In November 2020, the UK Government announced as part of its Net Zero agenda the Ten Point Plan for a Green Industrial Revolution which brought forward to 2030 the date when the sale of new petrol and diesel cars and vans will end.
To further its decarbonisation aims, the Government additionally launched in July 2021 its Transport Decarbonisation Plan together with two consultations on ending the sale of new non-zero emission HGVs, and a CO2 emissions regulatory framework for all newly sold road vehicles in the UK. A third consultation on ending the sale of new non-zero emission buses is planned for later in 2021.
Ministers see the consultation on when to phase out the sale of new, non-zero emission heavy goods vehicles as part of a programme of work which ‘will put the transport sector on an ambitious but credible pathway to achieve net zero emissions by 2050.’
The proposed phase-out dates for the sale of new non-zero emission HGVs in this consultation reflect what is needed for the UK’s HGV fleet to deliver its contribution to net zero by 2050. Zero emission vehicles (those without emissions at the tailpipe) offer an opportunity to create jobs, strengthen British industry, cut emissions and keep Britain moving.
Whilst the RHA supports the aim to decarbonise HGVs, we do not believe current Government’s plans are attainable and, having taken account of the views of many logistics operators, have put forward alternative proposals.
Last month’s publication of the Sixth Assessment Report by the UN’s Intergovernmental Panel on Climate Change (IPCC) once again highlighted the need for all of us to act quickly to address the challenges posed by climate change. As we collectively consider our responses, the question the RHA has put at the centre of its thinking is not “what” nor “why”, but “how”.
We support the aim to decarbonise heavy goods vehicles. However, based on current Government plans, we have reservations on its attainability and believe the plans should be adjusted. The ramifications for the economy arising from the apparently simple question posed by the consultation of “when” are highly complex, and we note the impacts have yet to be scoped by ministers via an Impact Assessment. We also point out that HGVs account for 4.3% of overall UK greenhouse gas emissions,3 and so we look for a proportionate and coherent policy response that empowers operators to play their full part.
That said, we understand the imperative to act and our response intends to help the Government and our sector work through the issues to determine “how” CO2 emissions from the HGV fleet can be reduced sustainably.
From this starting point, we give qualified support to the Government’s proposal to split out the banning dates for “new non-zero emission HGVs” into different weight categories. As a first step, this is a sensible and pragmatic approach to take. However, we do not agree that setting the weight threshold at 26 tonnes and below from 2035 is the right way forward, as it does not adequately address the barriers-to-entry that currently impede the adoption of zero tailpipe emission HGVs.
Instead, from our assessment of the emerging technologies and initial estimate of implementation timelines, we believe the timetable for stopping the sale of new diesel HGVs should be determined by the following weight categories and dates:
a. from 2035, 18 tonnes and below
b. from 2040, 32 tonnes and below
c. from 2045, over 32 tonnes
Our assessment however comes with a significant “health warning” as it assumes the satisfactory resolution of future cost, operational and supply barriers, both known and unknown, to meet all use-cases. These dates could be brought forward if appropriate solutions to meet all types of service are provided. However, some specialist or remote area operations may need to be exempted from the ban. Our assessment should be seen as a guide to stimulate continued dialogue and planning with Ministers and officials.
We comment that, whilst we share the ambition to decarbonise at pace and strongly support technological developments to deliver it, sustainable implementation is not yet apparent. Splitting out the banning dates is heavily dependent on whether the new alternative technology can be applied successfully in all use cases in the weight categories. The operational capabilities and limitations of the emerging technologies are not yet fully understood, and government policy must cater for these technical risks.
We make two further starting observations. First, there is a substantial gap in the analysis presented in the consultation document. Nowhere does it outline the Government’s intentions regarding the diesel fleet that is put on the road before any phase-out bans apply. If ministers intend to ban the use of any part of the diesel HGV fleet before or after 2035, they should say so. It can be interpreted from the consultation document that the Government intends to ban all diesel or fossil-fuelled HGVs from operation from 2050, but the Government has not said so. We believe that all HGVs should be given a minimum guaranteed operating life of at least 15 years before facing bans, penalties, or supplementary charges.
Secondly, there is a bias in the consultation document towards electric drivetrain solutions4 which excludes plausible and pioneering alternative technology options, such as hydrogen combustion and net zero fuels. This should change so that all technology options that allow Net Zero targets to be achieved are within scope.
With this in mind, we have three core messages for ministers:
• for net zero to succeed, all types of operation and HGV use must be accommodated so that all parts of the economy and all types of supply chain are catered for;
• considerable market uncertainty exists with operators currently having insufficient information available to make informed choices. This must be managed in an agile way, with ministers regarding this consultation as the first in a series of conversations with our sector to navigate flexibly the many issues that lie ahead. We particularly flag that ministers must give clear guidance on how unavoidable emissions are offset;
• the whole vehicle lifecycle must be central to decision making so that all owners of any vehicle bought before the new vehicle bans are introduced are able to benefit from its utility and a full known economic lifespan. Central to this is sustaining asset values so that all businesses, including our vital SME sector, have the standard financial tools intrinsic to any business available to manage natural vehicle replacement cycles.
To assist the certainty our sector needs to plan their vehicle fleet replacement programmes, we have sent a policy proposal for ministers to consider which, if implemented, sustains asset values so that a sustainable transition to Net Zero is achieved. We also set out in our response a further six recommendations to shape the development of the supporting policy framework that achieves Net Zero targets.