Key information
Request reference number: MGLA280623-0789
Date of response:
Summary of request
Your request
1. Air Pollution
a. What are the current levels in Barnet? (if you are unable to provide data specifically on Barnet, please provide for the area covered by the extension generally)
b. How much will this be reduced by your measures?
c. What is the timeframe for this?
d. What figures are you using for tyre particulate emissions?
e. How much have you built into your equation the increases in particulates due to heavier cars?
f. Why have you chosen NOx rather than tyre emissions, when the later has a considerably larger impact on air quality, and your measures will increase this further?
2. Climate Change
a. What is the data you have for suggesting your policy is climate positive, when all
the science says the exact opposite?
b. How many cars do you believe will be removed from circulation as a result of the
extension?
c. What is the basis for this, considering all previous scrappage schemes have
resulted in more cars in circulation?
d. What figure have you used for the carbon footprint of scrappage?
e. What figure have you used for the carbon footprint of manufacturing a
replacement vehicle?
f. What carbon reduction figures are you using to illustrate that, in your view, this
is a climate and nature-positive policy?
g. What are those figures based on, and what is the net effect?
h. What measures have you undertaken to reduce the scrap metal being moved to Turkey by ship (UK’s current policy)?
3. Congestion
a. What are the current congestion figures for Barnet? (if you are unable to provide data specifically on Barnet, please provide for the area covered by the extension generally)
b. How much will this be reduced by your measures?
c. What is the timeframe for this?
d. Will these be compared on a like-for-like basis (that is, no traffic measures implemented just prior to the policy)?
e. Does your policy support faster or slower moving cars, in the drive to reduce
congestion?
4. Legal questions
a. On what basis would I be 'fined' if I do not pay a ULEZ (Ultra Low Emission Zone) charge?
b. Is this a criminal offense, or a civil matter? Either way, what is the statutory framework sitting behind your or Transport for London’s (TfL) right to fine me?
c. Likewise, what happens if I do not pay the fine, and on what legal basis?
d. How do you or TfL obtain my personal details, and that of my car?
e. How does this meet the Information Commissioner's Office and data protection requirements?
f. If my car passes MOT emissions requirements, why am I not allowed to drive it in London without a charge?
g. How do you know if or whether my car, which is 'non-compliant' because it is older than your arbitrary cut-off date, is in fact less polluting than my neighbour’s compliant car?
What do you envisage I should do in order to counter the disastrous effect your policy will have (indeed, is already having) on me, my family and our mental health?
Our response
Air Pollution
London has one of the most comprehensive air quality monitoring networks of any global city and air quality is constantly monitored at over 150 locations. These sites are operated and funded by the London boroughs, TfL and Heathrow Airport.
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.
These websites include the monitor locations and dates they have been running, as well as all the pollution concentration data, which can be freely downloaded.
Barnet regularly reports on air quality monitoring in the borough, as per the requirements of
the statutory London Local Air Quality Management process.
More information on air quality monitoring in Barnet is available on the borough website.
The GLA regularly reports on air quality trends in London. This reporting uses data from the city’s air quality monitoring network to analyse the long term trends in pollution concentrations (the levels of pollution in the air). The most recent modelling is the London Atmospheric Emissions Inventory (LAEI) 2019.
This is a public dataset and includes modelled ground level concentrations of annual mean NOx, NO2, PM10 and PM2.5 in µg/m3 (microgramme per cubic metre) at 20m grid resolution.
You can access the data on the London Datastore.
The most relevant document is titled ‘Our proposals to help improve air quality tackle the climate emergency and reduce congestion by expanding the ULEZ London-wide and other measures'. Section 6 of this document sets out the expected impacts of the London-wide ULEZ on emissions and concentrations of key pollutants in 2023 compared to what the would be without the London-wide ULEZ. Tyre particulate emissions are discussed in this document.
The air quality modelling was undertaken by Imperial College London working with TfL in order to assess the air quality impacts the ULEZ expansion could have. The method and data used are described in Appendix C. Borough-level impacts are set out in Appendix D.
The rationale for the original introduction of the ULEZ is set out in the consultation documents for the scheme. The first ULEZ consultation happened in October 2014, with subsequent consultations in 2016 and 2017 ahead of its implementation in central London in 2019.
The consultation documents are available on the TfL website in the 'ULEZ Consultations' section.
The Mayoral Decisions for the implementation and subsequent expansions of the ULEZ are available on the GLA website:
- MD1463 Ultra Low Emission Zone
- MD2186 Central London Ultra Low Emission Zone in April 2019
- MD2305 Changes to the London-wide Low Emission Zone and expansion of ULEZ
- MD3060 London-wide Ultra Low Emission Zone (ULEZ) Scheme
The GLA has already responded to similar requests for information on this topic. Please refer to our previous Freedom of Information responses, MGLA040423-4303 and MGLA070323-2003.
The GLA does not hold further information in scope of your request.
Congestion
The GLA does not hold this information. You may wish to send a further request to TfL at [email protected]
As noted above, the expected impacts of the London-wide ULEZ were published as part of the consultation.
Section 6 of this document sets out the expected impacts of the London-wide ULEZ on traffic flows and congestion in 2023 compared to what they would be without the London-wide ULEZ.
As part of the Mayor’s Vision Zero policy, which aims to see no one killed or seriously injured on London’s roads by 2041, TfL and many of the London boroughs are lowering speed limits on their roads.
You can read more about this programme on the TfL website.
Legal questions
The legal basis for the imposition of the charge and the penalty charge for non-payment is the Scheme Order itself as made pursuant to the powers contained in section 295 of the Greater London Authority Act 1999 supplemented by the provisions contained in schedule 23 to that Act.
The consolidated version of the Scheme Order is available on the TfL website.
The full text of the Greater London Authority Act 1999 is available online.
If you drive within the ULEZ in a non-compliant vehicle and do not pay the daily charge in time, you risk receiving a Penalty Charge Notice (PCN). As mentioned above, the Scheme Charging Order provides the legal basis for a penalty to be paid for non-payment of the charge.
TfL has a range of robust policies, processes and technical measures in place to control and safeguard access to and use of personal data associated with the camera systems used for charging schemes in London.
TfL has followed the required Data Protection Impact Assessment (DPIA) process and has a published DPIA on its website which sets out how it minimises data collection from ANPR
cameras to only what is needed, how data will be used and how TfL keeps it secure.
More detail is available on the TfL website.
The ULEZ specifically targets the air pollutants that are most harmful to human health: nitrogen oxides (NOx) and particulate matter (PM). These are regulated by the Euro standards, which require vehicle engines to be designed to meet emission limits for these pollutants.
As noted on the TfL website, the ULEZ standards are based on the Euro standards, not a vehicle’s age. Compliance with the limits imposed by the Euro standards is precisely tested and measured by national approval authorities before engines can be put on the market.
The Vehicle Certification Agency (VCA) is the designated UK Type Approval Authority.
You can read more about the process of vehicle type approval on the VCA website.
In contrast, the MOT test is an indicator of the general health of the engine and emissions
control system and does not give precise measurements of the emissions performance of a vehicle or measure NOx or PM emissions.
Details of the support available to Londoners can be found on the TfL website.
If you have any further questions relating to this matter, please contact us, quoting
reference MGLA280623-0789.