Cleaner Air for Scotland 2 - a consultation on a draft new air quality strategy for Scotland

UKIFDA generally agrees with the action points listed,

We all agree CO2 reduction and clean air must be effectively managed, we believe that a better understanding of other countries data, weather/direction changes that can impact Scotland should be considered. This will all help to better understand how effective the Scottish measures can be from other external factors if those high risk areas are exposed.

Whilst government is heavily focused on the renewable options to resolve the clean air issue, we must not be mislead by this and any research must consider all options for in- cab and vehicle impact to health, on that basis it is important that the planned research is set up in a way to consider and ask the right questions, even for those current options, rather than be excluded.

Research should include:
Type of industry, location, type of journey, area layout and design, technology design and type of power source, even those classed as renewable for example, electric motor and battery emissions.

Evidence can suggest that renewable and those developing options rely on life cycle assessment to meet the CO2 reduction objectives, these may not have any direct benefit for Scotland.

Providing it is done in a way that considers cost impact and gives a degree of flexibility for those areas that are important to the Scottish economy.

Clear evidence has recently been seen when policies, and/or regulations come into force, local authorities may not fully understand the requirements, expanded on, regional variables and confusion.

This was seen recently when the DSR was introduced in Ireland.

Whilst we have used the above as an example 'how things can be made difficult for industry' on a positive SEPA changed legislation to incorporate Oil Storage Regulation and onward Distribution into CAR Controlled Activities Regulation, this was done by engaging with the relevant industry trade associations (UKIFDA/TSA) to ensure the correct process and legislation was correct before implementation.

On that basis Scottish Government must make sure that any integration plan is done in a way that is meaningful and interruption is clear, not left to local authorities to decide/vary. We suggest once again liaise with and work with the relevant industry body to assist in these developments.

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Technology to monitor has improved over many years. It is important industry can support the objectives of the Scottish Government for data collection

Traffic and vehicle sensors can only do so much, but don't go far enough,

We can estimate the average local travel when considering car transport for the normal consumer. However, when considering industry and haulage a more robust method of data collection should be considered based on mileage, long or short journeys, type of vehicle design, fuel types, system and usage, loaded or unloaded, return journey, engine management system data, technology retrofit or improvements, together with industry reporting of data. If this is done on a regular basis it can only help improve this position.

We should consider adopting a similar engine management, retrofit, data collect system for the agricultural sector, as already indicated in the consultation. Further discussion is need with SNFU.

UKIFDA believes when considering energy usage within the domestic sector that engagement and awareness by using various methods can only help improve public behaviour and in some cases help the most vulnerable in society and those in fuel poverty and the fuel poor, both in transport and energy.

As a trade association representing the fuel distribution industry both in transport and energy we value the importance of consumer awareness. Member and consumer engagement has been one of our objectives moving forward in the support of low carbon liquid bio-fuels for the future and the development of new non fossil based fuels.

Key to public behaviour is accurate information including installation and infrastructure costs when switching to low carbon options which must include liquid biofuels as a high percentage of Scottish homes may not be suitable for electrification, or be energy efficient. This allows those who require information can be sure that what they are given is correct to enable the right decision to be made when required. This also includes the same approach for transport.

We strongly believe liquid fuel heating does have a future and continue to encourage governments to include low carbon liquid biofuels as an option in energy policy so further industry investment and development can be undertaken.

We support plans to enable the switch from heating oil to a much more environmentally friendly liquid biofuel that cuts emissions while allowing consumers to keep their existing oil heating systems to cut costs too.

Any suggested replacement of fossil fuels with electrification does not take into account the impact this will have on off-grid households, including upfront costs and ongoing running costs.

This can be achieved in time to meet the 2050 Paris Agreement targets and in line with changes that are happening in related industries such as aviation as well as with the changes to on-grid properties. In fact, a new low carbon liquid biofuel is already being trailed in the UK so there is no reason why the Scottish government cannot support this as a decarbonisation solution.

It makes much more sense to utilise an existing full supply chain that works and simply change the liquid fuel that is distributed

UKIFDA's business strategy clearly shows our position for supporting low carbon fuels, helping Scottish Government meet targets for clean air
see below links
https://ukifda.org/resources/future-vision/

Consumer awareness:
https://ukifda.org/consumers/future-liquid-fuels/
https://ukifda.org/consumers/uk-and-ireland-home-heating-facts/

Decarbonisation plan:
https://ukifda.org/make-the-right-decarbonisation-decision-for-your-off-gas-grid-home/

Any consumer package must include a regular review, this allow the right decision to be made.

We agree with the consultation that industry emission to reduce air pollutant on a compulsory basis must be considered carefully and the impact this may cause to the economy.

If businesses decide to go beyond compliance, modern technology such as Euro 6 in transport and condensing boilers in the energy sector, linked with liquid biofuels, and/or other low carbon fuel options such as for example HVO (Hydrotreated Vegetable oil) can indeed help.
HVO link below:
https://www.neste.com/sites/default/files/attachments/neste_renewable_diesel_handbook.pdf

Trade association, OFTEC's data shows that a liquid fuel condensing boiler can run 97% efficient which meets the Energy efficiency obligation, reduce consumption by 30% in a year and for example by using fossil free fuels such as HVO in transport and other industry sectors can reduce emissions by at least 80%.

It has been independently confirmed that HVO has one of the lowest carbon intensities of all domestic heating fuels listed in SAP Table 12 – 0.036kgCO2e/kWh (for comparison Biomass is listed at 0.053 and electricity 0.233 kgCO2e/kWh).

Trials are currently taking place within the heating sector using 100% fossil free HVO to determine emissions, this also includes the rail sector..

A great deal of work has been done by the Environment Agencies to understand the true impact of transport, including noise from those non- exhaust emissions where further improvements could be made by changing people thinking, increasing awareness to this issue. UKIFDA support in principle the suggestion to investigate legislation with an aim to improve.

Whilst the construction industry has equipment based on longer life cycles than that of transport, the power source can be old euro designs, some way behind other sectors, systems should be replaced, upgraded or considered for retrofit.

Non-road mobile machinery is an area that needs carefully consideration as this can impact both business and the economy.

The latest government measures to implement changes to the type of fuel 'red diesel' BS2869 to 'white diesel' EN590 used within the NRMM sector can still promote benefits, including the use of other alternative liquid biofuel options.

These changes stand to cost the fuel industry both in cashflow and infrastructure, however this outlay is still far less than those costs associated with other alternative powered designs which is still in real time development and may not be feasible to certain sectors.

Any work or review in this field should be industry neutral when taking into act the power source, there are many different option to consider, as already indicate non fossil fuels, blends such as liquid bio-fuels, including new developing technology hydrogen/diesel mix by direct injection or blending can still reduce NOX, CO2 emissions.

UKIFDA would be more than happy to work with Scottish Government and SEPA to develop the right standard or regulation the can improve emissions in the NRMM sector.

Whilst we all agree with the targets set out in this consultation, we must consider impact to industry, develop suitable timelines for equipment improvement that can help industry and Government to move forward, this includes the use of liquid bio-fuels.

UKIFDA believes that NRMM requires different thinking and additional controls unlikely those in haulage. On that basis it would not be straightforward to simply include within the current framework without fundamental changes.

Suggest further consultation with industry should be considered before any change to legislation in this area.

We must remember that liquid biofuels can still be a cost effective option, low running and installation costs, better option to replace with a carbon neutral liquid fuel thereby reducing emissions within an acceptable timeline.

This will ensure that government plans are looking towards 2050 AND also acknowledging that 16% of homes off grid are in fuel poverty and will need a tiered approach to change and a supportive government.

A range of liquid biofuels/alternative fuel options beside oil could facilitate that transition to lower emission heating with minimal adjustment to the system but they need coordinated work and leadership.

We support plans to enable the switch from heating oil to a much more environmentally friendly liquid biofuel that cuts emissions while allowing consumers to keep their existing oil heating systems to cut costs too.

It makes much more sense to utilise an existing full supply chain that works and simply change the liquid fuel that is distributed
Key Facts
A. Carbon

• Off grid heating in the UK creates 6m tonnes of carbon emissions. Encouraging efficiencies rather than technology changes would significantly reduce that figure.
• In 2019, fellow trade association OFTEC commissioned a study through consultants In Perpetuum that showed biofuels provided the lowest cost per tonne of carbon saving compared to other technologies
• OFTEC believe that at least 400,000 boilers in the UK are non-condensing. Encouraging the update of that equipment could increase efficiency and therefore reduce emissions by around 25%. Additional efficiencies could be found in homes with new boilers through smart metering and zonal controls.

B. Costs
• Sutherland Tables suggests that the annual cost of heating a 3-bedroom home in GB based on Q3 2020 data using liquid fuel was £636 versus £1,555 for LPG and £1,793 for air source heat pump (ashp) with radiators (an ashp solution is likely to be a combination of underfloor heating downstairs and radiators upstairs)
• The cost of installing an ashp is between £9,000 and £11,000 according to the https://energysavingtrust.org.uk/advice/air-source-heat-pumps/
• The cost of a new liquid fuel condensing boiler and tank is between £3,000 and £5,000 dependant size of property and tank location. The cost of burner tweaks to accept HVO is estimated to be £500. (OFTEC - February 2020).
• 6% of oil heated homes in England were built pre-1919 and have solid walls making energy efficiency improvements dificult(OFTEC – ‘A Strategy for decarbonising oil heated homes’ May 2020)
• Hydrotreated Vegetable Oil (HVO) offers a rapid, convenient and cost-effective solution to decarbonise the existing off gas grid housing stock.

o It has been independently confirmed that HVO has one of the lowest carbon intensities of all domestic heating fuels listed in SAP Table 12 – 0.036kgCO2e/kWh (for comparison Biomass is listed at 0.053 and electricity 0.233 kgCO2e/kWh).

o Global and European production of the fuel is increasing. In 2017 the global capacity of HVO was 4.75 million tonnes. The expected capacity in 2020 is 6.8 million tonnes of which 3.87 million tonnes of installed capacity is in Europe.

o The capital cost of conversion from kerosene to HVO is around £500 (OFTEC Decarbonisation Strategy August 2020) and requires no fabric improvement to the property.
o HVO has a 90% life cycle carbon emission saving
o Running costs have been independently modelled and suggest that the annual heating and hot water running cost of a three-bedroom house would be £1,859 for an ASHP serving radiators and £1,628 if using wood pellets. A condensing boiler using rebated 100% HVO would cost £35 less per annum than an ASHP, but £196 more than using biomass. However, a fully controlled and interlocked condensing boiler would cost £24 per annum less than biomass (OFTEC Decarbonisation Strategy August 2020)


UKIFDA supports the suggestion of energy efficiency and building standard under any development plan.

It was only recently that Government were very supportive of burning wood pellets seeing this as the neutral and one of the best technology solutions to off grid home heating, now the Clean Air Strategy appears to be against burning solid fuels and wood. Our evidence backs this up. In 2017 the BBC highlighted several biomass wood pellet schemes that have been installed by housing associations under the government scheme. One particular example was at Queens Park, Bradford, Holsworthy, Devon where elderly residents experienced 39 breakdowns with a wood pellet system within a two month period. It resulted in the property becoming cold many times which was not only inconvenient but life threatening for many residents.

On that basis we can only see improvements by using suitable alternative liquid fuel options.

It is important that Government do NOT advocate technology solutions but rather set targets and allow industry and consumers to make the right choices to achieve those targets suitable for their own needs.

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Whilst the overall plan does appear to be constructive, infrastructure and roll out costs within a suitable timeline maybe a concern post COVID

It is encouraging to see Scottish Government understand the important roll liquid biofuels can have when considering fuel emissions options., on that basis UKIFDA would be more than happy to work with Scottish Government as part of this programme.

When consider vehicle and transport emissions it is important and interesting to see the data supplied by the Road Haulage Association which includes age profile

rha.uk.net/getmedia/c717f220-c8c2-4dcc-946d-656112036dfd/190426-2019-RHA-Emission-Assessment-v4a_1.pdf.aspx

This data clearly shows that licenced Euro 6 vehicles by 2025 will be 80% of HGV's planned to be low emission vehicles, if this same practice was introduced in any NRMM plan then government targets maybe heading in the right direction without major change or cost, even without further engine management technology and improved fuel specifications.

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Difficult to answer correctly as government and industry has not seen the full impact of COVID and what type of recovery plan may be required.

Would suggest further discussions with industry post COVID might be a suitable option to address these plans further .

No comments to add, looks acceptable at this stage.

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These areas may be more difficult to change to alternative fuel systems, been reliant on easy accessible options without incurring major costs to the consumer, the consumer could be of a certain age, may not have the finance to change or could be in fuel poverty or vulnerable. you cannot expect people placed in this position to change without 100% funding from government.

Property design may well be of early 1900's design, may not be energy efficient and require major improvement grants.

As stated early in this consultation surely it makes economic sense to expand the deployment of low carbon liquid fuels at very lower installation cost (£500), remain in service, but still improving air quality.

Government needs to be careful in the current climate.

The installation and running costs of electrification and the expansion of heat pump design could force homeowners further into fuel poverty, you cannot expect owners to fund the high costs of this type of heating.

Whilst we support the commitment to reduce emissions, meet the net zero target for 2050, you should not exclude other forms of heating options, we must consider all option to help the pathway to 2050.

From experience I can say heat pump performance and costs are not what they state,
I know, 'I have one' fully understand how the technology works, two year property with all the latest technology.
Not instant heat, takes two days to increase the temperature in the property.
Daily running cost is high (smart meter) even at a steady 20C
Unreliable system
Question if a standard heat pump is suitable for a 3 bed property, suggested by
manufacturer two heat pumps (really)
Doesn't work efficient in minus temperature, cannot keep the property warm.
These are just some of the points made, our concern is that you cannot expect heat pumps to work in properties that are not designed for them, that is why liquid bio-fuels can be a better option for those properties already using fossil fuels.

If we look at temperature in Scotland within the winter period and my comments above, we would have further concerns for those older and vulnerable people who may well have to use other methods to increase heat again at extra costs.

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Before implementing any proposal, further research work should be considered to full understand the true impact.

Careful consideration must be given to limit the impact of any cross board activities where transport, emissions and policy may differ.

Same Question, answer as above

No further comments relating to the Environmental report, look complete, detailed to allow the correct information to be used.

No comments at this stage

Support monitoring of the environment, no comments to add.