ULEZ: Why The (Slightly) Lower Emission Zone Matters

00:01 hours on Monday 8th April 2019 saw the introduction of the so-called Ultra Low Emission Zone (ULEZ). We look at the past, present and future of low emission zones in London, what is trying to be achieved and why, for now, the ULEZ is a bit of hyperbole, but important nonetheless.

It is not just a transport issue

One of the pre-conceptions often exacerbated by the way harmful emissions are covered in the news is that they are fundamentally a transport issue. This isn’t the full picture.

There are other causes of unwanted emissions, be that NO₂, CO₂ or particulates. Two that have been highlighted recently have been gas for home use (whether cooking or heating) and also wood-burning stoves. Both are a lot worse than might be envisaged. One of the problems of gas is unburnt methane from gas leaks (much worse than CO₂) which contributes to climate change and is a consequence of having a gas supply – whether used or not. This may be why the government is looking to not merely reduce gas usage but ban new gas installations.

There are also a lot of emissions from generating electricity and it is a valid point that, if you look at the issue nationally or globally, electric trains, trams and electric cars are only as clean as the power used to create the electricity.

It would also be valid to mention that, if just concerned with the level of background particulates and other noxious emissions, a far cheaper and more producing ‘quick win’ would be to ban older gas boilers and incentivise people to change over to a newer one.

There are, however, genuine reasons for the Mayor to concentrate on transport to reduce emissions, not least because it is one of the areas that the Mayor can genuinely affect. So whilst it is important to recognise that transport is only part of the problem, that the other areas are still to be addressed is not a valid reason for not taking action here.

Electric vehicles won’t solve the problem

Another issue in the complex world of reducing emissions is that the particularly harmful emissions, the particulates, are also given off by rubber tyres and brakes. So, whilst electric vehicles replacing fossil fuel vehicles on the roads will help, they do not represent a simple solution. Even trams and electric trains produce some harmful emissions, as friction brakes kick in to bring the vehicle to a complete stop.

Protagonists of electric road vehicles will argue that electric vehicles are far better in respect of brakes and tyre use than their internal combustion engine equivalent. This is because they use regenerative braking. It is not, however, as simple as that. Due to the limitations of the current technology, the electric equivalent vehicle is also heaver than its combustion counterpart, which leads to more tyre pollution. Scientists cannot yet agree whether one outweighs the other or not.

One problem with planning for the future is that technological developments are continuing apace and it is hard to predict what benefits could be capitalised on. It is believed, for example, that tyre and brake manufacturers are working hard to reformulate their products whilst, at the same time, not wishing to highlight their work. After all, doing so would be a tacit admission of the damage caused by current products.

The real game changer could be the electric battery. If it were significantly cheaper, more energy-dense or even charged faster then this could change the dynamics of the argument. Despite this, other problems such as deaths on the road or congestion could still remain. The Uber experience has shown that going from a society based on car ownership to on-demand travel will not solve all problems.

Managing expectations

Another valid point, not made often enough, is that, when looking at background emission levels, road vehicles in London don’t actually contribute that much to the level found in London. A small portion of air-borne pollution originates from Continental Europe when the air blows from that direction. Air particles are no respecter of national – or borough – borders. A lot more comes from the M25.

Taken together, the above factors all highlight that one shouldn’t expect a dramatic improvement in the quality of London air any time soon.

So why does the Mayor obsess over transport emissions?

It is clear from his rhetoric that the Mayor wants to do something about emissions. Wanting to do something and doing something useful are two different things. So why does he bother? There are a number of very valid reasons.

Because he can. The Mayor has limited powers. Two areas where he has a lot of power are in formulating and implementing transport policy.

Because he can now. The Mayor would like to do a lot of things in relation to clean air. It is believed that he would also like to be able to restrict wood burning stoves, as damage caused is out of all proportion to their benefits. This would, however, require powers which he does not currently have. When it comes to transport, the Mayor has a lot of levers that he can pull to change people’s behaviour. These can be financial or achieved by traffic restrictions.

Because the government won’t. Certain things are best done at government level. For example, there is not really much sense in the London Mayor having his own sets of technical emission standards for vehicles to conform to. Other things though, such as the practical implementation of measures to reduce emissions caused by traffic are, at least partially, best done at a more local level. More to the point, government policy is to not get involved at this level, but to enable metropolitan mayors and other local government decision-makers to produce their own solutions.

Because air pollution levels breach EU legal levels. Before anyone points out that what the EU decides doesn’t matter any more, one has to be aware that there is still the possibility we will be following EU rules for a while to come. In any case, it is entirely irrelevant as the government has indicated our pollution laws will be as high – or higher – than the EU ones.

To meet his EU obligations and avoid the potential of large fines, the Mayor has to show that he is doing everything possible to reduce current levels of emissions.

Because it is measurable. The difference between air quality levels before and after implementation of low emissions zone may be small, but it is detectable. As such, the ULEZ is expected to show not only that low emissions zones can work in the real world, but also which measures work best. The run-up to the implementation of the ULEZ has already produced measurable benefits beyond what could be otherwise expected, as companies either replaced their older non-compliant vehicles or re-assigned them elsewhere.

Because it is consistent with the Mayor’s Healthy Streets policy. Rather bravely, the Mayor has made much of a Healthy Streets policy. This is a nebulous concept that incorporates many things, including lower speed limits, cycle routes and a reduction of deaths on the road. Much of it is about making the environment more pleasant and less polluting vehicles would help that.

And finally, the clincher:

To target very local high levels of emissions. Whilst bringing emissions down throughout London is a big ask, a lot can be achieved by improving it in limited areas where the level is exceptionally high. These tend to be busy roads and, crucially, around schools.

There is a lot of evidence to show that pollution particularly affects the heath of children – even before they are born. A massive benefit to society could be achieved if the levels could be cut down in the vicinity of schools and the best, more effective way of doing this is to reduce the emissions from nearby road vehicles.

From the Mayor’s point of view, the schools argument also has a very convenient political advantage – it is very hard to argue against. Science backs up this argument which also appeals to the emotional aspect. Arguments about causing hardship for the poor, or a further problem businesses could do without, will cut little ice in the populist viewpoint.

A lot of politics is about winning the argument. If the argument can be won then a lot of other measures such as banning traffic around schools at the start and end of the school day (as already happens in some places) can also be implemented. You are also more likely to make other behaviour less socially acceptable – such as running the car engine whilst waiting for children to be picked up from school.

The first emissions zone

The first emissions zone in London had very little to do with transport. Various Clean Air Acts starting from the late 1950s led to local authorities introducing Smoke Free Zones. These limited the burning of coal and were often primarily aimed at domestic houses. Most London boroughs are entirely covered by a smoke free zone but, incredibly, there are still some areas that are not.

The clean(er) air revolution was considerably helped by the subsequent introduction of North Sea gas starting in the late 1960s. This led many households to switch over to gas. It also meant that polluting gas works could be closed. These changes made it easier for local councils to designate further smoke free zones within the boroughs.

Nowadays, gas is seen as part of the problem and this is one of many examples where a transitional technology has saved the day only for it to subsequently become the bad guy. Gas itself is now starting to appear on the environmental assassin’s list. It probably isn’t the first example of this – one can look back at the internal combustion engine being the saviour and ridding London of large quantities of horse manure on the streets.

The dual-purpose Congestion Charge

When Mayor Ken Livingstone introduced the Congestion Charge in 2003, it wasn’t entirely clear what its purpose was. Clearly, a major goal was to reduce congestion. Sir Peter Hendy, the former Transport Commissioner, has also commented that, in retrospect, a major benefit was to provide an extra income to enable the expansion of the bus services. Something which might not have otherwise happened.

The Congestion Charge did include exceptions. One was related to vehicles with low or no tailpipe (or ‘exhaust pipe’ in UK English) emission. Clearly such vehicles did not cause less congestion. Crucially, the Toyota Prius, an early ground-breaking hybrid car becoming popular at the time, qualified as did the small number of fully electric vehicles on the road. An important, much overlooked, statement was made at the time: As the years passed, the standard for qualifying for the ”clean’ exception would be tightened so it was higher than ‘standard’ polluting cars.

Another group excepted from the Congestion Charge was the private hire vehicle (PHV or mini-cab as often called). The logic behind this was less clear, but one factor could have been that mini-cabs tended not to need somewhere to park. As a result they could be seen as an efficient user of road space. Alternatively, by adding their drivers to the many categories of exceptions, the Mayor reduced the opposition to the scheme.

At the time, the number of PHVs in central London was quite low. As a result, the Congestion Charge was initially successful at reducing traffic levels, largely through the near elimination of private cars. What was not anticipated though was how much the PHV numbers would rise.

To a large degree, this has been the effect of Uber and other Uber-like rideshare apps. These not only increased demand for PHV journeys in central London, but have also incentivised those drivers to drive around in anticipation of their next fare rather than park up (which cost money) or leave the zone. The economics of this was much helped by PHV drivers favouring the Prius, which was inexpensive to run in slow moving traffic. Whilst good for mini-cab drivers and their passengers, the additional PHV presence had an unanticipated and unwelcome effect on traffic flow.

In fairness to mini-cab drivers, it should also be noted that black cab drivers have a bigger incentive than mini-cab drivers to behave the same way, as they can be hailed on the street. Driving around thus maximises their chances of a fare. Worse still, the places likely to produce the best chance of a pick-up tend to be popular places and these tend not to have free-flowing traffic.

The short-lived Chelsea Extension

In 2007 a western extension to the Congestion Charge was controversially introduced by Ken Livingstone. With a mayoral election due in 2008, it inevitably became an election issue though no mainstream candidate suggested abandoning the central London zone.

In 2008 Boris Johnson became Mayor. He claimed to support it but also said that he wanted local residents to decide. From the outset, however, he opposed Mayor Livingstone’s policy of a CO₂ based emission charge. Interestingly, at the time, the issue was CO₂ and other emissions were scarcely mentioned, which shows both how our knowledge and attitude to the subject has changed. Fairly predictably, local residents voted against the Congestion Charge in Chelsea. This is just one example (of which there are many) of local users of a particular service or road being able to decide policy that affects other people. There will always be controversy as to how much this should be allowed to happen.

The ‘Low’ Emission Zone

Separate to the Congestion Charge, Mayor Livingstone proposed a London-wide restricted zone that would charge a substantial fee for the worst emitting vehicles to drive within that zone. It was called the Low Emissions Zone, but that really was unfortunate and led to nomenclature problems later on. It was actually a ‘not-High Emissions Zone’, as all it really did was ban the most polluting vehicles. For the most part, these were the ones that were probably getting towards the time at which they ought to be replaced anyway.

Crucially, private cars were omitted from the restrictions. This was probably a good move politically and based on the desire not to alienate voters. Cars also tend not to be the largest polluters. However, many cars have a van equivalent with similar emissions and these were subject to the Low Emission Zone – so basically it was a case of once you are in business you are fair game.

The Low Emission Zone at the time of introduction was always intended as just the start, with standards gradually being raised. In 2009 Mayor Johnson announced plans to cancel Phase 3, due to be introduced in 2010, which would have tightened the rules for larger vehicles. The then-Mayor cited the pressures business were under in a recession, but the move attracted a lot of criticism, perhaps more than the Mayor was expecting. This may have been partly down to an increased understanding of just how damaging bad air is for Londoners.

Phase 3 was eventually introduced in 2012, which tightened up the rules for large lorries, buses and coaches. Cars were still exempt. Meanwhile, standards for new vehicles have got stricter. So one could well argue that by 2019 the restrictions (compared to what is ‘the norm’) have actually got more lax overall.

The T-Charge

The T-Charge (toxicity charge) was never part of any long term plan. It was proposed by the current Mayor, Sadiq Khan, and was introduced to do something about the worsening central London air quality and fill the gap prior to the Ultra-Low Emission Zone being introduced. Its implementation was a quick and dirty solution, built on the Congestion Charge mechanism.

The T-Charge was a less-than-perfect implementation, but did do something more than the Congestion Charge to encourage drivers to use cleaner vehicles. The charge was separate to the Congestion Charge, but in addition to it (if the vehicle was liable to the charge).

The biggest weakness of the T-Charge was that it only operates during the hours of the Congestion Charge, whereas clearly a pollution charge should not be limited by time of day or day of week. Blue badge holders were also exempt which seems slightly illogical. Whilst there is a lot of logic in exempting Blue badge holders from the Congestion Charge, there is no logical reason why they should be allowed to avoid paying the T-charge – especially as the requirements for cars are not that onerous. Furthermore, this must create problems because the a qualifying blue badge holder is a person whereas the T-charge applies to a vehicle.

One of the major apparent weaknesses of the T-charge has been that taxis are exempt even if the vehicles do not comply. This is because the approach to making taxis cleaner is done in a different way, helped in some part by the fact that they are regulated by TfL. There is more opportunity to tailor the requirements of taxis more closely to that desired in central London elsewhere.

In terms of raising standards and being more universal, the T-charge had the redeeming features that cars were included. A vehicle that didn’t meet the standards also incurred further costs if driven into central London during hours of operation from the all-London LEZ thus ‘qualifying’ for two charges.

The Ultra Low Emission Zone (Phase One)

The Ultra Low Emission Zone (phase 1) was introduced on the 8th April 2019.

Most changes are about eliminating inconsistencies brought about by the T-charge, but the other critical change is that compliance with the requirements (and so therefore not have to pay the charge) has become much more challenging. Diesel vehicles now have to be Euro6/Euro VI compliant which, for most diesel vehicles, means not be more than four years old. This is much stricter than before but hardly ‘ultra-low’. This stricter requirement will primarily affect businesses.

Many of the exceptions have now been removed as well. For example, it is not enough just to be a blue badge holder. Buses and coaches have to be compliant, even though they are exempted from the Congestion Charge. Finally, the Congestion Charge is almost becoming just that – a charge for being a cause of congestion. The main exception is a pure electric vehicle or vehicle capable travelling 20 miles on electric propulsion only. These vehicles do not pay the Congestion Charge and, of course, they qualify for exemption of payment for the ULEZ.

The anomaly of the hours of operation of the T-Charge is removed and the ULEZ applies 24 hours a day seven days a week. It would even appear to apply to a parked vehicle on the public highway, which logically ought to be subject to the Congestion Charge but not the ULEZ.

What might be considered the biggest change of all applies not to the ULEZ, but to the Congestion Charge. Private Hire Vehicles are no longer exempt, although wheelchair-adapted vehicles will get an exemption whilst being used to fulfil a disabled booking. It will be interesting to see what difference this makes to the popularity of PHVs in the Congestion Charge area.

Stricter LEZ from 2020

From 26th October 2020 the rules for the London-wide LEZ are changing for buses, coaches and lorries or “other specialist vehicle over 3.5 tonnes”. These vehicles will then have to comply with the same conditions as the ULEZ. From that date these vehicles will only have to pay one charge – not one for each zone.

Looking at this another way, effectively from 26th October 2020 the ULEZ as a separate zone disappears for larger vehicles. For these vehicles there is only a LEZ which covers most of London.

The Big One: ULEZ phase 2 in 2021

It could be argued that the ULEZ phase 1 is little more than the logical progression of more restrictive emission zones, updated to take into account the changing world. Where the Mayor has chosen to break new ground is to extend the ULEZ area all the way to the North and South Circular Road boundaries. This is roughly the outer limit of Zone 3 public transport fares, and, also crudely, a boundary between car-preferred local travel in outer London and bus, rail or green-modes-preferred travel in inner and central London.

This would be a massive change for owners of cars, vans, minibuses and motorbikes. Owners of other, larger vehicles will be unaffected as their changes take place in 2020. For owners of these smaller vehicles that do not comply, a large portion of London is now out of bounds or subject to a daily charge when the vehicle is being used or even parked on the road. This is likely to be the most controversial phase and already there is talk of exemptions for non-profit making organisations for a limited period, as well as ‘sunset’ exceptions or reduced rates for resident in order for them to be able to take time to be compliant.

Beyond ULEZ phase 2

With phase 2 over two years away and the impact of phase 1 of ULEZ not yet known, it is too early to look to what we could expect beyond phase 2. In no small part, this will depend on who London has as a Mayor, what is technically feasible and what supporting legislation the government brings in.

One obvious option is to get rid of the ULEZ and just have the LEZ, requiring ULEZ standards for all vehicles. A disadvantage of this is that it doesn’t disincentivise drivers from visiting central London. But, arguably, that is the job of the Congestion Charge and not of any emissions zone requirements.

A further fairly obvious option for the future is to tighten the rules in the Congestion Charge zone – so reinstate the idea of a central London ULEZ. Subject to what is technologically possible, this could mean that the only exempt vehicles would be those capable of 20 miles on an electric charge or alternatively only be allowed to use electrical propulsion within the ULEZ.

Facing the future

All this progress should lead to London seeming a lot cleaner in the next five to ten years. Of course, whether it is actually much cleaner is going to depend partly on a load of other factors, some of which will remain beyond the Mayor’s, or even the government’s, control.

Nonetheless, it is important to be wary of those who seek to criticise the Mayor – or London as a whole – for implementing the zone when there are larger sources of emissions elsewhere. Some of that criticism should likely be regarded as disingenuous. If not, then it at least fails to consider the basic need to be pragmatic.

One of the strengths that Frank Pick, and his various organisation heirs, have continually displayed in London is an awareness that sometimes you have to take the options that are on the table, not wait for the ideal ones that exist in your head. What applied to the Tube in the 20th Century could easily be said to apply to the subject of emissions now.

It’s certainly true that the overall impact – in raw numbers terms – of the ULEZ (Phase 1) may prove to be limited. But sometimes it’s not the size that matters, but what you do with it that counts.

In transport terms, London has a proud tradition of often being the first among the great cities of the world to tackle the biggest problems head on. Tackling emissions (and, more broadly, climate change) is something that can no longer be avoided and where the ‘Big Smoke’ leads, other cities will follow.

This city shrugged off that nickname once. It is time for it to start doing so again.

Thanks to Graham Feakins and Jonathan Roberts for corrections and improvements. Cover photo by David Holt.

201 comments

  1. Fantastic news for Londoners.

    I suspect it won’t be long before the “Congestion Charge” zone ends up like the Madrid central zone. At the moment, only zero emission vehicles are allowed to circulate for free (other vehicles need to pay/have an exemption), and by 2025 only zero emission vehicles will be allowed at all.

    This site outlines the various schemes across Europe very well – http://urbanaccessregulations.eu/

  2. One of the more interesting things to me is how well the North/South Circular ULEZ will be accepted by residents. Having been a resident of the Congestion Charging zone, it was always something at the back of my mind (especially prior to Auto Pay) whenever setting foot inside a car, hightailing it out of London with the rest of the family before 6:30am became a holiday staple, but all in all we found the Congestion Charge was more of a help than a hindrance. With a 24 hour ULEZ, things will be different, of course – no use frantically flooring the accelerator for the A406 at 6am – but I feel that it’ll eventually be received as a positive thing by most residents.

    (One thing that somewhat amuses me is that the North Circular being so much further out than the South – Clapham South vs South Woodford anyone? – will simply deepen the North/South London divide… but that’s a whole different discussion)

    If anyone is curious, CC/Phase 1 ULEZ residents have a 100% discount during phase one (the “sunset” period), which allows us a little longer to upgrade to a compliant vehicle/find some relatively safe street parking over 7 miles from home to stick a noncompliant car before Phase 2 ULEZ in 2021.

  3. I spent 18 months working on the LEZ around 2006/07.

    It’s fair to say that the project team knew it would have very limited impact; you’re attacking a relatively small number of highly polluting vehicles which are scattered all over London.

    It did however put a marker down for what was to come.

    Kings College found that the LEZ had no impact on air quality in the first three years of its operation. Not a great surprise.

  4. I believe TfL are storing up the trouble until 2021 (when’s the next Mayoral election?) as, aiui, residents in the current CC-ULEZ area get a dispensation and don’t pay, whereas the massive 2021 expansion will both remove their exemption and make a grab for a considerable portion of the GLA area, arguably unfairly covering a lot more of North London than South given the way the “circulars” are routed.

    The Guardian has an article today suggesting that around two-thirds of Londoners support the ULEZ plans, however I expect it to be somewhat like the ‘B’ word that it will only be as we get closer to the 2021 implementation date that people will truly understand what will happen. People have got used to the idea that in-zone residents get access free or at a substantial discount, plus that it should be trade vehicles and commuters driving in who should be stopped from doing so, not people who live here (pay rates, etc.etc)

    For myself, I live in the expansion area and, being retired on a fixed income, will not have the option to replace my diesel (which emissions tests at MOT say is actually rather good although it isn’t Euro6 compliant), indeed the possibility of LEZes expanding across the country mean the resale value has probably dropped substantially! Even though I don’t drive anywhere within the LEZ or ULEZ zones except directly out and home again the £12.50 (at start) charge will make coming home very expensive. Changing from 24-hour/7-day to, say, 22-hour/7-day with those hours during the night would make little difference to traffic levels but would permit residents some access.

    By the way, “no tailpipe (or ‘exhaust pipe’ in UK English)” – Isn’t this primarily a UK site? Should that not have read “no exhaust (or ‘tailpipe’ in American)”?

  5. I wonder how much the 2021 ULEZ will clog up the North and South Circulars themselves. Hangar Lane will struggle, and if the Woolwich Ferry can’t cope its a huge detour to the Dartford Crossing. I’m surprised the A102 to the Blackwall tunnel wasn’t made an exception. Perhaps there will just be a a big-trade in for 6+ year old diesels for 5 year old ones.

  6. @AlisonW I thought that was odd myself, but I think it can be explained by the fact that it’s commonly referred to even in the UK as “tailpipe emissions” even though “exhaust pipe” would be more appropriate for UK English.

  7. Re Muzer and Alison,

    The international accepted terminology in this case is tail pipe as the American started emissions testing first.

    E.g. “well to tail pipe” would also include oil extraction, transportation and refining.

  8. John B: The crazy-to-me thing is that my 2011 Land Rover is considered unacceptable but my mother’s 2006 Honda is fine. Grrr!

    If the extra traffic being routed around the inner ring road avoiding the CC is anything to go by then yes, the circulars will definitely get increased traffic. Given that the detours will be very substantial the overall exhaust fumes produced will go up a lot, defeating much of the intent.

  9. Just a small correction. Peter Hendy was not Transport Commissioner when the Congestion Charge was introduced in 2003. It was Bob Kiley until 2006. Peter Hendy was still Managing Director of London Buses in 2003.

    [Whoops. Corrected. Thanks. PoP]

  10. Alison W; the next Mayoral election in London is May 2020. The ULEZ expansion will be an election issue, as the Conservative candidate has pledged to stop it.

    However, the people directly and adversely affected by the ULEZ expansion reduces on a daily basis as vehicles are replaced. The last figures I saw suggested that there were fewer than 2.7m cars registered in the whole of London, or roughly one for every 3 residents. There is evidently higher car ownership in outer London Boroughs (generally blue politics) than inner London Boroughs (generally red politics). Already, 2/3 of vehicles in the ULEZ are compliant. By the election, it will be more.

    With some fag-packet-arithmetic, you can get to a point where by the election only about 10% of the electorate are going to lose out through the ULEZ expansion, and most of those will be in boroughs that already vote conservative.

  11. Sad Fat Dad,

    More than that, the non-compliant cars within the North/South Circular Roads will still have a resale value. So it is not as if their car has to be written off. If petrol then by 2021 they will have to be over 15 years old to not comply so getting towards the point where all repairs are uneconomic.

    So really the issue is residents of the expanded zone who own diesel vehicles prior to c.2015. The problem there is that the price of second-hand diesels has dropped dramatically.

  12. I will be most amused if the actual pollution levels inside the current ULEZ do not drop significantly ( Because of the “Oslo Effect” )
    Like Alison I will be screwed in 2021, unless something changes. ( She presumably has a Td5, I have a 300 Tdi )
    Ironically, if my car was an otherwise identical model, but 2 months older I would be allowed to keep it.
    The 2020 Mayoral elections are going to be … interesting

  13. A canter through the TfL website makes no mention of foreign registered cars, One thing I hated about driving round Belgium last year were the Antwerp and Brussels LEZ, which my car met the standards for, but involved two convoluted registration systems to prove the fact if I’d driven into their zones. Without cross-Europe car databases, I can see driving abroad to be fraught with difficulty with all the Balkanised schemes, are TfL any more sensible for visitors here?

  14. Greg Tingey,

    But Greg, the ULEZ has already shown a significant and measurable drop in emissions due to the planned introduction of the scheme as business replaced their non-compliant vehicles. What the effect of brakes and tyres does (the so-called ‘Oslo’ effect) is prevent you reducing the level to near zero.

    By the way, in Oslo they are planning to ban all cars from the city centre that emit any tailpipe emissions. So they obviously believe that it is better to have pollution from just brake blocks and tyres than have emissions from any internal combustion engine vehicle.

  15. Ah-ha, foreign vehicles are liable, and while they’ve heard of some non-uk plates, if not you get cheery statements like

    “LEZ charge applies for this vehicle. According to our records your vehicle is subject to the £200 daily LEZ charge. This could be because the vehicle’s details as registered with us show it doesn’t meet the required LEZ standards”

    and advice on uploading 3 different documents with phrases like “A letter from the vehicle manufacturer’s homologation department stating the vehicle’s Euro standard or a conformity certificate”

    “homologation” is not in my vocabulary, let alone foreigners.

  16. Thanks for an interesting article. The tangle of different zones over the years has been quite confusing.

    From the article: the electric equivalent vehicle is also heaver than its combustion counterpart, which leads to more tyre pollution

    of course applies only to battery powered vehicles – those that draw power from overhead wires (or the modern equivalent of conduit) can be lighter.

  17. JohnB. Homologation is a commonly used word in the motor industry, and has been for decades.
    Cross border validation of vehicle pollution class is possible. Example – to enable me to use my motorbike in France last year I had to obtain a ‘Crit Air’ sticker. The application process included me uploading a pdf copy of my V5 registration document.

  18. The north and south circulars do feel like odd boundaries, but were presumably chosen for the ease in putting up cameras along them?

    Has anyone estimated just how many cameras will be needed? Presumably it’s a lot more than for the central London zone?

  19. Frankie Roberto,

    I am puzzled by this concern about cameras. The cameras are already in place as part of the London-wide LEZ. It is true they might put some more around the immediate interior of the North and South Circular Road zone but it is hardly a major issue. If they have got them around the perimeter of London (and I can assure you they have) then it is not such a big task to cover a smaller perimeter.

  20. AlisonW: “my diesel (which emissions tests at MOT say is actually rather good although it isn’t Euro6 compliant)”. Unless I’m wrong, the MoT test doesn’t check NOx emissions. The main thrust of Euro6 was to reduce the permitted level of nitrogen oxide emissions for both diesel and petrol engines.

  21. @JB
    There is a large discrepancy between foreign registered vehicles driven by visitors to his country and foreign registered vehicles which have been acquired by UK residents and illegally driven without ever being registered.
    If you were to buy a white van with,say, Bulgarian plates, you can continue to drive it. You will not have to worry about MOT, speed cameras, traffic signs, C charge, LEZ, ULEZ or parking restrictions. If in an accident just run away. When it is no longer useable, just dump it.
    In my part of London, CEOs won’t even bother to ticket.
    There is also the phenomenon of people buyimg UK registered vehicles and fitting Romanian plates which share the same format. If the CEO sees a parked car or untaxed car with foreign plates, nobody bothers to check.
    That’s the only way I can explain why there are so many RHD cars with Romanian plates.

  22. PoP
    Thanks – we will be watching carefully, I suspect ….
    One niggle, for future reference.
    It’s well-known that “LPG” powered vehicles emit low levels of NOX & virtually zero particulates. But Khan & TfL have stated that an LPG-conversion will still be treated as if it had its original engine.
    Which strikes me as “perverse” …. to put the politest label to it.

  23. @FRANKIE ROBERTO

    According to the National Police Chief’s Council, there are thousands of Automatic Number Plate Recognition (ANPR) cameras in the UK :

    ” At present [April 2016] approximately 9000 cameras submit between 25 and nearly 40 million reads daily to the NADC. ”

    Reading vehicle plates inside the expanded low emissions zone is a “done job”.

  24. @PoP
    It is not just vehicles registered in the extended ULEZ which are affected. There are plenty of people who drive over the boundary. This is a vastly greater number than those who drive into the existing CC zone.
    This is difficult if a tradesperson finds that he can no longer economically undertake work or make deliveries and collections inside the zone.
    I also think we will see builders and plumbers merchants and other businesses relocate to just outside.
    It is also unfortunate that many hospitals such as the North Middlesex are just inside the zone but also cover a large area outside.
    I do not think the idea of running someone to A&E late at night and incurring two daily charges will be popular.
    By the way, when I replaced my car in 2015, I made sure not to buy a secondhand diesel. At the time, most of the public were unaware of the changes. (At last L-R saves me some cash!).
    Finally, the new charge will hit individuals and small businesses harder than large fleet owners. The latter can swap newer compliant vehicles in unregulated areas with older ones currently serving the proposed zone

  25. Best article on ULEZ that I have seen – thanks!

    On the politics, maybe Khan feels he can be a bit daring? I’m writing from more than 200 km away, but if he’s a shoe in anyway, why not include such stuff in the manifesto and so that he can claim afterwards that it has popular support?

  26. Re “tailpipes” – surely the ”exhaust pipe” is the whole system from the manifold, including the catalytic converter and silencer, whilst the “tailpipe” is the end of the system, where the exhaust gases add to the general pollution. There is a significant aftermarket in “tailpipes” often for tuning noise and/or performance, as well as appearance.

    The Congestion Charge exemption was originally based on CO2 emissions – starting at 100g/km, reducing to 75g/km and now at that level plus 20 mile zero emission capability and Euro 6 compliant. Whilst cars like the Prius were always exempt, CO2 emissions of some models even now exceed 75g/km, with the first generation’s being 114g/km and the second’s 104g/km.

    I never understood why residents of the Western Extension voted against continuing the charge, since it gave them virtually free access into the original zone and reduced congestion in that zone. Also not sure why residents have to leave the zone before 6.30am as they have a 90% discount.

  27. @Christian Schmidt
    I’m going to avoid going into the politics but objectively Khan is not a shoe-in. The election next year will be hard fought.

  28. @Nameless
    By 2021, petrol vehicles affected will be at least 15 years old and diesel vehicles will be at least 6 years old. I understand that a small group of people may have taken out vehicle loans for 7 or 8 years in 2014/15 and bought a diesel vehicle. This is unfortunate for them, certainly. I also understand that a van, for example, may have been purchased in 2015 with the expectation of a 10-15 year lifespan regardless of any loan length.

    But the whole aim of the LEZ/ULEZ is to get these older vehicles off the road, not to raise revenue from them. A tradesman or small business faced with the ULEZ charge will simply buy a new van, or move their business (and their vehicle) somewhere else, because the economics has pushed them to do so. Either way, the ULEZ will have achieved what it set out to do.

  29. Re JIM R @ 08:26

    AlisonW: “my diesel (which emissions tests at MOT say is actually rather good although it isn’t Euro6 compliant)”. Unless I’m wrong, the MoT test doesn’t check NOx emissions. The main thrust of Euro6 was to reduce the permitted level of nitrogen oxide emissions for both diesel and petrol engines.

    Correct, the MOT only looks at CO, HC and crudely at a proxy for PMs.
    The allowed levels are several multiples of the relevant standard levels. So even a “pass” may not meet the relevant standards!
    The only nod (May 2018 MOT changes*) to NOx levels is to check that SCR / AdBlue systems are functional and being used on Euro 5/6/V/VI engines if fitted (if not MOT failure).

    *Also made Diesel Particle Filter (DPF) removal a failure.

  30. You say “this could mean that the only exempt vehicles would be those capable of 20 miles on an electric charge”. I assume you are only stating that for brevity.

    I would expect that the exemptions for historic vehicles (i.e. pre 1973) will continue to apply.

  31. Re Fred,

    Exhaust vs Tail Pipe. Simply the emission testing measurement point which is normally at the end point. as previously mentioned the America stated measuring first so tail pipe is used worldwide.

    The are several other start and end measuring points e.g. tank or (oil) well and wheel (includes frictional wear PMs) or tailpipe just for combustion.

    Prius: The new Drive cycle introduce in September ’18 for testing purposes but back dated to April ’18 for all vehicle emission taxation purposes by HMT (which TfL piggy back on) has the current Prius at 76. hence TfL have very cunning managed to slow the growth in Uber drivers unless they go for an electric vehicle.

  32. The rather arbitrary boundaries ignore the geography. The hills to the north & south of London, Chilterns & North Downs converge and act as a trap for pollutants. The east side is open so pollutants can flow out that way. The worst situation is normally a light easterly breeze that stops the flow and thus traps the pollution. This can happen both due to geostrophic winds and in the summer the sea breeze. As a result the geographical boundaries for the scheme should be the Chilterns & North Downs. Pollution within this area will tend to accumulate in the Thames basin.

    It is interesting to note that the current pollution levels in London are moderate to high see http://www.londonair.org.uk/LondonAir/nowcast.aspx .

    One thing that was briefly mentioned above but has been described elsewhere is that the pollution from one wood burning stove is equal to 8 lorries sitting idling.

    Another thing would help would be to enforce the legal requirement for engines to be turned off vehicles that are stationary (other than in traffic jams). I regularly see vehicles stationary with their engines running. The fact they have their ‘running’ light on is a good clue that the engine is running !

  33. Paul,

    Subtly, I think nameless was referring to the location of merchants who might choose to relocate just outside the North/South Circular Road zone. The issue is not whether their fleets are compliant it is whether customers driving non-compliant vehicles are put off.

    If someone has a six year old non-compliant van, the issue will be what the cost of selling it and replacing it with a second-hand compliant van (say four years old). I suspect not that much if the diesel vehicle market consistently drops in value.

  34. @Paul
    Unfortunately, it tends to be the less wealthy and those with a poor credit history who run cheap old vehicles. For many, even a four year old diesel van will be out of reach. This will not be helped by the fact that if one is forced to replace a relatively new van, the residual trade-in value will have fallen through the floor.
    There needs to be a massive publicity campaign now to ensure that those who undertake business inside the A205/406 ring will make arrangements in good time.
    Some people running elderly small Honda motorbikes are in for a shock, too.

  35. Fred Rodgers,

    I must admit to being unhappy about the use of ‘tailpipe’ which is a very neutral inoffensive word. ‘Exhaust pipe’ more accurately describes its purpose and highlights the fact that noxious stuff comes out of it. But I accept ngh’s argument that tailpipe is the standard term used in this context and it is better to stick with accepted terminology rather than insist on our own.

    Don’t get me going on Toyota’s ‘self-charging’ Prius.

  36. Greg Tingey: FL2 SD4 actually. Cost a lot (though second hand) and historically I replace my vehicle every nine or ten years unless due to accident. In this case I bought it in 2016.

    Nameless: As I see it, there is a difference between “people who live in the expanded zone” and “people who drive daily into the zone but live outside”. Those who live here – like Greg and myself – don’t have a choice in the matter, the zone is expanding to encompass us whether we like it or not. I’ve lived here over 33 years and was not intending to move. It is now a consideration. Those who commute can switch to TfL or rail services, though whether there is the space for them on those services is another issue.

  37. @Fred Rodgers

    Residents of the CC zone left home before 6:30am for the same reason that people precariously carry their shopping home instead of paying 5p for a plastic bag.

    Another reason is that prior to CC AutoPay, while going into Central London is a conscious decision to make for visitors and thus paying the charge is a notable event, getting slapped with whatever fine TfL deem appropriate the one time you use the car and believe you’d already paid for that day (when actually it was yesterday’s charge you remembered paying) leaves certain levels of resentment towards paying the charge unnecessarily.

    As for driving within the zone and not leaving meaning no charge to pay, many vans were deployed to catch anyone out who attempted to do just that. The locations of where these vans liked to park was important local knowledge…

  38. @Fred Rodgers
    I used to live in what was the Western Zone. The main problem with it was that the more residential parts of the zone didn’t have, and still don’t have, a problem with congestion. The irony of North Kensington residents paying a c-charge – even 10% of a c-charge – to drive on typically empty local streets whilst above their heads the charge-free Westway was bumper to bumper with particulate-extruding traffic was not lost on them.

    Reducing traffic through the Knightsbridge Junction, along Bayswater Road, through Kensington High Street perhaps, was probably helpful. Maybe the zone was just too big, but the c-charge model makes it hard to define boundaries anywhere other than at major arteries, and they tend to be the routes you want inside the zone, not at the boundary.

    A braver, but ultimately more successful proposition might have been to include the Edgware Road-Park Lane-Vauxhall Bridge corridor inside the charged zone. Paying to drive down an empty street only to hit a traffic jam consisting mainly of non-payers at the end of it gets a bit galling.

  39. Re FRANKIE ROBERTO @ 07:49

    The north and south circulars do feel like odd boundaries, but were presumably chosen for the ease in putting up cameras along them?

    No[, They are] a very sensible choice if you look at the actual data and modelling,

    e.g. this 3rd party 3D false colour map using V1 of the 2013 LAEI data (2013V2 and 2016 V1 data will be available shortly):
    https://parallel.co.uk/3D/laei-no2/#11.79/51.48944/-0.13765/0/45

    The biggest NOx source is actually Natural Gas consumption especially in boilers so housing (/ commercial property) density is a big factor in background levels.

    If you look at areas above 30ug/m^3 (the “legal” exposure threshold is 40) as a background level
    In South London the South Circular road as a boundary is very good at capturing most areas above 30 and not leaving to many outside (just some a band of Clapham, Wandsworth, Earlsfield) and then the big roads outside as local sources e.g. A3, A21, A23, A24 but with low background levels.

    In North London the North Circular does very similarly to the West and North but to the East there are some areas with low background levels included within the North Circular limit but no easy or sensible way of excluding them as they are surrounded by high background level areas. Again outside the North Circ the problems are largely just around the big roads.

    Heathrow (bad) and Mogden (Sewage Works hardly noticable) are the only big areas outside.

    The 2021 enlargement will also mean that emissions on the big roads outside will also drop.

    It also works quite well politically as it doesn’t go for everyone in the Mayoral Area.

  40. The details of all the congestion charge based schemes (including LEZ and ULEZ) have been based on practicality and politics, and rarely on what would be the optimal solution. For example, the North and South Circulars as boundaries have been chosen because they do provide a simple peripheral route (as do the inner ring road and the M25) but no other options achieve this. Most of the exceptions and discounts in the original scheme were included just to minimise opposition – hence the 90% discount for residents, the exemption for taxis and PHVs and the discount for nurses. Similar political considerations are bound to take place with respect to exemptions and discounts for ULEZ – following recent angst about the numbers of Ubers, removing the PHV exemption was straightforward.

  41. I’m not sure where the comment:
    ‘Quite a substantial portion of air-borne pollution originates from Continental Europe’
    comes from. It’s certainly not true for PM2.5. These particles don’t travel that far. Given that our prevailing wind is south westerly, that is, comes from the Atlantic Ocean, I would be surprised for this to be true for other pollutants either.

  42. Re JOHNM @ 11:38
    “The rather arbitrary boundaries ignore the geography…”

    See my comment above, a good practical compromise based on evidence..

  43. Quinlet,

    The prevailing wind is from the west or south west but it is not always the case e.g. ‘Beast from the East, fallout from Cherbynol*’. It is also probably true that we pollute Europe than Europe pollutes us.

    *yes, I know Cherbynol itself is in Ukraine.

    Throughout the article I have been a bit vague as to which pollutants I am referring to. This is partly to concentrate on various aspects of emission zones rather than the emissions themselves, and partly not to get too technical – and shown to be wrong. I accept that the PM particles may not travel far. In fact they advise you to walk away from the traffic (e.g. along a side street) as it makes a significant difference. It is a pity buses tend to be on main roads and that is where many bus stops are sited.

  44. Re QUINLET @ 12:24
    “I’m not sure where the comment:
    ‘Quite a substantial portion of air-borne pollution originates from Continental Europe’ comes from.”

    Agreed it certainly isn’t based on any current understanding or data.
    SO2 in the 1980s and before but certainly not currently. Unfortunately PoP continues to stick to this belief despite evidence to the contrary.

    [Now changed from substantial to small and made the point that it is only when the wind blows from the continent. PoP]

  45. Re PoP,

    At ground level the general advice for NOx* is to aim to be 75+m from a large source (e.g. main road) to minimise the impact. (less for smaller sources)

    *regarded as the best general proxy for AQ emission thinking hence some of the focus on it.

    As soon as wind speed pick up the pollutants get so mixed, dispersed and diluted that AQ issues disappear as can be seen from the the data for the several windy (40mph+) Fridays/Saturdays in Feb and March with gales showed.

    In AQ hotspot locations emissions from local sources are typically 15-20x local background levels, hence we shouldn’t focus on background levels too much but the local sources. Reducing bad local sources has the biggest effect on sorting local background levels.

  46. Question: To how many unaware residents inside or close to the N/S CIrculars do these problems apply?
    With that in mind I have some comments & I hope they don’t come across as too personal, because they will apply to a lot of people.
    With that caveat: …

    Alison W
    I cannot move & my choice of vehicle was very very carefully considered, back in 2003 on both financial & environmental grounds – I was never, ever going to buy another car after “this one” – if you consider the long-term costs of making new vehicles, for instance.
    I am now faced with the choice of trying to exchange for an older version of the one I have & transferring the “special bits” – or simply getting an older, more polluting estate car, which passes the 25 year rule. Which is not, presently, to be rolling – it’s a fixed date.
    Talk about perverse incentives.

    Quinlet
    Similar political considerations are bound to take place with respect to exemptions and discounts for ULEZ
    I would love to believe this, but at the moment, there is zero sign of anything of the sort happening.
    Presently I will be charged the pllution tax for the 6 days a week the car is not used as well as the one day when I do use it & really need it – typically to go outside the M25, where there is no convenient public transport, or public transport at all ….
    IF a proposal for an actual “use tax” was proposed, I might be much more inclined not to object.
    I wonder if Khan might propose not to charge private cars as a vote-buyer, before the election date?

  47. Some nitrogen oxides are far more toxic than other and some are more stable than others the half lives in the atmosphere vary between just hours and 150 years in sunlight depending on which oxide.
    Most are also very unstable and react on /shortly after contract with water with many having a half life of just few seconds on contact with water.

    The cyclic reduction and oxidation of NOx also results in most of the local ozone formation as regards air quality issues but this happens over a wider area over time hence O₃ [ozone] levels are good way of understanding background vs new local combustion generation of NOx.

    The tendency is to measure NO₂ as it is the easiest.

  48. Something to also bear in mind is that when people say “Zero emissions” they are referring to such vehicles like the NHS – Zero *at the point of use only*. Battery manufacture and electric charging are very polluting overall, they just push the pollution elsewhere, indeed I noted a study a few weeks ago which put diesel cars as the least polluting end-to-end (raw materials and fuel to recycling/final disposal) than petrol cars, with electric somewhere in the middle.

    Too often people concentrate on what the fuel cost only is, ignoring all the other costs.

  49. Excellent article, and a really valuable deep-dive into some of the issues around this. Thank you for posting.

    Re. ANPR cameras for the expanded ULEZ in 2021 – I fear some of the comments so far are a bit simplistic.

    POP: “I am puzzled by this concern about cameras. The cameras are already in place as part of the London-wide LEZ.”

    The existing LEZ cameras do not form a perimeter around Greater London – too many would have been needed and the money wasn’t there. The LEZ cameras cover major roads at points near the boundary and there are a scattering of “spot check” cameras elsewhere on the TfL road network. But the LEZ largely relies on honesty because the surveillance for it is very porous. If you took your heavily polluting non-compliant truck into London on a B-road and pottered about the suburbs, TfL would be none the wiser.

    What’s more, cameras on the fringes of Greater London are no use in enforcing a boundary further in. They will not tell you whether a vehicle has crossed from one side of the North Circular to the other. I don’t see how they can possibly be used to enforce the expanded ULEZ boundary.

    Re. thousands of ANPR cameras nationwide… Brian Butterworth: “Reading vehicle plates inside the expanded low emissions zone is a “done job”.”

    Alas no – not enough existing cameras are in the right places to enforce the ULEZ boundary, nor are they necessarily owned by people who will allow TfL to access the data they capture. Many are in private hands, owned by companies like TrafficMaster.

    On many locations on the national trunk network you will see pairs of co-located ANPR cameras, one blue and one green. The blue ones are older and were installed by TrafficMaster. The green ones are owned by Highways England, installed because putting their own cameras in proved cheaper than paying for the data captured by TrafficMaster.

    I’m in no doubt that if TfL want to enforce a boundary around the North and South Circulars they will be installing many, many new ANPR cameras!

  50. AlisonW,

    Not a universally held belief although, like a lot of this stuff, promoted by those with a vested interest (on both sides). People moan that producing the electricity for electric cars isn’t clean but they never mention that producing oil at an oil refinery involves massive amounts of electricity. It seems far more sensible to direct that electricity directly into the car battery.

    You also have to add the pollution of the fuel tankers taking the fuel to the service station. If the crude oil is transported by tanker you probably have to add the effect of the bunker oil (the most polluting of the lot) used to power the tanker.

    We have the old chestnut of disposing of batteries but that is not quite as true as stated. Apart from the fact that they already last a lot longer in cars that early predictions suggested, they don’t get thrown away. They are recycled and generally put in home batteries (where the energy density isn’t so critical) and are expected to have at least a further ten years of life reducing the need for ‘peaker’ plants – the very expensive power stations only needed to supply the peak load.

    Electricity is energy agnostic. It is as good or as bad as what is used to create it. Most of the claims in the US have been thoroughly debunked by evidence. For example, electric car owns are more likely to have solar panels and have only bought the solar panels because they have an electric car. Powering your car on sunshine isn’t especially polluting.

    Even if everything you stated were correct, you still have the fact that there are an awful lot of people in central London affected by pollutants and particulates and it is less harmful to have these elsewhere. Sadiq Khan is not trying to save the planet – his policies aren’t especially consistent with that. He is trying to improve the health and well-being of Londoners.

  51. @Chris5156/POP/Brian Butterworth:

    I suspect it’ll be done in a similar way to early CC days – by the deployment of a number of (presumably ULEZ-compliant) vans just sitting at random spots within the zone to catch people out…

  52. Re PoP,

    That why I mentioned the Well to Wheel /Tail pipe metrics above they take account of all oil extraction, refining and transport emissions.

    Electricity generation at oil refineries is actually done using complex very high efficiency CHP systems using mostly waste energy from steam production and the fuel source is the unusable /unsaleable fractions of oil. The refineries CHP also tend to export to local distribution networks (but often the distribution network connection aren’t large enough)

    As a result of the Fuel Quality Directive (FQD EU 2009/30 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32009L0030 ), the well to tank (oil extraction and petrol /diesel production and distribution) is understood to an incredible level (e.g. down to Petrol station lighting) with targets to reduce the GHGs involved in Fuel production. ( a younger NGH was heavily involved in the implementation technical detail to make sure no one could “misunderstand with accidental commercial advantage”)

    The Canadians were livid as it effectively banned tar sands from the European fuel supply chain.

    I’m slightly surprised electric came between diesel and petrol so would be entertained to see those calculations especially as regards annual mileage assumptions and urban /extra urban driving proportions.

  53. Re Greg @ 08:47

    PoP
    Thanks – we will be watching carefully, I suspect ….
    One niggle, for future reference.
    It’s well-known that “LPG” powered vehicles emit low levels of NOX & virtually zero particulates. But Khan & TfL have stated that an LPG-conversion will still be treated as if it had its original engine.
    Which strikes me as “perverse” …. to put the politest label to it.

    because the computer says it still have the original emission test certificate…

    The solution is to get a new proper emission test on a dynamometer done by an approved firm. This is the way the owners of some older motorbikes are dealing with things especially where manufacturer/DVLA records are lacking! (Motorbikes only need to comply with Euro 3)

  54. @CHRIS5156

    Not sure why you need to enforce a “boundary” for the ANPR cameras? You are charged for being in any part of the zone (wherever it is), so being picked up by *any* camera is fine.

  55. @Nameless
    I can appreciate the challenges of a small, barely surviving business, for example retail in a rail arch, that depends on an older polluting van to bring in stock. These people perhaps need support to switch to alternative vehicles. The Cargobikes scheme could be an example of this, but I don’t disagree that more would be preferable.

    On the other hand, as a long term resident within the area we’re discussing – something approximating zones 1-3 in 2021 – the idea that “less wealthy” residents are dependent on a fleet of cheap second hand cars just to get around doesn’t stand up to any scrutiny. Not only is the comprehensive 24 hour bus network the main mode of transport for poorer and older folks in these areas, the rise of car clubs, uber-like services and floating bikes means that actual car ownership is becoming a luxury which many residents of all incomes choose to eschew.

    Do some people in these areas *want* to buy cheap second hand cars? Quite probably. But do they *need* to such that they would be tangibly disadvantaged by not doing so? I don’t think so. The whole point of the ULEZ is to modify behaviour such that there are fewer polluting vehicles – this is doing exactly that.

  56. @Alisonw
    I am not so much worried about the daily commuters as those who might have no realistic choice but to drive to essential destinations within the zone. My example was the North Middlesex Hospital, which is just inside the 2021 ULEZ boundary. The hospital is at the centre of the current knife crime outbreak and it is not exactly safe to walk there from the nearest station at certain times of day. There are many staff on shifts who have no option but to drive. The hospital security staff escort them back to their cars at night, so parking north of the A406 is not an option.
    Similarly, running someone to A&E at and waiting with them until some time after midnight could incur a charge of £25 or, worse, two penalties, at least £160.
    The boundary is arbitrary and did not exist when these people moved into their current homes.

  57. @Paul,

    I am not against the scheme per se and I never meant to say that the majority of 2021 ULEZ residents are dependent on low cost vans or bangers.
    My point is that the scheme, as being implemented, is disproportionately harsh on those who are, when compared with larger well funded businesses.
    Further, I would love to see the cargo bike that can carry a WC and close coupled cistern together with several metres of copper pipe and a short length of plastic waste pipe, let alone a full set of plumbing tools and a stock of fittings.
    The worst polluters are old gas boilers and wood burning stoves. Surely these should be targeted as a priority.

  58. @Nameless: None the less, you cannot make the border complex or it will cause accidents as non-locals try to guess if a street is in or out of the zone and make sudden lanes changes/turns etc.. The North circular is an easy and well marked border.

    I am very annoyed with the Blackwall tunnel corridor not being exempt. I have issues with the QE II bridge and mostly try to avoid it…

  59. @The Orange One

    As long as these ANPR vans aren’t parked with the engine running…..

  60. Nameless 16:38,

    That is where firms like Toolstation or Screwfix come into their own. Toolstation will happily deliver your 3m copper pipe reliably, promptly and at a reasonable price (I speak from experience). For £10 (less than the emission charge) Screwfix will deliver within the hour. Let these firms have the problem of having a compliant vehicle.

    As Paul points out, it is about persuading people to change their habits.

  61. Where does the suggestion that vehicles parked on a highway are somehow eligible for an emissions charge come from? If the vehicle does not move and the engine is not running how can there be any liability? They’ll be after vehicles declared SORN and parked off the highway next.

    I am of the view that life is going to get very difficult for the Mayor in the upcoming election. Clearly the ULEZ wider expansion was purposely delayed to 2021 to try to lessen the controversy but I think it will be extremely unpopular. Now I don’t drive but I live not far from the A406. There are loads of local trips that involve crossing what will be the boundary. Charging local people £12.50 to drive down the road to the shops or to visit a relative or to go to work is not going to be popular. Even accepting the point about the turnover in vehicles etc there will be a lot of people caught by this and it won’t be an “easy sell” on the doorstep.

    {<Snip>. Too political and not related to either transport or air quality PoP]

  62. Walthamstow Writer,

    Clearly the ULEZ wider expansion was purposely delayed to 2021

    Hardly. The central London ULEZ was brought forward. In 2020 there will be a London-wide ULEZ for all vehicles over 3.5 tonnes (see article) andt ULEZ will be expanded for cars in 2021. That seems pretty breakneck speed to me.

    I think it will be extremely unpopular

    but only with the people who are ‘caught out’. It won’t be unpopular generally.

    Charging local people £12.50 to drive down the road to the shops or to visit a relative or to go to work is not going to be popular

    More accurately … Charging local people who do not have a compliant vehicle £12.50 to drive down the road to the shops or to visit a relative or to go to work is not going to be popular with those people

  63. re SHLR,

    Blackwall Tunnel – But they really want to reduce emissions on the approaches and in the tunnel so excluding it would be somewhat illogical.

  64. @Nameless @PoP
    I recently had a load of work done on my house in zone 2, and I can definitively say that –
    – By and large, the workers all arrived and left by public transport, tools in hand if necessary
    – Materials and fittings were all delivered directly to the house
    – Rubbish was taken away by a third party contractor
    – The supervisor/foreman would sometimes turn up in a van with items like bulkier tools, buckets, paints etc but always zipped away quickly to avoid parking issues
    – There is an acute shortage of tradespeople in inner London, so they are quite expensive, make good money and can afford newer vehicles where they need them!

  65. PoP
    And those of us, admittedly a small minority …
    Who made a carefully calculated long-term decision, to have it screwed over?
    I don’t use my car much, but when I need it, I REALLY need it & – it has to be an “estate” & I don’t want a “new” one – I’d have to pay a garage, then!
    To repeat – if I’m forced to sell, I will get a more-than-25 year old one that I can still maintain myself, at least for routine stuff ….

    To still lower pollution & yet to get more wide suport, whoever is Mayor needs to do some or all of the following:
    Exempt private cars, if only for one Mayoral term.
    Make the charge apply only when the car is in use – road-pricing for non-compliant vehcles, effectively
    Make the 25 year date “rolling” as is done forthe Road Fund Licence 40-year rule.
    Allow engine-change to a less polluting version a lot easier.

  66. Re PoP @1658,

    But if you look at the link in the DG comment and follow on behind it to look at the detailed data is shows a different picture, the algorithm that comes up with the combined simple number is slightly misleading (it takes the worst number usually PM2.5 at this time of year and uses that as the displayed AQ value)
    All the gaseous emissions are good for the last 48 hours(e.g. NOx) but PM10 and PM2.5 are medium high.

    The high PM2.5s combined with easterly winds aren’t typically “Primary” combustion (liquid or wood), tyre or brake related related thought, during these episodes the majority (typically 70-80%) are actually “Secondary” nitrate and sulphate compounds formed in the middle and upper atmosphere from NOx and SO2 from previous decomposition that coalesce and grow overtime. The easterly winds are much more turbulent in their jet stream interaction (effectively flow in the opposite direction) so particles that normally remain high up in the atmosphere are flushed out by the increased turbulence. There is nearly 5 decades of detailed data on PMs, April which sees changeable wind including lots of easterly has the highest average monthly PMs because of the high Secondary PM levels.

    Toxicity wise the origin of the PMs matters especially the smaller they are. PM formed from residues of the salt from sweat on the Underground probably being the least worst but slightly localised and unique!

  67. This is a policy created by the London Mayor to improved London’s air quality. The pollution caused elsewhere – to either generate electricity or manufacturer newer cars – is quite literally someone else’s problem.

    Those of us who support the ULEZ also, I would hope, support whoever it is that regulates those industries to reduce their carbon footprint and pollution output.

  68. Surprised at the passion for commenting on a Public transport forum about entitlements to private motoring.

    Two misunderstandings were shown:
    1, older cars is not 2000 but 1980 (same as 40 year VED)
    “any car built before 1 January 1980 will be unaffected by the new regulations,”

    2, residents discount
    “People currently living within the ULEZ will be granted a three-year sunset period with 100% discount to give them more time to meet the ULEZ standards, which will expire on 6 September 2023.”

    Personally my daily driver (45mpg) fails so I will swap with my w/e 2000 V6 coupe (21mpg) which qualifies.

  69. Looks like the Sunset discount has gone! Only the 90% until 2021 remains.
    “Transport for London confirmed that residents will not receive a discount on the charge and those living within the zone will have to pay the full fee if they use their car at any time of any day from the 2021 deadline.”

  70. ‘Because air pollution levels breach EU legal levels. Before anyone points out that what the EU decides doesn’t matter any more, one has to be aware that there is still the possibility we will be following EU rules for a while to come.’

    The 2008/50/EC Ambient Air Quality Directive was transposed into UK law with the 2010 Air Quality Standards (http://www.legislation.gov.uk/uksi/2010/1001/contents/made), so even if we leave imminently then the limit values continue to exist in UK law and interested parties such as ClientEarth could continue to bring Judicial Reviews to compel relevant authorities to undertake action.

    An interesting development will be the role of the to be created Office for Environmental Protection and quite how any enforcement power it will have will function and the extent to which local or national government will need to ‘have regard’ to such issues in policy formation.

  71. The argument about being inside the zone without driving is –
    “Vehicles that are parked all day will not be charged for that day.”

    So between 2014 and 2018 the advice given to ULEZ residents based on the TfL consultation proposals was that they should plan a vehicle replacement by 2023, some will have lost out

    The Supplementary information (page 77) states:

    “It is proposed all residents living in the ULEZ while it is operational in the phase September 2020 to September 2023 will be granted a three year time-limited 100 per cent discount on any ULEZ charge that their vehicle might incur. This is to acknowledge that they are unable to avoid the ULEZ (for example by re-routing a journey) and may require more time to change their vehicle for one to meet the ULEZ emissions standards. An ULEZ residents’ vehicles would therefore need to be compliant with applicable ULEZ emissions standards from 7 September 2023 (instead of 2020). After that point all residents must pay 100 per cent of the daily charge to drive a non-compliant vehicle in the ULEZ. This provides residents with eight years advance notice.”

    Bikers too will be surprised and confused
    “Two wheeled motorcycles, mopeds and scooters are currently exempt from the Congestion Charge. It is proposed they will also be exempt from the Emission Surcharge.”

    Actual
    “Motorcycles need to meet minimum emission standards when travelling within the Ultra Low Emission Zone (ULEZ) being Euro 3 emissions standards for NOx. Generally speaking Euro 3 engines are those registered with the DVLA after July 2007.”

  72. There will always be anecdotal examples of people who will lose out or make perverse decisions to try and outwit any policy. But anecdotal examples are poor ways to make policy. Just how many people would be willing to exchange a currently non-compliant car with one more than 25 (or 40) years old, just so they can maintain it themselves (Greg)? Just how many people have the choice between a non compliant diesel, albeit with better fuel economy, and a compliant petrol car with poorer fuel economy (Aleks)? We know, in particular, that less than half the households in inner London own any cars and that car ownership is closely related to income. Poorer households are far less likely to own a car and far more likely to rely on public transport, especially buses – so where’s the equality outcry when bus fares are increased and why the condemnation of the Khan fares freeze when it is a socially progressive policy?

    So many arguments put in this column about how inequitable the ULEZ is and how unpopular it will be are strikingly similar to the arguments made against the original congestion charge in 2003. They were wrong then, because there was a political mood that saw congestion charging as the one major untried proposal and one that looked likely to succeed, and they are wrong now because there is a high degreee of public support for measures to tackle air pollution. The fact that the majority of inner Londoners do not own a car just makes it easier.

  73. Interesting. I do support this policy, living in the same part of town as WW and Greg, just inside the A406.

    However, I also have a non compliant car. And while it gets little use (and will get less still when ULEZ turns up) it is still useful with a large number of kids in tow – usually on monthly weekends to escape London. It has exceeedinly low CPZ permit charge and VEL charges so I’d just thought I’d have to take the ULEZ hit on the rare occasions I drive it. An electric car is a non starter as it doesn’t have the range and a new car would be an absolute waste of money, depreciating like a stone while being slowly dinted and scuffed on my road. The comments here that the ULEZ applies to parked cars is news to me and would result in an enforced need to change to my vehicle.

    Frustratingly though as Nameless highlights, there are many big old diesel polluting 15 year + beemers, all RHD on various eastern European plates that will presumably remain exempt (read unenforced). I suppose my options are go Romanian or go for a battered old petrol.

  74. TL driver
    I ( And, I supect a lot of others ) would not mind being able to change the motive power ( =engine ) of my vehicle for a less-polluting power source , which is a win-for-everybody situation.
    But this option does not appear to be on the table.
    A scrappage grant is on offer, but nothing similar for a conversion to LPG or electric – why not?
    I cannot afford a new, complaint car, yet I need a car – OK only once, sometimes twice a week & I suspect that others are in the same boat … and there is no “helping hand” being offered at all, which is not good politics, actually.

    May I add, that I walk, I cycle locally, I use tubes & trains a huge amount & buses very occasionally & yet I still object hugely to the way this is being implemented – not the theory or desirability of reducing pollution – but the practical effects on those caught in the crack of politicans making gestures?

    P.S to Quinlet
    I really do not want to ever own a car built after about 1999, that is full of electronics, that cannot be adjusted without expensive & incompetent outside “help” – I’ve recently had rides in very recent vehicles & it scares me!

  75. Couple of points: The CC and current ULEZ zone are very central but, I’d suggest, fewer people living inside that area have private cars because of the high costs associated with parking or garaging. This will not be the case with the greatly expanded zone next year.
    Greg: As it happens I had to drive this afternoon from my flat in N6 to my place outside London. I measured the distance to the north circular as exactly three miles, of which 1.1mi was on TfL roads and 1.9 on DfT. If I went directly to the NC I could cut off half of the 1.9 but then add a couple of miles in detour. I’m definitely joining the opinion in favour of road pricing rather than flat-rate-for-24hours as £4.33per mile strikes me as excessive.
    As occasionally the air in my flat gets bad (I’m at the ceiling of where a temperature inversion creates a pollution layer) I actually support the concept, I’m just not sure the implementation mechanism is right for such a massive increase in the area covered.

  76. Road pricing would involve fitting equipment to older cars that you would hope have a limited life, which would be perverse. The invasion of privacy would worry many. it would be an expensive IT system which when developed would have pressure to be applied to all motorists, even though its unpopular with them.

    Having said that, £12.50 seems a very high charge, I guess its set to be penalty rather than a pro-rata compensation for the pollution caused.

    I have no skin in this game, as a Z6 resident I cross the South Circular once or twice a year, and have a compliant car.

  77. Walthamstow Writer and others,

    Charging a pollution tax for parked cars (as mentioned in the article) is a bit perverse but it is the old case of it is something that is easy and do-able even if it is a bit crude.

    Rightly or wrongly (I have no strong opinion) emissions-based parking surcharge for residential permits is now the norm in London not the exception. Or more, strictly, is the policy in the majority of London boroughs but possibly not yet implemented. See page 9 of this report for a map.

    One could argue that the Queen’s highway should not be used as a public stable yard but that argument seems to have been lost a long time ago.

  78. There is a banana-shaped incursion along the A4 in the 2021 ULEZ boundary (http://lruc.content.tfl.gov.uk/ulez-boundary-map-from-25-october-2021.pdf)

    I understand this is because Highways England refused to install signage before junction 2 of the M4 so drivers who didn’t want to enter the ULEZ could exit at J2 and turnaround there. Instead, the signage will be on the A4 which is TfL road and the turnaround at Hogarth roundabout on the A4.

    There has been grumbling about the Chiswick banana from local residents because they are being excluded from the ULEZ but I can’t see it making much difference. How many vehicles will actually turnaround? And the pollution along the A4 is already awful.

  79. Question
    I was under the impression that, come the proposed expansion of the ULEZ in 2021, that cars more than 25 years old at [ $DATE ] will be exempt, presumably because there will be so few of them.
    I’m sure I found a reference, but it now seems to have vanished & the sites are only mentioning the “40-year” rule, which also applies o the “Road Fund Licence”.
    Does anyone have more accurate & up-to-date information, please?

    This does NOT apply to the current ULEZ, of course,only the expected future one …..

  80. I’m sure the DVLA and Met will get live ANPR feeds of the vehicle registration numbers which they will love and lead to lots of extra targeted enforcement, in that respect having North and South Circ boundaries is also very useful

  81. How strictly close to the Circulars will the boundary be? I’m thinking of Tilling Road, which runs parallel to the North Circular on the ‘inside’ at Brent Cross, which is the easiest way to get to the shopping centre from the east. There is a parallel road on the ‘outside’ but I can’t imagine this then wouldn’t get very congested?

  82. @Leo Tilling ? Tesco is INside, Brent South is OUTside

    https://consultations.tfl.gov.uk/environment/67b1e605/user_uploads/ulez_108.pdf

    @GregT – a lot of changes from announcements to Implementation.
    Date brought forward by a year as limit breaches are Urgent.
    The Sunset transition was eliminated ‘because too many residents had vehicles that would be exempt’. In other words a flagship policy would be ineffectual as the benefits of creating the scheme would be deferred by three years.
    All I can think is that 20 years ago the CO2 scheme was introduced and that is about the earliest Euro compliant petrol engines began appearing. Maybe 25 years is the absolute oldest of any compliant vehicle, not the other way round.

    @PoP – ” the ULEZ applies 24 hours a day seven days a week. It would even appear to apply to a parked vehicle on the public highway, ”

    ref https://tfl.gov.uk/modes/driving/lez-lez-services-37309
    Emission charges only apply to ‘driven’ vehicles.
    “The charges only need to be paid if you drive your vehicle within the zone. Parked vehicles are not subject to any charges.”

  83. I have just noticed the following on the ULEZ website:

    Vehicles included are:

    Motorcycles
    Mopeds
    Motorised tricycles
    Quadricycles (L category)
    Minimum emission standards

    All vehicles need to meet Euro 3 emissions standards for NOx.

    I reckon that the moped rules in particular will catch out a significant number of impecunious people dependent on their ancient Honda for transport.

    I hope that there will be a major publicity campaign well before October 2021.

  84. There is still no sign of the hybrid bus technology being transferred to trucks, which is disappointing. The difference between the initial torque being taken up with an electric motor and all cylinders revving is considerable, and it ought to be the next thing to be tackled to improve matters along red route corridors and the like.

  85. PoP, your post at 0829.
    The link to the parking map seems to just open a second copy of this Web page?

    [Curses. I can’t correct it because the web page is now unavailable. It was on the London Borough of Croydon website. PoP]

  86. NickBxn,

    I don’t think we will see hybrid trucks. Once you stick in an electric motor and batteries in a lorry it makes a lot of sense just to go the full Monty. Unfortunately you do have to sacrifice cargo space and weight for the extra batteries. Electric trucks already exist in the US in limited form. Tesla deliver some of their electric cars using electric trunks (which are still under development and not yet on sale).

    Delivery trucks in London don’t do that many miles and often sit in traffic jams so are a surprisingly good candidate. The real trick is to get the charging points at the warehouses visited so they can be recharging when loading and unloading.

  87. Hi all, a question and apologies if I have missed this in the article or comments. I own a 9 year old non compliant large diesel vehicle and live in E17 which is inside the North Circular. Please don’t judge me. It is parked on the road or as someone said above “On the Queen’s Highway”, although I can’t imagine the Queen would particularly wish to lay claim to this particular piece of Highway! Is it proposed that I will get charged whether I use the vehicle or not?

  88. The TfL website keeps talking about “driving in the zone”. Merely being parked in the zone does not appear to be an issue. They don’t have enough cameras to record every transition in and out, and I can’t see mobile cameras scanning parked cars.

  89. Nameless
    Sorry, no go!
    I have already looked at those … but, as I suggested, I’m fairly certain that the information has changed.
    Does anybody have some accurate information, or have “They” changed their minds about 25-yr old vehicles?

    Mitch – you live close to me & I think that you too are going to be penalised

  90. The LEZ, Congestion Charge and T-Charge all don’t apply to residents’ parked vehicles, and all of the ULEZ documentation refers to vehicles “driving” in the zone. I haven’t been able to find a solid cite that parked vehicles won’t be charged, but PoP hasn’t provided a cite that they will, and I think it would be easy to if that were the intention.

    (it would also potentially see TfL in court, as penalising owners of parked cars would have dubious grounds for matching the stated purpose of the ULEZ)

    Greg: See section 2.23 here: https://www.london.gov.uk/sites/default/files/md2305_stage_3b_ulez_expansion_signed.pdf

  91. FYI, electric vehicles are not always heavier than ICE ones. While battery powered busses generally are heavier than diesel buses, trolley buses usually are lighter!

  92. Just looking at the TfL charging website I note that to have automatic payment of zone fees *costs* £10 per year (!), and that the charging ‘day’ is midnight to midnight, thus catching out anyone who thinks it might work the same as travelcards at 04:30. Rushing to get out of the zone before midnight might be fun and restrict nightlife.

    As regards the coping abilities, or not, of the Woolwich Ferry, if there is a substantial increase in usage then maybe it promotes the further Thames crossing just downstream from there?

    A further issue with battery technology is the requirement for Lithium and (up to 5kg of) Cobalt for each one. Mining them has big implications for energy use (‘green-ness’) and health issues over child slave labour () with China attempting to corner the market. As far as replacing it, “There isn’t a better element than nickel to increase energy density, and there isn’t a better element than cobalt to make the stuff stable,” Marc Grynberg, the chief executive at Umicore, told Reuters. “So (while) you hear about designing out cobalt, this is not going to happen in the next three decades. It simply doesn’t work.”

  93. Chris: That’s because they don’t need to keep the battery on the bus! Far more sensible in many ways (and, imho, the way to go to reduce the costs of batteries and charing infrastructure).

    [mod: I posted a relevant link in earlier post but it didn’t show.]

  94. The inner London crossing will be near the Blackwall Tunnel, so upstream of Woolwich. ULEZ is not going to influence their placement, as I suspect it will quickly thin out diesel usage in London, so be outside their timeframe. Of course there will be precedent for future tightening of standards, so by 2030 we could be electric only in the zone. £10 for auto-pay membership is taking the piss, but its a captive audience.

    As far as parking goes, I can see the ULEZ legitimising councils extending punitive parking permit costs for diesels.

  95. @PoP comment at 0829 today.
    Differential pricing for parking permits – based on emissions category – has definitely been implemented in some boroughs. I know Islington and Tower Hamlets both do this already.

  96. @Pop 9th April 14:26
    “You also have to add the pollution of the fuel tankers taking the fuel to the service station. If the crude oil is transported by tanker you probably have to add the effect of the bunker oil (the most polluting of the lot) used to power the tanker.”
    I wonder if this is what you were intending to write as it seems to fuse two things.
    Crude oil is carried in Oil Tankers which are ships powered using bunker oil.
    Fuel is delivered to service station by Fuel Tankers which are Road Tankers designed to carry fuel and which run on the standard fuel that they deliver.

  97. Re RayJayK,

    As I said before both are already included for analysis of fuel GHG analysis for the Fuel Quality Directive.

  98. Mitch 10/04.

    As another dweller in the same postcode, we are inside the 2021 ULEZ but one one posted to the tfl site above stating that parked cars will not be charged. So maybe I’ll stick with mine and just use it even less. If only everyone else I know outside London lived near a station I wouldn’t need a car… 😀

    Interestingly I also noticed on the tfl site that it says “all foreign registered cars will be charged £12.50 a day unless registered with tfl and proven to be compliant”. So maybe it’ll play out like unpaid tickets where ther value jacks up,and up and then the car is towed? If so foreign plates will be no use.

    “The £12.50 charge also applies automatically if your vehicle is registered outside the United Kingdom and we don’t hold its details.”
    https://tfl.gov.uk/modes/driving/check-your-vehicle-35896

  99. @Mitch (and others)
    While the regulations formally apply to all vehicles within the zone, whether moving or marked, as enforcement is only carried out using ANPR cameras, there is no practical method for enforcement against parked vehicles. Once you start to move it, however…

  100. Re TL Driver,

    Just replace the foreign plates frequently – it will still be cheaper than ULEZ charges!

  101. Thanks Vince. That must be the site PoP referred to.

    @Quinlet – In the LB of Southwark, there are Controlled Parking Zones, such as in my area where restrictions and payments apply between 12.00 and 14.00 on weekdays to discourage commuters for local stations parking on nearby residential roads:
    https://www.southwark.gov.uk/parking/find-somewhere-to-park/parking-zones
    All roads affected have frequent inspections by parking enforcers, using number plate recognition, and then the offenders of parked cars are notified that they have to pay if they haven’t. I can easily see that extended to cover non-ULEZ compliant vehicles.

    @AlisonW 10 April at 16:44 – Re that link that didn’t appear, my guess is that you included it as the last line before sending. In my experience, subsequent non-appearance is because you need to type one more thing, such as a ‘new line’ for it to appear in the “Leave A Comment” section before sending.

  102. Graham ( 16.04 10th April )
    Highly uninformative link, I’m afraid ….

    IF it means I “only” have to pay £12.50 when I actually use the car to direcly exit past the N Circular & not pay when it’s parked, it might, just might be worth hanging on, until I can get a “cleaner” engine or power-source installed …
    There is still ( deliberately, I think ) a huge amount of vagueness about.
    Because, of course the “Inner-inner” zone is nothing like the vastly bigger area encompassing virtually all of zones 2 & 3 & parts of 4, & political considerations of backlash from the voters.
    If ( very big if ) for instance, Khan was to exempt “Private Cars” only, he would walk it, with no problem & I think 99% of any opposition would melt away.
    Will he / won’t he? And other similar questions.

  103. @PoP
    I had no idea that Tesla were developing electric trunks to deliver their cars. Do they work like Wallace’s “Wrong Trousers”?

  104. Greg Tingey,

    I can’t see private cars being exempt. Petrol cars except for the very worst are exempt now.

    If diesel cars were exempt then I think there would be derision especially when parents drop their darlings off at school in their old diesel vehicle. The Mayor could get away with it for the London-wide LEZ because I think everyone knew this was only a toe-in-the-water job.

    You have the additional problem that your vehicle is only a private car in the sense that it is in that category for licensing purposes. Just as a privately-owned Routemaster used to be a 65 seat private car until the rules changed. So, even if they made further exceptions on the vehicle, it would have to be fairly dramatic to include a Land Rover.

    Sorry for being so negative but that I think is the reality of the situation.

  105. @PoP

    Thanks, but you wrote ” Tesla deliver some of their electric cars using electric trunks”.

    I’ll get my coat.

  106. I will be interested to see what it’s like on Saturday, which from my observations, has become the the time of the heaviest and stickiest traffic in the West End since the C-Charge came in. There is quite a chance that people will stay away due to uncertainty and lack of knowledge. A relative of mine last night checked about visiting me… “because they have extended the Congestion Charge to the South Circular”. I reassured her on several points of clarification.

  107. I live within the expanded zone myself, and am generally supportive, but my main issue is that it catches fairly new diesel cars and vans (from 2015 as opposed to 2006 for petrol).
    If they had some kind of sunset clause (perhaps just for residents) with diesel vehicles first registered, e.g. after 2010 I think it would be more palatable.

    @GrahamFeakins it would be interesting to know whether some of the existing CPZs will become unnecessary or economically much more expensive for councils to run if the ULEZ dramatically reduces the number of vehicles…

  108. Re: Parked Vehicles
    There doesn’t seem to be any statement in the ULEZ material about parked vehicles.

    However, the LEZ material states:
    “Vehicles parked in the zone …but not driving are not subject to LEZ requirements for that day.”

    And I think in the absence of specific statements to the contrary, one could fairly confidently assume that this also applies to the ULEZ.

  109. Assuming the ULEZ operates in the same way as the LEZ, “cameras will read your number plate as you drive within the LEZ and check it against our database of registered vehicles.” – so if you have an old non-compliant diesel for your monthly family trip out of London, you will only pay when you drive it.

    Does anyone have good predictions of what the second-hand electric or hybrid car market will be like by 2021? Or figures for car-club usage (as opposed to membership)?

    I live a mile south of the South Circular, and have a seven-seater which isn’t a new-enough diesel. I doubt the charge will affect me more than a couple times a year (when I might take a cab instead), but like many people locally, we considered both car clubs and electric before buying this car 18 months ago. Zipcars have grown like weeds near me, but none are 7-seaters and chucking sprogs in the back of a Zipvan is frowned upon. There were no electric or hybrid 7-seaters for sale under £15k – will be interesting to see what happens in the next couple years. Really need minicab drivers to be buying new hybrids now so they can land on the second-hand market three years later (19 of 20 Galaxys/Sharans for sale in my price range was an ex-minicab).

  110. @Graham Feakins
    Your CPZ (and everyone else’s) is enforced by the borough. ULEZ is enforced by TfL. TfL does not have the sort of street patrols that the boroughs have. Boroughs will not enforce ULEZ because they don’t have the powers, unless TfL delegates these, and don’t have the money for this, unless TfL pays them. All the penalty income from ULEZ enforcement will go to TfL, even if they do delegate powers to the boroughs. It won’t happen. TfL will rely on ANPR for ULEZ enforcement which will mean that parked cars will not be enforced against.

  111. @Hessie. No affordable electric seven seaters yet, But plenty with (ULEZ compliant) petrol. Autocar magazine this week has an article on this very topic, you might want to have a look at that.

  112. And …
    I still can’t find anything re. the 25 vs 40 year old possible exemptions. that I’m sure I saw …
    HINT: Finding a 25.01-year old car is easy, finding a 40.01 year old one, not so much.
    Oh well, we will see how this progresses.

  113. @GT
    I think you can safely assume that any previous consideration of a 25 year exemption threshold did not survive the consultation and implementation.
    The published exemption requires that the vehicle is both 40 or more years old and has been reregistered in the “historic vehicle class” with DVLA.

  114. @GT
    Of course, if you were unfortunately to get a blue badge, you could re-register your existing car in the “disabled” class.
    This is also allowable if the car is not owned by the blue badge holder but is exclusively used by or for such person.

  115. Thanks @islanddweller – but I think I’ll keep the current car for a few years at least – usually we keep a car until it dies. I use it mostly as a van locally, or a trip across South London or outside about once a fortnight. Almost all on sale when we needed one were diesel.

    Its mpg is over twice that of my previous Galaxy, so that’s at least an improvement in what I’m spewing into the air.

    Though have just double-checked and the ULEZ will include Charlton and Lewisham, which could be a problem… will decide what to do nearer the time. I may be entitled to a blue badge by then…

  116. In reality the ULEZ is an anti diesel charge, as a petrol car would have to be incredibly old to be hit with the charge. Although the TfL pages suggest petrol cars from 2006 meet the requirement, my 2002 car passes it. So anyone with an older diesel should just switch to a petrol vehicle instead.

    Clearly this is more of an issue with vans, SUVs and MPVs where all or most were diesel powered, but not a problem for the average family car.

  117. https://consultations.tfl.gov.uk/environment/67b1e605/user_uploads/ulez_108.pdf
    https://consultations.tfl.gov.uk/environment/67b1e605/user_uploads/ulez_109.pdf

    Thanks for the maps of the ULEZ around Brent Cross. I can see some real confusion as a result, with people going the “wrong way” into the centre from the A406 and being caught.

    For example any traffic coming off at the Brent Cross A41 junction can currently access the centre from the south via Tilling Road or from the north via the roundabout, Cooper Road and Prince Charles Drive. Any drivers leaving the A406 at the next junction Staples Corner, can also access the centre from the south via Tilling Road or the north via Prince Charles Drive. One of these four options goes though the ULEZ, three don’t, I hope the signs make this clear…

    I imagine the shops in the Brent South retail park are worried as their car park is in the ULEZ. You can park on the other side of the A406 and walk across, but it’s not a nice walk at all. I imagine a LOT of retail parks and business located JUST on the wrong side of the ULEZ will be concerned.

  118. Mikey C
    I have noted that little twist.
    If, as seems likely, I am forced to get rid of my beloved Land-Rover, I get two choices ( *note* )…
    A 2006+ Volvo estate ( petrol ) …or … wait for it … an even older Landie, specifically a Series III built before October 1981, which definitely qualifies as a “Heritage Vehicle” under the new regs, even if fitted with overdrive. ( There are even V8 versions ! )
    Like I said in an earlier post, … “talk about perverse incentives” ….
    ( *note*… Not counting doing without a car at all, of course …. )

    More generally – a question.
    The stats appear to show an immediate improvement in air quality …
    Is it sufficient that people walking in the innermost zone can detect it, personally?
    Any reports, please, as if such an improvement can be detected by the Mk1 Human-nose-&-lungs, then the whole palaver might actually be worthwhile?

  119. There are two fully electric cars I know of that you can buy as 7 seaters – the Nissan e-NV200 van and the Tesla Model S/X. I don’t think anyone is using either of those as a minicab.

    The Prius+ (essentially a Prius estate) has 7 seats, possibly as standard. I see quite a lot of those gliding round London in minicab form, so there should be quite a lot on the secondhand market.

    Zipcar should have 7 seat Tourans somewhere near you. Most likely diesel though, so you won’t be doing people’s lungs a favour by using them.

  120. @Greg
    “an improvement can be detected by the Mk1 Human-nose-&-lungs”
    Whilst obviously there are fumes you can smell and taste in the air, it’s important to consider that many health-damaging emissions are consciously undetectable, and affect individuals, particularly children, when they’re repeatedly exposed over a longer period of time.

  121. @Mikey C
    Although initially the retail carparks just south of the N circular seem perverse to include in the future ULEZ, one imagines that the two nearby schools were a factor in this decision.

  122. My understanding is that wigh the Congestion Charge – at least as it was when first introduced – residents got two concessions:

    1. The 90% discount
    2. The charge only applied for moving the vehicle within the zone during the operative period (rather than to being present within the zone during the operative period – as applied to non-residents).

    Am I mistaken? And more importantly, am I to understand that a similar concession is not to be applied to residents of the ULEZ?

  123. Roy Badami
    AFAIK – you are correct.
    The residents are going to be forced to “take” one of the four following choices:
    1. Have a petrol-driven car manufactured after (approx) 2006
    2. Have a diesel-powered car manufactured after (approx) 2015
    3. Do without a car altogether
    4. Buy a car manufactured before (approx) October 1981

    It’s basically an anti-diesel pogrom – directly opposed to the previous deliberate policy of the past 10-15 years, when diesels were encouraged by government.

  124. As I understood “2”, the exemption applied if you were parked in a resident’s bay.

    Otherwise, any vehicle on the public highway (as distinct from private land such as an NCP car park) during the charging hours was liable to pay the charge, whether it moved or not.

  125. My hunch made a couple of days ago about a major initial impact on Saturday traffic seems to have been borne out by observations on a trip on the 59 bus at around 6pm from Waterloo Bridge southwards. I have never seen such empty roads down to Brixton at that time of the week, and that was with Westminster bridge closed for a demo’ too. It was a wonder that the driver didn’t spend time idling at bus stops ‘to regulate the service’, as we breezed through.

  126. @Greg Tingey
    “It’s basically an anti-diesel pogrom”

    Greg, “pogrom” is an offensive word to use about a campaign to improve air quality. You know its origins. It is unjustifiable to use a term overladen with connotations of racism and murder.

  127. Alanbg
    Well, maybe ..
    But it is, actually, retrospective legislation, penalising people in the future for what they did in the past, when it was perfectly legal, & even encouraged.
    There’s a good case to be made that the whole thing is ultra vires.
    Note: That IF the proposed legislation had said: “You can keep whatever vehicle you have, but WHEN you sell or exchange it, your new one must comply with these new clean-air regulations” … that would give rise to no problems at all.
    Note also, that this applies only to private persons … I think ( IANAL ) that the rules for commercial orgaisations might be different ….

    [Snip. This and any further references (by anyone) to pogroms will be deleted PoP]

  128. Greg Tingey,

    Absolute nonsense. The decision to encourage diesel was done on the basis of the evidence available and the general understanding at the time. There were, of course, some people who can see this was going in the wrong direction but this was not an established view.

    The decision to vilify diesel, or at least earlier diesel engines, was also done on a rational basis when new information came to light. I know it must be incredibly frustrating and annoying for diesel owners but an early scrappage scheme is the only way the government can do anything to rectify the situation without adversely affecting innocent other people (including children) or doing something else that is arguably immoral.

    To see the absurdity of your argument look at smoking. Doctors even encouraged this and governments didn’t discourage it (with one noticeable exception*). This was done on the belief it was good for you. In World WarII the even gave free cigarettes to the troops as part of their ration. You could hardly expect the government not to address the issue once the facts were known.

    When the evidence about smoking suggested otherwise you could hardly argue that since they had previously encouraged it, it was wrong for the government to discourage and penalise those who smoked.

    This sort of thing happens all the time. We have invested more than £2,000 over the years to have our wood burning stove for heating. At the time it was considered environmentally good. Now we know how bad it is but we have to accept that is what the latest science shows and we just have to have the good grace to stop using it, or using it extremely sparingly, for the sake of our neighbours.

    * Actually, the dangers of cigarette smoking were well known in one country by the 1940s. In Germany a statistical link was discovered and the leader of that nation strongly disapproved of the habit. Unfortunately no -one believed then despite it being good science. Worse still, as the Nazi Party disapproved, youngsters defiantly took up smoking to show their good anti-Nazi credentials.

  129. Re Greg,

    One of the key issues is that pollutant levels need to be brought down as soon as practicable to comply with all the court judgement. Any sort of Grandfathering won’t bring levels down to required levels any time soon…

    DfT were told before the dash to diesel what would happen with NOx and PM levels.

    Lots of the modern diesels (unlike petrol engines) emit far more than would be suggested by complying with the standards.

  130. Re PoP,

    “Absolute nonsense. The decision to encourage diesel was done on the basis of the evidence available and the general understanding at the time. There were, of course, some people who can see this was going in the wrong direction but this was not an established view.”

    Or alternatively the person at DfT at the time couldn’t deal with complexity and had no science background…

    Lots of people including oil majors, car manufacturers (non German), Greenpeace and others were telling DfT that it was bad idea, one of the “others” even went on to fund the VW gate study quite a few years later!

  131. I think also, at the time that the Government were promoting diesel cars, nobody – at least nobody in an official position – had any idea of the lengths the automotive industry were going to to falsify and deceive on actual emission levels from diesels. They still are, with many vehicles still emitting many times the maximum permitted and formal test levels of NOx.

  132. Slightly unfair to just blame the DfT as the rush to diesel was across the EU. Diesel engines are more efficient and thus produce lower CO2 emissions which 20 years ago was THE top priority. CO2 targets and engine emission standards are very much an EU led policy, and diesel technology was led by European car manufacturers (which also used their technology to sometimes cheat the emission regulations…)

    Indeed I remember an excellent Top Gear episode involving an economy run from Geneva? to Blackpool to turn on the lights, with 3 diesels on one tank of fuel, and the economy figures were amazing, and great for “saving the polar bear” etc

    And it’s slightly tricky for national politicians as while cities like London have a major issue with the pollution they’ve caused, for people living in more rural areas air pollution isn’t an issue, and diesel cars may still make sure sense. Why should diesel cars in Cornwall or the Highlands be banned or scrapped?

  133. I hesitate to intervene in a debate which has become highly politicised, but as long ago as the mid-80s, I was in charge, amongst other things, of the client side of the department’s research programme – a remit that extended to promoting fuel conservation. It was clear as long ago as then that diesel particulates were a major health hazard. Nevertheless, we ere told to ignore such evidence and promote the use of diesel rather than petrol on the grounds that that was what SMMT wanted. [A small book could be written on the baleful influence of the car industry on transport policy across the board, but that was one of the more blatant examples – more generally, SMMT lobbied hard and successfully against fuel conservation being given any sort of priority and such efforts as we were allowed to take were laughable – a desk I was happy to vacate…]

  134. The point remains that people are going to be penalised by government for following government advice – yes?
    In which case really adequate compensation should be offered, &/or a tapering-off period allowed.
    Just to dump the policy-reversal decision – even if it is the correct decision – on people & then making them bear all the costs is grossly unfair.
    Note that I am not saying that the more polluting vehicles should not be got rid of, just that a fairer method ought to be employed.

  135. Greg Tingey,

    I can see the logic of appropriate compensation (e.g. scrappage). I can also see the logic in fine-tuning the policy so people aren’t adversely affected. If you use your vehicle once a week the sensible option would be to charge you once a week. There is even a logical environmental argument for this as new vehicles are rapidly becoming cleaner. In a few years time, you might end up buying a second-hand compliant vehicle but that stimulates demand and enables someone at the top of the chain to trade in their clean vehicle for a cleaner one still. So, if an occasional user, what makes most sense is to discourage use but not encourage you to buy a new vehicle (with all the environmental cost of building it).

  136. I was going to reply to ngh’s comment pointing out broader issues but others have done this in a far better way than I can.

    The other thing about this is we are definitely not alone. Although London may be going for the largest lower emission zone other cities outside Britain are following suit. The strongest backlash against diesel seems to be in Germany where there is considerable debate as to how far to go with there inevitably being court cases ruling against the establishment. They aren’t just talking about it, they are doing it.

    Even Stuttgart, home of Porsche, is hitting hard against diesel. See the relevant page on the Stuttgart official website (in English).

  137. Re Graham H,

    In more recent times the “SMMT ” couldn’t actually reach a consensus with Diesel (German), Petrol (Italian, Japanese and some US) and also a both group (mainly French).

    The later 2 groups got it and also understood that much of the petrol /diesel efficiency gap could also be bridged.

    HMRC’s occasional thinking over the years about the possibility to move Fuel Duty from volumetric to energy content clearly shows they got it!

    I can still remember 3* car manufacturing groups saying the dash to dieselisation didn’t make sense as you just couldn’t fit all the then future (now current) exhaust system clean up equipment in small cars, there just wasn’t the space or enough of the right kind of heat in the exhaust of smaller efficient diesel engines. They couldn’t understand the Germans.
    *2 of those 3 later got in trouble for “VW” type solutions on a single engine family each in both cases it looked like cleaning up after other solutions didn’t work as well as expected. As the efficiency of diesel engines improves the minimum size of engine that abatement technologies (all require a certain quantity of heat around or above a certain temperature in the exhaust) will work on increases.

    There are also other issues in that DPFs were traditionally designed to be able to use both exhaust NOx and Oxygen for oxidative regeneration with the former requiring temperatures ~300C lower. Now as soon as you remove the NOx with Selective Catalytic Reduction (SCR e.g. Ad-Blue) before the DPF [Diesel Particulate Filter], the is virtually no NOx and the SCR has sucked more heat out of the exhaust so the gas temperature is then too low for Oxygen regeneration of the DPF,..
    Hence the need for the car manufactures to enable the engines to produce NOx to keep the DPFs working and not clogging. The DPF functionality effectively get tested in MOTs or equivalent, NOx abatement doesn’t.

  138. Re PoP,

    I been referring to the latest wave of dieselisation push this century when the evidence was available in large quantities when previously it might not have been.

    In the US the Carter administration commissioned lot of research by the EPA and mainly done by NASA and Argonne National Lab on PMs, NOx , S02 and volatile organics. Hence no rush to Diesel in the states.

  139. ngh,

    There is always a disconnect between what is known (somewhere) and what is generally known. The wobbly problems of the Millennium Bridge were well known to the Japanese (and were well documented – in Japanese). It didn’t need a new report and experiments to determine what was known.

    The USA often has different policies to the UK. There lack of any embracement of action against climate change and the cheapness and availability of ‘home-grown’ oil could be another factor why the USA was less interested in pursuing a diesel agenda.

    You also have the problem of how much weight you give to a piece of research when differing research suggests different objectives to be made. This in turn is related to the relevant clout and competence of different government departments (and lobbying groups). We don’t hear much about the views on the Department of Health on these issues – the department that you would have thought would have been taking the lead.

    There was clearly a belief, undoubtedly sincerely held by some, that there was an overriding need to reduce CO₂ emissions even at the expense of other consequences and this amounted to government policy. It might not have been good science but neither was a host of other things (from lead additives in petrol, CFCs and bad farming practices) that were encouraged by governments.

  140. “Even Stuttgart, home of Porsche, is hitting hard against diesel. ”
    Porsche no longer make any diesel vehicles.

  141. If anyone deserves compensation over the rush to diesel, surely it’s the city dwellers who’ve had no choice but to breathe the toxic air they produced, not the much smaller group who chose to save a couple of quid for themselves while switching off their brains and their noses, and apparently any sense of personal responsibility.

    And at the head of that queue should be the 60+% of inner Londoners who “do without” a car completely.

    Why should diesel cars in Cornwall or the Highlands be banned or scrapped?

    There speaks someone who’s not been walking or cycling on an empty country lane, only to have a single diesel vehicle pass by and stink up the air for several minutes.

  142. The background to the “diesel incentivisation mistake” is nicely covered by this Guardian article from 2015. The Kyoto agreement, the EU, UK Gov and motor industry all played a role.

    “David Fisk, chief scientist and policy director in the department of environment and transport in the 1990s, told the Guardian that there had been “concern” in government when it was proposed that diesel be backed over petrol.”

  143. The taxation system does take account of the dirtier diesel emissions. Both the VED and company car benefit in kind (BIK) systems tax a diesel the same as a petrol car emitting 20g/km of CO2. (E.g a diesel car emitting 100g/km is taxed the same as a petrol car emitting 120g/km)

    Moreover, since the list price of a diesel is usually more than a petrol equivalent, you pay more in VAT, BIK tax etc (the latter being based on both list price and emissions.

    One of the unintended consequences of emissions based parking charges. I know a household with two cars, but they only need one parking permit as one of the cars is used for travelling to work and is not there during charging hours. Guess which one is now used every day?

  144. @Paul – How very curious – by the 1990s, Transport and Environment had been sundered from each other for a decade.

  145. @GRAHAM 12:34

    A Euro IV or V diesel of the sort which is now chargeable in the ULEZ zone shouldn’t be producing clouds of diesel smoke, especially as being outside of the stop start inner city, its DPF filter should be working properly.

  146. Re Mikey C,

    Except DPFs a have tendency not to work all the time (or get removed).

    The (invisible) NOx is a far bigger problem with V or VI engines as emissions are typically an order of magnitude higher in reality than in a standard test.

  147. @Mikey C It’s not visible smoke, it’s the invisible acrid smell many of them leave behind. Modern cars seem perfectly capable of doing it. I have zero faith that post-2015 diesels are actually any better than old ones.

  148. @Paul – thank you for reminding me of that brief interlude at the end of the ’90s. I am surprised that there was time to evolve a chief scientist role (plus, presumably research and support staff) common to the integrated department – DTp had not had one of those since TRRL was privatised (and it was TRRL who was the source of advice on pollutants).

    I’m afraid we must disagree on whether an integrated department was a good thing or not. Having been the secretary to the “Integrated approach to the Environment” group set up when DoE was first created, I must say, I was convinced that the integration of transport and planning was a rational thing to do. Everything I have seen subsequently has reinforced that view. Si monumentum requiris, look at the disasters of Local and Neighbourhood Plans which are being created in an infrastructure-free context.

  149. @NGH

    DPFs are a nightmare in cities are the vehicles never go fast enough to burn off the soot, which is another reason why diesels in towns are a bad idea

    Outside of cities though, traffic moves much faster though and thus the DPF should work as it was intended. And in the examples I earlier mentioned like the West Country and the Highlands air quality is fine as there is a low population density and plenty of fresh air.

    Yes the occasional badly maintained smelly diesel vehicle when out on a country walk is very unpleasant, but that’s not the main health risk which is people in cities surrounded by constant pollution.

  150. Re. a previous post ….
    I crossed Bishopsgate yeaterday at approx 18.30 hrs … where was the traffic?
    And, in spite of diesel taxis & diesel buses, I think it was “cleaner”
    Even more noticeable at about 20.45, when I came out of the “Royal Oak” & crossed over to Borough Tube …..

  151. @greg The Extinction Rebellion protests have blocked many bridges and main roads into central London yesterday and today.

    Parliament Square and Waterloo Bridge have almost no traffic and there’s no buses from there to Victoria so Victoria St is eerily silent. And yes, less smelly.

    Rather annoyingly, TfL alerts recognise there are problems with Parliament Square and certain stops on Great Smith/Victoria St, but claims there are no problems with other nearby stops even when no buses expected in the next half hour (and intermittently can’t cope with demand and tells me to check a timetable).
    https://tfl.gov.uk/bus/status/?Input=Parliament+Square+%2F+Westminster+Abbey&stopId=490015048W

    Will just have to allow an extra 20 minutes to walk to the station to get home.

  152. Re Mikey C,

    DPF regeneration has nothing directly to do with how fast the vehicle is going.
    DPF regeneration is function of exhaust chemistry, temperature and duration in regeneration conditions which is just very unlikely to happen in stop-start traffic (without NOx). Which is why manufacturers still have the ability to programme ECUs to make engine generated sufficient NOx under special conditions (aka most the time in Urban areas) to make sure regeneration can take place a much lower temperature you would find under more typical Urban running conditions.

    Agree on Diesel being fine outside urban / industrial areas.

  153. Yes the occasional badly maintained smelly diesel vehicle when out on a country walk is very unpleasant, but that’s not the main health risk

    Can you hear yourself? As long as doesn’t actually kill you it’s absolutely fine. What a bloody attitude.

  154. Here are some measurements of Extinction Rebellion impact upon air quality.

    https://www.londonair.org.uk/LondonAir/general/news.aspx

    It would be interesting to see measurements around Hammersmith and Barnes following the bridge closure there.

    London spends £30M and fails to get one garden bridge then two come along for free… 😉

    At the risk of getting off-topic, it would be interesting to see impact upon traffic as well, particularly for Oxford Street given fear of displaced traffic was a key reason why many residents opposed pedestrianisation.

    Maybe TfL could open up a back channel to Extinction Rebellion to suggest locations for protests so they can get some real world data rather than all that complex and assumption-filled traffic modelling… 😉

  155. I’d be interested to see the same graphs for the southern approaches to both Waterloo Bridge and Westminster Bridge, both of which were snarled up considerably more than usual during the protests.

  156. It’s been very agreeable having the missing link in Quiteway 1 plugged into place during the last few days, on the other hand, I will also be glad when the buses are back to normal.

    Thanks for the useful/informed comments about diesel trucks. On seeing a response to my earlier complaint that hybrid technology isn’t being adopted from buses because it doesn’t make sense on trucks, I just thought ‘not good enough’ – after all, what use is a ULEZ if you are going to have large diesel trucks driving around in it? If they are only ok out of town, then there still needs to be some means of equipping them to be ok in town too. It can’t be beyond the wit…

  157. @Nickbxn. Lots of trucks are operating at the weight limit. Typically 32 tonnes. If you add hybrid tech that means batteries. For every kilo of batteries (and you’d need a lot), you remove a kilo of load capacity.
    If we’re serious about reducing trucks in London, we need consolidation centres around the outskirts then electric delivery vehicles into the city. The Olympic construction programme managed something close to this (albeit without electric last mile) with a depot near the London end of the M11 motorway so it can be done if the political will is there.
    But in current circumstance, I don’t see the political will to adopt this….

  158. @IslandDweller
    Actually average load factors for trucks are less than 50% by weight and more trucks cube out – that is their load fills all the available space but is less than the maximum weight permitted – than weigh out. This is particularly true for distribution (think of all the packaging). This ought to encourage more hybrid and electric trucks, and these are coming on stream, particularly in the US. The issue up to now has been less about weight but more about the business case, but this is improving. This doesn’t make what you say about distribution centres wrong, they are also important and can make the last mile more efficient

  159. @IslandDweller
    The London Olympics were incredibly lucky in that there was a motorway with a half built but disused junction with spare land (a planned service station on the M11 that was never built).

    https://www.google.co.uk/maps/place/Stratford,+London/@51.6298254,0.06924,1386m/data=!3m1!1e3!4m5!3m4!1s0x47d8a78bf2ab9b87:0xbd69d3e95620fb8a!8m2!3d51.5501741!4d-0.003371

    I’m struggling to think of many other locations where something similar could be done, as most of the available sites will be a long way out

  160. It’ll be interesting to see which non compliant vehicles are still entering the ULEZ.

    I would guess that virtually all will be vans rather than private cars, as so few people need to drive private cars into the current ULEZ, and most will be rich individuals driving (expensive) new cars.

  161. @Mikey C
    I’m afraid I think your last comment is a massive generalisation/over-simplification.
    I have had cause to drive over the boundary into the ULEZ at Elephant & Castle a couple of times since it was implemented (doing some DIY and furniture moves for a friend). My (non-compliant) car is neither expensive nor new.

  162. @Jim

    I did say virtually all! Your circumstances are pretty rare, and will surely make up a very small percentage of the traffic within the ULEZ?

  163. Also worth considering how much the Extinction Rebellion blockades helped reduce (high polluting) traffic. It’ll be worth keeping an eye on the stats to see if this drop is maintained.

    Also on the actual pollution levels to see how much of a difference is made. Not sure when/who would release those stats (although I’m sure City Hall will issue a press release if there’s an improvement).

  164. One place I have noticed a very definite change is close to the Royal Exchange building.
    I fairly frequently walk to/from Liverpool St – Cannon St stations – & walking along Old Broad St + crossing Lombard & King William Streets – less traffic ( The Bank junction closure ) & much less diesel fumes, anyway.
    IMHO, if the ULEZ ban was only restricted to “commercial” vehicles – we would still see a significant improvement.
    Right now, you can tell when a taxi or bus goes past, which was not perceptible before the change ….

  165. Greg Tingey,

    That has been my experience too. Though I am pleased to see that the number of electric taxis is really starting to proliferate – and starting to make an appearance in the suburbs.

    Not sure of the current situation but Cannon St has been so much nicer in respect of air quality, noise and space whilst the gas works are/were taking place.

  166. @Greg

    Surely the main factor there was the closure of the Bank junction to most motor traffic. Working not far from there, I certainly noticed a difference long before the ULEZ came in.

  167. timbeau.

    I think that is what Greg means. It was the closure of the junction to motor traffic which made the difference. But the effect was to improve the air quality.

    Similarly, the temporary improvement along Cannon St is down to gas works.

    The point is that the air quality is noticeable improved (not just measurable with instruments) if the amount of traffic is reduced and, by implication, if a ULEZ is introduced which involves some people moving to cleaner vehicles and others avoiding making the journey altogether.

  168. Was in central London last week for the first time in a couple of years. Queues to get into the tube station at Oxford Circus led to my deciding to walk from there to Kings X — until then I had no idea how much worse the air quality had got in a fairly short space of time.

  169. @MOOSEALOT

    I suspect that you were walking on a “bad day” rather than the air quality significantly deteriorating over the previous 2 years since your last visit. Or you’d forgotten how horrible certain roads in London (like the Euston Road) are to walk along…

  170. I own a vauxhall astra van diesel eu4 2008 I have purposely chosen the older model without the dpf on it as there more reliable. I rarely drive into the ulez zone, and while I know the air pollution needs improving I’m not sure we have the answer. Saying a eu6 diesel can drive in the ulez but a eu4 can’t without charge to me is stupid. Most if not all eu6 diesels have to have an adblue additive which has to be produced in a factory in plastic containers then transported around the country, where is the mention of the emissions from this. Now we get onto dpf not only do these have to be produced but in order to stop them clogging up every so often you have to drive them above a certain rpm for a certain time in order to clear then out. So they trap the particulate matter then dump it out a while later.
    Not to mention all of the adblue and dpf systems are unreliable and pass on massive expense to the motorists. So not only do you have to buy the eu6 vehicle you also have more ongoing costs just to run it (the average price of a dpf is around £1200.) I’m a mechanic so I see this all the time.
    If the ulez was about saving our planet there would be sufficient notice and a ban completely on non compliant vehicles, however you can still pollute the capital as long as you pay us.
    Now moving into electric vehicles, not only are they more complex and costly to make and therefore expensive to buy, the distance that the components have to travel just to get the car built as astonishing and at the end of the day what do they run on? fossil fuels.
    I’m all for improving our air quality and I’m sure one day we will get there however in my opinion people without the knowledge as to how the parts and vehicles are made and the true cost of that will buy into yet another government money making scheme.
    For the time being I will stick to my astra van until we have the answer.

  171. @Tom

    Fossil fuels are a decreasing proportion of electricity generation. It was on the News earlier this month that the UK went a whole week without using any coal to generate electricity

  172. Tom. There are still many problems with electric vehicles, notably cost, life of the battery pack and range. But no, they’re not much more complex than conventional vehicles. There are far fewer moving parts.

  173. @Tom

    The ULEZ isn’t about saving the planet, it’s about reducing air pollution in London.

    The pollution is killing people right now, the problem can’t be left until some nebulous time in the future when a perfect solution is found.

    I’m not sorry for the people who find this personally inconvenient/expensive.

  174. @Timbeau.
    No coal, perhaps, but how much biomass comprising woodchips obtained by cutting down trees in the USA and transporting them to Drax by filthy diesel ships, trains and motor vehicles ?

  175. @nameless

    If you’re comparing biomass to coal then there’s no contest, coal and its supply chain is much more carbon intensive than biomass and its supply chain. And either way, biomass generally sits at about 7 – 8% of the UK grid mix. Lower on most days than petroleum-based fuels, nuclear or wind (or solar too in the summer months). See http://gridwatch.co.uk/

    This also doesn’t take into account that over time the UK grid mix is getting greener and greener on a national level, before you start considering the number of people getting solar panels for their home to reduce their grid dependency.

    Furthermore if you’re comparing a biomass powered EV to an ICEV, that supply chain doesn’t hold a candle to pumping oil out of the ground in the middle east (or less commonly the North Sea), shipping it to the UK, distilling it into Octane then driving it round the country in trucks to individual petrol stations.

  176. Also, @Tom the supply chain for an EV is no more complex or well-travelled than an ICEV – pretty much every vehicle produced nowadays is a global product with components and assemblies being made in factories around the world.

    On the cost of an EV, it’s worth considering economies of scale. Not taking into account the rapidly plummeting cost of batteries (the main cost driver in an EV); as more and more consumers buy EVs they become cheaper and cheaper to buy, whereas over time we’re highly likely to see the cost of an ICEV increase as the auto OEMs desperately try to recoup the sunk costs of designing the things in the first place and tooling the production line to deliver a certain output with a decreasing market for the vehicles.

  177. Thank you to anyone who took the time to reply,
    I am by no means an expert on any of this stuff, I found a study online and they pointed out this….
    “It will come down to where is the battery made, how is it made, and even where do we get our electric power from,” said Henrik Fisker, chief executive officer and chairman of Fisker Inc., a California-based developer of electric vehicles.

    For perspective, the average German car owner could drive a gas-guzzling vehicle for three and a half years, or more than 50,000 kilometers, before a Nissan Leaf with a 30 kWh battery would beat it on carbon-dioxide emissions in a coal-heavy country, Berylls estimates show.
    And that’s one of the smallest batteries on the market: BMW’s i3 has a 42 kWh battery, Mercedes’s upcoming EQC crossover will have a 80 kWh battery, and Audi’s e-tron will come in at 95 kWh.

    As you can see it depends very much on where/how the vehicle is produced. Some country’s are better than others with Germany being one of the worst and France being one of the best.

    If every electric vehicle can be produced in a way that uses as close to zero coal as possible, and they become more affordable then we might just have the answer.
    On a side note I need a van for work and right now my choices are limited. Everything out there is expensive and has a short real world range. And I’m sorry but not everyone can afford a new van with a tiny range.

  178. @Tom: The coal consumption you cite is mostly from Germany’s power plants. (UK would do somewhat better as they use more natural gas & nuclear and not much coal anymore.) You’re running into a chicken-and-egg problem: for sustainable transport you need good sources of electricity, and cars which can use that electricity. You have to start somewhere.

    And yes, I understand that that’s not easy at this point if you need a van. You’re waiting on other people (who can afford an EV) to drive the demand so the prices will fall eventually.

  179. @albert the only reason why I mention Germany is they export more cars to the UK than anywhere else. We also buy more German cars than any other European vehicles. And by a long way nearly 4x more than France.
    In fact the top 25 selling electric cars in the UK 13 of them are from germany and 4 out of the top 10 are German.
    The best selling German model is the BMW 330e closely followed by the BMW i3 which would take about 40k miles just to break even with the emissions from making and running a petrol equivalent (114i in this case) not to mention the 114i is 12k cheaper than the i3 entry level model.
    Now I know that from 40k onwards you would see the benefit but how long do the battery’s last before they need replacement, a friend has an i3 and after 60k miles his range has dropped from about 85 miles to 55 the car is currently 5 years old, BMW warranty on the Battery is 8 years I think he said but they won’t change it for free until it gets worse. By which point it will be out of warranty and he will be left to buy a new pack which for all 8 modules in a pack is nearly £10000 not including labour.
    While I would love ev’s to become cheaper with more range there is alot of information which is not so available unless you look.
    I think more pressure should be put on the manufacturer because right now their having a field day.
    As I said previously I will keep my van until suitble ev van becomes available, I guess I will have to swallow the ulez charge until then and hope that the money generated is going into making ev vehicles more affordable and cleaner.

  180. If you aren’t willing to out-right ban polluting vehicles (which would be effective until the riots started) then that’s basically the only way it can work.

    Put up taxes on polluting vehicles, and use them to subsidise development (or purchase) of non-poluting vehicles, so that the costs make sense for an individual buyer to acquire a non-poluting vehicle.

    For what it’s worth most batteries are produced in China where the share of power generation from coal has dropped from around 80% in 2004 to around 65% today and will likely fall further as their government tries to get to grips with their own pollution issues.

  181. @bob while the battery’s may be refined and packaged in China the majority of the nickel and other elements needed comes from Canada and Indonesia, with Canada producing over double the nickel that China does. Toyota get there nickel from Canada where it has to be mined then shipped over to Europe then China and then finally Japan that’s before it’s fully assembled and ready for use. All of this negates the benefit. I agree that a ban completely would cause riots and that’s not the answer phasing them out would be the best option.
    However until it is more transparent to the true cost of the emissions in building from ground to the car not just the factory’s the manufacturers will keep quiet to the buying public.
    I think there should be a scheme where the while process is monitored and the total emissions produced to make is transparent to the public that would force the manufacturers into reducing the emissions produce and therefore make electric cars truly green.

  182. It seems to me that there are two aspects to car based pollution problems. First, as in this discussion, is the problem of air quality in urban areas. This can be best addressed by using vehicles with zero emissions such as electric or hydrogen fuel cells. Second there is the wider problem of carbon emissions.

    The use of battery powered vehicles solves the first problem but the overall effect is almost certainly very questionable regarding the second case because of the nature of the materials used in batteries and the need to transport them and dispose of them after a short life. I have very serious worries about battery power. Hydrogen is a better bet but I think that its use for small vehicles may be expensive.

    Obviously the use of electric public transport is quite feasible as we have experienced trams and trolleybuses for many years and electric railways are a no-brainer.

  183. Like Jim Jordan says, there are two issues at play here, the global one of CO2 emissions which are largely already-solved (coal replaced by natural gas, solar panels getting cheaper every year), we just need to wait for the deer to pass through the python as coal and heavy oil power stations are replaced at the end of their lives with less CO2-dense alternatives.

    Air pollution — by which I mainly mean soots/particulates and oxides of nitrogen and sulphur — is a different matter all together. This is a localised, very localised in some cases, problem which is an issue right now rather than something that may become an issue in the future if left unchecked.

    If looking at the CO2 output issue, battery vehicles make little sense. The energy required to make the battery roughly evens out with the amount of energy saved by using it and the grid vs. a conventional engine over the useful lifespan of the battery. In the mean-time the vehicle is hauling round a load of unnecessary weight. When looking at local air pollution problems, it’s another matter entirely because the aim is to reduce emissions locally without worrying about what happens in other parts of the supply chain in other places.

    Like fusion power, a good way of storing/transporting hydrogen has been 20 years away for a vey long time. NASA were keen to have better H2 storage for the space shuttle, on which design started 50 years ago. Most of the research into it has been government-backed because the lack of an extant hydrogen infrastructure means that there isn’t a large market for it so private actors are not interested. Of course, there isn’t the hydrogen infrastructure because it’s such a pain to store/transport… Batteries on the other hand are already being made in huge quantities. When automotive power packs start to reach end of life in large numbers — probably 5-10 years away — there will be an enormous incentive to buy these up for next-to-nothing and find a way of extracting the metals for which there is already a large and growing market.

  184. Moosealot: No objection to the broad thrust of this comment. But one perhaps-important detail: burning natural gas (a hydrocarbon) does put CO2 into the atmosphere – though somewhat less than coal (per kWh). If we had acted earlier against coal, we (the species) might have been able to continue to use natural gas and lighter oils, in moderation. But with the amount of CO2 already up there, it’s probably now too late to emit another gram of ex-fossil-fuel CO2.

  185. @Jim Jordan

    The problem with Hydrogen is that the most common source is as a byproduct of extracting hydrocarbons. Producing Hydrogen by electrolysis of water is very energy intensive so it’s only really viable if you have an oversupply of electricity.

  186. And Hydrogen isa real pig to handle.
    Because of the molecule-size ( really small ) it will leak out in places & way you wouldn’t believe.
    For low pollution & easy-to-handle … LPG is the alternative to batteries

  187. To summarize:
    – tailpipe/fossil fuel cars en masse are unacceptable in a big city because air pollution kills
    – battery cars en masse are currently unpractical because of cost (skipping the lifecycle emissions calculations which heavily depend on various assumptions)
    – hydrogen cars do not exist en masse

    This leaves… cargo bikes?

    Also,

    > phasing them out would be the best option.

    Arguably ULEZ _is_ the phasing out option.

  188. Expanded ULEZ significantly impacts owners of large special purpose vehicles which are expensive to replace. E.g. motor caravans, horse boxes, but could be business vehicles too.

    If the rules change to increase cost of keeping such vehicles parked on the street then I will have to give up my older (post 1980) petrol motor caravan. Paying to park it off road somewhere else isn’t a great option either.

    I did respond to the consultations with exactly this point.

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