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TfL Starts Consultation on Proposed ULEZ Expansion

I know tfl has to ''consult'' but it's a fait accompli as we all know. Maybe if his little twerpship devoted as much energy to knife crime, house building and the state of public transport as he does to the relentless pursuit of money from motorists he'd be less disliked

Peter King ● 1585d36 Comments

He is being forced to implement measures like this to raise revenue because the government has squeezed the funding it supplies to transport in London.

Jeremy Parkinson ● 1585d

Pollution kills far more people in London than knife crime

John Hall ● 1585d

Yes reducing higher polluting cars in London is a good thing.

Paul Campbell ● 1585d

try telling that to parents who have lost their kids

Peter King ● 1585d

PK: "try telling that to parents who have lost their kids"To knife crime? Or pollution? Or car accident?It's hardly an either/or, is it?

Richard Cathcart ● 1585d

The reference was to knife crime. By the way, only friends get to call me PK

Peter King ● 1585d

It’s a false equivalence bordering on callousness to equate knife crime deaths with deaths from pollution.Whereas a the catastrophic life from a stabbing is unambiguously from a single cause, poor air quality serves to shorten life expectancy and, with the exception of rare cases, is one of a complex mix of factors which can include poor diet, stress, alcohol, drugs. Air pollution kills people in the same way that sugary carbonated drinks and cheap white bread kill people. The one factor that everyone who analyses these things will tell you that the strongest link of any given factor to early mortality is being on a low income so the primary test of any public policy when it comes to not ‘killing people’ should be does it or does it not make people poor. By targeting older vehicles the ULEZ seems almost designed to act as a regressive tax and it hits hardest the ‘just about managing’ section of society and has tipped some over the edge.This would perhaps be easier to justify if there was some sort of meaningful public health benefit to the measure. The ULEZ is most effective in reducing the amount of nitrogen dioxide in the air most of the vehicles that need to be replaced are Euro 5 or older standard diesel. The reduction isn’t massive in wider scheme of things but a difference is being made. Just how harmful nitrogen dioxide can be is not something on which there is an academic consensus. As it generally occurs alongside particulates when emissions are made, separating the specific impact of this gas is difficult. One thing research does show however, is that if you have a gas cooker, particularly with a gas stove, you will be exposed to up to 100 times the levels of Nitrogen Dioxide in your own home as you would be outside by a busy London street. See the following link for a summary of research on the subject.https://www.vox.com/energy-and-environment/2020/5/7/21247602/gas-stove-cooking-indoor-air-pollution-health-risksThis raises the question about why people who are making very alarmist statements about the toxicity of our air due to vehicle emissions and quoting high number for the number of people dying as a result are not focused on where this problem is most acute i.e. in our kitchens. If tens of thousands are dying due to fumes from cars outside then, give relative levels of concentrations of the same harmful gases in a large proportion of homes, then wouldn’t hundreds of thousands of people be dying from this cause?The actual impacts of the ULEZ on life expectancy are probably too small to be identified and measured but I do believe there is a strong possibility that it will not serve to reduce it because any public health benefit from cleaner air will be outweighed by the number of people dying younger due to stress related to the financial impact of the scheme particularly during this ongoing cost of living crisis.What needs to be recognised is that the primary purpose of initiating and extending the ULEZ is financial and not for public health reasons. Due to vicious financial squeeze put on TfL by the government, new sources of revenue need to be developed. Reports suggest that the projections made by TfL for the revenue generated by the first stage of the ULEZ were well below what was expected as people switched to new vehicles more quickly and changed their driving habits so that they didn’t enter the zone but did business outside it. The capital investment in the scheme has been huge and therefore a very strong incentive has arisen to increase the returns it brings by extending its reach. Despite all of the above, I do believe Sadiq Khan is right to extend the ULEZ. He has little choice as the ongoing financial crisis for TfL continues and the question is not will public transport in London get worse both it terms of cost and quality of service, but by how much. The money from a bigger ULEZ will not solve this problem but it will serve to slow the decline of public transport in London and therefore will slow the inevitable resulting increase in private vehicle use.

Jeremy Parkinson ● 1583d

Can't disagree with a word of what you say. I do think Sadiq Khan recognises that the ULEZ is regressive and the hope would be that a fairer and more sophisticated charging system will be developed which provides TfL with a stable revenue. At the moment the revenue from a ULEZ extension will go into decline from the day it is implemented.

Francis Rowe ● 1583d

Jeremy, it is very far from a false equivalence. You may not be aware but recent successful methods of tackling knife crime follow epidemiological methods. To say that it has a single cause is not correct, just as covid or pollution related deaths do not. 

John Hall ● 1582d

You are confusing cause of death with broader causes of a particular phenomenon. If you get stabbed, that's what it will say on your death certificate. As Jeremy says, the false equivalence you are making borders on the insensitive.Seeking better air quality is fully justified by the health benefits it brings to us all. Presenting the available data in an alarmist and misleading way probably only serves to undermine the argument.

Francis Rowe ● 1582d

Jeremy's probably right that the ULEZ is being used as a politically palatable method of introducing road pricing.He is probably wrong that extending the ULEZ will kill more people than air pollution.Francis complains "the revenue from a ULEZ extension will go into decline from the day it is implemented" - but the idea is that you tax the thing you want less of (i.e. pollution), so it is meant to decline and that's a good thing.They can always tweak it by bringing in charges on all ICE vehicles regardless of emissions and/or convert it into a congestion charge.

Ed Saper ● 1582d

Ed, pollution won't decline overall as a result of the ULEZ as the vehicles no longer entering the zone due to the charge are mainly still going to be on the road. The scrappage scheme only deals with a small fraction and is something that could be done without implementing a ULEZ.

Francis Rowe ● 1582d

I don't believe the falling revenues for the ULEZ scheme can be said to be a good thing. The pollution benefits of the change in vehicle type are pretty marginal. The much more significant net benefit to air quality comes from the investment it allows in public transport. This declines as the revenue declines and, given the cost of the network and the much lower than expect revenue, we have to be concerned that the scheme becomes revenue negative and ends up taking money from public transport schemes.It was anticipated by TfL that revenue would decline but they probably didn't expect the fall to be as significant and they can't have foreseen the huge rise in petrol prices and the cost of living crisis. Originally a fairer more sophisticated road pricing scheme would have been the next step for the infrastructure put in place for ULEZ but this will be difficult to implement over the next few years as driving has already become much more expensive. Extending the current charge to all non-electric vehicles is unlikely to be an option. I don't envy the Mayor having to work out what to do.

Jeremy Parkinson ● 1582d

There are on average 44 lightening strikes per second in EnglandEach is said to create 7kg of nitrous oxides.I make that 9.7 billion kgs per annum.Completely swamps the emissions from 40,000,000 road vehicles.(that figure for all UK)Who has a hotline to reduce the number of strikes?  Step forward Sadiq/Boris/Keir.  (given his ability for survival (so far), Boris must be the favorite)On the other hand"Hydroxyl radicals, which are "crucial" to the atmosphere's ability to cleanse itself, are directly produced by flashes of lightning, and those flashes produce the radicals in quantities far greater than expected, a new study published Thursday in Science found."So its the usual "on the one hand this, on the other hand that"

James Roy ● 1582d

Motorists have always been an easy target.  I was interested to hear EU citizens now have the right to sue their respective governments over poor quality air. I wonder when we will get this right.

Nicholas Beard ● 1582d

Amazingly David Davies made a good point on this on Any Questions last week. He pointed out that the standard Civil Service cost benefit analysis tended to mean that London infrastructure projects were approved because there were more passengers who were expecting to pay higher fares.The approach has changed now and it is worrying to see some of the national press coverage on the Elizabeth line which basically said London has had its turn - now for the rest of the country.I think we will have to wait for a Labour government for TfL's finances to be stablised and public transport to move back to an upward trend such is the hostility of the Tories to Sadiq Khan. In the meantime the Mayor will be forced to raise revenue from wherever he can.

Francis Rowe ● 1580d

"..the standard Civil Service cost benefit analysis tended to mean that London infrastructure projects were approved because there were more passengers who were expecting to pay higher fares."Andy Burnham (current Labour Mayor of Manchester, who was the minister responsible for signing off Crossrail) made a similar point in the Evening Standard recently, while also saying it was the North's turn for transport investment. So don't hold your breath for a future Labour government improving TfL's finances.

Richard Greenhough ● 1580d

There would definitely be a distinct improvement in TfL's finances under a Labour government and at least a slowing of the decline in the capital's transport infrastructure. I don't expect a future Labour government to invest significantly in London but I would anticipate an end to the politically motivated manufactured uncertainty about TfL's short term financing position which makes any planning or improvements more or less impossible.The removal of Johnson would also improve the position as he and his transport advisor Andrew Gilligan have a deeply held grudge against Sadiq Khan and will do whatever they can to humiliate and frustrate him. Unfortunately recent events suggest we will be stuck with them both for a couple of years.

Francis Rowe ● 1580d

The ULEZ is equivalent to cigarette taxes.Smoking is estimated to cost the NHS £2.5bn per year across the entire UK and raises about £10bn in duties.Pollution is estimated to cost over £10bn in health costs in London alone and rather neatly, transport is responsible for about 25% - or £2.5bn in health costs.  Smoking taxes started off low and steadily increased as that harm to the individual and the people around them became better understood and the taxes more politically acceptable.Raising the cost of cigarettes by 10% via taxation has shown to reduce smoking by 4% - and just as smokers can move over to electronic cigarettes which are lower harm, drivers can move to EVs.    Pollution taxes are starting off low, the ULEZ will raise about £200m, so they won't come close to paying for the direct costs of pollution, but they can be increased over time.If the last smoker stubbed out his last cigarette, there will be a £10bn shortfall of revenue, but it will also be a cause for celebration, and by then we'll be taxing sugar more heavily anyway.  Similarly, if we come to rely on pollution taxes to pay for public transport and every single vehicle is zero emissions, we'll have a shortfall, but we can live with it by taxing fuel, congestion, parking, Uber, Amazon etc.

Ed Saper ● 1580d

Sorry Ed but this is a completely false analogy. Smoking is a personal choice and it benefits both society and the individual if it is reduced. The vast majority of vehicle movements across London are not made by choice but are unavoidable. A good proportion are commercial (deliveries, business related, taxis) and generally only the wealthy will use a private car with no consideration for the cost of the journey.Therefore there is little elasticity of demand so taxing transport more will raise the cost of living with relatively limited impact on demand. More consideration needs to be given to the fact that a large proportion of the population has a very limited disposable income and increased taxes will have a disproportionate impact on their lives.The ULEZ's primary benefit is a reduction in nitrogen dioxide but this is very marginal in the context of overall London Air Quality. If you really believe that this is material and contributes to £2.5bn in health costs wouldn't your efforts be better employed campaigning for the banning of gas ovens which expose owners to much high concentrations of nitrogen dioxide than they would get standing by the most polluted road?You might believe that a policy of taxing people until they either change their habits or decline further into poverty is justified but I don't think there will be much support for this approach. Better air quality should be achieved by investment in public transport but that isn't likely to happen to the degree needed at present. The ULEZ achieves little in terms of improved air quality and disproportionately affects people who are struggling financially but it is a necessity of desperate times because otherwise there would be a huge hole in the funding for London's transport. We shouldn't pretend otherwise.

Jeremy Parkinson ● 1580d

"More consideration needs to be given to the fact that a large proportion of the population has a very limited disposable income and increased taxes will have a disproportionate impact on their lives."Exactly the same argument is deployed against taxes on cigarettes, alcohol, sugar etc. They hit the poorest hardest while the wealthy can smoke or eat themselves to death....except they don't.  Consumption taxes are regressive and always hit those with smaller disposable incomes harder, but they also have the biggest impact and achieve better outcomes, particularly for those with the lowest disposable incomes. "The vast majority of vehicle movements across London are not made by choice but are unavoidable."  Exactly the same argument was made the nicotine was addictive and therefore people didn't have a choice.Vehicles don't have to be polluting - but since the cost of pollution is carried by everyone and not the polluter, it is cheaper to pollute than invest in an EV, bike or Chiswick Tractor.  When that logic changes, so will the makeup of the vehicle fleet - both personal and commercial.  60% of car trips are made for shopping, leisure and personal business purposes, just 20% for work purposes, while a third of car trips are shorter than 2km.It is almost certainly bollocks that the vast majority of current personal and work journeys currently done by car can only be done by car.Many could be replaced with public transport, walking or cycling - either immediately or following improvements in infrastructure.  It might not feel like that to those who are addicted to their cars, but for many (not all) driving a petrol car to the shops a mile away "is a personal choice and it benefits both society and the individual if it is reduced".

Ed Saper ● 1579d

"It is almost certainly bollocks that the vast majority of current personal and work journeys currently done by car can only be done by car"Yep - that being the core premise the rest of the argument wasn't even worth reading.

Paul Campbell ● 1579d

You offer no evidence only your own opinion that it 'is almost certainly bollocks that the vast majority of current personal and work journeys currently done by car can only be done by car' but let's just assume for a second that you are right.Assuming you significantly add to the tax burden of people who continue to use their cars you are likely to have a limited effect on the school-run mum SUV drivers who exercise you so much for whom the extra expense will be a fraction of what they have spent on their car. For your policy to be effective it will need to encourage modal shift from drivers with greater sensitivity to cost who will tend to be those on lower incomes.We have already seen a significant rise in cost for drivers over the last few months which will have increased costs for people who need to drive on a regular basis by more than you could dream of adding to their tax burdens. This will have encouraged some to shift to different means of transport but for most it will have resulted in a squeeze in income at the worst time.You are two relatively fortunate men whose jobs and circumstances allow you to operate with relatively little car usage. You need to develop a bit more empathy with the vast majority of working people in this country for whom this is not possible particularly those who earn far less than you and for whom the current rise in costs is catastrophic. Wanting to load more expense on them at this point with policies that are bound to be largely ineffective in their stated aims is just callous.

Jeremy Parkinson ● 1579d

Yes we offer no evidence only our own opinion to refute your evidence-free opinion. Correct. As for the rest of your evidence-free opinions: ditto.

Paul Campbell ● 1579d

Car ownership in London drops off steeply as household income is reduced: 83% of households with income over £100k have access to a car compared to only 19% with incomes less than £5k. It's clearly not correct to say that "the vast majority of vehicle movements across London are not made by choice but are unavoidable". Using a car in London might appear to be unavoidable but only for those who have sufficient income to operate one in the first place.

Tom Pike ● 1579d

Tom, looking at income in this way gives a distorted picture. Car ownership is very low in the bottom decile for income. However, the relationship between income and car ownership breaks down as you move up the scale. Also what is more important that car ownership is use of a vehicle to make a living. Very few bankers, ad execs, university professors, IT consultants, company executives need to use a vehicle for their work. This does not apply to lower paid jobs such as those in the building trade, delivery drivers, taxi drivers, health workers etc. In addition house prices are quite closely linked to transport accessibility so people often can't afford to live close to their place of work. If you still have children of school age, ask their teachers about this and they will explain to you why so many of their colleagues drive to work, speak to a police officer and they will tell you than none of their team live in central London, speak to hospital staff and you will hear a similar story. Commuting into London by car isn't generally something that people do as a lifestyle choice.It is these lower and middle income earners that are hardest hit by the ULEZ because they will tend to have older cars which they will have had to replace at a cost which may seem not particularly material to you but can be catastrophic for some people.I believe is it correct to say the majority of vehicle movements in London are unavoidable (assuming current state of public transport provision). I looked closely at this some time ago using the DfT numbers for Chiswick High Road for total vehicle movements, adjusted on a conservative basis for private hire and then using TfL definitions of what could potentially be cycled or walked the result was 18% for cycling and 7% for walking.These potential numbers do not take account of journeys that need to be driven because the person or a passenger is disabled or elderly, because something difficult to carry is being transported, because there is severely bad weather, because it is necessary for employment and a whole host of other reasons why a relatively short journey may be unavoidable.

Jeremy Parkinson ● 1579d

Funds went on bike lanes which at least children are using during schoolterm, it was stated on here that they don't want reliable services, they want to make money out of motorists.

Janice Evans ● 1579d

The relationship between car ownership and household income does not “break down” at high income levels.  It rises steadily to around 80% at £75k and then stays flat. Car numbers on the High Road have fallen significantly over the last two decades, from 16k in 2000 to £11k in 2018. They have fallen further to around 8k since the pandemic.  In just the last five years, bike counts have climbed from 1.6k to nearly 3k. The idea that only 17% of car trips on the High Road are unavoidable doesn’t stand much scrutiny.

Tom Pike ● 1579d

I didn't say 17% of car trips on CHR were unavoidable I said vehicle movements if you assume no improvement in public transport.The biggest factor in the fall in car journeys on Chiswick High Road will have been improving public transport. Bus provision was substantially increased, the Overground has been substantially upgraded and there have been significant improvements on the District Line. Investment in public transport works which I am prepared to accept a profoundly unfair tax like the ULEZ charge is probably justifiable.We've discussed the figures about cycle trips along the High Road before. The CCTV based figures from TfL you quote are indicating that around half of cyclists on the High Road are not in the cycle lane which even C9's most blinkered opponents would not claim therefore these numbers need to be treated with caution and you can't build a sound argument based on them.

Jeremy Parkinson ● 1579d

If extending the ULEZ zone means fewer high polluting vehicles on Greater London roads, why not?  Kahn should have done it years ago instead of playing political games. He should also ban all diesel vehicles in the current  ULEZ zone if he is serious about reducing pollution but I doubt that he is if it doesn’t suit his political agenda.

Steve Taylor ● 1579d

"You are two relatively fortunate men whose jobs and circumstances allow you to operate with relatively little car usage"Ed just air freights product to offset carbon emissions.

David Lesniak ● 1578d

Rubbish. Once again the needs of those unable to use public transport (36% of Londoners over 65 have a recorded disabilit, overall 11% of Londoners have a recorded mobility issue according to LTDS),are dismissed in a single sentence by the blinkered.

N V Brooks ● 1578d

Why ban all Diesels when the particulate emissions of Euro6d compliant vehicles is often significantly less then the petrol equivalent?  We need to adopt the Dutch model of random roadside emissions testing with the immediate impounding of, and a swingeing fine for, vehicles that fail to meet the standards.

N V Brooks ● 1578d

“ We need to adopt the Dutch model of random roadside emissions testing with the immediate impounding of, and a swingeing fine for, vehicles that fail to meet the standards.”Yes, good idea. I would support that wholeheartedly!

Steve Taylor ● 1578d

First of all, the reduction in traffic numbers on the High Road is similar to that for cars, a drop of 23% between 2002 and 2018, from 19k to 15k. Improved public transport may well have contributed partly to that fall, but as far as that has occurred it indicates that those vehicle trips can indeed be substituted, and are therefore not unavoidable. The increase in cycle counts I gave is taken from TfL's manually collected annual series, not the camera counts. However, the 2021 manual data agrees well with the camera counts for hours monitored on 10/11 June last year: the manual count was 2889 while the sum of the S62 cycle lane and S62 eastbound roadway at a similar location comes to 2753, less than a 5% difference. I've excluded the westbound roadway bike counts because, as you mention, there is an issue with this camera picking up a portion of the bikes in the cycle-lane. Hence including them leads to an  overestimate of the proportion of bikes in the roadway. Using just the cycle lane and eastbound roadway numbers, 83% of the cycle counts came from the cycle lane.The vehicle counts using both the east and westbound roadway cameras come to just over 8k, a drop to 42% of the 2002 levels, while car counts have fallen even lower to 35% of 2002 levels. Because of the more than doubling of bike counts, bike numbers reached over 50% those of cars in June last year and peaked at 54% in September. The increase in cycling on the High Road is exceptional on a London-wide basis. Between 2019 and 2021, Chiswick High Road has seen the largest increase in bike counts of any of the 450 Outer London locations monitored by TfL. Also in the top ten was Boston Manor Road. It's unlikely to be coincidental that both of these roads provide segregated cycle lanes. As I said, the observed shifts in travel mode along the High Road already demonstrate that a much higher proportion of vehicle trips than your estimate of 17% are avoidable. Once there is a clear run from the High Road to Hammersmith Road, we might even see bike counts overtake car counts along stretches of C9.

Tom Pike ● 1578d

“How to avoid ULEZ charges:1.Buy a petrol car. Since September 2015, every car sold has had to meet the Euro 6 emission standard; that goes for petrol and diesel cars. ... 2.Buy a recent diesel car. ... 3.Invest in a classic car. ... 4.Go electric. ... 5.Choose a modern van. ... 6.Run away and join the circus. ... 7.Drive a tank (or tractor) ... 7.Move to central London.”

Steve Taylor ● 1578d