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Supplementary Agenda Document Pack - Economic Development and Infrastructure Services Committee - 15/11/2022

Moray Council · 15 November 2022
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Economic Development and Infrastructure Services
Committee 
Tuesday, 15 November 2022 
SUPPLEMENTARY AGENDA 
The undernoted reports have been added to the Agenda for the meeting of the
Economic Development and Infrastructure Services Committee to be held at
Council Chambers, Council Office, High Street, Elgin, IV30 1BX on Tuesday, 15
November 2022 at 09:30. 
BUSINESS 
9a) Climate Change Strategy Update
Report by Depute Chief Executive (Economy, Environment and
Finance)  
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REPORT TO: ECONOMIC DEVELOPMENT AND INFRASTRUCTURE
SERVICES COMMITTEE ON 15 NOVEMBER 2022 
SUBJECT: CLIMATE CHANGE STRATEGY UPDATE 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 This report provides an update to Committee on actions approved within the
Climate Change Strategy (CCS) for 2020-2030, consultancy studies, staffing,
and next steps in order to achieve the Council’s declaration of being net zero
by 2030. 
1.2 This report is submitted to Council in terms of Section III (F) (33) of the
Council’s Scheme of Administration relating to providing, developing and
monitoring the Council’s Economic Development and Infrastructure Services. 
2. RECOMMENDATION 
2.1 It is recommended that Committee consider and note the updates on the
CCS actions. 
3. BACKGROUND 
3.1 Climate change is arguably the biggest challenge that we face in our lifetime
and for future generations.  On the 27 June 2019 the Council made a
Declaration which recognised that climate change is an ecological emergency,
and the Council needs to take necessary actions to protect our area, country
and planet (para 6 of the Minute refers).   
3.2 In response to the commitments made in the declaration, on the 10 March
2021 (para 13 of minute refers) the Council adopted a Climate Change
Strategy for 2020-2030.  The strategy set a goal of the Council being carbon
neutral by 2030 and that the Council, its officers and members will work with
others across Moray to deliver that goal.  The strategy also set out a 57 point
Action Plan to assist in the progress to net zero and it was agreed to
commission further consultancy reports for key actions relating to hydrogen,
buildings and transport.  This is required to allow the CCS to be developed to
include detailed targets, costings and milestones. 
Item 9a)
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3.3 On 6 April 2022 (para 18 of the Minute refers) the Council adopted a route
map for the Council to reach net zero emissions by 2030.  This noted that the
current pathway the Council is on means that 2030 remains in the range of
possible dates when net zero will be met.  It also noted the additional budget
pressure from 2023/24 onwards arising from the new statutory climate change
measures for which external funding will be a major component. 
4. PROGRESS UPDATE 
4.1 To progress the CCS a number of actions were agreed to create a platform for
change.  A number of these actions are being worked up and researched
before they can be developed and delivered.  The phase each action is
currently on is detailed in Appendix 1 and is as follows: 
Phase 1 – Scoping & Research 19
Phase 2 – Design & Developing Business Case 15
Phase 3 - Delivery 27 
61 
4.2 Action Plan updates are reported to the Climate Change board where they are
given a project status if the work is on schedule, on budget, and meeting their
objectives.  A red status means there are serious issues or concerns that
need addressed.  Projects with a red status are discussed in section 4.4.  The
status of the projects can be summarised as follows: 
Summary of Schedule, Budget and Objectives
Type Green Amber Red
Schedule 40 9 0
Budget 34 2 2
Objectives 37 6 0 
4.3 Action Plan Progress
Some key actions are being progressed or delivered, these include:
• Scotland’s Climate Week 2022 provided an opportunity for the climate
change team to work with partners internally (Energy, Sustainable Travel,
and Public Transport) as well as tsiMORAY and others. Visited 5 schools
and met with 600 pupils, also connecting with their teachers. 
• The Moray Council Travel Plan has been updated and an internal working
group has been formed to implement the Actions of the plan.  
• Although delayed for 4-6 months, the NESS energy from waste plant is
expected to be operational in June 2023. This will divert all of Moray’s
waste from landfill and reduce climate change emissions.
• Depot and Store review ongoing and Office use (Smarter Working)
business case in development which will identify surplus assets and permit
removal from asset base. Work continuing with public and 3rd sector
partners to permit use of shared facilities. This will result in lower
emissions from buildings and potentially from altered travel patterns. 
• Guidance for the requirement for climate change and biodiversity
information on committee papers has been published, development of
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guidance for Climate Change Impact Assessment in investment decisions
and capital budgeting is progressing
• Carbon Literacy Training – Training delivered in house. Two courses
delivered, third set for October
• An exercise to calculate whole carbon and whole cost correlations is being
trialled for a Moray Growth Deal project. 
4.4 However there are a number of actions that are identified as red or amber
because of resource constraints and the work not progressing on schedule. Of
particular concern are the following actions.
• Action 1.1: to convert all fossil-fuel based building heating systems to low
or zero carbon alternatives.  While this is still in Phase 2 the design stage,
there are considerable difficulties identified in securing external funding
and in fluctuating material prices. An application for funding to the Just
Transition Fund on behalf of Moray Council, Aberdeen City Council and
Aberdeenshire Councils to commission surveys of various property types
across the north east to assist in decarbonisation was unsuccessful.
Officers are considering how best to undertake surveys to support
decision making. In the meantime officers are developing information on
assets to establish if there are any early wins possible.
• Action 1.3: Complete Learning Estate Asset Management plan to identify
opportunities for 'Heating and Power' refurbishment and implemented
over next 10 years. While PassivHaus (or similar) standards are the
benchmark sought in new build projects, this will incur additional  costs
which will be part of the options appraisal and actively reviewed by council
on a case by case basis.  While this standard will guarantee meeting
energy efficiency targets, current buildings present significant challenges
in terms of technologies and operating costs for non-fossil fuel transition
without consideration of energy efficiency improvements.
Action 2.1 Displace fossil fuelled vehicles and plant with ULEV options.
Our replacement programme has slowed due to global circumstances i.e.
available parts for manufacturer to build vehicles and the Ukraine war.
Lead time for all trucks is approx. 24 months. We cannot progress with
replacing fossil fuel trucks, large vans and pick-ups when the technology
is not yet fully developed and due to the same global issues. This a not
just a Moray Council problem. Cost is also a factor as an Electric vehicle
can cost between 2 and 3 times that of a fossil fuel vehicle and hydrogen
4 times. This issue has to be recognised in future planning and again will
be an active part of options appraisal. A report produced by the Energy
Saving Trust (EST) in 2021 set out an initial overview of the need to
transition and the timing of vehicle replacements that would be necessary
to meet the 2030 target. This is included as Appendix 2 and will contribute
to the decarbonisation strategy being produced. 
4.5 Consultancy studies 
The following consultancy studies are required to allow the creation of a
detailed route map for the Council to reach net zero emissions.
• Hydrogen Strategy: to consider opportunities for the transition of Council
owned buildings and transport fleet, associated infrastructure and
opportunities for business and industry.  A Hydrogen Strategy for Moray
was adopted by the Council on 6 September 2022 (para 10 of the minutes
refers). Feasibility studies on potential projects resulting from the strategy
are being progressed with funding from the NE Just transition Fund.
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• Electric Vehicle(EV) Strategy: to develop a strategy for on and off street
public charging infrastructure for electric vehicles and to identify a rolling
procurement programme for converting the Councils transport fleet to low
emission vehicles.  Work is progressing to develop the EV Strategy into a
document which meets the criteria for funding applications to Scottish
Government. The Strategy will include both proposals for the future sites
and the approach to partnership working in Moray.  The Strategy in its final
draft form will go to ED&I committee for approval in February.
• Buildings Strategy: to calculate current emissions of the Council property
assets and review the planned projects through the Property Asset
Management Plan and the 10 year Capital Plan to create an outline plan
and recommendations.  Officers are developing information on assets to
establish if there are any early wins possible. The results of the study are
scheduled to be completed in 2022/23 although there are concerns that
this might be delayed.   
4.6 Just Transition Fund
Moray Council has been successful in receiving a total of £881k funding from
the North East Just Transition Fund for five interlinked projects to support
Moray’s journey away from fossil fuel. The projects are:
• Buckie Harbour Feasibility Study - Feasibility study to expand Buckie
Harbour to meet the needs of Offshore Wind companies and the existing
Harbour users. 
• Blackhillock Masterplan - masterplan for Blackhillock, Keith, the largest
UK substation receiving power from across the North of Scotland and
Offshore wind sites. 
• Hydrogen Feasibility Study – feasibility work to progress the Moray
Hydrogen Strategy including pilot projects and a Hydrogen Working
Group. 
• Carbon Offset Feasibility Study - to develop Council owned land and open
space to increase Carbon Offset opportunities and biodiversity in line with
a natural capital approach
• Sustainable Development Feasibility Study - the acquisition, design and
development of solutions for vacant and derelict land in urban settings 
4.7 Staffing 
Funding of £75,000 per annum per local authority had been agreed by the
Scottish Government and COSLA to progress work on Local Heat and Energy
Efficiency Strategy (LHEES) for the next five years. On the 6 September 2022
(para 11 of the minutes refers) the Council agreed to appoint a LHEES Officer
for the period of 5 years to deliver LHEES work and additional climate change
priorities. Recruitment to the post is underway. 
4.8 Governance
When the CCS was approved it noted that due to the wide scope of climate
change and climate change related activities, Heads of Service will have
responsibility and accountability for climate change actions and targets within
their service area.  However, they may delegate their responsibility to third tier
managers to ensure that day to day management responsibilities are clear
and that delegated decision making is undertaken at the appropriate level. 
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4.9 A CCS board of Heads of Service has been established to monitor and review
strategic progress in delivering the action plan.  This meets on a quarterly
basis. 
4.10 Wider Community 
TsiMORAY are in talks with Scottish Government to establish a Climate
Action Hub in Moray.  The Climate Change Team have been assisting and if
this is successful the hub will be an opportunity to progress actions 
4.11 Next Steps
Additional future work includes:
• Review route map to net zero incorporating the most recent calculations
of emissions from Council operations.  This will be presented to Council in
May 2023.
• Meet with Service Management Teams to incorporate strategy actions
into individual service plans at next review point.
• Progress adaptation benchmarking process
• Develop whole life carbon accounting process for Moray Growth Deal
projects.
• Determine suitability of Council properties for solar projects
• Develop a climate change communications strategy to promote
behavioural change and crate networking opportunities. 
• Input into implementation of National Planning Framework 4 (NPF4) which
is expected to be laid before Scottish Parliament in November 2022. 
5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The CCS supports the priorities set out in the Corporate Plan and 10
Year Plan. The Council has declared a climate change emergency and
the measures set out in the CCS seek to create a resilient, biodiverse,
fair and more sustainable future for everyone within Moray. 
The strategy is aligned to deliver the following priorities:
• Ensuring a just transition for all in the shift to a low carbon
economy;
• Addressing inequalities of fuel poverty;
• Empowering individuals and communities through education and
information provision to make informed choices with respect to
climate change;
• Protecting and enhancing the world we live in to protect it for the
future; and 
• Being innovative in identifying solutions for cost reduction and
income generation opportunities. 
(b) Policy and Legal
Climate Change (Scotland) Act 2009 places a duty on public bodies to
act in a way they consider most sustainable and in the way best
calculated to deliver emission reduction targets set in the Act. 
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Climate change is increasingly being embedded in all government
policies ranging from Infrastructure delivery, energy policies and NPF4
and these will influence the majority of council policies moving forward. 
(c) Financial implications
To achieve a position of net zero carbon emissions by 2030 will require
significant capital investment for which external funding will have to be a
major component. Progressing actions that are not covered by current
approved plans will require additional budgetary approval through the
normal process. 
(d) Risk Implications
Climate change is arguably the biggest challenge that we face in our
lifetime. It poses significant risks to our health, our economy, our
environment, and endangers the wellbeing of future generations.  There
is a risk that the Council’s aim of being net zero by 2030 will not be
realised if the actions within the CCS are not progressed as a priority. As
set out in the Route Map To Net Zero, 2025 is a decision point when it
should be clearer if the ambitious target of the Council is achievable. 
(e) Staffing Implications
This report has no additional staffing implications. However, workload
around net zero is increasing across services and will continue to add
pressures to existing workloads, especially the ability to apply for
external funding. 
(f) Property
Ongoing progress to decarbonise council property will impact on council
housing, corporate buildings and the Learning Estate. These implications
will be set out in more detail as the key actions relating to Property are
progressed. 
(g) Equalities/Socio Economic Impact
Tackling Climate Change will impact on every service area delivered by
the Council. It has the potential to impact on Equalities for example in
respect of support for active travel and fuel poverty. Delivering individual
elements of the strategy will be screened and, where appropriate,
assessed on their implications for equality and human rights. 
(h) Climate Change and Biodiversity Impacts
All proposals will chiefly and directly support mitigation of, and
adaptation to, the climate and biodiversity crisis. 
(i) Consultations
Consultations have been undertaken with the Chief Executive, the
Deputy Chief Executive (Economy, Environment and Finance), the
Deputy Chief Executive (Education, Communities and Organisational
Development), the Head of Housing & Property, the Head of Economic
Growth & Development, the Head of Environmental & Commercial
Services, the Chief Financial Officer, the Head of Education, the Head of
Education Resources & Communities, the Head of HR, ICT &
Organisational Development, the Head of Governance, Strategy &
Performance, the Equalities Officer, and Lissa Rowan (Committee
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Services Officer). Where comments have been received, these have
been included within the report. 
6. CONCLUSION 
6.1 This report provides an update on progress on the actions identified
within the CCS. 
6.2 Significant external capital investment will be required to decarbonise
Council public buildings and fleet vehicles.   
6.3 An annual update of the route map to net zero incorporating the most
recent calculations of emissions from Council operations will be
presented May 2023. 
Author of Report: Rod Lovie, Principal Climate Change Strategy Officer
Background Papers: 
Ref:
http://spman.moray.gov.uk/MANComRepDraftSite/_layout
s/15/DocIdRedir.aspx?ID=SPMAN-813460984-315
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APPENDIX 1
Overview of Actions
Key
Phase 1 - Scoping & Research
Phase 2 - Design & Developing Business Case
Phase 3 - Delivery 
No. Action
2021/22
2022/23
2023/24
2024/25
2025/26
2026/27
2027/28
2028/29
2029/30
2030/31
1.1 Convert all fossil fuel heating systems to low carbon
alternatives.                    
1.2 Increased renewable energy generation from council
assets.                    
1.3 Complete Learning Estate AMP.                    
1.4 Implement zero carbon standards in new buildings.                    
1.5 Achieve EESSH for all council houses.                    
1.6 Increased building user awareness on energy usage.                    
2.1 Displace fossil fuelled vehicles and plant with ULEV
options.                    
2.2 Develop and promote Travel Plans for council, etc.                    
2.3 Promote and enhance active travel at schools.                    
2.4 Develop strategy and guidance for public EV charging
facilities.                    
3.1 Reduction of waste landfilled through diversion to
energy recovery.                    
3.2 Reduce waste through reuse and recycling.                    
3.3 Support creation and promotion of community benefit
wish list.                    
4.1 Support homeworkers to reduce their emissions.                    
4.2 Ratify buildings and develop shared facilities.                    
4.3 Apply zero and low carbon objectives in all investment
decisions.                    
4.4 Ensure CCS and CCAP remain fresh and valid until
2030.                    
4.5 CC and Biodiversity assessment as part of all
committee papers.                    
4.6 Deliver carbon literacy training.                    
4.7 Update CC awareness training as part of staff
induction process.                    
4.8 Pilot a network of staff climate change champions.                    
4.9 Support networking opportunities for teachers and
pupils on CC.                    
4.10 Increase opportunities for Learning for Sustainability
in schools.                    
4.11 Continue to reduce carbon impact of school meals.                    
4.12 Improve sustainability and recycling in cll buildings                    
4.13 Increase use of virtual environment for information.                    
4.14 By default ICT equipment to operate in most energy
efficient mode.                    
4.15 Promote and increase opportunities for remote
working.                    
5.1 Continue to develop the non-cash benefits through
procurement.                    
5.2 Implement updates into procurement process.                    
Item 9a)
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5.3 Develop simple process for suppliers to evidence
carbon reduction.                    
5.4 Develop action plan for raising awareness of local
businesses.                    
5.5 Develop sustainable procurement guidance and
inform lead officers.                    
6.1 Commission research for baseline carbon inset                     
6.2 Development of Indicative Carbon Offsetting Plan.                    
6.3 Large scale tree planting on TMC owned land.                    
6.4 Tree planting in partnership with landowners in
Moray.                    
6.5 Innovative carbon offsetting projects.                    
6.6 Community offsetting projects.                    
7.1 Deliver LHEES programme.                    
7.2 Continue the HEEPS programme.                    
7.3 Promotion of the Active Travel Strategy.                    
7.4 Increase relevant skills and knowledge for a greener
economy.                    
7.5 Feed into the development of Moray apprenticeship
strategy.                    
7.6 Support awareness raising for businesses.                    
7.7 Development on CC Engagement Strategy.                    
7.8 Assist effective governance for CC priorities for Moray.                    
7.9 Consult community groups and residents about
climate change                    
7.10 Reporting and monitoring of results in area-wide
emissions.                    
7.11 Support the work of the Moray Climate Assembly.                    
7.12 Engage with local communities to facilitate renewable
energy                    
7.13 Develop and promote Moray-specific climate
emergency training                     
7.14 Promote national campaigns.                    
7.15 Join support networks to assist the progress of climate
change work                     
7.16 Implement NPF 4 policies relating to the climate crisis.                    
7.17 Develop Regional Spatial Strategy                    
7.18 Review Forest and woodland strategy                    
7.19 Develop 20 minute neighbourhood concepts for
Moray’s main towns                    
7.20 Promote and support brownfield development over
greenfield development.                    
7.21 Deliver Moray Growth Deal Housing Mix Delivery
project.                    
7.22 Review and support Food Growing Strategy and Open
Space Strategy                     
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www.energysavingtrust.org.uk
By: Alex Foyn
02/01/2021
www.energysavingtrust.org.uk
Fleet decarbonisation report
Moray Council
Item 9a)
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Contents
1. Terms & definitions .................................................................................................... 4
2. Introduction ................................................................................................................ 6
3. Executive summary ................................................................................................... 9
4. Summary of recommendations ................................................................................ 11
5. Carbon footprint ....................................................................................................... 12
5.1. Data quality and assumptions ........................................................................... 12
5.2. LA owned fleet overview ................................................................................... 12
5.3. Grey fleet overview ........................................................................................... 14
6. Fleet profile .............................................................................................................. 16
6.1. Age distribution ................................................................................................. 16
6.2. Carbon emissions ............................................................................................. 17
6.3. Euro status ....................................................................................................... 19
6.4. LEZ compliance ................................................................................................ 20
7. Fleet recommendations ........................................................................................... 21
7.1. Rationalise your fleet ........................................................................................ 21
7.2. Follow the sustainable travel hierarchy ............................................................. 22
7.2.1. Adopt eBikes .................................................................................................. 24
7.2.2. Adopt eCargo bikes ....................................................................................... 24
7.3. Install telematics in all fleet vehicles ................................................................. 25
7.4. Downsize vehicles where possible .................................................................... 26
7.5. Adopt ZEVs ...................................................................................................... 27
7.5.1. ZEV car replacement ..................................................................................... 29
7.5.2. ZEV LCV replacement ................................................................................... 30
7.6. Use a whole life cost procurement method ....................................................... 32
8. Fleet decarbonisation strategy ................................................................................. 34
8.1. Vehicle replacement profiles and plans ............................................................. 34
8.1.1. Cars ............................................................................................................... 35
8.1.2. LCVs .............................................................................................................. 36
8.1.3. HDVs ............................................................................................................. 38
9. Charging infrastructure requirement ......................................................................... 40
9.1. Charging site Considerations ............................................................................ 40
9.2. Types of chargers ............................................................................................. 42
9.2.1. AC or DC charging and smart management ................................................... 42
9.2.2. Basic chargers ............................................................................................... 42
9.2.3. Smart chargers .............................................................................................. 43
9.2.4. Rapid chargers............................................................................................... 43
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9.3. Load management ............................................................................................ 43
9.4. Energy storage and solar PV ............................................................................ 46
9.5. Emerging technology ........................................................................................ 47
9.5.1. Inductive (wireless) charging .......................................................................... 47
9.5.2. Vehicle to grid (V2G) ...................................................................................... 47
9.6. Charging profiles .............................................................................................. 47
9.6.1. Socket per vehicle .......................................................................................... 47
9.6.2. Charge vehicles on a rota .............................................................................. 48
9.6.3. Charging vehicles at home ............................................................................. 49
9.6.4. Getting the timing right ................................................................................... 49
9.7. Estimated infrastructure costs ........................................................................... 50
9.8. Engagement with the DNO ............................................................................... 51
10. Conclusion ............................................................................................................... 52
11. References .............................................................................................................. 54
Appendix 1 GHG Methodology – Road Transport ..................................................... 56
Appendix 2 Euro standards ....................................................................................... 66
Appendix 3 Air quality, public health and LEZs ......................................................... 67
Appendix 4 ZEV HDVs, RCVs and SPVs .................................................................. 71 
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1. Terms & definitions
▪ AC – alternating current electricity
▪ AFR (advisory fuel rate) - the rates set by government as guidance for
reimbursing fuel costs
▪ BEV (battery electric vehicle) – a vehicle driven solely by a battery powered
electric motor(s)
▪ CAZ (clean air zones) -areas in towns and cities that restrict access to vehicles
with emissions over a certain threshold to improve air quality. Restrictions vary in
different cities, with vehicle access usually granted by paying a fee or restricted
to certain times of day (like LEZs)
▪ Carbon footprint – is the tonnage of greenhouse gases emitted over the period
of a year by an organisation/vehicle
▪ Charge point – a single piece of charging equipment housing one, two or three
sockets for charging BEVs. Depending on the specification of the charge point, it
will deliver AC electricity at up to 7.4kW, 22kW or 43kW, or DC electricity at up to
50kW. The rate at which electricity can be drawn will also depend on the vehicle
▪ Charger - another term for a charge point
▪ CO2e (carbon dioxide equivalent) – a standardised method of measuring a
carbon footprint where the impact of different greenhouse gases is expressed in
terms of the equivalent quantity of CO2 emitted to create the same amount of
warming
▪ DC – direct current electricity
▪ DNO (distribution network operator) – the owner and operator of power lines and
infrastructure in an area’s electricity transmission network
▪ EV – Electric Vehicle
▪ GHG (greenhouse gas) – gases in the atmosphere responsible for reflecting
solar radiation back towards the Earth’s surface. Higher levels of greenhouse
gases are responsible for atmospheric warming. Common Greenhouse gases
include water vapor, carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O),
and ozone (O3)
▪ HDVs (heavy duty vehicles) – freight vehicles with a gross vehicle weight of more
than 3.5 tonnes (trucks) or passenger transport vehicles of more than 8 seats
(buses and coaches)
▪ HFCV (hydrogen fuel cell vehicle) – a vehicle powered by a fuel cell generating
electricity using compressed hydrogen and oxygen from the air. This is not
plugged-in and is refuelled in a similar way to petrol / diesel ie via a pump
▪ ICE (internal combustion engine) vehicle – a vehicle powered by a diesel or
petrol engine
▪ kWh (kilowatt-hour) - is a unit of energy equal to one kilowatt (kW) of power
sustained for one hour
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▪ LCV (light commercial vehicle) – vans with a gross vehicle weight of up to 3.5
tonnes
▪ LEZ (low emission zone) - areas in towns and cities that restrict access to
vehicles with emissions over a certain threshold to improve air quality.
Restrictions vary in different cities, with vehicle access usually granted by paying
a fee or restricted to certain times of day. (like CAZs) 
▪ NIC – national insurance contribution
▪ OZEV - Office for Zero Emission Vehicles
▪ Particulate matter (PM) – also known as aerosols are fine particles either solids
or liquids suspended in the air. These can be natural, like pollen, or manmade
such as soot. Inhaling some types of PM can be damaging to health
▪ PHEV (plug-in-hybrid electric vehicle) – a vehicle driven by either an electric
motor powered by the battery, a petrol/diesel engine, or a combination of both.
This has two separate drive trains
▪ Power Factor - an expression of energy efficiency. It is usually expressed as a
percentage - the lower the percentage, the less efficient the power usage
▪ PSVs (public service vehicles) – public transport vehicles (typically over nine
seats) including buses and minibuses
▪ PV (photovoltaics) – materials used in solar panels to convert light into electricity
▪ SMR – service maintenance & repair
▪ State of charge (SoC) – the level of charge of a battery ie a battery with a SoC of
100% would be said to be fully charged
▪ SUVs (sport utility vehicles) – larger vehicles with four-wheel drive, traditionally
for multipurpose off-road use, but have recently become popular for all uses,
including in an urban setting
▪ VED (vehicle excise duty) – a tax paid by vehicles corresponding to their CO2
emissions
▪ WLC – whole life costs
▪ ZEV (zero emissions vehicle) – a vehicle that emits no tailpipe emissions, can be
a BEV or a HFCV
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2. Introduction
The Scottish Government declared a climate emergency in April 2019 and has set
some of the most ambitious climate change targets in the UK. Moray Council
followed suit by declaring a climate emergency in June 2020, one of the earliest
local authorities in Scotland to do so. Moray also set ambitious targets in
September 2020 to become carbon neutral by 2030. Domestic transport accounts
for 31 percent of all greenhouse gas emissions in Scotland (see Figure 2-1). To
combat transport emissions and improve air quality the Scottish Government’s
Programme for Scotland (2019/20) set bold targets to phase out petrol and diesel
vehicles, especially within public sector fleets: 
“We will work with public bodies to phase out petrol and diesel cars from our public
sector fleet and phase out the need for any new petrol and diesel light commercial
vehicles by 2025.” (Scottish Government, 2019) 
Figure 2-1- Greenhouse gas emissions 2018: estimates, grouped by National Communication
category (Scottish Government, 2020)
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Transport powered by fossil fuels is killing us. By polluting the air we breathe with
Nitrogen Dioxide (NO2) and particulate matter (particularly PM10 and 2.5), air
pollution in the UK is linked to 40,000 deaths a year (Royal College of Physicians,
2016). A high proportion of these pollutants come from burning fuel in our vehicles,
wear on our tyres and particulates from our brake pads. Climate change is often
viewed as a huge global crisis; however air quality is a crisis on our doorstep and is
directly affected by localised emissions. Decarbonising and rationalising our fleets,
as well as driving less and using public and active travel more, is key to making our
cities, towns, and villages cleaner and healthier places to live. In doing so, we will
also be reducing our contribution to climate change and preserving our world for
future generations. 
Vehicles have been getting cleaner, on average emitting less CO2e per mile driven
than they have in the past. But with the current trends of driving larger vehicles
such as SUVs and with more vehicles on the road, there has been virtually no
change in the transport sector’s total CO2e emissions since the 1990s, shown as the
light blue line in Figure 2-2. The public sector must lead the way, to show that we
are committed to the climate agenda, and that climate change and air quality are
priorities for the government. 
Grant funding for the adoption of zero-emission vehicles (ZEVs) will not be around
forever. As the cost of ZEVs comes down, and price parity with internal combustion
engine (ICE) vehicles is met, there will be no further requirement for additional
Figure 2-2 - GHG emissions by sector change (1990 - 2018) (Scottish Government, 2020)
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funding support. As public sector organisations are able to access frameworks
and procurement channels that are not available to other organisations, you are
able to access large discounts that will substantially reduce ZEV costs. As cost
parity is approached between ICE and BEV cars it is likely that Switched on Fleets
support will be reduced. It is therefore important that you develop your own
financial plans to replace all of your ICE cars with ZEV cars by the target date of
2025. 
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3. Executive summary
The Scottish Government has declared a climate emergency. In line with this, it has
set several targets to reduce emissions from transport, as these make up a large
part of the country’s total carbon emissions. For the public sector, these targets
include phasing out petrol and diesel cars by 2025; phasing out the need for new
petrol and diesel vans from 2025; and phasing out the need for petrol and diesel
versions of all other vehicles from 2030. You therefore need to take action to
ensure your fleet meets these targets.
LCVs make up the largest segment of your vehicle fleet at just over 52%. followed
by HDVs and cars with 27% and 20% respectively. PSVs make up the remaining 2%. In
terms of total fleet CO2e emissions, your fleet emits a total of 3,227t CO2e annually.
HDVs contribute the greatest amount with 62% of total emissions; LCVs contribute
29%, cars, 5% and PSVs 3%.
Your car fleet comprises 91 vehicles of which 12 are zero-emission vehicles. These
are eight Vauxhall Corsa-Es, two Nissan Leafs, one Peugeot Ion and one BMW I3.
Reducing your car fleet emissions to zero is a feasible target with currently
available vehicles. As part of this work, you should implement a sustainable travel
hierarchy to reduce unnecessary journeys. For unavoidable journeys, you should
replace your ICE vehicles with ZEVs to create a zero-emission fleet. All of your cars
are due to be replaced before 2025, so you are on track to meet the government’s
target provided these vehicles are replaced on schedule with ZEVs.  Replacing all
cars with BEVs will provide an estimated annual saving of approximately £29,402
and 91t CO2e1.
As LCVs make up the largest portion of your fleet, you should also look to replace
these with ZEVs where you can. Currently, the number of ZEV LCV replacement
options available decreases with increasing vehicle size, however the number of
new ZEV models being manufactured is increasing. If a ZEV alternative is not
currently available, you should consider delaying the replacement until more zero-
emission alternatives are available, or downsizing the vehicle if the larger capacity
is not required. Replacing all LCVs with BEVs will provide an estimated annual
saving of approximately £245,627 and 579t CO2e1.
Older vehicles are less efficient, incur greater fuel and repair costs, and emit more
CO2e. The average age of your fleet is just over six years, but you have several
vehicles over ten years old. Following your fleet replacement plan you will replace
all your vehicles at least once by 2031 and all of your car fleet by FY2023/24. When
following the fleet replacement plan, you should consider how ZEV availability will 
1 The design of the calculators used to make this report’s financial estimates and those relating to CO2e results
in very precise savings forecasts. In practice, due to variance in real world situations, these values should all be
taken as approximate.
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change over the next decade. Particularly for larger LCVs as these have fewer
suitable ZEV replacements in the current market. When you are replacing any such
vehicle, if a ZEV alternative is not available you should investigate downsizing the
vehicle or taking on a Euro 6 model.
Alongside adopting BEVs, you need to investigate charging solutions to
accommodate your growing electrified fleet. As we did not have data on your
depots’ electricity use nor their electrical capacities, we were unable to conduct
detailed analysis on what charging infrastructure you could install at these sites.
However, the key things to consider when designing and implementing charging
infrastructure are:
• Site constraints – these can be determined by comparing the available
site electrical capacity with current site demand
• The duty cycles of vehicles based at the site – how much time they
have available to charge each day
• The daily mileage requirements of the vehicles based at the site
• The energy requirements of the vehicles based at the site – this will vary
depending on each vehicle’s efficiency
• Engagement with your distribution network operator (DNO) – this should
happen as early in the design process as possible to highlight issues
that may arise and to speed up the installation phase
Following the recommendations in this report will help you decarbonise your fleet.
However, replacing ICE vehicles with ZEVs on a like-for-like basis is not the only
solution to combating the climate emergency. It is also important that you reduce
the number of journeys you take, use active travel more often, downsize your
vehicles, and reduce the number of vehicles you operate.
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4. Summary of recommendations
The design of the calculators used to make this report’s financial estimates and
those relating to CO2e results in very precise savings forecasts. In practice, due to
variance in real world situations, these values should all be taken as approximate. 
2 Based on a 5% reduction in fuel cost for company owned fleet. Implemented robustly, this will also tackle grey
fleet mileage which will reduce costs further.
3 Savings are based on all vehicles being replaced with ZEV alternatives. However, not all vehicles will be
suitable on a like for like replacement basis. Percentage savings will translate to individual vehicle
replacements. 
4 All savings are absolute; therefore, by adopting multiple recommendations actual savings will vary.
5 Savings do not include reduction in grey fleet CO2 emissions and mileage claims unless stated.
Description of recommendation Ease Estimated
% saving
Estimated
annual
saving (£)
Estimated
annual
emission
reductions
(CO2e tonnes)
Install telematics in all vehicles Moderate
This will not directly reduce CO2 emissions or costs. But
by analysing the data and using this in tandem with fuel
efficient driver training and the travel hierarchy, you will
be able to maximise savings.
Implement a robust travel hierarchy that
will reduce unnecessary journeys and
encourage active travel
Easy 5%2  £25,702 54t CO2e
Replace all ICE cars with ZEV alternatives
at the next replacement cycle. Easy
355% reduction in CO2e
emissions and 41%
reduction in fuel costs 
£29,402 91t CO2e
Replace all ICE LCVs with ZEV alternatives
at the next replacement cycle. Easy
263% reduction in CO2e
emissions and 55%
reduction in fuel costs 
£245,627 579t CO2e
Downsize fleet vehicles where possible Moderate Up to 25% per vehicle downsized
Develop the financial plan for replacing all
vehicles with ZEVs Moderate Carbon, fuel costs, VED and SMR costs will all decrease
significantly; the extent varies with vehicle size.
4,5
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5. Carbon footprint
5.1. Data quality and assumptions
The method used to calculate CO2e emissions is dependent on the quality of the
data available. There are five methods available. Method one is the most accurate
as it uses the fuel type and the litres used. Method five is the least accurate as it
uses the vehicle mileage and the emissions of an average vehicle in the UK.
Appendix 1 provides further details of the methods used to calculate fleet CO2e
emissions.
For this report, you provided us with annual mileage and fuel type data for most of
your vehicles. For 17 of these, DVLA data was unavailable so emissions could not be
calculated. These included eight Vauxhall Corsa-Es funded by Switched on Fleets
in FY 2019/20, a Vauxhall Movano Tipper and six of your eight PSVs. For these
vehicles, an assumed CO2e/km was estimated based on the vehicles’ weight and
used to calculate annual CO2e emissions with the milage provided.
The data also included the total mileage of external hire car used. As there was no
record of the individual vehicle details, the CO2e/km of an average diesel car was
used to calculate the carbon footprint.
5.2. LA owned fleet overview
The fleet CO2e footprint (carbon footprint) quantifies the carbon dioxide that has
been emitted by your fleet over a year. The estimate does not include the life cycle
CO2e emissions from vehicle manufacture and disposal, or from fuel refining and
distribution.
One tonne of CO2e is produced when 390 litres of diesel is burnt at a cost of around
£510 (based on 2019 UK fuel prices (BEIS, 2020)). Every litre of fuel burned, or mile
driven, also results in emissions of nitrogen oxides and particulate matter
(emissions with a negative impact on public health). More information on air
quality can be found in Appendix 3. These emissions vary depending on driving
behaviour, usage cycle, engine condition and the effectiveness of the exhaust gas
cleaning system. Average non-greenhouse gas (GHG) emissions from UK car, van
or heavy-duty vehicles (HDV) are published by the National Atmospheric Emissions
Inventory. 
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13 
Table 5-1 and Figure 5-1 show the fleet’s CO2e footprint broken down by fleet
segment. The CO2e totals were calculated using (where available) the fuel use in
litres, fuel type and the 2019 Greenhouse Gas (GHG) conversion factors published
by the UK government (BEIS, 2019). Note that Figure 5-1 does not include the external
hire cars.
Figure 5-1 shows that there is not a direct link between carbon emissions and the
number of vehicles in a fleet segment. In absolute numbers, cars account for 20%
of the entire fleet but contribute 5% of all CO2e emissions, whereas HDVs account
for 27% of the entire fleet but contribute 62% of all CO2e emissions. LCVs and PSVs
account for the remaining 29% and 3% respectively. This demonstrates that some
vehicle types, typically larger ones, are less efficient, and more polluting than 
6 No OEM CO2e g/km data available for PSVs, therefore some assumption had to be made see Section 5.1
7 No record of the individual vehicle details so average CO2e/km values were used, see Section 5.1 for more
details
27%
32%
62%
52%
48%
29%
20%
17%
5%
2%
3%
3%
0% 20% 40% 60% 80% 100%
Fleet size
Annual mileage (miles)
Annual CO2e emissions
HDVs LCVs CAR PSVs
Fleet group Fleet size
(vehicles)
Annual
mileage
(miles)
Annual CO2e
emissions
(tonnes)
CARS 91 932,380 170
LCVs 235 2,587,158 945
HDVs 121 1,682,421 2,005
PSVs 8 137,972 1066
External Hire Cars nd 218,253 597
Total 455 5,558,184 3,285
Table 5-1 - Fleet carbon footprint
Figure 5-1 - Fleet carbon footprint by fleet type
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others. This also highlights the scale of the challenge ahead for Moray Council to
transition to ZEVs and to net zero CO2e emissions. 
5.3. Grey fleet overview
You currently operate a grey fleet which covers 1.2 million miles and costs an
estimated £571,680 annually (shown in Table 5-2). Without data on the vehicles
used, it is not possible to build a detailed profile of this fleet. However, grey fleet
vehicles are typically older and more inefficient, which means you are likely to be
paying more for miles driven by a polluting fleet. The data provided included only
the total annual mileage. As the individual vehicle’s gCO2/km emissions values
were not recorded, we used the average emissions value for all cars on the road in
2019 (177.1gCO2e/km) (BEIS, 2019) to calculate an approximate carbon footprint for
your grey fleet. We estimate that your grey fleet emits 362t CO2e annually, over
double that of your owned car fleet.
As we were not provided with individual claimants, we cannot perform more
detailed analysis, however Figure 5-2 outlines the profile of an average local
authority grey fleet. For this grey fleet, a large portion of drivers (58%) claim
relatively few miles (under 1,000 miles per year) and are responsible for only 12% of
the total miles claimed. A small number of drivers claim most of the miles. In this
case, over 50% of the total miles are claimed by only 16% of the drivers, and these
drivers are all travelling over 3,000 miles annually.
Table 5-2 - Grey fleet profile 
As you do not have any direct control over the vehicles in this fleet it is unlikely that
this area of your transport emissions (approximately 362 tonnes of CO2e) will
reduce in line with your owned fleet ambitions. We therefore recommend that you
regain control of this element of your fleet by introducing more pool cars, hire cars
or car club vehicles as alternatives. While also ensuring that staff follow the
sustainable travel hierarchy.  Collecting individual grey fleet claim details will allow
you to focus on the highest mileage claimants as a priority. This will not only
reduce CO2e emissions, but will also result in a significant cost saving, which can
then be ring-fenced for fleet decarbonisation. 
Annual
mileage (miles)
Annual CO2e
emissions (tonnes)
Annual grey fleet
claims cost (£)
1,270,401 362 571,680
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Figure 5-2 - Grey fleet claimant profile
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6. Fleet profile
Your fleet is made up of a variety of cars (20%), LCVs (52%), HDVs (27%) and PSVs
(2%). Cars make up 20% of the fleet, with a total of 91 vehicles, the most common
model being the Vauxhall Corsa. Your car fleet also currently includes 12 ZEVs;
these are eight Vauxhall Corsa-Es, two Nissan Leafs, a Peugeot Ion and a BMW I3.
Your 235 LCVs make up the largest segment of your fleet. These are a mixture of
primary panel vans, tippers and car derived vans. The most common models are
the Vauxhall Corsa van (50), Vauxhall Movano (47) and Ford Transit 350 (28). The
fleet also includes five BEVs, all of which are Nissan E-NV200s.
The HDV fleet is made up of a variety of weights, chassis types and body types and
will prove the most difficult to decarbonise. You have a small number of PSVs
which may also be challenging to replace with ZEV alternatives. However, it is
encouraging to see that you already have an electric PSV on your fleet, the Optare
Solo M890 Auto. As these replacements have the highest potential CO2e savings, it
is good that you are already focusing on this fleet segment. Collaboration will play
an important part in enabling all of Scotland’s local authorities to switch to ZEVs.
We would therefore encourage you to share your findings relating to the operation
of zero-emission PSVs with colleagues across the country, to assist them in
smoothly transitioning their fleets to these vehicles.
6.1. Age distribution 
Table 6-1- Fleet age profile (years) number of vehicles by fleet group 
0-1 1-2 2-3 3-4 4-5 5-6 6-7 7-8 8-9 9-10 10-11 11-12 12-13 17-18 Unknown
CAR 7 17 7 15 41 1 2 0 0 1 0 0 0 0 0
LCV 1 39 38 18 44 41 23 17 6 7 0 0 0 0 1
HDV 19 5 11 6 7 8 10 13 12 20 2 6 1 1 0
Total 27 61 56 39 92 50 35 30 18 28 2 6 1 1 1
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
HDVs
LCVs
CAR
0-1 1-2 2-3 3-4 4-5
5-6 6-7 7-8 8-9 9-10
10-11 11-12 12-13 17-18 Unknown
Figure 6-1 - Fleet age profile (years) proportion of vehicles within fleet group
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Figure 6-1 shows the age profile of your vehicles as a percentage of the various
fleet segments; Table 6-1 shows your fleet age profile in absolute numbers. Over
40% of the whole fleet is at least five years old, with a small number over ten years
old. The oldest vehicles are HDVs, which is common as their high costs tend to
result in a longer lifecycle. Careful consideration should be given to the timing of
replacing vehicles with longer replacement cycles. We suggest that to meet the
ZEV adoption targets, you aim to avoid a situation where relatively new ICE vehicles
have to be replaced in the late 2020’s.
Vehicle age is a key consideration as it impacts adversely on:
▪ fuel consumption - older engines are less efficient
▪ air quality - older engines are significantly more polluting
▪ safety – older vehicles have less safety equipment
▪ reliability – older vehicles require more regular maintenance
▪ service delivery – older vehicles are more likely to have breakdowns,
which can be disruptive and costly
6.2. Carbon emissions
Vehicle excise duty (VED / road tax) for cars is determined by their CO2 emissions.
Figure 6-2 outlines the VED bands and the corresponding CO2 emission range for
each band. This banding scale is useful as we can use it to profile the emissions of
the car and LCV fleet. Unfortunately, it cannot be used for all fleet segments as
manufacturer claimed CO2 emissions are not available for all vehicle types.   
Figure 6-2 - VED bandings (post April 2017 scale)
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Your fleet emits a total of approximately 3,227t CO2e annually, with the highest
portion emitted by your HGV fleet. Figure 6-3 shows the CO2 emission profile of the
current Moray Council car and LCV fleet. This colour chart can be used as a
baseline for measuring future CO2 emission improvements in these fleet segments.
The chart highlights the proportion of ZEVs already in the fleet as band A. At
present, there are 18 ZEVs in your fleet, the 12 cars and five LCVs shown in Figure 6-3,
and one Optare Solo M890 Auto PSV, all of which are battery electric (BEVs). Cars
are the easiest segment to replace with ZEVs. You should therefore replace the
remaining ICE cars with ZEVs at their next replacement cycle to meet the 2025
government target. 
While you have five ZEVs within the LCV fleet (all Nissan E-NV200s), these only make
up 2% of your entire LCV fleet. As many LCVs are small vans with multiple ZEV
alternatives already available, you should target this segment for early ZEV
adoption. You can transition your larger vans once there are more ZEV options
available on the market.  
A
A B
D
D
E
E
F
F
G
G
H I J K L
Unknown
0% 20% 40% 60% 80% 100%
LCVs
CAR
A B D E F G H I J K L Unknown
Figure 6-3 – Moray Council LCV and car fleet VED profile (post April 2017 banding)
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6.3. Euro status
Table 6-2 - Fleet Euro standards
Fleet
group ZE E6 E5 E4 E3 nd
CARS 12 76 3  
LCVs 5 111 114 4  1
HDVs  54 62 4 1 
Total 17 241 179 8 1 1 
The Euro standard is a measure of the harmful exhaust emissions being produced
by a vehicle (see Appendix 2 for more information). From a public health
perspective, the two air pollutants of most concern are nitrogen oxides (NOX) and
particulate matter (PM).  There are different Euro standards for petrol and diesel
vehicles.  For example, a 2006 Euro 4 petrol car and a 2016 Euro 6 diesel car
produce a similar amount of harmful emissions. 
Figure 6-4 shows the Euro standard profile of your whole fleet. As a minimum,
vehicles should be Euro 6 compliant. Currently 42% of your fleet is Euro 5 or lower.
Just over 3% of cars are not Euro 6 compliant which may be a reflection of the age
of these vehicles. Ensuring vehicles are at least Euro 6 compliant should be
addressed as a priority during the next replacement cycle.
The LCV and HDV fleets currently have a high proportion of vehicles classed as
Euro 5 or lower, with 51% and 55% respectively. We recommend that you aim for a
Euro 6 standard as a minimum. The large number of small vans in your LCV fleet
can be replaced easily with ZEVs due to the wide range available on the market.
This segment of your fleet should be targeted before your HDVs as the
replacement of these is more feasible. The range of zero-emission HDVs is
expected to expand in the next few years. This should be considered when
designing your vehicle replacement plan.  
ZE
E6
E6
E6
E5
E5
E5
E4 E3
nd
0% 20% 40% 60% 80% 100%
HDVs
LCVs
CAR
ZE E6 E5 E4 E3 nd
Figure 6-4 - Fleet Euro standards
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6.4. LEZ compliance
Figure 6-5 - Fleet LEZ compliance 
Across the UK, local authorities are implementing Low Emission Zones or Clean Air
Zones (LEZ/CAZ) (see Appendix 3). In Scotland, Glasgow is the first city to announce
the minimum standards for penalty-free entry. The minimum standards for the
Glasgow LEZ are as follows:
▪ Euro 4 petrol engine
▪ Euro 6 (Euro VI) diesel engine
▪ Zero-emission vehicle
The Edinburgh, Dundee and Aberdeen LEZs are currently in consultation but are
expected to follow the same standards. More information on LEZs can be found on
the Low Emission Zones Scotland website. 
Table 6-3 - Fleet LEZ compliance
Row Labels Yes No
HDVs 45% 55%
LCVs 49% 51%
CAR 97% 3%
Total 58% 42%
Table 6-3 shows that at least 42% of your entire fleet is not currently compliant with
Scottish LEZs. We recommend that these vehicles are replaced as a priority with
vehicles which meet, or exceed, the minimum LEZ standards. Where possible, you
should be looking beyond Euro 6 to zero-emission vehicles. 
45%
49%
97%
55%
51%
3%
0% 20% 40% 60% 80% 100%
HDVs
LCVs
CAR
Yes No
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7. Fleet recommendations
There are several actions you can take to decarbonise your fleet. 
Rationalise your fleet
You should continually try to rationalise your fleet to make sure that it is as small
and efficient as possible. This will help to reduce your costs and CO2 emissions.
Follow the sustainable travel hierarchy
You should follow the sustainable travel hierarchy (see Figure 7-1 below). The
hierarchy encourages people to choose the solution with the lowest CO2 emissions
when deciding how to travel. The first thing to consider is whether you can avoid
the journey completely by using remote working technologies, as this provides the
largest CO2 and cost savings. Staff should be encouraged to choose travel options
as close to the top of the hierarchy as possible.
Use telematics
You should install a telematics system in all fleet vehicles. With good quality data
on your fleet use you will find it easier to develop a plan to transition to zero-
emission vehicles.
Downsize vehicles
You should downsize vehicles wherever possible, as smaller vehicles are simply
more efficient than larger ones. Smaller vehicles have lower CO2 emissions and
fuel costs. An additional benefit to downsizing LCVs is that there is currently a
greater choice of smaller zero-emission LCVs than larger ones.
Adopt ZEVs
You should use zero-emission vehicles wherever possible. It is important you
establish your actual vehicle requirements so that you can select the cheapest
and lowest emission option for each.
7.1. Rationalise your fleet
Fleet rationalisation is the process of reducing the size of your fleet to ensure that
each vehicle is used as efficiently as possible. This involves examining the usage of
each vehicle and removing any vehicles that are excess to requirements. This can
provide significant cost savings as less vehicles need to be leased, purchased and
insured. This also provides CO2 savings as each vehicle has CO2 emissions
imbodied in its production. 
It will be important to rationalise your fleet as you recover from the Covid
pandemic. The pandemic has encouraged widespread use of remote working
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technology and this is likely to have a permanent impact on the number of miles
that you need to physically travel. This means that you may no longer need some
of your fleet vehicles. Aside from the impact of the Covid pandemic, encouraging
staff to follow the sustainable travel hierarchy (ie encouraging remote working,
active travel, public transport use, car sharing and car clubs) naturally leads to a
reduction in the need for fleet vehicles. Fleet rationalisation should therefore be a
continual part of your fleet management activity.
7.2. Follow the sustainable travel hierarchy 
First and foremost, if you don’t need to travel, you shouldn’t. This is the simplest,
most cost effective and immediate way to reduce CO2e emissions, improve air
quality and save money. COVID-19 has shown how useful, powerful, and
appropriate video conferencing can be in delivering everything from team
meetings to interviews and stakeholder engagement. Using video technology can
bring substantial efficiencies to business by cutting out the time lost to travelling. It
can also help improve communication and team working. This should be your first
step in implementing a sustainable travel hierarchy or building a sustainable
travel or decarbonisation strategy.   
Active travel should replace short trips that may otherwise be completed using a
vehicle. You can encourage staff to choose the most sustainable travel option by
introducing a travel hierarchy for all staff and providing incentives such as pool
ebikes / bikes. The aim of this is to guide staff through a decision-making process
that will help them choose the most sustainable mode of transport possible. A
simplified sustainable travel hierarchy can be seen in Figure 7-1.
Figure 7-1 - Sustainable travel hierarchy
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The benefits of active business travel are:
▪ reduced or free travel costs
▪ healthier and more productive staff – staff that use active travel take on
average 50% less sick days per year than those who don’t (Sustrans,
2013) 
▪ reduced parking space provision and associated costs
▪ reduced congestion
▪ contribution to improved air quality
▪ potential to combine with public transport.
Short local business journeys of up to three miles from the office could potentially
be completed by active travel ie walking and cycling.
Way to Work is a new time-saving tool which helps workplaces in Scotland to
promote active and sustainable travel. It showcases funding, training, advice and
activities available, alongside inspiring case studies and the latest sustainable
travel news. 
Utilising software designed to advise users on the most efficient mode of transport
to take for a specified journey can encourage the use of the sustainable hierarchy
model. For example, if a journey is under three miles and does not require moving
luggage, the employee will be encouraged to walk or use a bike or e-bike. Likewise,
if the journey is within ZEV range (which most journeys now are) the software will
encourage the user to take a ZEV. Although it might feel like employees are ‘forced’
into using ZEVs, users tend to have a much more positive perception of ZEVs once
they have driven one.
The data available does not allow us to determine the proportion of short journeys
that could be replaced with active travel. However, as many of your journeys are
within towns and cities it is expected that many will be short. Replacing 5% of all
journeys with active travel would provide annual savings of 54 tonnes of CO2e and
£25,7028. 
Shorter journeys tend to be in urban areas and, because city driving is the least
efficient form of travel for ICE vehicles, fuel and CO2e emissions may be higher
than stated.  Driving in towns and cities also contributes significantly to local air
pollution. Although the journey distances are short, urban congestion can increase
journey time resulting in vehicles producing high quantities of harmful emissions. 
8 Based on a 5% reduction in fuel cost for company owned cars and LCVs. Implemented robustly this will also
tackle the grey fleet mileage as well which will reduce costs further. 
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Poor air quality from harmful emissions contributes to 40,000 deaths a year in the
UK (based on figures from (Royal College of Physicians, 2016)). 
7.2.1. Adopt eBikes 
An ebike is an electric-assisted pedal bicycle. That is a regular bicycle with the
addition of an electric motor and battery. The battery supplies power to the motor
and can be charged from a regular 3-pin socket. The motor provides power
assistance when the cyclist is pedalling to ease the amount of effort required. The
power assistance removes some of the physical effort required to cycle, meaning
staff can arrive at their destination without being exhausted or in need of a
shower. 
The efficiency of ebikes, and the low cost of electricity, means that any miles
cycled instead of driven will result in a reduction in CO2e emissions and a
significant reduction in fuel costs.  A five-mile journey in a grey fleet vehicle costs
£2.25 at £0.45 per mile, while an ebike costs <£0.01 in electricity and saves around
1.34kg of CO2e. Cycling 100-miles on an ebike costs as little as 8p in electricity costs.
eBike journeys offer all the same health benefits to staff of active travel.
Ebikes are a suitable alternative to driving short distances such as those journeys
under ten miles.
7.2.2. Adopt eCargo bikes
eCargo bikes are specially designed to carry a load and come in many shapes
and sizes. With a weight capacity of up to 350kg and a load volume capacity of up
to 1m3, ecargo bikes can be ideal for short distance deliveries and logistics in and
around urban areas and between operational sites.
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eCargo bikes offer similar cost and CO2e savings to standard ebikes although the
increased weight of the bike means they have slightly higher running cost. From a
business perspective however the increase in running costs is negligible. Travelling
100-miles on an ecargo bike, for example, will cost around 28p in electricity costs.  
If introducing ecargo bikes into the fleet, we recommend that you implement a
training programme to familiarise staff with ecargo bikes. Familiarisation training
will build staff confidence with the bikes, reduce risk, and ultimately ensure the
organisation reaps the maximum financial and environmental benefits from the
bikes. 
Cycling Scotland currently offers a suite of cycle training programmes to support
workplaces with pool bike adoption. Cycling Scotland also offers funding towards
installing cycling infrastructure in the workplace.  Funding is also available to local
authorities for the purchase of ebikes through Energy Saving Trust’s eBike Grant
Fund.
7.3. Install telematics in all fleet vehicles
As with many aspects of modern life, having good quality data allows good
decisions to be made. If you implement zero-emission vehicles into your fleet
based on good quality fleet use data, the process should be smooth and easy.
Telematics systems can provide the good quality fleet data required to
successfully implement zero-emission vehicles. The most important factors to
consider when selecting a ZEV replacement are the daily mileage and maximum
range required, and the opportunities for recharging (usually overnight but also
during the day). You can also use telematics data to identify potential locations for
charging hubs. The data highlights the locations where vehicles are stationary
during the day, and the length of time that they are stationary for, thereby
pinpointing potential locations for charging infrastructure.
You can also use telematics data to forecast the energy required at each
charging hub. You can calculate the energy used by each vehicle to get to each
charging location, and therefore how much energy it will need to recharge. This
energy requirement can then be compared with the available energy supply at
the site, to work out whether a connection upgrade is needed.
You can also use telematics data to identify vehicles that are underused. This will
help inform your fleet rationalisation decisions. You can then make decisions over
whether some vehicles can be removed from fleet, or whether additional work can
be put on them to make them more effective. 
Overall, telematics systems provide you with a clearer picture of how your fleet is
being used. This data makes the process of transitioning your fleet to ZEVs easier,
as you can match zero emission technology with vehicles, and accurately plan
your charging infrastructure. 
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7.4. Downsize vehicles where possible
Table 7-1 - Emissions reduction from downsizing fleet cars 
Downsizing fleet vehicles will reduce emissions and costs. Table 7-1 and Table 7-2
illustrates the change in carbon emissions and fuel use across the VW car and
Ford van range. A similar table could be produced for any of the major
manufacturers.
Both fuel and capital costs increase with size, with fuel costs increasing by up to
72% in the car comparison and 50% in the van comparison. Research carried out by
Ricardo for Department for Transport (DfT) has shown the impact on fuel efficiency
of fully loading a van is a 9-10% increase in fuel consumption (AEA Technology,
2010). Therefore, it is significantly more efficient to have a full small van than a half
empty large van.
There are carbon, operating cost, and capital cost savings from using smaller
vehicles whenever possible. We recommend avoiding a one-size-fits-all
procurement model and instead assess vehicle suitability during the replacement
process. As the market for ZEVs is still considerably smaller than that of ICE
vehicles, there may not be a direct replacement for every vehicle. However, as
there is a larger variety of smaller ZEVs for both cars and vans, if you can downsize,
you will have more options to choose from. 
9 Fuel costs are based off the average UK fuel prices in 2019 excluding VAT, petrol: 100.609ppl diesel: 105.012ppl
Volkswagen
car model Fuel Class Combined
mpg
mpg
change
CO2
g/km
9£/mile
fuel OTR price
VW up! 3Dr Petrol City car 55.4 - 117 £0.11 £12,705
VW Golf Petrol 5-door
hatchback  53.3 +4% 121 £0.12 £23,300
VW T-Cross Petrol Small SUV 47.1 +15% 136 £0.13 £24,970
VW Touareg Diesel SUV 34.4 +38% 214 £0.19 £50,705
Ford van model Fuel Class Combined
mpg
mpg
change
CO2
g/km
7£/mil
e fuel
OTR
price
Fiesta van 1.0 Petrol I 54.3 - 118 £0.12 £18,490
Transit Connect L2 Petrol II 44.1 +19% 136 £0.13 £22,186
Transit Custom L1 Diesel II 39.8 +27% 186 £0.16 £28,689
Transit Custom L2 H2 Diesel III 35.8 +34% 206 £0.18 £32,049
Table 7-2 - Emissions reductions from downsizing fleet vans
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7.5. Adopt ZEVs
When ICE vehicles are due for replacement, you should replace them with ZEVs
wherever possible. The choice of ZEVs on the market is continually growing and is
expected to grow significantly over the next few years. The UK Government website
lists most of the ZEVs currently available. There are less ZEV replacement options as
vehicle size increases. There is, for example, a high number of ZEV car models
available however there are fewer zero-emission HDVs, RCVs and SPVs (See
Appendix 4 for more information).
Creating a zero-emission fleet will likely require you to replace current vehicles with
a mixture of different technologies. Currently most ZEVs are battery electric
vehicles (BEVs) but there are also hydrogen options available.
It is important to develop a good knowledge of the ZEVs currently available and to
keep abreast of new models as they arrive on the market. Supply constraints can
be an issue, so placing orders early, can be advantageous. 
Once you find a ZEV that is a potential replacement for a current ICE vehicle (ie
correct size, load carrying capacity, seats, equipment etc.), you must then assess
its operational viability. The key considerations are as follows:
1. Maximum required driving range of the vehicle on a single charge
2. Rate of charge (charging time)
3. Whole life cost (see section 7.6)
4. Vehicle efficiency (Wh/km or kWh/100km).
BEVs have a lower range on a single charge than most ICE vehicles do on a full
tank of fuel, however, it is important to understand exactly how far you need to
drive. Some fleet vehicles may drive long distances, but if they have regular stops,
and can access a charge point, a vehicle with a relatively small battery may be
suitable. This will reduce your capital costs as the battery is often the most
expensive component in the vehicle. It will also reduce your CO2e emissions as
there are embedded CO2e emissions in battery production. Driving with an
unnecessarily large battery is also less efficient as batteries are heavy. Installing
and using telematics will highlight how often vehicles are driving high mileages.
You could then have dedicated vehicles for high mileage journeys and others for
shorter trips. 
Figure 7-2 shows journey distances in 5 miles increments up to 25 miles from Elgin.
The largest distance showing on the figure therefore represents a 50-mile round
trip from Elgin. This shows the journeys that you could easily complete using a
battery electric vehicle. Most battery electric cars now have ranges of over 150
miles, and some of up to 250 miles, on a single charge. Therefore multiple 50-mile
round trips (ie Elgin, to Dufftown) would be possible on a single charge. For larger
electric LCVs, the range is more limited. The Renault Master ZE, for example, has a
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driving range of around 50 miles in poor conditions when fully laden. In good
conditions, and unladen, however, it can exceed 124 miles. Even in the worst
conditions therefore, a large electric LCV could complete a 50-mile round trip from
Elhin, to Dufftown or Keith. Whether large battery electric LCVs can replace any of
your large LCVs now, will depend on the daily mileage required of each vehicle,
and the availability of charging opportunities.
Figure 7-2 - Map of Moray Council area showing 25-mile distances from Elgin, demonstrating approximate
travel distances for a 25-mile and 50-mile round trips. 
Most BEVs on the market can rapid charge (at around 50kW). This can add
between 50 and 80 miles of range in 30-40 minutes (depending on the size and
efficiency of the vehicle). Models that are not capable of rapid charging take
longer to charge, but are cheaper to purchase, so may be a better option if rapid
charging isn’t a requirement. If vehicles are used during the day, but are parked all
night, they may never need to rapid charge. Therefore, understanding your vehicle
duty cycles will help you select the best ZEV replacement option. It is important to
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avoid over-specifying vehicles, or automatically replacing them on a like-for-like
basis, as this will only add unnecessary costs and CO2e emissions to your fleet.
A vehicle with high mileage, but which stops regularly throughout the day, may
have time for additional charges. This type of work pattern can increase the
maximum daily range of an electric vehicle, making lower specification models a
viable option (reducing costs and CO2e emissions). Careful consideration has to be
taken to ensure that there is suitable charging infrastructure in place to support
this. Further information relating to charging infrastructure can be found section 9. 
The efficiency of ICE vehicles is measured in miles per gallon (mpg). For electric
vehicles this is measured in Wh/km or kWh/100km. Vehicle efficiency can be
affected by vehicle weight, drag, battery size and motor type. Therefore, it is
important to determine exactly what your requirements are in terms of range
(battery size), charging type and vehicle size, before you buy. You should aim to
purchase the most efficient models possible as this will translate into the lowest
running costs and largest CO2e savings. 
7.5.1. ZEV car replacement
We have analysed your fleet data using the data provided and have calculated
the carbon and cost savings that would result from you switching to BEVs. Within
your car fleet there are currently 79 non-ZEV vehicles which you need to replace
with ZEVs before 2025 to meet the Scottish Government’s public sector fleet
decarbonisation target
Replacing all your non-ZEV cars with ZEVs could lead to 41% savings in fuel and
Vehicle Excise Duty (VED) costs and a 55% reduction in CO2e emissions. In addition
to this you would see savings in service, maintenance, and repair (SMR). This would
provide annual savings of £29,402 and 91 tonnes of CO2e. Table 7-3 outlines a
breakdown of the savings you could achieve based on two of the most common
car models in your fleet – assuming a mileage of 10,000 miles per year. 
Also, if any of your ICE cars are used by staff for personal use, and you replace
these with ZEVs, they would benefit from the reduced benefit in kind (BIK) rate of 0%
that came into effect in April 2020. This could provide substantial savings in
national insurance contributions (NIC) for the council and BIK savings for your
employees. 
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Table 7-3- Replacement savings from ICE cars to BEV equivalents 
Based on 10,000
miles per year
Existing
vehicle
ZEV
Alternative
Existing
vehicle
ZEV
Alternative
Vauxhall
Corsa
Vauxhall
Corsa-e   Vauxhall Astra Peugeot e-208
Official CO2
emissions (g/km) 941 0 1181 0
Annual CO2e
(tonnes)2 2.01 0.803 2.52 0.843
Annual fuel cost £8294 £4565 £1,0414 £4785
Fuel over 6 years £4,976 £2,733 £6,246 £2,867
First year VED6 £125 £0 £165 £0
VED over 6 years £825 £0 £865 £0
First year costs (Fuel
+ VED) £954 £456 £1,206 £478
6-year costs (Fuel +
VED) £5,801 £2,733 £7,111 £2,867
First year cost
saving £499 £728
6-year cost saving £3,068 £4,244
Annual CO2e saving 1.21t CO2e 1.69t CO2e
1 CO2 figure obtained from https://vehicleenquiry.service.gov.uk. 
2 Includes an uplift to reflect real-world driving style, based on BEIS methodology.
3 Electric vehicle CO2 emissions are calculated using the BEIS/Defra figure for average emissions from UK electricity
generation.
4 Fuel prices based on 105p/litre for diesel, 100.6p/litre for petrol.
5 Electric vehicle fuel cost is based on a 13.34p/kWh tariff. Further savings can be made if off-peak charging is
utilised or vehicle is charged using a free ChargePlace Scotland charger.
6 Vehicle Excise Duty (road tax). VED figures are based on the date the current vehicle was first registered and the
post April 2017 rates for the replacement vehicle.  Annual VED of £320 is payable in years 2-6 if the vehicle costs
more than £40,000.
7.5.2. ZEV LCV replacement
You have a large LCV fleet of 235 vehicles including five BEVs (all Nissan E-NV200
Acentas). In addition to your cars, you should replace as many of your LCV fleet as
possible with zero-emission alternatives. The vehicles to replace are your smaller
panel vans and car-derived vans like the Vauxhall Combo, Vauxhall Corsa Van,
and Vauxhall Vivaro. It will be easy to replace vehicles with daily mileages within
the range of electric alternatives like the Nissan e-NV200, Renault Kangoo Z.E. and
Renault Zoe van. Table 7-4 provides a breakdown of the savings you could achieve
based on two of the most common van models in your fleet – assuming a mileage
of 10,000 miles per year.
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Our analysis of the data provided suggests that replacing all ICE LCVs with the ZEVs
outlined could save in the region of 55% in fuel and VED costs and 63% in CO2e
emissions, in addition to cost savings in SMR. This would provide annual savings of
£245,62710 and 579 tonnes of CO2e. If any of your fleet LCVs are used for personal
use, and you switch these to zero-emission vehicles, you would benefit from
reduced national insurance contributions (NIC). Staff members with zero-emission
company vans will also pay lower company van tax due to the reduced BIK rate for
zero-emission vans.
Table 7-4- Replacement savings from ICE small/medium LCVs to BEV equivalents
Based on 10,000
miles per year
Existing
vehicle
ZEV
Alternative
Existing
vehicle
ZEV
Alternative
Vauxhall
Combo
Renault
Kangoo Z.E.  
Ford Transit
350
Mercedes
eSprinter
Official CO2
emissions (g/km) 1331 0 2221 0
Annual CO2e
(tonnes)2 2.98 0.803 4.81 2.013
Annual fuel cost £1,2314 £4575 £1,9854 £1,1505
Fuel over 6 years £7,384 £2,741 £11,913 £6,900
First year VED6 £265 £0 £265 £0
VED over 6 years £1,590 £0 £1,590 £0
First year costs (Fuel
+ VED) £1,496 £457 £2,250 £1,150
6-year costs (Fuel +
VED) £8,974 £2,741 £13,503 £6,900
First year cost
saving £1,039 £1,101
6-year cost saving £6,233 £6,603
Annual CO2e saving 2.19t CO2e 2.80t CO2e
1 CO2 figure obtained from https://vehicleenquiry.service.gov.uk. 
2 Includes an uplift to reflect real-world driving style, based on BEIS methodology.
3 Electric vehicle CO2 emissions are calculated using the BEIS/Defra figure for average emissions from UK electricity
generation.
4 Fuel prices based on 105p/litre for diesel, 100.6p/litre for petrol.
5 Electric vehicle fuel cost is based on a 13.34p/kWh tariff. Further savings can be made if off-peak charging is
utilised or vehicle is charged using a free ChargePlace Scotland charger.
6 Vehicle Excise Duty (road tax). VED figures are based on the date the current vehicle was first registered and the
post April 2017 rates for the replacement vehicle.  Annual VED of £320 is payable in years 2-6 if the vehicle costs
more than £40,000.
10 This does not consider whole life cost savings and in many cases the increased capital costs will reduce any
running cost savings, this is discussed further in section7.6. 
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7.6. Use a whole life cost procurement method 
ZEVs currently have higher capital costs than their ICE counterparts, but they do
have lower running costs. Because of this, it is important to consider all aspects of
vehicle ownership when working out cost comparisons between ICE and ZEV
models. As a minimum the areas to consider are as follows:
▪ Depreciation (if purchased) / lease costs (if leased)
▪ Service, maintenance, and repair costs (SMR)
▪ Value added tax (VAT)
▪ Vehicle excise duty (VED) 
▪ Fuel and electricity costs
▪ Class 1a national insurance contributions (NIC) (if applicable)
▪ Vehicle insurance
▪ Grants that may be available for specific vehicles and charging
infrastructure.
Adopting a WLC based policy often satisfies both financial and environmental
objectives. This is because vehicles with a lower WLC tend to use less fuel and emit
less pollutants. Where the WLC analysis includes ZEVs, a pragmatic approach must
be taken when considering range and opportunity to recharge. 
Organisations that do not use a WLC approach are often found to be buying
vehicles that are cheaper to acquire but which are more expensive to run over
their operational life. 
Table 7-5 shows WLC comparisons between a variety of ICE vehicles and BEV
alternatives. Table 7-5 assumes that these vehicles are leased for four years and
are driving 10,000 miles per year. ZEVs are not always the lowest cost option, but
they are the lowest carbon option. The use of the WLC model allows you to put a
cost on your carbon reduction programme. 
The following comparisons do not consider NIC as it is assumed that vehicles are
pool vehicles and therefore not for staff personal use. If vehicles are for staff
personal use, such as company cars, NIC must be included, this will work in favour
of the electric models as they carry a lower BIK rate. For certain models, the NIC
saving from switching from ICE to BEV amounts to thousands of pounds per year.
Insurance is not included in the below comparison as we assumed that you self-
insure your vehicles. 
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Table 7-5 - WLC analysis of ICE vehicles and ZEVs; based on vehicles being leased for four years and 10,000
miles, costs are accurate as of 01/10/2020
Based on 4 years
and 10,000 miles Seat Ibiza Nissan
Leaf
Kia
Sportage
Kia e-Niro
39kWh
Ford
Fiesta van
Renault
Zoe van
Renault
Kangoo
ML19
Renault
Kangoo
Z.E.
Peugeot
Expert
Standard
1000kg
Peugeot
e-Expert
Annual lease cost
excluding VAT £1,755 £2,603 £2,394 £2,998 £1,755 £2,476 £1,755 £2,679 £1,755 £2,777
Annual fuel /
electricity cost £1,204 £543 £1,746 £450 £1,164 £522 £1,314 £459 £1,553 £656
SMR annual £246 £205 £334 £262 £295 £192 £435 £214 £397 £241
VED Total (+1st
year registration
fee)
£665 £55 £1,360 £55 £1,115 £55 £1,115 £55 £1,115 £55
Total CO2e
emissions
(tonnes)
2.59 0.80 3.76 0.78 2.51 0.80 3.19 0.80 3.76 1.14
Total cost (4 year)  £13,483 £13,458 £19,257 £14,894 £13,969 £12,815 £15,132 £13,460 £15,932 £14,748
£ per mile £0.34 £0.34 £0.48 £0.37 £0.35 £0.32 £0.38 £0.34 £0.40 £0.37
Cost difference
per mile £0.00 -£0.11 -£0.03 -£0.04 -£0.03
Cost difference
per year -£6 -£1,091 -£288 -£418 -£296
Cost difference
over 4 years -£24 -£4,363 -£1,154 -£1,671 -£1,184 
The ZEVs come out cheaper over the term of the lease. This is down to their lower
running costs and associated taxes. Savings will continue to increase for those
vehicles that travel more than 10,000 miles per year, however those with a lower
mileage can work out more expensive than their ICE counterparts. You should also
factor-in the cost of charging infrastructure. Charging infrastructure will however
have a much longer lifecycle than the vehicle lease, so you will have to take a
pragmatic approach to this. 
There will be many internal factors that will influence the procurement approach
used, however, whether you lease or purchase, using a WLC analysis will ensure
that you select the most suitable and cost-effective vehicle models.
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8. Fleet decarbonisation strategy
As you have started to invest in BEVs, you have already begun to decarbonise your
fleet. The majority of your fleet (just under 60%) is under five years old, with very few
vehicles over ten years old. You do not have any vehicles that are overdue for
replacement, and provided you follow your fleet replacement plans, you are on
course to meet both the Scottish Government’s 2025 and 2030 decarbonisation
targets.
Your car fleet already contains 12 BEVs, leaving 79 vehicles you need to transition to
ZEVs. With the wide range of BEV cars on the market, making this a zero-emission
fleet by 2025 should be easily achievable. Your cars are also the youngest part of
your fleet, with an average age of under four years. The oldest vehicle is a ten-
year-old, BEV Peugeot Ion due for replacement this year (2021) so is not a concern.
Your LCV fleet will be more difficult to transition to ZEVs. These vehicles have
replacement cycles of over six years on average, compared to an average of
under four years for car fleet vehicles. It is important to therefore consider ZEVs
now, to avoid at least six years of unnecessarily running highly polluting vehicles.
This is particularly important for the smallest vehicles in this group as there are
many ZEV models already available that fall into this category, so these will be the
easiest to decarbonise.
8.1. Vehicle replacement profiles and plans
You have a varied fleet, with some expensive specialist and purpose-built vehicles
that have long replacement cycles to maximise the return on their investment.
Moray Council vehicle replacement cycles currently range from 3.7 years on
average for cars, to 6.1 years for the light fleet, and 9.1 years for the heavy fleet.
Because of the length of these cycles, it is crucial to consider ZEVs now, rather than
at the end of the next replacement cycle. This will help you make emissions
reductions sooner. 
It may be preferable to have an equally distributed replacement cycle from a
procurement perspective. As supply is often an issue when adopting large
numbers of ZEVs. However, spreading the replacement of vehicles will be
dependent on how your vehicles are financed, and may not always be possible.
Your replacement plans are currently weighted towards FY2020/21 with 152 due for
replacement in this year, roughly a third of your entire fleet. Evenly distributing
replacements across many years may avoid a disproportionately large financial
pressure on any year, especially if supporting charging infrastructure also has to
be installed.
You may want to consider altering your replacement plan based on the availability
of ZEV alternatives. For example, small LCVs with suitable ZEV replacements
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currently available could be changed sooner than planned. While you could delay
changing larger vehicles without a suitable ZEV replacement until such
alternatives become available. This would most likely speed up the rate of fleet
decarbonisation and reduce your overall emissions sooner. 
8.1.1. Cars
Figure 8-1 - Cars replacement profile curve (based on existing replacement dates) 
Table 8-1 - Cars replacement profile (number of vehicles replaced per year)
Fleet group 2020/21 2021/22 2022/23 2023/24
Car 64 4 15 8
Figure 8-1 and Table 8-1 outline the current replacement profile for your car fleet.
From this you can see that all cars are scheduled to be replaced at least once by
FY2023/24. Provided these cars are replaced with ZEVs, you are on course to meet
the Scottish Government’s target to phase out petrol and diesel cars from public
sector fleets by 2025. Since there are alternative ZEV models available for every car
in your fleet, this is the earliest date at which you could have a zero-emission car
fleet if you follow your replacement cycles.
Your replacement plan is weighted towards FY2020/21, as a positive result of which
you will decarbonise your fleet faster. However, it will require a large number of
chargers to accommodate all these new BEVs. We did not receive data on your
existing charging facilities and depot site electrical capacities so have not
provided forecasts of the level of new infrastructure you will require. Given the
number of new vehicles you will take on, it is likely you will need to install a large
number of chargers to meet these vehicles’ energy demands. Depending on your
existing infrastructure, replacing a large number of cars in FY2020/21 may result in
an initial lack of chargers. You will therefore need to determine how much
infrastructure you need and set installation plans in motion as early as possible.
0%
20%
40%
60%
80%
100%
2020/21 2021/22 2022/23 2023/24
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8.1.2. LCVs
Figure 8-2 - LCVs replacement profile curve 
Table 8-2 - LCVs replacement profile (number of vehicles replaced per year)
Fleet group 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2029/30
LCVs (car-
derived/integral
<2000 Kgs)
37 7 5 1 3 1 10  
LCVs (medium
vans 2001-2600
Kgs)
4 8 11 14 1 4      
LCVs (heavy vans
2601-3500 Kgs) 23 12 26 15 12 21 12 1 
LCVs (pickups) 4 1     1       1
Total 68 28 42 30 17 26 22 1 1
With your current replacement plan, you are on course to meet the government’s
2030 target to phase out all new petrol and diesel vehicles by 2030. Like your car
fleet, the number of vehicles due to be replaced are weighted towards 2020/21. To
accelerate the reduction of your fleet’s carbon impact, we recommend that you
aim to replace diesel LCVs with zero-emission alternatives whenever possible. If a
diesel LCV has to be replaced between now and the end of 2025 and a ZEV model
is not a viable replacement, we recommend that a Euro 6 diesel option is selected.
The process of replacing the Euro 4 and Euro 5 diesel LCVS should be accelerated
0%
20%
40%
60%
80%
100%
2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2029/30
LCVs (Car-Derived/Integral <2000 Kgs) LCVs (Heavy Vans 2601-3500 Kgs)
LCVs (Medium Vans 2001-2600 Kgs) LCVs (Pickups)
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to ensure that these vehicles are compliant with the low emission zones that are
due to be implemented across Scotland. 
While you shouldn’t have a problem adopting replacements for your smaller LCVs,
or your car-derived and medium vans, replacing some of your larger vans may be
more difficult, as there are fewer alternatives available. Particularly if they are
required to do high journey mileage. Your LCV fleet averages 43 miles daily11 which
is within the range limits of larger LCVs like the Renault Master Z.E. For smaller vans,
there are a range of vehicles available on the market that can travel up to 250
miles on a single charge. These vehicles will be sufficient for the bulk of your driving
needs, as journey longer than this will be very rare. There are also several new BEV
or range extended electric vehicle (REEV/REX/eREV) vans due to come onto the
market this year (2020) which may be more suitable for higher mileage driving. The
arrival of these vehicles, alongside the continued growth of Scotland’s network of
public charging infrastructure, will help to overcome any barriers posed by the
Moray area’s size. 
11 Calculated assuming LCVs are used for 255 working days per year.
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8.1.3. HDVs
Figure 8-3- HDVs replacement profile curve 
Table 7-4- HDVs replacement profile curve
Fleet groups 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31
HDVs (rigids 2 axle
>15000 Kgs) 4 4 4    2  7 4 
HDVs (rigids 2 axle
12001-15000 Kgs) 2 1 2       1        
HDVs (rigids 2 axle
3501-7400 Kgs) 9 1 7 1 2  8    
HDVs (rigids 2 axle
7401-7500 Kgs)       2 3 1     2 1 3
HDVs (rigids 2 axle
7501-12000 Kgs)  3   1      
HDVs (rigids 3 axle) 5 8 7 2 4   4 2 3 5  
HDVs (rigids 4 axle)     1       1 1      
PSVs    1   6  1  
Total 20 17 21 6 10 1 22 3 13 10 3 
0%
20%
40%
60%
80%
100%
HCVs (Rigids 2 Axle >15000 Kgs) HCVs (Rigids 2 Axle 12001-15000 Kgs)
HCVs (Rigids 2 Axle 3501-7400 Kgs) HCVs (Rigids 2 Axle 7401-7500 Kgs)
HCVs (Rigids 2 Axle 7501-12000 Kgs) HCVs (Rigids 3 Axle)
HCVs (Rigids 4 Axle) PSVs (Fare Stage Buses)
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Your replacement plan for HDVs is quite evenly spread out over the next 10 years.
This will be beneficial if you find it easier to replace the same number of vehicles
each year. Unlike cars and LCVs, there are few suitable ZEV HDVs currently on the
market. However, this is expected to change over the next decade as technology
develops. Manufacturers such as Tesla, Hyundai and Mercedes-Benz are currently
producing electric HDVs for short and long-haul journeys. As a result, you may
want to consider delaying the replacement of HDVs where an electric equivalent is
due to be released. Especially those in a lower weight class or those that do short
journeys. 
You should investigate the possibility of downsizing vehicles that need replaced in
the next two years. Where this is not feasible due to the requirements of the
vehicle, you should take on Euro 6 models, as these are more efficient and so
release less carbon. Under the current Scottish Government targets for the public
sector fleet there is no requirement to buy ZEV HDVs until 2030. Between now and
then the market is expected to mature significantly with greater choice and
reduced costs. 
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9. Charging infrastructure
requirement
9.1. Charging site Considerations
As we were not provided data on the half hourly energy consumption of the sites
and the available capacity that you have agreed with your provider, we cannot
provide specific charging infrastructure advice based on your depots. This data
would allow us to state whether you would be able to install any additional charge
points without requiring a larger capacity or grid connection upgrade. You should
try to minimise the need for grid connection upgrades as these can add
substantial cost and delays to any project, although sometimes these works are
unavoidable. 
Figure 9-1 - Example half hourly site energy demand (yearly average) 
Figure 9-1 shows an example energy consumption profile at a typical local
authority depot, averaged over a whole year. In this figure the capacity at the site
is 50kVA. Applying a 95% power factor to this means the maximum consumption at
the site could be 47.5kW. The consumption peaks at 29kW and under these
conditions it would be possible to install 18.5kW of static basic charging without
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any issues (the types of chargers are discussed further in section 9.2). This could be
one 3.7kW and two 7.4kW single-outlet chargers, five 3.7kW single-outlet chargers
or any combination which when added total under 18.5kW. The blue area of the
graph shows where there may be spare capacity, as this represents one-off high
usage events. Investigating whether this could be controlled would determine
what additional energy might be made available here.
There is a large amount of spare overnight capacity at this example site which
could be utilised to charge electric vehicles. Between approximately 6pm and 6am
the power requirement drops to below 5kW. This is quite typical for the usage in
most depots, so you are likely to also experience this. In this scenario, with a 50kVA
capacity, the site could accommodate around 42.5kW of charging through the
night. This could provide up to 510kWh of electricity to electric vehicles, enough to
travel around 1,500 miles12 . This charge could be split between up to 11x3.7kW single-
outlet charge points. Therefore supporting 11 individual vehicles if they need to
charge every night. Depending on the duty cycle of vehicles and daily mileage,
they may only need to charge every other day, then these charge points could
support double that number of vehicles. To allow this sort of charging your
infrastructure must be able to understand the energy demand of your building
and be able to vary the power output of the chargers. This is a more expensive
option than static basic chargers but could allow you to avoid costly connection
upgrades (more on this in section 9.2). 
Depending on the vehicle types, daily mileage and downtime, the type of charging
infrastructure you need will vary. Ideally you should charge your vehicles as slowly
as possible to maximise your available capacity. You should avoid charging
patterns in which vehicles draw a high power for a short amount of time, then sit
plugged in and fully charged until they are picked up for their next shift. This will
save you money as you won’t need as high a power capacity at your site.
With the average daily mileages in your LCVs and cars fleets being around 43
miles and 40 miles respectively, most vehicles are not going to be completing long
journeys regularly. You tend to use each of your vehicles over an eight-hour period
per day, leaving at least 16 hours of possible charging time. Because the mileages
are not excessively high, if you have electric vehicle that can drive 100 to 200 miles
on a charge, they will usually only require a top up charge. Given this, you should
not need many, if any, high powered chargers. Over 13 hours a 3.7kW charger will
charge a battery with up to 48kWh of electricity, enough energy to drive around
144 miles12 
12 Based on a rough average of three miles per kWh in an average electric car.
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9.2. Types of chargers 
9.2.1. AC or DC charging and smart management
There are two basic types of charging infrastructure: AC (Alternating Current) and
DC (Direct Current).  Batteries need DC and electric motors need AC. An AC
charger relies on the vehicle’s “on-board” charge management system to convert
the AC to DC and ensure that the battery is not damaged during charging.  This is
the simplest type of charger. The output of AC charging systems range from 3.7kW
(240 Volt, 16 Amp, single phase) up to 43 kW (400 Volt, 60 Amp, three phase) but are
usually 7.4 kW (240 Volt, 32 Amp, single phase) or 22 kW (400 Volt, 32 Amp, three
phase).  
DC charging systems deliver the power directly to the batteries and do not use the
vehicle’s on-board charge management system. To do this safely and without
damaging the expensive batteries, the DC charge point must communicate with
the vehicle and understand the size of the battery as well as its state of charge
(SoC). DC chargers are, therefore, a lot “smarter” and management of DC charging
can be more sophisticated as the charge management software knows the SoC
and battery size of all the vehicles it is connected to.
A charging strategy must also consider the non-linear nature of the process. If a
vehicle returns to a 7.4kW charger needing 74 kWh of energy to replenish its
battery, it will take longer than 10 hours to fully recharge it.  When a battery is fully
depleted there is little internal resistance to the flow of current (Amps) and so
energy can be quickly transferred to the battery, but as it reaches 80%-90% SoC,
the internal resistance increases, and the charging system has to increase the
voltage to maintain the current.  However, there is a maximum voltage above
which damage to the battery will occur. When that voltage is reached, the flow of
energy to the battery (Amps) falls and the battery charge rate diminishes. Because
of this, the vehicle that returns to a 7.4kW charger requiring 74 kWh of energy may
take 12 hours to fully recharge.  
9.2.2. Basic chargers 
Basic chargers, or as they are commonly known, dumb chargers, are given this
name due to the charge point’s level of intelligence, connectivity, and
communication. A basic charger can often be no more than a socket on a wall.
They tend however, to be rated between 3.7kW and 7.4kW (AC) and can be either
tethered (permanently connected to a charging cable) or untethered (allowing
the charging cable to be removed from the unit and swapped). When you plug a
vehicle into it, it will charge at the rated power output until the vehicle is fully
charged. These units can normally be de-rated (the power output reduced from
say 7.4kW to 5kW) if there is insufficient supply. This is a manual process and would
need to be completed by an engineer.
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The benefit of this style of charge point is its simplicity and cost. However, because
it cannot communicate there is no way to optimise charging times (at the unit, this
may be possible by programming the vehicle itself), monitor electricity
consumption or connect to a back office. 
9.2.3. Smart chargers
A smart charger does all the things a basic charger can do, but also allows for
communication between the charge point and an app, back-office system or
another piece of software. This allows you to set charging times, monitor charge
point availability (which will be crucial in depot charging) and even automate
over-the-air (OTA) updates for the charge point’s software. This additional
capability does however come at a cost and therefore smart chargers are more
expensive than basic chargers.  
9.2.4. Rapid chargers
Rapid chargers tend to be rated at around 50kW and depending on the unit can
be either DC only, or DC and AC. These will always be smart capable and offer you
the ability to add between 50 and 80 miles of range in 30-40 minutes, depending
on the size and efficiency of the vehicle. These are the most expensive units and,
due to the power that they draw, they will often require a supply upgrade. If you are
installing multiple rapid chargers, sometimes you will even need a new substation.
In depot charging situations these units will only be used when vehicles have very
little down time and need to be charged quickly before going back out on the road.
Installing rapid chargers should always be a last resort for a depot as they will add
substantial cost to any charge point installation project and are often
unnecessary.
9.3. Load management
Load management type Description
Static load management
Evenly distributes a set power to all charge points. No
matter how many of the vehicles are charging, every
charging station is allocated the same power.
Dynamic load management
The power available for charging is variable based
on the current power consumption of the site or
building. More power will be available for charging
vehicles if the building or site decreases its power
consumption.
Load management systems offer a potential solution for multiple charge points to
be operated without exceeding the maximum power capacity of a site. Load
management works by distributing the available power to the charge points that
are in use. This is demonstrated in Figure 9-2.
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Load management systems can also limit the proportion of a site’s total energy
supply that BEV charge points can use, again preventing exceedance of that site’s
total capacity. The use of load management technology can avoid costly
upgrades to electrical supply. 
The principle of load management is that when a charge point is being used, the
vehicle is charged at the fastest speed permitted by the charge point and vehicle
in question. When several charge points are being used, the rate of charge being
delivered to each can be reduced.
Organisations running fleets with vehicles requiring quick top-up charges during
shifts and vehicles requiring a slow charge overnight at the end of a shift, would
benefit from load management systems. Particularly if the system allows the
business to avoid costly upgrades to its electrical supply. Fleet managers should
consider the likely future growth of their BEV fleet, as installing flexible load
management technology at the outset can save on infrastructure replacement
and upgrades later. Charge points with features such as remote access
functionality, back office integration and load management are also useful from a
payment perspective. They can also include the ability to remotely control charge
points (to end or prioritise a vehicle charging session, for example) and to monitor
the usage of charging infrastructure on site over time. The end-user can often be
identified through an RFID card or user app which is advantageous for determining
the amount of electricity any vehicle is using and allows individual vehicle and
driver efficiencies to be determined and costs charged to cost centres. Where
employees can charge their private vehicles at work, this system can allow the
cost of the electricity they use to be charged to them. In the same way visitors
using the infrastructure on site can be identified and managed as deemed
appropriate.
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Figure 9-2 - The principle of load management
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9.4. Energy storage and solar PV
If your charging requirements exceed the capacity of the local network
infrastructure, an alternative to a costly distribution network upgrade is to install a
charge point solution which incorporates energy storage (batteries). This would
offer a means of storing electricity off grid to charge electric vehicles, but would
also incorporate load management, and integrate with smart charging. This can
be further improved by installing solar PV to generate renewable energy during
daylight hours. Solar energy can be stored on site, ready to be used to charge
vehicles at any time of day at a lower cost than electricity from the grid. Figure 9-3
illustrates how this sort of charging system would work. These systems have been
used widely, for example Dundee City Council has implemented multiple systems,
like the one outlined, for its charging hubs. The incorporated load management
allows more charge points to be available but at slightly reduced rates of charge. 
This energy storage does have a capacity limit. Once the stored energy is
consumed, you will rely fully on the existing site connection capacity. When
considering installing large numbers of charge points it is key that you engage
with your distribution network operator (DNO) and installer early to uncover any
issues that your site may have.
Figure 9-3 - The principles of energy storage
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9.5. Emerging technology
9.5.1. Inductive (wireless) charging
Inductive, or wireless charging uses an electromagnetic field to transfer energy
between an electric vehicle and a charging pad through electromagnetic
induction. There are many companies around the world that are working in this
space and many charge points are already being installed in such a way that
when wireless charging becomes available, the existing charge points can be
switched to this technology relatively easily. There is even a wireless charging road
in Sweden that charges vehicles as they drive on it (Smartroad Gotland, 2020). This
technology, although new, may be worth considering. It is also worth ensuring that
when you are looking to install charge points that it is easy to update the
technology type.
9.5.2. Vehicle to grid (V2G)
Another technological advancement is Vehicle-to-Grid (V2G). This looks and acts
very similar to a standard charging installation but includes bi-directional inverters
so that energy flows both to and from the vehicle. In effect, this turns a vehicle into
a portable battery which can provide services to the home, business, and grid
such as energy storage. This will maximise the benefits of charging on time of use
tariffs. V2G technology is currently in the testing for commercialisation stage and
trials are underway, most recently with EON and Nissan. FleetNews wrote an article
on this (07/08/2020) and highlighted that further participants are being sought to
take part in the trials, the full article can be found here.
9.6. Charging profiles
9.6.1. Socket per vehicle
To support a smooth transition from ICE vehicles to BEVs, recharging should be
made as simple as possible. Ensuring that every vehicle has its own socket means
that whenever a vehicle comes off shift, staff will not have to go searching for a
charge. Staff buy-in is crucial to BEV adoption and the success of a
decarbonisation strategy, so you want to make charging as simple and
convenient as possible.
The simplest solution could involve installing basic chargers, that will charge the
vehicle at the highest rate possible from the charge point, and allowable by the
vehicle. So long as the sum of the power ratings of a number of charge points is
below the static charging availability (shown in dark green in Figure 9-1) there will
be no issues. However, this system can result in spikes in power demand, as if
everyone plugs in at the same time, all vehicles will try and draw the maximum
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allowable power. If you need more sockets than you have capacity for, you will
need to apply for a larger capacity from your grid connection. This may result in
expensive grid connection upgrades, capacity charges or even the requirement
for a new substation. Individual charge points can be manually downrated to
avoid exceeding the site capacity, but this might prove impractical if vehicles
sometimes need to charge more quickly, for instance, if shift patterns change. 
To install more sockets on the same grid connection, you could adopt this solution
in tandem with load management. This will allow you to charge more vehicles at
the same time at lower charging speeds (for instance, overnight), but if there are
fewer vehicles charging, those plugged in can charge more quickly. This will give
you more flexibility than downrating charge points. 
If you need even more charge points but are still trying to avoid grid upgrades, you
could opt for using dynamic load management. This will allow you to dip into the
power that is available elsewhere on the site (e.g. buildings or offices) (shown in
light green in Figure 9-1), when it is not being consumed, for instance if offices on
site are shut and there are no lights or heaters on. This system requires you to be
able to actively monitor the building consumption in real time and will be the most
expensive form of load management but offers the most flexibility. It is also likely to
be cheaper than upgrading grid connections. 
9.6.2. Charge vehicles on a rota
The average daily mileage of your fleet is only 46 miles. Although daily milage will
vary, most electric vehicles on the road today can drive well over 100 miles on a
single charge. Considerably more than the daily distances driven by most of your
vehicles. It will therefore not be necessary for you to charge your vehicles every
day. By using a rota system where (depending on the daily mileage of the vehicle
and the BEVs range on a full charge) staff charge their vehicle on one or more
specific days of the week, the number of required charge points could potentially
be reduced.
It is important to keep the rota system simple to ensure staff plug in when they are
supposed to (e.g. by letting them charge on the same day/s each week) and avoid
a situation where charge points are blocked by vehicles that do not require a
charge. A system also needs to be devised to allow for essential charging, where a
vehicle is greatly in need of a charge, but a charge point is not available. This could
be installing a small number of buffer chargers that are only used for essential
charging or using public charge points if available. 
This system would require smart chargers so that the charge point usage could be
monitored and effectively managed. This would also allow you to stagger the time
of charge to further reduce the maximum required demand from the grid, as well
as allowing you to take advantage of time-of-use tariffs. 
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9.6.3. Charging vehicles at home
In situations where staff take fleet vehicles home with them, a home charging
solution will be required. This brings unique challenges around how to charge
these vehicles and reimburse staff for the energy used.
In the first instance, you should determine if fleet vehicles really must go home with
staff. For those vehicles that do, you should ensure that staff are able to get a
charge point installed at their home (ie they have off street parking). If staff do not
have off street parking, they could instead be provided with a ChargePlace
Scotland card to access the public charging network. This could be linked to a
company account meaning the employee could recharge on the public network
without having to pay for it themselves. These cards can be specific to a vehicle, or
staff member, so energy consumption can be monitored. 
The typical cost for a home charge point and its installation is approximately
£1000.  As part of its Electric Vehicle Homecharge scheme, OZEV currently offers
applicants £350 towards this cost. Energy Saving Trust (EST) will also provide up to
a further £300 funding on top of this, with an additional £100 available for those in
the most remote parts of Scotland. For the cost covered by OZEV, you will not need
to make any payment to your supplier, as they will receive this money from OZEV
directly. For the costs above what OZEV cover, you will have to pay your supplier,
and EST will then provide you with your reimbursement. Any remaining costs above
the £350 provided by OZEV, and the funding provided by EST, you would need to
pay for yourself. Full terms and conditions can be found on our website here. 
Then comes the task of reimbursing staff for the personal electricity used.
Currently, the advisory fuel rate (AFR) for BEVs is 4 pence per mile, hybrid cars are
treated as either petrol or diesel cars when working out mileage rates. Fuel rates
can be found on the government website here. Combining the use of a telematics
system with these fuel rates will allow you to accurately reimburse staff for their
business fuel use. There are however alternative solutions coming to market. One
solution involves a third-party provider connecting directly to the employee’s
energy supplier; this means the employee can charge at home or on the public
network without having to directly pay themselves. Instead, the provider sends the
employer an invoice for all the energy consumed (both at the employee’s home
and on the public network). This is currently being trialled by Mitie, as highlighted in
this FleetWorld article. As this is an emerging challenge for fleet managers. new
products are continually being developed to take it on. We therefore recommend
that you keep abreast of these developments to find the best solution for you and
your staff. 
9.6.4.  Getting the timing right 
Ideally, vehicles should be charged overnight, to avoid the demand from large
scale BEV charging having a negative impact on the grid. During the working week,
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from 06:00 to 23:00 hrs, demand on the UK Grid is at its maximum, and grid GHG
emission intensity (kgCO2e/kWh) may be high due to the use of fossil-fuel based
generation having to be used to meet demand.  
However, avoiding the peak entirely leaves a narrow window of seven hours in
which to charge vehicles. The reduction in GHG emissions from avoiding the higher
“daytime” intensity is around 10%-15% over the entire charging period. As the grid
decarbonises the amount of CO2e saved by charging off peak will reduce. 
During the summer months, on-site solar PV generation can be used during the
late afternoon and early evening to charge vehicles at a time when the “domestic”
site load is falling. Using the solar PV to displace grid import will have a significant
cost saving and GHG emission reduction.  
9.7. Estimated infrastructure costs
Our experience administering grants for the installation of charge points gives us a
good insight into the average cost of installing charging infrastructure. Table 9-1
below outlines the average cost of installing charging infrastructure of different
power ratings. The costs include the purchase of the hardware (the charge point
unit). As these are average costs per unit, installing large numbers of units, as
would be done in a depot installation, would naturally bring costs down. 
Table 9-1 - Average cost of installing charge points combining FY2019/20 and FY2020/21 (not publicly
accessible)  (excluding DNO costs) 
Although you do not currently need any bespoke advice on installing charge
points, you can use this table to give you an idea of costs as your electric fleet
expands over the next few years. Additionally, although we mostly recommend low
power chargers, it is worth considering installing a rapid charger within the depot
charging mix. Some local authorities have opted for this approach as a fail-safe,
for instance in case of human error issues with pool car charging. This can be a
good option for boosting resilience, note however that a rapid charger would 
13 The cost is inclusive of the purchase of the hardware and the installation of the charge point but does not
include any costs that may be associated with grid connection upgrades. These costs are derived from those
charge points that were funded by the EST administered Workplace Charge Point Grant Fund through
FY2019/20.
Charge point rating (kW) and type
Average
charge point
cost13
50kW triple outlet, smart, AC/DC £37,304
22kW double outlet, smart £10,877
7kW double outlet, smart £7,101
7kW single outlet, basic £2,635
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impose a significant additional electricity demand on the site. This would curtail
the number of lower power units that could be installed if smart charging and load
management solutions were not also included.
9.8. Engagement with the DNO
Once the decision has been taken to progress a project at a location, initial
engagement with the DNO should take place as soon as reasonably practicable.
This will enable the full logistics of the project to be scoped out, determining
amongst other things, if there is enough existing capacity to accommodate the
installation(s) and therefore whether a substation upgrade, or new substation, will
be required. As well as introducing substantial additional cost – likely to be in the
region of £50k – lead times for the delivery of new substations can be in excess of
nine months, making it vital that planning arrangements are initiated as early as
possible. Providing the DNO with clear long-term plans for each location will allow
them to determine what additional undertakings should be included, such as
ducting, to facilitate later works should the decision be taken to expand
infrastructure provision. 
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10. Conclusion
At the end of FY2019/20 you had a fleet of 455 vehicles. 20% of this fleet is cars, 52%
LCVs and 27% HDVs. 40% of the fleet is over five years old, with HDVs the oldest
segment. In total, your fleet emits more than 3,227 tonnes of CO2e annually, 62% of
which comes from your HDVs, 29% from your LCVs, 5% from your cars and 3% from
PSVs. 
You currently have 18 ZEVs in your fleet, 12 of which are cars. To meet the Scottish
Government’s fleet decarbonisation target, all your cars must be ZEVs by 2025.
Replacing all the remaining non-ZEV 79 vehicles with ZEVs will save you
approximately £29,402 per year and 91t CO2e.
You have a large LCV fleet of 235 vehicles which already contains five BEVs. We
recommend that you replace all small and medium ICE vehicles with BEV
equivalents as soon as possible. There is a range of ZEV alternatives to these ICE
vehicles already available. While there are fewer large ZEV LCVs, you should aim to
replace as many of your LCVs as you can, based whether you can viably switch
them for BEV equivalents. Replacing all your ICE LCVs with BEVs would provide
annual savings of approximately £245,627 and 579t CO2e. Currently your
replacement strategy puts you on target to meet the Scottish Government’s fleet
decarbonisation targets for 2025 and 2030.
There are sufficient BEV model options available on the market to replace all your
cars and potentially all of your LCVs with zero-emission equivalents. While the BEV
heavy LCVs recommended should meet your requirements, you should identify the
maximum daily mileage of each of your vehicles before replacing them. This will
avoid you procuring BEV vehicles required to regularly complete journeys
exceeding their range. We recommend that you base your funding strategy for
these vehicle replacements on the fleet decarbonisation plan outlined in this
report.
In addition to ZEV fleet replacement, you should continue encouraging staff to use
pool cars and car clubs, instead of grey fleet. Most importantly, you should advise
staff to follow the sustainable travel hierarchy when selecting business travel
options.
We were not provided with any data on your depots, so have not provided any
specific, bespoke advice. However, in terms of general infrastructure advice, the
key things to be aware of when designing and implementing charging
infrastructure are as follows:
• Site constraints – these can be determined by comparing the available
site electrical capacity with current site demand
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• The duty cycles of vehicles based at the site – how much time they
have available to charge each day
• The daily mileage requirements of the vehicles based at the site
• The energy requirements of the vehicles based at the site – this will vary
depending on each vehicle’s efficiency
• Engagement with your distribution network operator (DNO) – this should
happen as early in the design process as possible to highlight issues
that may arise and to speed up the installation phase
You are moving towards having a fully decarbonised fleet, having already
replaced a number of your vehicles with ZEVs. Your priority should be to ensure
that your fleet replacement plans are followed, and ZEVs are adopted wherever
possible.  This is particularly the case for your car fleet, which you need to make
sure is entirely zero-emission by 2025. 
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11. References
AEA Technology, 2010. Light Goods Vehicle - CO2 Enissions Study:
Final Report, s.l.: Department for Transport.
BEIS, 2019. Greenhouse gas reporting: conversion factors 2019.
[Online] 
Available at:
https://www.gov.uk/government/publications/greenhouse-gas-
reporting-conversion-factors-2019
BEIS, 2020. Weekly road fuel prices, s.l.: BEIS.
DG Cities, 2018. The Case for Repowering Refuse Collection
Vehicles from Diesel to Electric. [Online] 
Available at: https://issuu.com/dgcities/docs/ercv_final_report__1_
[Accessed 27 February 2020].
ecoDrive, 2008. ECODRIVEN Campaign Catalogue for European
Ecodriving & Traffic Safety Campaigns, s.l.: Intelligent Energy
Europe.
Eunomia, 2020. Ditching Diesel, A Cost-benefit Analysis of Electric
Refuse Collection Vehicles, s.l.: Eunomia.
Everglade Services Ltd, 2020. Fuel Savings. [Online] 
Available at: https://www.speedlimiter.net/fuelsavings.html
[Accessed 02 March 2020].
Gov.uk, 2019. National Speed Limits. [Online] 
Available at: https://www.gov.uk/speed-limits
[Accessed 10 October 2019].
MRW, 2019. Scottish firm latest to trial electric RCVs. [Online] 
Available at: https://www.mrw.co.uk/latest/scottish-firm-latest-to-trial-
electric-rcvs-02-10-2018/
[Accessed 27 February 2020].
Royal College of Physicians, 2016. Every breath we take, The
lifelong impact of air pollution, s.l.: Royal College of Physicians.
Safe and Sound Vehicle Systems Ltd, 2020. Speed Limiters. [Online] 
Available at: https://www.sasmobile.co.uk/view-category/346/speed-
limiters
[Accessed 02 March 2020].
Scottish Government, 2019. Protecting Scotland's Future The
Government's Programme for Scotland 2019-20, s.l.: The Scottish
Government.
Scottish Government, 2019. Scottish Greenhouse Gas Emissions
2017. [Online] 
Available at: https://www.gov.scot/publications/scottish-greenhouse-
gas-emissions-2017/
[Accessed 18 10 2019].
Scottish Government, 2020. Greenhouse gas emissions 2018:
estimates. [Online] 
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Available at: https://www.gov.scot/publications/scottish-greenhouse-
gas-emissions-2018/
[Accessed 17 September 2020].
Smartroad Gotland, 2020. Smartroad Gotland. [Online] 
Available at: https://www.smartroadgotland.com/
[Accessed 27 July 2020].
Sustrans, 2013. 2013 Commute and Exercise Survey, s.l.: Sustrans.
The Highland Council, 2019. Highland Council cuts 800,000+ miles
with Enterprise Car Club. [Online] 
Available at:
https://www.highland.gov.uk/news/article/12103/highland_council_cut
s_800000_miles_with_enterprise_car_club
[Accessed 11 March 2020].
Transport Scotland, 2020. National Transport Strategy , s.l.:
Transport Scotland.
Veolia, 2020. Veolia to trial electric Refuse Collection Vehicles.
[Online] 
Available at: https://www.veolia.co.uk/press-releases/veolia-trial-
electric-refuse-collection-vehicles
[Accessed 27 February 2020]. 
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Appendix 1 GHG Methodology –
Road Transport 
Reporting of GHG emissions 
The carbon dioxide (CO2e) footprint (often shortened to carbon footprint) of an
organisation, details the tonnage of greenhouse gases (GHG) emitted in a period
of one year.  The ‘e’ in CO2e stands for ‘equivalent’ and indicates that the estimate
includes all the reportable greenhouse gases emitted. 
For road transport the reportable GHGs are carbon dioxide
(CO2), methane (NH4) and nitrous oxide (N2O).   The methane and nitrous oxide are
reported in terms of their carbon dioxide equivalence using their global warming
potential (GHG Protocol, GWP Values).  For example, one tonne of nitrous oxide has
a GWP 265 times that of carbon dioxide and is therefore equivalent to 265 tonnes
of CO2. The GWP of methane is 28 so one tonne is reported as 28 tonnes CO2.  All
organisations should report CO2e emissions and not just CO2 if the reporting
is to comply with national and international GHG reporting standards.   
For reporting of road transport GHG emissions, we use tank to wheel (TTW) factors.
This means that the factors do not include any CO2e emissions relating to the
extraction, refining and distribution of the fuels, known as well to tank (WTT) factors,
nor do they include the manufacture and disposal of the vehicles. WTT factors are
published and can be combined with TTW factors to give well to wheel (WTW)
values, but the upstream emissions of WTT should be reported by the supplier of
the fuel. 
Emission reporting categories – use of scopes 
GHG emissions are reported in one of four categories known as Scope 1, Scope 2,
Scope 3, and “Out of Scope”.  All the GHG emissions from the direct burning of fossil
fuels are in Scope 1. For road transport these are the fuels that
the organisation buys and burns in its vehicles and are usually diesel, petrol, LPG or
natural gas.  Scope 2 covers purchased energy, so this includes the GHG emissions
associated with generating the electricity used to charge all plug-in electric
vehicles.   
Scope 3 is used for “indirect” emissions. This is where the GHG emissions associated
with cash allowance cars and grey fleet vehicles fall; the organisation has paid for
the use of the vehicle as a service and some of that payment has gone to buying
fossil fuels or electricity.  “Out of Scope” GHG emissions covers all
the biogenic emissions associated with biofuels like biomethane, biodiesel and
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bioethanol.  These are carbon emissions produced from short-cycle carbon
sources like crops. 
All large organisations must report Scope 1, Scope 2, and some of the Scope 3
emissions over which it has direct control such as those associated with the grey
fleet, cash allowances cars, rail travel and air travel.  Some organisations go further
and report the Scope 3 emissions associated with their supply chain, both
upstream & downstream, this is not mandatory but could be regarded as best
practice as long as it does not trivialise the Scope 1 and Scope 2 emissions of the
organisation by making them seem insignificant in comparison.   
Scope 1 and 2 GHG emissions as well as Scope 3 transport emissions are ones that
you can directly impact by choosing smaller vans, implementing a pro-electric
company car policy and setting carbon emission limits on the cash allowance and
grey fleet.  Changing the carbon emissions embedded in the supplies you buy may
be a lot harder and have less impact.  
Why do we use these categories? 
These categories are intended to avoid double counting.  Only the organisation
burning the fossil fuel will report its Scope 1 emissions.  The Scope 2 emissions from
using electricity become the Scope 1 emissions of the generating company that
burnt the gas or coal to make the electricity.  The Scope 3 emissions associated
with a train journey become the Scope 1 emissions of the train operator who burnt
the diesel to power the train.   
So why bother reporting Scope 2 and Scope 3 at all?  Because it is the end user,
e.g. the consumer of the electricity or the user of
the train, who creates the demand for the service.  Without that demand the Scope
1 emissions would not be created by the service provider, so it is important
companies focus on reducing the Scope 2 and 3 emissions because that puts
pressure on suppliers to reduce their Scope 1 emissions.   
Car/van GHG & kWh calculations (DBEIS 2019 data set) 
This transport methodology has been developed and refined since its introduction
by the Energy Saving Trust (EST), DfT and Defra in 2004 and is fully compliant with
the UK’s Streamlined Energy and Carbon Reporting (SECR) if the data used is for the
company’s financial year.  Initially established to determine the carbon dioxide
emissions it has been adapted to determine energy use as required for the Energy
Saving Opportunity Scheme (ESOS) but again the correct period must be
covered.   
It is based on the DBEIS GHG fuel conversion factors for CO2e/unit (litre, kg,
kWh) and CO2e/kWh which are published annually in June or July.  The factors used
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must reflect the data year, so for the financial year 2019/20 you must use the
2019 GHG conversion factors published by the Department for Business, Energy &
Industrial Strategy (DBEIS).  Full data sets are available from 2014, new data sets are
published every June.   
This part of the methodology covers all vehicles up to 3.5 tonnes.  There are five
methods and they are used in order of diminishing accuracy:   
Type of fuel and fuel used (litres, kg or kWh). 
Mileage driven with published (OEM) gCO2/km and “real-world” uplift. 
Mileage driven with fuel type and car engine size or van size. 
Mileage driven with fuel type. 
Mileage driven with UK average car or van. 
Methods 1 and 2 are based on data about the actual fuel used or the actual vehicle
used.  Methods 3 to 5 are based on data from the UK national fleet combined with
diminishing information about the vehicle used and are a way of estimating GHG
emissions and energy use in the absence of any specific data about the fuel
usage or GHG emissions of the vehicle.  It follows therefore that any improvement
made to fuel efficiency or to the vehicles in the fleet will not be accurately tracked
by using Methods 3 to 5.   
Method 1: fuel use 
This is the most accurate means of determining both energy use and GHG
emissions.  The following factors are used for the determination of GHG emissions
and energy use from fuels. 
Table 11-1 - GHG factors for fuels
Fuel  Units  GHG scope  kg
CO2e/unit 
kg
CO2e/kWh  kWh/unit 
Petrol  Litres  1  2.2090  0.2337  9.4513 
Diesel  Litres  1  2.5941  0.2446  10.6047 
CNG  Kg  1  2.5420  0.1839  13.8267 
LNG  Kg  1  2.5500  0.1844  13.8266 
LPG  Litres  1  1.5226  0.2145  7.0994 
Electricity  kWh  2  0.2556  0.2556  1.0000 
Electricity T&D  kWh  3  0.0217  0.0217  1.0000 
There is an expectation that fuel data will be available for all directly operated
LCVs (vans) and HDVs (lorries).  It is sometimes available for company or lease cars
where fuel cards are provided, and either staff receive private fuel as a benefit, or
they reimburse the company for their private mileage.  In the case of the opt-out
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or cash allowance car fleets and the grey fleet, fuel data will not usually be
available, so will have to use Method 5.   
When linked with mileage driven fuel use provides a measure of energy efficiency
which in the UK is usually referred to as miles per gallon (mpg) but can also be
represented as miles/kWh, litres/100km and kWh/km.  Use of kWh is independent of
the type of fuel or its delivery method (litre, kg or kWh).  Electric vehicles
use Wh (Watt hours) per mile (Wh/mile) or miles per kWh. 
Method 2: Mileage and published g/km 
In the absence of fuel data, the published GHG emissions of the vehicle in g/km are
the next most accurate estimate of energy use and GHG emissions.  The data has
been available for all cars since 2001 (and for some cars since 1997) and for all vans
since 2009.  If the data is not held for Benefit in Kind income tax reporting (P11D) it
can be obtained from the DVLA via agents such as CarweB using the vehicle
registration mark. 
The published factor must be uplifted to reflect the real-world performance of the
vehicle and compensate for the manipulation of the NEDC test by the
manufacturers.  In the car fleet the variance between published data and actual
emissions has been increasing steadily and since 2014 this annual variance has
been reflected in the DBEIS GHG factors.  The most accurate method is an age-
related uplift based on the DBEIS data shown in Table 11-2. 
Table 11-2 - DBEIS Real world uplift by year of registration
Year  2002  2003  2004  2005  2006  2007  2008  2009 
Uplift  8.6%  9.7%  10.8%  11.9%  13.0%  15.65%  18.3%  20.95% 
Year  2010  2011  2012  2013  2014  2015  2016  2017 
Uplift  23.6%  26.25%  27.6%  29.0%  33.3%  41.5%  38.0%  31.5% 
The calculation is therefore based on:  
Published g/km x (1+% Uplift for Year) x Distance travelled (km) = gCO2e 
The fuel factor for kg CO2e/kWh is then used to convert the calculated GHG
emission into kWh of energy used, therefore, the fuel type must also be
known.  Where the year is not known an appropriate rolling average uplift can be
used.  
Method 3: Mileage plus fuel and a size factor 
This method is used where no published emission data is available about the
actual vehicles used but fuel type and engine or vehicle size is known.   
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Table 11-3 - DBEIS average emissions factors where vehicle type is known
Petrol cars  kg
CO2e/km  kWh/km 
< 1,400  0.1537  0.6576 
1400-2000  0.1923  0.8227 
> 2,000  0.2830  1.2106  
Diesel cars  kg CO2e/km  kWh/km 
< 1,700  0.1537  0.6576 
1,700-2,000  0.1923  0.8227 
> 2,000  0.2830  1.2106  
LPG car  kg CO2e/km  kWh/km 
< 2,000  0.1807  0.8424 
> 2,000  0.2659  1.2398  
Petrol motorbikes  kg CO2e/km  kWh/km 
<125cc  0.0845  0.3613 
125 - 500cc  0.1029  0.4402 
>500cc  0.1350  0.5776  
Petrol van  kg CO2e/km  kWh/km 
(Class I), <1.305 tonne  0.2374  1.0157 
(Class II), 1.305 - 1.74
tonne  0.2283  0.9769 
(Class III), 1.74 - 3.5 tonne  0.3846  1.6455  
Diesel van  kg CO2e/km  kWh/km 
(Class I), < .305 tonne  0.1496  0.6114 
(Class II), 1.305 - 1.74
tonne  0.1946  0.7953 
(Class III), 1.74 - 3.5 tonne  0.2778  1.1355 
Method 4: Mileage plus fuel type 
If only fuel type is known the following factors are used: 
Table 11-4 - DBEIS average emissions factors where only fuel type is known
Cars fuel only  kg CO2e/km  kWh/km 
Average petrol car  0.18084  0.7737 
Average diesel car  0.17336  0.7087 
Average LPG car  0.19901  0.9279 
Average electric car  0.06020  0.2461    
Van fuel only  kg CO2e/km  kWh/km 
Average petrol van  0.2365  1.0116 
Average diesel van  0.2521  1.0307 
Average LPG van  0.2724  1.2703 
Average CNG van  0.2478  1.3478 
Average electric van  0.0629  0.3419 
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Method 5: UK fleet average 
In the absence of any data other than mileage driven the only option is to use UK
fleet data.  National data for England, Scotland and Wales is not yet available. 
Table 11-5 - Average UK vehicle emissions factors
UK average  kg CO2e/km  kWh/km 
Car  0.1771  0.7438 
Van  0.2516  1.0286 
Motorbike  0.11551  0.4942 
Electric vehicles and plug-in hybrids 
The factor to use for a battery electric vehicle (BEV) is linked to the source of the
electricity.  If it is drawn from the national grid, then the current Scope 2 factor
for GHG should be used to which should be added the Scope 3 factor for
Transmission and Distribution (T&D).  Because BEVs do not directly burn a fuel their
Scope 1 emission is zero, hence they are correctly rated by the OEMs as
0 gCO2/km.   
Table 11-6 - DBEIS average emissions factors for BEVs
Fuel  Units  Scope  kg
CO2e/unit 
kg
CO2e/kWh  kWh/unit 
Electricity  kWh  2  0.2556  0.2556  1.0000 
Electricity T&D  kWh  3  0.0217  0.0217  1.0000 
If the electricity is generated from other sources, for example a combined heat
and power (CHP) plant or an energy from waste (EfW) plant, then an appropriate
factor must be determined for that plant.   
If the BEVs are charged on-site, then the GHG emissions may already be reported
under the site’s Scope 2 and 3 reporting of electricity consumed and it is important
that this is not double reported.   
If the cars are charged off-site (at employee’s homes or on-the-road) then those
emissions should be included in the vehicle’s carbon footprint but reported
separately to fuel burnt (diesel, petrol and gas). 
HDV GHG & kWh calculations (DBEIS 2019 data set) 
This is a standardised approach to estimating Heavy Commercial Vehicle (HDV)
fleets’ CO2e emissions.  HDV fleets should normally have full and accurate records
of both fuel used and mileage driven (this may be recorded in kilometres).   
The methods are presented in order of accuracy and the most accurate
methodology should be used for each vehicle. 
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Method 1: Fuel consumption data 
If comprehensive fuel consumption data is available from fuel card records and/or
a bunkered fuel system, the GHG emissions and energy use should be calculated
by applying the following factors to the quantity of fuel consumed.  
Table 11-7 - GHG emissions factors for fuels
Fuel  Units  GHG
Scope 
kg
CO2e/unit 
kg
CO2e/kWh  kWh/unit 
Petrol14  litres  1  2.2090  0.2337  9.4513 
Diesel8  litres  1  2.5941  0.2446  10.6047 
CNG  kg  1  2.5420  0.1839  13.8267 
LNG  kg  1  2.5500  0.1844  13.8266 
LPG  litres  1  1.5226  0.2145  7.0994 
Electricity  kWh  2  0.2556  0.2556  1.0000 
Electricity T&D  kWh  3  0.0217  0.0217  1.0000 
Methods 2 to 5: Mileage data but no fuel data. 
If fuel data is not available, the methodology must be based on distance travelled
(miles or km) and the appropriate conversion factor which depends on the
additional data available (see Table 11-8).   
Table 11-8 - HDV methodologies - mileage data
GHG
Methodology  Mileage  Artic/rigid  GVW  Load
factor 
Method 2  ✓ ✓ ✓ ✓
Method 3  ✓ ✓ ✓  
Method 4  ✓ ✓    
Method 5  ✓       
To convert from kg CO₂e km-1 to kWh km-1 the GHG factor is divided by the fuel
factor (diesel) in kg CO2e kWh-1 to give kWh km-1 
Table 11-9 - Rigid HDV average GHG emissions (not refrigerated)
GVW
Class  GVW  % Load
factor  kg CO₂e km¯¹ 
Class 1  >3.5-7.5t 
0%  0.4570 
50%  0.4961 
100%  0.5352 
UK average
46%  0.4922 
14 The diesel and petrol factors are for the biofuel blends sold in the UK.
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Class 2  >7.5-17t 
0%  0.5529 
50%  0.6306 
100%  0.7083 
UK Average
39%  0.6010 
Class 3  >17t 
0%  0.7661 
50%  0.9311 
100%  1.0961 
UK Average
54%  0.9556 
Average  Unknown  UK Average
53%  0.8001 
Table 11-10 - Articulated HDV average GHG emissions (not refrigerated)
GVW
Class  GVW  % Load factor  kg CO₂e km-
¹ 
Class 1  >3.5-33t 
0%  0.6407 
50%  0.7979 
100%  0.9551 
UK average
44%  0.7853 
Class 2  >33t 
0%  0.6626 
50%  0.8788 
100%  1.0951 
UK average
62%  0.9351 
Average  Unknown  UK average
61%  0.9253 
Table 11-11 - Average HDV GHG emissions - Any Type (not refrigerated)
GVW
class  GVW  % load factor  kg CO₂e km¯¹ 
All Average  0.8665 
Table 11-12 - Rigid HDV average GHG emissions (refrigerated)
GVW
class  GVW  % load factor  kg CO₂e km-
¹ 
Class 1  >3.5-7.5t 
0%  0.5437 
50%  0.5903 
100%  0.6369 
UK average
46%  0.5856 
Class 2  >7.5-17t 
0%  0.6578 
50%  0.7504 
100%  0.8431 
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UK Average
39%  0.7152 
Class 3  >17t 
0%  0.9110 
50%  1.1079 
100%  1.3047 
UK Average
54%  1.1371 
Average  Unknown  UK Average
53%  0.9525 
Table 11-13 - Articulated HDV average GHG emissions (refrigerated)
GVW class  GVW  % load factor  kg CO₂e km-
¹ 
Class 1  >3.5-33t 
0%  0.7418 
50%  0.9244 
100%  1.1069 
UK average
44%  0.9098 
Class 2  >33t 
0%  0.7670 
50%  1.0180 
100%  1.2690 
UK average
62%  1.0832 
Average  Unknown  UK Average
61%  1.0716 
Table 11-14 - Average HDV GHG emissions - Any Type (refrigerated)
GVW
class  GVW  % load factor  kg CO₂e km-¹ 
All average (refrigerated)  1.0158 
Electricity Renewable Energy Guarantees of Origin (REGO) and Gas Renewable
Transport Fuel Obligation (RTFO) certificates. 
Many organisations have opted to have their grid electricity supplied from
renewable sources backed by REGO certificates or grid biomethane backed by
RTFO certificates. 
The GHG emissions of the electricity or gas can be reported in line with the
“market-based” (consumer) value calculated by the supplier (e.g. Zero gCO2e/kWh
if 100% renewable electricity) but it should also be reported alongside the “location-
based” (national) figure.   
This is because the zero-emissions benefit of the electricity or gas has already
been accounted for in the national UK grid figure.  The benefit cannot be taken
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twice, nor can the carbon factor for other consumers be adjusted upwards to
compensate. 
The requirement to do this is fully documented in: 
HM Government: Environmental Reporting Guidelines (ERG): Including streamlined
energy and carbon reporting guidance.  March 2019, pages 48-49 
"Where organisations have entered into contractual arrangements for renewable
electricity, e.g. through Power Purchase Agreements or the separate purchase of
Renewable Energy Guarantees of Origin (REGOs), or consumed renewable heat or
transport certified through a Government Scheme and wish to reflect a reduced
emission figure based on its purchase, this can be presented in the relevant report
using a “market-based” reporting approach. It is recommended that this is
presented alongside the “location-based” grid-average figures and in doing so,
you should also look to specify whether the renewable energy is additional,
subsidised and supplied directly, including on-site generation, or through a third
party. A similar “dual reporting” approach should be taken for biogas and
biomethane (including “green gas”)." 
GHG Protocol, Scope 2 Guidance, Corporate Standard, Section 1.5.1, page 8 
“Companies with any operations in markets providing product or supplier-specific
data in the form of contractual instruments shall report scope 2 emissions in two
ways and label each result according to the method: one based on the location-
based method, and one based on the market-based method. This is also termed
“dual reporting.” 
What is permitted is time specific emission factors.  The HM Government ERG
state:  
“Where available, time specific (e.g. hour-by hour) grid average emission factors
should be used in order to accurately reflect the timing of consumption and the
carbon-intensity of the grid.” 
The carbon intensity of the grid varies throughout the day and the year.  The grid
data is publicly available in half hourly intervals, but organisations may have
difficulty providing half hourly consumption data unless that is how they are
billed.   
Where a company generates its own renewables on-site or locally, for example by
using photovoltaic, wind with “private wire” or an on-site anaerobic digester and
does not supply the grid it can be accounted for as a zero or low carbon supply. 
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Appendix 2 Euro standards
The vehicle emission standards in force in the EU are known as the Euro standards
and are now widely used around the world although not always to the same
timeline as in the EU. More stringent air quality standards apply in the USA where
standards do not differentiate between fuel types and air quality is seen as a more
important issue than carbon emissions. 
The Euro standards were first introduced in 1993/94 to regulate and reduce the
toxic emissions of vehicles. Carbon monoxide (CO), hydrocarbons (HC), nitrogen
oxides (NOX), particulates under 10 microns in diameter (PM10) and the number of
those under 2.5 microns in diameter (PM2.5) are all regulated. Carbon dioxide
(CO2) emissions are not regulated as they do not have a direct health impact but
may be included in the Euro 7 standard. 
Prior to 1993 a range of national standards were in place across the EU and before
1988 there was little or no effective regulation of vehicle emissions. 
In most cases the standard for all new vehicles sold came into force one year after
the date for new type approvals. However, for Euro 5a cars and vans
implementation was delayed until 01/2011 and for 5b cars and vans until 01/2013
Euro standards and dates they were introduced can be seen below in Table 11-15.
Table 11-15 -  Euro emission standards implementation dates
<3.5t Euro standard Cars Vans
1 07/1992 10/1994
2 01/1996 01/1998
3 01/2000 01/2001
4 01/2005 01/2006
5a 09/2009 09/2010
5b 09/2011 09/2011
6 09/2014 09/2015
7 By 2021? By 2021?
Euro 5b added a restriction on the number as well as the mass of particles (PM)
from diesel and petrol engines. Euro 6c changed the test regime to one more
representative of real-world performance and Euro 7 planning has begun. For
small cars a Euro 7 diesel engine may be prohibitively expensive to make.
It is important to understand that the Euro standards are not the same for petrol
and diesel and at all levels they permit diesel vehicles to be more polluting. The
Euro 6 standard for a diesel car or van is like the Euro 4 standard for a petrol car or
van and as a result a 10-year-old Euro 4 petrol car can have the same emissions
as a brand-new Euro 6 diesel car.
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Appendix 3 Air quality, public health
and LEZs
Health impact of poor air quality
The impact of poor air quality on human health is under constant re-assessment.
In December 2015 Defra15 reported that each year 23,500 premature deaths are
associated with NO2 and a further 29,000 with PM10 and PM2.5. This gives a total of
52,500 premature deaths each year due to the two pollutants. 
The February 2016 report on Air Pollution by the Royal Colleges of Physicians,
Paediatrics and Child Health16 suggests 40,000 premature deaths per annum and
attributed the difference in the total to an overlap between deaths caused by NO2
and PM. 
In 2017, the number of road deaths was 1,793 and there were 24,831 serious injuries.
Clearly the research would suggest that air pollution is responsible for many more
premature deaths than road collisions. 
Since 2000 the assessment of the impact of poor air quality has shifted from it
being an antagonist to pre-existing medical conditions to it being a major cause
of poor health and premature death. The number of deaths from asthma in
England and Wales has increased by 25% since 2007.
There is evidence from around the world that children brought up within 100m of a
main road suffer significantly more respiratory ailments (e.g. asthma). There is also
evidence to link particulates in the air with particulates in the blood, blood clots,
strokes and heart failure2. A study published in The Lancet Respiratory Medicine
(November 201317) has linked fine particulates to low birth weight. Particulates have
also been linked to a form of dementia by a study in Taiwan.
Under the precautionary principle reducing these emissions in residential urban
areas is important but it is also the case that people working in cities are subject to
prolonged exposure at times when pollutant levels are at their highest. 
A 2014 study from Public Health England looked at deaths from particulate air
pollution in each UK borough. This has been published in graphical form by “The
Guardian DATABLOG” and the map shows for each geographic area the 
15 Draft plans to improve air quality in the UK, Tackling nitrogen dioxide in our towns and cities. UK Overview Document,
September 2015, Defra.
16 Every breath we take, the lifelong impact of air pollution, February 2016
17 Ambient air pollution and low birthweight: a European cohort study (ESCAPE), The Lancet Respiratory Medicine, Vol 1, No 9
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percentage of premature deaths in 2014 calculated to be caused by fine
particulate matter (ambient PM2.5). 
Clean air in the workplace is now becoming an issue and there is the possibility of
legal claims over employee exposure to diesel exhaust fumes. The Royal Mail and
Christchurch Council are being sued by Unions for their alleged failure to protect
staff from diesel exhaust fumes18.
Air quality in the UK
There are over 200 local authorities with designated Air Quality Management Areas
(AQMAs) in the UK and most are due to diesel engine emissions. The BBC Radio 4
programme “Costing the Earth” and the Channel 4 Despatches programme “The
Great Car Con” have raised public awareness of the issue while the VW
“dieselgate” crisis has focused attention on the very poor real-world performance
of modern diesel engines. It is not unusual for a Euro 5 or 6 diesel car to have higher
toxic emissions (mg/km) than a Euro VI lorry or bus.
In April 2015 the Supreme Court ordered the UK Government to bring forward long
delayed proposals to comply with 2010 UK air quality standards. The plan produced
by Defra in December 2015 envisaged Clean Air Zones (CAZ) in just five cities out of
sixteen considered: Birmingham, Leeds, Nottingham, Derby and Southampton. 
These CAZs would restrict access by the most polluting diesel buses, coaches, taxis
and lorries. In Birmingham and Leeds, the zones were also expected to restrict the
most polluting diesel vans. No restrictions on cars were envisaged although it soon
became clear that all diesel vehicles would need to be included if the plans were
to be effective.
In early November 2016, following legal action against the government by the
lobby group ClientEarth, the High Court ruled the government’s CAZ plan was “far
too leisurely” used “over-optimistic” pollution modelling and was based on “flawed”
lab tests. 
In late November 2016 the High Court further ruled that an effective plan must be
delivered in eight months; the draft by 24th April 2017 and the final by 31st July 2017. 
The final plan19 was released in late July 2017. It did not require any more cities to
implement CAZs, but it did identify the CAZ as the most effective means of
reducing nitrogen dioxide pollution. It required 23 additional areas to bring forward
plans to improve air quality but did not mandate Clean Air Zones as the solution.
The plan was widely criticised and led to further legal action by ClientEarth and this
resulted in 33 more towns and cities being included. 
18 UK legal claims grow over exposure at work to toxic diesel fumes, The Guardian, September 2017
19UK plan for tackling roadside nitrogen dioxide concentration, Defra and DfT, July 2017
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Standards
Fuel & category Minimum standard
Petrol – all types Euro 4/IV
Diesel – all types Euro 6/VI
Motorcycles Euro 3
Electric – all types All charge free
The proposed minimum emission standards for unrestricted and charge-free
access to a UK Low Emission/Clean Air Zone from 2020 are shown in Appendix 3.
Penalties for non-compliant vehicles could eventually be as high as £200/day
(London LEZ charge for non-compliant HDV). 
However, to meet the 2010 UK air quality standards, it may prove necessary to ban
all internal combustion engine vehicles from polluted town and city centres, but
this may not occur until 2025 - 15 years after the air was meant to meet the
standard - and then only after all the other options have been tried and shown to
be unsuccessful. 
Further information about LEZs in Scotland can be found Low Emission Zones
Scotland. 
Categories
According to the Transport Scotland, Defra and the Department for Transport
Clean Air Framework there will be four UK-wide categories of Low Emission/Clean
Air Zone each differing in the scope of vehicles included:
Class A - Buses, coaches, taxis and private hire vehicles (PHVs),
Class B - Buses, coaches, taxis, PHVs and heavy commercial vehicles (HDVs),
Class C - Buses, coaches, taxis, PHVs, HDVs and vans (LGVs),
Class D - Buses, coaches, taxis, PHVs, HDVs LGVs and cars.
In theory there can also be charging and non-charging LEZ/CAZs. It is not clear how
a LEZ/CAZ would be enforced without some form of charging or fines. 
LEZs in Scotland
According to the LEZ Leadership group terms of reference: “Air quality is a priority
for Scottish and local government. The Programme for Government has set out
a commitment to establish Low Emission Zones (LEZs) in Scotland’s four biggest
cities by 2020, with the first LEZ being in place by 2018.”
Table 11-16 - Minimum standards for charge-free access to Glasgow LEZ
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Glasgow
Scotland's first Low Emission Zone (LEZ) came into effect in Glasgow city centre on
31 December 2018. Glasgow's LEZ is being phased in and to start with, will only apply
to local service buses which are required to meet the Euro VI emission standard.
Phase two is expected to launch on 31/12/2020 an on 31 December 2022 a Class D
zone will be implemented which will apply to all vehicle types. 
Edinburgh, Aberdeen & Dundee
LEZs are due to be launched in Edinburgh, Aberdeen and Dundee between
February/May 2022. This is due to be a full Class D Zone covering all vehicle types. 
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Appendix 4 ZEV HDVs, RCVs and
SPVs 
HDVs
Table 11-17 - Non-exhaustive list of ULEV HDVs
Make and
model GVW (tonnes) Notes
DAF CF Electric
(4x2 tractor
unit)
up to 37
tonnes
170kWh battery, up to 100km range and around 3x the
cost of a diesel truck
DAF LF Electric 19 tonnes Up to 222kWh battery pack, 220km range (for fully
laden truck) Around 3x the cost of a diesel truck
Eforce Trucks 26-44 tonnes
Modular batteries up to 340kWh, comes in many
different models and as an RCV, 91% battery to wheel
efficiency, possible range of over 450km, DC
charging up to 350kW
IVECO Daily
Electric 
Up to 5.6
tonne
3.5,11 and 22kW charging and a charging time within 2
hours. Up to 200km range
IVECO Euro
Cargo Hybrid 7.5 or 12 tonnes
Fuel savings of up to 30% in the urban cycle,
compared with conventional diesel engine vehicles.
1.9kWh battery pack
MAN eTGM 26 tonnes 6x2 truck, 190km range, 185kWh battery pack, up to
150kW DC charging
Mercedes-Benz
eActros 18 - 25 tonne Range of up to 200km, two battery packs totalling
240kWh, up to 150kW charging speeds
Mitsubishi
Canter Eco
Hybrid
7.5 tonne 2kWh battery (Hybrid), 23% reduction in fuel
consumption
Mitsubishi Fuso
eCanter 7.255 tonne 82.8kWh battery, 80 miles of range, 30% less
maintenance costs
Paneltex (Isuzu) 7.5 tonne Only a 9kW or 18kW charger, no rapid charging, 80,
120 or 160kWh battery packs, range of up to 240km
Volvo FE 27 tonnes
Can be fitted with up to four battery packs. Each
pack has an energy capacity of 50 kWh and an
estimated lifetime of 8–10 years. Range: Refuse and
light construction up to 120 km, distribution up to 200
km
Volvo FL 16 tonnes
Can be fitted with up to 6 battery packs at
50kWh/pack and an estimated lifetime of 8-10 years.
Up to 186 miles of range
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Table 11-17 outlines some of the zero-emission and ultra-low-emission HDVs that
are either on the market or coming to the market soon. The sizes and capabilities
of these vehicles vary widely, so it is important to be specific in your requirements
and trial vehicles where possible to determine their operational suitability.  
Scania BEV Up to 29
tonnes
BEV with battery capacity of 165kWh or 300kWh and
gives a range of up to 250km. Available with the L and
P-series cabs and body types such as refrigerated
box, tipper, concrete mixer and refuse collector, as
well as special vehicles for fire and rescue services.
Can charge at up to 130kW.
Scania PHEV Up to 29
tonnes
Can cover 60km on electricity only. Available with the
L and P-series cabs and body types such as
refrigerated box, tipper, concrete mixer and refuse
collector, as well as special vehicles for fire and
rescue services. can charge at up to 130kW.
Renault D wide
Z.E. 26 tonnes
available with up to four, 66kWh modules, allowing
ranges of up to 180km. This is only available in a 3.9-
meter wheelbase. Can charge at 20kW AC and 150kW
DC.
Renault D Z.E. 16 tonnes
available with up to six, 66kWh modules, allowing
ranges of up to 400km. This is available in two
wheelbases (4.4 and 5.3 meters). Can charge at
20kW AC and 150kW DC.
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RCVs 
Table 11-18 - Non-exhaustive list of ULEV RCVs
There are several electric RCVs (eRCVs) on trial and in active service across the
country. Most noticeably in London where Veolia have commissioned seven zero-
emission 26-tonne eRCVs from Electra Commercial vehicles. These eRCVs are
based on the Dennis Eagle Elite Chassis. Edinburgh (MRW, 2019), Sheffield (Veolia,
2020) and Greenwich (DG Cities, 2018) are also trialling eRCVs. 
A recent report by eunomia “Ditching Diesel, A Cost-benefit Analysis of Electric
Refuse Collection Vehicles” (Eunomia, 2020) suggests that the total cost of
ownership of an eRCV is only £29,608 greater than a diesel equivalent and if
including the monetised impact of emissions they produce a saving of £12,365.
There is also a CO2e saving of up to 88%. This is based on RCVs collecting
household residual waste five days a week on a 60-mile round trip and over a
vehicle lifetime of eight years. Figure 8-1 below outlines some of the cost
differences between the models.     
Make and
model GVW (tonnes) Notes
Volvo FL 16 tonnes
Can be fitted with up to four battery packs. Each pack
has an energy capacity of 50 kWh and an estimated
lifetime of 8–10 years. Range: Refuse and light
construction up to 120 km
Volvo FE 26 tonnes
Can be fitted with up to 6 battery packs at 50kWh/pack
and an estimated lifetime of 8-10 years. Up to 186 miles
of range
Dennis Eagle
eCollect 26 tonnes 300kWh batteries
Geesinknorba
electric GPMIV 26 tonnes 200kWh batteries
Magtec - Retrofitters of ICE HGVs and RCVs to electric, hybrids and
hydrogen
Electra
Commercial
Vehicles
26 tonnes 
Retrofitters of ICE HGVs and RCVs to electric, generally
retrofit Mercedes Benz Econics and Dennis Eagle Elites.
Currently in use in London.
Eforce  26 tonnes
Modular batteries up to 340kWh, retro fit to a
Geesinknorba body. Up to 450km range, up to 350kW DC
charging using CCS, urban consumption of 800-
1200Wh/km
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Figure 11-1 - Diesel and electric RCVs - How do they compare? (Eunomia, 2020)
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SPVs
Table 11-19 - Non-exhaustive list of ZEV SPVs 
Make and model GVW
(tonnes) Notes
Boschung Urban-
sweeper S2.0 3.5 tonnes Street sweeper. Currently being operated by
Nottingham City Council, 8 hours of operation
Dulevo D.Zero2  - Street sweeper. Battery electric, 8 hours of operating
on a full charge
Global Environmental
Products M4 ZE-Series 7.5 tonnes Street sweeper. Driven by a hydrogen Fuel-cell 
Glutton Zen - 
Compact street sweeper ideal for town centres,
alleyways, pedestrian zones, town squares, historic
centres, marketplaces, confined or inaccessible
places.
Schmidt eSwingo
200+ 5 tonnes Street sweeper. 75kWh battery, 10hr running time, 4hr
charging time 
Tenax International
(MaxVac) Electra 2.0
neo
4.3 tonnes Compact Street Sweeper, available with Li-ion, Lead
acid or gel batteries   
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