New proposals to improve Air Quality - new Emissions Surcharge and the Ultra Low Emission Zone

Ealing Council appreciates Mayor ’s new emphasis to improve air quality in . We welcome both the new Emissions Surcharge and the proposed Ultra Low Emission Zone (ULEZ) expansion in principle. However, we have strong concerns over the boundary of the proposed ULEZ and would like to see its expansion to cover the whole of London actively considered.

We support London Council’s view that a long-term roadmap is developed showing how we will improve air quality in London well beyond the implementation of the ULEZ. London should aim for the safe levels of air pollution as set by the EU as a minimum, but have a long term view to reaching the levels set out by the World Health Organisation (WHO), which are more stringent. Additionally, in geographical terms we should aim for the whole of London to meet these levels at all times.

We welcome the Mayor’s commitment to only purchase hybrid or low emission buses from 2018 and retrofit existing vehicles and look forward to hearing more details of these initiatives.

Part 1 - Emissions Surcharge

1. To what extent do you support or oppose the introduction of a new £10 Emissions Surcharge on the Congestion Charge to discourage the use of older, more polluting vehicles in central London to improve air quality and health?

2. We are proposing that the Emissions Surcharge will start on 23 October 2017 as the earliest possible operational date for implementing the scheme. Do you agree with this implementation date?

Ealing Council supports the introduction of the Emissions Surcharge/T-Charge (ES) in October 2017 and we ask that full before and after monitoring data are made available in order to gauge the impacts of this and future emission control proposals.

We reinforce London Councils view that private hire vehicles should not be exempt from the ES. This is due to the increasing number of these vehicles in recent years and their consequent usage, plus the popularity of diesel vehicles in this group. We feel that applying the ES to them would be effective in moving more operators towards low emission vehicles.

3. Following the start of ULEZ in central London, to what extent do you support or oppose residents continuing to be liable for the Emission Surcharge, at the discounted rate of £1, during the ULEZ sunset period (for the first 3 years, while residents do not pay the ULEZ charge)?

Regarding the residents discounted rate (‘sunset period’), either a sliding scale increasing over time, or a stepped increase, should be considered to encourage more, earlier switching away from diesel vehicles.

4. To what extent do you support or oppose the exemption of historic tax class vehicles?

5. To what extent do you support or oppose the exemption of Showmans vehicles?

For consistency and parity, at least some controls should also be applied to these vehicles to control their use. They should not just have a blanket exemption.

6. Do you support or oppose including L-Category vehicles (e.g. three wheeled vehicles and quadricycles) that currently pay the congestion charge?

For consistency and parity, L-Category vehicles should also be included in the ES.

7. Do you support or oppose including 9+ seater vehicles, such as coaches, buses and minibuses?

For consistency and parity, 9+ seater vehicles, such as coaches, buses and minibuses should also be included in the ES.

Part 2 - Bringing ULEZ forward to 2019

8. Do you support or oppose the idea of bringing forward the introduction of the central London ULEZ to 2019 to improve air quality and health?

We support the earlier introduction of the ULEZ to 2019, to deliver air quality improvements sooner. Again, we need full pre and post implementation monitoring data are made available to us to understand the full impacts, plus to gauge impacts of future emission control proposals. Part 3 - Expanding ULEZ to inner London

9. Do you support the overall principle of expanding ULEZ (up to but not including) the North and South Circular roads for all vehicles?

10. When do you think the expansion of ULEZ (up to but not including) the North and South Circular roads for all vehicles should be introduced? Please choose the year you think would be most appropriate.

In principle we support expansion of the ULEZ, but ask that full consideration is given to its expansion up to the M25. We have strong concerns over the likely negative boundary effects as Ealing would be split by the A406 border. Effects could include: potential traffic displacement and the resultant increased congestion outside the ULEZ, increased air pollution in areas outside of and along the boundaries (for instance the A406 North Circular Road carries over 30,000 vehicles per day currently, which is likely to increase).

There are also concerns regarding the impact the charge could create for residents and small businesses that have to travel across this border regularly. For residents this could be those who have to commute to work via car, or for people visiting family in hospital. We support London Councils’ suggested approach to negating this impact for residents by encouraging modal shift with a diesel scrappage scheme.

Expansion of the ULEZ to the M25 would realise greater air quality and health benefits for all of London, particularly for outer London. This includes deprived communities such as parts of Greenford and Northolt adversely affected by emissions from the A40 and A312.

11. An expanded ULEZ will affect many more cars, vans and motorcycles. Do you think the daily charge for the ULEZ in inner London (between the Congestion Charge zone and the North and South Circular roads) should be the same or different to the current charge for the ULEZ in central London?

For consistency and parity, the charge for the ULEZ should be the same in both areas.

Part 4 - Expanding ULEZ Londonwide

12. To what extent do you support or oppose the overall principle of expanding ULEZ London-wide for heavy vehicles?

We strongly support London-wide expansion and want to see this considered for all vehicles (including coverage of a significant traffic generator). This would realise full air quality and health benefits for all of London, particularly outer London. 13. When do you think the expansion of ULEZ London-wide for heavy vehicles should be introduced? Please choose the year that you think would be the most appropriate.

We support the Mayor’s introduction of the ULEZ in 2019.

Part 5 - Further comments

There are issues with the validity of the ‘Euro’ standard emission tests, particularly as the vehicles do not perform as well in real world conditions. We would like the Mayor and TfL work with the government to investigate more robust methods of vehicle emission testing and measurement.

For consistency and parity, we think that motorcycles should be controlled at the same emission standard as other petrol vehicles, i.e. Euro 4 standard. In particular, two stroke engines that are frequently used in motorcycles can be very polluting.

14. If you have any further comments about any of the proposals to improve air quality in London, please write these in the box below.

We concur with London Councils that there is a need for more information and data behind the assumptions made in the Mayor’s consultation. There should be more transparency about how decisions have been made. There is a need for more detailed cost/benefit analysis of different options around the expanded ULEZ boundary, and other potential proposals, so that boroughs are able to make informed decisions. We have not seen that anything other than the north/south circular ULEZ option has been considered. It is important for boroughs to understand how TfL have conducted their modelling, for instance what methodologies and data sets have been used. This allows a truly inclusive and effective discussion to take place, and ensure that a solution is found that best suits all of London’s needs.

It has been confirmed by the Mayor that the inner London ULEZ would worsen air pollution in some local areas, but improve the air quality in London on average. There is a need for more information regarding the locations expected to face increased levels of air pollution. It is therefore not possible for boroughs to support this proposal without a guarantee from the Mayor that there would be additional funding for specifically developed solutions to mitigate this. For example, the proposed Clean Bus Zones would need to cover any areas that suffered worse air quality as a result of the inner London ULEZ.

If air quality in Ealing was made worse we would be put in a very difficult situation, and would find it difficult to support these plans if residents were affected negatively, even though we support the Mayor’s objectives in principle. A solution needs to be found that benefits everyone and it is clear that a London wide option is better. We ask that the Mayor to conduct modelling on a London-wide scheme, which could be a strengthened LEZ/ULEZ that becomes tighter over time.

We welcome the Mayor’s commitment to only purchase hybrid or low emission buses from 2018 and retrofit existing vehicles and look forward to hearing more details.

We are also interested to hear more about the proposed 12 low Emission Bus Zones and propose that the Haven Green outside is seriously considered as a low Emission Bus Zone. This is already part of the Ealing Broadway Air Quality Focus area and has high exposure due to the number of station passengers, (currently over 23 million per year and set to increase will ) plus shoppers and workers in the adjacent Ealing Broadway town centre. There are also 10 London bus routes that use this facility.

We also note that the size of private cars has been growing with adverse effects on congestion and hence emissions, especially in narrow and residential streets, both when passing and parking. The most popular cars have increased in width by around 16 per cent, for example from a 1.57m Ford Escort to a 1.85m Ford Focus. Also many more cars are even larger due to the popularity of Sports Utility Vehicles. Besides increasing congestion, larger vehicles can create issues when overtaking cyclists and can be more off-putting for novice cyclists. Therefore, we ask that the Mayor and TfL look into encouraging smaller vehicles over larger vehicles in London. We look forward to working in partnership with the Mayor to improve air quality both in Ealing and across London.

Produced by Russell Roberts, Principal Transport Planner with input from John Freeman, Regulatory Services Officer (Pollution). Reviewed by Cllr. Bassam Mahfouz, Cabinet Member Environment and Transport and Cllr Julian Bell Leader of Ealing Council. 16 December 2016