Ultra Low Emission Zone Transport for London
Addendum to the Integrated Impact Assessment (October 2014)
Document No. | 2 July 2015
Addendum to the Integrated Impact Assessment (October 2014) Transport for London
Document history and status
Revision Date Description By Review Approved
1 13.07.2015 Draft for review and approval M. Cottrell M. Baker R. Bellion
2 14.07.2015 Final revision M. Cottrell M. Baker R. Bellion
Distribution of copies
Revision Issue Date issued Issued to Comments approved
1 13.07.2015 13.07.2015 TfL
2 14.07.2015 14.07.2015 TfL Addendum to the Integrated Impact Assessment (October 2014)
Ultra Low Emission Zone
Project no: B1993000 Document title: Addendum to the Integrated Impact Assessment (October 2014) Document No.: 1 Revision: Draft 4 Date: 7 May 2015 Client name: Transport for London Client no: ULEZ Project manager: Roselle Bellion Author: Michelle Cottrell File name: Document1
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Limitation: This report has been prepared on behalf of, and for the exclusive use of Jacobs’ Client, and is subject to, and issued in accordance with, the provisions of the contract between Jacobs and the Client. Jacobs accepts no liability or responsibility whatsoever for, or in respect of, any use of, or reliance upon, this report by any third party.
Document No. 1 i Addendum to the Integrated Impact Assessment (October 2014)
Contents 1. Introduction ...... 1 1.1 Overview ...... 1 1.2 Integrated Impact Assessment ...... 1 1.3 Structure of this report ...... 2 1.4 Key terms used within this report ...... 2 2. Ultra Low Emission Zone (ULEZ) ...... 5 2.1 Overview ...... 5 2.2 Study area ...... 5 2.3 The ULEZ Package 2 ...... 6 3. Updates for taxis ...... 9 3.1 Background ...... 9 3.2 Update 1 – maintain 15 year age limit with voluntary decommissioning payments scheme for taxis older than 10 years ...... 10 3.3 Summary of impacts of Update 1 ...... 24 4. Updates for Private Hire Vehicles ...... 25 4.1 Background ...... 25 4.2 Update 2 – two year ‘sunset period’ exemption from the ZEC requirement for PHVs that carry 6 or more passengers ...... 26 4.3 Update 3 – change to definition of ZEC PHV ...... 26 4.4 Impacts of Update 2 and 3 on PHVs ...... 28 5. Summary and conclusions ...... 29 5.1 Summary of proposed taxi and PHV updates ...... 29 5.2 Impact of proposed updates ...... 29 5.3 Changes to air quality impacts ...... 29 5.4 Changes to health impacts ...... 29 5.5 Changes to impacts on equality groups ...... 29 5.6 Changes to impacts on London’s economy and SMEs ...... 30 6. Acronyms ...... 33 7. References ...... 34
Appendix A. Environmental Assessment – updated air quality chapter Appendix B. Health Impact Assessment – updated air quality chapter
Document No. 1 ii Addendum to the Integrated Impact Assessment (October 2014)
1. Introduction
1.1 Overview 1.1.1 To help reduce harmful emissions from road transport the Mayor and Transport for London (TfL) developed a package of proposals for taxi and private hire vehicle (PHV) licensing, vehicle emission standards and charges1 and TfL-operated bus services in a central London “Ultra Low Emission Zone” (ULEZ). The proposed vehicle emission standards and charges elements are to be implemented from 7 September 2020. It was proposed that only hybrid double decker buses and zero-emission (at tailpipe) single-decker buses would operate in the area from 2020. The implementation of the vehicle emission standards and charges, and the TfL bus proposals, was confirmed by the Mayor on 23 March 2015 following a public and stakeholder consultation which occurred between 27 October 2014 and 9 January 2015. The Mayor did not at that time confirm the taxi and PHV proposals, and asked TfL to revisit them following further engagement. 1.1.2 The objectives for the ULEZ (in line with the polices set out in the Mayor's Transport Strategy) are to: reduce air pollutant emissions from road transport, particularly those with greatest health impacts, to support Mayoral strategies and contribute to achieving compliance with European Union (EU) limit values;
reduce carbon dioxide (CO2) emissions from road transport, to support Mayoral strategies and contribute to a London-wide reduction; and stimulate the low emission vehicle market by increasing the proportion of low emission vehicles and promoting sustainable travel.
1.2 Integrated Impact Assessment 1.2.1 TfL commissioned Jacobs in May 2014 to undertake an Integrated Impact Assessment (IIA) of the ULEZ package of proposals consulted upon (i.e. the vehicle emission standards, TfL bus and licensing proposals for taxis and PHVs) in order to identify and articulate key impacts associated with its implementation. The IIA looked at a range of impacts on the environment, health, equality groups and London’s economy in 2020 and 2025 and was supported by the following individual technical assessments: Environmental Assessment; Heath Impact Assessment; Equality Impact Assessment; and Economic and Business Impact Assessment.
1.2.2 The IIA was considered critical by TfL to assist with identifying how negative impacts could be avoided, mitigated or remedied, and how positive impacts could be enhanced. 1.2.3 The IIA was completed in October 2014 and is available online through TfL’s ULEZ consultation website, along with the associated technical assessments: https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone 1.2.4 Following the public and stakeholder consultation, and taking into account additional analysis and stakeholder engagement, TfL proposed modifications or updates to the original ULEZ vehicle emission standards proposals in relation to: pre-1973 vehicles and historic vehicles; vehicles adapted for disability. 1.2.5 These were assessed by Jacobs in March 2015 in an Addendum Report (first addendum report) to the original IIA. This was considered by the Mayor when he approved the vehicle emission standards and charges with the above modifications on 23 March 2015.
1 These were set out in a Variation Order to the London Low Emission Zone (LEZ) Scheme Order.
Document No. 1 1 Addendum to the Integrated Impact Assessment (October 2014)
1.2.6 At the same time, the Mayor requested that additional consultation and engagement be undertaken by TfL in relation to the taxi and PHV licensing proposals. The original consultation proposals (hereon referred to as “ULEZ Package 1”) are depicted in Figure 1.1 and explained further in Chapter 2. 1.2.7 TfL’s engagement with the taxi and PHV trades has resulted in revised or updated licensing proposals and additional mitigation measures2 which together with the parts of the ULEZ scheme already confirmed are hereon referred to as “ULEZ Package 2” as depicted in Figure 1.1. 1.2.8 This Addendum Report (second addendum report) to the original IIA will help inform current consultation and engagement and presents the findings of an assessment undertaken by Jacobs of the updated taxi and PHV proposals. This report should be read in conjunction with the original IIA report (October 2014) produced by Jacobs for the ULEZ Package 1 consulted on between October 2014 and January 2015. 1.2.9 TfL’s proposals for ULEZ Package 2 are the subject of further consultation with the trades, stakeholders and general public. The consultation began on 1 July and is due to end in mid to late August 2015. TfL has published a Supplementary Information Addendum (SIA) to accompany this consultation, which explains: the licensing proposals of the ULEZ Package 2; the original licensing proposals consulted upon (published for the October to January consultation) – ULEZ Package 1; and a further taxi licensing alternative (12 year mandatory age limit) considered during development of the ULEZ Package 2. 1.2.10 The initial summary findings of this report are included in TfL’s SIA.
1.3 Structure of this report
1.3.1 Chapter 2 provides an overview of the ULEZ, including those parts that have been adopted by the Mayor and those parts which are yet to be finalised and are the subject of this consultation.
1.3.2 Chapter 3 provides an overview and assessment of the impacts associated with the updates to the taxi proposals.
1.3.3 Chapter 4 provides an overview and assessment of the impacts associated with the updates to the PHV proposals.
1.3.4 Chapter 5 provides a summary of the updates and their impacts and conclusions.
1.3.5 Chapter 6 provides a list of acronyms used throughout this report.
1.3.6 Chapter 7 lists the references relied on in writing this report.
1.4 Key terms used within this report
1.4.1 The “ULEZ Package 1” refers to:
the confirmed proposals for the “ULEZ Standards” for vehicle emissions and related matters (including charges) that were confirmed by the Mayor in March 2015, including the two modifications mentioned above, which will be introduced in London on 7 September 2020;
the operation in the ULEZ area from January 2020 of TfL buses that are only either hybrid double-deckers or zero-emission (at tailpipe) single-decker buses;
2 Additional mitigation measures include: retrofitting of 400 Euro V buses in outer London to meet a Euro VI standard; zero emission double-decker bus trial in central London; a Low Emission Neighbourhood in central London. Refer to Chapter 8 of TfL’s SIA for more information.
Document No. 1 2 Addendum to the Integrated Impact Assessment (October 2014)
the taxi / PHV licensing proposals as consulted upon between 27 October 2014 and 9 January 2015 which are summarised in column 2 of Table 2.3. It included a proposal for a 10 year mandatory age limit for taxis (with compensation scheme) referred to as “taxi Option A” in TfL’s SIA.
1.4.2 The “ULEZ Package 2” refers to:
the confirmed proposals for the “ULEZ Standards” for vehicle emissions and related matters (including charges) that were confirmed by the Mayor in March 2015, including the two modifications mentioned above, which will be introduced in London on 7 September 2020
the operation in the ULEZ area from January 2020 of TfL buses that are only either hybrid double-deckers or zero-emission (at tailpipe) single-decker buses.
the taxi / PHV licensing proposals as set out within this report and which are the subject of this current consultation; these are summarised in column 3 of Table 2.3. It includes a proposal to retain the current 15 year taxi age limit combined with a voluntary taxi decommissioning scheme for taxis older than 10 years, referred to as “taxi Option C” in TfL’s SIA.
1.4.3 These terms are illustrated in Figure 1.1.
Document No. 1 3 Addendum to the Integrated Impact Assessment (October 2014)
(Source: TfL, 2015) Figure 1.1 : Description of ULEZ packages (the different zero emission capable (ZEC) standards associated with taxis and PHVs for the different ULEZ packages outlined above are described in Chapter 2).
Document No. 1 4 Addendum to the Integrated Impact Assessment (October 2014)
2. Ultra Low Emission Zone (ULEZ)
2.1 Overview
2.1.1 The confirmed ULEZ proposals (March 2015), which will take effect in central London, comprise of: emission standards for vehicles (the ULEZ Standards)3: to encourage the uptake of cleaner vehicles, from 7 September 2020, vehicles that do not meet set emissions standards would be required to pay a daily charge to drive within the ULEZ area; and TfL buses: investment in the TfL bus fleet so that all double decker buses operating in central London will be hybrid and all single-decker buses will be zero emission (at tailpipe) by 2020.
2.1.2 The ULEZ Package 1 included the above proposals, alongside other proposals to make taxi and PHV licensing changes to reduce harmful vehicle emissions. The following key licensing requirements for taxis (black cabs) and PHVs were included in the ULEZ Package 1: taxis (black cabs) and PHVs: a requirement that all taxis and new PHVs not more than 18 months old presented for licensing from 1 January 2018 would need to be zero emission capable (ZEC) while all used PHVs (not less than 18 months old) would need to meet the new emissions standards from 1 January 2018, alongside an accompanying reduction in the age limit for all non-ZEC taxis from 7 September 2020 from 15 to 10 years (irrespective of date of licensing).
2.1.3 The current consultation that began on 1 July 2015 includes new taxi/PHV licensing proposals described in Updates 1 to 3 in this report (see section 2.3.3) as TfL’s preferred approach. These changed proposals are subject to this IIA Addendum report and are combined with the confirmed proposals outlined above to form ULEZ Package 2.
2.2 Study area
2.2.1 The study area for ULEZ falls within the Greater London Administrative Area (GLAA). In some instances, areas beyond the GLAA were considered, as changes to vehicle trip patterns on London’s road network brought about by implementation of the ULEZ are likely to extend beyond this boundary.
2.2.2 The study area is divided into five zones as described in Table 2.2, which correspond to those employed in the atmospheric emissions modelling that informed the development of the ULEZ.
3 The ULEZ Standards for all types of vehicles are set out in Table 2.1 and will operate for 24 hours a day, seven days a week. The geographical scope of the area within which the ULEZ Standards will be enforced within the limits of the current Congestion Charge Zone (CCZ), which covers the City of London in its entirety (aside from a small area near to Tower Hill), and covers to varying extents, the City of Westminster and the London boroughs of Camden, Hackney, Islington, Lambeth, Southwark and Tower Hamlets. This area also experiences the highest levels and concentrations of pollution within London, to which the greatest number of people are exposed.
Document No. 1 5 Addendum to the Integrated Impact Assessment (October 2014)
Table 2.1 : The ULEZ Standards (confirmed by the Mayor in March 2015 as modified)
Vehicle name Description Proposed Date when Charge if not emission manufacturers must compliant standard sell new vehicles meeting the emission standards Motorcycle, Any motorcycle or moped Euro 3 From July 2007 £12.50 moped etc. (tricycle or quadricycle) Car and small A passenger vehicle with no Euro 4 (petrol) From 1 January £12.50 van more than 8 seats in addition to 2008 the driver’s seat. A goods vehicle with weight when empty Euro 6 (diesel) From 1 September less than 1,205kg 2015 Large van and Goods vehicle with a gross Euro 4 (petrol) From 1 January £12.50 minibus weight of 3.5 tonnes or less. 2007 Passenger vehicle with more than 8 passenger seats and Euro 6 (diesel) From 1 September gross vehicle weight of 5 tonnes 2016 or less HGV Lorries and specialist vehicles of Euro VI From 1 January £100.00 more than 3.5 tonnes gross 2014 vehicle weight Bus / coach Passenger vehicles with more Euro VI From 1 January £100.00 than 8 passenger seats of more 2014 than 5 tonnes gross vehicle weight
(Source: TfL, 2014)
Table 2.2 : Description of the five zones making up the ULEZ study area
CCZ Based on the existing boundary which has been in operation since 2003 Inner Ring Road (IRR) A 12 mile (19km) route formed form a number of major roads that encircle the CCZ Inner Zone Extends from the CCZ to cover a number of London boroughs including Haringey to the north, Newham to the east, Lambeth to the south and Hammersmith and Fulham to the west Outer Zone Extending from the boundary of the Inner Zone to the boundary of the GLAA. Includes London boroughs such as Enfield to north, Havering to the east, Croydon to the south and Hillingdon to the west Non-GLAA Covers the area outside the GLAA boundary
2.3 The ULEZ Package 2
2.3.1 Following further work undertaken subsequent to the original consultation, TfL is now proposing revisions or updates to the taxi and PHV licensing requirements of the ULEZ Package 1 published in October 2014, which together with the elements of the original ULEZ consultation already confirmed, creates ULEZ Package 2 as set out in Table 2.3 and which are the subject of this report. The previous taxi and PHV requirements from the ULEZ Package 1 are also provided in Table 2.3 for comparison. The proposed updates are highlighted in bold.
Document No. 1 6 Addendum to the Integrated Impact Assessment (October 2014)
Table 2.3 : Proposed updates to the ULEZ requirements
Vehicle ULEZ Package 1 taxi/PHV proposals ULEZ Package 2 taxi/PHV proposals Taxi A requirement that all taxis presented for A requirement that all taxis presented for licensing for the first time need to be licensing for the first time need to be ZEC ZEC1 from 2018 with a petrol only range from 2018 (petrol requirement for extender engine where appropriate; internal combustion engines); A 10 year age limit for non ZEC taxis Retention of a 15-year age limit for all from 2020 with an associated taxis and the introduction of a compensation scheme for affected voluntary decommissioning scheme vehicle owners. for taxis older than 10 years; A policy review at the start of 2020 (or sooner) to gauge progress on the voluntary decommissioning scheme and ZEC uptake. PHV A requirement that new vehicles licensed A requirement that new vehicles (up to for the first time as PHVs need to be ZEC 18 months old) licensed for the first (vehicle definition as per taxis) from 2018; time as PHVs need to be ZEC from 2 A discontinuation of the introductory five 2018 ; year age limit rule; A two-year sunset period exemption A requirement that used vehicles (older until 2020 from the ZEC requirement than 18 months) licensed for the first time for PHVs that carry six or more as PHVs must be at least Euro 6 (diesel) passengers; and Euro 4 (petrol) from 2018. A discontinuation of the introductory five year age limit rule; A requirement that used vehicles (older than 18 months) licensed for the first time as PHVs must be at least Euro 6 (diesel) and Euro 4 (petrol) from 2018.
1 A ZEC vehicle is defined as ≤50g/km CO2 with a minimum zero emission range of 30 miles. For taxis, the original consultation specified that the conventional engine must be petrol. 2 For PHVs only, the criteria for a ZEC vehicle has been updated since the original consultation. It is now proposed that a ZEC PHV is defined as ≤50g/km CO2 and minimum zero emission range of 10 miles; or >50g/km and <75g/km CO2 and minimum zero emission range of 20 miles.
2.3.2 Further to this TfL is also proposing further additional measures which will reduce emissions in central and outer London including retrofitting of 400 Euro V buses in outer London to meet a Euro VI standard and introducing a zero emission double-decker bus trial and a Low Emission Neighbourhood in central London. The measure taken into account for this impact assessment is primarily focused on the proposal to retrofit an additional 400 Euro V buses to make them Euro VI which will operate outside the ULEZ area.
2.3.3 The proposed requirements of the ULEZ Package 2 outlined in Table 2.3 which are the subject of this IIA Addendum report are the following:
Update 1: Retention of a 15-year age limit for all taxis and the introduction of a voluntary decommissioning scheme for taxis older than 10 years (this is collectively referred to as “taxi option C” in TfL’s SIA for the current consultation); Update 2: A two-year sunset period exemption until 2020 from the ZEC requirement for PHVs that carry six or more passengers; Update 3: A requirement that new vehicles licensed for the first time as PHVs need to be ZEC from 2018 with the definition of a ZEC vehicle changed to align with the OLEV criteria, namely ≤50g/km CO2 and minimum zero emission range of 10 miles or >50g/km and <75g/km CO2 and minimum zero emission range of 20 miles.
Document No. 1 7 Addendum to the Integrated Impact Assessment (October 2014)
2.3.4 In relation to Update 1, TfL will monitor progress and undertake a review at the start of 2020 (or sooner) of ZEC taxi uptake, and the removal of 10 year plus vehicles from the fleet. If there is insufficient progress then a reduction in the mandatory taxi age limit (for example to 10 years) could be considered as a necessary alternative, subject to further consultation.
2.3.5 The updates have been built into the atmospheric emissions modelling of which the results have been used for this assessment i.e. to assess the difference between the ULEZ Package 1 and the ULEZ Package 2. The differences between the inputs to the atmospheric emissions modelling between the ULEZ Package 1 and the ULEZ Package 2 are identified in Table 2.4 (differences highlighted in bold).
Table 2.4 : Data input into atmospheric emissions model used for assessment
The ULEZ Package 1 The ULEZ Package 2
In CCZ: Euro 4/6 petrol/diesel for LGV and Car ULEZ Euro 4/6 petrol/diesel for LGV and Car ULEZ standard standard Euro VI HGV and Coach and non-TfL buses Euro VI HGV and Coach and non-TfL buses ULEZ ULEZ standard standard All double-decker buses Euro VI hybrid, except All double-decker buses Euro VI hybrid, except for for new Routemaster Euro V; all single-decker new Routemaster Euro V; all single-decker electric electric 15 year taxi age limit with a voluntary 10 year taxi age limit decommissioning scheme. This is assumed in the modelling to remove 3,500 taxis older than 10 years in 2020 Grants for the purchase of ZEC taxis. It is assumed in the modelling that there will be 9,000 ZEC taxis by the end of 2020 Outside CCZ: Knock on impact from car, LGV, HGV and coach Knock on impact from car, LGV, HGV and coach ULEZ Standards ULEZ Standards Buses incorporated into a London wide average Central London Buses incorporated into a fleet composition London wide average fleet composition + 400 10 year taxi age limit non-CCZ Euro V buses are retrofitted to make them Euro VI 15 year taxi age limit with a voluntary decommissioning scheme. This is assumed in the modelling to remove 3,500 taxis older than 10 years in 2020 Grants for the purchase of ZEC taxis. It is assumed in the modelling that there will be 9,000 ZEC taxis by the end of 2020
2.3.6 The proposed zero emission double decker bus trial and the Low Emission Neighbourhood in central London have not been built into the atmospheric emissions model used for this assessment. This is because the impacts are not possible to predict as they are subject to further feasibility and design work.
2.3.7 An assessment of whether the updates would result in a change to or removal of any impacts identified in the IIA (October 2014) is provided in Chapter 3 (for taxis) and Chapter 4 (for PHVs).
Document No. 1 8 Addendum to the Integrated Impact Assessment (October 2014)
3. Updates for taxis
Update 1: Maintain current 15 year age limit for taxis with voluntary age limit for older taxis (including decommissioning payments scheme)
3.1 Background
3.1.1 In 2020, emissions from taxis are estimated to make up 18 per cent of the total road transport oxides of nitrogen (NOx) emissions in central London.
3.1.2 TfL is the licensing authority for taxi vehicles and drivers in London. Currently, taxis presented for licensing must be no older than 15 years, in order to comply with policies in the Mayor’s Air Quality Strategy (2010).
3.1.3 The ULEZ Package 1 proposed to lower this current age limit for licensing from 15 to 10 years for all non-ZEC taxis from 7 September 2020. Therefore, after this date no vehicle older than 10 years would be able to be re-licensed as a taxi. The purpose for this reduction in age limit was to remove the oldest and most polluting vehicles from the fleet and increase the uptake of ZEC vehicles.
3.1.4 The IIA (October 2014) which undertook an assessment of the ULEZ Package 1 for the years 2020 and 2025 found that the impact of lowering the taxi age limit from 15 years to 10 years in 2020 would mean that: there would be substantial air quality and health benefits; 4 approximately one third (31.2 per cent) of the total taxi fleet contributing to NOx in London would need to upgrade their vehicles sooner than would be required under the current licencing rules; there could be a decrease in the number of licensed taxis as a result of older (60+) taxi drivers (who make up more than one third of licensed taxi drivers) retiring early rather than upgrading their vehicle to comply with the ZEC requirements and standards; as a result of this there could be a reduction in the number of taxis available at night which may impact certain equality groups (e.g. women and the Lesbian, Gay, Bisexual and Transgender (LGBT)) community who were identified to have a heightened fear for their personal safety.
3.1.5 The IIA (October 2014) further identified that these impacts would be offset by: compensation received through TfL’s committed mitigation fund which would be established specifically for drivers of older taxis to help them switch to newer ZEC vehicles; and the Office for Low Emission Vehicles (OLEV) plug-in car grant.
3.1.6 It was assumed within the IIA that the level of compensation paid would be whatever was necessary to maintain broadly the same number of taxis as now i.e. approximately 22,000. In order to retain the same number of taxis as there are today there will need to be an increase in the number of taxis purchased between now and 2020 in addition to natural churn in the market.
3.1.7 During consultation of the ULEZ Package 1, the taxi trade raised significant concerns about the proposed reduction in age limit as it would result in a large number of taxis being no longer licenced from 2020. Therefore to retain the same number of taxis as there are today (~22,000) there would need to be an increase in the number of new taxis purchased between now and 2020 in addition to natural churn in the market.
4 The total taxi fleet at the time of assessment was based on Department for Transport statistics which identified that in 2013 there were 22,200 licensed taxis in operation in London
Document No. 1 9 Addendum to the Integrated Impact Assessment (October 2014)
3.1.8 The Licensed Taxi Drivers Association (LTDA) has argued that a reduction in the current 15 year taxi age limit is not required in order to encourage the take up of ZEC vehicles. Specifically the LTDA has assumed that with the right incentive in place, an uptake of 9,000 ZEC vehicles could be achieved between 2018 and 2020 without further intervention. This is based on natural churn in the market and general attractiveness of ZEC taxis e.g. fuel savings, in addition to the right financial incentives being put in place. Under these proposals a ZEC taxi must have a maximum CO2 emission limit of ≤50g/km and a minimum 30 mile zero emission range (with a requirement that any ‘range extender’ engine included in the vehicle runs on petrol rather than diesel).
3.1.9 As a result, the Mayor asked TfL to undertake further feasibility work and engagement with the trade. This has resulted in proposals in the ULEZ Package 2 for the retention of the current 15 year age limit but with a 10 year voluntary age limit combined with a decommissioning payments scheme to no longer licence taxis older than 10 years. TfL will monitor progress of the retirement of older taxis and ZEC taxi uptake, set against the 9,000 target by 2020. It will undertake a review at the start of 2020 (or sooner if necessary) of decommissioning numbers and ZEC uptake. If there is insufficient progress TfL will consider a mandatory reduction in the taxi age limit (e.g. to 10 years), subject to further consultation.
3.2 Update 1 – maintain 15 year age limit with voluntary decommissioning payments scheme for taxis older than 10 years
Baseline for assessment
3.2.1 The baseline for this assessment is the results from the 2014 King’s College London atmospheric emissions model of London with ULEZ Package 1 for the years 2020 and 2025. These results were presented in the Environmental Assessment and Health Impact Assessment prepared by Jacobs dated October 2014 and Ricardo-AEA’s ULEZ Air Quality Health Impact Assessment and are summarised as follows.
3.2.2 In 2020 the ULEZ Package 1 would see an improvement in annual mean NO2 concentration of 4.6µg/m3 and a further 2.3µg/m3 in 2025 in the CCZ. This would reduce towards the Outer Zone with 3 3 the improvement potentially lessening to 0.6µg/m in 2020 and a further 0.3µg/m in 2025.
3.2.3 In 2020, the ULEZ Package 1 would result in a total of 18,023 (out of 34,000 without ULEZ) receptors5 no longer being located in areas exceeding annual mean NO2 Air Quality Objectives (AQO’s). In 2025, the ULEZ Package 1 would result in a total of 1,892 receptors no longer being located in areas exceeding annual mean NO2 AQO’s.
3.2.4 In 2020, without ULEZ, for PM10 approximately 34 receptors in London would be exposed to concentrations which exceed the annual mean AQO. With the ULEZ Package 1 this would not change.
3.2.5 Refer to Table 3.1 and Table 3.2 for more detailed results on changes in NO2, PM10 and PM2.5 concentrations in 2020 and 2025 for the ULEZ Package 1.
5 Receptors include all relevant receptors within 200m of the London road network. Relevant receptors may include residential properties, schools, care homes and health care facilities.
Document No. 1 10 Addendum to the Integrated Impact Assessment (October 2014)
Table 3.1 : Anticipated zone-wide average changes in NO2, PM10 and PM2.5 concentrations in 2020 for the ULEZ Package 1
Zone Average Change in no. Average Change in no. Average Change in no. change in receptors change in receptors change in receptors
AM* NO2 exceeding AM* PM10 exceeding AM* PM2.5 exceeding 3 3 3 conc. (µg/m ) AM* NO2 conc. (µg/m ) AM* PM10 conc. (µg/m ) AM* PM2.5 objectives objective objective
CCZ -4.6 -4,579 -0.2 0 -0.1 0 IRR -3.8 -2,435 -0.1 0 -01 0 Inner -1.6 -10,472 0.0 0 0.0 0 Outer -0.9 -2,848 0.0 0 0.0 0 Non GLAA -0.6 -124 0.0 0 0.0 0 Total -1.1 -18,023 0.0 0 0 0
* AM = annual mean
(Source: Jacobs, derived from TfL / KCL, 2014)
Table 3.2 : Anticipated zone-wide average changes in NO2, PM10 and PM2.5 concentrations in 2025 for the ULEZ Package 1
Zone Average Change in no. Average Change in no. Average Change in no. change in receptors change in receptors change in receptors
AM* NO2 exceeding AM* PM10 exceeding AM* PM2.5 exceeding 3 3 3 conc. (µg/m ) AM* NO2 conc. (µg/m ) AM* PM10 conc. (µg/m ) AM* PM2.5 objectives objective objective
CCZ -2.3 -456 0.0 0 0.0 0 IRR -1.8 -304 0.0 0 0.0 0 Inner -0.6 -1,115 0.0 0 0.0 0 Outer -0.3 -309 0.0 0 0.0 0 Non GLAA -0.2 -12 0.0 0 0.0 0 Total -0.4 -1,892 0.0 0 0 0
* AM = annual mean
(Source: Jacobs, derived from TfL / KCL, 2014)
3.2.6 Additionally, the ULEZ Package 1 would result in reductions in the number of people living in areas above the NO2 and limit values in 2020 and 2025. Specifically in 2020, the ULEZ Package 1 would result in the following reductions of people living in areas above the NO2 annual limit value: Central Zone – reduction of 74 per cent; Inner Zone – reduction of 51 per cent; and Outer Zone – reduction of 43 per cent.
3.2.7 The ULEZ Package 1 would result in a large reduction in the number of care homes, hospitals and schools in areas of NO2 exceedences. The fall would be greatest in central London and is as follows: care homes – decreases from 1 (without ULEZ) to 0 (with the ULEZ Package 1); hospitals – decreased from 29 (without ULEZ) to 10 (with the ULEZ Package 1); schools – decreased from 27 (without ULEZ) to 4 (with the ULEZ Package 1).
Document No. 1 11 Addendum to the Integrated Impact Assessment (October 2014)
3.2.8 The ULEZ Package 1 would, for each year (2020 and 2025), improve the health ‘burden’ associated with the absolute levels of pollutant concentrations as calculated based on the relative change in burden in hospital admissions in 2020 and 2025. Specifically, the reduction in life years lost associated with pollution (NO2, PM10 and PM2.5) reductions across Greater London in 2020 would total 4,123. However, not all the mortality benefits would fall in the first year of implementation (2020). The size of the benefit would reduce between 2020 and 2025 amounting to 1,550 life years lost in the latter. This corresponds to the decrease in the pollutant reduction impact between 2020 and 2025. The benefits associated with reductions in NO2 concentrations are significantly larger than those delivered through reductions in PM due predominantly to the greater reductions in NO2 which would be achieved by the ULEZ. The equivalent savings in life years lost for 2020 and 2025 attributable to PM10 and PM2.5 only amounts to 123 life years lost and 26 life years lost respectively.
3.2.9 The health benefits noted in 3.2.8 for the ULEZ Package 1 were valued (i.e. presented in monetised terms) to show the economic benefit associated with reductions in air pollution. The improved health outcomes arising from the reduction in NOx, PM10, and PM2.5 would have a total monetised benefit of £101m in 2020 and £32m in 2025.
3.2.10 Other relevant impacts for the baseline as identified within the IIA (October 2014) include: from a road traffic emissions perspective, implementation of the ULEZ Package 1 would bring about London wide reductions in CO2 emissions.
the total population living in areas above the NO2 annual limit value in 2020 and 2025 is forecast to reduce as a result of the ULEZ Package 1. This reduction would be higher in the most deprived areas;
changes in NOx emissions resulting from the ULEZ may have an impact upon potentially sensitive nature conservation sites. The most substantial impacts of the ULEZ Package 1 in terms of total tonnage per annum change in NOx are likely to be upon the Sites of Special Scientific Interest (SSSI) Hampstead Heath Woods in Camden (95 tonnes in 2020 and 38 tonnes in 2025) and the five SSSIs in Hillingdon (77 tonnes in 2020 and 21 tonnes in 2025). The sites in Hillingdon are Denham Lock Wood, Fray’s Farm Meadows, Mid Colne Valley, Old Park Wood and Ruislip Woods.
borough level changes in NOx and PM10 as a result of the ULEZ may affect cultural heritage assets. The ULEZ Package 1 would have a positive impact on many of London’s cultural heritage receptors, particularly in terms of reducing damaging levels of NO2 which is a major contributing factor in acid rain.
Assessment of Update 1
3.2.11 Update 1 has the potential to influence air quality and health benefits and impacts identified on certain equality groups and London’s economy. As such, the assessment of Update 1 is broken down into four sections: 1) assessment for the environment; 2) assessment for health; 3) assessment for equalities groups; and 4) assessment for London’s economy and SMEs.
Document No. 1 12 Addendum to the Integrated Impact Assessment (October 2014)
1. Assessment for the environment
Determine, as a result of maintaining a 15 year age limit for taxis and introducing a voluntary decommissioning scheme for taxis older than 10 years, for the years 2020 and 2025:
(a) the reduced improvement in NO2 concentrations and in PM10 and PM2:5 emissions; (b) the reduction in the number of receptors forecast to no longer be exposed to concentrations exceeding the annual mean NO2 Air Quality Objective including for: across London, inner London and outer London;
(c) the reduced improvement of total road traffic CO2 emissions per annum; (d) the increase to the stated reduced risk of degradation of cultural heritage assets.
3.2.12 The air quality impacts of Update 1 in relation to the environment have been identified through undertaking an assessment against a ‘without ULEZ’ scenario. This assessment is provided in Appendix A and is a replacement of the air quality chapter of the Environmental Assessment (October 2014) for the ULEZ Package 2. The assessment is measured against annual mean concentration for 3 3 NO2 which is 40µg/m and the annual mean limit value for PM10 and PM2.5 which is 40µg/m and 25µg/m3 respectively.
3.2.13 The relevant impacts for this assessment from the IIA (October 2014) are copied in Table 3.3.
Table 3.3 : Environmental impacts from IIA (October 2014) for the ULEZ Package 1 relevant to Update 1
Relevant impacts identified in the IIA (October 2014) Scale of original impact
ULEZ Package 1 would result in air quality improvements in nitrogen dioxide (NO2) Major positive long concentrations in 2020 and 2025 term In 2020 ULEZ Package 1 would result in 18,000 receptors across London no longer Major positive long being exposed to concentrations exceeding the annual mean NO2 Air Quality Objectives term and a further 2,000 receptors no longer being exposed by 2025. The largest percentage reduction in receptors exceeding the Air Quality Objectives in 2020 would be in central London (approx. 4,500 or 86%), followed by Inner Zone (approx. 10,500 or 52%) and Outer Zone (approx. 2,800 or 33%)
ULEZ Package 1 would result in air quality improvements in particulate matter (PM2.5) Minor positive long concentrations and PM10 emissions in 2020 and 2025 term
ULEZ Package 1 would result in reductions in total road traffic CO2 emissions by 123,000 Minor positive long tonnes per annum in 2020 and 169,000 tonnes in 2025 in London term ULEZ Package 1 would result in a reduced risk of degradation of cultural heritage assets Minor positive long as a result of PM10 emissions. Most significant in CCZ (9% or 10tpa in 2020 and 3% or term 3tpa in 2025)
(Source: Jacobs, 2014)
Document No. 1 13 Addendum to the Integrated Impact Assessment (October 2014)
(a) NO2 concentrations and PM10 and PM2.5 emissions
3.2.14 The results from comparing a ‘without ULEZ’ scenario with the ULEZ Package 2 in relation to NO2 concentrations and PM10 and PM2.5 emissions are provided in the updated air quality chapter in Appendix A and compared with the ULEZ Package 1 results in the following.
3.2.15 The assessment found that the ULEZ Package 2 would result in very minor changes to the impacts identified in the IIA (October 2014), with the greatest differences occurring in 2025. A comparison of the ULEZ Package 1 compared to the ULEZ Package 2 is provided in Table 3.4 and visually represented in Figure 3.1 to Figure 3.4.
3.2.16 For Figure 3.1 to Figure 3.4 the darkest blue shade of colour represents the greatest level of change and the lightest blue shade of colour represents the least amount of change. The full figures for the ULEZ Package 2 can be sighted in the updated air quality chapter of the Environmental Assessment (October 2014) provided in Appendix A and the full figures for the ULEZ Package 1 can be sighted in the air quality chapter of the Environmental Assessment (October 2014) which can be found at https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone.
Table 3.4 : Comparison of air quality benefits – the ULEZ Package 1 versus the ULEZ Package 2
Variable The ULEZ The ULEZ The ULEZ The ULEZ Package 1 Package 2 Package 1 Package 2
2020 2020 2025 2025
Improvement in annual average mean NO2 4.6 4.5 2.3 1.8 concentrations in CCZ (µg/m3)
Improvement in annual average mean NO2 0.9 0.9 0.3 0.2 concentrations towards Outer Zone (µg/m3) Improvement in annual mean limit value 0.2 0.1 0.0 0.0 3 for PM10 concentrations in CCZ (µg/m ) Improvement in annual mean limit value 0.0 0.0 0.0 0.0 for PM10 concentrations towards Outer Zone (µg/m3) Improvement in annual mean limit value 0.1 0.1 0.0 0.0 3 for PM2.5 concentrations in CCZ (µg/m )
(Source: Jacobs, derived from TfL / KCL, 2015)
Document No. 1 14 Addendum to the Integrated Impact Assessment (October 2014)
ULEZ Package 2 ULEZ Package 1
Figure 3.1 : Comparison of the average change in NO2 concentrations (2020) between the ULEZ Package 2 and the ULEZ Package 1
ULEZ Package 2 ULEZ Package 1
Figure 3.2 : Comparison of the average change in PM10 concentrations (2020) between the ULEZ Package 2 and the ULEZ Package 1
Document No. 1 15 Addendum to the Integrated Impact Assessment (October 2014)
ULEZ Package 2 ULEZ Package 1
Figure 3.3 : Comparison of the average change in NO2 concentrations (2025) between the ULEZ Package 2 and the ULEZ Package 1
ULEZ Package 2 ULEZ Package 1
Figure 3.4 : Comparison of the average change in PM10 concentrations (2025) between the ULEZ Package 2 and the ULEZ Package 1
3.2.17 As represented in the data and figures, the ULEZ Package 2 (when compared to the ULEZ Package 1) results in the following changes to the impacts identified in the IIA (October 2014):
a slight worsening on average in annual NO2 concentrations in the CCZ in both 2020 (i.e. an improvement by 4.6µg/m3 drops to 4.5µg/m3) and 2025 (i.e. an improvement by 2.3µg/m3 drops to 1.8µg/m3);
no change in annual NO2 concentrations towards the Outer Zone in 2020;
a slight worsening on average in annual mean NO2 concentrations towards the Outer Zone in 2025 (i.e. an improvement by 0.3µg/m3 falls to 0.2µg/m3);
a slight worsening on average in annual mean PM10 concentrations in the CCZ in 2020 (i.e. an improvement of 0.2µg/m3 falls to 0.1µg/m3);
no change in annual PM10 concentrations towards the Outer Zone in 2025; and
no change in PM2.5 concentrations.
Document No. 1 16 Addendum to the Integrated Impact Assessment (October 2014)
3.2.18 Overall the ULEZ Package 2 with Update 1 would result in a slight worsening to the air quality benefits identified in the IIA (October 2014) for both 2020 and 2025. This impact would mainly affect the air quality within the CCZ. The air quality towards the Outer Zone remains largely comparable as a result of TfL proposing to upgrade an additional 400 Euro V buses to Euro VI to operate outside the CCZ / ULEZ area.
(b) Receptors forecast to no longer be exposed to concentrations exceeding the annual mean NO2 Air Quality Objective
3.2.19 The results from comparing a ‘without ULEZ’ scenario with the ULEZ Package 2 in relation to the number of properties located in areas exceeding NO2 AQO’s are provided in the updated air quality chapter in Appendix A and compared with the ULEZ Package 1 results in the following.
Table 3.5 : Comparison of number of receptors no longer located in areas exceeding NO2 Air Quality Objectives in 2020 – the ULEZ Package 1 versus the ULEZ Package 2
Variable The ULEZ Package The ULEZ Package Difference 1 2
Number of receptors no longer located in areas 4,579 4,522 -57 exceeding NO2 AQO’s in CCZ Number of receptors no longer located in areas 10,472 10,581 +109 exceeding NO2 AQO’s in Inner Zone Number of receptors no longer located in areas 2,848 2,943 +95 exceeding NO2 AQO’s in Outer Zone Number of receptors no longer located in areas 124 128 +4 exceeding NO2 AQO’s in Non-GLAA Total number of receptors no longer located 18,023 18,174 +151 in areas exceeding NO2 AQO’s
(Source: Jacobs, derived from TfL / KCL, 2015)
Table 3.6 : Comparison of number of receptors no longer located in areas exceeding NO2 Air Quality Objectives in 2025 – the ULEZ Package 1 versus the ULEZ Package 2
Variable The ULEZ Package The ULEZ Package Difference 1 2
Number of receptors no longer located in areas 456 379 -77 exceeding NO2 AQO’s in CCZ Number of receptors no longer located in areas 1,115 965 -150 exceeding NO2 AQO’s in Inner Zone Number of receptors no longer located in areas 309 245 -64 exceeding NO2 AQO’s in Outer Zone Number of receptors no longer located in areas 12 12 0 exceeding NO2 AQO’s in Non-GLAA Total number of receptors no longer located 1,892 1,601 -291 in areas exceeding NO2 AQO’s
Document No. 1 17 Addendum to the Integrated Impact Assessment (October 2014)
(Source: Jacobs, derived from TfL / KCL, 2015)
3.2.20 The assessment found that the ULEZ Package 2 would result in an overall improvement in the number of receptors no longer located in areas exceeding NO2 AQO’s in 2020. Specifically, in 2020, an additional 151 receptors would no longer be located in areas exceeding NO2 AQO’s. These results are a reflection of the model for the ULEZ Package 2 incorporating proposals by TfL to upgrade an additional 400 non-CCZ Euro V buses to Euro VI.
3.2.21 In 2025 there would be 291 fewer receptors being no longer located in areas exceeding NO2 AQO’s as a result of the ULEZ Package 2.
(c) Road traffic CO2 emissions
3.2.22 The minor positive long term impact associated with reductions in CO2 emissions as identified in the IIA (October 2014) for the ULEZ Package 1 was provided for all road traffic attributable to CO2 emissions and was not broken down by mode of transport. The Environmental Assessment however did provide a breakdown of these reductions per mode of transport. As Update 1 relates to taxis, it is important that the assessment is related to taxis only and their contribution to reductions in CO2 emissions for 2020 and 2025.
3.2.23 Therefore, for the purposes of this assessment, of the identified reduction in total London wide CO2 emissions in the IIA (October 2014) of 123,000 tonnes per annum for 2020, taxis account for 82,232 tonnes or 66.8 per cent of this. Further to this, of the identified reduction of CO2 emissions of 169,000 tonnes per annum for 2025, taxis account for 108,235 tonnes per annum or 64 per cent.
3.2.24 The ULEZ Package 2 would result in a total reduction in CO2 emissions across London of 109,140 tonnes per annum for 2020 and 147,139 tonnes per annum for 2025 of which taxis account for 68,746 tonnes or 63 per cent in 2020 and 112,325 tonnes or 76.3 per cent in 2025.
3.2.25 For taxis, the ULEZ Package 2 would result in a reduced improvement of CO2 emissions per annum when compared to the ULEZ Package 1. However, the ULEZ Package 2 would still result in an overall improvement of CO2 emissions per annum when compared to a without ULEZ scenario. Improvements in CO2 emissions directly and indirectly contribute towards climate change and assist with reducing greenhouse gas emissions.
(d) Degradation of cultural heritage assets
3.2.26 Pollutants principally responsible for causing acid rain are sulphur dioxide and oxides of nitrogen. Reductions in NOx emissions can result in benefits for cultural heritage assets as almost all materials are affected by the deposition of acid.
3.2.27 As the ULEZ Package 2 would provide for reductions in NOx emissions, similarly to the ULEZ Package 1 it would have positive impacts upon many of London’s cultural heritage receptors, particularly in terms of reducing damaging levels of NOx, a major contributing factor in acid rain. It would also result in a reduced risk of degradation of cultural heritage assets as a result of PM10 emissions.
3.2.28 The IIA (October 2014) identified that the ULEZ Package 1 provided for a reduced risk of cultural heritage asset degradation in central London, through PM10 emissions, of nine per cent or 10 tonnes per annum in 2020 and three per cent or three tonnes per annum in 2025, the ULEZ Package 2 would provide for a reduced risk of degradation of eight per cent or eight tonnes per annum in 2020 and two per cent or two tonnes per annum in 2025. This impact is as a result of exhaust and non-exhaust6 PM10 emissions.*
*These calculations have been based on updated and more accurate baseline emissions data. This updated data does not change the outcome of the assessment.
6 Non-exhaust sources of PM include brakes, tyres and re-suspension, of which re-suspension is not generally considered directly attributable to road traffic.
Document No. 1 18 Addendum to the Integrated Impact Assessment (October 2014)
3.2.29 As the ULEZ only targets vehicle exhausts, the reduced risk of cultural heritage asset degradation in central London from the ULEZ Package 2 through a reduction in PM10 emissions from vehicle exhausts, would be 47 per cent or five tonnes per annum in 2020 and 26 per cent or one tonne per annum in 2025.
2. Assessment for health
Determine, as a result of maintaining a 15 year age limit for taxis, for the years 2020 and 2025:
(a) the increase in the number of people living in areas above NO2 annual limit value;
(b) the increase in the number of care homes, hospitals and schools in areas exceeding NO2 Air Quality Objectives; (c) the reduced number of life years lost; (d) the reduced estimate of monetised benefit.
3.2.30 The air quality impacts of Update 1 in relation to health have been identified through undertaking an assessment against a ‘without ULEZ’ scenario. This assessment has been informed by Ricardo-AEA and is provided in Appendix B. The assessment is measured against annual mean concentration for 3 3 NO2 which is 40µg/m and the annual mean limit value for PM10 and PM2.5 which is 40µg/m and 25µg/m3 respectively.
3.2.31 The relevant impacts for this assessment as copied from the IIA (October 2014) are provided in Table 3.7
Table 3.7 : Health impacts from the IIA (October 2014) relevant to Update 1
Relevant impacts identified in the IIA (October 2014) Scale of original impact ULEZ Package 1 would result in reduction in the number of people living in areas above Major positive long NO2 annual limit value in 2020 and 2025 term ULEZ Package 1 would result in reduction in the number of care homes, hospitals and Major positive long schools in areas exceeding the NO2 Air Quality Objectives (AQOs) across London term (greatest in central London) ULEZ Package 1 would result in reductions of 4,123 life-years lost across Greater Moderate positive London, however this reduces in 2025 long term ULEZ Package 1 would result in improved health outcomes estimated to have a total Moderate positive monetised benefit of £101m in 2020 and £32m in 2025 long term
(Source: Jacobs, 2014)
(a) People living in areas above NO2 annual limit value
3.2.32 The ULEZ Package 2 would, similarly to the ULEZ Package 1, result in a reduction in the number of people living in areas above NO2 annual limit value in 2020 and 2025. Specifically, in 2020, the ULEZ Package 2 would result in the following reductions of people living in areas above NO2 annual limit value as follows: Central Zone – reduction of 72 per cent; Inner Zone – reduction of 52 per cent; and Outer Zone – reduction of 42 per cent.
Document No. 1 19 Addendum to the Integrated Impact Assessment (October 2014)
3.2.33 The number of people living in areas above NO2 annual limit value in 2020 and 2025 is shown in Table 3.8.
Table 3.8 : Comparison of population living in areas above NO2 annual limit value in 2020 and 2025
Year Zone Number of people % population living
Baseline The ULEZ The ULEZ The ULEZ The ULEZ Package 1 Package 2 Package 1 Package 2
2020 Central 123,454 32,127 33,995 16.4% 17.4% Inner 434,290 212,934 208,882 6.2% 6.1% Outer 95,207 54,719 54,822 1.0% 1.0% London-wide 652,951 299,780 297,700 3.3% 3.3% 2025 Central 34,374 6,491 9,859 3.2% 4.9% Inner 77,528 45,009 50,862 1.3% 1.4% Outer 10,658 6,707 7,558 0.1% 0.1% London-wide 122,559 58,207 68,280 0.6% 0.7%
(Source: Ricardo-AEA, 2014 and 2015)
3.2.34 As per Table 3.8, the ULEZ Package 2, when compared with the ULEZ Package 1 would result in:
an additional 1,868 people still living in areas above NO2 annual limit value in the Central Zone in 2020 and 3,368 in 2025;
a decrease of people living in areas above NO2 annual limit value in the Inner Zone of 4,052 in 2020;
an additional 3,368 people still living in areas above NO2 annual limit value in the Central Zone in 2025; and
an additional 103 people still living in areas above NO2 annual limit value in the Outer Zone in 2020 and 851 in 2025.
3.2.35 While overall the ULEZ Package 2 results in additional people still living in areas above NO2 annual limit value when compared to the ULEZ Package 1, it still results in a significant improvement on a ‘without ULEZ’ scenario. The decrease in people living in areas above NO2 annual limit value in the Inner Zone in 2020 would be attributable to TfL committing to upgrade an additional 400 non-CCZ Euro V buses to Euro VI.
(b) Care homes, hospitals and schools in areas exceeding NO2 AQOs
3.2.36 The ULEZ Package 2 will result in one care home, 19 hospitals and 21 schools no longer being located in areas exceeding the NO2 AQOs across London. A comparison of these figures against those reported in the IIA (October 2014) for the ULEZ Package 1 is provided in Table 3.9.
3.2.37 For care homes and hospitals, there is no difference between the ULEZ Package 2 and the ULEZ Package 1. However for schools, the ULEZ Package 2 would mean that, when compared to the ULEZ Package 1, an additional two schools would remain located in areas of NO2 exceedence.
3.2.38 Overall, the ULEZ Package 2 would result in positive benefits for care homes, hospitals and schools.
Document No. 1 20 Addendum to the Integrated Impact Assessment (October 2014)
Table 3.9 : Comparison of the number of care homes, hospitals and schools located within areas of NO2 exceedences
No. within areas of NO2 No. within areas of NO2 No. within areas of NO2 exceedences Without exceedences with ULEZ exceedences with ULEZ ULEZ Package 1 Package 2
Care homes 1 0 0 Hospitals 29 10 10 Schools 27 4 6
(Source: Ricardo-AEA, 2014 and 2015)
(c) Life years lost
3.2.39 The ULEZ Package 2 would result in 4,192 life-years lost across greater London associated with pollution (NO2, PM10, PM2.5). This is compared to 4,123 life-years lost across Greater London for the ULEZ Package 1 which is an increase of 69 life-years lost. This increase is expected as a result of the slight overall decrease in concentrations when comparing the two ULEZ scenarios.
3.2.40 Overall, the results of the core air quality health impacts analysis undertaken by Ricardo-AEA suggest that the ULEZ Package 2 would deliver positive health benefits relative to the base-case in both modelled years of the study. The size of the benefit is seen to reduce between 2020 and 2025 corresponding to the decrease in the pollutant reduction impact, over and above the baseline, between the two study years.
(d) Monetised benefit
3.2.41 Ricardo-AEA has employed the Defra Impact Pathway Approach Guidance to estimate the monetary values attributable to the impacts on health. The improved health outcomes arising from the reduction in NOx, PM10 and PM2.5 under the ULEZ Package 2 for the Greater London Administrative Area (GLAA) are estimated to have a total monetised benefit of £103m in 2020 and £27m in 2025. This is compared to a total monetised benefit of £101m in 2020 and £32m in 2025 for the ULEZ Package 1.
3.2.42 The increase by £2m in 2020 is as a result of TfL proposing to upgrade an additional 400 Euro V buses to Euro VI to operate outside the CCZ / ULEZ area as this would slightly improve NO2 concentrations towards the Outer Zone (when compared to the ULEZ Package 1).
3. Assessment for equalities groups
Determine whether maintaining a 15 year age limit would: (a) reduce the positive differential impact on school age children, older people and pregnant women; (b) provide incentive for those licensed taxi drivers who are older than (60+) and who may have otherwise chosen to retire early rather than upgrade to a ZEC vehicle; and (c) result in more available taxis reducing the differential impact on woman and the LGBT community who may fear for their safety at night.
3.2.43 The relevant impacts for this assessment as copied from the IIA (October 2014) are provided in Table 3.10.
Document No. 1 21 Addendum to the Integrated Impact Assessment (October 2014)
Table 3.10 : Equality impacts from the IIA (October 2014) relevant to Update 1
Relevant impacts identified in the IIA (October 2014) Scale of original impact ULEZ Package 1 would result in a minor long term beneficial reduction in the average Minor positive long exposure to NO2 for all people in 2020 and 2025 however this would be greater for those term in deprived areas as the average level of reduction on NO2 concentrations is higher in the most deprived areas ULEZ Package 1 would have a positive differential impact on school age children, older Moderate positive people and pregnant women. This is as a result of the reduction of sensitive receptors long term (schools, care homes and hospitals) that would be in areas which experience exceedences in NO2 emissions Lowering the taxi age limit may have a disproportionate effect on the third of licensed taxi Minor negative drivers who are older (60+) who may choose to retire early rather than upgrade to a ZEC short-medium vehicle term ULEZ Package 1 may have a differential effect on women and the Lesbian, Gay, Minor negative Bisexual and Transgender (LGBT) community arising from increased fear for personal short-medium safety in central London and other town centres in Greater London at night as a result of term a potential decrease of available taxis.
(Source: Jacobs, 2014)
(a) Population living in deprived areas
3.2.44 Similarly to the ULEZ Package 1, the ULEZ Package 2 is forecast to reduce exposure to NO2 on average for all people in both 2020 and 2025.
3.2.45 The areas identified as deprived in the ULEZ Package 1 has not changed and therefore the average level of reduction on NO2 concentrations as a result of the ULEZ Package 2 would still be higher in the most deprived areas.
(b) School age children, older people and pregnant women
3.2.46 As per Table 3.9, when compared to a without ULEZ scenario, the ULEZ Package 2, similar to ULEZ Package 1, would result in a reduction of sensitive receptors (schools, care homes and hospitals) that would be in areas which experience exceedences in NO2 AQOs. Therefore the ULEZ Package 2 would still result in a positive differential impact on school age children, older people and pregnant women.
3.2.47 However, the ULEZ Package 2 would have slightly less benefit for school age children than the ULEZ Package 1. When compared against a without ULEZ scenario, the ULEZ Package 2 would result in 21 schools no longer being located within areas exceeding the NO2 AQOs across London, whereas the ULEZ Package 1, when compared against a without ULEZ scenario, would result in 23 schools no longer being located within areas exceeding the NO2 AQOs across London. Regardless, the ULEZ Package 2 still results in benefits for school age children.
3.2.48 There is no difference in the impact on older people and pregnant women as the ULEZ Package 2 results in the same outcomes as the ULEZ Package 1 in terms of improvements for those using care homes and hospitals.
(c) Taxi drivers older than 60+ years
3.2.49 Following the original consultation undertaken by TfL, the proposal for the ULEZ Package 1 to reduce the taxi age limit from 15 years has been met with strong resistance as the proposed reduction in the taxi age limit would result in a large number of taxis no longer being licensed from 2020. Specifically, for the ULEZ Package 1, approximately 3,500 taxis of the total fleet (approximately 22,000 taxis)
Document No. 1 22 Addendum to the Integrated Impact Assessment (October 2014)
would no longer be able to be licensed from 2020. Of these it was estimated that approximately 600 vehicles are owned by people over 65.
3.2.50 As the ULEZ Package 2 proposes to maintain the current age limit of 15 years, there would no longer be a disproportionate impact on the one third of the taxi drivers who are older (60+) as a result of the ULEZ.
(d) Women and LGBT community
3.2.51 The impact on women and the LGBT community was linked to the potential decrease in the number of taxis available at night resulting from the one third of older taxis drivers who may have chosen to retire earlier rather than upgrade their vehicle. However, as the ULEZ Package 2 is proposing to maintain the existing licensing requirements, the ULEZ Package 2 will no longer have a differential impact on women and the LGBT community.
4. Assessment for London’s economy and SMEs
Determine whether maintaining a 15 year age limit would result in: (a) a reduced estimate of monetised benefit.
3.2.52 The relevant impacts for this assessment as copied from the IIA (October 2014) are provided in Table 3.11.
Table 3.11 : Economic impacts from IIA (October 2014) relevant for Update 1
Relevant impacts identified in the IIA (October 2014) Scale of original impact
The improved health outcomes arising from the reduction in NOX, PM10 and PM2.5 under Moderate positive the ULEZ Package 1 for the Greater London Authority area are estimated to have a total long term monetised benefit of £101m in 2020 and £32m in 2025 ULEZ Package 1 would result in a 1-2% loss to the night time economy and 0.2% loss to Minor negative the tourist sector (of which taxis fall within) and an overall loss of 0.03-0.08% short-medium term
(Source: Jacobs, 2014)
(a) Monetised benefit
3.2.53 As assessment of the ULEZ Package 1 identified that improved health outcomes arising from the reduction in NOx, PM10, and PM2.5 would have a total monetised benefit of £103m in 2020 and £27m in 2025. This increases by £2m in 2020 with the ULEZ Package 2 however decreases by £5m in 2025.
(b) Loss to night time economy and tourist sector
3.2.54 ULEZ Package 2 would not change the current licensing requirements. Therefore, as taxis contribute to the night time economy and tourist sector, the ULEZ Package 2 would lessen the impact previously identified in the IIA (October 2014) on the night time economy and tourist sector.
Document No. 1 23 Addendum to the Integrated Impact Assessment (October 2014)
3.3 Summary of impacts of Update 1
3.3.1 The adoption of Update 1 would be positive for the taxi industry and also certain equality groups7. However, whilst positive for the taxi industry overall, the updates would result in reductions to the air quality and health benefits identified in the IIA (October 2014) for 2020 and 2025. Having regard to the reductions, TfL is proposing to implement measures that fill an ‘emissions gap’ (i.e. the difference in emissions between the overall ULEZ package with a 10 year and 15 year taxi age limit). Specifically TfL is proposing to retrofit an additional 400 Euro V TfL buses to meet the Euro VI standard which will operate outside the CCZ area as well as proposing a zero emission double-decker bus trial and a Low Emission Neighbourhood in central London.
3.3.2 The adoption of Update 1 would not result in any changes to the impacts on London’s economy or small medium business enterprises (SME’s) as identified in the IIA (October 2014).
3.3.3 Overall, the adoption of Update 1 together with TfL’s proposal to retrofit an additional 400 TfL buses outside the ULEZ area would still guarantee emission savings by removing the oldest, most polluting taxis from the fleet compared to a ‘without ULEZ’ scenario.
7 When compared with the ULEZ Package 1 and the impacts included in the IIA (October 2014)
Document No. 1 24 Addendum to the Integrated Impact Assessment (October 2014)
4. Updates for Private Hire Vehicles
Update 2: Introduce a transition period for PHVs that carry six or more passengers which would mean that: (a) those presented for licensing from 1 January 2018 would need to meet Euro 6 emission standards; and (b) those presented for licensing from 1 January 2020 would need to be ZEC
Update 3: Alter the definition of what constitutes a ZEC PHV to:
(a) ≤50g/km CO2 and minimum zero emission range of 10 miles; or
(b) >50g/km and <75g/km CO2 and minimum zero emission range of 20 miles
4.1 Background
4.1.1 In 2020, emissions from PHVs are estimated to make up four per cent of the total road transport NOx emissions in central London.
4.1.2 Currently, to qualify for a PHV licence, most new vehicles or vehicles new to licensing must be no older than five years and meet Euro 4 emission standards at the time of licensing8. PHV’s excluded from this rule (as of 1 January 2015) include full electric and petrol hybrid vehicles which emit less 9 than 110g/km CO2 as defined by the manufacturer .
4.1.3 The ULEZ Package 1 required all vehicles, new or up to 18 months old, presented for PHV licensing for the first time from 1 January 2018 to be ZEC where a ZEC PHV was defined as having: a minimum zero emission range of 30 miles; and
a maximum CO2 emission limit of 50g/km.
4.1.4 The ULEZ Package 1 also required that all older or second hand vehicles (i.e. those over 18 months old) licensed as a PHV for the first time must meet the ULEZ Standards which requires the vehicles to be of Euro 4 (petrol) or Euro 6 (diesel) emission standards from 1 January 2018. The five year age limit remained for vehicles that have already been licensed as a PHV and are being re-licensed.
4.1.5 Most impacts identified in the IIA (October 2014) for PHVs relate to compliance with the ULEZ Standards rather than the licensing requirement that any new PHV (as defined) had to be a ZEC vehicle from January 2018. Some financial impacts for individuals from Black, Asian and Minority Ethnic (BAME) groups were identified, as this group is disproportionately represented in the PHV industry. However, it was anticipated that this would be offset by the availability and price of compliant second hand vehicles and by the OLEV plug-in car and van grant, helping drivers to switch to newer vehicles.
8 Transport for London. (2015). Private hire vehicle licence. Accessed on 19 February 2014 from: https://www.tfl.gov.uk/info-for/taxis-and-private- hire/become-a-private-hire-licensee/private-hire-vehicle-licence 9 Transport for London. (2014). Newly Licensed Private Hire Vehicles – Hybrid Vehicles. Notice 17/14. Issued 23 December 2014.
Document No. 1 25 Addendum to the Integrated Impact Assessment (October 2014)
4.1.6 From April 2015 three categories of OLEV grants became available for cars, differentiating between 10 ultra low emission vehicles on the basis of their CO2 emissions and their zero emission range . They include:
category 1: CO2 emissions of less than 50g/km and a zero emission range of at least 70 miles;
category 2: CO2 emissions of less than 50g/km and a zero emission range between 10 and 69 miles; and
category 3: CO2 emissions of 50-75g/km and a zero emission range of at least 20 miles.
4.2 Update 2 – two year ‘sunset period’ exemption from the ZEC requirement for PHVs that carry 6 or more passengers
4.2.1 Jacobs did not previously undertake an assessment for this sub-sector of the PHV market and therefore no impacts on air quality, health, equality groups or London’s economy and SMEs were identified specifically for PHVs that carry 6 or more passengers in the IIA (October 2014).
4.2.2 Given that the PHVs do not contribute significantly to emissions in central London i.e. total contribution of four per cent NOx from road transport in 2020 it is unlikely that the proposal in ULEZ Package 2 for a 2 year sunset period exemption from the ZEC requirement for PHVs that carry 6 or more passengers would result in a change to the benefits and impacts identified within the IIA (October 2014) and this report.
4.3 Update 3 – change to definition of ZEC PHV
Baseline for assessment
4.3.1 A PHV includes 'any vehicle that seats up to eight passengers and is available for hire with a driver who has a PHV licence'11.
4.3.2 As of early 2015, there were 63,000 licensed PHVs in London (TfL, 2015). PHVs can only be pre- booked and do not have to be wheelchair accessible.
4.3.3 A summary of the PHV vehicle market is provided in Table 4-1.
Table 4.1 : Summary of PHV vehicle market
Type of PHV Approximate % of PHV fleet Saloon (e.g. 5 seater) 50 People carrier 30 Luxury 15 Non-car (e.g. accessible) 5
(Source: TfL, 2014)
4.3.4 Based on TfL's current understanding of ZEC vehicles suitable for private hire and on the market in 2015, approximately only 20 vehicle models would have a minimum zero emission range of 30 miles (ie the minimum range proposed as part of ULEZ Package 1). Manufacturers currently producing cars with a minimum range of 30 miles include BMW, Nissan, Audi, Volkswagen, Renault and Mitsubishi12.
10 Office for Low Emission Vehicles. (2015). Guidance: Plug-in car grant eligibility guidance. Updated on 13 February 2015. Accessed on 19 May 2015 from https://www.gov.uk/government/publications/plug-in-car-grant/plug-in-car-grant-vehicles#changes-to-the-plug-in-car-grant-from-april- 2015 11 Transport for London (TfL). (Year unknown). Private hire vehicle licence. Accessed on 5 February 2015 from: https://www.tfl.gov.uk/info-for/taxis- and-private-hire/become-a-private-hire-licensee/private-hire-vehicle-licence 12 Go Ultra Low. (2015). What Go Ultra Low cars are right for me? Car Menu. Accessed on 23 February 2015 from: https://www.goultralow.com/car- selector/
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Assessment of Update 3
4.3.5 Update 3 has the potential to influence impacts identified on certain equality groups and London’s economy. As such, the assessment of Update 3 is broken down into two sections: 1) assessment for equalities groups; and 2) assessment for London’s economy and SMEs.
4.3.6 Update 3 has negligible changes in air quality and therefore changes to air quality and health impacts have not been assessed.
1. Assessment for equalities groups
Determine whether the change in definition of what constitutes a ZEC PHV to the criteria outlined would reduce or remove the equality impacts on the BAME community who are disproportionally represented as PHV drivers
4.3.7 The relevant impacts for this assessment as copied from the IIA (October 2014) are provided in Table 4-2.
Table 4.2 : Impacts from IIA (October 2014) relevant to Update 3
Relevant impacts identified in the IIA (October 2014) Scale of original impact Black and Minority Ethnic (BAME) people are disproportionately represented as PHV Minor negative drivers and therefore any additional costs from the proposed ZEC licensing requirement short-medium may impact upon this group disproportionately term
(Source: Jacobs, 2014)
4.3.8 The IIA (October 2014) identifies that the majority of PHV drivers are from BAME groups (43 per cent Asian / Asian British, 10 per cent Black / Black British).
4.3.9 As per Update 3, additional vehicles which have a zero emission range of 20 miles or 10 miles could be purchased and licensed as a PHV.
4.3.10 For those vehicles that have a zero emission range of 10 miles, one vehicle, additional to those currently known to be available, that could be purchased and licensed as a PHV, is a Toyota Prius plug-in, which has a zero emission range of around 15 miles and currently is the only widely available ZEC vehicle suitable for PHV use which costs just under £30,000. While this update would not remove the disproportionate impact on BAME groups, it may assist with providing more market competition and affordable options for complying with the ZEC licensing requirement after 2018.
4.3.11 Similarly, as Update 3 will result in the availability of a wider range of ZEC vehicles suited to the PHV market, it is likely that this would result in more affordable options for those PHV operators and drivers who need to replace existing PHVs as a result of ULEZ, and want to buy a new vehicle.
4.3.12 It is acknowledged that the number of ZEC vehicles suited to the PHV market is expected to increase over time, whereby there would be sufficient models that cover the range of services being offered. This is supported by current information available from the Department for Transport, which notes that the popularity of ultra-low emission vehicles continues to grow13.
13 Department for Transport. (2015). Take-up of plug-in car grant continues to rise. Accessed on 19 February 2015 from: https://www.gov.uk/government/news/take-up-of-plug-in-car-grant-continues-to-rise
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2. Assessment for London’s economy
Determine whether the change in definition of what constitutes a ZEC PHV to the criteria outlined would reduce or remove the financial impact on those PHV operators who are an SME as identified in the IIA (October 2014)
4.3.13 The relevant impacts for this assessment as copied from the IIA (October 2014) are provided in Table 4-3.
Table 4.3 : Impacts from IIA (October 2014) relevant to Update 3
Relevant impacts identified in the IIA (October 2014) Scale of original impact The total costs to businesses of either complying with the ULEZ or paying the charge is Minor negative expected to be around £120-250m in the first year which will fall disproportionately on short-medium SMEs but will diminish over time as the proportion of vehicles becoming compliant term increases.
(Source: Jacobs, 2014)
4.3.14 Update 3 would increase the range of ZEC vehicles suited to the PHV market that would be available to purchase and be eligible for the £5,000 OLEV plug-in car grant.
4.3.15 The eligibility of the Toyota Prius plug-in, as well as other lower cost vehicles, over time as they come onto the market, may assist with lessening the total costs to businesses of complying with the ULEZ. Therefore, Update 3 would lessen the impact identified in Table 4-3.
Summary of impacts of Update 3
4.3.16 As per current market knowledge, the ULEZ Package 1 would result in approximately 20 different types of vehicle being available for purchase on the market. This number is expected to increase between now and 2018 and more generally over time as popularity of ultra-low emission vehicles continues to rise, and manufacturers bring more models onto the market.
4.3.17 The increase in the number of vehicles available for purchase and licencing as PHVs would provide greater range in terms of make / model and affordability and may help to reduce financial impacts on PHV drivers and operators. Update 3 would also slightly increase the number of models available.
4.3.18 Update 3 would align with the OLEV plug-in grant eligibility criteria making compliance with the requirement for all newly licenced PHV to be ZEC from 2018 more affordable and reducing the impacts identified in Table 4.2 and Table 4.3.
4.4 Impacts of Update 2 and 3 on PHVs
4.4.1 The proposed Update 2 and 3 would have a positive impact on the PHV industry.
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5. Summary and conclusions
5.1 Summary of proposed taxi and PHV updates
5.1.1 TfL is proposing updates to the ULEZ Package 1 as summarised in Table 5.1.
Table 5.1 : Summary of updates to the ULEZ taxi and PHV licensing proposals
Update number Description
1 Maintain current 15 year age limit for taxis (coupled with introducing a voluntary decommissioning payments scheme for those taxis that would be older than 10 years in 2020) 2 Introduce a transition period for PHVs that carry six or more passengers which would mean that: (b) those presented for licensing from 1 January 2018 would need to meet Euro 6 emission standards; and (c) those presented for licensing from 1 January 2020 would need to be ZEC 3 Alter the definition of what constitutes a ZEC PHV to:
(a) ≤50g/km CO2 and minimum zero emission range of 10 miles; or
(b) >50g/km and <75g/km CO2 and minimum zero emission range of 20 miles
5.2 Impact of proposed updates
5.2.1 Similarly to the ULEZ Package 1, overall the ULEZ Package 2 would make a strong and lasting positive contribution to London’s environment and health and wellbeing of those who live, work and visit it. The positive impacts resulting from the ULEZ Package 2 are in contrast to the do-nothing scenario. The changes to impacts identified in the IIA (October 2014) for the ULEZ Package 1 and the impacts identified in this report for ULEZ Package 2 are as follows.
5.3 Changes to air quality impacts
5.3.1 The ULEZ Package 2 would result in improvements to air quality, however, on average, improvements in annual mean concentrations of NO2 and PM10 would be slightly worse compared to Package 1. TfL is therefore proposing mitigation measures, including the retrofit of 400 Euro V TfL buses to meet the Euro VI standard as well as a zero emission double-decker bus trial and a Low Emission Neighbourhood in central London to help offset any emission gap as a result of the update.
5.4 Changes to health impacts
5.4.1 The ULEZ Package 2 would result in minor changes to health benefits identified for the ULEZ Package 1. Specifically, the ULEZ Package 2 would have slightly less benefit for school age children than the ULEZ Package 1, the number of life-years lost would increase and the monetised benefit would improve for 2020.
5.5 Changes to impacts on equality groups
5.5.1 Some impacts identified in the IIA (October 2014) on certain equality groups would be removed as a result of the ULEZ Package 2. Specifically, these proposed taxi and PHV licensing proposals would no longer impact: the third of licensed taxi drivers who are older (60+) who may choose to retire early rather than upgrade to a ZEC taxi vehicle; and
Document No. 1 29 Addendum to the Integrated Impact Assessment (October 2014)
women and the LGBT community who may experience increased fear for personal safety in central London and other town centres in Greater London at night as a result of a potential decrease of available taxis.
5.5.2 The ULEZ Package 2 would also result in a reduction of impact on BAME PHV drivers.
5.6 Changes to impacts on London’s economy and SMEs
5.6.1 In 2020, the ULEZ Package 2, when compared to the ULEZ Package 1, results in an improvement in the health outcomes arising from the reduction in NOx, PM10 and PM2.5 for the Greater London Administrative Area (GLAA). Specifically, the ULEZ Package 2, when compared against a without ULEZ scenario, is estimated to result in a total monetised benefit of £103m to in 2020. This is compared with the ULEZ Package 1 which against a without ULEZ scenario was estimated to have a total monetised benefit of £101m in 2020. However, the ULEZ Package 2, when compared with the ULEZ Package 1, would result in a slight worsening in health outcomes in 2025.
5.6.2 A summary of the changes to impacts identified in the IIA (October 2014) and discussed within this report is provided in Table 5.2.
Table 5.2 : Summary of changes to the impacts identified in the IIA (October 2014) for the ULEZ Package 2
Relevant impacts identified in IIA (October 2014) as Scale of Relevant Change to scale Cross a result of Package 1 impact update of impact with reference to assessed Package 2 relevant section of report
Environmental impacts ULEZ would result in air quality improvements in Major Update 1 Worsened but 3.2.17 nitrogen dioxide (NO2) concentrations in 2020 and positive long still major 2025 term positive long term In 2020 ULEZ would result in approximately 18,000 Major Update 1 Improved in 3.2.19 receptors across London no longer being exposed positive long 2020 but still 3.2.20 to concentrations exceeding the annual mean NO2 term major positive Air Quality Objectives and a further 2,000 receptors long term no longer being exposed by 2025. The largest percentage reduction in receptors exceeding the Air Quality Objectives in 2020 would be in central London (approx. 4,500 or 86%), followed by Inner Zone (approx. 10,500 or 52%) and Outer Zone (approx. 2,800 or 33%) ULEZ would result in air quality improvements in Minor Update 1 Worsened but 3.2.17 particulate matter (PM2.5) concentrations and PM10 positive long still minor emissions in 2020 and 2025 term positive long term overall ULEZ would result in reductions in total road traffic Minor Update 1 Worsened but 3.2.24 CO2 emissions by 123,000 tonnes per annum in positive long still minor 3.2.25 2020 and 169,000 tonnes in 2025 in central term positive long London. term overall ULEZ would result in a reduced risk of degradation Minor Update 1 Worsened but 3.2.28 of cultural heritage assets as a result of PM10 positive long still minor 3.2.29 emissions. Most significant in CCZ (9% or 10tpa in term positive long 2020 and 3% or 3tpa in 2025) term overall
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Relevant impacts identified in IIA (October 2014) as Scale of Relevant Change to scale Cross a result of Package 1 impact update of impact with reference to assessed Package 2 relevant section of report
Health impacts ULEZ would result in reduction in the number of Major Update 1 Slightly 3.2.33 people living in areas above NO2 annual limit value positive long worsened but 3.2.35 in 2020 and 2025 term still major positive long term overall ULEZ would result in reduction in the number of Major Update 1 Slightly 3.2.37 care homes, hospitals and schools in areas positive long worsened but exceeding the NO2 Air Quality Objectives (AQOs) term still major across London (greatest in central London) positive long term overall ULEZ would result in reductions of 4,123 life-years Moderate Update 1 Slightly 3.2.39 lost across Greater London in 2020, however this positive long worsened but reduces in 2025 term still moderate positive long term overall ULEZ would result in improved health outcomes Moderate Update 1 Slightly 3.2.41 estimated to have a total monetised benefit of positive long improved for 3.2.42 £101m in 2020 and £32m in 2025 term 2020 but still moderate positive long term overall Equality impacts ULEZ would result in a minor long term beneficial Minor Update 1 No change 3.2.44 reduction in the average exposure to NO for all positive long 2 3.2.45 people in 2020 and 2025 however this would be term greater for those in deprived areas as the average level of reduction on NO2 concentrations is higher in the most deprived areas ULEZ would have a positive differential impact on Moderate Update 1 Slightly 3.2.46 school age children, older people and pregnant positive long worsened but 3.2.47 women. This is as a result of the reduction of term still moderate 3.2.4 sensitive receptors (schools, care homes and positive long 8 hospitals) that would be in areas which experience term overall exceedences in NO2 emissions Lowering the taxi age limit may have a Minor Update 1 Removed 3.2.49 disproportionate effect on the third of licensed taxi negative 3.2.50 drivers who are older (60+) who may choose to short- retire early rather than upgrade to a ZEC vehicle medium term ULEZ may have a differential effect on women and Minor Update 1 Removed 3.2.51 the Lesbian, Gay, Bisexual and Transgender negative (LGBT) community arising from increased fear for short- personal safety in central London and other town medium centres in Greater London at night as a result of a term potential decrease of available taxis.
Document No. 1 31 Addendum to the Integrated Impact Assessment (October 2014)
Relevant impacts identified in IIA (October 2014) as Scale of Relevant Change to scale Cross a result of Package 1 impact update of impact with reference to assessed Package 2 relevant section of report
Black and Minority Ethnic (BAME) people are Minor Update 3 Reduced 4.3.7 disproportionately represented as PHV drivers and negative 4.3.8 therefore any additional costs from the ULEZ short- Package 1 may impact upon this group medium 4.3.9 disproportionately term 4.3.10 Economic impacts The improved health outcomes arising from the Moderate Update 1 Slightly 3.2.53 reduction in NOX, PM10 and PM2.5 under the ULEZ positive long improved for for the GLAA are estimated to have a total term 2020 but still monetised benefit of £101m in 2020 and £32m in moderate 2025 positive long term overall ULEZ would result in a 1-2% loss to the night time Minor Update 1 Reduced 3.2.54 economy and 0.2% loss to the tourist sector (of negative which taxis fall within) and an overall loss of 0.03- short- 0.08% medium term The total costs to businesses of either complying Minor Update 3 Reduced 4.3.13 with the ULEZ or paying the charge is expected to negative 4.3.14 be around £120-250m in the first year which will fall short- disproportionately on SMEs but will diminish over medium time as the proportion of vehicles becoming term compliant increases
Document No. 1 32 Addendum to the Integrated Impact Assessment (October 2014)
6. Acronyms
AQO Air Quality Objective
AM Annual Mean
BAME Black, Asian, Minority Ethnic
CCZ Congestion Charging Zone
CO2 Carbon Dioxide
DfT Department for Transport
DVLA Driver and Vehicle Licensing Agency
GLAA Greater London Administrative Area
EU European Union
HGV Heavy Good Vehicle
IIA Integrated Impact Assessment
LGBT Lesbian, Gay, Bisexual and Transgender
LGV Light Goods Vehicle
LV Limit Value
NO2 Nitrogen Dioxide
NOx Oxides of Nitrogen
OLEV Office for Low Emission Vehicles
PHV Private Hire Vehicle
PM Particulate Matter
SIA Supplementary Information Addendum
TfL Transport for London
UK United Kingdom
ULEZ Ultra Low Emission Zone
ZEC Zero emission capable
Document No. 1 33 Addendum to the Integrated Impact Assessment (October 2014)
7. References
Department for Transport. (2013). Taxi and private hire vehicle statistics: England and Wales 2013. Sourced from Taxi Licensing Authorities, August 2013. Accessed on 12 February 2015 from: https://www.gov.uk/government/statistics/taxi-and-private-hire-vehicle-statistics- england-and-wales-2013
Driver & Vehicle Licensing Agency. (2014). Notes about Tax Classes. V355/1. Accessed on 17 February 2015 from: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/360119/V355X 1_140714.pdf
European Commission. (2015). Air Quality Standards. Accessed on 18 May 2015 from: http://ec.europa.eu/environment/air/quality/standards.htm
Go Ultra Low. (2015). What Go Ultra Low cars are right for me? Car Menu. Accessed on 23 February 2015 from: https://www.goultralow.com/car-selector/
Jacobs. (2014). Ultra Low Emission Zone. Integrated Impact Assessment. October 2014.
Jacobs. (2014). Ultra Low Emission Zone Integrated Impact Assessment. Environmental Assessment. October 2014.
Jacobs. (2014). Ultra Low Emission Zone Integrated Impact Assessment. Health Impact Assessment. October 2014.
Office for Low Emission Vehicles. (2015). Guidance pug-in car grant eligibility criteria. Updated on 13 February 2015. Accessed on 19 May 2015 from: https://www.gov.uk/government/publications/plug-in-car-grant/plug-in-car-grant- vehicles#changes-to-the-plug-in-car-grant-from-april-2015
Tooze, S. (Year Unknown). Euro 6: Diesel cleans up its act. Accessed on 12 February 2015 from: http://www.fleetnews.co.uk/fleet-management/euro6-diesel-cleans-up-its-act/52786/
Transport for London (TfL). (2014). Newly Licensed Private Hire Vehicles – Hybrid Vehicles. Notice 17/14. Issued 23 December 2014.
Transport for London (TfL). (2014). Ultra Low Emission Zone – Supplementary Report. Accessed from: https://consultations.tfl.gov.uk/environment/ultra-low-emission- zone/user_uploads/ulez-supplementary-information---final-291014.pdf-1
Transport for London (TfL). (2013-2014). Taxi and Private Hire Licensee Customer Satisfaction Survey 2013/14.
Transport for London (TfL). (2013). Taxi Fares and Tariffs Consultation. Transport for London, London Taxi and Private Hire. 23 October 2013.
RAC. (2012). Blog: Euro 6 and diesel vehicles. Accessed on 12 February 2015 from: http://www.rac.co.uk/community/blog/rac-blog/january-2012/euro-6-and-diesel-vehicles
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Wood, D. (2014). Euro 6 Emissions – what it means. Accessed on 12 February 2015 from: http://www.parkers.co.uk/cars/advice/green-cars/2014/may/euro6-emissions--what-it-all- means/
Document No. 1 35 Addendum to the Integrated Impact Assessment (October 2014)
Appendix A. Environmental Assessment – updated air quality chapter
Document No. 1 ULEZ Environmental Assessment – Air Quality Chapter update July 2015
7. Air Quality
7.1 Introduction
7.1.1 Air quality is defined as the condition of the air with respect to the presence (or absence) of pollutants. Emissions from motor vehicle exhausts contain a number of pollutants including oxides of nitrogen (NOx), carbon monoxide (CO), hydrocarbons, carbon dioxide (CO2) and particulate matter (PM). The quantity of each pollutant emitted depends upon the type of vehicle, quantity and type of fuel used, engine size, speed of the vehicle and abatement equipment fitted.
7.1.2 Emissions of PM can also occur through the interaction of vehicle tyres with the road surface and from use of the braking system. Once emitted, the pollutants are diluted and dispersed in the ambient air. Pollutant concentrations in the air can be measured or modelled and then compared with statutory Air Quality Objectives (AQOs).
7.1.3 The main air pollutants of concern in this assessment are nitrogen dioxide (NO2) and PM less than 10 microns in aerodynamic diameter (PM10). These pollutants are the most likely to be present at concentrations close to, or above, their statutory objective values in areas where traffic emissions are the main source of air pollutants.
7.1.4 All combustion processes produce oxides of nitrogen, for which NOx is the collective term. Oxides of nitrogen comprise nitrogen oxide (NO) and NO2, the former readily converted to the latter by oxidation. NO2 is a pollutant of concern due to its impact on health, and it is this to which AQOs for pollution apply. Since NO easily converts to NO2, it is necessary to reduce emissions of NOx in the management of NO2. NO2 can cause inflammation of the airways and long-term exposure can affect lung function and aggravate respiratory conditions such as asthma.
7.1.5 PM can be inhaled, resulting in significant respiratory and cardiovascular health impacts, such as, aggravation of asthma and respiratory symptoms; and mortality from diseases and lung cancer if exposure is severe or over a sustained period of time (WHO, 2013).
7.1.6 Some pollutants have AQOs expressed as annual mean concentrations due to the chronic way in which they affect human health or the natural environment (i.e. impacts occur after a prolonged period of exposure to elevated concentrations). Others have AQOs expressed as 24-hour or 1-hour mean concentrations due to the acute way in which they affect human health or the natural environment (i.e. after a relatively short period of exposure). AQOs are shown in Table 7.A for NO2, PM10 and NOx.
Table 7.A: Air quality objectives
Pollutant Averaging Period Objective Date for compliance
3 NO2 – for the protection of Annual mean 40µg/m UK 11 June 2010 human health 1-hour mean 200µg/m3 (not to be exceeded UK 11 June 2010 more than 18 times a year (99.8th percentile)) 3 PM10 – for the protection of Annual mean 40µg/m UK 11 June 2010 human health 24-hour mean 50µg/m3 (not to be exceeded UK 11 June 2010 more than 35 times a year (90.4th percentile)) 3 NOx – for the protection of Annual mean 30µg/m UK 11 June 2010 ecosystems (Source: The Air Quality Standards Regulations, 2010) ULEZ Environmental Assessment – Air Quality Chapter update July 2015
7.1.7 A growing body of research has suggested that smaller particles, in particular particles less than 2.5μm in aerodynamic diameter (PM2.5), are closely associated with health impacts. However, to date there are no statutory AQOs in UK law which govern their emission to the atmosphere. This is largely due to lack of evidence to indicate that there is a concentration of PM2.5 below which health impacts do not occur (Defra, 2012).
7.1.8 The approach to PM2.5 reduction in the UK thus far has focused on achieving reductions in the overall exposure of the population, based on the concept that greater public health benefits could be obtained from a general reduction than policies aimed at reducing exposure in the most heavily affected areas only.
7.1.9 The focus of legislation for PM2.5 is on limiting long-term exposure through the use of annual objectives, coupled to a reduction of PM2.5 background concentration in urban areas across the UK over the period 2010-2020. The national aspirational target for annual mean PM2.5 concentrations in the UK is 25μg/m3.
7.1.10 Potential changes in concentrations of this pollutant resulting from the Ultra Low Emission Zone (the ULEZ) have been considered in the Environmental Assessment prepared by Jacobs dated October 2014 and the Addendum to the IIA dated July 2015.
7.2 Baseline
7.2.1 Road transport is a major source of air pollution in London and the United Kingdom (UK), emitting air pollutants such as PM and NOx, which are harmful to human health. Pollution concentrations in London are influenced by local factors and by London-wide and regional (including trans-boundary) sources and determinants of pollution (e.g. trends in vehicle numbers in London, vehicle technology, meteorological conditions and long-range transport of pollutants).
(a) Exposure to pollutant concentrations exceeding AQOs
7.2.2 The baseline data used in this assessment has been sourced from Transport for London (TfL) and King College London’s (KCL’s) 2014 atmospheric emissions model of London for a ‘without ULEZ’ scenario in the years 2020 and 2025.
7.2.3 The data shows that in 2020, approximately 34,000 receptors (including residential properties, care homes, health facilities and schools) across London would be exposed to NO2 concentrations which exceed the annual mean AQO.
7.2.4 For PM10, approximately 34 receptors in London would be exposed to concentrations which exceed the annual mean AQO.
(b) Vehicle sources of pollutant emissions
7.2.5 As the ULEZ is aimed at tackling air pollutants in central London, the baseline conditions established for the air quality assessment were primarily based on forecasted pollutant emissions in central London between 2020 and 2025.
7.2.6 The proportion of central London’s total NOx, NO2, PM10 and PM2.5 emissions attributable to various transport modes are shown in Table 7.B and Figures 7-A to 7-H. Please note that the totals and percentages may not be exact due to rounding. ULEZ Environmental Assessment – Air Quality Chapter update July 2015
In order to better inform the reader, the baseline emissions data for 2020 and 2025 have been updated since the IIA Report (October 2014) was published. This updated baseline data does not in any way change the outcome of the assessment or influence the results presented in section 7.3.
7.2.7 Further information on the KCL model and methodology which underpins it can be found in Appendix B.
Table 7.B: Total NOx, NO2, PM10 and PM2.5 emissions in central London by vehicle type (2020 and 2025)
Total emissions (tonnes per annum)
NOx NO2 PM10 PM2.5
% % % %
chang chang chang chang Vehicle Type e (+/-) e (+/-) e (+/-) e (+/-) 2020 2025 2020 2025 2020 2025 2020 2025 Motorcycle 5 3 -31% 0 0 0% 2 2 0% 1 1 0% Taxi 120 92 -23% 51 35 -30% 17 10 -43% 12 5 -54% Car 161 116 -28% 51 31 -40% 26 23 -8% 14 11 -15% LGV 92 69 -25% 31 21 -33% 11 9 -15% 6 4 -27% TfL Bus 155 70 -55% 36 23 -36% 10 9 -15% 6 4 -24% Non-TfL Bus 57 27 -53% 7 3 -58% 3 2 -21% 2 1 -32% and Coach HGV 71 39 -45% 8 4 -50% 7 7 0% 4 3 -14% Total 661 417 -37% 192 122 -36% 76 62 -18% 44 31 -29%
(Source: TfL / King’s College London, 2014)
7.2.8 As shown in Table 7.B, in the baseline ‘without ULEZ’ scenario total emissions of NOx from all vehicle types would reduce between 2020 and 2025 by 37 per cent or 254 tonnes per annum. The greatest percentage reductions would be seen in TfL bus emissions (55 per cent or 85 tonnes per annum), Non-TfL Bus and Coach emissions (53 per cent or 30 tonnes per annum) and Heavy Goods Vehicle (HGV) emissions (45 per cent equivalent to 32 tonnes per annum).
7.2.9 Similar to NOx, NO2 emissions would also decrease for all vehicle types by 2025 in the baseline scenario. The greatest reductions as a percentage would come from Non-TfL Bus and Coach (58 per cent or 4 tonnes per annum) and HGV (50 per cent or 4 tonnes per annum) emissions. The greatest reduction in total NO2 emissions would come from cars (20 tonnes per annum).
7.2.10 Overall, reductions in PM10 emissions between 2020 and 2025 would be 18 per cent or 14 tonnes per annum. Emissions from Taxis would decrease by 43 per cent (7 tonnes per annum), whilst Non-TfL Bus and Coach emissions would also see a decrease in PM10, of 21 per cent or 1 tonne per annum.
7.2.11 Total PM2.5 emissions would reduce by 29 per cent (13 tonnes per annum) in the baseline ‘without ULEZ’ scenario between 2020 and 2025. Most of this reduction would come from taxis (54 per cent or 7 tonnes per annum), car (15 per cent or 3 tonnes per annum) and Large Goods Vehicle (LGV) emissions (27 per cent, equating to a reduction of 2 tonnes per annum). ULEZ Environmental Assessment – Air Quality Chapter update July 2015
Road Traffic NOx Emissions in Central London 2020 Motorcycle 1%
HGV 11% Taxi 18% Non TfL Bus&Coach 9%
TfL Bus Car 23% 24%
LGV 14%
Figure 7.A: Road traffic NOx emissions in central London (2020) (source: TfL / KCL, 2014)
Road Traffic NOx Emissions in Central London 2025 Motorcycle 1%
Non TfL Bus&Coach HGV 6% 9% Taxi 22%
TfL Bus 17%
Car 28% LGV 17%
Figure 7.B: Road traffic NOx emissions in central London (2025) (source: TfL / KCL, 2014) ULEZ Environmental Assessment – Air Quality Chapter update July 2015
Road Traffic NO2 Emissions in Central London 2020 Motorcycle 0% Non TfL Bus&Coach 4% HGV 4%
Taxi 28% TfL Bus 19%
LGV 17% Car 28%
Figure 7.C: Road traffic NO2 emissions in central London (2020) (source: TfL / KCL, 2014)
Road Traffic NO2 Emissions in Central London 2025 Motorcycle Non TfL Bus&Coach 0% 3% HGV 3%
Taxi TfL Bus 30% 20%
LGV 18%
Car 26%
Figure 7.D: Road traffic NO2 emission in central London (2025) (source: TfL / KCL, 2014) ULEZ Environmental Assessment – Air Quality Chapter update July 2015
Road Traffic PM10 Emissions in Central London 2020 Motorcycle 3% Non TfL Bus&Coach 4% HGV 9%
Taxi 23%
TfL Bus 13%
LGV 14%
Car 34%
Figure 7.E: Road traffic PM10 emissions in central London (2020) (source: TfL / KCL, 2014)
Road Traffic PM10 Emissions in Central London 2025 Motorcycle 3%
Non TfL Bus&Coach HGV 3% 11% Taxi 16%
TfL Bus 15%
LGV 15% Car 37%
Figure 7.F: Road traffic PM10 emissions in central London (2025) (source: TfL / KCL, 2014) ULEZ Environmental Assessment – Air Quality Chapter update July 2015
Road Traffic PM2.5 Emissions in Central London 2020 Motorcycle 2% Non TfL Bus&Coach 5% HGV 9%
Taxi 27%
TfL Bus 13%
LGV 13%
Car 31%
Figure 7.G: Road traffic PM2.5 emissions in central London (2020) (source: TfL / KCL, 2014)
Road Traffic PM2.5 Emissions in Central London 2025
Motorcycle 3% Non TfL Bus&Coach 4% HGV 10% Taxi 16%
TfL Bus 14%
LGV 15% Car 38%
Figure 7.H: Road traffic PM2.5 emissions in central London (2025) (source: TfL / KCL, 2014) ULEZ Environmental Assessment – Air Quality Chapter update July 2015
7.2.12 The baseline forecasts suggest that cars, TfL buses and taxis would be the three main contributors to total emissions of NOx, NO2 and PM2.5 in 2020 and 2025. Together these three vehicle types would account for 66 per cent of total NOx emissions in central London in 2020 and 67 per cent in 2025.
7.2.13 In 2020, the three main sources of PM10 emissions in central London would be car (34 per cent), taxi (23 per cent) and LGV (14 per cent). In 2025, the proportion of emissions from cars and LGVs would increase by 3 per cent and 1 per cent respectively, whilst the proportion of emissions from taxis would decrease by 7 per cent.
7.2.14 Car emissions would be the greatest contributor to total road traffic NOx, PM10 and PM2.5 emissions in both 2020 and 2025.
7.2.15 With the exception of NO2, the proportion of pollutant emissions from cars would increase between 2020 and 2025, increasing from 24 to 28 per cent for NOx, 34 to 37 per cent for PM10 and 31 to 38 per cent for PM2.5.
7.2.16 The percentage contribution of taxis to total NO2 emissions would also increase between 2020 and 2025, from 28 per cent to 30 per cent. In contrast, PM10 and PM2.5 emissions from taxis would decline between 2020 and 2025 (23 to 16 per cent for PM10 and 27 to 16 per cent for PM2.5).
7.2.17 The baseline forecasts indicate that car, TfL buses and taxi emissions are the biggest contributors to total road traffic NOx, NO2 and PM2.5 emissions in central London.
7.2.18 TfL has recently completed an extensive retrofit programme of over 1,000 older buses in an attempt to reduce the contribution of buses to total pollutant emissions. This involved fitting them with selective catalytic reduction (SCR), an innovative system which helped to reduce emissions of NOx by up to 88 per cent (TfL, 2014).
7.2.19 Technological improvements to the vehicle fleet, in addition to policy interventions such as TfL’s Low Emission Zone (LEZ), have reduced pollutant emissions to a point where AQOs are largely being met. However, further initiatives are required to reduce the remaining gap to achieve AQOs for NOx and NO2. This includes the ULEZ as well as a range of measures identified in the Mayor’s Transport Emission Roadmap (TERM).
7.3 Impacts on air quality
7.3.1 Changes to pollutant concentrations resulting from the implementation of the ULEZ Package 2 would be dependent on a number of variables, including changes to vehicle technologies and fleet composition, and changes to traffic volumes, flows and speeds.
7.3.2 The results of atmospheric emissions modelling undertaken by TfL and KCL in 2015 are shown in Tables 7-C to 7-F.
Note: the atmospheric emissions modelling results previously published in the Environmental Assessment and Integrated Impact Assessment (October 2014) have since been updated to take into account the updates to the ULEZ. These updates are outlined in the current addendum (July 2015) to the ULEZ IIA.
7.3.3 Change in the number of properties exceeding pollutant AQOs to no longer exceeding as a result of the ULEZ were calculated by first identifying all relevant receptors within 200m of the London road network, including residential properties, schools, care homes and healthcare facilities. Impacts on the population as a result of changes to air quality are discussed in the HIA. Each receptor was then joined to the TfL / KCL atmospheric emissions model results at a resolution of 20 metres. For each pollutant, the number of properties exceeding AQO values in the baseline was counted, along with the number of properties exceeding the values in the ‘with ULEZ’ scenario. The difference between the two represents the change in the number of properties which go from exceeding the AQO to no longer exceeding.
ULEZ Environmental Assessment – Air Quality Chapter update July 2015
Table 7.C: Anticipated zone-wide average changes in NO2, PM10 and PM2.5 concentrations in 2020 with ULEZ Package 2
Zone Average Change in no. Average Change in no. Average Change in no. Change in AM properties Change in AM properties Change in AM properties
NO2 conc. exceeding PM10 conc. exceeding PM2.5 conc. exceeding 3 3 3 (µg/m ) AM NO2 (µg/m ) AM PM10 (µg/m ) AM PM2.5 objective objective objective CCZ -4.5 -4,522 -0.1 0 -0.1 0 IRR -3.8 -2,412** -0.1 0 -0.1 0 Inner -1.6 -10,581 0.0 -1 0.0 0 Outer -0.9 -2,943 0.0 0 0.0 0 Non GLAA -0.6 -128 0.0 0 0.0 0 Total -0.8 -18,174 0.0 -1 0 0 *AM stands for Annual Mean **The IRR is a 12 mile (19km) route formed from a number of major roads that encircle the CCZ, therefore any properties within the IRR are already counted for within the CCZ and the Inner Zone and have not been counted in the total (Source: Jacobs derived from TfL / King’s College London, 2015)
Table 7.D: Anticipated zone-wide average changes in NO2, PM10 and PM2.5 concentrations in 2025 with ULEZ Package 2
Zone Average Change in no. Average Change in no. Average Change in no. Change in AM properties Change in AM properties Change in AM properties
NO2 conc. exceeding PM10 conc. exceeding PM2.5 conc. exceeding 3 3 3 (µg/m ) AM NO2 (µg/m ) AM PM10 (µg/m ) AM PM2.5 objective objective objective CCZ -1.8 -379 0.0 0 0.0 0 IRR -1.5 -273** 0.0 0 0.0 0 Inner -0.5 -965 0.0 0 0.0 0 Outer -0.2 -245 0.0 0 0.0 0 Non GLAA -0.1 -12 0.0 0 0.0 0 Total -0.8 -1,601 0.0 0 0.0 0 *AM stands for Annual Mean **The IRR is a 12 mile (19km) route formed from a number of major roads that encircle the CCZ, therefore any properties within the IRR are already counted for within the CCZ and the Inner Zone and have not been counted in the total (Source: Jacobs derived from TfL / King’s College London, 2015) ULEZ Environmental Assessment – Air Quality Chapter update July 2015
Table 7.E: Anticipated borough-wide average changes in NO2, PM10 and PM2.5 concentrations in 2020 with ULEZ Package 2
Borough Average Change in Average Change in Average Change in Change in no. Change in no. Change in no.
AM NO2 properties AM PM10 properties AM PM2.5 properties conc. exceeding conc. (µg/m3) exceeding conc. (µg/m3) exceeding 3 (µg/m ) AM NO2 AM PM10 AM PM2.5 objective objective objective Barking and -0.9 -73 0.0 0 0.0 0 Dagenham Barnet -1 -184 0.0 0 0.0 0 Bexley -0.8 -38 0.0 0 0.0 0 Brent -1.1 -478 0.0 0 0.0 0 Bromley -0.8 -45 0.0 0 0.0 0 Camden -2 -1,433 0.0 0 0.0 0 City of London -5.7 -308 -0.2 0 -0.1 0 City of -2.9 -4,424 -0.1 0 -0.1 0 Westminster Croydon -0.9 -189 0.0 0 0.0 0 Ealing -1 -269 0.0 0 0.0 0 Enfield -0.9 -156 0.0 0 0.0 0 Greenwich -1.1 -274 0.0 0 0.0 0 Hackney -1.7 -592 0.0 0 0.0 0 Hammersmith -1.7 -617 0.0 0 0.0 0 and Fulham Haringey -1.4 -463 0.0 0 0.0 0 Harrow -0.7 -21 0.0 0 0.0 0 Havering -0.7 -22 0.0 0 0.0 0 Hillingdon -0.7 -23 0.0 0 0.0 0 Hounslow -1 -346 0.0 0 0.0 0 Islington -1.9 -775 0.0 0 0.0 0 Kensington -2.3 -1,614 -0.1 0 0.0 0 and Chelsea Kingston -1 -92 0.0 0 0.0 0 Lambeth -1.8 -1,185 0.0 0 0.0 0 Lewisham -1.4 -518 0.0 0 0.0 0 Merton -1.1 -159 0.0 0 0.0 0 Newham -1.3 -361 0.0 0 0.0 0 Redbridge -0.9 -93 0.0 0 0.0 0 Richmond -1 -122 0.0 0 0.0 0 Southwark -1.9 -1,327 0.0 0 0.0 0 Sutton -0.9 -50 0.0 0 0.0 0 Tower -1.9 -841 0.0 -1 0.0 0 Hamlets Waltham -1.1 -312 0.0 0 0.0 0 Forest Wandsworth -1.5 -636 0.0 0 0.0 0 *AM stands for Annual Mean (Source: Jacobs derived from TfL / King’s College London, 2015) ULEZ Environmental Assessment – Air Quality Chapter update July 2015
Table 7.F: Anticipated borough-wide average changes in NO2, PM10 and PM2.5 concentrations in 2025 with ULEZ Package 2
Borough Average Change in Average Change in Average Change in Change in no. Change in no. Change in no.
AM NO2 properties AM PM10 properties AM PM2.5 properties conc. (µg/m3) exceeding conc. (µg/m3) exceeding conc. (µg/m3) exceeding
AM NO2 AM PM10 AM PM2.5 objective objective objective Barking and -0.2 -5 0.0 0 0.0 0 Dagenham Barnet -0.2 -9 0.0 0 0.0 0 Bexley -0.2 0 0.0 0 0.0 0 Brent -0.3 -71 0.0 0 0.0 0 Bromley -0.2 0 0.0 0 0.0 0 Camden -0.7 -155 0.0 0 0.0 0 City of -2.3 -42 0.0 0 0.0 0 London City of -1.2 -351 0.0 0 0.0 0 Westminster Croydon -0.2 -17 0.0 0 0.0 0 Ealing -0.3 -39 0.0 0 0.0 0 Enfield -0.2 -1 0.0 0 0.0 0 Greenwich -0.3 -20 0.0 0 0.0 0 Hackney -0.5 -72 0.0 0 0.0 0 Hammersmit -0.5 -66 0.0 0 0.0 0 h and Fulham Haringey -0.4 -48 0.0 0 0.0 0 Harrow -0.2 -3 0.0 0 0.0 0 Havering -0.2 -1 0.0 0 0.0 0 Hillingdon -0.2 0 0.0 0 0.0 0 Hounslow -0.3 -16 0.0 0 0.0 0 Islington -0.6 -80 0.0 0 0.0 0 Kensington -0.9 -120 0.0 0 0.0 0 and Chelsea Kingston -0.2 -2.0 0.0 0 0.0 0 Lambeth -0.5 -81 0.0 0 0.0 0 Lewisham -0.4 -34 0.0 0 0.0 0 Merton -0.3 -13 0.0 0 0.0 0 Newham -0.4 -33 0.0 0 0.0 0 Redbridge -0.2 -3 0.0 0 0.0 0 Richmond -0.3 -12 0.0 0 0.0 0 Southwark -0.6 -133 0.0 0 0.0 0 Sutton -0.2 -6 0.0 0 0.0 0 Tower -0.6 -64 0.0 0 0.0 0 Hamlets Waltham -0.3 -27 0.0 0 0.0 0 Forest Wandsworth -0.4 -65 0.0 0 0.0 0 *AM stands for Annual Mean (Source: Jacobs derived from TfL / King’s College London, 2015) ULEZ Environmental Assessment – Air Quality Chapter update July 2015
7.3.4 Maps showing the anticipated changes in air pollutant concentrations and properties exceeding AQOs resulting from implementation of the ULEZ Package 2 can be found in Figure 7-I to Figure 7-P.
(a) NO2
7.3.5 The results show that the largest change in relevant receptor weighted average annual mean NO2 concentration in 2020 may be seen in the Congestion Charging Zone (CCZ) (a reduction of 4.5µg/m3). The impact of the ULEZ Package 2 dissipates towards the Outer Zone, where the improvement lessens to 0.9µg/m3.
7.3.6 In 2025, the largest change in relevant receptor weighted average annual mean NO2 concentration is again anticipated to occur in the CCZ (a further reduction of 1.8µg/m3). As with the results for 2020, in 2025 impacts of the ULEZ Package 2 dissipate towards the Outer Zone where the improvement reduces to 0.2µg/m3.
7.3.7 Around 18,174 additional relevant receptors are anticipated to change from being exposed to concentrations exceeding the annual mean NO2 objective, to no longer being exposed to exceedences in 2020, as a result of the ULEZ Package 2. This equates to a reduction of approximately 55 per cent. The majority of these are likely to be seen in the Inner Zone (just over 10,500).
7.3.8 The largest percentage reduction in properties exceeding the AQO in 2020 would be in the CCZ (approximately 4,500 properties or 85 per cent). This is followed by the Inner Zone (approximately 10,500 properties or 55 per cent) and the Outer Zone (approximately 2,900 properties or 34 per cent).
7.3.9 By 2025, the total number of relevant receptors no longer exceeding the annual mean NO2 objective because of the ULEZ Package 2 is expected to decrease, with over 1,600 relevant receptors anticipated to change from being exposed to concentrations exceeding the annual mean NO2 objective, to no longer being exposed to exceedences. This equates to a further reduction of around 25 per cent. Once again the majority of these are likely to be in the Inner Zone (965 or 13 per cent).
7.3.10 The local authority with the largest change in property weighted average annual mean NO2 concentration in both 2020 and 2025 is anticipated to be the City of London, with respective average reductions of 5.7 and 2.3 µg/m3 per relevant receptor.
7.3.11 The local authority with the greatest reductions in the number of properties exposed to exceedence of the annual mean NO2 objective in both 2020 and 2025 is City of Westminster, with anticipated reductions of just under 4,500 properties in 2020 and just over 350 properties in 2025.
(b) PM10
7.3.12 In 2020, relevant receptor weighted average annual mean PM10 concentrations would reduce by a small amount in the CCZ (0.1µg/m3). Moving away from the influence of the ULEZ Package 2 this reduction is anticipated to be less than 0.1µg/m3 in the Inner Zone and beyond.
7.3.13 Relevant receptor weighted average annual mean PM10 concentrations reduce by a smaller amount in 2025, with the CCZ anticipated to see an average reduction of less than 0.1µg/m3. Away from the influence of the ULEZ this reduction would decrease further still.
7.3.14 The results suggest a single relevant receptor would change from being exposed to concentrations exceeding the annual mean PM10 objective, to no longer being exposed to exceedences in 2020 as a result of the ULEZ Package 2. This relevant receptor is in the London Borough of Tower Hamlets. The fact that this number is much lower than for NO2, reflects the lower pollutant concentrations associated with PM10 and the reduced number of relevant receptors exposed to exceedence in the first place.
7.3.15 In 2025, no relevant receptors are anticipated to change from being exposed to concentrations exceeding the annual mean PM10 objective, to no longer being exposed to exceedences. ULEZ Environmental Assessment – Air Quality Chapter update July 2015
7.3.16 The local authority with the largest reduction in relevant receptor weighted average annual mean PM10 concentration in 2020 is the City of London, with an average reduction of 0.2µg/m3. In 2025, no local authority would experience a reduction of more than 0.1µg/m3 per relevant receptor.
(c) PM2.5
3 7.3.17 The results indicate that PM2.5 concentrations may reduce by 0.1µg/m in both the CCZ and IRR in 2020. This declines over time, such that by 2025 each zone may experience a reduction of less than 0.1µg/m3.
7.3.18 No relevant receptors are estimated to be exposed to exceedence of the annual mean PM2.5 objective in either the Baseline or the ‘with ULEZ’ scenario for the years 2020 and 2025.
7.3.19 The local authorities with the largest property weighted average annual mean PM2.5 concentration reductions per relevant receptor are the City of London (0.2µg/m3), the Royal Borough of Kensington and Chelsea (0.1µg/m3) and City of Westminster (0.1µg/m3).
7.3.20 All local authorities are anticipated to experience average relevant receptor weighted annual mean 3 PM2.5 concentration reductions of less than 0.1µg/m per relevant receptor in 2025.
7.4 Mitigation and enhancement
7.4.1 As the impacts of the ULEZ Package 2 upon air quality are anticipated to be positive, no mitigation is considered necessary.
7.4.2 Over time the cost of producing low and zero emission vehicles is likely to reduce. This may make it more economically feasible for a greater proportion of London’s buses and other vehicle types to utilise these technologies. TfL should, where possible, continue to support the development of the low and zero emission vehicle market and facilitate their use through additional policies and proposals.
7.4.3 An effective programme of vehicle maintenance would need to be adopted to ensure that positive impacts on air quality are maintained over time.
Figure 7-I
Non GLAA
Outer Non GLAA
Key Inner Properties exceeding AQO for NO2 (2020) [baseline] Statistical LAEI Zone Boundaries
Congestion Charge Zone (CCZ) Inner Outer CCZ Non Greater London Administrative Area (Non GLAA)
IRR Inner Ring Road (IRR)
0 20/10/2014 Air Quality Assessment SP MC DP MB
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Client
Transport for London
Project
Ultra Low Emission Zone - Integrated Impact Assessment
Drawing Title
Properties exceeding AQO for NO2 (2020) [baseline]
Drawing Status Final Scale @A3 1:200,000 DO NOT SCALE Jacobs No. B19930000 Client No. Filepath Drawing No. 0 1 2 3 4 5 Figure 7-I
Miles Ordnance Survey data © Crown copyright and database right 2014 This drawing is not to be used in whole in or part other than for the intended purpose and project as defined on this drawing. Refer to the contract for full terms and conditions. / Figure 7-J
Non GLAA
Outer Non GLAA
Key Inner
Average change in NO2 concentrations (2020) [with ULEZ (as updated)] Highest level of reduction
CCZ Lowest level of reduction
Statistical LAEI Zone Boundaries IRR Congestion Charge Zone (CCZ) Inner Outer Non Greater London Administrative Area (Non GLAA)
Inner Ring Road (IRR)
0 23/06/2015 Air Quality Assessment CB MC MC MB
Rev. Date Purpose of revision Drawn Check'd Rev'd Appr'd
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Client
Transport for London
Project
Ultra Low Emission Zone - Integrated Impact Assessment
Drawing Title
Average change in NO2 concentrations (2020) [with ULEZ (as updated)]
Drawing Status Final Scale @A3 1:200,000 DO NOT SCALE Jacobs No. B19930000 Client No. Filepath Drawing No. 0 1 2 3 4 5 Figure 7-J
Miles Ordnance Survey data © Crown copyright and database right 2014 This drawing is not to be used in whole in or part other than for the intended purpose and project as defined on this drawing. Refer to the contract for full terms and conditions. Figure 7-K
Non GLAA
Outer Non GLAA
Key Inner Properties exceeding AQO for PM 10 (2020) [baseline] Statistical LAEI Zone Boundaries
Congestion Charge Zone (CCZ) Inner Outer CCZ Non Greater London Administrative Area (Non GLAA)
IRR Inner Ring Road (IRR)
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Client
Transport for London
Project
Ultra Low Emission Zone - Integrated Impact Assessment
Drawing Title
Properties exceeding AQO for PM10 (2020) [baseline]
Drawing Status Final Scale @A3 1:200,000 DO NOT SCALE Jacobs No. B19930000 Client No. Filepath Drawing No. 0 1 2 3 4 5 Figure 7-K
Miles Ordnance Survey data © Crown copyright and database right 2014 This drawing is not to be used in whole in or part other than for the intended purpose and project as defined on this drawing. Refer to the contract for full terms and conditions. / Figure 7-L
Non GLAA
Outer Non GLAA
Key Inner
Average change in PM10 concentrations (2020) [with ULEZ (as updated)] Highest level of reduction
CCZ Lowest level of reduction
Statistical LAEI Zone Boundaries IRR Congestion Charge Zone (CCZ) Inner Outer Non Greater London Administrative Area (Non GLAA)
Inner Ring Road (IRR)
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Client
Transport for London
Project
Ultra Low Emission Zone - Integrated Impact Assessment
Drawing Title
Average change in PM10 concentrations (2020) [with ULEZ (as updated)]
Drawing Status Final Scale @A3 1:200,000 DO NOT SCALE Jacobs No. B19930000 Client No. Filepath Drawing No. 0 1 2 3 4 5 Figure 7-L
Miles Ordnance Survey data © Crown copyright and database right 2014 This drawing is not to be used in whole in or part other than for the intended purpose and project as defined on this drawing. Refer to the contract for full terms and conditions. Figure 7-M
Non GLAA
Outer Non GLAA
Key Inner Properties exceeding AQO for NO 2 (2025) [baseline] Statistical LAEI Zone Boundaries
Congestion Charge Zone (CCZ) Inner Outer CCZ Non Greater London Administrative Area (Non GLAA)
IRR Inner Ring Road (IRR)
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Client
Transport for London
Project
Ultra Low Emission Zone - Integrated Impact Assessment
Drawing Title
Properties exceeding AQO for NO2 (2025) [baseline]
Drawing Status Final Scale @A3 1:200,000 DO NOT SCALE Jacobs No. B19930000 Client No. Filepath Drawing No. 0 1 2 3 4 5 Figure 7-M
Miles Ordnance Survey data © Crown copyright and database right 2014 This drawing is not to be used in whole in or part other than for the intended purpose and project as defined on this drawing. Refer to the contract for full terms and conditions. / Figure 7-N
Non GLAA
Outer Non GLAA
Key Inner
Average change in NO2 concentrations (2025) [with ULEZ (as updated)] Highest level of reduction
CCZ Lowest level of reduction
Statistical LAEI Zone Boundaries IRR Congestion Charge Zone (CCZ) Inner Outer Non Greater London Administrative Area (Non GLAA)
Inner Ring Road (IRR)
0 23/06/2015 Air Quality Assessment CB MC MC MB
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Client
Transport for London
Project
Ultra Low Emission Zone - Integrated Impact Assessment
Drawing Title
Average change in NO2 concentrations (2025) [with ULEZ (as updated)]
Drawing Status Final Scale @A3 1:200,000 DO NOT SCALE Jacobs No. B19930000 Client No. Filepath Drawing No. 0 1 2 3 4 5 Figure 7-N
Miles Ordnance Survey data © Crown copyright and database right 2014 This drawing is not to be used in whole in or part other than for the intended purpose and project as defined on this drawing. Refer to the contract for full terms and conditions. Figure 7-O
Non GLAA
Outer Non GLAA
Key Inner Properties exceeding AQO for PM10 (2025) [baseline] Statistical LAEI Zone Boundaries
Congestion Charge Zone (CCZ) Inner Outer CCZ Non Greater London Administrative Area (Non GLAA)
IRR Inner Ring Road (IRR)
0 20/10/2014 Air Quality Assessment SP MC DP MB
Rev. Date Purpose of revision Drawn Check'd Rev'd Appr'd
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Client
Transport for London
Project
Ultra Low Emission Zone - Integrated Impact Assessment
Drawing Title
Properties exceeding AQO for PM10 (2025) [baseline]
Drawing Status Final Scale @A3 1:200,000 DO NOT SCALE Jacobs No. B19930000 Client No. Filepath Drawing No. 0 1 2 3 4 5 Figure 7-O
Miles Ordnance Survey data © Crown copyright and database right 2014 This drawing is not to be used in whole in or part other than for the intended purpose and project as defined on this drawing. Refer to the contract for full terms and conditions. / Figure 7-P
Non GLAA
Outer Non GLAA
Key Inner
Average change in PM10 concentrations (2025) [with ULEZ (as updated)] Highest level of reduction
CCZ Lowest level of reduction
Statistical LAEI Zone Boundaries IRR Congestion Charge Zone (CCZ) Inner Outer Non Greater London Administrative Area (Non GLAA)
Inner Ring Road (IRR)
0 25/06/2015 Air Quality Assessment CB MC MC MB
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Client
Transport for London
Project
Ultra Low Emission Zone - Integrated Impact Assessment
Drawing Title
Average change in PM10 concentrations (2025) [with ULEZ (as updated)]
Drawing Status Final Scale @A3 1:200,000 DO NOT SCALE Jacobs No. B19930000 Client No. Filepath Drawing No. 0 1 2 3 4 5 Figure 7-P
Miles Ordnance Survey data © Crown copyright and database right 2014 This drawing is not to be used in whole in or part other than for the intended purpose and project as defined on this drawing. Refer to the contract for full terms and conditions. Addendum to the Integrated Impact Assessment (October 2014)
Appendix B. Health Impact Assessment – updated air quality chapter
Document No. 1 ULEZ Health Impact Assessment – Air Quality Chapter update July 2015
8. Introduction
8.1 Overview 8.1.1. An analysis of air quality modelling and associated improvement to health as a result of the Ultra Low Emission Zone (ULEZ) has been undertaken by Ricardo-AEA. The results are summarised in this chapter with further detail provided in Appendix 1. 8.1.2. Ricardo-AEA used modelled concentrations of pollutants for a base case (i.e. without ULEZ) and a ‘with ULEZ’ scenario (being the ULEZ Package 2) provided by Kings College London (KCL). These were used to calculate the impact of the ULEZ on exceedences of the European Union (EU) Limit Value (LV) for the protection of human health and to quantify health impacts. 8.1.3. Ricardo-AEA captured a range of positive health impacts directly associated with changes in concentrations of air pollutants for the ULEZ Package 2, including: the impact of chronic exposure to particulate concentrations on mortality; the impact of acute exposure to particulate concentrations on respiratory hospital admissions and cardio-vascular hospital admissions; and in the extended set of sensitivity analysis, the assessment also includes the impact of chronic exposure to NO2 concentrations on mortality and the impact of acute exposure to NO2 concentrations on respiratory hospital admissions. 8.1.4. The air quality assessment for the Health Impact Assessment (HIA) was completed using population data at a finer level of detail (smaller Output Areas) than that set out in Appendix 1.
8.2 Health pathway 8.2.1. Studies of air pollution have shown that high levels of ambient air pollution are associated with strong increases in adverse health effects. Due to the health concerns associated with many pollutants, United Kingdom (UK) and European Union (EU) legislation has been introduced to improve air quality. The ULEZ Package 2 is seen as an important mechanism for helping London respond to this legislation. 8.2.2. The specific health pathway assessed to identify impacts on health from air quality as a result of ULEZ Package 2 was a reduction in the inhalation of airborne pollutants due to road traffic emissions.
8.3 Receptors 8.3.1. Key receptors include all people exposed to local air pollution (e.g. residents, road users, pedestrians, the elderly/ children). As such, the following buildings and places are considered as receptors: residential properties, schools, hospitals, care homes, open spaces, public rights of way and nature conservation sites.
8.4 Impact assessment
(a) Limit Value (LV) exceedences 3 8.4.1. The annual mean concentration LV for NO2 is, set at 40µg/m . This was due to be met by January 2010 (EU Air Quality Directive); however, this is regularly exceeded in 16 zones across the UK, including Greater London (European Commission, 2014). Ricardo-AEA analysed reductions in NO2 levels for all the London boroughs. The results indicate that those with the highest levels of social deprivation (based on the Index of Multiple Deprivation 2010) will experience higher annual mean NO2 concentration in both 2020 and 2025.
8.4.2. The average exposure to NO2 across the population would be reduced with the ULEZ Package 2 compared to the base-case in both years. However, ULEZ Package 2 would have (on average) a greater impact on air quality in locations where the residential population has higher levels of social deprivation.
1 ULEZ Health Impact Assessment – Air Quality Chapter update July 2015
8.4.3. The ULEZ Package 2 would result in reductions in the number of people living in areas above the NO2 annual LV in 2020 and 2025 compared to the without ULEZ scenario as per Table 8-A. Specifically in 2020, the ULEZ Package 2 would result in the following reductions in numbers of people living in areas above the NO2 annual LV: Central Zone – reduction of 72 per cent; Inner Zone – reduction of 52 per cent; and Outer Zone – reduction of 42 per cent.
Table 8-A: Population living in areas above the NO2 annual limit value in 2020
Year Zone Number of people % population living
Baseline The ULEZ Baseline ULEZ Package 2 Package 2
2020 Central 123,454 33,995 63.0% 17.4% Inner 434,290 208,882 12.7% 6.1% Outer 95,207 54,822 1.7% 1.0% London-wide 652,951 297,700 7.2% 3.3% 2025 Central 34,374 9,859 17.1% 4.9% Inner 77,528 50,862 2.2% 1.4% Outer 10,658 7,558 0.2% 0.1% London-wide 122,559 68,280 1.3% 0.7%
(Source: Ricardo-AEA, 2015) 3 8.4.4. For PM10, the annual mean LV of 40µg/m , which was due to be achieved by January 2005, has been met throughout London when Defra last reported on compliance in 2013. The daily PM10 LV of no more than 35 days with daily mean concentration greater than 50µg/m3 is somewhat more challenging to achieve, but central government are currently reporting compliance with this EU LV across the UK. Defra report annual compliance assessments on this to the European Commission1. 3 8.4.5. The annual mean PM2.5 LV of 25µg/m (to be achieved by January 2015) is also met throughout London. The impact of the ULEZ Package 2 on PM10 and PM2.5 would be much smaller than the impact on NO2 and there is no distinct difference between the impacts on areas experiencing lower or higher levels of multiple deprivation.
(b) Hospital admissions and life years lost 8.4.6. The quantification of health impacts as a result of changes in air pollution follows the widely- recognised Impact Pathway Approach (IPA). Ricardo-AEA used five health impact pathways to analyse air quality health impacts, including:
mortality associated with long-term exposure to particulate matter (PM2.5);
respiratory hospital admissions associated with acute exposure to particulate matter (PM10);
cardio-vascular hospital admissions associated with acute exposure to particulate matter (PM10);
mortality associated with long term exposure to NO2; and
respiratory hospital admissions associated with acute exposure to NO2. 8.4.7. Concentration response functions (CRFs) were used in the IPA to link a given change in air pollutant concentration to a specific health response. The CRF’s used in the analysis undertaken by Ricardo-
1 see: http://uk-air.defra.gov.uk/ for more details
2 ULEZ Health Impact Assessment – Air Quality Chapter update July 2015
AEA are detailed in Table 8-B for each impact pathway. The estimated health impacts are presented in Table 8-C and 8-D. 8.4.8. Table 8-C and 8-D show for each study year, the health ‘burden’ associated with the absolute levels of pollutant concentrations under the base-case and ‘with ULEZ’ scenario, and the impact of the ULEZ Package 2 relative to the base-case (i.e. the health benefit associated with the ULEZ Package 2, calculated as the difference between the base-case and ULEZ Package 2 burdens). Hospital admissions (HA) show the burden or relative change in burden in the study year (2020 or 2025) associated with the pollutant change in that year. Chronic mortality values reflect the total burden or change in burden in life years lost (LYL) over a 100-year assessment period associated with the change in pollution in the initial assessment year (2020 or 2025).
Table 8-B: Concentration response functions (CRF) used in Ricardo-AEA’s analysis of health impacts
Impact pathway Pollutant Inclusion CRF (% Source Pollutant Other of impact change in threshold in analysis risk rate per 10 µgm-3 change in pollutant concentration
Chronic PM2.5 Core 6% Defra N/A Ages 30+ years, uses mortality the lag profile recommended by COMEAP
Respiratory PM10 Core 0.8% Defra N/A All ages hospital admissions (HAs)
Cardiovascular PM10 Core 0.8% Defra N/A All ages (CVD) hospital admissions (HAs) -3 Chronic NO2 Sensitivity 5.5% HRAPIE >20 µgm Ages 30+ years mortality Impacts should be reduced by (up to) 33% to account for possible overlap with effects from long-term PM2.5 exposure uses the lag profile recommended by COMEAP
Respiratory NO2 Sensitivity 0.5% Defra N/A All ages hospital admissions
(Source: Ricardo-AEA, 2014)
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Table 8-C: Results of air quality health impacts analysis for the base-case and ULEZ Package 2 scenario in 2020
Scenario Region Chronic Chronic Respiratory Respiratory CVD HA Total Total
mortality mortality HA PM10 HA NO2 PM10 chronic respiratory
PM2.5 NO2 mortality HA all Base case Central 1,436 1,363 35 38 28 2,799 74 Inner 22,899 15,733 563 542 445 38,632 1,106 Outer 36,347 14,880 850 714 672 51,227 1,563 London wide* 60,731 32,206 1,448 1,294 1,145 92,937 2,742 ULEZ Central 1,424 1,042 35 33 28 2,466 69 Package 2 Inner 22,850 13,726 562 513 445 36,576 1,075 Outer 36,325 13,138 849 689 671 49,463 1,538 London wide* 60,648 28,097 1,447 1,236 1,144 88,745 2,682 ULEZ Central 11 322 0 5 0 333 5 Package 2 Inner 49 2,007 1 29 1 2,056 30 changes Outer 22 1,742 0 24 0 1,764 25 in burden London wide* 84 4,109 2 59 1 4,192 60
Those numbers in italics are NO2 impacts included in the extended sensitivity tests. *Totals may differ from individual sub-values due to rounding
(Source: Ricardo-AEA, 2015)
Table 8-D: Results of air quality health impacts analysis for the base-case and ULEZ Package 2 scenario in 2025
Scenario Region Chronic Chronic Respiratory Respiratory CVD HA Total Total
mortality mortality HA PM10 HA NO2 PM10 chronic respiratory
PM2.5 NO2 mortality HA all Base case Central 1,448 1,052 36 34 28 2,500 69 Inner 23,302 11,797 576 492 455 35,100 1,067 Outer 37,113 9,691 876 660 692 46,804 1,535 London wide* 61,908 22,720 1,487 1,185 1,176 84,628 2,672 ULEZ Central 1,445 915 36 32 28 2,360 67 Package 2 Inner 23,296 11,123 575 482 455 34,419 1,057 Outer 37,112 9,226 876 653 692 46,338 1,529 London wide* 61,898 21,429 1,487 1,167 1,176 83,327 2,654 ULEZ Central 3 138 0 2 0 140 2 Package 2 Inner 6 675 0 10 0 681 10 changes Outer 1 464 0 7 0 465 7 in burden London wide* 10 1,291 0 18 0 1,301 18
Those numbers in italics are NO2 impacts included in the extended sensitivity tests. *Totals may differ from individual sub-values due to rounding
(Source: Ricardo-AEA, 2015)
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8.4.9. The results of the core air quality health impacts analysis undertaken by Ricardo-AEA (and presented in Table 8-A and 8-B) suggest that the ULEZ Package 2 would deliver positive health benefits relative to the base-case in both modelled years of the study. The size of the benefit is seen to reduce between 2020 and 2025 corresponding to the decrease in the pollutant reduction impact, over and above the baseline, between the two study years.
8.4.10. The reduction in LYL associated with pollution (NO2, PM10 and PM2.5) reductions across Greater London in 2020 would total 4,192. However, not all the mortality benefits would fall in the first year of implementation (2020): this health impact is associated with reductions in chronic exposure and these impacts are modelled to accrue over a 100-year period2. The size of the benefit would reduce between 2020 and 2025 amounting to 1,301 life years lost in the latter. This corresponds to the decrease in the pollutant reduction impact between the two study years. The benefits associated with reductions in NO2 concentrations are significantly larger than those delivered through reductions in particulate matter due predominantly to the greater reductions in NO2 which would be achieved by the ULEZ Package 2. The equivalent savings in LYL for 2020 and 2025 attributable to PM10 and PM2.5 only amounts to 84 LYL and 10 LYL respectively.
(c) Impacts on different age groups 8.4.11. Ricardo-AEA undertook an analysis to assess the proportion of different age groups exposed to different levels of NO2 concentrations across London. The population in areas above the LVs split by age was calculated from the average concentration by output area data. Table 8-C and Figure 8-A shows the proportion of people exposed to concentrations of NO2 above the annual LV within three age categories: the young (aged 0-19), the elderly (65+) and the adult population (20-64).
Table 8-E: Different age groups exposed to different levels of NO2 concentrations across London
Age range Population % population
0-19 2,215,240 24% 20-64 5,851,215 64% 65+ 1,061,112 12%
(Source: Ricardo-AEA, 2015)
2 It is important to note that not all the mortality benefits will fall in that year: this health impact is associated with reductions in chronic exposure and these impacts are modelled to accrue over the 100-year period following the concentration change through the life-tables approach. This is to capture the more long term effect on health of the pollution change. The 100 year period is consistent with Defra cost benefit analysis guidance.
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(Source: Ricardo-AEA, 2015)
Figure 8-A: The population in areas exceeding NO2 limit values in 2020 split by age group
8.4.12. Figure 8-A shows that the age groups potentially most vulnerable to health impacts associated with air quality, namely children and the elderly, have lower proportions of their population in areas where NO2 concentrations exceed the annual LV relative to the average and adult populations. An assessment of the impact of the ULEZ Package 2 shows that the proportion of the population living in areas exceeding the NO2 annual LV decreases by at least 45 per cent for all age categories, and the impact is slightly greater for children and the elderly.
(d) Hospital, care homes and schools 8.4.13. Ricardo-AEA further analysed the impact of the proposed ULEZ Package 2 on the concentration of pollutants at schools, hospitals and care homes, as these buildings are disproportionately used by young people and older people, and therefore classified as sensitive receptors. The findings are presented in Appendix 1 and the EqIA. In summary, the ULEZ Package 2 would result in a large reduction in the number of care homes, hospitals and schools in areas of NO2 exceedences. The fall is greatest in central London, as follows: care homes - decreases from 1 (without ULEZ) to 0 (with ULEZ Package 2); hospitals - decreases from 29 (without ULEZ) to 10 (with ULEZ Package 2); and schools - decreases from 27 (without ULEZ) to 6 (with ULEZ Package 2). 8.4.14. The reductions in the number of care homes, hospitals and schools in areas of NO2 exceedences across London are shown in Table 8-F.
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Table 8-F: Reduction in the number of care homes, hospitals and schools in areas of NO2 exceedences across London
London-wide
Basecase Scenario % Basecase % Scenario
Care homes 9 4 1.2% 0.5% Hospitals 39 16 15.7% 6.4% Schools 71 25 2.5% 0.9% (Source: Ricardo-AEA, 2015)
(e) Monetary value of health benefits 8.4.15. The health benefits associated with the ULEZ Package 2 can be valued (i.e. presented in monetary terms) to show the economic benefit associated with reductions in air pollution. The valuation of health improvements captures a number of 26 economic effects, including the direct impact on the utility of the affected individual (commonly captured by the ‘willingness-to-pay’ of the individual to avoid the detrimental health outcome), reduction in medical costs and increase in productivity. Monetising the health impacts in this way is a common approach which allows the economic benefits of improved health outcomes to be compared to the costs of delivering the ULEZ Package 2 in cost-benefit analysis. 8.4.16. Ricardo-AEA has employed the Defra Impact Pathway Approach Guidance to estimate the monetary values attributable to the impacts on health. The improved health outcomes arising from the reduction in NOx, PM10 and PM2.5 under the ULEZ Package 2 for the Greater London Administrative Area (GLAA) are estimated to have a total monetised benefit of £103m in 2020 and £27m in 2025. These results, including the extended sensitivity analysis for inner/outer/central London and London-wide are presented in Table 8-G.
Table 8-G: 2020 Extended sensitivity health benefit
Region Chronic Respiratory CVD HA Total mortality HA
Low High Low High Low High Central 8,138.7 11.0 45.3 0.5 1.5 8,150.2 8,185.5 Inner 50,254.2 67.1 276.0 2.1 6.8 50,323.3 50,536.9 Outer 43,109.1 54.8 225.6 0.9 2.9 43,164.8 43,337.7 Greater 102,456.2 132.9 546.8 3.4 11.2 102,592.5 103,014.2 London (Source: Ricardo-AEA, 2015)
8.5 Conclusion 8.5.1. The assessment found that the ULEZ Package 2 would result in a reduction in the inhalation of airborne pollutants due to road traffic emissions (the health pathway) compared with a without ULEZ scenario. 8.5.2. Ricardo-AEA conclude that the ULEZ Package 2 would bring about important reductions in the health impacts associated with air pollution compared with a without ULEZ scenario, and would therefore be an important part of London’s overall strategy for improving air quality and limiting the associated health impacts. This is evidenced from: the analysis of the number of people who would no longer be in exceedence areas for NO2 after the introduction of the ULEZ Package 2; analysis of the mean exposure to NO2 and PM; and from the quantification of actual health benefits. 8.5.3. The size of the benefit is seen to reduce between 2020 and 2025 corresponding to the decrease in the impact of the ULEZ Package 2 on pollutant reductions between the two study years.
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8.5.4. The majority of health benefit and associated economic impacts realised from avoided mortality would be associated with reductions in NO2. This highlights the importance of the impact of ULEZ Package 2 on NO2 concentrations. 8.5.5. The improvements in health outcomes under the ULEZ Package 2 are estimated to have a total London-wide economic benefit valued around £103m in 2020 and £27m in 2025 for the London-wide area (all impacts are in 2014 prices and discounted to 2014). Please note: these figures are based on economic valuation specific to health considerations. 8.5.6. There are significant differences in the distribution of these benefits. Central London boroughs are forecast to experience the highest level of benefit due to the fact that this is where the ULEZ would be located and air quality problems are the most severe. It is the most deprived communities that on average would experience the largest reductions. Although the relative reductions are not forecast to be significantly greater than those experienced in less deprived areas, this is still important given that such communities are more vulnerable to air quality impacts on health. In areas of exceedence, other vulnerable groups, determined on the basis of age, are not expected to experience very different levels of beneficial impact of the ULEZ, compared with the population as a whole.
8.6 Recommendations 8.6.1. Anticipated impacts upon air quality from the ULEZ Package 2 are positive and therefore no mitigation is required. 8.6.2. Over time, the cost of producing low and zero emission vehicles is likely to reduce. This may make it more economically feasible for a greater proportion of London’s buses and other vehicle types to utilise these technologies. TfL should, where possible, continue to support the development of the low and zero emission vehicle market and facilitate their use through additional policies and proposals. 8.6.3. Further improvements in air quality could be enhanced through: encouraging increased usage of hybrid, electric and hydrogen buses. Initially, the greatest proportion of routes running these buses will be in central London. This could be extended into the Inner Zone and Outer Zone; reducing private motorised vehicle usage and increasing active travel and public transport use; and a more stringent ULEZ, which should be considered at the earliest opportunity.
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