Air Pollution and the ULEZ – More Information

The revised ULEZ proposals are subject to a public consultation which closes on June the 25th. I made some initial comments on it here: https://abdlondon.wordpress.com/2017/04/04/mayors-latest-announcements-on-ulez/

The intention was to provide some more comments after I have obtained more information on the costs and benefits of the proposals from Transport for London (TfL). So after no initial response from TfL I submitted an FOI ACT request which included this question: “Could you please also provide the costs of implementing the ULEZ (i.e. the capital cost) and the other proposals and the revenue and profits, i.e. surplus over operating costs in future years, forecast to be obtained by TfL as a result”. This request was refused on the grounds of commerciality sensitivity. I have disputed that rejection on the basis that it is of major public interest to know that information before people respond to the consultation, and also that as this request was handled under the Environmental Information Regulations it is not a valid cause for rejection. It will now go to an internal TfL review and after that probably to a complaint to the Information Commissioners Office. But the outcome of these appeals will not probably be known until after the date of the consultation is closed. Certainly that is likely to be too late to educate the population of London on the facts before they respond. In effect, we have a very dubious concealment of the cost/benefits of the proposals and how much profit the Mayor and TfL might generate from this new regime.

But here are some further comments based on what information is available in the current consultation documents.

It suggests that there would be a 30% saving in NOX emissions in central London in 2019 by bringing forward the ULEZ proposals. Most of the savings would come from HGVs and buses, plus to a lesser extent from vans. Emissions from cars would only reduce by 8%. The major reduction would be in central London, but there would also be benefits in inner and outer London due to trips extending to/from those areas and the change to the vehicle fleet encouraged by the ULEZ rules.

There would also be reductions in PM10 and PM2.5 (particulate) emissions, particularly the latter. But these are still relatively small – for example a 7% reduction from cars in central London, and only 2% across the GLA area.

The document does give some indication on the “damage cost savings” that might result. This is the savings on the calculated costs of the current level of pollution. These could be as high as £15.8 million in central London to as low as £10 million. They give a mid-point estimate of £28 million for the whole GLA area. They provide very little information on how those figures have been calculated. But without knowing the cost of the ULEZ scheme to the road users and the required TfL infrastructure, plus their running costs, it is impossible to say whether there is any overall benefit to the population.

In addition, please note the relatively low benefit from including cars of any kind within the ULEZ proposals.

In my view, these proposals are out of proportion to the benefit to be obtained, at least so far as the impact on car owners and drivers are concerned. The fact that TfL are apparently reluctant to disclose the financial budgets for this scheme suggests to me that it is more about tax raising than simply tackling the air pollution health issue.

So if you will be affected, please respond to the consultation which is here: http://www.tfl.gov.uk/airquality-consultation . PLEASE MAKE SURE YOU RESPOND AS SOON AS POSSIBLE

Roger Lawson

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