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

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.


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

Second Consultation on ULEZ – Make Sure You Respond

The Mayor of London has announced the second stage of consultation on the Ultra Low Emission Zone (ULEZ). If you are a resident or drive a vehicle in London, this consultation will affect you so it is important that you respond to it.

For example, anyone who drives a diesel car registered before 2014 may face a charge of £12.50 to drive within the North/South Circular from 2019 – or even earlier! That’s in addition to the Congestion Charge (a.k.a. Tax) so you will be paying over £20 to drive into central London. In addition older vehicles (pre-2006) will be paying an additional £10 as an “Emissions Surcharge” (or T-charge) almost immediately and many commercial vehicles will face very substantial additional charges.

Is this simply a money making scheme to fund Transport for London? Or a genuine attempt to tackle air pollution problems? You can try to answer that question by studying the supporting documents, but you won’t find any cost/benefit analysis. In addition it actually says “Predicted air quality concentrations and analysis of change in population exposure to air pollution will be provided during the statutory consultation in 2017 if the Mayor decides to take this forward”.

It would seem to be a case of consult first, then provide the data to justify the scheme later. That’s in the hope that polemics about the impact on health from transport pollution will swing the views of the public to come to a conclusion before they know the facts.

The Mayor has already done one consultation on the proposals, and there was general support indicated there but here’s one quote they give in the report on that consultation: “These latest proposals are attempts to foist unfair stealth taxation upon the vast majority, thus making the rich/poor divide worse”. Bearing in mind that there is no evidence given on the real impact, when pollution is coming down as the vehicle fleet modernises anyway so at best there will be only a short term benefit, it certainly looks more like a tax raising scheme to this writer.

The latest proposals include extending the ULEZ London-wide for HGVs and buses, possibly as early as 2019, and extending the ULEZ area to within the North/South Circular and bringing it forward to 2019.

So make sure you respond to this consultation which you can do at the bottom of this web page which summarises the proposals: https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-2/?cid=airquality-consultation#Have your say

Roger Lawson

Ultra Low Emission Zone (ULEZ) to be Toughened

As new London Mayor Sadiq Khan promised in his manifesto, he plans to tackle vigorously the problem of air pollution in London, a lot of which comes from motor vehicles. To that purpose he yesterday announced proposals, and associated public consultations, on strengthening and bringing forward the planned Ultra Low Emission Zone (ULEZ).

As proposed by previous Mayor Boris Johnson, the ULEZ would impose a charge on all vehicles that were not compliant with certain standards from 2020 within the existing Congestion Charge area of central London. The charge for cars was to be £12.50. Zero or very low emission vehicles were exempt and most modern cars, but not older ones and particularly not diesel vehicles. They needed to be Euro 4 compliant for petrol vehicles or Euro 6 for diesel cars – which meant only diesels manufactured after 2015 would likely be free of charge. Similar tough rules applied to large vans and HGVs with a £100 charge for the latter.

The objective, as with the new proposals, was to substantially reduce NO2 and particulate emissions which are the main health hazards and where London has been consistently breaching EU legal standards on certain roads (but as also happens in many other major cities). Although air pollution from vehicles has been falling, and will continue to fall as the vehicle fleet is replaced by newer models, the timescale is quite extended for major impacts and the increasing use of diesel cars has not helped. Diesel vehicles were mistakenly promoted by the Government because of their alleged lower emissions of CO2, but are much worse for other pollutants – and that’s assuming even that their pollution controls were working properly and the figures were not being fiddled by VW et al, which we now know to be untrue.

In summary the latest proposals are:

– To bring the implementation of the central London Ultra Low Emission Zone (ULEZ) forward by one year to 2019

– To expand the ULEZ beyond central London in 2020 (to within the North/South Circular).

– Introducing a new Emissions Surcharge from 2017 for the most polluting vehicles entering central London (congestion charge zone) – in essence those older vehicles such as cars, buses and HGVs made before January 2006, or a year later for vans. This charge will be £10 (Toxicity Charge).

– Giving TfL the go-ahead to start looking at a diesel scrappage scheme as part of a wider national scheme run by the government.

– Making sure TfL leads by example by cleaning up its bus fleet and buying only hybrid or zero emission double-decker buses from 2018.

Note that as many as 9,000 vehicles that do not qualify for exemption and hence will incur the £10 Toxicity Charge currently enter central London. There will obviously be a strong incentive for the owners to replace their vehicles with newer ones, or not drive in at all.

You can find out more information, and respond to the public consultation, by going to this web page: www.london.gov.uk/cleanair

Here’s some comments from this writer:

Ensuring older vehicles are replaced, or removed from central London by 2017 is wise as they are a major source of pollution. However this will bring hardship to many, particularly van owners. Clearly those who own such vehicles are often the less wealthy or run small businesses so putting in place a “diesel scrappage” scheme would be helpful. But will the Government go along with this and provide the necessary funding? That is a big question.

Expanding the ULEZ to within the North/South Circular in 2020 will affect many more people and will be particularly difficult for current diesel vehicle owners as it will affect relatively modern vehicles at that time. Again a diesel scrappage scheme would help enormously. Note though that the previous plan to solely have the ULEZ cover the congestion charge zone made little sense as the air blows in from around and hence it was not likely to have much impact. But it was a lot cheaper because the existing congestion charge cameras could be used. Presumably a whole new technology infrastructure will be needed for the wider area. What are the costs of this likely to be? We do not know.

One particular negative effect will be on the environment on the North/South Circulars which are already heavily congested and hence have poor local air quality in some locations. This might be made worse if the boundary is just within those roads.

Note that the initial public consultation also covers such matters as giving the Mayor control over Vehicle Excise Duty (VED) receipts, the pedestrianisation of Oxford Street and your local town centre, the closure of roads (for car-free days, play streets, etc), the funding of a boiler scrappage scheme, etc, so there is lots to comment on. So please make sure you respond to this consultation.

But unfortunately there is no cost information provided for these proposals, or cost/benefit analysis, as is usual with recent consultations from TfL so any responses may be ill informed.

One last comment: the survey system asks you for lots of personal information which is highly inappropriate. I suggest you avoid answering those as best you can. But if they see any responses from 116 year olds living in Bromley with no specific gender bias then you will know who it is. For security reasons I simply do not give out such data as any simpleton now knows.

Roger Lawson