EIR - ULEZ Compliance [Aug 2022]

Your request

1. Where do all the non-ULEZ compliant cars go? How will they be disposed of in an environmentally friendly way? There is a finite number of people who will buy these cars and what is the environmental impact of scrapping perfectly good cars?
2. What are you doing to counteract this high level of crime and inconvenience, for example, the cloning of vehicle registrations? What are your proposals to prevent this from happening if the zone was to be extended?
3. Compliant cars are also not available locally and people are having to travel hundreds of miles to view and purchase the cars. How is that impacting the environment and people's expenses?
4. Why don't you plant a tree in every place that there is a ULEZ sign and see the positive impact this has on the emissions, the whole environment and people's wellbeing? What is the cost of supplying and erecting all the ULEZ signs that would be needed?
5. How on earth is a low income family, a keyworker carrying out vital work, a charity or community group supposed to fund a compliant car?
6. When the LEZ was introduced modifications for vehicles over 3.5 tonnes were permitted and readily available so they could meet the emission standards. Why is there not an option to modify existing diesel cars to meet the criteria?
7. What exactly are the air pollution numbers for these areas?
8. How much is introducing the expansion going to reduce emissions?
9. What are you going to do about emissions being pushed across your boundary into abutting counties?
10. How much will it cost to implement the ULEZ expansion?
11. What is the projected income from the expansion?
12. What is the number of non-compliant vehicles registered in the Greater London area?
13. What percentage of buses in the Greater London area are Euro 6?
14. Who has agreed the cost of the charges?
15. What are all the figures for the ULEZ? Include everything to date and income from charges and fines

Our response

Please find below the information we hold within the scope of your request, with each question answered in turn. The GLA does not hold the information to be able to respond to all your questions in full. However, much of what you have requested is already publicly available and links to these sources are included in our response.

1. The Ultra Low Emission Zone (ULEZ) targets only the most polluting vehicles in order to reduce the emissions from road transport that are most harmful to people’s health. Drivers of non-compliant vehicles who do not want to pay the daily charge can choose to either sell or scrap their vehicle and purchase a compliant car, join a car club, or move to walking, cycling or public transport for more journeys. Ideally, the most polluting cars should be removed from the fleet altogether and their raw materials recycled and reused. There are 55 facilities within the M25 permitted to deal with correct disposal of end-of-life (ELV) vehicles and under the ELV Directive there is a target for a minimum of 95% recycling and recovery of ELVs.

More information of the impact of scrappage on waste in London is available in the Integrated Impact Assessment for the proposed London-wide ULEZ which is available on Transport for London (TfL)’s consultation page.

2. The illegal cloning of vehicles is an issue TfL is aware of, but numbers remain low. If customers believe they have received a penalty charge notice (PCN) because their vehicle has been cloned, they should make a representation against the PCN, report the issue to the police and advise the DVLA. TfL work with the police to tackle number plate crime, including number plate tampering and number plate cloning.

3. Please see our answer to Question 5.

4. Please see our answer to Question 10.

5. There is no need to buy a brand new or electric vehicle to meet the ULEZ standards. All petrol cars registered new from 2006 and all diesel cars registered new from 2016 meet the standards. Used compliant vehicles start from around £1,000.

Car clubs in London also operate fleets that meet the ULEZ standards and joining one may be a more cost-effective option than either paying the daily charge or switching to a  personal compliant vehicle depending on how often an individual drives. Many people will also be able to walk, cycle or use public transport for more of their journeys.

Additionally, some vehicles are eligible for a discount or exemption under the existing ULEZ. For example, community transport vehicles used by not-for-profit organisations can register with TfL and receive a 100% discount from the ULEZ charge until October 2023. The proposals for the London-wide ULEZ currently under consideration include a proposal to extend this grace period until October 2025.

Should the ULEZ be expanded London-wide following consultation, the Mayor has also committed to providing the largest scrappage scheme feasible to help charities, small businesses, Londoners on low incomes and disabled Londoners prepare.

6. Heavy vehicles and vans fitted with a Clean Vehicle Retrofit Accreditation Scheme (CVRAS) certified retrofit system are considered to meet the LEZ and ULEZ standards and do not need to pay the charge to drive in the respective zones.

The CVRAS is a government scheme, funded by Defra, that establishes common standards for all Clean Air Zone cities, not just London. There are currently no CVRAS approved retrofit emission control systems for pre-Euro 4 petrol cars or pre-Euro 6 diesel cars and it is not expected that any will come to market in the foreseeable future.

7. All data from the reference air quality monitors in London are publicly available on either the London Air or Air Quality England websites, depending on which data manager the borough subscribes to.

To expand London’s monitoring capacity, the Mayor piloted and recently expanded the Breathe London low-cost sensor network. There are now over 350 active sensors in the network, with many located near priority locations like schools and hospitals. Data from the Breathe London network is also publicly available.

The websites above include the monitor locations and dates they have been running as well as all pollution concentration data which can be freely downloaded.

Additionally, TfL and the GLA regularly report on modelled pollution levels across London. The most recent modelling is the London Atmospheric Emissions Inventory (LAEI) 2019 which includes maps of pollution levels across the city.

8. The expected emissions reductions of the proposals to expand the ULEZ London-wide are set out in the key documents available on TfL’s consultation page.

Modelling suggests that expanding the ULEZ London-wide in August 2023 would lead to are reduction of nearly 10% of nitrogen oxides (NOx) emissions from cars in outer London on top of the 30% reduction in road transport NOx emissions expected from the current ULEZ and tighter Low Emission Zone standards. It is also expected to reduce fine particulate matter (PM2.5) exhaust emissions from cars in outer London by nearly 16%, leading to a 1.5% overall reduction in PM2.5 emissions London-wide.

9. The modelling published in the consultation documents includes the expected impact of the proposed London-wide ULEZ on the area from the GLA boundary (roughly the proposed limit of the scheme) up to and including the M25. This modelling shows an expected reduction in non-compliant vehicle kilometres and a related reduction in NOx emissions in this non-GLA area.

Furthermore, evidence from the central ULEZ and expanded ULEZ supports these estimates, indicating that there has been a positive impact on air pollution on the boundary
roads of both schemes following their introductions. This is because incentivising the use of cleaner vehicles has benefits for any area outside the zone these vehicles drive to.

Monitoring reported in the Central London ULEZ - Ten Month Report showed that all sites on the boundary roads measured a continued downward trend in nitrogen dioxide following the introduction of the central ULEZ.

Similarly, the Expanded ULEZ Six Month Report showed that all monitoring sites on the boundary of the expanded zone have seen reductions in nitrogen dioxide concentrations, with an estimated 17-24% reduction in pollution on the boundary compared to a scenario without the ULEZ expansion.

Analysis from another charging scheme, the London-wide Low Emission Zone (LEZ) for large and heavy vehicles, provides further evidence that emissions-based charging schemes have benefits outside of their geographic footprints. The analysis showed that vehicles that passed through London’s Low Emission Zone went on to drive through 95% of the major towns and cities in England and Wales, bringing air quality benefits to a combined population of 18 million people.

10. The estimated costs to set up the proposed London-wide ULEZ are around £185 million. This includes back-office infrastructure, on-street cameras and signage changes.

11. Expanding the ULEZ is not about making money. As with existing schemes, including the ULEZ and Congestion Charge, this has been proposed to deliver policy objectives. Any net revenue generated by TfL’s road charging schemes (the ULEZ, LEZ or the Congestion Charge) must by law be reinvested back into London’s transport network, including in outer London.

TfL is still working on detailed financial projections for the proposed expansion of the ULEZ scheme to outer London in August 2023. However, it is expecting to generate an additional net operating surplus of around £200 million, with a range of plus or minus 50%, in the first full year of operation.

12. The GLA does not hold this information. TfL estimates that 95% of vehicles seen driving in the existing ULEZ on an average day and 85% of vehicles seen driving in outer London on an average day meet the ULEZ standards.

The consultation documents also show that without a London-wide ULEZ there would be an estimated 160,000 non-compliant cars driving in London every day in 2023.

You may wish to send a further request to TfL at [email protected]

13. As of January 2021, all buses in TfL’s 9,000-strong bus fleet meet or exceed the ULEZ standards (Euro VI). As part of this there are over 800 zero emission buses currently on London’s roads.

14. The power to make changes to a road user charging scheme is exercisable in the same manner and subject to the same limitations and conditions as applies when a scheme is first established (paragraph 38 of Schedule 23 to the GLA Act). Paragraph 4(3) of Schedule 23 provides that the Mayor, acting on behalf of the Greater London Authority, must do the following:

• Consult, or require an authority making a charging scheme (TfL) to consult, other persons;
• Require it to publish its proposals for the scheme and to consider objections to the proposals;
• Hold an inquiry, or cause an inquiry to be held, for the purposes of any order containing a charging scheme;
• Appoint the person or persons by whom any such inquiry is to be held;
• Make modifications to any such order, whether in consequence of any objections or otherwise, before such order takes effect;
• Require the authority by whom any such order is made to publish notice of the order and of its effect;
• Require it to place and maintain, or cause to be placed and maintained, such traffic signs in connection with that order as the Mayor may require.

To make a lawful decision as to whether to confirm a new scheme or changes to an existing scheme, the Mayor must comply with the statutory procedural requirements relevant to the exercise of his functions under Schedule 23 and make a rational decision, after having taken into account all relevant considerations and discounting any irrelevant ones.

15. TfL publishes quarterly ULEZ factsheets which include the number of penalty charge notices (PCNs) issued per month. A ULEZ PCN is £160, reducing to £80 if paid within 14 days.

TfL publishes details of income from all road user charging schemes, including the ULEZ, in its Annual Report and Statement of Accounts. Expected income for future years is published in its Budget, Business Plan and Financial Sustainability Plan.

All revenue raised by road pricing must by law be used to implement the Mayor’s Transport Strategy. Therefore, income received from the ULEZ is reinvested by TfL into improving the transport network, including its roads, cycleways, buses and the Tube, and making London’s air cleaner.

If you have any further questions relating to this matter, please contact us, quoting reference MGLA120722-4899.