1. Actionon AirQuality
Action on Air quality written submission to the Commons Select Committee on Air Quality
Noel Lock, Founder, The Greenfuel Company Ltd, Director BRC (GB) Ltd
Diesel kills people
Government policy promotes diesel
Government policy kills people.
In 1998 the government produced the shocking statistic that 24,000 died each year in Britain from
air pollutionandthatthe primary cause of this was exhaust emissions from vehicles. These deaths
and the far greater numbers of non-fatal illnesses far exceeded the number of people dying or
injuredinroadtrafficaccidents.Infact,our roads are the safestinthe worldfroma potential trauma
injuryperspective,something we should all be very proud of. Britain can be world-beating when it
wants to be but somehow this air pollution scourge was below the radar. I had found a cause and
shortly thereafter I founded the Greenfuel Company with the express purpose of reducing air
pollutionthroughthe promotion of cleaner-burning fuels. More than a decade later my failure can
be attestedbythe latestestimateddeathtoll –29,000. Regrettably,we simplyhave nottakenthe air
pollutionthreat as seriously as we should have and the consequences will haunt us for decades to
come.
I verymuch hope thatthe CommonsSelectCommittee on Air Quality can have a positive influence
on thiscurrently terrible state of affairsandproffermyopiniononhow we gothere and whatshould
be done moving forward.
How we got here:
Threat not taken seriously. When pollution is visible it is viewed as a problem. When it is
invisible it is rendered unimportant. An example of this has been the recent furore about
Saharan sand. As far as I am aware, this sand and dust is made of inactive compounds that
have not been listed as carcinogenic by the World Health Organisation (WHO), but you can
see it. A glassof water thatis not crystal clearis rejectedaswe understandthatwhat we eat
and drinkcan have a direct effect on our health. A typical adult inhales 14,000 litres of air a
day. If you live in London that air is increasingly toxic.
The false trade-offbetweenGlobal Warmingand air quality.I was at an EnergySaving Trust
(EST) Conference andworkshopwhere Citroenexecutives were pressing the case for ‘clean
diesel’ despitethe concern,indeed horror, expressed by some of the most august research
organisations in the world such as Harvard University. As one of the Citroen marketing
people put it “Would you rather die from what you breathe or by being flooded?” This
thinkingledto‘pollution’beingexpressed purely in terms of the amount of tailpipe carbon

2. dioxide emitted per mile with the smug assumption that new technology was making cars
cleaner all the time. This is wrong. The exhaust produced by the latest diesel vehicles has
been proven to be substantially more medically dangerous than that of petrol vehicles
produced at the end of the last century. Nonetheless, diesel is taxed at the same rate per
litre aspetrol and companycar taxationfavoursdiesel to the point where the new vehicles
bought for this market are almost exclusively diesel. This is despite the fact that burning a
litre of diesel producesmore carbondioxidethanburningalitre of petrol.Thisisdespite the
fact that otheremissions,bothtailpipe andwell-to-tank,make upglobal warminggases.This
is despite the fact that various research from around the world has highlighted the link
between diesel exhaust and heart attacks, strokes, cancer, autism and various respiratory
diseases including asthma and COPD.
Evenif switchingtodiesel enabledustopreachharderat the countriesthatwere not pulling
their weight in the collective effort to reduce global warming could this ever be worth the
lives of an estimated 1,000 British children each year?
As a matter of fact the biggest reductions of carbon dioxide emissions have been made by
countriesswitchingfromdirtytocleanburningfossil fuels, such as the UK a decade ago and
more recently in the USA with the advent of shale gas.
Failure to test properly.Europe has simplistically reduced the air pollution problem to that
of carbon dioxide exhaust emissions on the mistaken assumptions that these are more
important than all the others and that emission standards would automatically ensure
improvinglocal airqualityanyway.Thisstrategyhasfundamentallyfailedinlarge partdue to
the failure of the testingregime. The current test for European standard approval has been
shown to be a very poor mimic of real world driving conditions and styles. Further, car
makers have been allowed ever increasing latitude in how the tests are conducted to the
point where the ‘vehicle’ under test is no longer road legal. As a consequence drivers
complainof notgettingthe fuel economyadvertisedandreal worldemissiontests can show
pollutionupto500% of published. Othertestregimesenjoyabetterreputation, particularly
that of the USA.
The search for the silver bullet that does not exist. Extraordinarily, politicians seem to
believethattechnologiesthatmightalleviate airpollutionare engagedina winner-takes-all
beautycompetition.Inasocietythat valueschoice above almostanythingelsethisis bizarre
and wrong. Over the last decade and more I have witnessed politicians jump on the
bandwagon of one technology after another before abandoning it for the next. Clean-
burning gaseous fuels were all the rage until it was pointed out that crop-based fuels are
greener, literally. Then, as growing disquiet grew about third world hunger and
deforestation,bio-fuels were dumped in favour of hydrogen. The latest fad is electric cars.
In fact, all of these technologies have significant merit and a whole-hearted attempt to
reduce air pollution in the UK must take advantage of every technology to hand. For many
years now all the major car makers have been advocating what Ford calls the ‘Portfolio

3. Approach’. In spite of this our civil service and Ministers responsible still dream of leading
the world by investing trivial amounts of money in projects that will ‘solve’ the problem.
Lack of Leadership and Policy. The last decade has seen too many ministers come and go
withthe resultthatthe incumbentsrarelydevelopexpertiseinthe field.Bywayof example I
cite Norman Baker in a letter he wrote in 2010.
“new emission measurementtechniquesand accompanying emissionslimitsensurethat“Euro 5”
diesel cars currently coming onto the marketemit no moreparticles than petrol cars.
So,in summary,theenvironmentalperformanceof LPGas a transportfuelis on balancenot
substantially differentthan thatof petroland diesel.”
I choose thisquotationfornootherreasonthan that it demonstratestypical incompetence.
It is dispiriting to realise that the Minister responsible does not recognise the difference
between petrol and diesel.
This lack of leadership and a childlike attention span has led to a dizzying blizzard of often
contradictory policy when what has been needed is a consistency and clarity. It has taken
politiciansalongtime toadjustto the idea that the environment is no longer a subject that
isabout fine flowingwordsandaslittle aspossible of anythingelse. This thinking allied to a
lack of operational ability at departmental and quango level has led to a state of practical
impotence.
Any witness to the tragic history of EST’s bungled Powershift scheme can understand the
likely panic at their involvement with actual technology deployment again. For those not
familiar it was a scheme to encourage adoption of LPG and CNG through the provision of
generous grants. Over an agony of several years, the parameters of the scheme were
changed and changed again, offending many that might have qualified for a grant but no
longer did. The funding pot ran dry prompting panic by companies being told ‘cheque is in
the post’whilstthe administrationcontinuedadvisingpeopletodelaypurchase onthe hope
of future grants. In the end the Minister responsible ended the scheme citing European
rules,anexplanationthat wasrebuffedbyBrussels.Whilstthe industrybrieflyrallied on the
demise of Powershift,the UK car industry took note and is extremely wary of LPG and CNG.
The brief, disastrous lifeof E85 bio-ethanol inthe UK isanotherexample. The vehicles were
provided by Ford and Saab and the refuelling infrastructure by Morrisons. The fuel launch
was supported by significant marketing investment including TV advertisements and
cruciallythe vehiclescouldalsouse pure petrol.The Governmentprovidedthe ditheringand
policy u-turn and so the initiative failed. Still very much alive in many other parts of the
world!
Since policy and often taxation treatment and funding regimes are in an almost constant
state of flux, the UK suffers from a lack of industrial investment into alternative fuels. As a
Shell executive once told me it is sad when investment decisions favour Nigeria over the
North Sea due to level of political risk.

4. By way of contrast the German government offered no grant incentive but a simple, clear,
consistent medium term policy. As a result there are now 6,000 LPG refuelling sites and
approximately half amillionLPG vehicles in Germany. Most car manufacturers offer factory
fit LPG vehicles in most of mainland Europe where there are over ten million LPG vehicles
and over25,000 refuellingstations. Inthe UK,Opel (Vauxhall) produce LPG fuelled Astras at
Ellesmere Port for export only. If only we could keep up with Europe!
Moving forward.
Learn from mistakes and emulate success.The mistakesthathave beenmade are very clear
and impossible to justify. However, the advantage of such current failure is that there is
comparative success everywhere. Whether we look to Japan or the USA or almost any
countryin Europe there are policies withprovenresults that can simply be copied. This will
however require a change of direction from the Department of Transport. One senior civil
servant once patiently explained that what happens beyond our shores has no interest to
him since his job relates to what happens in the UK only.
PortfolioApproach. Whenthe majorcar manufacturersandalmost all developed countries
are supportinga broad range of technologies, Britain’s ‘eggs in one basket approach’ looks
very high risk. What if the rest of the world is right and Britain is wrong? What if it can be
shown that this approach has led to tens of thousands of avoidable deaths and illnesses?
Fill the Policy Vacuum. Firstly create a toolkit of all the helpful and available technologies.
Thendevelopstraightforward,honest,clearandconsistent medium term strategies to best
harness this mosaic to reduce pollution. Tinker very lightly and always ensure that early
adoptersare not penalisedbypolicychange.Make the UK a safe place for green technology
to invest in.
Better Accountancy. In economics, an externality is the cost or benefit that affects a party
whodidnot choose to incurthat cost or benefit.Pollutionisagoodexample andtherefore a
challenge tofree-marketpricing.Itisclearlythe case that the countryhas highdebtsand not
the free will tospendlavishlyon‘goodworks’. However, current estimates put the NHS bill
for dealing with the consequences of poor air quality at £19bn per year. That pays for a lot
of clean cars or even a few hundred yards of rail track! The polluter pays principle is often
citedbutneedsto be more rigorouslyenforced. Tax on a litre of diesel must be higher than
petrol since the science is unambiguous on the pollution caused. Taxation on road fuel is a
primary source of revenue for our Government and will remain so. Subject to the rate per
fuel type, it is also simple to administer and faithful to the polluter pays principle. It also
avoidsthe horrorsof large-scale WhitehallITprojectsand civil libertyissues thatnationwide
road pricing introduce.
Greentaxeswouldbe farmore politicallyacceptable if the revenue wasseentobe well used
to reduce pollution.Examplesmightbe touse some of the AirPassengerDuty (APD) toassist
all companiesoperatinginairside areas of airports to use exclusively electric vehicles. This

5. couldleadto securitybenefitsandalsoanarea of niche expertise that could provide export
opportunities. Rises in diesel duty should be used to assist adoption of alternative fuels.
Deploymentnot research.Too oftenpublicmoneyiswastedontrial projectsthathave little
or no prospect of deployment. The deaths and illnesses caused by air pollution are not
abstract and necessarily the solutions have to be real world and in the form of massive
deployment.Itissimplynotgoodenoughtoproudlydemonstrate five hydrogentaxisforthe
London Olympics when the remaining 24,000 run on diesel. The score remains 24,000 to 5
(losing).Three millionpoundsof public money has been assigned to install three hydrogen
filling stations in London. This money could have put one hundred LPG stations into our
capital. The scheme which results in the greatest reduction in pollution is the one that
shouldattract publicfunds.Schemeswhichdeliverinstantbenefitare betterthanthose that
holdout some hope for future undefined benefit. A small company in London has recently
re-engineeredsome blackcabstorun themon LPG fromdiesel andthe results are dramatic.
These reconfiguredvehiclesnow passthe mostrigorous emission standards that have been
developedyearsafterthe vehiclesthemselves were originally built. Tailpipe Pm emissions
are eliminated and NOx massively reduced. These emission results have been verified by
MillbrookTestingGroundand the certificate isavailable if required. All 24,000 current black
cabs could be converted in this manner for less than the first year’s threatened fine from
Europe and,more to the point,wouldgoa verylarge way towards addressing what is a very
large problemand save lives.Rememberthatwhilstpetrol/hybridtaxisare promised for the
future a new taxi bought today is constrained to be diesel by the rules (despite the export
version being petrol) and will likely still be in service until 2026.
There is no reason that policies that have been shown to be successful around the world
cannot be successful in the UK if their adoption is carried out with the same vigour.
Repeat: There is no silver bullet. I have explained my views too many times to know that
some people will simply think that electric cars produce no tailpipe emissions, therefore
they are the best technical solution and therefore the future so any effort spent on any
otherdirectionisa distraction. This is simply not the case, as almost all major stakeholders
repeatedlyandforcefullystate.We mustlistentothemratherthanfantasizingthatwe know
better.Electriccars are excellent but the internal combustion engine is going to power the
majorityof road vehicles for decades to come. It is therefore necessary that they are using
the cleanest burning fuels possible. This is not and never will be diesel. For those that
believethatelectriccarsonlyhave the temporary obstacle of ‘range anxiety’ to overcome I
invite youtoconsiderthe meritsof electrichome heating and what role ‘range anxiety’ has
played in the dominance of mains gas in this market.
By enthusiastically embracing the very many technologies that are currently available we
will succeed in providing our children with air fit to breathe.
Noel Lock
Founder,The GreenfuelCompany.
Director,BRC (GB) Ltd.