The New ULEZ
In response to the 'triple challenges’ of the climate emergency, congestion, and toxic air pollution (whereby poor air quality kills 9,400 in London each year), TfL have launched a consultation on plans to expand the Ultra-Low Emission Zone (ULEZ) to cover a much larger extent of the capital from 29th August 2023. The new ULEZ will cover the extent of the existing Low Emission Zone (LEZ), encompassing most of Greater London.
London residents have been invited to comment on the proposals which also comprise:
From a policy perspective, it is clear how the proposals could help address each of these issues: according to a survey undertaken by ‘The Motorway’, as many as 1 in 3 London drivers plan to sell their car in response to the scheme. Furthermore, a report published by TfL found that the initial Central ULEZ scheme reduced NOx by 20% in 3 months, and the total number of vehicles dropped by 10%. This is perhaps key in some boroughs where car ownership remains high, parking supply limited, and yet a significant proportion of these vehicles sitting on the public highway are not actually in demand for daily use, but only used for occaisional trips. Reducing uncessary second car ownership in favour of public transport or car clubs can make meaningful improvement to the function of local roads in some areas.
The rationale behind extending the ULEZ is also clear from a local health perspective. Links between NO2 emissions, NOx and P2.5 particulate pollution have been established by the British Heart Foundation and much other research as having profound and measurable impact on health and mortality. A study by King’s College London shows that if the existing LEZ had not been implemented, it would have taken 193 years for London’s air quality to become compliant with legal limits. However, the benefits of the LEZ are weaker when compared to the results of the existing ULEZ, which only covers a comparatively small area of the worst impacted Inner London boroughs.
It should be argued that London’s cycling infrastructure and mass transit system puts it in a better position than most UK cities to encourage modal shift, and the expansion of the scheme would generate funding for TfL to reinvest in sustainable travel infrastructure. Claims made by the London Assembly in 2020 state that the ULEZ will save the NHS around ￡5 billion over next 30 years, with almost 300,000 Londoners saved from diseases attributable to air pollution, and one million fewer hospital admissions. If nothing is done, the impact of poor air quality could result in new cases of pollution related disease rising to 850,000 by 2050, according to HealthLumen.
Whilst outer London boroughs are not necessarily the worst for air quality in the capital, they do contain pockets which are, and are the focus of a large portion of London's emerging development. It is therefore argued that the current ULEZ does too little and benefits too few.
There are; however, a number of concerns with the proposed expansion. One often raised by critics is that it is seen to be a regressive policy – meaning that it affects those on lower incomes more than wealthier motorists, despite the latter generating the most air pollution. Compliant vehicles are expensive and whilst over 82% of cars are compliant, many of the remaining 18% are likely to be owned by lower income drivers who have less means to upgrade their car. This is potentially a problem as many of the areas covered in the extended ULEZ are less well connected to public transport (meaning that some people may have little alternative to using their car) and have a larger percentage of London’s lower income residents.
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On the reverse of the coin, air pollution has been shown in research by Imperial College London to disproportionately impact on lower-income families, the elderly, and ethnic minorities, with census data showing that these groups generally also have statistically lower rates of vehicle access and ownership. In other words, these groups contribute the least to the problem, but suffer more of the disadvantages.
Dissuading car use is of course the intention of the policy - TfL relies on discouraging personal vehicle use to meet their wider goals of tackling climate change, congestion, and toxic air pollution. Ideally, the negative effect of the ULEZ can be mitigated with the provision of high-quality, affordable, sustainable alternatives – a ‘carrot and stick’ approach; where the ULEZ is the stick and improved mass transit/ active travel infrastructure is the carrot.
As discussed earlier, London should be well suited to encourage a mode shift; however, current planned budget cuts mean that services risk stagnating rather than improving and could provide just the ‘stick’ at a time where many are already struggling in a cost-of-living crisis. Just recently, TfL have announced plans to remove 16 bus routes, albeit in central boroughs, but 78 other services could also be effected by cuts, and plans for new rail transit links can take a long time to deliver.
According to the Guardian, for those within the ULEZ who need to drive daily, the cost equates to ￡4,500 per year. The strongest critics have accused it of being a ‘stealth tax,’ particularly those who bought diesel cars under the last Labour government’s scrappage scheme, these vehicles now subject to even steeper ULEZ costs. Others have previously pointed out that London’s large fleets of buses, emergency vehicles and black cabs are exempt, yet are also generators of pollution, although it should be noted that taxis and buses are increasingly moving towards electric fleets.
Finally, some night workers, including NHS staff, have pointed out that the system makes no allowance for those driving into the ULEZ before midnight and leaving after, charging them twice for the journey. However, throughout the pandemic, some leeway for reimbursement for NHS staff has been allowed. It is not known if this will be retained through to the new extension.
Overall, it is clear that expansion of the ULEZ has potential to bring many benefits to the city and its residents, yet critics do raise some valid concerns which have yet to be fully addressed. The policy should not be done in isolation and should form part of a wider upgrade of existing infrastructure to ensure that the benefits are felt by all. It is hoped that when it comes into effect, it will be implemented with monitoring to pick up discrepancies, inequalities, and blind spots.
By Matthew Loadwick and Ben Grogan
Graphics and editing by Sarah Chapman