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

Twitter: https://twitter.com/Drivers_London

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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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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

 

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

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