There’s still time to have your say on TfL’s ultra-low emission zone

Happy New Year!  We hope that you have had an enjoyable and relaxing time.

Transport for London is currently consulting on an Ultra Low Emission Zone (“ULEZ”) to come into effect from September 2020.  The consultation ends on Friday 9 January so there is still time to make your voice heard!

TfL's Ultra Low Emission Zone map

The proposed boundaries would be the same as the current central London congestion charge zone. With frequent exposure to high levels of airborne pollutants in this area, such a measure would be welcome. But we feel both the scope and the range of the zone are uninspiring and represent a missed opportunity.

We’d encourage everyone with an interest in air quality across London to respond to the consultation.

You can find our reply to the consultation below. You may like to consider or adapt it while composing your own response. We haven’t included questions that require personal information.

13. In your opinion, how important is it to tackle poor air quality in central London?

(Very important down to very unimportant) – “Very important”

14. Do you support an Ultra Low Emission Zone (ULEZ) in central London to encourage the use of low emission vehicles to improve air quality?

(Strongly support to strongly oppose) – “Strongly support”

15. It is proposed that private and commercial vehicles that do not meet the ULEZ standards must pay a daily charge to drive within the ULEZ from 2020. Do you support this?

(Range of vehicles & options strongly support to strongly oppose) – Chose “Strongly support” for all

16. Do you think the proposed boundary of the ULEZ shown on the map is the appropriate area for charging vehicles which do not meet the ULEZ standards?

(Yes, Should be smaller, Should be larger, No) – “Should be larger”

17.Do you support the proposal that the ULEZ standards would be enforced 24 hours a day, 365 days a year?

(Strongly support to strongly oppose) – Chose “Strongly support”

18. Do you think the proposed charge (£100 for heavy vehicles and £12.50 for cars, vans and powered two wheelers) is appropriate?

(Yes, No too low, No too high, Don’t know) – Chose “No, too low”

19. It is proposed that residents in the ULEZ would not need to meet the ULEZ standards until 2023 (and therefore not pay a daily charge until then). Do you support this? 

(Strongly support to strongly oppose) – “Neither support nor oppose”

20. Do you support the proposal for TfL to operate only hybrid double deck and zero emission single deck buses on bus routes operating through the ULEZ?

(Strongly support to strongly oppose) – “Strongly support”

21-23. Do you support the proposals to reduce emissions from taxis and private hire vehicles by:
a) Introducing a requirement in 2018 that newly licensed vehicles would be zero emission capable for:
(Strongly support to strongly oppose) – “Strongly support”
b) Reducing the Londonwide age limit for non zero emission capable taxis to 10 years and exempting all licensed taxis from the ULEZ standards (and therefore daily charge)
(Strongly support to strongly oppose) – “Strongly support”
c) Requiring PHVs to meet the ULEZ standards for private cars in order to drive in the ULEZ without paying a daily charge (similar to other cars and vans)
(Strongly support to strongly oppose) – “Strongly support”

24. Do you think the proposed date of 2018 for requiring new taxis and PHVs to be zero emission capable is:

(About right, could be achieved earlier, should be achieved later, no opinion) – “Could be achieved earlier”

25. Please write in the box below if you wish to make any other comments about any aspect of the ULEZ proposal including any potential exemptions or expand on any of your responses above.

The ULEZ represents a missed opportunity. It is restricted to the existing Congestion Charge zone which only covers a few of the areas in London which suffer from poor air quality.  While the area of the proposed ULEZ features some areas where pollution is particularly high, the choice of area gives the impression that it was picked for the ease of implementation and monitoring – as infrastructure is already in place and it is an area of the road network that due to its size TfL can really control – rather than for its impact on pollution.

Poor air quality is very much localised, and your crude measure – “the percentage of population living in areas of NOx exceedance” – does not reflect the real health issue facing London.

While we would not wish anyone to have to suffer poor air quality, it is notable that these measures are focussed on an area with just 200,000 residents. It appears one motivation behind the ULEZ is to protect the image of London rather than actually protecting all of the residents of Greater London: “this [the ULEZ area] is where most people visiting and living in London are exposed to pollution on a daily basis.”

It is also not clear whether the current ULEZ proposal would a) solve the air pollution issue, b) get London to just within legal limits, or worse, c) do nothing.

We believe: 

a) the ULEZ should be extended to cover at least all inner London boroughs (to the east, at least as far as Greenwich and Newham) but should probably expand further to cover the whole area inside the M25.

b) In addition to the ULEZ, the mayor should be stopping road building schemes such as the Silvertown Tunnel, a project that will further increase congestion and air pollution. This should be in conjunction with an expanded ULEZ.

We would also question whether the ULEZ is actually that much of a game-changer. The standards would already be quite old: “If approved by the Mayor, the ULEZ standards would be introduced from 7 September 2020 and by this time it is expected many vehicles will already be compliant” and “the oldest Euro VI HGV will be six years old, whilst the oldest Euro diesel 6 car will be five years old”.

Therefore much of the change you hope for would be down to the natural process of changing vehicles and updating fleets. If the ULEZ is being introduced to reinforce good air quality, it should be designed to be more aggressive than simply reflecting updated standards.  It’s  also not good enough that some of the vehicles that will remain non-compliant would be in TfL’s own fleet, unless retrofit measures are introduced.

In addition, the ULEZ does not address what we see as the core issue – the sheer weight of traffic in Greater London. More needs to be done to tackle this.

26. As vehicle technology advances, TfL may consider strengthening the ULEZ standards at a later date to set a zero emission requirement. Do you support this in principle?

(Strongly support to strongly oppose) – “Strongly support”

27. Would you support a future expansion of the area of the ULEZ to spread the benefits of improved air quality to other parts of London?

(Strongly support to strongly oppose) – “Strongly support”