Manage energy for profit & planet

www.aems.ie 1 of 13 © Authentic solutions Ltd 10/11/2018

Saturday, 10 November 2018

[email protected]

NECP submission

After agriculture, road transport and specifically car use is Ireland’s largest and fastest growing

source of CO2, reducing car use by 10% would reduce Ireland’s emissions by 1%, and help to

reduce households’ largest single bill after rent; transport costs (source CSO).

We work commercially in this area (declaration of interests over) delivering measured fuel, cost

and emissions savings to transport operators and their fleets. Based on our experience, we

believe there are 3 priorities for the NECD to mitigate the effects of our climate breakdown:

1. Urgency and transparency;

o Keep our national targets simple to aid clear communication – round upwards

o Account for the carbon cost of delay and/or doing nothing in all policy, projects and

tenders

2. Reduce GHG emissions and improve air quality; penalise imports of Euro 1-5/I-V vehicles;

o 19+UK cities will shortly implement their Low Emission Zones, this will result in the

dumping of dirty and inefficient vehicles on Ireland’s second-hand market. Euro

6/VI are the cleanest and most fuel efficient, send tax signal to buy the most fuel

efficient and cleanest second-hand vehicles.

3. Recognise a green freight programme by incentivising essential road users;

o Leverage the existing diesel rebate scheme as there is no excise on gas or electricity,

switch the rebate from excise to carbon tax; give a clear signal to operators planning

transport operations and investments to 2030.

o Capture improving performance data from goods and passenger transport

Lastly can we appeal to the DCCAE to influence the Dept of Finance to map road transport taxes

out to 2030, we understand this goes against the grain, but Ireland needs to show suppliers of

Right Hand Drive (RHD) vehicles its plans. Without this tax certainty RHD vehicles will be sent to

UK first and Irish buyers will be at back of the queue (lead times for EVs are already extending).

Yours sincerely

Conor Molloy MSc (Energy) CMVP

Managing Director

087 255 4070

Manage energy for profit & planet www.aems.ie

Authentic solutions limited t/a

AEMS Authentic Energy Management Services

50-56 Merrion Road, Ballsbridge, Dublin 4, Ireland

Registered in Ireland No.397388

01 230 5018 or [email protected]

D i rec tor s

Conor Molloy (MD), Mary Kingston

VAT No. IE 6417388H

Member sh ips :


Declaration of interests

Over the last 15 years, Conor Molloy has worked for energy suppliers (Enprova, Calor and Airtricity,

ESB), government bodies (SEAI, BIM, Enterprise Ireland and Revenue), large semi-states (CIE Group,

Coillte, An Post) and a long list of private companies in Ireland, the UK and EU.

Why now

In June 2018 we participated in Al Gore’s Climate Reality leadership training in Berlin; whilst we are

often paid to advise with regard to consultations; we now feel we should share our experience from

our customers efforts to tackle climate change directly. We have not been funded for this submission.

Relevant experience

• Convener for EN16247-4 Transport Energy Audit standard at EU CEN/CENELEC in Brussels

• 200+ fleet energy audits completed for fleets up to 1200+ HGV & PSV

• Chaired the EU Transport Energy Management Working Group at CEN/CENELEC 2013-14

• In 2011, AEMS developed a database of transport energy savings measures for SEAI.

See our commercial work at www.aems.ie and https://ecofleet.ie or www.ecodrive.ie

Overleaf – supporting arguments

Ireland CO2 emissions – source SEAI 28th May 2018 ...................................................................................................... 3

4.2 Energy Union Dimension Energy Efficiency ................................................................................................................ 4

Question 5: Targets ................................................................................................................................................................. 4

Question 6: Milestones .......................................................................................................................................................... 5

Question 7: Policies and measures ................................................................................................................................... 7

Transport measures ................................................................................................................................................................ 7

Overview of waste in mobility ............................................................................................................................................... 10

How to reduce car use? Charge for road use .................................................................................................................. 11

Why penalise Euro <5/V car, van and truck imports .................................................................................................... 12

Our letter to Dept Finance on VRT change to CO2 (2007) .................................................................................... 13


Ireland CO2 emissions – source SEAI 28th May 2018

This SEAI graphic confirms 61% of Ireland’s

CO2 emissions come from energy related

sources, of which 37% are from transport i.e.

22.5% of total, past SEAI reports have stated

private car use accounts for 43% of transport

energy use or just under 10% of total

emissions.

Reducing car use by 10% would therefore

reduce national emissions by 1%, relatively

speaking.

Similarly goods transport accounts for 5% of vehicle population but 25% of fuel use, or 15% of total

energy related emissions come from moving goods needed by each and every household, whether to

or from farm to mart, factory, shop or home i.e. Heavy Duty Vehicles are Ireland’s essential road users.


4.2 Energy Union Dimension Energy Efficiency

A generalised approach to Energy Efficiency in Transport is addressed in our response to Q.7.

Question 5: Targets

Bearing in mind Ireland’s current state of progress on energy efficiency, what contribution do you

believe Ireland should make to the EU indicative energy efficiency target of 32.5% by 2030, and why?

Given Ireland’s projected population growth, continuing fossil fuel imports of over 10,000ktoe per

annum, and the #Brexit need for cost competitiveness across all sectors, Ireland should go to 40+%

improvement in energy efficiency by 2030, why?

1. Clarity: Businesses find it hard to keep up with the diverse targets and their meanings, setting a

clear and easily understood target is key to accelerating adoption and implementation.

2. Profit; a simple round number can be seen to contribute to profit and citizens pockets e.g.

• transport is our fastest growing emitter and largest household cost after rent (more than

food now – CSO), 20-40% of transport costs are fuel, a 40% improvement in road

transport efficiency 2005-2030 = 8% reduction in cost (still just 1.6% per annum).

• at the 3% margin typical of the transport sector (all modes) that 8% would double profits;

over time these gains are eroded, but the communicable benefit is increased profit.

3. Import reduction: There’s been a complete lack of govt. communication on our 10,000+ktoe /

€4.6bn of fossil imports each year, and the associated security of supply challenge. Citizens and

business will benefit from reduced import costs from countries inimical to our interests.

4. Growth; Our economy and population are set to grow from 4.6m people in 2015 to 5.2m in 2030;

(+13%) without massively improved energy efficiency our net emissions will continue to increase:

we need a much larger increase in efficiency than the EU to achieve our targets.

• 32.5% + 13% = 36% but we need to go much further if we are to stay ahead of

population as it grows towards 6+m by 2080.

Lastly the Irish Public sector has led by example in energy efficiency with an overall energy effiency

gain for 20% and many trasnport providers at 33% or higher 2009 to 2020, 40% is doable.


Question 6: Milestones

What indicative national milestones for energy efficiency do you believe that Ireland should set for

2030, 2040 and 2050, and why?

Milestones need a solid basis in up to date data; often lacking in Ireland, from our work we see a need

to publish a single set of energy, waste and emissions conversion factors; attach a societal price in €uro

to each (available from DPER now). Various conversion factors are in circulation leading to uncertainty

in business cases and projections, delaying action across all sectors.

With regard to the milestones themselves: Keep it simple, a 40% improvement in energy efficiency by

2030, 60% by 2040, 80% by 2050; 100% for those that can stretch i.e. the same percentages as our

GHG reduction targets under the Paris Agreement.

Much of the data needed for transport milestones is already collected by CSO at 4 yearly intervals;

work with trade associations to increase interim data quality and to collect year-round and publish as

monthly cumulative sums (CUSUM i.e. a rolling annual total).

Benchmark and report reductions in and increases in;

Vehicle distance travelled as a total Km per

annum

gCO2e/PAX.Km in public and private transport

gCO2e/Tonne.Km for goods transport

Walking /cycling to school, aim to get back to

the 80% we had in 1990 (from 20% now)

Public Transport load factor across all mode’s

bus, rail and plane.

Freight load factor i.e. am increase from typical

70% to 80% would take 10% of trucks off our

roads.

Why benchmark and reduce distance travelled

Irish households need to reduce their driving habit; transport accounts for 14.9% of household

outgoings slightly above food at 14.7% (Source CSO).

Distance; electric vehicles reduce €/100km by 70% at the pump/charger, 30% CO2e at the national

level after grid losses. Bikes and eBikes can reduce our per km emissions to zero. But if we continue

to travel further each day these gains are wasted; measure and report household journey choices

annually – see example based on CSO 2016 right.

A side issue is that emissions control equipment does

not work effectively when cold, it takes 5-8km of driving

to warm an engine through. These short journeys are

doubling impacting on our planet and local air quality.


Reductions in gCO2e/PAX.Km

Measure and report passenger transport in total

CO2e/PAX.km in the same way we do road

fatalities.

Private operators have made a stab at this on

an ad hoc basis, CIE Group included figures in

their annual report for the first time ➔

Compare public transport with an average car

that carries 1.6 passengers, break into A/B class

ICE and Electric compared to off-road (please

replace ‘SUV’ with ‘off-road’ to properly

describe such vehicles).

The NTA is the relevant government agency to

publish such performance data, based on existing CSO and SEAI statistics.

Reducing gCO2e/Tonne.Km

Goods transport comprises 5% of vehicles and 15% of emissions, as we grow, goods transport will

increase (IEA estimate by +40% to 2050), the amazon effect (more air per item) and our projected

population growth will only add to this.

Work with Green Freight Programmes to gather data, report and reduce gCO2e/Tonne.Km (✋ full

disclosure; designing these programmes is our business). See Smart Freight Centre

http://www.smartfreightcentre.org/ for a global picture of Green Freight Programmes.

The Freight Transport Association of Ireland operate the closest Ireland has to a green freight

programme in their accreditation scheme supported by us with our ECOfleet service and Enprova with

funding i.e. government policy has made helped us make start.

Help green and efficient operators by recognising their efforts in the Diesel Rebate Scheme. Whilst at

the same time gathering the data needed to support goods transport milestones in the NECP..


Question 7: Policies and measures

What policies and measures do you believe Ireland should adopt to achieve its energy efficiency

contribution and what are the grounds for your recommendations?

The ITF, UN, IEA and our own approach to reducing transport emissions is to Avoid (travel), Shift

(mode) and Improve (performance).

• Avoid travel e.g. encourage flexible start times, home working and improve spatial planning

• Shift modes from single occupant cars to public transport and to cycling or walking

• Improve performance of the vehicles we do have to use, each has a life of 10 years or more

However other aspects need to be addressed across all government legislation and policy first;

1. A sense of urgency, encourage government and society to start small and fail early; help

government learn what works and where – faster.

2. Integration; Ireland has useful measures e.g. our integrated EV charging system. But they operate

hamstrung by the pace of regulatory decisions, or in isolation because govt Depts naturally

defend their budgets, political leadership is needed to bridge these gaps.

• Introduce carbon accounting within govt. e.g. price all actions with a €50/tonne CO2e - the

projected price per tonne for 2030, as we will likely have to pay this by then.

• Use carbon savings to trade credits amongst depts as they will not trade budgets.

3. Public procurement complexity is a significant barrier to delivery; put a carbon cost (see above) per

day to every project so the cost of delay or doing nothing is reflected in procurement, regulatory,

planning and other (legally) necessary processes.

4. Public health; whilst discouraging burning of fuels and materials at all levels of society;

• Communicate clearly the sources of Irelands air quality issues, which are mainly domestic

burning of waste, coal and biomass (sources NUIG, UCD).

• Focussing on CO2e reduction is key to our achievement of 2030 targets; PMs and NOx are

important issues in public health, pricing all in the above mentioned factors will help

clarify communications and prioritise debate and actions.

• Penalise imports of Euro 1-5 cars and vans and I-V heavy duty buses and trucks, there will

be screams of anguish, but the reality is these vehicles will cost operators more in fuel

costs than they save on the cheaper capital costs (particularly when carbon tax is

increased).

Transport measures

Supports for improved performance of new cars in Ireland are adequate, increasing sales of electric

cars prove this, supports are needed for the most efficient vehicles on our roads namely heavy duty

vehicles (HDV) such as articulated lorries and buses.

However, no amount of money spent on new efficient commercial vehicles, bio fuels or electric trucks

and buses can help, if these vehicles are stuck in traffic.


Average speeds for buses are dropping, see Bus Eireann and Dublin Bus performance 2012 to date; a

congestion charge (by time of day) is necessary but is politically unacceptable; moving road tax to a

charge per km based on unladen weight of vehicle would address inequities in CO2 based road tax.

Overleaf we illustrate the huge wastes in our transport systems and the internal combustion engine

(ICE). Below is what works in our experience, within the avoid shift improve (ASI) framework:

Avoid

• Congestion (time of day) Charge in all cities; ring fence funds to build safe walking and cycling

routes.

• Price parking spaces to increase visitors to town centres; enable town centres compete with out of

town attractions e.g. first 3 hrs free in town centre, mandatory minimum parking charge

elsewhere; ring fence funds for walking & cycling routes.

• Replace road tax with kg per km tax;

o Rate by unladen weight of vehicle in kg and check km from odometer at each NCT.

▪ Smaller, lighter vehicles will pay less tax i.e. it is progressive for lower income

families, free to buy diesel in rural areas or alternatives in cities.

▪ Efficient electric vehicles will pay less, excessively heavy will pay more.

▪ Bicycles could be included to demonstrate fairness, as they would actually be

owed tax (they weigh less than the person and payload they carry, repaid in cycle

to work scheme).

o Use the data gathered to help plan transition from excise taxes on fuels to per km tax on

all vehicles, excise taxes may fall faster than expected (see Apple vs Nokia), prepare now.

Shift

Passengers are already switching to cycling and public transport as congestion squeezes then off the

roads at peak hours. But main road bus services cannot fill all the gaps, NTA Locallink does an

excellent job in rural areas, but its much less well known in urban areas.

• Ask NTA to accelerate testing and roll-out of Shared Taxi services (see https://www.itf-oecd.org/itf-

work-shared-mobility ) in cities; proven to deliver increased access to public services and reduce

car space requirements by up to 90%, whilst reinforcing use of public transport spines as

proposed in #BusConnects.

Improve

• Green Freight Programmes (GFE) can be supported by EEOS (S.I.131:2014)

o All sectors of the economy need competitive goods transport; international customers are

demanding evidence of GFE participation, Irish govt. does not.

o Similar programmes can be extended to passenger transport services.

• Ecodriving training for all experienced drivers

o Use existing EEOS incentives to encourage private ADIs to offer ecodriving training to

experienced drivers, join the dots with road safety and reduced insurance.

o Collect data at point of training (✋ full disclosure we offer this since 2006, but lack of

government recognition restricts uptake to early adopters).


• Alternative fuel and electric vehicles are selling fast to car owners, commercial fleets are slower but

the fuel cost savings are compelling: Thus for business, the argument for electric vehicles is made;

what is needed is an extensive and urgent build out of the electric vehicle charging network.

• Allow the EEOS to recognise the final energy savings of transport operators switching from fossil to

electric; currently there’s a complicated discussion around conversion factors, which halves the

perceived benefit to the end user, this applies in the public sector reporting as well as EEOS.

• Policy wise we urge that all charging networks private and public, include two vital features;

o Be compatible with the Open Charge Point Protocol OCPP standard from the Open

Chargeh Alliance https://www.openchargealliance.org/

o Be open to all i.e. operators can charge whatever price they want, but the charger must

work for anyone who seeks to use it. A prime example are the Tesla Superchargers at

Birdhill services on the M7, the motorway signage says EV charger but you can’t use it

even if you pay for it.


Overview of waste in mobility

Structural waste in mobility systems courtesy – Ellen MacArthur foundation

Internal combustion engine (ICE) waste

You will note the absence of

alternative fuels for transport in the

above list, this is because burning any

form of fuel in an internal combustion

engine (ICE) is extremely wasteful. This

graphic from the European

Environment Agency (EEA) shows how

much fuel disappears in heat and

exhaust; typically, 75-82% of every €100

spent on fuel is wasted.


How to reduce car use? Charge for road use

Ireland already has road use charges in the form of road and bridge tolls, these broadly follow

European policy and best practice i.e. they are distance based.

Recent discounts offered to EVs have introduced time of day pricing, a welcome development; can the

Dept confirm these would apply to commercial vehicles as well up to 46t – helping operators, who

even now are seeking to test electric heavy duty vehicles on tolled routes.

Govt already have the basics to move from fuel excise to a road use charge, every vehicle undergoing

an NCT or CVRT test has its odometer read and this data is available to all.

Moving road tax to a Km charge X CO2 rating or unladen weight in kg, would be fair and lay the

foundation for a transition from excise on liquid fuels to distance based charges as the national fleet

moves to electric.

As shown overleaf manufacturers will game any CO2 test, however the move from the discredited

NEDC to real world WLTP testing is underway and heavy vehicles will have a realistic CO2 emissions

certification in the coming years.

The time is right to move to a revised road tax and fuel excise system that takes account of planned

changes to 2030.

How will increasing road transport costs decrease household costs?

By sending clear price signals; households can choose from existing alternatives, often funded by the

state e.g.

• Local Link services in rural areas, Bus Eireann, Dublin and Transport for Ireland services across

the country.

• Mobility as a service (MaaS) is already reducing costs for car users in cities and across rural

Ireland with GoCar present in 17 counties.

• Bicycle use is increasing.

All of these services are cheaper per km than cars. Even a pittance in road use charge equivalent to

current road tax, sends a signal, as we all are aware that taxes can be increased.

By highlight that short journeys cold engine cost owners the most fuel and emissions per km govt. can


Why penalise Euro <5/V car, van and truck imports

Our work in Ireland measuring and

verifying fleet fuel performances

shows clear cost, fuel and emissions

savings for operators moving to

Euro VI heavy duty vehicles (buses

and trucks)

With 19 UK cities banning Euro5/V

and below class vehicles in the

coming years, Ireland needs to

guard against dumping of dirty

inefficient vehicles and increasing

Irish fleet operators costs.

This is the summary graphic from

ICCT for Euro 3-5 vs 6 for light

vehicles:

Regardless of test data flaws – all

tests have their flaws – we must

stop old inefficient second hand

RHD vehicles being dumped into

Ireland. The gap for diesel between

Euro 5 real world (0.8) and Euro 6

real world (0.6) is 0.2 or 25%

decrease in NOx – a key cause of

asthma in urban environments.

UCD and others testing for PM’s in

Dublin found domestic burning was

the dominant source for PM’s

hence our focus on NOx above.


Our letter to Dept Finance on VRT change to CO2 (2007)

We have responded to several consultations since, but we remind the Dept that the market will find a

way to optimise its offering vs any tax regime.

Manage energy for profit & planet

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