FOI - ULEZ and environmental impact [Apr 2023]

Your request

1. How is your figure of 27,000 tonnes CO2 saving arrived at? What are the underlying calculations?
2. What is the free-cash demographic of the owners of the non-compliant cars, and how does that compare with compliant car owners? In other words, how much poorer on average are non-compliant car owners (calculated before having to scrap their cars)?
3. Your suggestion that if people will buy second hand cars, no new cars will need to be manufactured is fundamentally wrong, unless all sellers of the second hand cars then stop driving altogether, and do not replace it. But we know that not to be true, because London car ownership has gone up c.6 per cent since 2007 (mostly hovering around 2.6m), despite various scrappage schemes. What evidence or data do you have to suggest that this longstanding (and global) trend will be reversed in London, and the sellers of the second hand cars will not replace them?
4. What figure are you using for the environmental impact per car of the recycling process? 
5. What is the net impact of the Ultra Low Emission Zone (ULEZ) scheme per car (not the 'gross' impact of, apparently, 27,000 tonnes)? 
6. How many people replied to the Have Your Say document, and what proportion of them agreed to your ULEZ expansion proposals?

Our response

Question 1

Modelling was undertaken by Imperial College London working with Transport for London (TfL) in order to assess the air quality and carbon emission impacts the ULEZ expansion could have.

The result of this work is summarised in the key consultation document (‘Our proposals to help improve air quality tackle the climate emergency and reduce congestion by expanding the ULEZ London-wide and other measures’) and the Integrated Impact Assessment undertaken by Jacobs Ltd (‘London-wide ULEZ Integrated Impact Assessment (ULEZ Scheme IIA)’).

These documents are publicly available on the TfL consultation website.

Section 5.2.1 of the ULEZ Scheme IIA summarises the expected carbon impacts of the policy, including the expected c.27,000 tonne reduction in road traffic CO2 emissions in outer London, compared to the expected emissions without the scheme. Appendix B of the consultation document provides information on the modelling methodology in further detail. 

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

Questions 2 - 5

The GLA does not hold this information. As the Mayor's transport authority, TfL is responsible for the policy development, implementation and ongoing operation of road user charging schemes such as the ULEZ.

As noted above, TfL prepared the consultation documents for the scheme, including working with Imperial College London to model the expected impacts.

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

Question 6

The public consultation on proposals to expand the ULEZ London-wide ran from 20 May to 29 July 2022. The consultation received nearly 58,000 responses to a number of different questions. TfL’s report to the Mayor is available on both the GLA and TfL websites and includes an analysis of the responses received and themes raised. 

You also asked

Have you taken into consideration any of the following?

• 30 tonnes per car in manufacturing process.
• Carbon footprint of importing new cars.
• Environmental imp[act of scrappage process.
• 70 per cent of UK car scrap metal being shipped to Turkey.
• Social impact of cobalt any lithium mining.
• Battery disposal.
• Net likely improvements in EVs (etc) over the period that the non-compliant cars would otherwise remain (if not for the ULEZ expansion).

Why are you advocating forced obsolescence when the entire manufacturing industry  (electronics, consumables, white goods, food, fashion, etc), is moving in the exact opposite directions in full knowledge that forced obsolescence and the corresponding 
purchases and scrappage are environmentally disastrous? Why and how is the car industry different to all these other sectors? 

As noted in our previous response, the principal aim of the ULEZ is to reduce harmful emissions from road transport by disincentivising the use of older, more polluting vehicles.

The ULEZ specifically targets the air pollutants that are most harmful to human health: nitrogen dioxide (NO2) and particulate matter (PM). The existing ULEZ has been highly effective, helping to reduce roadside NO2 concentrations by nearly half in central London and a fifth in inner London.

In addition to incentivising people to use less polluting vehicles, the London-wide ULEZ will 
also encourage a shift to active, efficient and sustainable modes of transport and a 
corresponding reduction in vehicle kilometres, thus delivering a reduction in carbon emissions from road transport.

Drivers have multiple options to avoid paying the ULEZ charge, including switching to a car or van club, walking, cycling, using public transport, or switching to a compliant vehicle.

There is no requirement to switch to a brand-new or electric vehicle. Analysis of the existing ULEZ shows that there has been an overall reduction in vehicles and traffic flows in the zone. This suggests that the scheme has indeed helped encourage a shift to 
more sustainable forms of transport rather than a complete like-for-like replacement of every impacted vehicle. 

In October 2022, there were 47,000 fewer vehicles seen in the existing inner London ULEZ on an average day (a reduction of five per cent) compared to the weeks before the ULEZ 
expanded to inner London in October 2021. The data also suggest traffic flows are around 
three per cent lower than in the weeks before the expansion.
 
Regarding scrappage, as noted in our previous response, for scrapped vehicles there is a target for a minimum of 95 per cent recycling and recovery under the 'End of Life (ELV)' directive. 

Furthermore, not all the embedded CO2 emissions during manufacture should be counted or considered for a scrapped vehicle as it would be much nearer its end of life (otherwise it would be more financially beneficial to sell it). Additionally, a survey of successful applicants to the previous TfL car and motorcycle scrappage scheme found that many of those who used the scheme reported reducing their vehicle ownership and changing their travel habits to more sustainable modes of transport.

Other relevant links

Inner London Ultra Low Emission Zone Expansion One Year Report

TfL consultation documents and reports related to the ULEZ

If you have any further questions relating to this matter, please contact us, quoting reference MGLA040423-4303.