Consultations


DFA input to recent UK Government consultations:

DFA is active in representing its members’ views to UK Government and to the EU. The following consultations recently have been submitted:

  • Vehicle Technology and Aviation Bill (formerly the Modern Transport Bill)  and ultra low emission vehicle measures
  • Alternative Infrastructure Fuels Directive – New European fuel labelling regulations
  • Proposed amendments to the Road Transport Fuel Obligation Order (2007)

 

Vehicle Technology and Aviation Bill

The DFA has made a submission to the Office for Low Emission Vehicles (part of the DfT)  which is consulting interested parties on the proposed ultra low emission vehicles measures to be included in the Vehicle Technology and Aviation Bill.

What does the Government want? Advice on how best to encourage the creation of a fuelling infrastucture for Electric Vehicles (EV) and hydrogen powered vehicles.

Key points from the DFA response:

  • The existing network of 11,000 EV charging points is adequate at present. Demand for more points will grow as the fleet of EV’s grows and DFA members are considering strategic locations on their networks of petrol forecourts which might be used to meet this demand.
  • The space constraints on many DFA members’ forecourts means that it is not practicable for EV charging points to be installed on them without restricting the area available for re-fuelling vehicles with petrol and diesel.
  • The DFA opposes any mandatory requirement for fuel retailers to provide EV charging points on the forecourt. Many EV’s will be re-charged overnight at home or at non-transport locations such as shopping centre car parks. Also, because the minimum charging time will be 30 minutes, charging at existing petrol forecourts will have to be away from petrol pumps and there may not be space for this on many existing forecourts.
  • The market for hydrogen fuelled vehicles is so small that no case can be made for the investment in hydrogen fuelling at present. There are only 100 such vehicles registered out of a total vehicle population in the UK of 35 million.
  • SUMMARY: DFA members will invest in EV charging points when the market demand emerges. It opposes mandatory legislation requiring investment in charging points which would impose punitive costs on its members.

 

EU Directive on Alternative Fuel Infrastructure (DAFI)  2014/94/EU – new fuel labelling regulations and the proposal for a communication initiative for motorists on new fuel identifiers (EN 16942)

Article 7 of the EU’s DAFI requires EU member states to implement measures to improve the information given to consumers when faced with a choice of fuels for their vehicles. This applies to all fuel types including petrol, diesel, LPG, hydrogen and electricity.

To enable this to happen a new CEN standard has been adopted – EN 16942 – which provides for common fuel “identifiers”. These will be placed on all new vehicles filler caps and on the fuel pumps so that when re-fueling the customer will see the same identifier on the pump as is on their filler cap.

What does the Government want? The UK government was required to transpose this Directive into UK law by October 2016 which it has done, and will enforce the new laws for both new vehicles and fuel pumps from 12 October 2018.

Key Points from DFA and UPEI:

  • DFA is co-operating with other European Trade Associations involved in the vehicle and fuel supply and distribution industries (UPEI, ACEA, ACEM and FuelsEurope) to prepare for the roll-out of the new laws and their practical implementation.
  • DFA supports a co-ordinated implementation of the new directive across Europe to minimise consumer confusion.
  • There is a need to ensure that all customers are fully aware of the new fuel identifiers especially users of existing vehicles which will not have the new fuel identifiers attached to their filler cap.
  • Industries must prepare the necessary information for all vehicle and motorcycle dealers so that the information is available at the dealerships.

 

Renewable Transport Fuel Obligations Order 2007 (Amendments)  and proposed move to 10% biofuels in petrol (E10)

The amendments to this Order aim to increase the percentage of biofuels in petrol as a means of reducing Green House Gas (GHG) emissions and to help meet the UK’s 2020 GHG emission target. The recent Government consultation asked for industry’s views on its proposal to mandate the provision of an E10 fuel on all petrol forecourts – possibly later in 2017.

What does the UK Government want? To define which biofuels and feedstocks that can be utilised; to decide on an appropriate “crop cap” percentage; to obtain evidence of the practicality of having an additional pump for E10 on petrol forecourts and the demand for E10;  and to enquire about unforseen and negative consequences of the proposal.

Key points from the DFA submission:

  • The introduction of E10 is not viable in the timescale envisaged.
  • Whilst the DFA supports the Government’s general policy,  there must be a full consumer education campaign and an adequate lead time before the new fuel is introduced if consumer confusion on forecourts is to be avoided.
  • There are concerns that E10 will increase air pollution and GHG emissions. DFA’s comprehensive research raises serious concerns about the performance of E10 fuels. Fuel consumption (mpg) was down by as much as 2.7% on the urban driving cycle, and average Nitrous Oxide (NOx) emissions were up by 16.6%. NOx is a serious air pollutant and a contributor to GHG.
  • Currently forecourts are configured to supply a maximum of two grades of petrol; current tank capacity means that there is a real danger of retailers having a shortage of tank capacity if they have to supply E10 which fails to sell in adequate quantities – as happened in Germany.
  • The Association supports plans that other fuels including hydrogen, hydrogenated vegetable oil (HVO) , aviation fuel and biobutanol can be included in the list of specified fuels together with biomethane.