of     A 20 year vision for the automotive industry published earlier this year by the New Automotive Innovation and
an indigenous low carbon vehicle industry in              Growth Team recommended that Government and the industry agree technology roadmaps for low carbon
Scotland? If so, what are they and how might they be      vehicles and fuels.It recommendations were:




                                                                             84
overcome?                                               • Establish a joint industry/government Automotive Council to develop, guide and implement a long term
                                                        strategic framework for the industry; and
                                                        • Focus the UK R&D agenda around a new industry-consensus technology roadmap, and as part of this
                                                        establish 'Test Bed UK' a bold, large scale pilot to develop, demonstrate and build the new low-carbon
                                                        personal transportation system including its infrastructure
                                                        • Creating a transformed business environment in the UK to provide a more compelling investment proposition
                                                        versus other countries e.g. attract more Tier 1 suppliers to the UK which supply sub-systems to car-makers.•
                                                        Agreeing on the technology roadmaps for low carbon vehicles and fuels and exploiting opportunities to
                                                        promote the UK as a strong candidate to develop these and other technologies; and
                                                         • Developing a stronger and more competitive supply chain through joint research on focussed areas, skills
                                                        development and the enhancement and brokering of collaboration opportunities for achieving effective scale in
                                                        R&D and core technology components.

                                                        Scotland has the capabilities to develop a competitive LCV industry, with power utilities and public transport
                                                        operators, specialist vehicle manufacturers in Allied Vehicles and Alexander Dennis, and a battery
                                                        manufacturer in Axeon Holdings. It is essential that this manufacturing expertise is retained in Scotland,
                                                        especially with the US now offering substantial grant and local procurement incentives to relocate. Batteries
                                                        are competing with a well-established engine technology and technology developments are expensive.
                                                        Government therefore needs to continue supporting R&D from fundamental research to product development.
Question 21: Should Scotland’s industry focus on        Scotland is well-positioned to take commercial advantage from the move to EVs. Allied Vehicles is currently
particular vehicle types? If so, what are they and      developing a range of LGVs from 1.8 tonne to 4.5 tonne. Each of these will have passenger equivalents.
why? If not, why not?                                   Investment at this stage will maintain Scotland‟s EV technology and production lead and, as the market grows,
                                                        those countries which have a competitive LCV industry will be able to take advantage. Scotland has an ideal
                                                        opportunity to showcase internationally its low carbon vehicle technologies in the vehicle fleets for the
                                                        Commonwealth Games.
Question 22: Are there gaps in the supply chain? If     The demand for the expertise of electronics and power-storage companies is likely to grow, some of which
so, what are they and how might these be overcome?      have not previously supplied the car industry.
Question 23: Do we have the required skills base for    Even as a nascent technology, the Scottish LCV industry has the potential to create hundreds of jobs. If it is
the development of this market? If not, where are the   successful and expands with the market, its need and employment opportunities for automative-related
gaps?                                                   engineering skills will grow. The Scottish Government should consider an initiative to enhance these skills.
Question 24: How could the various stakeholders         Government, industry and fleet managers can collaborate on a programme to improve information and
collaborate to stimulate the development and uptake     encouraging vehicle buyers to consider their options.
of LCVs?
                                                        Collaboration between power generators and distributors, and vehicle and battery manufacturers on smart grid
                                                        technology development should be supported and incentivised. This would enable Scotland to take the lead in
                                                        developing and introducing standards that could be licensed and sold globally.




                                                                          85
R40 - Scottish Engineering


 RESPONDENT INFORMATION DETAILS
 Name:                                                 Susan Andrews
 Organisation:                                         Scottish Engineering
 Address:                                              105 West George Street, Glasgow
 Postcode:                                             G2 1QL
 Email:
 Telephone Number:                                     0141 221 3181
 Responding as:                                        On behalf of a group or organisation
 Individual Permission:                                Not Supplied
 Confidentiality:                                      Not Supplied
 Group or Organisation:                                Yes
 Share Response Permission:                            Yes
 Question 1: Which low carbon technologies and fuels   Cars, Vans, Light Goods Vehicles (LGV) Electric vans produced by Allied are available under the
 do you envisage will be first to be influential in    Department for Transport‟s Low Carbon Vehicle Public Procurement Programme and Allied are also leading
 reducing GHG emissions from the transport sector?     a Technology Strategy Board Project to demonstrate 40 electric cars in Glasgow. The technology that has
 Why?                                                  the largest potential to make an impact in GHG emissions in the short term is the battery electric vehicle
                                                       (EV). The technology is available now and with the implementation of renewable and low carbon electricity
                                                       generation is the cleanest technology available. In particular at point of exhaust, electric vehicles have no
                                                       emissions at all. Other technologies like efficient diesels and hybrid electric vehicles (HEV) continue to emit
                                                       not only carbon but also particulates and other gases like Nitrous Oxide which are more damaging to the
                                                       environment. HGV‟s The technologies identified in the „King Review‟ suggest a fuel efficiency saving of 30%
                                                       in 5-10 years. These technologies are basically improvements to the Diesel internal combustion engine.
                                                       The simplest technologies to adopt quickly on a large scale are
                                                       · Increasing levels of biofuels.
                                                       · Stop / start
                                                       · Microhybrid then Mild , full and Plug- in

                                                       These can be applied relatively easily given
                                                       · the existing fuel distribution net work
                                                       · engine technology available
                                                       · They require little behavioural change in the short term for the user.
                                                       · They have a large multiplier effect as the incremental cost over current technology for the end user is zero
                                                       to very low, therefore promoting early and widespread adoption. Using a household analogy, biofuels are
                                                       the equivalent to low energy light bulbs rather than covering ones roof with PV cells.
                                                       · Use of biofuels is applicable to passenger cars both petrol and diesel as well through to the largest HGV‟s.

                                                       Other technologies, particularly battery technology, does not scale up well to heavier trucks requiring longer
                                                       ranges. This is particularly applicable in Local authority fleets where the consultation document lists 90% of
                                                       LA emissions are from HGV and LGV combined. (page 14 figure 3)
 Question 2: Which low carbon technologies and fuels   Cars, Vans, LGV‟s Short term Electric vehicles because the technology has sufficient energy density for
 do you believe will ultimately have the greatest      lighter vehicles with smaller ranges and load carrying capacity requirements. However a balanced energy
 emissions abatement impact? Why?                      policy including nuclear energy will be needed. Renewable sources of central power generation do not have
                                                       sufficient reliability to meet the needs of zero carbon electricity generation. A behaviour shift of the user is
                                                       possible because even now electric/battery technology can meet the majority of journeys. For example short
                                                       travel to and from work, deliveries or shopping trips. This fits ideally with charge, drive, recharge, drive,
                                                       recharge timing of current vehicles. Longer Term Biogas from AD plants and hydrogen fuel-cell technology
                                                       will have the greatest impact in the longer term. HGV‟s Biodiesel for heavier trucks and buses. Battery
                                                       technology is so far away from being able to produce sufficient energy density for adequate range and
                                                       carrying capacity that it may never achieve the required levels. Refer to the Institute of Mechanical
                                                       Engineers papers on Low Carbon vehicles, ISBN – 978-1-84334-560-2, page 91, figure 1 showing the
                                                       relative energy densities of batteries to other liquid fuels. Today the best battery technologies are less than
                                                       1/30th the energy density of diesel. Even taking the higher conversion efficiency of battery power circa 90%
                                                       into useful work to propel the vehicle compare to diesel (30%) still leaves batteries at a disadvantage in an
                                                       order of magnitude. Other fuels such as compressed natural gas, liquid hydrogen and compressed
                                                       hydrogen are at a similar disadvantage. Although intrinsically more energy dense that batteries, the likely
                                                       conversion efficiency in an internal combustion engine, or fuel cell demotes them to a similar level to
                                                       batteries.
 Question 3: What timescales do you believe are        Cars, Vans, LGV‟s The King Review of 2007 identified EV‟s as the lowest carbon emissions route to clean
 feasible for the development of specific low carbon   transportation even taking into account differing methods of electricity generation. EV‟s will offer a long term
 technologies and fuels? Are there any important       development path as new cell chemistries lead to higher energy density, reduced weight and faster
 intermediate milestones within these timescales?      charging.
                                                       HGV‟s
                                                       · Biofuels – 10% - available now
                                                       · Stop/start mild to full hybrids for cars available now
                                                       · Hydraulic regenerative braking for cars trucks and buses available now
                                                       · Stop/start for trucks – 2011
                                                       · Biogas from AD plants 2014
                                                       · Second generation parallel hybrids 2018
                                                       · Hydrogen fuel cells 2019
                                                       · Biofuels – 30-40 % - 2020
                                                       · Fully synthetic fuels – 2030
                                                       · Fuel cell 2025
 Question 4: What timescales do you believe are the    Cars, Vans, LGV‟s Electric vehicles are ideal for city driving with battery ranges of 100 to 180 km. Wide
 feasible for the uptake of specific low carbon        spread use of second car as a small electric run around – 2015 – requires behavioural change in end user
 technologies and fuels? Are there any important       and acceptance of adequate range and carrying capacity. This will be accelerated by fossil fuel pricing.
 intermediate milestones within these timescales?      HGV‟s
                                                        · Biofuels – 10% - available now
                                                       · Stop/start mild to full hybrids for cars available now
                                                        · Hydraulic regenerative braking for cars trucks and buses widespread adoption in stop start urban
                                                       operations – 2015. Not applicable to long haul
                                                       · Stop/start for trucks – 2015 for wide spread adoption
                                                       · Biogas from AD plants 2014
                                                       · Second generation parallel hybrids 2025
                                                       · Hydrogen fuel cells 2019
                                                       · Biofuels – 30-40 % - 2020 adoption 2 to 3 years after available
                                                       · Fully synthetic fuels – 2030 adoption 2 to 3 years after available
                                                       · Fuel cell 2050 Public bodies should adopt these fuels at the first availability.

                                                       This would provide a stimulus to the development of the technology, plus retail points. If incentives to
                                                       purchase LCVs, were offered to commercial purchasers, it could lead to distortion of competition in a fragile
                                                       and fragmented logistics industry.
 Question 5: Are there other barriers to the           Cars, Vans, LGV‟s Vans or Light Goods Vehicles (LGV) are the majority of the public sector fleet and their
 development of such fuels and technologies that are   emissions are rising in contrast to other road transport vehicle types. Replacement EV‟s are available from a
 not mentioned in this document? If so, what are       number of sources including Allied Vehicles Ltd now. Moving these vehicles to electric drive systems would
 they?                                                 reduce CO2 emissions significantly. HGV‟s Underlying efficiency improvements in the internal combustion




                                                                          86
                                                          engine that would benefit fossil, biofuels and hydrogen fuels alike may be stifled by lack of investment due
                                                          to the economic downturn. Over investment and over emphasis on zero tank to wheel emissions may
                                                          promote economically unviable options unlikely to achieve widespread adoption. It will be better to save say
                                                          5% over 95% of users than say 50% from less than 1%.
Question 6: Are there other barriers to the uptake of     The fragmentation and low margins of the logistics industry, plus historic and enduring lack of collaboration,
such fuels and technologies that are not mentioned        even between „own account‟ operators. Lack of trust in Govt. long-term intentions (e.g. previous frequent
in this document? If so, what are they?                   changes to taxation policy; short-term incentives to purchase low carbon fuels.)

                                                          Lastly, the vehicle acquisition cycles of most commercial operators result in slow take-up, even when all
                                                          other factors are favourable. Consequently, the decision to adopt any particular technology must stack up
                                                          economically both in terms of total cost of ownership and initial capital outlay.
Question 7: Are there any negative social impacts         Competition for land for food use etc.
associated with either the development or uptake of
such technologies/fuels? If so, what are they?
Question 8: What, if any, technical challenges would      Government should increase the number of available charging points both 230v and 415v to give EV users
the grid reinforcement upgrades be likely to present?     confidence that they can plug in at their destination. Future development should be concentrated on fast or
How might these be overcome?                              rapid charging systems and infrastructure rather than hot swapping.
Question 9: Who would fund any grid upgrades?             Through the private sector providers, and recovered through amortisation across all users of the national
And, how might these costs be recovered?                  grid.
Question 10: Do any of the technologies present any       Electric vehicles EV‟s currently charge by connecting a charger to the Grid at either 230v (synchronous or
specific challenges or opportunities to island            single phase) or 415 v (asynchronous or three phase). 230v systems are typically available in homes and
communities and sparsely populated rural areas in         circuits providing up to 30 amps are available. 415v systems are typically found in industrial environments
Scotland? If so, how might these challenges by            and will charge vehicles at up to 9kw/hr. This means that charging on three phase will be up to twice as
addressed, and by whom?                                   quick as single phase. Developments in batteries will mean that EV‟s will be able to charge quicker by
                                                          accepting fast or rapid charges. These chargers may require a transformer but could result in charge times
                                                          of less than five minutes. They have the advantage of being able to be dispersed and readily available. Hot
                                                          swapping of batteries is not regarded as practical given the wide variation of electric vehicles and their
                                                          battery sizes, construction and composition. Hot swapping stations would put a huge centralised drain on
                                                          the grid rather than using the grid‟s ability to disperse power.

                                                          If so, how might these challenges by addressed, and by whom? Fortunately island and rural communities
                                                          are also typically rich in green electricity generating potential – wind and hydro for example. Coupling the
                                                          need for more, carbon neutral electricity generation in these areas with facilities and preferential rates for
                                                          electric vehicle charging as a benefit to offset the impact of these “in my back yard” may facilitate greater
                                                          uptake. For example, we put a wind turbine up, you get to charge your car for free. Power generating
                                                          companies can ultimately re-coup their investment across their whole operating area. Government needs to
                                                          look at decisions like the Beauly to Denny transmission line and prioritise them to avoid delays and missed
                                                          opportunities in the development of the low carbon technologies.
Question 11: Do you think that having a twin              Yes Electric Vehicles EV‟s have a ready available method for refuelling through the National Grid which
approach for the public sector and other users is         reaches to the vast majority of homes and businesses throughout the country.
appropriate? If so, why? If not, why not?
                                                          If so, why? As the consultation paper states, there is no point setting “targets over which we have no
                                                          significant influence”. There is the opportunity to influence the public sector.
Question 12: If so, should targets relate to the uptake   Total emissions across the fleet, (similar to the „cap and trade‟ CRC for energy usage).
of low carbon vehicles (either as a percentage of the
fleet or an absolute number), or a reduction in total     Why? Adopting total emissions reduction across the fleet gives the maximum flexibility in achieving the
emissions across the fleets or another format of          targets given the diversity of number and type in the fleet. Operators may choose to have fewer of the
target? Why?                                              current type of vehicles, or more low CO2 vehicles for the higher proportion of the fleet and retain current
                                                          technologies where appropriate. It is the outcome that is important rather than the way it is achieved. If the
                                                          targets relate to specific vehicle types or fuels (i.e. those originally defined as “LCV”), then there would be a
                                                          disincentive to development of technologies not foreseen in the legislation.
Question 13: If we follow a target relating to the        If a target for an overall reduction in fleet emissions was adopted then a target for vehicle uptake would not
public sector uptake of LCVs, what percentage of the      be required. However, it is not unreasonable to expect that a fair percentage of purchases for Scotland‟s
fleet should be LCVs by 2020? Please give reasons         public sector fleet should be low or zero emission vehicles by 2020. A variety of technology is available now.
for your answer.
Question 14: If we follow a target relating to the
uptake of LCVs across all road users, what
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        They would not need to be specifically excluded or included if a target for an overall reduction in fleet
should be excluded from the public sector target? If      emissions was adopted.
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        Electric vehicles At present EV‟s are significantly more expensive to purchase than ICE equivalents. e.g. a
than traditional vehicles (albeit with a smaller          £20,000 van would cost in the region of £50,000. This cost is distorted by the Battery which costs c.£20,000.
discrepancy between lifecycle costs) do you               These costs are expected to fall as vehicle numbers increase but are a significant hurdle for the uptake of
consider it to be efficient use of public resources to    these vehicles. The running costs of EV‟s are significantly lower than equivalent ICE vehicles with fuel
devote a greater short-term budget towards the            (electricity/diesel some 9-11.5p/km cheaper), no road fund licence and no congestion charges. HGV‟s
purchase of LCVs? If so, why? If not, why not?            Whole life cycle costs should be lower and suppliers should be able to demonstrate lower Total cost of
                                                          ownership over the life of the product before Local authorities should consider spending more in the short
                                                          term, they should not subsidise potentially ineffective technologies that do not demonstrate lower total cost
                                                          of ownership. It is up to central UK government to take the risk in funding emerging technologies to facilitate
                                                          their adoption in the market.
Question 17: Are there any opportunities or barriers      Electric vehicles UK Government support for electric vehicles has been mainly in the form of the Low
to public sector procurement of LCVs that are not         Carbon Vehicle Public Procurement Programme. This was announced in 2007 but and at the time of writing
mentioned in this document? If so, what are they?         has not put a vehicle on the road. There is a danger that programmes of this type which are restricted to a
                                                          small number of Government departments and local authorities could distort the market with non supported
                                                          departments and authorities putting off the investment decision.

                                                          Tender Process The adoption of a short term view in the tender process, and the over emphasis of
                                                          purchase price in the evaluation criteria. A much broader range of evaluation criteria is called for to support
                                                          the adoption of low CO2 technologies with the emphasis on lower total cost of ownership and low
                                                          embedded carbon at the point of manufacture and in delivery.
Question 18: What are the individual roles of different   Cars, Vans, LGV‟s The Technology Strategy Board has recently committed to a project (the Ultra Low
groups and organisations in ensuring the provision        Carbon Car Demonstrator Programme) across the UK. The Scottish consortium led by Allied and containing
of any infrastructure required for low carbon             Axeon, Scottish Power, Strathclyde University and Glasgow City Council will be putting 40 vehicles on
vehicles?                                                 Glasgow‟s streets for trial in 2010. HGV‟s There is a comment in the consultation document that “there may
                                                          be an expectation that the Freight Logistics industry will lead the development of [hydrogen fuel cell]
                                                          infrastructure” A member company of Scottish Engineering, a leading Freight Logistics company, is very
                                                          concerned that this is a misleading and dangerous statement. Where is the evidence to support this
                                                          assumption?
Question 19: Are there other supply side/capacity         Electric vehicles Allied Vehicles Ltd, Glasgow have committed to a programme of development of a range of
constraints impacting on LCV development and              light commercial vehicles from 1.8 tonne to 4.5 tonne. All of these vehicles have passenger car equivalents.
uptake? If so, what are they?                             These developments have been fully funded by Allied vehicles Ltd without specific support from Scottish or
                                                          UK governments. HGV‟s (non-electric) There are no test and verification houses such as Mira or Millbrook
                                                          that are experienced in and capable of the testing and verification of fuel consumption in Scotland. If
                                                          technologies are to be adopted they must demonstrate commercial viability and real savings. Rigorous
                                                          scientific testing to known standards NEDC and FTP-75 cycles is an essential tool in demonstrating the




                                                                             87
                                                        credibility of a particular technology. Without that credibility uptake will be patchy and subject to fads and
                                                        fashion with a high risk of not meeting the emissions reduction targets.
Question 20: Are there barriers to the development of   Electric vehicles Scotland with companies like Allied and Axeon is well positioned to take advantage and to
an indigenous low carbon vehicle industry in            create commercial advantage from the move to EV‟s. Initially as EV‟s are more niche market there could be
Scotland? If so, what are they and how might they be    hundreds of jobs created but as EV‟s become mainstream there is the opportunity for the economy that has
overcome?                                               invested in EV production to benefit significantly. HGV‟s (non-electric) There are no test and verification
                                                        houses such as Mira or Millbrook that are experienced in and capable of the testing and verification of fuel
                                                        consumption in Scotland. If technologies are to be adopted they must demonstrate commercial viability and
                                                        real savings. Rigorous scientific testing to known standards NEDC and FTP-75 cycles is an essential tool in
                                                        demonstrating the credibility of a particular technology. Without that credibility uptake will be patchy and
                                                        subject to fads and fashion with a high risk of not meeting the emissions reduction targets.
Question 21: Should Scotland’s industry focus on        Electric Vehicles Scotland is well placed to be at the forefront of electric vehicles benefiting not only the
particular vehicle types? If so, what are they and      environment but also the economy. The Scottish Government put in place support structures for public and
why? If not, why not?                                   private operators who wish to move in this direction. Scottish Government and its agencies should prioritise
                                                        support for development and job creation in these sectors. Support service tenders should include
                                                        requirements to utilise electric vehicles. HGV‟s One Particular vehicle type will not meet the requirements of
                                                        the freight/service transport sector. There is no one size fits all. For example, electric vehicles do not scale
                                                        up well to HGV‟s. Concentrating on one sector leaves significant development opportunity untapped.
Question 22: Are there gaps in the supply chain? If
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for    Not yet, gaps are with the manufacturers who are committed to the mass market i.e. Diesel Euro 5 and 6
the development of this market? If not, where are the   development.
gaps?
Question 24: How could the various stakeholders         Government organisations such as the Technology Strategy Board are key facilitators in the stimulation new
collaborate to stimulate the development and uptake     technology development and then in the transfer of information on viable technologies to targeted markets
of LCVs?                                                that would be required to support them in terms of supply chain and infrastructure. If the commercial case is
                                                        made for the adoption of the technology, it will go a long way in reducing the perception of risk. Seeing
                                                        lower risk that the technology is not a dead end will stimulate provision of the necessary support. Appendix
                                                        Acronyms EV – Electric vehicles ICE – Internal Combustion Engine LCV – Low Carbon vehicle Thanks
                                                        Scottish Engineering promotes the Scottish manufacturing engineering industry and its interests, in
                                                        Scotland, in the United Kingdom and Europe, whilst providing market leader high quality practical services
                                                        in all aspects of employment. Scottish Engineering is the major support and lobbying organisation for the
                                                        manufacturing engineering industry in Scotland. The present membership of Scottish Engineering
                                                        encompasses around 400 companies from throughout Scotland. Member companies include some of the
                                                        largest, together with many companies, which are smaller but also innovative and successful. They are
                                                        involved in all sectors of engineering and manufacturing across every geographic area of Scotland. Scottish
                                                        Engineering welcomes the opportunity to respond to this consultation on behalf of our member companies.
                                                        Thanks go specifically to Allied Vehicles, Glasgow Kuehne + Nagel, Milton Keynes and Bathgate Heil
                                                        Europe, Dalgety Bay




                                                                           88
R41 - Scottish Environmental Protection Agency


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Dave Gorman
 Organisation:                                             Scottish Environmental Protection Agency
 Address:
                                                           Scottish Environment Protection Agency, Corporate Office, Erskine Court, The Castle Business Park,

                                                           Stirling
 Postcode:                                                 FK9 4TR
 Email:
 Telephone Number:                                         01786 457700
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes

 Question 1: Which low carbon technologies and fuels       Substitute fuels that can be utilised with little or no engine modification are likely to be the first to have an
 do you envisage will be first to be influential in        impact due to their ease of use, indeed these are already being used. Hybrid and dual fuel vehicles are also
 reducing GHG emissions from the transport sector?         being taken up increasingly as they are well equipped to overcome initial supply location limitations. If
 Why?                                                      supported by the correct financial incentives and price drivers (i.e. if they are financially attractive) electric
                                                           cars will gather momentum, particularly in urban settings. These will be further enhanced once smart
                                                           meters and recharging points are more widespread.
 Question 2: Which low carbon technologies and fuels
 do you believe will ultimately have the greatest
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               Availability of finance in the current tight markets could slow investment take up, research and development.
 development of such fuels and technologies that are       Therefore dedicated support to ensure development of technology in this area would be useful
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     There is some way to go to fully convince the public and business of the attraction and benefits of LCVs;
 such fuels and technologies that are not mentioned        current information is piecemeal and difficult to compare and this is likely to make the public defer deciding.
 in this document? If so, what are they?                   Cognisance must be given to the development of a reliable supply chain as people will not be tempted by a
                                                           vehicle that can only be refuelled in a handful of places in Scotland. There is also a need for widespread
                                                           demonstration that LCVs are currently viable and will be supported in the future.
 Question 7: Are there any negative social impacts
 associated with either the development or uptake of
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would      Whilst SEPA has no expertise in this field, we understand that there may be issues of grid capacity,
 the grid reinforcement upgrades be likely to present?     particularly in remote areas. There is a need for demand side management to allow a user to ensure their
 How might these be overcome?                              LCV is ready for use. There may also be a need for grid reconfiguration and re-design to allow for suitable
                                                           flexibility. A long term view is essential, which takes into account the likely changes in electricity generation
                                                           and demand to minimise disruption and expense. Consideration must be given to environmental, landscape
                                                           and visibility concerns.
 Question 9: Who would fund any grid upgrades?             Grid infrastructure should be funded in the historic manner with the costs being recovered from the
 And, how might these costs be recovered?                  consumer. Perhaps government could find alternatives for such a nationally strategic outcome.
 Question 10: Do any of the technologies present any       Small island communities have the potential to become self sufficient in energy and surplus energy
 specific challenges or opportunities to island            (overnight) could be used to produce hydrogen or store energy for use in LCVs. Such a system would not
 communities and sparsely populated rural areas in         only leave interconnectors as a backup but open up the potential of cost recovery from over production.
 Scotland? If so, how might these challenges by            Care needs to be taken in land use decisions in order to preserve the natural environment of islands.
 addressed, and by whom?
 Question 11: Do you think that having a twin              Having the public sector lead by example is a quick win and will establish the necessary infrastructure that
 approach for the public sector and other users is         will ease wider public adoption, and would work as a clear demonstration that these technologies are viable
 appropriate? If so, why? If not, why not?                 and practical.
 Question 12: If so, should targets relate to the uptake   The driver behind LCVs is the reduction of GHG emissions and as such the appropriate target would be one
 of low carbon vehicles (either as a percentage of the     that looks at the overall reduction in total emissions. This should facilitate picking the low hanging fruit first
 fleet or an absolute number), or a reduction in total     and running cost savings can be used to reduce the financial burden of replacing and upgrading HGVs and
 emissions across the fleets or another format of          largest pieces of specialist kit.
 target? Why?
 Question 13: If we follow a target relating to the        SEPA is not in a position to recommend a precise uptake target, but it is essential that the target be
 public sector uptake of LCVs, what percentage of the      demanding, takes into consideration the overall reduction in total emissions and require significant
 fleet should be LCVs by 2020? Please give reasons         behaviour changes, as without this Scotland will not be able to meet the aspirations of the Climate Change
 for your answer.                                          (Scotland) Act.
 Question 14: If we follow a target relating to the
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        All vehicles should be included but the target should aim at maximum reduction in overall emissions and
 should be excluded from the public sector target? If      looked upon as delivering the BPEO solution.
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        Yes as the additional emissions savings have tremendous knock on effects. Much LCA does not consider
 than traditional vehicles (albeit with a smaller          running costs which will provide an additional benefit as many LCVs are fuel efficient and fuels themselves
 discrepancy between lifecycle costs) do you               are likely to be priced lower to encourage uptake.
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      Supply side issues: there may be limited availability of sufficient LCVs in the short term. It is also important
 to public sector procurement of LCVs that are not         to ensure that the requirement for “least cost” does not preclude the choice of LCV.
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different
 groups and organisations in ensuring the provision
 of any infrastructure required for low carbon
 vehicles?
 Question 19: Are there other supply side/capacity         Has full cognisance been taken of supply constraints to either procure new LCVs or to the skilled workforce
 constraints impacting on LCV development and              required to deliver modification of existing vehicles?
 uptake? If so, what are they?




                                                                               89
Question 20: Are there barriers to the development of
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders
collaborate to stimulate the development and uptake
of LCVs?
Additional information                                  SEPA welcomes the opportunity to respond to the Scottish Government‟s Consultation on Low Carbon
                                                        Vehicles (LCV). The contribution that transportation makes to global warming has long been recognised by
                                                        SEPA and this is clearly demonstrated in the recently released Environmental Clean Technologies Action
                                                        Plan* (developed with other strategic partners). I have attached a copy of the plan. It highlights Sustainable
                                                        Transport as one of the key areas of potential with anticipated growth of over 43% by 2014/15 making a
                                                        considerable impact on climate change. Transport will play a major part in meeting the challenge of an 80%
                                                        reduction in carbon emissions by 2050. The ECT action plan emphasises the contribution that electricity,
                                                        hydrogen and biofuels can make to achieving those targets.

                                                        It is worth mentioning that although LCVs are welcome it is better to reduce the need and frequency of
                                                        journeys, and secondly to maximise the use of public transport. It is important that LCVs are not seen as a
                                                        solution without wider behaviour changes. Scotland currently imports significant proportions of
                                                        biomass/biofuels and increasing demand would have serious implications for the growth, production and
                                                        importing of biofuels. There is a concern that this could lead to more primary biomass displacing other land
                                                        uses and increasing the pressure on food security. SEPA supports the recommendations of the Gallagher
                                                        Review and would like to see those findings becoming mandatory. Greater carbon sustainability reporting is
                                                        needed to ensure that idle and redundant land is used and land use change is properly managed.

                                                        There is an absence of an LCA (life cycle analysis) mapping exercise to illustrate and inform of the true
                                                        consequences of pursuing the different options for LCVs. SEPA would strongly support such an approach,
                                                        however in the absence of this SEPA would expect the best practice environmental option (BPEO) to be
                                                        used in each case.

                                                        There is no single best option and SEPA would like to see a wide support for differing forms of LCV that
                                                        would suit different situations and conditions. Although the production of hydrogen is very energy intensive,
                                                        in some circumstances it can be effectively produced from surplus renewable energy overnight and used to
                                                        power vehicles. This solution, or other forms of energy storage, lends itself to remote and island
                                                        communities with significant transfer costs.

                                                        Many of the consultation questions are of a technical nature and outside SEPA‟s bailiwick. Those questions
                                                        that have a direct bearing on SEPA are appended in Annex 1. Annex 2 contains our respondent
                                                        information. SEPA is content for this consultation to be published.

                                                        SEPA supports the promotion of LCVs and looks forward to the findings of this consultation having far
                                                        reaching and beneficial consequences for Scottish transport.




                                                                           90
R42 - Scottish Natural Heritage


 RESPONDENT INFORMATION DETAILS
 Name:                                                     John Thompson
 Organisation:                                             Scottish Natural Heritage
 Address:                                                  Scottish Natural Heritage, Battleby, Redgorton, Perth
 Postcode:                                                 PH1 3EW
 Email:
 Telephone Number:                                         01738 458504
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       SNH supports the development of biofuels from sustainable sources, and we agree with the findings of the
 do you envisage will be first to be influential in        Gallagher Review and implementation of them by the UK and Scottish Governments, as discussed in the
 reducing GHG emissions from the transport sector?         consultation paper. They are likely to be first to influence reductions in greenhouse gases from transport
 Why?                                                      because they can be made, delivered, supplied and used with existing infrastructure and engines with
                                                           limited impacts on performance or cost. We have no comment on which LCVs are likely to be influential
                                                           first.
 Question 2: Which low carbon technologies and fuels       No comment
 do you believe will ultimately have the greatest
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are            No comment
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        No comment
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               A central objective of UK and Scottish energy policy is energy security, and proposals to progress LCVs and
 development of such fuels and technologies that are       alternative fuels should take account of possible energy security issues arising. In the case of LCVs, battery
 not mentioned in this document? If so, what are           technologies are likely to make the UK and Scotland dependent upon imports of the resources required,
 they?                                                     including e.g. nickel, cobalt, lithium, lanthanum and other rare earth elements, and platinum. Care will be
                                                           needed to ensure that access to these resources does not give rise to energy security issues.
 Question 6: Are there other barriers to the uptake of     No comment
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         Measures to promote LCVs are clearly one of a number of actions required to reduce emissions from
 associated with either the development or uptake of       transport, as outlined in the Climate Change Delivery Plan. In general the measures are likely to be
 such technologies/fuels? If so, what are they?            compatible with one another, but the direct and indirect interactions between the various measures as they
                                                           are progressed should be reviewed to make sure that conflicts do not arise. For example, for short journeys
                                                           walking and cycling („active travel‟) can lead to health benefits as well as avoiding CO2 emissions. It will be
                                                           important to ensure that the space and infrastructure needs for LCVs (and motorised transport) are
                                                           compatible with the needs of those for active travel.

                                                           Safety issues associated with the relative quietness of electric vehicles will need to be addressed. Care may
                                                           need to be taken to make sure that the resources required for LCVs (e.g. battery materials) are sourced in a
                                                           sustainable and equitable manner. Parallels can be drawn with the direct and indirect social and
                                                           environmental consequences associated with the upsurge in demand for biofuels in the last few years, as
                                                           explored in the Gallagher Review.
 Question 8: What, if any, technical challenges would      In terms of securing supplies of renewable energy and connecting to mainly urban-based demand, from a
 the grid reinforcement upgrades be likely to present?     natural heritage perspective, the challenges arising are likely to be similar to those associated with grid
 How might these be overcome?                              upgrades in general. The potential to spread the demand load (e.g. night-time recharging) and to manage
                                                           the load from intermittent and periodic sources (e.g. wind and tidal) may assist in overall grid management,
                                                           including electricity from more remote sources. There may also be for local grid enhancements so as to
                                                           make the necessary energy available at battery recharging centres, and due emphasis should be paid to
                                                           mitigating any associated environmental effects, eg by undergrounding.
 Question 9: Who would fund any grid upgrades?             As soon as practicable, it would seem appropriate to fund grid upgrades on the present model,i.e. they are
 And, how might these costs be recovered?                  funded by the electricity consumer on the basis of costed proposals developed by the grid network company
                                                           in response to demand for electricity supply. There may however be a start-up period of a few years during
                                                           which funding might be required to stimulate the grid necessary to establish a basic network of recharging
                                                           facilities.
 Question 10: Do any of the technologies present any       For LCVs, the main current constraints are the journey type and vehicle range. For some islands (e.g.
 specific challenges or opportunities to island            Orkney) the combination of geographical actors and wind could be ideal for the development of LCVs using
 communities and sparsely populated rural areas in         alternative fuels (e.g. hydrogen from wind). In the Western Isles, Shetland, and rural areas on the mainland,
 Scotland? If so, how might these challenges by            the long travel distances may present range problems for LCVs, but the availability of wind and wave energy
 addressed, and by whom?                                   could be used to produce alternative fuels.

                                                            SNH is likely to be keen to participate in any scheme developed to promote the use of alternative
                                                           renewable fuels in an island setting. If several different options are to be considered (e.g. a variety of
                                                           alternative fuels and LCV types) then small garages may not be able to afford the start-up costs associated
                                                           with storing and selling several fuel types and maintaining a range of novel vehicles. Providing funding or
                                                           support to help smaller garages in rural areas may be required to extend the geographic coverage and
                                                           range of LCVs and alternatively fuelled vehicles. For example, we have found it difficult to make as much
                                                           use as we‟d like of our LPG vehicles because supply is very limited cross Scotland overall – we discuss our
                                                           difficulties in using LPG/dual fuel vehicles further in response to Q13
 Question 11: Do you think that having a twin              Yes. Given the number of vehicles in the public sector and their geographical distribution, the public sector
 approach for the public sector and other users is         can help to create an important core of demand to help trigger progress towards the transformational
 appropriate? If so, why? If not, why not?                 outcome of decarbonised road transport. The Scottish Government has direct control over public sector
                                                           spend and procurement, and can set required standards; whereas this is less possible for most other users.
                                                           The Government can choose to absorb early „risk costs‟ of this incipient sector by using the public sector to
                                                           break the ground and develop good practice for wider public benefits.
 Question 12: If so, should targets relate to the uptake   SNH is keen to play our part in helping to achieve the transformational outcome of a decarbonised transport
 of low carbon vehicles (either as a percentage of the     sector. However, uniform targets for LCVs for the whole of the public sector could create difficulties for
 fleet or an absolute number), or a reduction in total     organisations like SNH whose vehicle fleets and journey types differ significantly from the norms set by the
 emissions across the fleets or another format of          bulk of public sector fleets (e.g. local authorities). Targets for use of LCVs in the public sector should be
 target? Why?                                              practical and reflect the availability of vehicles suited to the tasks/journeys required. SNH runs 144
                                                           vehicles, most of which are cars, often for rural journeys. Through our Carbon Management Plan we will
                                                           look to see whether journeys can be broken down so that as much as possible is undertaken by public
                                                           transport with short end-pieces that could be undertaken by LCV – but that will still leave a significant
                                                           number of journeys that are operational requirements that will be outwith the scope of battery-dependent
                                                           LCVs, at least for the time being.

                                                           If targets are set for use of LCVs, it will be important to set targets depending on the journey type (distance,




                                                                              91
                                                          urban, rural) and vehicle (e.g. car, LGV, HGV, buses) which allow for the range of needs across the public
                                                          sector as a whole.
                                                          More specific targets on the use of LCVs (taking account of journey type and vehicle) could sit comfortably
                                                          alongside requirements for public bodies to meet overall CO2 emissions targets from work travel as part of
                                                          their respective Carbon Management Plans.

                                                          For example, we have an target to reduce our overall emissions by 4% each year, For travel emissions, we
                                                          achieve this by a mix of measures to a) reduce the amounts of work travel, b) buy more efficient vehicles
                                                          (which could include LCVs, where they meet operational requirements), c) achieve modal shifts from pool
                                                          fleet to public transport and non-car modes, and d) to reduce private car use on work travel. This gives us
                                                          great flexibility and the ability to focus our energies and investments on what works best for us at particular
                                                          locations (e.g. urban, rural or remote), over particular timescales, and in response to infrastructure
                                                          improvements.
Question 13: If we follow a target relating to the        The high degree of variation across the public sector in journey type and vehicle needs mean that it is
public sector uptake of LCVs, what percentage of the      difficult to specify a single target for the entire public sector. As discussed in our answer to Q12, doing so
fleet should be LCVs by 2020? Please give reasons         could create operational and cost difficulties for organisations whose vehicle fleets and journey types do not
for your answer.                                          conform to the average (or mode) for the public sector overall.

                                                          For example, in 1998 we decided to phase out diesel cars from our fleet and buy only LPG/dual fuel cars in
                                                          order to reduce emissions. However, the availability of LPG stopped growing in the early 2000‟s, the
                                                          operational costs and reliability proved worse than predicted, CO2 savings were much less than expected
                                                          and the CO2 emissions of new diesel cars have improved greatly over the last decade. In hindsight, rather
                                                          than investing in a single technology we should have focussed on wider travel reductions and modal shifts,
                                                          which is our current approach.

                                                          Even where LCVs and alternative fuels may be suitable (e.g. local and urban trips), we would still prefer
                                                          SNH staff to use active travel and public transport as the first choice. Targets should avoid having a
                                                          perverse effect in leading organisations to make as much use of investment in LCVs as possible. This could
                                                          delay the important role that the public sector has in fostering the cultural and behaviour change required to
                                                          make more use of active travel and
                                                          public transport, especially if they are not subject to performance targets.
Question 14: If we follow a target relating to the        See our answers to questions 12 and 13.
uptake of LCVs across all road users, what
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        Our answer to question 12 details our concerns about the potential use of uniform targets for LCVs for the
should be excluded from the public sector target? If      whole of the public sector, and the difficulties that this may cause for organisations like SNH whose vehicle
so, what are they and why should they be excluded?        fleets and journey types differ significantly from the norms set by the bulk of public sector fleets (e.g. local
If not, why not?                                          authorities). A solution might be to set targets depending on the journey type (distance, urban, rural) and
                                                          vehicle (e.g. car, LGV, HGV, buses) which might allow for more flexibility across the public sector as a
                                                          whole. This approach could help to ensure that the development and use of LCVs is closely matched to the
                                                          journey types for which they are best suited, given the available technology and that which is likely to be
                                                          available in the short term.
Question 16: As LCVs may have higher upfront costs        This answer to this question involves a number of factors. For an organisation considering investment in
than traditional vehicles (albeit with a smaller          vehicles (including LCVs) the decision must take account of best value (including purchase, running and
discrepancy between lifecycle costs) do you               disposal costs), affordability and emission savings (including the impact of the decision on efforts to reduce
consider it to be efficient use of public resources to    emissions from travel in the organisation overall). The latter involves the opportunity cost of investment in
devote a greater short-term budget towards the            equipment such as videoconferencing or enhanced broadband services that could help to reduce travel
purchase of LCVs? If so, why? If not, why not?            needs. Careful consideration will need to be given to the wording for any targets and any consequent
                                                          support provided to purchase LCVs. For example, one of the possible targets involves the public sector
                                                          buying „best in class‟ vehicles from 2010, which could lead to sub-optimum emission savings overall. In
                                                          SNH we currently buy vehicles that are „good in class‟ in terms of
                                                          emission performance. If we did by more expensive „best in class‟ vehicles then we would not be able to
                                                          afford to replace as many vehicles and would have to continue running older less efficient stock, leading to
                                                          higher overall emissions. Thus, any additional support made available for the purchase of LCVs should
                                                          take account of any impacts on the overall emission performance of the vehicle fleet. The approved Carbon
                                                          Management Plan for the organisation could be used as the basis for guiding investment, including
                                                          additional support for the purchase of LCVs, to optimise reductions in overall CO2 reductions.

                                                          Our understanding is that most larger public sector bodies (including all local authorities) have already
                                                          worked with the Carbon Trust to agree a Carbon Management Plan, and that most of the smaller
                                                          organisations (including SNH) will have an approved Carbon-lite Management Plan in place within the next
                                                          few years. SNH is in the first cohort of organisations currently working through this process.

                                                          We support the idea of using the public sector to trial new LCVs before general production, although any
                                                          cost implications would raise similar concerns to those outlined above for purchase of „best in class‟
                                                          vehicles.
Question 17: Are there any opportunities or barriers      It would be helpful if guidance were made available as soon as possible and kept up to date about the
to public sector procurement of LCVs that are not         range of LCV types and alternative fuel systems and their suitability for different geographical situations and
mentioned in this document? If so, what are they?         journey types. The guidance should include information about where the vehicles can be serviced and
                                                          refuelled/charged across Scotland. This would help to avoid unexpected costs arising, for example, when
                                                          SNH had to send our „Smart‟ cars from Inverness to Perth for repair, creating additional transport and
                                                          administrative costs. The guidance could be used to inform the transport aspects of public sector Carbon
                                                          Management Plans and thereby inform optimum investment decisions.
Question 18: What are the individual roles of different   No comment
groups and organisations in ensuring the provision
of any infrastructure required for low carbon
vehicles?
Question 19: Are there other supply side/capacity         No comment
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of     No comment
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          No comment
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If       No comment
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      No comment
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           No comment
collaborate to stimulate the development and uptake
of LCVs?




                                                                             92
R43 - Tayside Police


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Graham Strachan
 Organisation:                                             Tayside Police
 Address:                                                  Fleet Management Office, Tayside Police Workshop, Balunie Drive, Dundee,
 Postcode:                                                 DD4 8UT
 Email:
 Telephone Number:                                         01382 596290
 Responding as:                                            On behalf of a group or organisation
 Individual Permission:                                    Not Supplied
 Confidentiality:                                          Not Supplied
 Group or Organisation:                                    Yes
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       At present the vehicle manufacturers are researching and developing various different alternate fuels
 do you envisage will be first to be influential in        technology, however the momentum appears to be in the direction of the electric or hybrid vehicle
 reducing GHG emissions from the transport sector?         technology. The development of 2nd generation Bio-fuels and Hydrogen fuel cells will also have an impact
 Why?                                                      on the motor industry but with the quick fix that electric cars give I see the 2nd gen. bio-fuel and hydrogen
                                                           fuel cell alternatives taking time to gather momentum Taking this into consideration I would suggest that the
                                                           electric powered vehicle will have the most short term influence. The biggest issue with this technology and
                                                           the barriers that appear to centre around the longevity of battery charge, the batteries life cycle, the battery
                                                           re-charging time and also the performance of the vehicle. Lithium Ion battery technology has improved the
                                                           battery lifetime and charge cycle issue but the performance and recharging cycle is still an area of concern.
                                                           Consideration should be given to alternatives to improve performance for longer journeys. There may be a
                                                           case for looking at the road network itself to assist with the development of electric vehicles. The possibility
                                                           of roads carrying a mobile charge system similar to a scalextric slot car track is one area for consideration.
                                                           An electric vehicle would be capable of taking a charge from the road in a similar fashion to a slot car. This
                                                           in turn could be used to regulate speeds in areas that hold a possible accident risk.
 Question 2: Which low carbon technologies and fuels       Electrically powered vehicles will be the most effective way to reduce emissions produced by road vehicles.
 do you believe will ultimately have the greatest          As technology advances the re-charging of the vehicle battery will have less of an impact on the
 emissions abatement impact? Why?                          environment with the development of regenerative braking and solar recharging as current examples this.
                                                           Further advances in this technology will assist with the reduction of the environmental impact that the main
                                                           stream electricity production currently has. Any further technological advance in the electrical energy
                                                           production or capture should be encouraged.
 Question 3: What timescales do you believe are            Low carbon technology is advancing with the introduction of regenerative braking in hybrid and electric
 feasible for the development of specific low carbon       vehicles as one example. However there must be an acceleration of the research and development to allow
 technologies and fuels? Are there any important           advances in efficient technology to impact on the vehicle industry. As well as the investment of time and
 intermediate milestones within these timescales?          money being employed to ensure a reduction in emissions for fossil fuelled internal combustion engines,
                                                           vehicle manufacturers should be given incentives to drive the low carbon fuel alternatives forwards. The
                                                           private sectors current low uptake of the alternative fuel vehicle does not encourage the vehicle
                                                           manufacturer to invest heavily in this area. The main emphasis presently on technology coming to market is
                                                           reduced emissions and better fuel consumption in fossil fuelled vehicles. This helps reduce the emissions in
                                                           the short term but it is not a long term solution to the problem. The main driver for the motor industry is the
                                                           creation infrastructure for re-fuelling of vehicles as the current fuel stations will become redundant. I feel that
                                                           until this area is developed there will be a resistance to the manufacturer mass producing any alternate fuel
                                                           vehicle other than electric, which benefits from the resilience of the national grid network. It is therefore a
                                                           concern that the manufacturers will be driven down a route that may or may not be the best long term
                                                           solution due to the fact that it is the path of least resistance from the consumer‟s point of view.
 Question 4: What timescales do you believe are the        The uptake of low carbon technology and fuel from the consumer‟s point of view will be driven by the
 feasible for the uptake of specific low carbon            production of a re-fuelling network. This structure must be in place to encourage the development, by the
 technologies and fuels? Are there any important           vehicle manufacturers, of mass production low or no carbon emission vehicles. There must be clarity and
 intermediate milestones within these timescales?          understanding by the consumer that they can make longer journeys in low or no carbon vehicles and have
                                                           the security and peace of mind that there is a re-fuelling network available to use. If the electricity network
                                                           could be adapted to provide a system where vehicles can be charged from designated re-charge points at
                                                           car parks, workplaces and homes etc this would encourage uptake of the technology from the consumer‟s
                                                           point of view. This in turn could provide a relatively quick solution measured in years as opposed to decades
                                                           that an alternative re-fuelling network may take to set up and operate.
 Question 5: Are there other barriers to the               The only barrier would be assuming a blinkered approach to the development. Options should be kept open
 development of such fuels and technologies that are       and every possibility investigated thoroughly.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     No I feel that the more educated that the consumer becomes the more readily they will embrace the roll out
 such fuels and technologies that are not mentioned        of the new technology as and when it happens
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         There is likely to be a dramatic change in the way that we currently use vehicles to get around if low carbon
 associated with either the development or uptake of       vehicles become the norm. There needs to be a greater uptake of public transport to make extended
 such technologies/fuels? If so, what are they?            journeys as I feel there will be vehicle range and re-fuelling time issues that impact on journeys. This will
                                                           cause an initial resistance to the change from traditional fossil fuelled vehicles as the inconvenience will be
                                                           felt heavily by vehicle users until they become used to the change in pattern.
 Question 8: What, if any, technical challenges would      Unknown this is for the energy supply industry to establish. However, if rolled out throughout the UK, the
 the grid reinforcement upgrades be likely to present?     programme of roadside work is likely to cause major disruption on a scale previously unseen.
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             As the profit from the energy sale will be made by the energy companies I feel that the cost of providing the
 And, how might these costs be recovered?                  network should be borne by them. Alternatively to encourage the set up of the network could central
                                                           government share the cost of set up with a profit share then being returned as a form of repayment over a
                                                           set period?
 Question 10: Do any of the technologies present any       All of these technologies present a problem for the island communities and sparsely populated areas.
 specific challenges or opportunities to island            However these are no different to the current challenges that are encountered for fossil fuel distribution.
 communities and sparsely populated rural areas in         Electricity is possibly more available due to the renewable energy initiatives that are in place for wind and
 Scotland? If so, how might these challenges by            wave power.
 addressed, and by whom?
 Question 11: Do you think that having a twin              Yes a twin approach is appropriate as this should encourage the manufacturers of LCV‟s to accelerate the
 approach for the public sector and other users is         move to market for the products with the technology to make a difference. However consideration has to be
 appropriate? If so, why? If not, why not?                 given to the role that these initial vehicles undertake and in certain environments, (e.g. Emergency service
                                                           blue light roles), there is no room for trialling and testing unproved technology. The product and technology
                                                           must be suitable and fit for purpose prior to any consideration being given. Therefore the 100% target by
                                                           2020 for Local Authority uptake is unachievable for Emergency Service vehicles without a dramatic
                                                           acceleration in the advance of technology.
 Question 12: If so, should targets relate to the uptake   It is the responsibility of the organisation to measure their carbon footprint. Within this there should be
 of low carbon vehicles (either as a percentage of the     targets set that show a reduction in the tonnage of CO2 emissions from the fleet over a set period. Each
 fleet or an absolute number), or a reduction in total     fleet is different with differing mileages, fuel usage and vehicle make up. If is therefore very difficult to set
 emissions across the fleets or another format of          broad brush targets. The responsibility should lie within the fleet managers remit to ensure that there are
 target? Why?                                              inroads made annually to the ultimate target of reducing emissions by 80% in 2050.
 Question 13: If we follow a target relating to the        This depends upon individual fleet policy and change cycle. Within the Police Forces of Scotland there are
 public sector uptake of LCVs, what percentage of the      differing opinions on change mileage and time criteria so it would be difficult to enforce a target relating to
 fleet should be LCVs by 2020? Please give reasons         the overall fleet. No Fleet Manager will want to replace vehicles that are still current and fit for service




                                                                               93
for your answer.                                          without a financial incentive. The targeting should relate to areas of the fleet that can readily accommodate
                                                          the change to LCV‟s. Initially targets should be set as a lower percentage to allow proving and ratification for
                                                          roles that are to be considered.
Question 14: If we follow a target relating to the        The answer to this is dependant again on technology advances. It is difficult to determine a percentage
uptake of LCVs across all road users, what                without a clear understanding and direction of where this technology is moving to. We are still in the infancy
percentage of all new vehicles should be LCVs by          of these advances and it is extremely difficult to gauge public reaction to such a dramatic shift from the
2020? Please give reasons for your answer.                dependence on fossil fuelled internal combustion engines to relatively untried LCV technology.
Question 15: Are there any vehicle categories that        Operational Emergency Services vehicles cannot operate with new unproven technology. These services
should be excluded from the public sector target? If      have a duty of care to the population that cannot be compromised.
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        Yes. Fleet size in this organisation as an example cannot be reduced to allow the purchase of more
than traditional vehicles (albeit with a smaller          expensive replacement vehicles. There would have to be funding to allow the uptake of the first life cycle of
discrepancy between lifecycle costs) do you               the LCV alternative. The reduction in revenue spend with the savings of running these LCV vehicles would
consider it to be efficient use of public resources to    then have to be diverted to allow the capital funding of the 2nd change cycle for these vehicles when they
devote a greater short-term budget towards the            reach the end of their life.
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers      The general public will expect that this reduction in CO2 should happen at no cost to them in any way.
to public sector procurement of LCVs that are not         However the funds will have to be found from somewhere, either increased revenue generation via taxation
mentioned in this document? If so, what are they?         or alternatively a reduction in the costs of the services currently provided to ensure that we meet the targets
                                                          that are set.
Question 18: What are the individual roles of different   The role of Tayside Police is to take a lead in the procurement and operation of a low carbon fleet that suits
groups and organisations in ensuring the provision        the purpose of an operational Police Force. To feedback the issues and advances to the sister forces and
of any infrastructure required for low carbon             via the National Association of Police Fleet Managers to ensure best practice is shared.
vehicles?
Question 19: Are there other supply side/capacity         The biggest issue is confidence in the technology. Once there is sufficient confidence that the technology is
constraints impacting on LCV development and              sustainable and operates efficiently and that there is a refuelling infrastructure the uptake will face little or no
uptake? If so, what are they?                             objection.
Question 20: Are there barriers to the development of     The low carbon vehicle industry is set for a period of major growth. If Scotland is to be at the forefront of this
an indigenous low carbon vehicle industry in              revolution it must get in at the grass roots level, now. If there are any barriers encountered in the
Scotland? If so, what are they and how might they be      progressing of this new industry they should be addressed and broken down as soon as is possible without
overcome?                                                 exception.
Question 21: Should Scotland’s industry focus on          Focus, should be at present, on the electric vehicle development as it is going to be the fastest moving
particular vehicle types? If so, what are they and        technology in the short term. However research and development in all forms of LCV technology should be
why? If not, why not?                                     encouraged. Scotland has a long and proud history of leading the way and developing new technology.
                                                          There are many examples of this that are well known worldwide Low carbon vehicle technology should be
                                                          the next major breakthrough for Scottish industry.
Question 22: Are there gaps in the supply chain? If       Consideration should be given to the after sales service provided by the vehicle manufacturer and their
so, what are they and how might these be overcome?        dealer network. There is going to be a massive re-training of vehicle technicians required to ensure that
                                                          there is a sufficient service and repair network established.
Question 23: Do we have the required skills base for      The skill base is in place in the motor trade but this radical change in the vehicles technology will require a
the development of this market? If not, where are the     massive amount of re-training to ensure that the service levels are maintained.
gaps?
Question 24: How could the various stakeholders           It is in everyone interest to ensure that the development and uptake of LCV is in the shorter term.
collaborate to stimulate the development and uptake       Communication between all stakeholders is the key. This must be driven centrally to ensure that best value
of LCVs?                                                  is gained. At the moment there are far too many interested parties operating individually. This can and will
                                                          lead to delays in the research, development, demonstration, commercialisation and uptake of LCV‟s. A
                                                          central body should be empowered to ensure that there is communication between all stakeholders to
                                                          accelerate the process, thus ensuring that Scotland is at the forefront of future developments




                                                                              94
R44 – World Wildlife Fund


    RESPONDENT INFORMATION DETAILS
    Name:                                                          Sam Gardner
    Organisation:                                                  World Wildlife Fund
    Address:                                                       Panda House, Weyside Park, Godalming, Surrey,
    Postcode:                                                      GU7 1XR
    Email:
    Telephone Number:
    Responding as:                                                 On behalf of a group or organisation
    Individual Permission:                                         Not Supplied
    Confidentiality:                                               Not Supplied
    Group or Organisation:                                         Yes
    Share Response Permission:                                     Yes




At the same time as Scotland‟s total greenhouse gas (ghg) emissions have declined by 19%, emissions from across Scotland‟s road transport sector have increased by
       2
11.5% . It is clear that if Scotland is to be successful in meeting the 80% ghg emissions reduction target set out in the Climate Change (Scotland) Act the transport sector
will have to reverse its current trend of growth in emissions and play a full part in meeting the target. Recent renewable energy targets at the EU, UK and Scottish level
have further highlighted the importance of tackling the transport sectors energy demands3.


If we are to successfully reduce the emissions contribution from road transport there must be an integrated policy that delivers demand management measures and
supports alternative low carbon travel options. This means commitment to public transport and active travel alongside the necessary investment in more efficient driving
through behaviour change measures and the vital role of low carbon vehicles. Low carbon vehicles will have a critical role to play in this policy mix but as with any
technology change they do not, on their own, provide a silver bullet to remove the emissions from road transport.

WWF Scotland is currently undertaking a piece of research looking at the emissions reduction potential of electric vehicles in Scotland. This study will
conclude after the consultation is closed but will provide valuable additional information that we hope the Scottish Government considers when developing
its policy in this area.

Technology Options

1. Which low carbon technologies and fuels do you envisage will be first to be influential in reducing GHG emissions from the transport sector? Why?

This question is answered on the basis of the current policy and private sector support mix that exists today The European Commission targets for new car tail pipe
emissions of 130g CO2/km by 2012 and 95g CO2/km by 2020 set the initial driver for the low carbon technologies that will have the early influence on ghg emissions. In
the first instance top-start technology will become the norm; both BMW and Bosch have predicted widespread availability of the technology by 2012. The additional costs
to the vehicle are minimal at approximately £180 and £270 for petrol and diesel cars respectively and the technology provides a 5-8% reduction over the NEDC (New
European Driving Cycle).

In the absence of an effective policy framework the introduction of alternatives to the internal combustion engine (ICE) will develop largely in order of the additional cost
they attach to the vehicle, which in turn are heavily influenced by the price of battery technology. Hybrid electric vehicles, such as the Toyota Prius, will continue to lead
the way. These will be followed by the Plug-in Hybrid vehicle with an onboard petrol generator which provides for a greater driving distance. The full electric vehicle will
develop in parallel with these other „introductory‟ technology types but, in the absence of concerted policy effort, will take longer to make the necessary significant impact
on transport emissions.

Low carbon vehicle research published by the EST4 suggests that dedicated ethanol and biodiesel vehicles will not play a significant part in the future market. Instead
biofuel supply will be used up to the level required by the RTFO to decarbonise conventional fuels with 5% or 10% blends. Biofuels will have a role to play as an
transitional technology on the way to a full electric car fleet.

2. Which low carbon technologies and fuels do you believe will ultimately have the greatest emissions abatement impact? Why?

Full electric vehicles will have the greatest emissions abatement impact in the future as they have the potential to generate zero emissions from power plant to wheel
when powered by 100% renewable electricity. The UK Committee on Climate Change (CCC) and BERR support this view with projections of future EV take up that see
this technology taking off and dominating the market place beyond the late 2020s. The same analysis also identifies future greater use of fuel cell vehicles, although this is
dependent on the necessary break through on fuel cell stack technology and hydrogen storage.

The internal combustion engine is inherently inefficient. In practice, only 18-23% of the chemical energy in the fuel actually reaches the wheels. Although efficiency
improvements remain possible, e.g. by developing super-light vehicle bodies, improving aerodynamics, increasing the efficiency of auxiliary components, reducing tyre
rolling resistance, etc. the potential efficiency gains in these areas apply in equal measure to electric vehicles, therefore they should complement – not forestall – the
electrification of automotive transport. Electric vehicles are not only much more efficient in principle than conventional vehicles – converting some 65-75% of the energy
stored in batteries into motion – they are also compatible with the full range of sustainable renewable energy sources including wind, solar, geothermal, hydro, wave, tidal,
etc.

The table below describes the significantly improved efficiency and reduced emissions from battery electric vehicles in comparison to the current internal combustion
engine.


Table 1 Comparison of the CO intensity of motive energy at the wheels of internal combustion engine vehicles (ICEV) and Battery Electric Vehicles (BEV) for
                                     2
representative US states and EU nations. Table taken from Plugged In The End of the Oil Age. Gary Kendall (2008) WWF




                                                                                                                                                     CO intensity of motive
                                                           CO intensity of energy                                                                         2
                                                               2                             (Refining &) T&D              Vehicle energy
                                                                                                                                                    energy (lower = better)
                                                             supply (gCO /kWh)                 efficiency (%)              efficiency (%)
                                                                           2                                                                             (gCO /kWh)
                                                                                                                                                               2

ICEV                        Gasoline                     242                             83%                         18%                           1619



                            Diesel                       248                             83%                         23%                           1300



US BEV                      California                   273                             92%                         65%                           457




2
    See Hhttp://www.airquality.co.uk/reports/cat07/0909231418_DA_GHGI_report_2007_maintext_Issue_1.pdfH
3
    See Hhttp://www.scotland.gov.uk/Resource/Doc/917/0066300.pdfH
4
    Revolution The road to a low carbon future. Energy Savings Trust.




                                                                                     95
                            Indiana                        937                            92%                            65%                           1567



                            US Average                     620                            92%                            65%                           1037



EU BEV                      Austria                        221                            92%                            65%                           370



                            Greece                         781                            92%                            65%                           1306



                            EU Average                     370                            92%                            65%                           619




Although the UK CCC also identify a future potentially important role for fuel cell vehicles it is important to keep in mind that hydrogen produced from sustainable
renewable power and then recombined in fuel cells to create electricity suffers terrible efficiency losses; as an energy carrier, hydrogen cannot compete with its own
energy source. On a life-cycle basis, electric vehicles convert renewable electricity into kilometres around three times more efficiently than hydrogen fuel cell vehicles.
Until we have an excess of renewable generating capacity, there can be no justification for throwing away this much energy.

3. What timescales do you believe are feasible for the development of specific low carbon technologies and fuels? Are there any important intermediate
milestones within these timescales?

Timescales for development of either EVs or PHEVS will vary depending on what is regarded as the point of conclusion of their development. In both cases the
technology already exists and has been developed to the point of application. However, it is also apparent that the technology will continue to develop partly in response
to increasing demand, competition and the innovation this requires but also in response to the current R&D efforts being committed to ensuring EV and PHEV technology
becomes mainstream. Electric vehicles are being launched this year to the market place and we can expect to see an acceleration of interest from both manufactures and
the public. For instance Renault have said they expect sales of their electric vehicle models to reach 100 000 a year from 2012.

The major milestone in the development of technology to support the mass market penetration of electric vehicles relates to the emergence of a low cost lithium-based
battery. There is widespread agreement that lithium-ion batteries will become the dominant technology for electric vehicles in the future (MIT 2007). In addition to the high
energy and power density they provide compared to competing technologies they also exhibit other positive characteristics such as low self discharge rates, good life time
and discharge cycle characteristics. However, despite being the dominant technology in consumer electronics the Li-ion battery is still in its infancy in terms of its
application for vehicle propulsion and battery cost reduction remains the main challenge to future large scale deployment of EVs. The battery leasing business model is
one proposed approach designed to reduce the initial capital cost and make the first electric vehicles directly competitive on the forecourt to ICEV.

4. What timescales do you believe are feasible for the uptake of specific low carbon technologies and fuels? Are there any important intermediate milestones
within these timescales?

This question will be addressed in more detail in the research WWF is taking forward on electric vehicles.
The literature provides some variation on expected uptake of specific low carbon vehicles and in particular to the future market penetration of EVs and much depends on
the collective effect of global efforts to substitute the ICE with the electric vehicles. In recent years we have seen a rapidly accelerating international interest in EVs which
is fuelling significant investment in both R&D and pilot projects. There are currently over 15 different EV pilot projects or public investment programmes across the EU
trialling and demonstrating emerging EV technologies. For instance, in France 400 million euros is assigned to developing EVs and in Germany 500 million. Outside the
EU the USA has committed $2 billion in grants for the manufacture of advanced vehicles batteries and systems and 30% credit for advanced energy investments
including plug in vehicle manufacturing. China plans to boost its annual production of electric or hybrid cars to 500 000 in the next two years from over 2000 in 2008.
It is clear that there is considerable attention being paid to the role of electric vehicles and this will do much to ensure that this new technology does not follow a traditional
market penetration timeline for new vehicle technology of between 10-20 years to achieve 5% of new sales.
Work commissioned by BERR offers a number of scenarios describing future uptake of electric vehicles in 2020 and 2030. Figures for number of vehicles in the UK car
fleet by 2030 range from 1,600,000 to 5,800,000 EVs and between 2,500,000 and 14,800,00 PHEVs. Work by EST describes how under their most effective policy
scenario the take up of EVs will reach 261,000 by 2030 and that LCVs will outsell traditional fossil fuel cars. Please note that the figures between these studies are not
directly comparable as one describes total EVs in the car pool by 2030 and the other the number of EV sales by 2030. Despite this difference of description both studies
show that by 2030 EVs and PHEVs can make very significant market penetration.

5. Are there other barriers to the development of such fuels and technologies that are not mentioned in this document? If so, what are they?
No

6. Are there other barriers to the uptake of such fuels and technologies that are not mentioned in this document? If so, what are they?

One other potential additional barrier relating to EVs and PHEVs is the need to establish consumer confidence and interest in this new technology so as to strengthen the
level of demand beyond that proportion of the population already motivated by issues of pollution and climate change.

7. Are there any negative social impacts associated with either the development or uptake of such technologies/fuels? If so, what are they?

There are potentially very significant social and environmental impacts associated with the development of biofuels that results in the displacement of food producing land,
loss of biodiversity and net increase in greenhouse gas emissions as a result of the intensive landuse change.

The growth of electric vehicles also establishes an additional and in some cases new resource demand on the raw materials used in the battery technology. The
estimated material composition of lithium-ion battery system for vehicle use is provided below.

                                        Material                                                       Share

   Aluminium                                                                                           30.3 %

   Copper                                                                                              13.9 %

   Manganese                                                                                           11.7 %

   Plastics                                                                                             9.7 %

   Steel                                                                                                9.2 %

   Ethylene oxide                                                                                       6.2 %

   Carbon dioxide                                                                                       6.2 %

   Others                                                                                               6.0 %

   Carbon                                                                                               5.7 %




                                                                                      96
   Lithium, lithium salt                                                                               0.9 %

   N-Methyl-2-pyrrolidone                                                                              0.2 %

   Polyvinyliden fluoride                                                                              0.1 %


European lithium resources are considered to be negligible, with some small mineral deposits are to be found in Finland and Austria. The most significant reserves are in
South-America and Asia. This immediately raises the prospect of resource extraction and the associated environmental impacts being divorced from the market demand
in northern America and Europe. BERR predicts that China and Bolivia will become the leading producers of brine-based lithium carbonate for battery production by 2010.
Every effort must be made to ensure that anticipated growth in demand for these raw materials is matched by comprehensive international regulation that protects the
environment and people who live at the place of extraction. There is also a need for the full quantification of the environmental impacts of battery production, recycling and
disposal if we are to understand all the consequences of an increase in electric vehicle numbers.


The replacement of a traditional ICE vehicle with an electric equivalent does not automatically address many of the negative environmental and social consequences of a
transport system dominated by the private car. Issues regarding health and mobility are common across both technologies and must be addressed. For instance, the
negative impacts of congestion must be addressed regardless of fuel type. If the emergences of EVs are not to actually result in an increase in total vehicle km i.e.
through their use for short journeys that were previously taken by bus or on foot, they need to be to be rolled out in conjunction with a truly integrated low carbon transport
plan and in particular investment in active travel. For instance, although almost all car journeys occur within even the current range of EVs consumer purchases are made
on the basis of total possible potential such as speed limits that are never reached, storage capacity that is rarely needed and a driving range that is required only once a
year. To ensure the EV actually becomes established as the primary vehicle choice, rather than second car for limited use, there needs to be more development of placed
on car clubs, car hire and quality intercity public transport network.

9. Who would fund any grid upgrades? And, how might these costs be recovered?

WWF does not have a view on this question other than to recommend that measures are put in place to ensure that any costs are not disproportionately placed on those
with limited means and who make only a marginal contribution to road transport emissions.

10. Do any of the technologies present any specific challenges or opportunities to island communities and sparsely populated rural areas in Scotland? If so,
how might these challenges by addressed, and by whom?

WWF does not foresee these low carbon technologies posing any specific challenges to island and sparsely populated rural areas of Scotland. Indeed the reverse is more
likely with electric vehicles powered by community owned renewable electricity providing the chance for low cost mobility in areas that are often the first to be hit by rises
in fossil fuel prices.

Setting Targets

11. Do you think that having a twin approach for the public sector and other users is appropriate? If so, why? If not, why not?

Yes it is appropriate to have a twin target approach. As the consultation makes clear public procurement of low carbon vehicles could have an important role in
accelerating the wider support for new technologies such as electric vehicles. It is important that the public sector target is sufficiently ambitious as to make an impact on
the wider market take up of new technologies. At the same time as transforming the public sector fleet there must be a wider public target for the take up of electric
vehicles that drives policy design and implementation in the right direction.


12. If so, should targets relate to the uptake of low carbon vehicles (either as a percentage of the fleet or an absolute number), or a reduction in total
emissions across the fleets or another format of target? Why?

The target should not refer to low carbon vehicle because just as the consultation states „there is not currently a simple definition of what constitutes a LCV‟ and the term
is therefore too ambiguous to give sufficient meaning to the target. Although it is clearly true that tail pipe

emissions do not reflect the „full life cycle‟ emissions associated with EVs those emission are reported at the point of power generation and will be tackled through the
Scottish Government‟s clear commitment to decarbonise the power sector by 2030. If the public sector target is to be effective in increasing investment in the most
appropriate technologies it has to explicitly identify those technologies as being the ones that count towards the target. If there is uncertainty regarding what counts, for
instance in terms of being „alternative powered‟ the purchasing power of the public sector will be diluted across the various interpretations fleet managers choose to take.

It is important to see this target in the context of the wider public sector duty set out in the Climate Change (Scotland) Act 2009 that requires public bodies to act “in the
way best calculated to contribute to the delivery of the targets set in or under Part 1 of this Act”. It should therefore not be necessary to frame this in terms of „meet their
emissions share‟ as this effectively repeats the CC Act and does nothing to direct investment towards the right technologies.

The Scottish Government must take a view as to which low carbon technology is best placed to deliver the required emissions reduction needed to hit the 2020 target of
at least 42% and put us on the right path to an 80% reduction. WWF Scotland is of the view that electric vehicle technology provides the greatest emissions reduction
potential, builds on our strong renewables capacity, is closest to mass market availability and would show the greatest return from public sector investment. As such we
would recommend that the target set for the public sector requires replacing the entire current fossil fuel car fleet and light vans with PHEVs and EVs by 2020.

However, it is clear from the data presented in the consultation document that a significant percentage of emissions from the Local Authority fleet come from HGVs where
electric propulsion will struggle to make a meaningful impact in the short term. Emissions reductions from this sector should be pursued through demand reduction
measures, improvements in efficiencies delivered through smart driving, shared vehicle use to reduce number of journeys and greater proportion of HGVs fuelled by
biofuels as electric car numbers increase. These changes should be done in order to comply with the duty in the CC Act and ensure savings are made from across the
public sector transport fleet. Guidance could be provided on how best to deliver the emission savings from those vehicles where there is no electric option.

13. If we follow a target relating to the public sector uptake of LCVs, what percentage of the fleet should be LCVs by 2020? Please give reasons for your
answer.

100% of the public sector car fleet should be either PHEV or EV by 2020. The average age of a public sector car is three years allowing for at least three replacement
vehicles purchases between now and 2020. This is sufficient opportunity to plan and establish EVs in the car fleet and this is in line with projections of EV availability by
2020. In time the balance should shift to a predominantly EV fleet as the PHEV is effectively phased out as a transitional technology.

14. If we follow a target relating to the uptake of LCVs across all road users, what percentage of all new vehicles should be LCVs by 2020? Please give
reasons for your answer.

This question is the subject of a current research programme for WWF Scotland. The research will allow us to provide an evidence based recommendation as to what an
appropriate target should be. The future projections of electric vehicle ownership provided by the UK CCC and analysis for BERR offer a starting point for identifying a
total Scotland fleet target for LCVs. The CCC describes a target where EVs make up 12.1% of new cars purchased in 2020 and some 16% of new vans with other
significant EV technology types such as the PHEV spread across cars, vans and HGVs.


16. As LCVs may have higher upfront costs than traditional vehicles (albeit with a smaller discrepancy between lifecycle costs) do you consider it to be
efficient use of public resources to devote a greater short-term budget towards the purchase of LCVs? If so, why? If not, why not?

Yes it is an efficient use of public resources to invest in vehicles that not only have significantly lower running costs, and ultimately cheaper total lifecycle costs, but also
make an important contribution to tackling climate change and therefore reducing our exposure to the huge costs associated with the impacts of dangerous climate
change. Some of the steps to tackling climate change do present an immediate short term cost. However, this represents an investment in new low carbon technologies
that Scotland can help pioneer while mitigating the future cost impacts of climate change.

The required change to the public sector fleet should also prompt a review of its size and need. An initial higher cost will help the public sector identify other means of
delivering its public service without being so reliant on the personal vehicle.




                                                                                     97
A concerted shift to zero emission vehicles will also provide important benefits in terms of improved air quality in urban environments and reduced cost associated with
the health impacts resulting from poor air quality.

17. Are there any opportunities or barriers to public sector procurement of LCVs that are not mentioned in this document? If so, what are they?

One significant opportunity that exists for the Glasgow area and could have a much wider ripple effect across Scotland is the Commonwealth Games in 2014. Glasgow
will attract an international audience and must present itself as the low carbon games. The high profile presence of electric vehicles in and around the city could help
position Scotland at the forefront of this new industry and act as a catalyst for other cities across Scotland.

18. What are the individual roles of different groups and organisations in ensuring the provision of any infrastructure required for low carbon vehicles?

The Scottish Government has a clear role to provide leadership on this issue and set the right policy framework to drive investment in low carbon vehicles and in particular
electric vehicles. Power companies have a potentially important role to play in providing the supporting infrastructure and generating renewable electricity to meet the
demand. There is also a clear need to ensure the roll out of Smart Meters happens in parallel with the growth in EV as they will have a critical role to play in managing the
additional demand on the grid.

19. Are there other supply side/capacity constraints impacting on LCV development and uptake? If so, what are they?
WWF is not aware of any supply side capacity constraints.

20. Are there barriers to the development of an indigenous low carbon vehicle industry in Scotland? If so, what are they and how might they be overcome?

Although Scotland does not currently have an indigenous car manufacturing industry it does have considerable expertise in aspects of vehicle manufacturing and in
particular in electronic engineering and as such there are no obvious barriers to Scotland playing an important role in a future low carbon vehicle industry.


21. Should Scotland’s industry focus on particular vehicle types? If so, what are they and why? If not, why not?


Scotland should continue to build expertise where it already has an established role, such as provided by Allied Vehicles and companies such as Axeon. However, longer
term we should have a strategy to ensure we have an established focus across the breadth of EV supply chain, including a diversity of vehicle types.



22. Are there gaps in the supply chain? If so, what are they and how might these be overcome?

WWF is not aware of any gaps in the supply chain.



23. Do we have the required skills base for the development of this market? If not, where are the gaps?
WWF does not have the expertise to answer this question but highlights the excellent R&D potential in our Universities and our existing expertise in electronics and
renewables; given the right policy stimulus there ought to be no reason we cannot have a world leading skill base in this area.


24. How could the various stakeholders collaborate to stimulate the development and uptake of LCVs?
WWF Scotland is keen to play a part in the future role of electric vehicles in Scotland and will work with other stakeholders to promote their benefits and role in
contributing to a low carbon Scotland.




                                                                                   98
R45 – Barry Hutton


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Barry Hutton
 Organisation:                                             Private Consultant
 Address:
 Postcode:
 Email:
 Telephone Number:
 Responding as:                                            An Individual
 Indvidual Permission:                                     Yes
 Confidentiality:                                          Yes
 Group or Organisation:                                    Not Supplied
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Electric vehicles have the great advantage of being non-polluting when brought a stand. Otherwise they
 do you envisage will be first to be influential in        relocate pollution from where vehicle-kilometres are driven to where the electricity is generated. That is
 reducing GHG emissions from the transport sector?         good for individual health but much less good for climate change. Much more research and information is
 Why?                                                      needed on real whole-life costs, particularly on the manufacture of batteries.
 Question 2: Which low carbon technologies and fuels       The greatest reduction in emissions by far will be achieved by reductions in travel coupled with the use of
 do you believe will ultimately have the greatest          those modes of transport where vehicle emission per person-kilometre is reduced. The use of Low
 emissions abatement impact? Why?                          Emission Vehicles is desirable but the effects will not reach desirable levels if they are used to increase the
                                                           numbers of vehicles and vehicle-kilometres: there is a great danger that Low Emission Vehicles will be used
                                                           to validate and increase in vehicle use.
 Question 3: What timescales do you believe are            I am not knowledgeable enough to answer this question.
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        I am not knowledgeable enough to answer this question.
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               I am not knowledgeable enough to answer this question.
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     The political pressure of the car-owning and car-using members of society is powerful and is articulated
 such fuels and technologies that are not mentioned        through the industry, through the SMMT and through the motoring media. The need for publicity, public
 in this document? If so, what are they?                   relations, information and education is crucial for the success of any attempts to change popular motoring.
                                                           The success of the seat belt campaign and the failure of the campaign about the use of mobile phones
                                                           whilst driving need to be studied.
 Question 7: Are there any negative social impacts         Too much government policy rests upon individual action. A government's job is to govern, to protect
 associated with either the development or uptake of       citizens from noxious trends and events - not to invite individuals to take individual evasive action. The
 such technologies/fuels? If so, what are they?            Construction and Use Regulations are in place and they should be extended.
 Question 8: What, if any, technical challenges would      I am not knowledgeable enough to answer this question.
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             The grid was built by the Central Electricity Generating Board efficiently and at minimal cost. Individual
 And, how might these costs be recovered?                  Area Boards brought electricity to almost every household in the country, again efficiently and at reasonable
                                                           cost, far below the costs incurred at present. The grid is a public service and, just as our safety and security
                                                           is based upon the services of the police, justice and emergency systems, so the basic public utilities of
                                                           electricity, water, gas, sewerage and waste
                                                           disposal have historically been well provided by public organisations.
 Question 10: Do any of the technologies present any       In space technology energy, water and waste are seen as a holistic system. We should stop fragmenting
 specific challenges or opportunities to island            services - integrated sewerage, methane, power and water should be developed from space technology to
 communities and sparsely populated rural areas in         serve remote, self contained communities.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              Private sector firms driven by share price and profit work well wherever there is real, effective competition.
 approach for the public sector and other users is         But competition in the utilities is impossible - they are natural monopolies. The Victorians recognised this
 appropriate? If so, why? If not, why not?                 and were proud of their municipal water, gas and electricity services. They believed in enterprise and
                                                           competition but recognised it was not the way to deliver public utilities. They were right and it is the legacy
                                                           of their infrastructure that sustains modern cities.
 Question 12: If so, should targets relate to the uptake   Targets are too often related to the means of achieving a desirable end rather than the end itself. The
 of low carbon vehicles (either as a percentage of the     percentages of fleets that are Low Emission is merely one way of reaching the real goal of reducing CO2.
 fleet or an absolute number), or a reduction in total     That is the target and policy should be designed to achieve it by a comprehensive mosaic of inter-related
 emissions across the fleets or another format of          policies.
 target? Why?
 Question 13: If we follow a target relating to the        See 12
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the        See 12
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        No exclusions. They just lead to boundary debates that divert attention. We do not have exclusions to the
 should be excluded from the public sector target? If      strictures upon other forms of anti-social behaviour - the Victorians did not say that mine owners could use
 so, what are they and why should they be excluded?        women and children as a percentage of their underground workforce. There was a complete and enforced
 If not, why not?                                          ban. Damage to the planet is unwise and immoral and should be bounded by law.
 Question 16: As LCVs may have higher upfront costs        No. Road safety depends upon good tyres. Compliance with the law on tyres is the responsibility of
 than traditional vehicles (albeit with a smaller          individual vehicle owners who should not look to the State and taxpaying members of society for financial
 discrepancy between lifecycle costs) do you               assistance to help meet their legal obligations. The cost of compliance with laws on global safety should
 consider it to be efficient use of public resources to    likewise fall on the individual.
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      None that are valid.
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different   This is the duty and responsibility of government
 groups and organisations in ensuring the provision
 of any infrastructure required for low carbon
 vehicles?
 Question 19: Are there other supply side/capacity         None of which I am aware.
 constraints impacting on LCV development and
 uptake? If so, what are they?




                                                                                99
Question 20: Are there barriers to the development of   The economies of scale and the modern structure of international industry. Production would have to be
an indigenous low carbon vehicle industry in            highly capitalised with volume production marketed worldwide. That would have to be grafted on the an
Scotland? If so, what are they and how might they be    existing organisation.
overcome?
Question 21: Should Scotland’s industry focus on        Modern industry is not organised like this. Nothing is made in its entirety - production consists of assembling
particular vehicle types? If so, what are they and      bought-in components from all over the world: talk of 'vehicle-type' is illusory. Scotland would probably be
why? If not, why not?                                   best at designing and building vehicle control systems.
Question 22: Are there gaps in the supply chain? If     Not of which I am aware
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for    Not of which I am aware
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders         Dispersing responsibility for government policy amongst "stakeholders" results in confusion, conflict,
collaborate to stimulate the development and uptake     inefficiency and excess cost. I repeat: the Government's duty is to govern and to do so, first by passing and
of LCVs?                                                enforcing law and, second, by creating a physical infrastructure within which private enterprise may securely
                                                        operate.




                                                                          100
R46 – Derek Halden


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Derek Halden
 Organisation:                                             DHC
 Address:                                                  26 Palmerston Place, Edinburgh
 Postcode:                                                 EH12 5AL
 Email:
 Telephone Number:
 Responding as:                                            An Individual
 Individual Permission:                                    Yes
 Confidentiality:                                          Yes
 Group or Organisation:                                    Not Supplied
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Plugging in electric vehicles (EV and PHEV) to renewable sources is the only certain way to reduce
 do you envisage will be first to be influential in        emissions. Other solutions will be needed but the effects are complex so require great caution.
 reducing GHG emissions from the transport sector?
 Why?
 Question 2: Which low carbon technologies and fuels       Investment in renewable electricity generation and storage (perhaps as hydrogen) will allow decarbonisation
 do you believe will ultimately have the greatest          of land based transport. The key is for this to take place sooner rather than later. (See for example the 2005
 emissions abatement impact? Why?                          DHC report for BCSC which explains the role of each fuel www.bcsc.org and the subsequent King report for
                                                           the Treasury)
 Question 3: What timescales do you believe are            The development work for EVs and PHEV is nearing completion and they are on trial. Hydrogen vehicle
 feasible for the development of specific low carbon       development (particularly for buses and lorries will be critical) and these programmes need to be
 technologies and fuels? Are there any important           accelerated.
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        It is critical that local authorities revise their land use development plans to show how electric vehicle
 feasible for the uptake of specific low carbon            infrastructure and renewable energy development can be incorporated. This might include charging points
 technologies and fuels? Are there any important           in each urban street, perhaps with new car parks for shared cars. A conducive taxation and charging
 intermediate milestones within these timescales?          structure for new technologies will be critical.
 Question 5: Are there other barriers to the               Yes - and these are only partially covered in current studies. DHC is currently looking at this in other
 development of such fuels and technologies that are       research and analysis.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     Yes - as for question 5. Note particularly the planning issues are given much too low a profile.
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         There are many positive and negative social impacts. These vary locally, regionally and nationally and
 associated with either the development or uptake of       should not be ignored. Note that the social impacts of the current Scottish Government policies such as rail
 such technologies/fuels? If so, what are they?            and road investment are very poorly understood so a comprehensive assessment is needed - not just
                                                           relating to new policies such as for low carbon vehicles.
 Question 8: What, if any, technical challenges would      The BERR and SSE studies cover this in part and would be a good starting point for the strategy. Note that
 the grid reinforcement upgrades be likely to present?     there are many detailed issues relating to transferring established technologies to widespread application
 How might these be overcome?                              through smart meters, links to payment mechanisms, etc. that could reduce the burden on the grid.
 Question 9: Who would fund any grid upgrades?             This should ultimately be done through market mechanisms rather than public funding for infrastructure by
 And, how might these costs be recovered?                  government. The scale of market change will be very large and government could destabilise the market by
                                                           paying electricity companies for investment. Government should subsidise consumers as the investment
                                                           mechanism through offer taxation incentives for early uptake to get the market moving e.g. increased
                                                           taxation of oil based fuels to reduce costs for consumers contemplating early uptake of new vehicles at
                                                           tariffs that pay for the required grid investment.
 Question 10: Do any of the technologies present any       The local balance between generation of electricity and use of electricity is easiest to understand at the local
 specific challenges or opportunities to island            island level but might be more expensive to manage e.g. with sufficient energy storage to cover times when
 communities and sparsely populated rural areas in         there is a low level of renewable generation.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              The public sector is a very large consumer and purchaser and should lead by example. This is not so much
 approach for the public sector and other users is         a twin approach as a market leadership approach.
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake   Targets can be useful politically and presentationally to help manage progress rather than drive change.
 of low carbon vehicles (either as a percentage of the     See my comments made on this to the Climate Change Bill Committee earlier in 2009.
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        100% of new purchases of cars and vans in the public sector should be EV and PHEV by 2020 in line with
 public sector uptake of LCVs, what percentage of the      the ambitious practical level of delivery envisaged by BERR. Scotland should move faster than the rest of
 fleet should be LCVs by 2020? Please give reasons         the world since renewable energy generation and EV take up are complementary markets and Scotland
 for your answer.                                          should seek to underpin its role and future economic growth in these markets. For lorries, buses, trains and
                                                           aviation targets are more complex and require further analysis before these can be set.
 Question 14: If we follow a target relating to the        Further analysis is needed of this. It is probably unhelpful to scrap vehicles early since the carbon used in
 uptake of LCVs across all road users, what                their manufacture is very significant. Vehicles being purchased at present under the current vehicle
 percentage of all new vehicles should be LCVs by          scrappage scheme will mainly still be on the road in 2020. See the article on this in Issue 44 of Scottish
 2020? Please give reasons for your answer.                Transport Review www.stsg.org
 Question 15: Are there any vehicle categories that        This is a complex question bundling targets with policy. The simple answer is that exclusions will be needed
 should be excluded from the public sector target? If      and that targets may not always be helpful.
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        The public sector should be eligible for the same level of market incentives and taxation relief that is
 than traditional vehicles (albeit with a smaller          available to consumers. Attempting to uncouple public purchasing decisions from the wider economy would
 discrepancy between lifecycle costs) do you               be dangerous leading to market distortions.
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      Overall it is a good document but there is a lot of detail missing that can only be closed through a more
 to public sector procurement of LCVs that are not         thorough analysis. Policy should not be determined solely from consultation but also from expert advice and
 mentioned in this document? If so, what are they?         analysis.
 Question 18: What are the individual roles of different   There will be roles and responsibilities for every stakeholder in society. Currently transport accounts for
 groups and organisations in ensuring the provision        more than 20% of the economy from warehousing and distribution through to the purchase of a bike. Every
 of any infrastructure required for low carbon             single transport decision will be affected by the move to LCVs (since 99% of transport is currently
 vehicles?                                                 dependent on oil) so the important points are to start the change now, move incrementally, learn from
                                                           mistakes and constantly develop policies and markets.
 Question 19: Are there other supply side/capacity         We know about some manufacturing issues like with batteries but in reality the most important issues will be
 constraints impacting on LCV development and              ones not yet foreseen. The market can respond quickly, but only if government provides a flexible
 uptake? If so, what are they?                             framework. Currently the major supply side issue where government could do more would be to clarify
                                                           planning policy on electric vehicle infrastructure such as charging points. Note that mobile phones took less
                                                           than 10 years to spread from only a few handsets to something everyone owned but planning issues with




                                                                             101
                                                        masts proved to be a major barrier. LCVs demand a larger level of investment. Government could delay
                                                        progress if it distorts the market by seeking to tackle supply side barriers (e.g. with businesses queuing for
                                                        government grants rather than getting on with delivery) so it would be better to accelerate progress by
                                                        investing in the demand side and letting markets overcome the problems.
Question 20: Are there barriers to the development of   The Norwegians are doing it with the ''Think'' car by partnering with Ford. The London Mayor ran a
an indigenous low carbon vehicle industry in            competition for a new London style red bus that created momentum. What about a Scottish Government
Scotland? If so, what are they and how might they be    competition backed with a commitment to purchase some for the public sector fleet.
overcome?
Question 21: Should Scotland’s industry focus on        It is important not to seek to determine how industry might develop.
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If     Again government should be very cautious about interfering.
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for    People will want to work on the latest technologies. Just as the oil industry attracted and trained people from
the development of this market? If not, where are the   across the globe the LCV industry could do the same. Scotland has a good base to build on Alexander
gaps?                                                   Dennis, Motherwell Bridge, Oil service and supply companies, etc.
Question 24: How could the various stakeholders         Project based partnerships to win funding from national competitions have consistently proved to be a good
collaborate to stimulate the development and uptake     approach to achieve delivery focused collaborations in the transport sector. This has been a point made in
of LCVs?                                                many DHC research reports for Scottish Government over the last decade.




                                                                          102
R47 – Ian Souter


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Ian Souter
 Organisation:
 Address:
 Postcode:
 Email:
 Telephone Number:
 Responding as:                                            An Individual
 Individual Permission:                                    Yes
 Confidentiality:                                          Yes
 Group or Organisation:                                    Not Supplied
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels             1.      Given that the purpose of this transport policy is to reduce the emission of greenhouse gases
 do you envisage will be first to be influential in                      from transport sources, it is disappointing to see that the options offered for consideration in
 reducing GHG emissions from the transport sector?                       the consultation exclude vehicles powered by electricity supplied from an external source.
 Why?                                                                    Such vehicles, commonly manifest as tramways/light railways and trolleybuses, are
                                                                         extensively used outside the UK.

                                                                  2.      The technology of application of electric vehicles is well known and is commonly available
                                                                         from other EC countries.

                                                                  3.     A particularly attractive feature of electric traction vehicles in respect of energy conservation is
                                                                         that they are capable of recovering energy which is otherwise wasted as heat during braking.
                                                                         This energy is returned through the power supply network to other vehicles in the vicinity.
                                                                         Improvements in technology, specifically lithium ion batteries and supercapacitors, offer further
                                                                         improvement in the level of waste energy which can be recovered. With supercapacitors, the
                                                                         waste energy of braking can be stored on the vehicle should the power supply network be
                                                                         unreceptive, and this energy can then be used to boost the next acceleration cycle.
                                                                         Supercapacitors for traction use have been in public service in the Far East for over 10 years
                                                                         and are now being offered by EC equipment suppliers.

                                                                  4.      The potential for generation of electricity by renewable methods in Scotland must rank among
                                                                         the best in the EC, with untapped potential for tidal, wave, and underwater current generation.
                                                                         Additionally, Scotland is one of the windiest places in the world, not in terms of high wind
                                                                         speed, but in respect of the point that complete calm is
                                                                         unusual.
 Question 2: Which low carbon technologies and fuels
 do you believe will ultimately have the greatest
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of            1.     Unless the low carbon powered vehicle has the same performance capabilities, carrying
 such fuels and technologies that are not mentioned                      capacity and range between refuelling as existing hydrocarbon powered vehicles,
 in this document? If so, what are they?                                 operators/users will be reluctant to accept them.

                                                                  2.     To assist in the acceptance of alternative low carbon powered vehicles, the state requires to
                                                                         understand the nature of the barriers to the exchanges of passengers or goods between
                                                                         modes and to take steps to minimise their negative effects. Such barriers are already
                                                                         inhibiting the use of rail and water transport and their potential is not being
                                                                         realised.


                                                                  3.     In respect of a wider adoption of electric traction vehicles, the present difficulties being
                                                                         endured in the setting up of the Edinburgh light rail scheme demonstrate the existence of
                                                                         major barriers to the adoption of this form of transport. The obligations in this country for
                                                                         establishing a light rail system are the most Byzantine in Europe. It takes some 9 to 12 years
                                                                         for a UK light rail scheme to open after the first serious moves are made to go ahead with a
                                                                         proposal; the equivalent gestation period in France is 4 to 6 years."
 Question 7: Are there any negative social impacts
 associated with either the development or uptake of
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would
 the grid reinforcement upgrades be likely to present?
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any
 specific challenges or opportunities to island
 communities and sparsely populated rural areas in
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin
 approach for the public sector and other users is
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake
 of low carbon vehicles (either as a percentage of the
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the




                                                                             103
uptake of LCVs across all road users, what
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that
should be excluded from the public sector target? If
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs
than traditional vehicles (albeit with a smaller
discrepancy between lifecycle costs) do you
consider it to be efficient use of public resources to
devote a greater short-term budget towards the
purchase of LCVs? If so, why? If not, why not?
Question 17: Are there any opportunities or barriers
to public sector procurement of LCVs that are not
mentioned in this document? If so, what are they?
Question 18: What are the individual roles of different
groups and organisations in ensuring the provision
of any infrastructure required for low carbon
vehicles?
Question 19: Are there other supply side/capacity
constraints impacting on LCV development and
uptake? If so, what are they?
Question 20: Are there barriers to the development of
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on
particular vehicle types? If so, what are they and
why? If not, why not?
Question 22: Are there gaps in the supply chain? If
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders
collaborate to stimulate the development and uptake
of LCVs?




                                                          104
R48 – Individual, Irene Brandt


 RESPONDENT INFORMATION DETAILS
 Name:                                                     Irene Brandt
 Organisation:
 Address:                                                  Suilven', Rhue, Ullapool, Ross-Shire
 Postcode:                                                 IV26 2TJ
 Email:
 Telephone Number:
 Responding as:                                            An Individual
 Individual Permission:                                    Yes
 Confidentiality:                                          Yes
 Group or Organisation:                                    Not Supplied
 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       I imagine hybrid vehicles will initially have the highest uptake as these are available at present.
 do you envisage will be first to be influential in
 reducing GHG emissions from the transport sector?
 Why?
 Question 2: Which low carbon technologies and fuels       I imagine electric vehicles will have the greatest impact as, supported by an increase in renewable
 do you believe will ultimately have the greatest          electricity generation, these will produce the least greenhouse gas emissions.
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are            Don't know but reliance on oil/petrol technologies must be eliminated by 2050.
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the        Don't know but reliance on oil/petrol technologies must be eliminated by 2050.
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               Specifically to the development of biofuels from crops, it would be dangerous to remove large areas of
 development of such fuels and technologies that are       land from food production and similarly unjust to import biofuels from abroad.
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     Mainly cost, but also efficiency.
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         Specifically to the development of biofuels from crops, it would be dangerous to remove large areas of
 associated with either the development or uptake of       land from food production and similarly unjust to import biofuels from abroad.
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would      Not many technical challenges but there is a lot of opposition in some areas to the extension and
 the grid reinforcement upgrades be likely to present?     improvement to the interconnector grid. To satisfy these, it may be necessary to use underground
 How might these be overcome?                              connections.
 Question 9: Who would fund any grid upgrades?             Government funding as investment in the future. Costs are not relevant.
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any       Most present opportunities to island and isolated communities as the development of renewable energy
 specific challenges or opportunities to island            sources will go hand-in-hand with the development of sustainable transport. Grants are already
 communities and sparsely populated rural areas in         available but should be increased.
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              Yes, as long as it means that the public sector is leading the way in adopting new, appropriate
 approach for the public sector and other users is         technologies.
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake   A reduction of total emissions would be most appropriate as this, after all, is the primary aim. Also the
 of low carbon vehicles (either as a percentage of the     reduction in emissions emphasises the adoption of other ways of conducting business, transporting
 fleet or an absolute number), or a reduction in total     materials, without using vehicles at all.
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        Don't think this is the best way.
 public sector uptake of LCVs, what percentage of the
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the        Don't know.
 uptake of LCVs across all road users, what
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that        I guess ambulances and fire engines should be excluded until appropriate technologies are developed to
 should be excluded from the public sector target? If      provide swift, efficient responses.
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        Yes, but I don't know what you mean by a short-term budget. If it means that grants should be available
 than traditional vehicles (albeit with a smaller          to encourage initial uptake, yes I agree but I think they should be available as soon as possible.
 discrepancy between lifecycle costs) do you
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers      Public sector procurement ought to be an incentive to manufacturers and suppliers.
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different   Scottish Government needs to be pro-active in developing generation points for electric vehicles
 groups and organisations in ensuring the provision        throughout the country.
 of any infrastructure required for low carbon
 vehicles?
 Question 19: Are there other supply side/capacity         The car industry has been antagonistic to any developments in the past. This has to be overcome by
 constraints impacting on LCV development and              governmental incentives and encouragement.
 uptake? If so, what are they?
 Question 20: Are there barriers to the development of     No, Scotland has a rich but moribund vehicle industry. Public investment could revive and develop this
 an indigenous low carbon vehicle industry in              for LCVs.
 Scotland? If so, what are they and how might they be
 overcome?
 Question 21: Should Scotland’s industry focus on          I think the industry should concentrate on the type of vehicles which it is best suited to produce. This
 particular vehicle types? If so, what are they and        will depend on the infrastructure, technology and workforce available in specific areas.
 why? If not, why not?
 Question 22: Are there gaps in the supply chain? If       I do not have the technical knowledge to answer this.
 so, what are they and how might these be overcome?
 Question 23: Do we have the required skills base for      The central belt should be able to provide the necessary skills but the nature of some technologies on a




                                                                             105
the development of this market? If not, where are the   smaller scale could encourage development in other areas of Scotland outwith the traditional
gaps?                                                   manufacturing cities.
Question 24: How could the various stakeholders         All levels of government to provide incentives to industry and public.
collaborate to stimulate the development and uptake
of LCVs?




                                                                         106
R49 – Individual, Gordon McLean


 RESPONDENT INFORMATION DETAILS
 Name:                                                   Gordon McLean
 Organisation:                                           Gordon McLean
 Address:                                                Taxi Way, Hill End Industrial Park, Dalgety Bay, Fife
 Postcode:                                               KY11 9ES
 Email:
 Telephone Number:
 Responding as:                                          An Individual
 Individual Permission:                                  Yes
 Confidentiality:                                        Yes
 Group or Organisation:                                  Not Supplied
 Share Response Permission:                              Yes
 Question 1: Which low carbon technologies and fuels     The first technologies will be the simplest to adopt on a large scale even if they save relatively little. I would
 do you envisage will be first to be influential in      rank these
 reducing GHG emissions from the transport sector?
 Why?                                                     a. Adoption of increasing levels of biofuels – I acknowledge this is against the policy adopted in the
                                                         consultation paper.
                                                         b. Stop / start
                                                         c. Microhybrid then Mild , full and Plug- in
                                                         Why? These can be applied relatively easily given
                                                          a. the existing fuel distribution net work
                                                         b. engine technology available
                                                         c. They require no behavioural change in the short term for the user.
                                                         d. They have a large multiplier effect as the incremental cost over current technology for the end user is
                                                         zero to very low, therefore promoting early and widespread adoption. Using a household analogy, biofuels
                                                         are the equivalent to low energy light bulbs rather than covering ones roof with PV cells.
                                                         e. Use of biofuels is applicable to passenger cars both petrol and diesel as well through to the largest
                                                         HGV‟s. Other technologies, particularly battery technology, does not scale up well to heavier trucks
                                                         requiring longer ranges. This is particularly applicable in Local authority fleets where the consultation
                                                         document lists 90% of LA emissions are from HGV and LGV combined. (page 14 figure 3)
 Question 2: Which low carbon technologies and fuels     Electric vehicles for cars from nuclear generated electricity and a mix of renewable sources. Biodiesel for
 do you believe will ultimately have the greatest        heavier trucks and buses.
 emissions abatement impact? Why?                        Why? Electric vehicles for cars because
                                                         a. the technology has sufficient energy density for lighter vehicles with smaller ranges and load carrying
                                                         capacity requirements.
                                                         b. Behaviour shift is the user is possible because even now electric/ battery technology can meet the
                                                         majority of journeys. For example I travel 21 miles to work, then the car sits there for 10 hours until I return
                                                         21 miles home. It then sits there for another 13 hours until I go to work the next day. This fits ideally with
                                                         charge, drive, recharge, drive, recharge timing of current vehicles. My wife is similar- take the kids to school,
                                                         then back home 12 miles. Drive to supermarket return home 30 miles. This behaviour matches the majority
                                                         of journeys and could be met even now with the current level of electric/ battery technology.
                                                         c. I do not believe renewable sources of central power generation have sufficient reliability and energy
                                                         density to meet the needs of zero carbon electricity generation. There must be an alternative. Carbon
                                                         Capture and storage may be viable but ultimately fossil fuels will run out. Nuclear provides and option, albeit
                                                         at high risk and divisive political impact. However, it can have an impact on non transport related CO2
                                                         emissions as well as an increasing impact on transport CO2 emissions with increase electrification or by
                                                         any use of hydrogen (generated by electrolysis) as a fuel Biodiesel for heavier trucks and buses.

                                                         I believe that battery technology is so far away from being able to produce sufficient energy density for
                                                         adequate range and carrying capacity that it may never achieve the required levels. I refer to the Institute of
                                                         Mechanical Engineers papers on Low Carbon vehicles, ISBN – 978-1-84334-560-2, page 91, figure 1
                                                         showing the relative energy densities of batteries to other liquid fuels. Today the best battery technologies
                                                         are less than 1/30th the energy density of diesel. Even taking the higher conversion efficiency of battery
                                                         power circa 90% into useful work to propel the vehicle compare to diesel (30%) still leaves batteries at a
                                                         disadvantage in an order of magnitude. Other fuels such as compressed natural gas, liquid hydrogen and
                                                         compressed hydrogen are at a similar disadvantage. Although intrinsically more energy dense that
                                                         batteries, the likely conversion efficiency in an internal combustion engine, or fuel cell demotes them to a
                                                         similar level to batteries.
 Question 3: What timescales do you believe are                  a.     Biofuels – 10% - available now
 feasible for the development of specific low carbon             b.      Biofuels – 30-40 % - 2020
 technologies and fuels? Are there any important                 c.      Fully synthetic fuels – 2030
 intermediate milestones within these timescales?                d.     stop/start mild to full hybrids for cars available now
                                                                 e.     stop / start for trucks – 2011
                                                                 f.      Hydraulic regenerative braking for cars trucks and buses available now
                                                                 g.     second generation parallel hybrids 2018 h Fuel cell 2025
 Question 4: What timescales do you believe are the              a.     Biofuels – 10% - available now
 feasible for the uptake of specific low carbon                  b.     Biofuels – 30-40 % - 2022 – adoption 2 to 3 years after available
 technologies and fuels? Are there any important                 c.     Fully synthetic fuels – 2032 adoption 2 to 3 years after available
 intermediate milestones within these timescales?                d.     stop/start mild to full hybrids for cars available now
                                                                 e.     Wide spread use of second car as a small electric run around – 2015 – requires behavioural
                                                                        change in end user and acceptance of adequate range and carrying capacity. This will be
                                                                        accelerated by fossil fuel pricing.
                                                                 f.     stop / start for trucks – 2015 for wide spread adoption
                                                                 g.     Hydraulic regenerative braking for cars trucks and buses widespread adoption in stop start
                                                                        urban operations – 2015. Not applicable to long haul
                                                                 h.     second generation parallel hybrids for cars 2025 I Fuel cell 2050
 Question 5: Are there other barriers to the             Underlying efficiency improvements in the internal combustion engine that would benefit fossil, biofuels and
 development of such fuels and technologies that are     hydrogen fuels alike may be stifled by lack of investment due to the economic downturn. Over investment
 not mentioned in this document? If so, what are         and over emphasis on zero tank to wheel emissions may promote economically unviable options unlikely to
 they?                                                   achieve widespread adoption. It will be better to save say 5% over 95% of users than say 50% from less
                                                         than 1%.
 Question 6: Are there other barriers to the uptake of   While there may be early adopters of this technology in the private sector, perhaps motivated by the need to
 such fuels and technologies that are not mentioned      be seen to be green, the majority of transport emissions come from sources other than cars. Moreover,
 in this document? If so, what are they?                 certainly all cars are not private purchases and not all private purchases will be driven solely by altruistic
                                                         need to save the planet. Consequently, the decision to adopt any particular technology must stack up
                                                         economically both in terms of total cost of ownership and initial capital outlay. If the initial purchase price is
                                                         say £100,000, but it more than pays for itself in half the vehicles life – this is still no good to anyone with less
                                                         than £100,000!
 Question 7: Are there any negative social impacts       All are stated in the document – competition for land for food use / Nuclear power.
 associated with either the development or uptake of
 such technologies/fuels? If so, what are they?
 Question 8: What, if any, technical challenges would    Don‟t know How might these be overcome? Their impact would be reduced by reduced consumption and
 the grid reinforcement upgrades be likely to present?   higher efficiencies in other areas. It may be more beneficial to invest in electrical efficiency measures than
 How might these be overcome?                            to spend that money on upgrades
 Question 9: Who would fund any grid upgrades?           Through the private sector providers, and recovered through amortisation across all users of the national




                                                                            107
And, how might these costs be recovered?                  grid.
Question 10: Do any of the technologies present any       Electrification of car transport would need to be met by general grid upgrades. Fortunately, these
specific challenges or opportunities to island            communities are also typically rich in green electricity generating potential – wind and hydro for example.
communities and sparsely populated rural areas in         Coupling the need for more, carbon neutral electricity generation in these areas with facilities and
Scotland? If so, how might these challenges by            preferential rates for electric vehicle charging as a benefit to offset the impact of these “in my back yard”
addressed, and by whom?                                   may facilitate greater uptake. For example, we put a wind turbine up, you get to charge your car for free If
                                                          so, how might these challenges by addressed, and by whom? Power generating companies who ultimately
                                                          can re-coup their investment
Question 11: Do you think that having a twin              Yes If so, why? I agree with the point made in the paper that there is no point is setting “targets over which
approach for the public sector and other users is         we have no significant influence”
appropriate? If so, why? If not, why not?
Question 12: If so, should targets relate to the uptake   Total emissions across the fleet. Why? Adopting total emissions reduction across the fleet gives the
of low carbon vehicles (either as a percentage of the     maximum flexibility in achieving the targets given the diversity of number and type in the fleet. Operators
fleet or an absolute number), or a reduction in total     may choose to have fewer of the current type of vehicles, or more low CO2 vehicles for the higher
emissions across the fleets or another format of          proportion of the fleet and retain current technologies where appropriate. It is the outcome that is important
target? Why?                                              rather than the way it is achieved.
Question 13: If we follow a target relating to the        Don‟t agree this should be the target
public sector uptake of LCVs, what percentage of the
fleet should be LCVs by 2020? Please give reasons
for your answer.
Question 14: If we follow a target relating to the        Don‟t agree this should be the target
uptake of LCVs across all road users, what
percentage of all new vehicles should be LCVs by
2020? Please give reasons for your answer.
Question 15: Are there any vehicle categories that        They would not need to be specifically excluded or included if a target for an overall reduction in fleet
should be excluded from the public sector target? If      emissions was adopted.
so, what are they and why should they be excluded?
If not, why not?
Question 16: As LCVs may have higher upfront costs        Whole life cycle costs should be lower and suppliers should be able to demonstrate lower Total cost of
than traditional vehicles (albeit with a smaller          ownership over the life of the product before Local authorities should consider spending more in the short
discrepancy between lifecycle costs) do you               term (by which I think you mean before then next local election) If so, why? If not, why not? Local authorities
consider it to be efficient use of public resources to    should not subsidise potentially ineffective technologies that do not demonstrate lower total cost of
devote a greater short-term budget towards the            ownership. I think it is up to central UK government to take the risk in funding emerging technologies to
purchase of LCVs? If so, why? If not, why not?            facilitate their adoption in the market.
Question 17: Are there any opportunities or barriers      Yes If so, what are they? The adoption of a short term view in the tender process, and the over emphasis of
to public sector procurement of LCVs that are not         purchase price in the evaluation criteria. A much broader range of evaluation criteria is called for to support
mentioned in this document? If so, what are they?         the adoption of low CO2 technologies with the emphasis on lower total cost of ownership and low
                                                          embedded carbon at the point of manufacture and in delivery
Question 18: What are the individual roles of different   I would view government organisations such as the Technology Strategy Board as key facilitators in the
groups and organisations in ensuring the provision        stimulation new technology development and then in the transfer of information on viable technologies to
of any infrastructure required for low carbon             targeted markets that would be required to support them in terms of supply chain and infrastructure. I feel if
vehicles?                                                 the commercial case is made for the adoption of the technology, it will go a long way in reducing the
                                                          perception of risk. Seeing lower risk that the technology is not a dead end will stimulate provision of the
                                                          necessary support.
Question 19: Are there other supply side/capacity         There are no test and verification houses such as Mira or Millbrook that are experienced in and capable of
constraints impacting on LCV development and              the testing and verification of fuel consumption in Scotland. If technologies are to be adopted they must
uptake? If so, what are they?                             demonstrate commercial viability and real savings. Rigorous scientific testing to known standards NEDC
                                                          and FTP-75 cycles is an essential tool in demonstrating the credibility of a particular technology. Without
                                                          that credibility uptake will be patchy and subject to fads and fashion with a high risk of not meeting the
                                                          emissions reduction targets.
Question 20: Are there barriers to the development of     See 19 above
an indigenous low carbon vehicle industry in
Scotland? If so, what are they and how might they be
overcome?
Question 21: Should Scotland’s industry focus on          No If not, why not? One Particular vehicle type will not meet the requirements of the transport sector. There
particular vehicle types? If so, what are they and        is no one size fits all. For example, electric vehicles do not scale up well to HGV‟s Concentrating on one
why? If not, why not?                                     sector leaves significant development opportunity untapped
Question 22: Are there gaps in the supply chain? If       No comment
so, what are they and how might these be overcome?
Question 23: Do we have the required skills base for      No comment
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders           I would echo the answer to question 18.
collaborate to stimulate the development and uptake
of LCVs?




                                                                            108
R50 – Anonymous


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 Share Response Permission:                                Yes
 Question 1: Which low carbon technologies and fuels       Electric vehicles are the furthest into proven technology and fit with the most common journey profile in
 do you envisage will be first to be influential in        Scotland - i.e. short, urban journeys.
 reducing GHG emissions from the transport sector?
 Why?
 Question 2: Which low carbon technologies and fuels       Again, electric vehicles are effectively zero carbon and make good use of Scotland‟s already low carbon
 do you believe will ultimately have the greatest          energy generation.
 emissions abatement impact? Why?
 Question 3: What timescales do you believe are            As above, electric vehicles are in development and on the road - this process must be accelerated.
 feasible for the development of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 4: What timescales do you believe are the
 feasible for the uptake of specific low carbon
 technologies and fuels? Are there any important
 intermediate milestones within these timescales?
 Question 5: Are there other barriers to the               Cost is always a barrier to development, particularly in the case of new infrastructure requirements
 development of such fuels and technologies that are
 not mentioned in this document? If so, what are
 they?
 Question 6: Are there other barriers to the uptake of     End consumer cost
 such fuels and technologies that are not mentioned
 in this document? If so, what are they?
 Question 7: Are there any negative social impacts         Safety of electric vehicles should be considered - as they are effectively silent, there is a greater risk of
 associated with either the development or uptake of       pedestrians walking out in front of them, particularly children. Stop, look and listen doesn‟t quite work the
 such technologies/fuels? If so, what are they?            same way for electric vehicles.
 Question 8: What, if any, technical challenges would      Given the standard journey profile in Scotland, there is little need to completely overhaul the grid. However,
 the grid reinforcement upgrades be likely to present?     recharging points should be considered, perhaps linked to parking meters.
 How might these be overcome?
 Question 9: Who would fund any grid upgrades?             The govt in conjunction with the EU should fund infrastructure upgrades.
 And, how might these costs be recovered?
 Question 10: Do any of the technologies present any
 specific challenges or opportunities to island
 communities and sparsely populated rural areas in
 Scotland? If so, how might these challenges by
 addressed, and by whom?
 Question 11: Do you think that having a twin              Yes - the govt has more direct control over the public sector and they should be encouraged to show
 approach for the public sector and other users is         leadership in this area.
 appropriate? If so, why? If not, why not?
 Question 12: If so, should targets relate to the uptake   Absolutely - as a % of fleet at the very least
 of low carbon vehicles (either as a percentage of the
 fleet or an absolute number), or a reduction in total
 emissions across the fleets or another format of
 target? Why?
 Question 13: If we follow a target relating to the        The fleet should be at least 75% LCVs by 2020 - this is more than attainable and shows leadership by the
 public sector uptake of LCVs, what percentage of the      public sector.
 fleet should be LCVs by 2020? Please give reasons
 for your answer.
 Question 14: If we follow a target relating to the        New vehicle % should be 50% by 2020 - anything short of this does not have a significant impact on climate
 uptake of LCVs across all road users, what                change.
 percentage of all new vehicles should be LCVs by
 2020? Please give reasons for your answer.
 Question 15: Are there any vehicle categories that
 should be excluded from the public sector target? If
 so, what are they and why should they be excluded?
 If not, why not?
 Question 16: As LCVs may have higher upfront costs        Absolutely - transport contributes significant GHG and needs to be decarbonised. A short term financial
 than traditional vehicles (albeit with a smaller          encouragment of LCVs will start the ball rolling so to speak. An ideal opportunity would have been to place
 discrepancy between lifecycle costs) do you               low carbon criteria for new vehicles on the scrappage scheme.
 consider it to be efficient use of public resources to
 devote a greater short-term budget towards the
 purchase of LCVs? If so, why? If not, why not?
 Question 17: Are there any opportunities or barriers
 to public sector procurement of LCVs that are not
 mentioned in this document? If so, what are they?
 Question 18: What are the individual roles of different
 groups and organisations in ensuring the provision
 of any infrastructure required for low carbon
 vehicles?
 Question 19: Are there other supply side/capacity
 constraints impacting on LCV development and
 uptake? If so, what are they?
 Question 20: Are there barriers to the development of
 an indigenous low carbon vehicle industry in
 Scotland? If so, what are they and how might they be
 overcome?
 Question 21: Should Scotland’s industry focus on
 particular vehicle types? If so, what are they and
 why? If not, why not?
 Question 22: Are there gaps in the supply chain? If
 so, what are they and how might these be overcome?
 Question 23: Do we have the required skills base for




                                                                             109
the development of this market? If not, where are the
gaps?
Question 24: How could the various stakeholders
collaborate to stimulate the development and uptake
of LCVs?




                                                        110   ISBN 978 0 7559 9154 9 (web only publication)

				
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