Low Emissions Vehicle Strategy West Midlands Low Emission Towns & Cities Programme (LETCP) 2016 – 2021

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The LETCP has been promoted by traditional Environmental Health Services with the support of local authority officers involved in transportation & travel planning; land-use planning and development control; procurement; fleet management; taxi licensing; parking and traffic enforcement, together with cooperation from public health specialists and the West Midlands Combined Authority.

The West Midlands LETCP acknowledges the assistance provided by Andrew Whittles, Low Emission Strategies Ltd., in developing and supporting the work of the LETCP.

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Contents Page

Low Emissions Towns & Cities Programme (LETCP) 6

Foreword 7

Executive Summary 8

Aims & Objectives of the Low Emissions Vehicle Strategy 12

1 Introduction 14

2 Evidence for Change 17

- Air Quality & Vehicle Emissions in the West Midlands 17

- Low Emission Zone Technical Feasibility Study 19

- Health Impacts of Air Pollution 21

- Legal Compliance 24

3 Creating a Low Emission Future 26

- Land-use Planning and Development Control 26

- Public Sector Procurement 28

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- Taxi Licensing 30

- Travel Planning 32

4 Low & Ultra Low Emission Vehicles & Infrastructure Measures 32

- European Emission Standards (Euro Standards) 33

- Total Cost of Ownership (TCO) 35

- Clean Air Zones (CAZs) 35

- Transport Emissions Framework (TEF) 37

- Cars and Light Goods Vehicles 38

- Taxis 41

- Buses 42

- Freight 45

- Low Emissions Vehicle Infrastructure 45

5 Future Challenges & Opportunities 47

Glossary 49

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Figures Page Figure 1 Emission Reduction Progression 14 Figure 2 Low Emission Strategy Drivers, Policy Areas, Stakeholders & Outcomes (adapted from WYLES) 16 Figure 3 Nitrogen dioxide concentrations across the West Midlands (2011) 17 Figure 4 Low Emission Zone Technical Feasibility Study 20 Figure 5 Percentage of Deaths attributable (<75 yrs) to PM2.5 22 Figure 6 Development Classification Mitigation 27 Figure 7 Suggested Clean Air Zone Standard for Taxis 31 Figure 8 European Emissions Standards (passenger cars) 33 Figure 9 Real World NOx Emissions from Diesel Cars compared with Regulated Limits 33 Figure 10 European Emission Standards for Heavy Duty Engines (ICCT 2015) 34 Figure 11 Performance of heavy duty engines against Euro 34 Figure 12 TCO of ULEV and diesel taxis 41 Figure 13 Emission damage costs of ULEV and diesel taxis 41 Figure 14 Relative emissions of buses per Euro Standard and Euro III retrofit (blue = NOX) 43 Figure 15 NOx emissions of the West Midlands bus fleet (tonnes NOx) - baseline scenario 44 Figure 16 Bus routes or streets to prioritise for deployment of Low Emissions Buses 44

Tables

Table 1 Source apportionment of NOx emissions at selected locations as a percentage of total vehicle emissions (examples) 19 Table 2 Current and predicted health impacts of NO2 in the West Midlands 23 Table 3 Limit Values & Target dates for NO2 and PM compliance 25 Table 4 World Health Organisation (WHO) Air Quality Guideline Values 25 Table 5 Tender evaluation criteria 30 Table 6 Clean Air Zone Classes 35 Table 7 Clean Air Zone emission standards for vehicle types in Birmingham 36 Table 8 Total Cost of Ownership (TCO) of selected diesel, petrol, hybrid and electric cars 39 Table 9 Plug-in vehicles (cars and light vans) by local authority area 40 Table 10 Current and projected fleet emission breakdown in 2015 and 2020 (normal fleet replacement) 42

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Low Emissions Towns & Cities Programme (LETCP)

A proposed Low Emissions Vehicle Strategy (LEVS) for the West Midlands has been developed by the Low Emission Towns & Cities Programme (LETCP), comprising the seven West Midlands Local Authorities:

* Birmingham City Council * Coventry City Council * Dudley Metropolitan Borough Council * Sandwell Metropolitan Borough Council * Solihull Metropolitan Borough Council * Walsall Metropolitan Borough Council * Wolverhampton City Council

The LETCP was established in 2011 and funded through the Defra Air Quality Grant scheme to enable collaborative work across the West Midlands region in tackling the principle cause of air quality problems - namely road vehicle emissions. The LETCP seeks to compliment and integrate local strategies to focus on improving vehicle emissions through the acceleration in take-up of cleaner vehicle fuels and technologies. The Programme seeks to secure win-win scenarios by promoting measures that not only improve air quality, but concurrently reduce road transport congestion, emissions of carbon dioxide and noise. The LETCP is governed by a Programme Board chaired by Walsall Metropolitan Borough Council and includes air quality representatives of all seven West Midland Local Authorities. The Programme consists of four main work-streams led by specified local authorities:

 West Midlands Low Emission Strategy (Walsall MBC)  Good Practice Planning Guidance (Dudley MBC)  Good Practice Procurement Guidance (Coventry CC)  Low Emission Zone Technical Feasibility Study (Birmingham CC)

Reports produced by the LETCP are available at: http://cms.walsall.gov.uk/low_emissions_towns_and_cities_programme

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Foreword

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Executive Summary

The West Midlands, as with any major conurbation around the world, experiences elevated levels of air pollution in urban centres and notably in the vicinity of the strategic and key route road networks. Levels of nitrogen dioxide (NO2) exceed the health-based National Air Quality Objective and European Union (EU) Limit Value in a range of locations and, with the exception of Solihull, all of the Metropolitan Councils have designated

Air Quality Management Areas (AQMAs) relating to ambient nitrogen dioxide concentrations. Although particulate matter (PM10) concentrations do not currently breach specific UK Air Quality Objectives and Limit Values, it is acknowledged that reducing concentrations will have significant health benefits.

The overriding cause of poor air quality is due to emissions from road transport, and in particular diesel vehicles. Whilst vehicle emissions are progressively reducing, they are not improving quickly enough to tackle the problems we face and action is therefore needed to speed up the transformation of the vehicle fleet; this can often also provide financial benefits to vehicle users and operators.

It is recognised that pollution does not respect boundaries and therefore the West Midlands Low Emission Towns & Cities Programme (LETCP) was established to promote further joint working between councils to improve air quality. The LETCP acknowledges that there are no quick, simple measures for tackling air quality problems, and co-ordinated activity is required to develop policies and measures that are capable of influencing continued emission reductions that will not only improve air quality, but create a low emission future that is needed to mitigate global warming. A commitment to jointly tackle air quality also now forms part of the West Midlands Combined Authority ‘Devolution Deal’, signed by the leaders of the seven Metropolitan Borough Councils.

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The Low Emissions Vehicle Strategy (LEVS) forms part of the newly adopted West Midlands Strategic Transport Plan “Movement for Growth”1, which will be implemented by the West Midlands Combined Authority (WMCA)2.

The LEVS comprises three main themes that are outlined below.

Evidence for Change

This section details the evidence base for action in the West Midlands, including:

- Details of current and future air quality across the West Midlands, including assessments of the technical feasibility of Low Emission Zones (LEZ) in the West Midlands and further consideration of the introduction of mandated and voluntary Clean Air Zones (CAZs) - Information regarding the health impact that air pollution levels have on the residents of the West Midlands - An outline of legal requirements to improve air quality

Creating a Low Emission Future

This discusses local authority policy developments to support current and future low emission activity, including:

- Good practice land-use planning guidance which encourages air quality mitigation to be considered at design stages, measures to support low and ultra low emission vehicle usage and an innovative approach of using damage costs to evaluate the scale and kind of mitigation necessary to make major schemes acceptable - Good practice procurement guidance which promotes innovative approaches to local authority vehicle procurement and mechanisms to ensure that general procurement is both sustainable and considers social value - Licensing measures to promote the uptake of cleaner cars and taxis

1 https://westmidlandscombinedauthority.org.uk/media/1178/2016-06-01-mfg-full-document_wmca.pdf 2 WMCA replaced the ITA and Centro/PTE on the 17th June 2016 9 PROPOSED – OCTOBER 2016

- Travel planning measures that consider improving the emissions of the vehicle fleet in addition to existing initiatives promoting sustainable modal shift

Low & Ultra-Low Emission Vehicles and Infrastructure

The LEVS focuses on vehicle emissions, embracing new, cleaner vehicle technology - much of which has been developed within the West Midlands region - and specifically promotes the use of low & ultra-low emission vehicles. It outlines issues with current vehicle technologies and highlights how successive European Emission Standards3 have not performed as well in the real world as had been originally indicated. The Strategy examines how low and ultra-low emission vehicles can provide savings for drivers and operators compared with standard vehicle technologies.

The West Midland Metropolitan area has seen the fastest growth in plug-in vehicles in the UK and current vehicle registrations account for just over 10% of the UK total of 60,204 vehicles, with Birmingham having by far the most plug-in vehicle registrations in any local authority area. This growth is supported by charging infrastructure developed as part of the Plugged in Midlands Programme and also through requirements for new developments to provide infrastructure. These measures will help support the Government’s commitment that nearly all new cars and vans will be zero emission capable by 2050.

As part of the Government’s plans to improve air quality, Birmingham is also legally bound to introduce a Clean Air Zone (CAZ) by 2020 or sooner. The CAZ will require that taxis, vans, lorries and buses entering the Zone meet the latest European Emission Standard or otherwise pay a fine. The LEVS references the CAZ measures and how other authorities may also implement a CAZ in line with the forthcoming National Clean Air Zone Framework and through the emerging Tackling Transport Emissions Framework (TEF).

The TEF initiative was approved by the Integrated Transport Authority (ITA), including all seven Metropolitan Council Leaders on the 28th January 2016 and forms part of the West Midlands Strategic Transport Plan. It includes measures that will be developed in 2016/17 and implemented by

3 https://en.wikipedia.org/wiki/European_emission_standards 10 PROPOSED – OCTOBER 2016

the WMCA through task and finish groups supported by the LETCP. Whilst the scope of some of the TEF measures relate to wider modal shift initiatives, key measures that form part of the scope of the LEVS include:

 Developing and adopting agreed metropolitan wide policies and targets towards the accelerated uptake and adoption of Ultra Low Emissions Vehicles and associated infrastructure (including hydrogen and gas refuelling opportunities);  Developing and adopting agreed metropolitan wide policies and actions for Low Emission Zones or Clean Air Zones - in specific and suitable locations;  Accelerated timescales to clean up buses through the West Midlands Bus Alliance and the West Midlands Low Emissions Bus Delivery Plan;  Developing and adopting Metropolitan policies and targets for the cleaning of vehicle emissions in respect of public and commercial fleets;

 Developing targeted policies toward zero emissions taxi and private hire fleets;

 Exploring the development of Low Emission Neighbourhoods and Green Travel Districts (GTD); and

 Developing an agreed funding, development and delivery framework

The LEVS outlines a five year plan to reduce road traffic emissions and improve air quality and health outcomes. The Strategy measures will be monitored and reviewed and the data used to inform and update the LEVS. The LEVS also recognises that appropriate planning beyond the timescales of this Strategy is required to evaluate and secure investment for alternatives to fossil fuel technologies. The LEVS discusses the vision beyond 2021 in line with the Strategic Transport Plan horizons to 2035, outlining opportunities and barriers. To this extent, the LEVS promotes and recognises the Birmingham Blueprint for Low Carbon Fuels Infrastructure and the West Midlands Low Emission Bus Delivery Plan.

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AIMS & OBJECTIVES OF THE LOW EMISSIONS VEHICLE STRATEGY

- Improve air quality across the West Midlands by reducing vehicle emissions through the accelerated uptake of cleaner fuels and technologies

- Embed an innovative approach to vehicle emission reduction through joint working and integrated policy development and implementation of the agreed policies.

OBJECTIVES By Who By When

1 General

1a Ensure effective joint working within the Combined Authority & between other supporting organisations LETCP/WMCA Ongoing to improve air quality across the West Midlands through a LEVS 2 Evidence for Change

2a Develop a robust framework for monitoring and mapping of air quality and emissions for the West LETCP/WMCA Ongoing Midlands 2b Undertake a Low Emission Zone Technical Feasibility Study of selected locations in the West Midlands LETCP Completed

2c To work with local health professionals in order to promote and further develop awareness of the health Public Health/ Ongoing impacts of vehicle emissions, and to procure additional air quality data and information relevant to aid and LETCP inform public health initiatives

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3 Creating a Low Emission Future

3a Produce planning guidance to secure mitigation of vehicle emissions through scheme design and off-set LETCP Completed mitigation for major developments, including supplementary planning documents 3b Produce procurement guidance to promote vehicle emission reductions through purchasing decisions LETCP Completed

3c Update licensing standards to promote low and ultra-low emission taxis Councils/WMCA Ongoing

3d Update travel planning guidance to promote and support the uptake of ultra-low emission vehicles Councils/WMCA Ongoing

4 Low & Ultra-Low Emission Vehicle & Infrastructure Measures

4a Raise awareness of the impact of vehicle emissions and promote the benefits of low emission WMCA/Councils Ongoing alternatives 4b Implement Clean Air Zones where required Birmingham/ Ongoing WMCA/Councils 4c Develop and implement an effective Transport Emissions Framework to improve vehicle emissions WMCA/LETC Ongoing

4d Develop and implement an Ultra-Low Emission Vehicle Infrastructure Plan for the West Midlands WMCA/Councils Ongoing

5 Future Challenges and Opportunities

5a Monitor implementation of LEVS measures and evaluate success against agreed criteria WMCA/LETCP Ongoing

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1 INTRODUCTION

1.1 The West Midlands comprises three cities and several major towns, forming one of the largest urban conurbations in the UK. As industrial emissions have subsided they have been replaced with vehicle related pollution, exacerbated to some extent by the position of the West Midlands being situated at the cross-roads of the national strategic motorway network. The West Midlands Low Emissions Towns and Cities Programme (LETCP) was thus established in 2011 with funding support from DEFRA’s4 Air Quality Grant scheme to promote a collective approach to reducing road transport emissions essentially through the development and implementation of innovative policies and measures, with an aim to create a Figure 1: Emission Reduction Progression consistent approach to air quality action planning across the region.

1.2 In certain locations levels of nitrogen dioxide (NO2) have remained stubbornly elevated over the last decade as action to improve air quality has stuttered for several reasons.

Firstly, over-optimistic predictions of future air quality have encouraged the belief that matters would simply improve on their own as newer vehicles, which are required to meet more stringent emission standards, enter the fleet. Evidence has shown however that many new vehicles emit far more oxides of nitrogen (NOx, a precursor for NO2) in real-world driving compared to manufacturers’ tests (https://www.gov.uk/government/publications/vehicle-emissions-testing-programme-conclusions).

Secondly, national transport and travel planning guidance has tended to focus on measures to avoid using vehicles and shifting to sustainable modes of transport as a principal approach to help solve air quality problems. The Low Emission Strategy (LEVS) acknowledges that we can go

4 Department for Environment, Food and Rural Affairs 14 PROPOSED – OCTOBER 2016

further and promotes an emission reduction progression that also seeks to improve the emissions of the vehicle fleet, whereby the LEVS compliments transport and travel planning (Figure 1).

Thirdly, there has been an increase in focus on reducing carbon emissions with some measures adversely affecting air quality. Central Government has encouraged diesel car sales through reduced Vehicle Excise Duty (VED)5 with sales increasing from 20% of cars bought to 60% 6 within 15 years . It is now known that even the newest diesel cars can emit significantly more NOx than petrol cars (and in some cases certainly more than the manufacturer’s tests claim).

While transport and travel planning plays a major role in potentially improving air quality, local authorities can make use of wider policy areas, including land-use planning and procurement practices to support the accelerated take-up and use of low emission vehicles that also have the potential to provide an enhanced platform for inward investment.

1.3 Working together, the LETCP and West Midlands Combined Authority (WMCA) have acknowledged these issues and the LEVS forms part of the new West Midlands Strategic Transport Plan (STP) – “Movement for Growth”. As part of the delivery mechanism for the STP and LEVS a Transport Emission Framework (TEF) is being developed, aimed at designing and implementing policies and measures to improve vehicle emissions, not only for the benefit of air quality but also to reduce carbon and noise emissions. The LEVS outlines key vehicle-specific measures that will be taken forward through the TEF. The LEVS so offers an over-arching framework of vehicle emission reduction activity to be delivered through an integrated policy approach. Figure 2 below illustrates this approach, highlighting the drivers, policy areas, key stakeholders and potential outcomes of the LEVS.

1.4 The West Midlands LEVS is one of the first emerging strategies of its kind in the UK and has been developed in parallel with the work of other local authorities, including Bradford and West Yorkshire Councils. Defra`s Plans to Improve Air Quality7 recognise the approach taken by

5 https://www.gov.uk/government/publications/vehicle-excise-duty 6 www.smmt.co.uk 7 https://www.gov.uk/government/publications/air-quality-in-the-uk-plan-to-reduce-nitrogen-dioxide-emissions 15 PROPOSED – OCTOBER 2016

the West Midlands and others and states, “As a minimum we expect all local authorities with areas currently exceeding the required (nitrogen dioxide) levels to consider putting in place a Low Emission Strategy. Such a Strategy could be used to set out a range of commitments and actions to tackle pollution as part of a coherent multi-year programme and ensure they identify and exploit the national assistance available.”

Figure 2: Low Emission Strategy Drivers, Policy Areas, Stakeholders & Outcomes (adapted from WYLES) Drivers Policy Areas Stakeholders Outcomes

Combined Authority/Local Authorities Improved Air Quality

Public Health Local Enterprise Partnerships Cleaner Transport Business & Commerce Carbon Transport Passenger Transport Improved Health Outcomes Development Highways England Spatial Planning Low Green Economy Planning Authorities Emissions Air Quality Economic Growth Vehicle Public Health Strategy Sustainable Development

Legal Obligations Environmental Health

Local Authority Solicitors Social Value Procurement Noise Procurement Public Sector Procurement Legal Compliance Climate Change Sustainability / Climate Change Officers

Carbon Reduction Local Residents

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2 Evidence for Change

Local air quality review and assessment across the West Midlands demonstrates a clear need to redress road transport emissions, the extent and scope for which has been evaluated under the LETCP initiative.

2.1 Air Quality & Vehicle Emissions in the West Midlands

Figure 3: Nitrogen dioxide concentrations across the West Midlands (2011)

With the exception of Solihull, all West Midlands local authorities have designated their whole districts as Air Quality management Areas (AQMAs) due to relevant exposure to annual average levels 8 of NO2 that breach both the Government Objective and the EU 9 3 Limit Value . Levels of NO2 in some areas exceed 60 µg/m set against the Government Objective of 40 µg/m3.

Whilst there are no locations in the West Midlands that currently 10 exceed the Government Objective/EU Limit Value for PM10 , it is acknowledged that significant health benefits can accrue from generally reducing particulate concentrations further in tandem with reductions in NO2. New aims to reduce urban background

8 The Air Quality Standards Regulations 2010 9 EU Ambient Air Quality Directive (2008/50/EC) 10 Particulate matter equal to or less than 10 microns in size 17 PROPOSED – OCTOBER 2016

11 levels of PM2.5 linked to the Public Health Outcomes Framework Healthy Lives; Healthy People have been introduced by the Government’s 2016 Local Air Quality Management Policy Guidance (PG16), recognising the significant impact that poor air quality can have on health. The specific Public Health Outcomes Framework Indictor for PM2.5 is intended to enable Directors of Public Health to prioritise action on air quality in 3 conjunction with a role for local councils. It is known that concentrations of PM2.5 exceed the World Health Organisation (WHO) 10 µg/m PM2.5 target level of at a number of locations in the West Midlands and local councils are expected to work towards reducing emissions and concentrations of PM2.5 alongside tackling other pollutants. The WHO also states that there is no evidence for of a safe level of exposure or a threshold below which inhalable particulate matter has no adverse health effects occur.

Further information on air quality levels in the West Midlands can be found on the websites of each of the West Midlands Metropolitan Boroughs and there is an underlying ambition to develop a new website for the West Midlands to provide access to air quality information and data.

LETCP source apportionment assessments have confirmed vehicle emissions are the most significant cause of elevated NO2 levels, with road transport emissions contributing up to 50% of measured concentrations at certain locations and also playing a significant role in background 12 concentrations . Table 1 shows the source apportionment of NOx emissions at selected areas by vehicle type. It can be seen that cars and light goods vehicles (LGV), particularly diesels, are significant contributors on all roads with heavy goods vehicles (HGVs), making substantial contributions on key trunk roads and tmotorways. Bus emissions become more significant in the urban centres. It was also found that light duty diesel vehicles (cars and LGV) provide the most significant source of primary NO2 emissions.

National studies show that road transport is the most significant source of fine particulate matter in urban areas. Vehicle emissions, including brake and tyre wear, account for over 25% with non-road mobile machinery (NRMM e.g. construction plant) contributing a further 11%13.

11 Particulate matter equal to or less than 2.5 microns in size 12 LETCP Low Emission Zone Technical Feasibility Study, Ricardo AEA, 2015. See - http://cms.walsall.gov.uk/low_emissions_towns_and_cities_programme 13 DEFRA 2012 18 PROPOSED – OCTOBER 2016

Table 1: Source apportionment of NOx emissions at selected locations as a percentage of total vehicle emissions (examples)

Percentage of Emissions (%)

Specific Location Petrol Cars Diesel Cars Petrol LGV Diesel LGV Rigid HGV Artic. HGV Bus & Coach A38 Children’s Hospital, 19 39 1 18 10 5 9 (Birmingham CC) Bearwood Road (Sandwell) 12 29 0 14 7 1 37 Yew Tree housing estate, J8, 7 19 1 15 9 48 2 M6 (Sandwell) Windmill Hill, Cradley (Dudley 10 25 0 11 24 9 21 MBC) Dudley St, Oldbury (Sandwell 9 21 0 16 15 12 27 MBC) Wolverhampton Road, 11 25 0 14 19 21 10 (Walsall MBC) Ball Hill (Coventry CC) 16 36 0 11 12 3 22 Halesowen Road, Netherton 9 23 0 17 18 10 22 (Dudley MBC)

2.2 Low Emission Zone Technical Feasibility Study

A key work-stream of the LETCP has been to carry out a Low Emission Zone Technical Feasibility Study (LEZ TFS). The study considered several locations across the West Midlands that could illustrate transferable models for introducing a LEZ. Figure 4 below shows the general locations of the study areas selected. These reflected urban areas, trunk roads, bus corridors and the M6/M6 Toll motorways.

19 PROPOSED – OCTOBER 2016 Figure 4: Low Emission Zone Technical Feasibility Study Areas For each study area scenarios based on selected emission standards for different vehicle types were modelled for their impact on emissions of NOx, PM and CO2 and concentration changes in NO2. For some scenarios it was clear that introducing a LEZ for key vehicle types would displace traffic and cause problems elsewhere, although for 3 of the study areas - Bearwood Road, Birmingham City Centre and the M6/M6 Toll motorways - a full cost benefit analysis (CBA) and an assessment of the impacts on health were carried out.

The Bearwood Road and Birmingham City Centre LEZ scenarios included access criteria based on emission standards for certain vehicle types – this showed that certain criteria have the potential for reducing NO2 concentrations significantly. The M6/M6 Toll scenario looked at options for diverting traffic transiting the West Midlands from the M6 and onto the M6 Toll

(around 25% of M6 traffic). This scenario demonstrated that concentrations of NO2 at residential properties in Walsall could be reduced by 3 around 3 µg/m . Upgrading bus emissions on the Bearwood Road would help meet the UK and EU legally required NO2 levels. 20 PROPOSED – OCTOBER 2016

For most of the scenarios it was found the costs of implementing LEZ, including the costs of upgrading vehicles and paying motorway toll costs, outweighed the air quality benefits. It should be noted however that damage costs used in the CBA have since been revised significantly upwards. This revision has, for example, shown that the benefits of introducing natural gas and bio-methane (CNG/CBG) buses and liquid petroleum gas fuelled taxis in Birmingham City Centre outweighed the costs.

In 2015 Birmingham City Council installed automatic number plate recognition (ANPR) cameras to study the vehicle types and emission standards of vehicles accessing the City and is currently working with Defra on the scope of a Clean Air Zone (CAZ) for the centre of Birmingham. Sandwell MBC is also looking in more detail at the potential to introduce a CAZ on the Bearwood Road. For further information on CAZs see section 4.3.

In 2016 it was announced that the (loss-making) M6 Toll Road was marketed for sale, thereby presenting a regional / national opportunity for the government & West Midlands Combined Authority to see better utilisation of the M6 Toll, as well as the better integration with the wider Strategic Highway Network.

2.3 Health Impacts of Air Pollution

Latest estimates by the Royal College of Physicians and Royal College of Paediatrics and Child Health (February 2016)14 indicate about 40,000 UK early deaths a year in the UK are attributable to outdoor air pollution. Prior to this, the death toll from air pollution had usually been estimated at around 29,000 deaths per annum based on PM2.5 which had not factored in the combined impacts of NO2 and particulate matter (as PM2.5). The annual cost to society of health impacts from exposure to air pollution exposure is of the order £25.3bn to £27.9bn15

14 www.rcplondon.ac.uk/projects/outputs/every-breath-we-take-lifelong-impact-air-pollution 15 Tackling nitrogen dioxide in our towns and cities, UK overview document, DEFRA, December 2015, 21 PROPOSED – OCTOBER 2016

16 Figure 5 illustrates the percentage of deaths attributable to PM2.5 across the West Midlands region in 2010 . Although levels of particulate pollution across the region meet EU Limit Values, there are significant health benefits in reducing particle levels as low as possible. The Public 15 Health Outcomes Framework includes fine particulates (PM2.5) as an indicator for health and all West Midland Metropolitan Borough & City Councils are committed to working in partnership to reduce levels.

Figure 5: Percentage of Deaths attributable (<75 yrs) to PM2.5

Table 2 below shows some of the health impacts that current and predicted NO2 levels are estimated to cause across the West Midlands11. It can be seen that health improvements are expected as air quality improves, and also illustrates that there are significant health impacts expected in the future at levels that meet current Government Objectives.

16 http://www.phoutcomes.info/ 22 PROPOSED – OCTOBER 2016

Table 2: Current and predicted health impacts of NO2 in the West Midlands

Deaths per year Prevalence of chronic bronchitis in Respiratory hospital Local Authority Areas attributable to nitrogen asthmatic children admissions per year dioxide air pollution 2011 2018 2026 Base Reduction 2011 2018 2026 2011 2018 2026 Birmingham 371 175 59 9,055 0 525 873 774 648 563 Coventry 70 21 4 2,209 0 101 164 200 171 152 Dudley 72 21 3 2,239 0 101 166 195 166 148 Sandwell 147 71 22 2,411 0 155 252 231 191 165 Solihull 62 24 7 1,516 0 80 130 138 116 102 Walsall 107 43 10 2,091 0 133 215 193 158 136 Wolverhampton 78 29 7 1,800 0 90 147 165 139 123

All West Midlands districts 906 383 112 21,322 - 1,184 1,946 1,896 1,589 1,388

Studies show that the adverse health effects from short and long-term exposure to air pollution include:  Increase in deaths from cardiovascular and respiratory diseases (COMEAP 2009 Long-term exposure to air pollution: effect on mortality)  Increase in coronary events, including myocardial infarction and ischaemic heart disease17  Increase in low birth weight babies (<2500g)18  Increase in childhood asthma development and wheeze19 and inhibits neurological development in children20 (it is thought that particulates pass through the olfactory system into the brain where they prevent normal synapse development)  Inhibits lung function in children, permanently affecting lung capacity (http://www.escapeproject.eu/publications.php)

17 Cesaroni, BMJ, 2014 18 Pederson, Lancet, 2013 19 Takenoue, Paediatrics Int, 2012 20 Jordi Sunyer, CREAL, PRBB group leader, 18 June 2014 23 PROPOSED – OCTOBER 2016

In 2013 the World Health Organisation (WHO) classified diesel exhaust emissions as carcinogenic to humans with evidence linking air pollution with a range of cancers21 (lung and bladder in particular).

The LETCP will continue to work alongside Public Health professionals to demonstrate the effects and raise awareness of the impacts of vehicle emissions on health across the Region and support relevant work streams set out in the Public Health Outcomes Framework.

2.4 Legal Compliance

The West Midlands has the most extensive areas in the UK exceeding the National Air Quality Objective and EU Limit Value (annual average) for

NO2 outside of London, and although local authorities have a duty to pursue Government Air Quality Objectives (AQOs), they are not legally bound to meet the AQOs. A failure to meet the EU Air Quality Limit Value for NO2 led to infraction proceedings against the UK on behalf of the EU. Whilst the reserve powers under the Localism Act 201122 allows for EU fines to be passed on to public authorities “whose act or omission” contributed to a breach of EU law, the implications of this following the UK’s referendum vote to leave the EU are as yet unknown.

In 2015 the Supreme Court ruled that the Government was acting illegally in failing to meet the EU Limit Value for NO2 and ordered the Government to produce a robust plan to improve air quality. In December 2015, Defra published plans to improve air quality – ‘Tackling nitrogen dioxide in our towns and cities’15. The plans include a mandated requirement that 5 cities outside London, including Birmingham, should introduce Clean Air Zones (CAZ) to improve air quality as soon as practicable and by 2020 at the latest (see section 4.3).

Given the EU referendum vote it is unclear as to what Air Quality Limit Values will be retained. The main driver to improve air quality is public health and the Limit Values (Table 3 below) are health based and correlate with the World Health Organisation (WHO) Air Quality Guideline

Values (Table 4 below) for NO2, whereas the WHO recommends lower concentrations for particulate matter than the EU Limit Values. It is important that going forward, the UK continues to work towards achieving and going beyond health based limits on air pollution concentrations and the LETCP would express serious concern should future standards be relaxed.

21 http://www.iarc.fr/en/media-centre/iarcnews/pdf/pr221_E.pdf 24 PROPOSED – OCTOBER 2016

Table 3: Limit Values & Target dates for NO2 and PM compliance

Table 4: World Health Organisation (WHO) Air Quality Guideline Values

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3 Creating a Low Emission Future

This section outlines some of the key policy areas that can be used to support the uptake of cleaner vehicles to help improve air quality and help shape the West Midlands as a place with a greener future.

3.1 Land-Use Planning and Development Control

The LETCP has produced innovative Good Practice Guidance22 for considering air quality and road transport emissions as part of the land-use planning and development control regime. The planning system in England has been reformed over recent years with the introduction of the National Planning Policy Framework (NPPF)23. The NPPF recognises air quality as a material consideration in the planning process and also introduces a presumption that planning approval will be granted for sustainable development. The LETCP Planning Guidance seeks to define what is meant by ‘sustainable’ in air quality terms in order to provide consistency and clarity to both local authority officers and developers alike.

In recognising that air quality is a material planning consideration the NPPF requires planning policy to contribute to the achievement of national objectives or EU Limit Values, taking into account Air Quality Management Areas and Air Quality Action Plans. The LETCP Planning Guidance provides a template for West Midland Authorities to update their Air Quality Action Plans with respect to planning decision making. The Black Country Councils have subsequently produced a Supplementary Planning Document (SPD)24 based on the guidance. A key consideration in the NPPF is the cumulative effect of ‘emissions creep’ - the LETCP Guidance seeks to simplify assessment and mitigation procedures through a standardised development scheme classification relating to potential impact, whilst recommending the types of appropriate and reasonable mitigation measures that should be designed into each scheme classification. A summary of this approach is shown in Figure 6.

22 www.legislation.gov.uk/ukpga/2011/20/contents/enacted 23 https://www.gov.uk/government/publications/national-planning-policy-framework--2 24 Black Country Air Quality Supplementary Planning Document, September 2016 26 PROPOSED – OCTOBER 2016

Figure 6: Development Classification Mitigation

By incorporating mitigation measures into scheme design as standard, it is envisaged that this approach can help counteract any associated effect on air quality including incremental emissions creep, inherent with many development schemes. The LETCP Guidance provides advice where exposure is likely to be an issue and possible ways in which this may be mitigated.

A key theme of the NPPF is that developments should enable future occupiers to make green vehicle choices, stating that low emission vehicle infrastructure, including electric vehicle (EV) re-charging, should be provided. The LETCP Guidance provides consistent EV re-charging standards for new developments in the West Midlands as Type 1 mitigation.

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For medium class developments Type 2 mitigation should be incorporated into scheme design where appropriate, in addition to Type 1. Type 2 mitigation includes commercial fleet emission standards and use of ultra-low emission service vehicles. For development schemes that have the potential for a major detrimental impact on air quality, the LETCP Guidance specifies an assessment procedure to evaluate the likely change in relevant pollutant emissions and concentrations arising from the scheme. As part of the assessment procedure a simple calculation is required to allow the quantification of any emission changes - the pollution impact of a scheme can then be monetised using the pollutant damage costs (per tonne) specified by Defra’s Inter-Governmental Department on Costs and Benefits (IGCB)25. The damage costs allow the assessment of any additional mitigation or compensation that is required to make the scheme acceptable. A suite of mitigation/ compensation measures termed Type 3 mitigation is provided in the LETCP Guidance for major schemes.

National Planning Practice Guidance (NPPG)26 states that air quality mitigation may include “contributing funding to measures, including those identified in air quality action plans and low emission strategies, designed to offset the impact on air quality arising from new development.”The LETC and WMCA will consider further how planning off-set contributions can help measures identified by the LEVS through the development of the Transport Emission Framework (TEF) - see section 4.4.

3.2 Public Sector Procurement

The LETCP has produced Good Practice Procurement Guidance27 to outline innovative procurement practices that can be adopted by public sector organisations (and others as required) to promote the uptake of cleaner vehicles and fuels. Public sector procurement is worth 2 trillion Euros across the EU

25 http://www.defra.gov.uk/environment/quality/air/air-quality/economic/damage/ 26 http://planningguidance.communities.gov.uk/blog/guidance/air-quality/ 27 www.walsall.gov.uk/low_emissions_towns_and_cities_programme 28 PROPOSED – OCTOBER 2016

Member States and accounts for 17% of GDP28. The guidance recognises this significant spending power and the potential influence it can have on transforming vehicle emissions, including:

 Local Sourcing initiatives and their ability to reduce road transport movements  Integration of environmental performance criteria within public sector supply contracts  Building on significant low emission vehicle development and demonstration activity within the region to inform business cases for accelerated deployment of LEVs  Legislative requirements for clean and fuel efficient procurement, including the consideration of Whole Life Costs and regional and national buying standards for transport29  Low emission vehicle and infrastructure cost reduction through joint procurement initiatives/public private partnerships, assisted by economies of scale  Stimulating regional economic development and supporting the activity of the Local Enterprise Partnerships

Low emission vehicle technology, as with most green products, is often more expensive to purchase than conventional vehicles but uses less energy over its life-time, meaning that their whole life costs can be less than those of standard technology. Birmingham City Council has adopted the whole life cost approach to vehicle purchasing. This approach is supported by the EU Clean Vehicle Directive30 which is enacted in England through the Cleaner Road Transport Vehicles Regulations 201131. These Regulations state that any public sector contracting authority, entity or operator when purchasing or leasing road transport vehicles must take into account the operational lifetime energy and environmental impacts, in respect of vehicles purchased or leased.

28 http://ec.europa.eu/environment/gpp/index_en.htm 29 http:// www.gov.uk/government/publications/sustainable-procurement-the-gbs-for-transport-vehicles 30 http://ec.europa.eu/transport/urban/vehicles/directive/directive_en.htm 31 http://www.legislation.gov.uk/uksi/2011/1631/made 29 PROPOSED – OCTOBER 2016

It is envisaged the WMCA, in partnership with the LETCP will develop and adopt policies and targets for the cleaning of vehicle emissions in public fleets through the TEF - see section 4.4. In addition to the vehicles purchased, the public sector can play a major role in ‘cleaning’ commercial fleets through the consideration of vehicle emissions as part of procurement exercises. Table 5 provides an example of how vehicle emissions may be considered in tender evaluations with the weighting attached to the criteria dependant on the nature of the contract to be awarded.

Table 5: Tender evaluation criteria

Sustainability West Midlands (SWM)32 is recognised for providing expert advice to West Midlands Authorities on matters of sustainability and procurement, producing reports and roadmaps to achieve the regional potential of a low carbon economy.

3.3 Taxi Licensing

There are over 5,000 licensed taxis in the West Midlands, including Hackney Carriages (HC) and private hire vehicles (PHV). Most taxis by the nature of their work operate in urban areas and can habitually leave their engines idling when stationary at taxi ranks. The majority of taxis are diesel vehicles. Each local authority sets licensing standards for taxis, albeit few include specific standards for emissions.

32 www.sustainabilitywestmidlands.org.uk 30 PROPOSED – OCTOBER 2016

Birmingham City Council are required to introduce a specified emission standard for taxis as part of a CAZ and Figure 7 provides suggested licensing standards for taxi emissions that could be introduced in Birmingham and considered by other local authority areas.

Figure 7: Suggested Clean Air Zone Standard for Taxis

It is recognised that taxi operations may be suitable for the use of ultra-low emission vehicles (ULEV)33 which can often provide financial benefits for drivers. Additionally, taxis provide an ideal opportunity for customers to gain an experience of riding in a plug-in vehicle, increasing the chances of a subsequent purchase by the customer. Targeted policies will be developed by WMCA and the Metropolitan Councils towards zero emission taxi fleets through the TEF (see sections 4.4, 4.6). This may include the following measures:

 ULEV/CAZ standard for taxis  ULEV/CAZ taxi recognition scheme  ULEV/CAZ compliant only taxi ranks  Increased provision of dedicated fast and rapid charging facilities for taxis  ULEV/CAZ requirements for public sector contracts  Negotiate emission standards with taxi ‘app’ providers

33 Vehicle emitting less than 75 g/km CO2 31 PROPOSED – OCTOBER 2016

3.4 Travel Planning

Many public and private sector organisations have developed travel plans to promote alternatives to vehicle use. Councils have also produced travel planning guidance to promote measures that seek to increase walking and cycling and the benefits of active travel. Whether aimed at schools, workplaces or residential developments, travel plans can play an important role in reducing vehicle emissions, particularly when they are effectively monitored, and travel planning can also include measures to improve the emissions from vehicles, for example:

 Preferential parking spaces and rates for ultra-low emission vehicles  Charging infrastructure to support plug-in vehicle use  Provision of ultra-low emission pool vehicles  Inclusion of ultra-low emission vehicles in ‘salary sacrifice’ programmes  Vehicle user allowance rates to incentivise ultra-low emission vehicle use

4 Low & Ultra-Low Emission Vehicles & Infrastructure Measures

Low and ultra-low emission vehicles and specific measures are being developed and implemented in the West Midlands to accelerate the uptake of cleaner vehicles, including the provision of infrastructure to support growth. Vehicles that either meet or go beyond the latest European Emission Standard (Euro Standard – see section 4.1) are normally associated as achieving a low emission vehicle status, though as already indicated some emissions are far higher under real-world driving conditions than in official tests and this needs to be recognised when 34 promoting emission standards. The Government defines a low emission bus as meeting Euro VI emission standards while reducing CO2 emissions by 15% compared with Euro V buses and light duty vehicles (cars and LGVs) as ultra-low emission if they emit less than 75 g/km of

CO2, irrespective of the Euro Standard.

34 European Emission Standards use normal numbering for light duty vehicles and Roman numerals for heavy duty vehicles 32 PROPOSED – OCTOBER 2016

4.1 European Emission Standards (Euro Standards)

In order for manufactures to sell vehicles within Member States they achieve exhaust emissions according to the latest Euro Standard, assessed during a standardised test cycle (Figure 8). It is seen that diesel cars emit significantly more NOx per vehicle. Emissions projections assume the Standards will not be met and there are plans to amend the Euro 6 regulations to use real world testing in the vehicle approval process with the 35 introduction of Euro 6c in 2017 (ICCT 2014 ). Euro 6 and 5 diesel cars have had compliance issues especially with the NOx requirements. Figure 9 illustrates the difference between the test cycle emissions of Euro 5 and 6 diesel cars and respective real world emissions.

Figure 8: European Emissions Standards (passenger cars) Figure 9: Real World NOx Emissions from Diesel Cars compared with Regulated Limits

European Emissions Standards (passenger cars) 1000

800

600

400 mg/km 200 0 Petrol NOx Diesel NOx Diesel PM

Euro 1 (Jan '93) Euro 2 (Jan '97) Euro 3 (Jan '01) Euro 4 (Jan '06) Euro 5 (Jan '11) Euro 6 (Sept '15)

35 http://www.theicct.org/real-world-exhaust-emissions-modern-diesel-cars

33 PROPOSED – OCTOBER 2016

The European Emission Standards for heavy duty vehicles are more stringent for Euro VI vehicles compared with previous standards - Figure 10. Evidence suggests that these Euro VI vehicles are demonstrating significant improvements under real world driving conditions. Figure 11 shows the results of conformity tests36 carried out on heavy duty vehicles with different Euro Standards, including buses and trucks. Each marker represents a real world test. The ‘conformity factor’ is the ratio of the result to the standard limit, so a value of ‘2’ means the vehicle was emitting twice the amount of NOx compared with its Euro standard, and any value under ‘1’ would mean it was cleaner than the Euro standard.

Figure 10: European Emission Standards for Heavy Duty Engines (ICCT 2015) Figure 11: Performance of heavy duty engines against Euro

European Emissions Standards (heavy duty engines) 9000 8000 7000

6000 5000 4000 mg/kWh 3000 2000 1000 0 Nox PM

Euro I ('93) Euro II ('99) Euro III ('01) Euro IV ('06) Euro V ('09) Euro VI ('15)

36 “Briefing: Comparison of real-world off-cycle NOx emissions control in Euro IV, V, and VI”, March 2015, www.theicct.org 34 PROPOSED – OCTOBER 2016

4.2 Total Cost of Ownership (TCO)

The TCO of cars can help the public make informed purchasing decisions. For example, while the purchasing cost of an electric or hybrid vehicle is generally more than a conventional diesel car, the total cost, including tax, fuel costs and depreciation is often less than the diesel.

4.3 Clean Air Zones (CAZs)

Government has set out its plans to improve the UK’s air quality, reducing health impacts, and fulfilling its current legal obligations37. The Defra Air Quality Plan sets out an approach for meeting these goals by implementing a programme of Clean Air Zones. Five cities outside London, comprising Birmingham, Derby, Leeds, Nottingham and Southampton are legally required to introduce in the shortest possible time and by 2020 at the latest. CAZ classes relating to the vehicles that need to be included in a CAZ are identified as set out in Table 6. Birmingham will be required to implement a class C CAZ where all included vehicles will be required to meet a Euro VI Standard for buses, coaches and HGVs and a Euro 6 (diesel) or Euro 4 (petrol) Standard for taxis and LGVs as indicated in Table 7. Defra Plans state that non-compliant vehicles will be required to pay a charge to enter the CAZ. Certain exemptions may be granted for emergency vehicles.

Table 6: Clean Air Zone Classes

Clean Air Zone class Vehicles included A Buses, coaches and taxis (including private hire) B Buses, coaches, taxis and heavy goods vehicles (HGVs)

C Buses, coaches, taxis, HGVs and light goods vehicles (LGVs)

D Buses, coaches, taxis, HGVs, LGVs and cars

37 https://www.gov.uk/government/collections/air-quality-plan-for-nitrogen-dioxide-no2-in-uk-2015 35 PROPOSED – OCTOBER 2016

Table 7: Clean Air Zone emission standards for vehicle types in Birmingham

Vehicle type NOx emissions limit Bus/coaches Euro VI HGV Euro VI Car/light commercial (up to 1305kg) Euro 6 (diesel) Euro 4 (petrol)

Defra has consulted Birmingham City Council during 2016 on the approaches by which CAZ duties will be imposed and will make funding available for more detailed scoping studies. The area identified for the Birmingham CAZ is the City Centre (within the Middleway Ring Road – A4540) although a scoping study will be undertaken prior to formal Clean Air Zone implementation to ensure issues such as traffic displacement can be effectively addressed. This is intended to avoid creating new problem areas and can take account of expected growth in and around the key locations. It should be noted that while the Defra Plans appear prescriptive, they also state that the final class of the mandated CAZ to be implemented and the area that it should cover will be based on scoping study findings.

Defra are in the process of developing a National Clean Air Zone Framework and any local authority may consider implementing a CAZ where poor air quality caused by road transport emissions is an issue. It is envisaged that voluntary CAZs will retain more flexibility in the types of vehicles included and the emission standards they are required to meet. Additionally, the CAZ framework may be used to include wider measures to support the uptake of ultra-low emission vehicles.

To ensure that there is a clear and consistent approach to implementing and enforcing CAZs in the West Midlands, the WMCA in partnership with the Metropolitan Borough Councils will develop and adopt agreed shared policies and actions for Clean Air Zones - in specific and suitable locations. This will be taken forward through the Transport Emission Framework – see section 4.4.

36 PROPOSED – OCTOBER 2016

4.4 Transport Emission Framework (TEF)

The LEVS forms part of the newly adopted West Midlands Strategic Transport Plan (STP) “Movement for Growth”38 which has replaced the third Local Transport Plan LTP3. “Movement for Growth” is the transport strategy for the West Midlands Combined Authority (WMCA), WMCA replacing the Integrated Transport Authority (ITA) and Centro/Passenger Transport Executive (PTE) effective 17th June 2016.

The STP also makes provision for the development and delivery of a ‘Tackling Transport Emissions Framework’ (TEF) for the West Midlands. The TEF project was approved by the ITA (which consists of the 7 leaders of the Metropolitan Councils) on 28 January 2016.

The TEF incorporates 10 measures that will be developed in 2016/17 and implemented by the WMCA through task and finish groups supported by the LETCP. The TEF is a key delivery mechanism for the LEVS. While the scope of some of the TEF measures relate to wider modal shift initiatives, this section discusses key measures that form part of the scope of the LEVS, including (for completeness, all 10 TEF measures are listed, with those outside of the scope of the LEVS italicised:

 Developing and adopting agreed metropolitan-wide policies and targets towards the accelerated uptake and adoption of Ultra Low Emissions Vehicles and associated infrastructure including hydrogen and gas refuelling opportunities;  Developing and adopting agreed metropolitan-wide policies and actions for Low Emission Zones or Clean Air Zones - in specific and suitable locations;  Accelerated timescales to clean up West Midlands buses, through the Bus Alliance and the West Midlands Low Emissions Bus Delivery Plan;  Making traffic management and coordination smarter through a West Midlands Key Route Network (KRN);  Developing and adopting Metropolitan policies and targets for the cleaning of vehicle emissions in respect of public and commercial fleets;

38 http://www.wmita.org.uk/media/8786/large-document-layout.pdf 37 PROPOSED – OCTOBER 2016

 Developing and adopting specific policies to encourage the wider roll out of Car Clubs and active travel measures;  Further development of the Metropolitan Strategic Cycle Network - linked to the Cycle Charter;  Developing targeted policies toward zero emissions taxi and private hire fleets;  Exploring the development of Low Emission Neighbourhoods and Green Travel Districts (GTD); and  Developing an agreed funding, development and delivery framework

The TEF will need to be developed in consultation with Government, businesses, freight and transport operators, the wider public sector, communities and commuters. It will also need to reflect policy areas wider than transport, including planning, procurement, public health and energy. The TEF will learn from best practice examples such as the London ‘Transport Emissions Roadmap - Cleaner transport for a cleaner London’39 developed by Transport for London (TfL). The following sections discuss some of the issues that will be covered by the TEF.

4.5 Cars and Light Goods Vehicles

One of the key reasons air quality has not improved in line with expectations is the significant increase in diesel car use throughout the UK. In 2000 around 20% of cars sold were diesel compared with around 60% today40. Diesel cars have been promoted as environmentally friendly with generally lower vehicle excise duty (VED)41, however not only are Euro Standards for diesel cars less stringent than for petrol cars, but they are known to emit far more NOx under real world driving conditions than their Euro Standard limit. Further action is needed by Government to look at the incentives provided for diesel cars, and their suitability for use in urban areas needs to be questioned.

The LEVS seeks to raise awareness about the relative emissions of cars and also the total cost of ownership (TCO) of standard technologies

39 http://content.tfl.gov.uk/transport-emissions-roadmap.pdf

40 www.smmt.co.uk 41 https://www.gov.uk/government/publications/vehicle-excise-duty 38 PROPOSED – OCTOBER 2016

compared with alternative fuelled models. Table 8 illustrates TCO for selected car models, including electric, hybrid, petrol and diesel and shows that over a three year period, including depreciation, the electric and hybrid models are likely to cost the motorist less to own. The LEVS also promotes the emission benefits of ultra-low emission vehicles (ULEVs) with take-up in the West Midlands among the highest in the UK. The number of plug-in models available is increasing42 while costs are reducing.

Table 8: Total Cost of Ownership (TCO) of selected diesel, petrol, hybrid and electric cars

Vehicle Leaf (hatchback) Octavia (hatchback) Octavia (hatchback) Prius (hatchback) Manufacturer Nissan Skoda Skoda Toyota Model details 80kw Visia 5dr 1.4TSI 140 SE 5dr 1.6TDI 105 S 5dr 1.8 VVT-I T3 5dr Fuel type Electric Petrol injection Diesel turbo Petrol hybrid Power (kw) 80 102.12 76.96 99.16 0-60mph (sec) 11.5 8.4 10.8 10.4 Euro std NA 6 6 6 Price £ 21,490 £ 18,860 £ 18,360 £ 21,995 3yr RV £ 7,820 £ 7,075 £ 8,185 £ 12,665 New/used New New New New Miles pa 25,000 25,000 25,000 25,000 mpg NA 35 47 52.2 litres/km (kwh/km) 0.173 0.081 0.060 0.054 Tax band A D A A Depreciation 3yrs £ 13,670 £ 11,785 £ 10,175 £ 9,330 Tax £pa £ - £ 110 £ - £ - Fuel £pa £ 519.00 £ 3,959 £ 3,054 £ 2,654 Servicing £pa 0 £ 185 £ 179 £ 202 Nox damage £/yr 0 £ 11.06 £ 80.93 £ 7.41 PM damage £/yr 0 £ 17.54 £ 17.54 £ 17.54 CO2 damage £/yr £ 144.94 £ 308.95 £ 268.16 £ 207.15

TCO for 1 yr (no depr) £ 664 £ 4,591 £ 3,599 £ 3,089 TCO for 3 yrs inc depr £ 15,661.82 £ 25,558.99 £ 20,973.21 £ 18,596.38

42 gNox/km 0.0623 0.4562 0.0418 https://www.goultralow.com/ gPM/km 0.005 0.005 0.005 kgCO2e/km 0.10270664 0.2189 0.1900 0.1468 39 kgCO2/km (tailpipe) 0 0.179924188 0.153809224 0.120638823 PROPOSED – OCTOBER 2016gNox/yr 0 2493 18247 1671 gPM/yr 0 200 200 200 kgCO2/yr 4108 8757 7601 5872

Table 9 shows the number of plug-in cars and small vans registered in Metropolitan Council areas in 2014 to 2016 (January - March)43. The figures show rapid growth in plug-in vehicle uptake over the last two years and represent over 10% of the UK total of 68,994 vehicles. Birmingham has the highest number of plug-in vehicle registrations in a UK local authority area by far. Whilst this is still at an early stage of growth, it is encouraging and understanding continues as to how and where these vehicles are being used, and by whom.

The Government has currently pledged that almost all new car and light goods vehicle sales will be zero emission by 2050 44 and it will continue to provide a grant of up to £4,500 towards the purchase of ultra low emission cars, including plug-in vehicles45 as well as providing support for rolling out the charging infrastructure needed to enable take-up (see sections 3.1, 3.3, 3.4 and 4.8).

Table 9: Plug-in vehicles (cars and light vans) by local authority area

Plug-in vehicle registrations by Metropolitan Council area Local Authority 2016 2015 2014 Q1 Q4 Q3 Q2 Q1 Q4 Q3 Q2 Q1 Birmingham 6,454 5,449 4,216 3,377 2,900 2,357 1,837 1,129 437 Coventry 139 162 137 116 102 95 75 66 48 Dudley 219 201 170 132 105 91 71 44 36 Sandwell 122 101 85 75 62 55 39 22 15 Solihull 448 370 244 256 205 191 188 188 184 Walsall 125 117 105 93 84 58 47 40 28 Wolverhampton 88 87 85 50 43 35 28 21 12 Total 7,595

43 DfT Statistics 44 https://www.gov.uk/government/news/uk-government-pledges-bold-ambition-for-electric-cars 45 https://www.gov.uk/plug-in-car-van-grants 40 PROPOSED – OCTOBER 2016

4.6 Taxis In addition to the taxi licensing measures discussed in section 3.3, the Metropolitan Authorities are continuing to work with the taxi trade to improve emissions.

Birmingham City Council secured £500,000 under the Clean Vehicle Technology Fund (CVTF, DfT,

2014) to convert 80 diesel Hackney Carriages to run on LPG, reducing NOx emissions and costs for drivers.

Birmingham, Coventry and Wolverhampton Councils have undertaken ultra-low emission taxi feasibility studies and are awaiting the issue of final guidance in order to submit bids for government funding46 to support take –up. There is a potential ‘win-win’ scenario with significant emission reductions and cost savings for operators. Figure 12 shows the TCO for an ULEV taxi compared with a common diesel taxi and Figure 13 illustrates the emission damage costs associated with ULEV and standard diesel models.

Figure 12: TCO of ULEV and diesel taxis Figure 13: Emission damage costs of ULEV and diesel taxis

46 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/382190/taxis-preliminary-guidance.pdf 41 PROPOSED – OCTOBER 2016

4.7 Buses

There are currently c. 2,331 buses operating within the West Midlands conurbation, not including coaches. Emissions from buses can be significant in urban locations due to the age and number of vehicles, and as buses tend to operate at lower speeds. For example, buses account for 37% of NOx emissions on Bearwood Road. Table 10 shows the bus fleet broken down by Euro Standard and it indicates that emissions are expected to improve as older buses are replaced with Euro VI through normal fleet replacement plans.

Table 10: Current and projected fleet emission breakdown in 2015 and 2020 (normal fleet replacement)

Current and Projected Fleet Emission Breakdown of the West Midlands Bus Fleet

Current (2015) Fleet Emission Breakdown 2020 (Expected Fleet Replacement)

Euro Standard % Euro Standard %

II 4 II 0 III 42 III 0 IV 17 IV 5 V 30 V 28 VI or better 8 VI or better 67

Through the development of the CAZ all buses in Birmingham will be required to meet a Euro VI Standard by 2020 or sooner, it is important that this doesn’t result in the older stock being cascaded to other areas of the West Midlands and that emissions are improved across the region.

The TEF commits to the acceleration of improving bus emissions through the Bus Alliance, with near term aims of improving air quality and

42 PROPOSED – OCTOBER 2016

longer term goals of reducing carbon emissions as well as being a part of the West Midlands Low Emission Bus Delivery Plan47. The Plan will set out the potential programme for introducing cleaner buses operating on natural gas/bio-methane, hydrogen and electricity.

The Bus Alliance Board is committed to a minimum Euro V Standard across the West Midlands by 2020. Figure 14 shows the relative emissions of buses with different Euro Standards operating at urban speeds.

Figure 14: Relative emissions of buses per Euro Standard and Euro III retrofit (blue = NOX)

It can be seen that Euro V buses tend to emit more NOx than Yearly bus emissions (50,000 miles/year) Euro IV buses which is due to the ineffective operation of 1200 25 their NOx catalysts at low speeds when exhaust 985 temperatures are insufficient. This is a known issue and the 1000 19.5 20

Euro V buses will be required to fit thermal management 827 systems to ensure that the catalysts are reaching their 800 15 correct operating temperature. 577 600

While the Low Emission Bus Delivery Plan outlines the 10 PM (kg/year) PM NOx (kg/year) NOx 400 strategy for introducing near-zero emission technologies, 4.7 5.4 5 including bio-methane, hydrogen and electric buses over the 200 2.2 75 next 20 years, it also looks at near-term goals for 41 0.5 significantly reducing bus emissions. Figure 15 shows the 0 0 III IV V (SCR) III + SCRT VI anticipated reduction in baseline emissions of NO over the x Euro standard next 20 years, including an expected 64% reduction by 2020.

47 West Midlands Low Emission Bus Delivery Plan, draft, 2016, Element Energy 43 PROPOSED – OCTOBER 2016

Figure 16 illustrates the general areas which are pollution hotspots and where new low emission buses will be prioritised.

Figure 15: NOx emissions of the West Midlands bus fleet (tonnes NOx) - baseline scenario Figure 16: Bus routes or streets to prioritise for deployment of Low Emissions Buses

There has been considerable work in upgrading bus emissions and promoting cleaner technologies with electric buses operating at the Coventry Park and Ride and a further 21 Euro III buses retrofitted in Coventry with SCRT48. Figure also 14 shows the emission improvements that can be achieved using SCRT49. A further 150 Euro III buses will be retrofitted in 2016/17 and Dudley MBC secured £158,000 through the Clean Vehicle Technology Fund50 to retrofit 10 Euro II and III coaches with SCRT.

48 Selective Catalytic Reduction and particle trap 49 Euro III+SCRT results based on PEMS test on Volvo bus operated by First, Bradford, 2015 50 CVTF, DfT, 2014/15 44 PROPOSED – OCTOBER 2016

In July 2016 the Government announced that it had awarded more than £3 million to National Express West Midlands to fund ten hybrid and nineteen fully electric buses, and install electric charging facilities. It also awarded £3.814 million to Birmingham City Council and Transport for London for forty two state-of the-art hydrogen fuel cell buses and hydrogen refuelling infrastructure.

4.8 Freight

The LEVS promotes strategic measures which could be introduced to help reduce road freight transport emissions and facilitate a transition to low emission fuels and technologies via the West Midlands Metropolitan Freight Strategy 2030. Such measures include:

- Sustainable Emission Criteria in public sector purchasing decisions

- Emission standards for commercial fleet operations associated with new development schemes

- Promotion of fleet emission recognition schemes such as Eco Stars51

- Alternative refuelling infrastructure such as natural gas, bio-methane, gas to liquids (GTL) and hydrogen (see section 4.9)

4.9 Low Emissions Vehicle Infrastructure

In order to accelerate the take-up of alternative fuelled vehicles it is important that sufficient infrastructure is available in the region to support growth.

51 http://www.ecostars-uk.com/ 45 PROPOSED – OCTOBER 2016

Electric Vehicle Charging

There has been a great deal of activity in rolling out charging points to support plug-in vehicles. The LETCP Planning Guidance (see section 3.1) requires all new development schemes, where practical, to install charging points. This is cost effective on new build properties and will save costs further down the line in retrofitting charging points.

The West Midlands has one of the most extensive public charging point networks in the country, developed as part of the Plugged-in Midlands52 (PiM) Programme. Details of all charging point locations can be found on the PiM website. All PiM charging points now form part of the national POLAR network which means that PiM membership gives access to all charging points on the national network.

From 2014 the Dudley MBC Parking SPD included a requirement for every new residential property to be provided with a designated electric vehicle charging point and for new commercial developments to provide between 5% and 10% of the associated parking spaces with charging points.

Alternative Refuelling Infrastructure

In 2015, Birmingham City Council published its Blueprint for Low Carbon Fuel Infrastructure53 detailing proposals for rolling out alternative refuelling infrastructure, including electric charging, natural gas/bio- methane and hydrogen. This has since led onto more focussed work relating to the practical introduction of new refuelling infrastructure. The Blueprint not only looks at Birmingham but covers the wider

52 https://pluggedinmidlands.co.uk/ 53 http://www.sustainabilitywestmidlands.org.uk/wp-content/uploads/Case-Study-Low-Emission-Refuelling-Infrastructure-in-Birmingham.pdf 46 PROPOSED – OCTOBER 2016

infrastructure requirements for the West Midlands, highlighting opportunities based on technology readiness and suitable locations for alternative technology fuelling. The LEVS, through the TEF will seek to build on the Blueprint to ensure there are sufficient facilities to refuel the new vehicle technologies that will be introduced over the next 20 years.

Natural gas and bio-methane refuelling facilities in the West Midlands can be found on the Gas Vehicle Hub (www.gasvehiclehub.org)

5 Future Challenges and Opportunities

5.1 This LEVS covers measures to facilitate and secure growth in low and ultra-low emission vehicle uptake across the West Midlands over a five year period and beyond. The Strategy objectives recognise the challenges we face and opportunities presented through a detailed delivery plan that will be developed in association with the Transport Emission Framework. It is believed significant vehicle emission reductions and improved air quality can be delivered. The challenges and opportunities include:

- Integrated approach to improving air quality across the West Midlands through the Combined Authority

- Increased funding opportunities for air quality improvement initiatives through the Combined Authority and Government funding

- Improved health outcomes for the residents of the West Midlands

- Prevent potential infraction proceedings against West Midlands Authorities for non-compliance with AQ objectives by the 2020 deadline

- Commence planning for facilities to support near-zero emission technologies beyond 2021

The vision of the future includes the West Midlands not only complying with Air Quality Objectives but improving air quality further to secure wider health benefits through the following vehicle emission measures: 47 PROPOSED – OCTOBER 2016

- CAZ for Birmingham and any other authority that considers it appropriate - An effective Bus Quality Partnership for the West Midlands that introduces low emission bus standards and works towards the future introduction of ultra-low emission buses - A zero emission taxi fleet - An effective Freight Partnership that supports the everyday use of low and ultra-low emission vehicles - Sufficient infrastructure and incentives to encourage and support the continued growth in ultra-low emission vehicle uptake - Ensure the planning system supports truly sustainable development and enables new developments to support green vehicle choices - Ensure public sector procurement recognises the social value in reducing vehicle emissions

As part of the delivery plan for this LEVS it is envisaged that success criteria will be agreed and the implementation of measures will be monitored and reviewed to inform future LEVS updates.

48 PROPOSED – OCTOBER 2016

Glossary of Terms

AQMA - Air Quality Management Area AQAP - Air Quality Action Plan CDV - Car derived van CO2 - Carbon Dioxide CVTF - Clean Vehicle Technology Fund Defra - Department for the Environment, Food and Rural Affairs DfT - Department for Transport DPF - Diesel Particulate Filter EEV - Environmentally Enhanced Vehicle Euro Standard - European Emission Standard FTA - Freight Transport Association HDV - Heavy Duty Vehicle i.e. bus or lorry HGV - Heavy Goods Vehicle ie lorry LEVS - Low Emissions Vehicle Strategy NHS - National Health Service

NO2 - Nitrogen Dioxide

49 PROPOSED – OCTOBER 2016

NOx - Oxides of Nitrogen i.e. a mixture of Nitrogen Dioxide, Nitric Oxide and Nitrous Oxide OLEV - Office for Low Emission Vehicles PHE - Public Health England PM - Particulate Matter

PM10 - Particulate Matter less than 10 microns in size

PM2.5 - Particulate Matter less than 2.5 microns in size RCV - Refuse Collection Vehicle RHA - Road Haulage Association SCR - Selective Catalytic Reduction TCO - Total Cost of Ownership µg/m3 - micrograms per metre cubed

ULEV - Ultra Low Emission Vehicle i.e. below 75 g/km CO2 WHO - World Health Organisation WLC - Whole Life Costs

50 PROPOSED – OCTOBER 2016