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 meets 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 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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Should a Value Be Placed on a Life, re Croydon 20MPH?

The scheme to implement a wide area, signed-only 20 Mph speed limit in the London Borough of Croydon has been covered in past articles (see the ABD’s campaign page here: http://www.freedomfordrivers.org/croydon20.htm ). The scheme will cost over £1 million and there have been lots of objections from local residents and the ABD. But Councillors have pushed it through regardless.

It is now the subject of a Judicial Review over the defective consultation process. In addition, I made a complaint to Croydon Council about that in June, and after an initial brush off have had a final response from Jo Negrini, their CEO. She ignored my arguments about the lack of proper cost/benefit justification and lack of provision of the likely benefits in the consultation documents. She simply argued that a value cannot be placed on a life.

This is an extract from my response: “you say (on page 3) that “the report emphasises several times that a value cannot be placed on a life and therefore the benefit of preventing, even a single fatality, cannot be said not to represent value for money to the public”. You use that statement to justify the fact that no proper cost/benefit analysis was done, or the benefit of the scheme put to councillors before they made a decision to proceed.

Such a statement just shows how ignorant you are on road safety matters and the decision-making process used on public schemes (or perhaps you are not so ignorant and are just using this as a poor excuse). A value is placed on a life everyday when evaluating public expenditure. That is for the simple reason that when comparing projects, or looking at where limited cash resources are spent (and as Theresa May recently said: “there is no magic money tree”), it is rational to choose the most cost-effective projects in which to invest. By so doing, the most lives are saved.

The problem with the Croydon 20 wide area scheme is that an enormous amount of money has been spent, that could have been better spent on other road safety projects. And hence saved more lives!

Valuing lives may be seen as somewhat hard-nosed for those who do not have any scientific background, or have not been schooled in how to make rational decisions, but it is how road safety schemes normally are, and should be evaluated.”

This unfortunately is a very good example of the poor quality of local authority decision making in not just London but the UK as a whole. Uneducated and ill-informed councillors make policy decisions that their executive staff are expected to justify and implement. But good council officers should tell the truth and stand up for what is right.

Simillarly the Mayor of London has caught this bug. So he went ahead with the London “T-Charge” this week despite being advised that it would not show any significant benefit in terms of reduced air pollution. It has just imposed enormous costs on one of the poorest sections of the community (those who drive very old cars), but the Mayor thinks it makes for good headlines. Just line up some young schoolchildren for a photo-shoot (a very dubioius practice) and explain this is one step to fixing air pollution problems in London. It makes for great publicity, and helps the Mayor to raise more in taxes under the guise of public health! Great politics if you can fool the public for long enough.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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

Twitter: https://twitter.com/Drivers_London

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Judicial Reviews invoked by Motoring Groups

T-Charge. The Sun has reported that FairFuelUK are planning to challenge the Mayor of London’s introduction of the “Toxicity Tax” (“T-Charge”) via a judicial review in the High Court. This is a tax of £10 on certain older vehicles that do not meet newer emission standards that is being imposed from October if they are driven into the central congestion charge area.

The challenge will be on the basis that it is unfair discrimination against a small minority of road users when other vehicles (e.g. TfL buses) and other sources (e.g. construction machinery and diggers) generate more pollution. In other words, it is an unreasonable attack on car users.

FairFuelUK may be looking for financial support to enable them to fight this case (judicial reviews are expensive), so anyone interested in this matter should keep an eye open for further news.

Croydon 20MPH. Another judicial review where the case has already been filed in court is that over the public consultation in Croydon on implementation of the blanket 20 MPH speed limit. The ABD supported an active local campaign against the proposals (see http://www.freedomfordrivers.org/Croydon20.htm ) and we have also complained to the Council about the defective consultation process. The process was changed from one area to another, apparently with the objective of obtaining the desired result, the information provided to residents was biased, the results ignored, and objections not considered properly. There are established legal principles about how public consultation should be run to ensure they are fair and unbiased, which is no doubt the basis of the challenge.

Both cases are in essence about illogical and unreasonable attacks on car and van drivers in the name of environmental improvement when there will allegedly be negligible advantage but significant costs imposed on drivers.

Roger Lawson

 

Mayor’s Latest Announcements on ULEZ

On the 4th April the Mayor of London, Sadiq Khan, made his latest announcements on how he intends to reduce air pollution from road vehicles in London. Not a mention of how he intends to reduce the 50% of air pollution caused by things other than road transport which is still growing as the population of London increases, but let us say no more about that for the present.

Mr Khan has revised his previous proposals somewhat, presumably based on the last public survey which did show overall support for his proposals with some reservations. But he is now definitely committed to:

– The introduction of a “T-Charge” of £10 for older vehicles (pre-2006) commencing in October this year. This will only apply within the existing Congestion Tax area of central London.

– The introduction of an Ultra Low Emission Zone (ULEZ) for all vehicles from April 2019, which will again only apply to the central London zone and replace the “T-Charge” mentioned above. The ULEZ daily fee to drive in the zone will apply 24 hours a day, 365 days a year and apply to all vehicles that do not meet the following standards:

a) Petrol Euro 4/ IV

b) Diesel Euro 6/ VI

c) Powered Two Wheelers Euro 3

These standards mean that petrol cars more than around 13 years old in 2019, and diesel cars over 4 years old in 2019 will have to pay a charge which will be £12.50 for cars, vans and motorbikes, and £100 for heavy vehicles such as HGVs and coaches.

They will be in addition to the Congestion Charge where applicable. The ULEZ will apply to all vehicle types, except black taxis, which are already being made cleaner through licensing restrictions. From next year all new licenced taxis must be zero-emissions capable.

Unlike the Congestion Charge, which only applies for limited hours on weekdays, these charges will apply all the time. So trips into central London for the evening will cost you £12.50.

There is again a public consultation on the above which everyone who drives in London should respond to and it is present here: http://www.tfl.gov.uk/airquality-consultation . PLEASE MAKE SURE YOU RESPOND AS SOON AS POSSIBLE. 

In addition to the above the Mayor is considering expanding the ULEZ to nearly all of Greater London in respect of heavy diesel vehicles such as buses, coaches and lorries to be implemented in 2020. Also he proposes to consult on extending the ULEZ to all other vehicles including cars within the North/South Circular, to be implemented in 2021. So you could be paying £12.50 just to drive within that ring road, although a lot of the previous respondents to the last consultation suggested a lower charge.

Mr Khan is calling on the Government to deliver a nationwide diesel vehicle scrappage scheme but there is no sign yet that the Government is listening. There is some concession to residents who live within the ULEZ and for disabled vehicle users who will have a “sunset” period until 2023.

Comment: some information required to make any intelligent comments on these proposals is not apparently available. For example what is the likely impact of these proposals on the level of air pollution within the zone or outside it? What is the cost/benefit justification? What is the cost of implementing this scheme and how much revenue and profit will TfL obtain from it as a result?

These questions are very important because the Mayor has a very strong financial interest in these proposals as the additional charges will no doubt raise much needed revenue for the Mayor and TfL whose budgets are currently under pressure.

It is most regrettable that this is yet another example of asking the public’s views on a matter without giving them the full facts to enable them to make a reasoned judgement on the proposals.

I have asked TfL to provide this information and will let you know if I receive it.

But having walked the streets of the City of London last week I certainly think something needs to be done about air pollution because my lungs were definitely affected and I have not suffered from asthma for many years. The problem was that all the roads such as Cannon Street, Eastcheap, Bishopsgate and around Aldgate were just gridlocked in the middle of the day with stationary traffic which consisted mainly of buses, LGVs, taxis and private hire vehicles. This happens quite regularly now because of the impact of the Cycle Superhighways, road closures, removal of gyratories and other measures promoted by the previous Mayor and local authorities over the last few years.

Vehicles may have been getting cleaner, only somewhat confounded by the Government’s misconceived promotion of diesel vehicles so as to save CO2 emissions. But if transport planners create gridlock then the inevitable will happen – air pollution will continue to get worse until only zero emission and expensive electric vehicles are allowed. We also need to tackle other sources of air pollution and the best way to do that is to stop the growth in the London population or even reduce it.

Postscript: on 9/4/2017:  This interview with Professor Tony Frew, a respiratory expert on TalkRadio is definitely worth listening to if you want the facts about air pollution and its sources: http://talkradio.co.uk/news/sadiq-khans-40000-pollution-deaths-year-zombie-statistic-and-isnt-true-says-respiratory

Julia Hartley-Brewer whom conducted that interview also attacked the promotion of the 40,000 deaths per year in the UK from air pollution in an article in the Daily Telegraph on the 7th April. She said “This 40,000 figure is alarmingly high. It is also alarmingly wrong”.

And as of today I am still awaiting a response from TfL on the data requested giving the data on the impact of the ULEZ on air pollution. Not even an acknowledgement of my request so far so I have submitted a Freedom of Information Act request.

Roger Lawson

Air Pollution and the ULEZ

The EU Commission has given the UK a final warning over air pollution in the country. That particularly covers London but also 15 other cities. Similar warnings have been given to Germany, France, Italy and Spain. There are persistent breaches of NO2 limits and the European Commission may decide to take legal action if they fail to act within two months. If not the UK could be taken to the Court of Justice of the EU, although that is one Court that will be affected by the UK departing from the EU. The UK Government is to publish a revised plan to deal with the problem in April.

Meanwhile London Mayor Sadiq Khan is not waiting for that. He has published the results of the public consultation on a new Emissions Surcharge and extensions to the Ultra Low Emission Zone (ULEZ). The proposals were covered in our last newsletter (Dec 2016) and would impose major extra costs on road users of many kinds in London. The consultation was done without any data on the likely benefits in terms of reduced pollution, and without any cost benefit analysis. TfL neatly summarised our response to the consultation in this paragraph:

“The Alliance of British Drivers (ABD) is opposed to the implementation of the ULEZ. The ABD believes the consultation is fraudulent and that the ES/ULEZ may be a money making scheme for TfL.”.  

Well they at least got that right, but of course with such biased information being provided, one might expect that the result would be as the Mayor desired. Here’s a brief summary of the results (go here for the full data: https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-2/?cid=airquality-consultation ).

  1. From 23 Oct 2017 some older vehicles will be required to pay a surcharge of £10 to enter the Congestion Charge (a.k.a. Tax) zone. This is called the Emission Surcharge (ES or “T”-charge). They have provided a web site to enable you to check your vehicle for compliance with this and the ULEZ. This is now definitely proceeding as it was a statutory consultation. 63% of respondents supported it, with 30% opposing. Most also supported the proposed start date.
  2. Other consultation questions were non-statutory and there will be another consultation on these soon. One question was on the proposal for an earlier implementation of the ULEZ to 2019. This received 63% support versus 29% opposed.
  3. A third question was on expansion of the ULEZ to within the North and South Circular. This received support from 59% of respondents versus 34% opposed. There was similar support for bringing that in during 2019.

Lastly the latest document from TfL repeats the very dubious claim that “The equivalent of around 9,400 deaths per year in London are attributed to air quality related illnesses”. This is simply wrong and exaggerates the scientific research that has been reported. It confounds possible contributory factors with actual “causes” of death. There is probably some impact on life expectancy from living and working in higher air pollution in London, but the impact is not nearly as clear cut as that and may simply mean some shortening of life in heavily polluted areas.

Note: there are about 48,000 deaths per year from all causes in London. Not a single one has air pollution assigned as a cause of death.

For example this is contained in a report from Clean Air in London: “The Department of Health estimates Bromley (6.1%) has the lowest death rate in London attributable to air pollution and Westminster (8.3%) has the highest” but that is based simply on categorising illnesses and causes of death as being affected to a lesser or greater extent by air pollution. So lung cancer is included even though the vast majority of deaths from it are undoubtedly caused by smoking. There could of course be other reasons from the differences between Bromley and Westminster related to life styles and the demographics of the two populations.

Even if all cars were banned from London, there would still be very considerable air pollution from buses, taxis, HGVs, domestic heating, commercial activities, rail transport, etc, as you can see from the chart below.

air-pollution-sources-london

The message though from these facts is that cleaning up the rest of London’s air to be as good as Bromley’s could only reduce the health impact of air pollution to a limited extent at best and the other demographic factors might mean there is no improvement in mortality . The cost of doing so may be outweighed by the other benefits on which money could be spent to improve the health of the community. For example on the NHS which is clearly desperately short of money as the national media keep telling us of late.

Roger Lawson