Thoughts on the Ultra LEZ
As you read this, a consultation on plans for an ULEZ (Ultra Low Emission Zone) in London has either closed or is drawing to a close. The deadline for getting in comments on the proposals is Friday 9 January 2015.
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With the aim of significantly reducing the number of people living in areas of poor air quality in London, the ULEZ is planned to halve emissions of nitrogen oxide (NOx) and particulate matter (PM10) from vehicle exhausts in central London. This means more than 80% of central London is expected to meet the nitrogen dioxide (NO2) annual legal limits in 2020. The ULEZ would also lead to a significant reduction in the number of people living in areas of poor air quality (where levels of NO2 exceed legal limits) – by 74% in central London, 51% in inner London and 43% in outer London.
The zone, which covers less ground than the original LEZ, is planned to come into effect on 7 September 2020. It applies to cars, motorcycles, vans, minibuses, heavy goods vehicles and coaches, which would need to meet new emissions standards in central London or pay a daily charge. Taxis, private hire vehicles and buses would also be affected.
The proposals would require all vehicles travelling within the zone to meet new emission standards and would be in operation 24 hours a day, seven days a week. TfL expects many vehicles would already meet these standards in 2020, however by introducing this requirement next year the Mayor and the city’s transport authority aim to accelerate the take up of low emission vehicles and stimulate the low emission vehicle market. The ULEZ will also ensure London’s air quality improves more quickly, making the capital a more pleasant place to live and work, and encourage the use of more sustainable forms of transport.
Buses and coaches (as well as HGVs) would have to meet Euro6, which means vehicles registered from 1 January 2014, or under seven years old in 2020. Non-compliant vehicles would be required to pay a daily charge of £100. Minibuses and large vans will have to meet Euro6 for diesel engines, which would be vehicles registered from 1 September 2016, so four years old or less when the regulations begin in 2020. For vehicles powered by petrol engines, Euro4 (registered from 1 January 2007 so 13 years old or less in 2020) would have to be met. Non-compliant vehicles would be required to pay a daily charge of £12.50.
Cars and small vans – Euro6 for diesel engines (registered from 1 September 2015 so five years old or less in 2020) and Euro4 for petrol engines (registered from 1 January 2006 so 14 years old or less in 2020). Non-compliant vehicles could still drive in the zone but they would be required to pay a daily charge of £12.50. Motorcycles and similar vehicles – Euro3 (registered from 1 July 2007 so 13 years old or less in 2020). Non-compliant vehicles would be required to pay a daily charge of £12.50.
Boris Johnson, Mayor of London, said, ‘Introducing the world’s first Ultra Low Emission Zone is an essential measure to improve London’s air quality and reduce NO2. Safeguarding Londoners’ health and well-being is a top priority for my administration. I understand that people need adequate time to switch to greener vehicles and help is at hand for those who will be hardest hit, but let’s be clear, we need to make these important changes ASAP to continue to improve Londoners’ quality of life and give everyone who lives in or visits the city the cleanest possible air to breathe.’
As part of the ULEZ proposal, TfL is working to reduce emissions from its buses alongside taxis and private hire vehicles and to increase the number of zero emission capable vehicles. This will create demonstrator fleets in London, boost industry sales and lead the transition towards this technology.
By 2020, TfL proposes all its double deckers operating in central London will be hybrid and all single deckers will be zero emission (at point of use). This will require substantial investment by TfL and will mean nearly all double deck buses operating in inner London will be hybrid and many in outer London too.
In developing the ULEZ proposal, and in line with the Mayor’s aspirations, TfL also considered a ‘zero emission capable’ ULEZ standard for all other vehicles. However it was concluded that it would not be feasible or affordable to set this requirement for all vehicles for 2020. Nevertheless it is expected that such a standard would be appropriate at a later date.
MD of Planning at TfL, Michele Dix CBE, said, ‘Improving London’s air quality is of paramount importance as it affects the health and well-being of every Londoner. That’s why we are doing everything in our power to address emissions from road transport, with the introduction of an Ultra Low Emission Zone at the core of our work to improve the capital’s air. We would urge everyone who lives, works or travels in London to give us their views on the ULEZ proposal.’
After the consultation closes, TfL will analyse the results of the consultation and make a recommendation to the Mayor. The Mayor will then make a decision on whether to confirm the scheme order, with or without modifications. Subject to confirmation of the ULEZ Scheme Order by the Mayor in spring 2015, this would effectively provide a five year notice period prior to the ULEZ coming into operation in 2020 and eight years notice for residents of the zone.
What the industry thinks
Commenting on how he expects the ULEZ proposals will affect him, MD of Crayford, Kent based Centaur Travel, Matthew Sims, said, ‘Quite significantly. We run quite a few commuter services and we have some private hire business going to London. We are in early discussions about it currently. It will mainly affect the commuter services, with a number of them having dropped off the majority of their passengers before the LEZ starts. It may leave us with the dilemma of whether we will avoid going into the Zone. Most of our vehicles are less than four or five years old anyway and we will upgrade them in time, so it won’t have a massive effect, but it will have some effect. We will have to see how it progresses. In principle, I think it’s a good thing. We certainly do not have any problems with it.’
One thing Matthew would like to see reviewed are certain exceptions made to vehicles, for instance, having to avoid the ULEZ to reach a parking space would mean a coach might have to park further away and therefore increase the amount of emissions it produces. He believes this would be especially worthwhile as he says official figures denote only 9% of emissions in the capital are from coaches. Matthew said, ‘The current LEZ adds expense. It really is a cost factor, which ultimately is passed onto the customer. However, all other operators are paying the same though, so we are all in the same boat.’
One operator that runs a considerable amount of coaches into London, The Kings Ferry, does not see the ULEZ as too much of a challenge. MD, Ian Fraser, said, ‘As far as we’ve planned it, the ULEZ shouldn’t affect us. We run a seven year life cycle on our vehicles and it just so happens that in the first half of 2020 we will be replacing our last batch of Euro5 coaches. It will not affect us unless something else changes. I do recognise that it will mean a huge investment for our industry. It may be alright for me and our business, but it will have an economic impact.’
He continued, ‘It could be a good idea if every mode of road transport is treated the same. It has to be a level playing field. If I was to change anything, it would be to anything that doesn’t make it a level playing field.’
Relating to Ian’s point, it is planned that some vehicles will receive extra funding to address the transition. In considering the impact of the reduced taxi age limit, the Mayor and TfL are proposing a specific fund to assist taxi drivers to replace their vehicles. In addition, TfL has been in regular dialogue with the Office for Low Emission Vehicles to ensure their new £500m funding allocation specifically supports taxi and PHV drivers to purchase zero emission capable vehicles, as well as supporting a fund for on-street rapid charging infrastructure. Taxis will be the second largest contributor to NOx and the largest contributor to PM10 emissions from road transport in central London in 2020. The ULEZ proposes to reduce the London-wide age limit for non zero emission capable taxis from 15 years to 10 years. This would substantially reduce emissions from these vehicles across London (by 45% for NOx and 71% for PM10) and help accelerate the take up of new zero emission capable taxis.
Commenting on the roll out of the original LEZ, Ian said, ‘We had a fairly positive experience when it was first introduced. We noticed the traffic levels decreased slightly. However, they picked up again and now traffic in London is the worst it has ever been.’
Not all operators take such a positive view on the ULEZ. Transport Manager of London tour bus operator, Golden Tours, Andy Bassom, said, ‘It’s going to have a massive impact.’ Commenting on the large investment the company made in Euro5 buses of late, he said, ‘We bought these vehicles to operate in the LEZ. People are still having Euro5s delivered, so it’s absolutely crazy. We’ve got vehicles we bought in 2011, 12, 13 and 14, that won’t be meeting the ULEZ in 2020. It’s absolutely crazy. There needs to be some sort of system whereby those newer vehicles at Euro5 should be able to have a 15 year operating life. That would still achieve what they want. Or if they want to, subsidise vehicle replacement. In London, there are really no more “dirty” buses, so this is over the top. They need to concentrate on taxis and smaller vehicles.’
MD of Motts Coaches (Aylesbury), Roger Mott. He said, ‘It’s going to give us the choice of putting a premium on going to London or to make sure we have the kit to comply. Even if we replace five vehicles a year to Euro6, we are still not going to comply by 2020. And you don’t tend to buy new coaches to go to London, all our modern vehicles do the distance work, to Switzerland and Spain. Obviously, it’s going to effect everybody though, especially the likes of those operating from London itself.’
‘It’s going to produce logistical issues too. We might have a Euro6 vehicle going to London, but what happens if that breaks down and you don’t have a Euro6 to replace it with? It’s not going to be as difficult as the current LEZ, it’s not so wide and doesn’t cover so much of London, but it’s still a big issue. The loss will be all out of the operators’ pockets. If we said to our customers that a trip to London theatres is going up by £2 per head, which is what it probably would be, then we could loose the business. It’s a very, very price competitive market.’
When asked what he would change about the proposal, Roger said, ‘My feeling is perhaps change it to Euro5, not Euro6. Euro5 is a pretty compliant level and most would probably have a lot of Euro5s by then. Euro6 compliance isn’t going to happen, there will be implications. It’s too heavy, too soon.’
The consultation request landed in Roger’s inbox over the busy Christmas period and he expressed his concern over its short notice nature. He said, ‘Most responding to this will be non-commercials, the likes of trade bodies and such likes, without the same commercial incentives as us. It is a case of having to invest now, that’s the thing. That’s probably the most difficult thing to cope with, being forced to invest.’
‘We thought that having the whole fleet converted to Euro4 during the first roll out of the LEZ would make us able to sustain an attainable price, but we haven’t seen a penny more. I question whether we would convert the whole fleet again. Just like with all of these things, as an industry we shrug our shoulders and get on with it.’