Panicking Londoners: Consultation on ULEZ Extension

London Mayor Sadiq Khan has announced today a consultation on the extension of the Ultra Low Emission Zone (ULEZ) to within the North/South Circular in 2021. Any vehicle that does not meet the required emission standard will be required to pay a charge of £12.50 for cars/vans in addition to any central London Congestion Charge that might also apply. Cars and vans will need to meet the Euro 6 standard for diesels and Euro 4 standard for petrol vehicles.

In addition motorcycles will be in included in the above and the ULEZ tighter emission standards will apply to the whole of London from October 2020 for heavy vehicles (buses, coaches, lorries and other specialist vehicles).

The announcement was launched with the following claims from Alex Williams of Transport for London: “Right now, air pollution in London is a public health crisis…….filthy air contributes to thousands of early deaths each year in London, and impacts our health over the course of our lives, leading to decreased lung function in our children, and greater risk of dementia and stroke when we get older.

This is scaremongering of the worst kind. The claim relating to deaths is an exaggeration and the claims about dementia and stroke are disputed by some authorities. In any case these are often based on epidemiological studies and results from such research may simply reflect the fact that those who live in poor inner-city neighbourhoods lead unhealthy life styles.

Even the suggested reduction in air pollution from these new taxes are only expected to have any impact in the next few years and by 2030 the benefit will have disappeared anyway. So very high short- term costs are being imposed on many vehicle owners as they will need to change their cars/vans unnecessarily.

I commented about claims that air pollution is causing an epidemic of asthma in a previous blog post here: https://abdlondon.wordpress.com/2017/11/18/does-air-pollution-in-london-cause-asthma/ . It’s basically nonsense.

London’s air, and the vehicles which drive in London, have been getting cleaner and that will rapidly progress as vehicles are replaced without this expensive scheme (of which the Mayor is refusing to disclose the costs). Where is the cost/benefit justification? There is none.

The Mayor claims that London’s air is “lethal” but that is simply not true. Sadiq Khan is now not just scaring children and dragging them into his politicking, but now is attempting to disconcert the elderly who might be worried about the diseases of age. It’s simply unprincipled. To say there is a “public health crisis” is just wrong. Londoners are living longer and there is no evidence that air pollution is shortening the lives of Londoners to any measurable extent.

Make sure you go here to respond to the public consultation: https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-3b/?cid=airquality-consultation

Roger Lawson

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Does Air Pollution in London Cause Asthma?

One response to the ABD’s campaign against the Mayor’s Transport Strategy is that we should not oppose it because it might stop their kids getting asthma. Children have been widely used in Sadiq Khan’s publicity over his plans to reduce air pollution and there is a strong emphasis in the Transport Strategy on the potential environmental benefits. But unfortunately, a lot of the arguments put forward are simplistic and show little understanding of the causes and prevalence of asthma.

Like the Mayor, this writer has suffered from asthma, so I have a personal interest in this issue. Note also that the ABD does not oppose cleaning up London’s air because one does not need a scientist to tell you that air quality in central London, and in some outer London “hot spots”, is appalling bad and not just makes walking or cycling unpleasant but probably exacerbates some medical conditions (including pre-existing asthma of course). The ABD’s opposition to the Mayor’s Transport Strategy is based on other factors and the irrational, ineffective and uneconomic approach to the environmental issues.

Let’s cover some of the basics about asthma:

  • Does air pollution cause asthma (in children or others)? As far back as 1995, a Committee on the Medical Effects of Air Pollutants (COMEAP) looked at this issue and came to the conclusion that although air pollution may provoke asthma attacks or aggravate existing chronic disease, the effect is generally small with other factors such as viruses, cigarette smoke, diet and house dust-mite droppings more important. They also noted that there had been a general increase in asthma in the last 30 years so it was now a very common disease. Was this down to more urbanisation and are city dwellers more likely to suffer from it because of air pollution? The answer is no. Indeed, a study in the Isle of Skye, where air pollution was believed to be minimal, showed as high a prevalence of asthma as anywhere else. See this report in The Independent for more information: http://www.independent.co.uk/news/air-pollution-is-not-the-cause-of-asthma-epidemic-1578437.html . Very heavy air pollution may reduce lung function in children according to more recent studies, but it is not the cause of the asthma epidemic in the last 50 years.
  • Why are allergies, that drive asthma, more common? There have been many possible causes put forward for this. It seems to relate to the exposure of very young children, or their mothers, that condition the immune system to over-react. For example, it has been argued that excessively clean houses are one cause. Smoking by mothers, or in houses, may have been another cause. Or a general increase in pollutants in the home. As we reported in the ABD London newsletter in June 2017, the concentration of some air pollutants can be five times higher indoors than outdoors. This is due to gas stoves, food cooking, dog/cat hairs, dead skin, lint particles from tumble dryers, deodorant spays, scented candles and air fresheners. The desire to minimise heat loss from homes, and reduce drafts (and hence fresh air) along with smaller homes might have contributed to these problems. Obesity is also a factor in asthma risk and we all know that has been rising. 
  • Are diesel vehicles a cause of worse air pollution and asthma? Diesel vehicles became popular for cars, and always have been for HGVs and buses, because of reduced fuel consumption and a desire to minimise carbon emissions. However that did not take account of the large emissions of NOX and particulates from such vehicles. But removing all diesel vehicles would not likely have much impact on overall air pollution levels in London. The reason is that much of the air pollution is from other sources such as home/office heating, industrial activities, or simply blown in from the countryside around. Even with vehicles, much of the particulates come from tyre and brake wear so converting all vehicles to electric ones will only reduce the emissions, not eliminate them. And removing private cars will have minimal impact when taxis, PHVs, LGVs, and HGVs continue to increase in number and are much bigger sources, as are trains, planes, river traffic and other transport modes. To reduce air pollution needs a much more “holistic” approach rather than focussing on one or two perceived evils alone. It seems very unlikely that attacks on diesel vehicles will have much impact on the causes or prevalence of asthma in any sensible timescale and the latest diesel vehicles are now very clean.

The above is a simplification of a very complex topic, but I hope it explains some of the key points. Does Mayor Sadiq Khan believe he is doing good by his aggressive environmental policies that will get us all walking and cycling (other than the disabled presumably)? Is he simply ignorant of the real issues? Or is he promoting these policies for other reasons, such as the financial problems of Transport for London, his desire to raise more funds and his desire to be seen as “doing good” to help his re-election?

Lastly, it’s worth mentioning that although asthma has become a lot more prevalent, the medical treatments for the disease are now quite effective in other than the worse cases. Certainly, much better than when I was a child. The high prevalence of asthma in the UK has been given as one reason why the UK became a centre for the medical research into treatments. But it seems to be a worldwide phenomenon that asthma levels have increased.

My conclusion is that cleaning up London’s air might make it a more pleasant place to live and work, but it won’t have much impact on the prevalence of asthma.

Incidentally a great article on the scare-mongering associated with air pollution is present here: https://notalotofpeopleknowthat.wordpress.com/2017/08/15/claims-of-40000-deaths-from-air-pollution-debunked-by-death-statistics/

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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Mayor Pushes Ahead With ULEZ

London Mayor Sadiq Khan has announced today that he is definitely going ahead with the introduction of the Ultra Low Emission Zone (ULEZ) in central London from 2019, i.e. he is bringing forward the original planned date based on the results of his last consultation.

This will cover any vehicle that enters the existing Congestion Charge zone and will operate seven days per week, 24 hours a day, unlike the Congestion Charge (a.k.a. tax). The additional charge will be £12.50 for cars, vans and motorbikes that do not meet defined emission standards, or £100 per day for lorries, buses and coaches.

Diesel cars that do not meet the Euro 6 standard, which means most of them that will be more than 4 years old in 2019, will need to pay the additional charge – making it cost as much as £22.50 to drive into central London. Petrol cars will only have to meet the Euro 4 standard so even older such vehicles may be OK. Go to this web page to check your vehicle: https://tfl.gov.uk/modes/driving/ultra-low-emission-zone/check-your-vehicle?intcmp=32646

The ULEZ will replace the “T-Charge” on older vehicles which came into force in October this year.

The Mayor is also introducing a “particulate matter standard” to the ULEZ standards bearing in mind recent concerns about that kind of air pollution. It is not clear how that will work as it suggests that vehicles that comply with the Euro standards might fail on other grounds.

Bearing in mind that the ULEZ may be extended across a wider area (for example to the North/South circular), it seems likely that not many London residents will be buying diesel cars in future as emissions standards tighten, and more will buy electric vehicles.

The consultation responses (over 18,000 in total) showed 72% of the general public support the principle of a ULEZ, with only 21% opposed. But for those who drive within central London, 65% were opposed. Some 52% of drivers were also opposed to bringing forward the ULEZ to 2019. The ABD was one of only three stakeholder groups who opposed the ULEZ.

The Mayor also makes a pitch for a national vehicle scrappage scheme, a new Clean Air Act, changes to VED, and more money for City Hall in his press release.

Will the announced measures reduce air pollution? Probably although these are improving anyway as older vehicles are scrapped and replaced. But the main culprits as regards pollution were and are HGVs, LGVs, buses and taxis. Imposing such draconian standards on cars and even motorbikes 24×7 is not a cost-effective solution. The fact that the Mayor and Transport for London (TfL) have failed to provide any cost/benefit justification, nor even any of the budget costs of the scheme in response to an FOI Act request just tells you one thing. This scheme is as much about making money for the Major’s coffers as improving air pollution. This was also reflected in the consultation comments “written in” where 5% of respondents suggested it was a tax/revenue raising scheme for TfL.

But there were very few comments in support of extending the ULEZ boundary. Only 1% supported extending it to the North/South Circular. Let us hope that kills off that idea which would impose a major financial burden on many more London residents.

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Air Pollution from Small Particulates

The Mayor of London, Sadiq Khan, has released new research giving the emissions of toxic particles known as PM2.5. He claims most Londoners are exposed to levels that exceed WHO guidelines. Here’s a summary of the report:

The research, based on the latest updated London Atmospheric Emissions Inventory, shows that 7.9 million Londoners – nearly 95 per cent of the capital’s population – live in areas of London that exceed the guidelines by 50 per cent or more.

PM2.5 are small toxic air particles which are alleged to have the greatest impact on health with both short and long-term exposure increasing the likelihood of respiratory and cardiovascular diseases. Children are particularly affected and may develop reduced lung function and asthma.

Around half of PM2.5 emissions in London are from external sources outside the city, however, the main sources of PM2.5 emissions in London are from tyre and brake wear, construction and wood burning.

The Mayor is clear that he wants to reduce emissions from wood burning through improved education about the types of fuel that should be used and when they should be used. He also wants a stricter set of emission standards on future sales of wood burning stoves to tackle this problem.

Comment: Why anyone should be permitted to use a wood-burning stove in central London when most people think such usage was banned under the Clean Air Act rather surprises me. But a lot of the particulate emissions are from construction in London, or are blown in from outside – and much of those are from agriculture, or even pollution from other countries. It is not at all clear how the Mayor is going to tackle these, but dust from tyre and brake wear is more easily controlled. Whether this would have a significant impact overall, or are cost effective measures, is not obvious though. Unfortunately this looks like political posturing by the Mr Khan, using children as his cheer leaders in this campaign.

Regrettably such pollution is mainly a symptom of over population, which Mr Khan and his predecessors seem not to want to do anything about.

Roger Lawson

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Opposition to Mayor’s Air Pollution Plans

I have covered some of the dubious aspects of the Mayor’s approach to tackling air pollution in London before. The T-Charge and ULEZ plans will be very expensive for Londoners, may have little effect and will target private car users unnecessarily when they are very minor contributors to emissions.

Campaign group FairFuelUK have launched a fund-raising to finance a judicial review of the T-Charge. The Toxicity Charge is a £10 penalty to be paid from October by older vehicles that do not meet newer emission standards if they are driven into the central Congestion Charging area. In summary they argue that even TfL concede it will have little impact on air pollution so it’s another of those “political gestures” that will impose major costs on some of the poorer road users. Go here for more information and to help fund the case: https://www.crowdjustice.com/case/stop-toxic-taxes/

Their arguments are backed up by a recently published report from the GLA Conservatives under the title “Clearing The Air”. This is a comprehensive analysis of London’s air pollution problems, and Mayor Sadiq Khan’s proposals. It also makes some alternative suggestions which would lessen the financial impact of the plans.

They also argue that the T-Charge should be scrapped and plans to bring forward the ULEZ by a year and then extending it across most of London should be abandoned. They point out that just implementing the latter could cost as much as £810 million, i.e. £220 for every household in London.

Make sure you read their full report if you want to get a good understanding of the issues around transport and air pollution in London. See: http://glaconservatives.co.uk/wp-content/uploads/2017/08/ClearingTheAir.pdf

Roger Lawson

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How Many Deaths from Air Pollution in London?

How many deaths from air pollution in London each year? You might think that is a simple question to answer because you have seen the headlines in the media – it’s 9,416 according to a report published by Kings College which is of course a nice exact figure. The press have abbreviated it to “nearly 9,500”.

The first problem though is that 9,416 is “premature deaths”, i.e. their lives were shortened to a greater or lesser extent. There were no actual deaths directly attributed to air pollution, i.e. present on the death certificate. Even the 9,416 is not a correct figure because there are a range of “shortenings”, which may stretch from hours to years. The estimated distribution of shortenings has been converted to a single figure of deaths so that the ignorant readers of the popular press, or those reading internet blogs, might understand it.

Yes this is an exceedingly complex topic which I won’t even attempt to explain in full in this brief article. But the latest news is that even the estimates used to calculate this number are dubious to say the least. New advice from the “Committee on the Medical Effects of Air Pollution” (COMEAP) set up by DEFRA is that the uncertainty about the evidence is growing. Although there appears to be a statistical association between air pollution factors and mortality, in the case of NO2 COMEAP have now said: “The Committee has not been able to come to a consensus view on how the epidemiological associations between NO2 and mortality can be used to either predict the benefits of interventions to improve air quality or to estimate the current mortality burden imposed on the UK population by air pollution. Some members are doubtful that the evidence is sufficient to allow a robust recommendation for quantification to be made. This is particularly the case for effects likely to be caused by NO2 itself.”

Regardless of that opinion, they still came down in support of giving specific recommendations on the likely impact of air pollutants on mortality.

Now this writer is not going to argue that cleaning up London’s air is not necessary, and it’s already happening of course. The key question, is by how much and what should be spent on doing it. What is the cost/benefit ratio of extending the ULEZ is one key point that needs to be answered.

If nobody has an accurate figure of the current disbenefits, how can we know what the benefits of cutting pollution are likely to be? Also TfL have been remarkably evasive in answering some simple questions about the costs of implementation of their proposals. They have refused to provide the data in response to an FOI request. Why are there no budgets that they are willing to disclose so we can attempt to work out the answers for ourselves.

One has to suspect that the case for really tough measures, such as effectively removing all diesel cars from London’s streets, is not as strong as it should be. When the costs imposed on car users can run into very substantial figures, we should be told the truth.

Making up policy based on guesstimates is not good enough.

Roger Lawson

The Social Costs of Air Pollution

A very good paper on the costs of air pollution in the UK, and the costs likely to be imposed on the public by the proposed measures nationwide, particularly in London, has been produced by Neil Lock. It is entitled “The Social Costs of Air Pollution from Cars in the UK” and is available here: http://www.freedomfordrivers.org/Social-Cost-Cars.pdf

Mr Lock in his Conclusion to the note says the following: “If my figures are right, then on the specific issue of air pollution from cars in the UK, there may be a case for charging drivers of Euro 3 and perhaps Euro 4 diesel cars to enter certain very limited areas like central London. There is no social cost case for any such charges for Euro 5 or 6 diesels, or for any petrol cars. There is a case for charging drivers of diesels, and of petrol cars which do not meet the latest standard, an amount equivalent to the social cost of the pollution they cause (excluding the part of the pollution from diesels which is the manufacturer’s fault). There is no case for charging any more than this.”

He also says: “It is high time, I think, for the good people of the UK and of the world to wake up. To see the deep green agenda for what it is. To reject it and its proponents. And to seek to set up in its place just measures based on good science, honesty and common sense.”

The paper is well worth reading, particularly by those who live in London and who will be affected by Sadiq Khan’s plans. More technical data is available to support his case if you need it. Mr Lock can be contacted at e-mail: neillock@aol.com.  Mr Lock is a software consultant, with a degree in mathematics. He lives in Surrey and drives a diesel car, which he says he would not have bought if he could have found a petrol one of the model he wanted at the time.

Roger Lawson