Air pollution is one of the most a significant challenges facing London. The equivalent of around 9,400 deaths per year in London are attributed to air quality related illnesses. Soon after his election in May this year, Mayor of London, Sadiq Khan, called for new proposals to urgently tackle London’s current poor air quality.
We have now developed detailed proposals for the implementation of the Emissions Surcharge (ES), and ideas for improving the Ultra Low Emission Zone (ULEZ).
The first of these proposals is to introduce the ES (more commonly known as the ‘T-Charge’) in 2017, for the older, more polluting vehicles driving into and within central London. This would be in addition to the Congestion Charge.
This consultation contains detailed statutory proposals for the ES. The introduction of the ES will involve changes to the current Congestion Charge Scheme order, subject to this consultation. The Mayor will consider representations received and decide whether or not to approve them (with or without modifications) in early 2017.
Why improve air quality?
The health impacts of the two pollutants of concern in London are:
- Nitrogen dioxide (NO2): At high concentrations, NO2 causes inflammation of the airways. Long-term exposure is associated with an increase in symptoms of bronchitis in asthmatic children and reduced lung development and function
- Particulate matter (PM): Long term exposure contributes to the risk of developing cardiovascular and respiratory diseases, including lung cancer. Research shows that particles with a diameter of 10 microns and smaller (PM10) are likely to be inhaled deep into the respiratory tract. The health impacts of particles with a diameter of 2.5 microns or smaller (PM2.5) are especially significant, as smaller particles can penetrate even deeper
Research commissioned by the GLA group has quantified the impact of NO2 on the risk of illnesses that could bring forward death, in addition to the previously identified impact of PM2.5. It is estimated that in 2010 the combined impact of NO2and PM10 was responsible for the equivalent of 9,400 deaths. The scale of the air pollution crisis in London and the prospect of the situation getting worse means further action is vital.
The UK’s Air Quality (Standards) Regulations 2010 set legal limits for concentrations of pollutants in outdoor air. These are based on European Union (EU) directives, which will remain in force regardless of the UK leaving the EU, unless specifically repealed.
The Department for Environment, Food and Rural Affairs (Defra) has reported compliance with PM limits for 2015 across England and Wales, with most areas in London also falling below the legal limits. However, there are no safe limits for PM2.5 which is more damaging to health than PM10. Health evidence suggests that further emissions reductions, will bring about improvements in health for Londoners. Without further action there is the prospect of PM2.5 emissions increasing if traffic levels rise.
Crucially, large sections of the Capital continue to exceed limits for NO2, which is likely to continue to occur beyond 2020, and this is why more action needs to be taken. Within the first six days of 2016, Putney High Street breached legal limits in terms of the number of times pollution episodes are allowed.
Concentrations of annual average NO2 in 2013 (Source: LAEI 2013)
Road transport is a significant source of NOx, which forms harmful NO2 in the atmosphere. Currently around 50 per cent of NOx emissions in Greater London are from road transport, with diesel vehicles forming a significant proportion of this. The graph below shows the sources of NOX in Greater London.
NOx source apportionment in Greater London in 2013 (LAEI 2013)
What is already being done to improve air quality?
London’s air quality has improved significantly in recent years. However, more needs to be done to ensure that we continue to tackle pollution effectively and address public health concerns as London’s economy and population grows. We already have a number of schemes planned:
Ultra Low Emission Zone
An Ultra Low Emission Zone (ULEZ) is due to come in effect at the end of 2020 for central London. This will set emissions standards for vehicles entering central London. It is expected to approximately halve NOx emissions in central London. To further improve air quality, the Mayor and many Londoners are interested in introducing ULEZ sooner than 2020 and for it to cover a larger area.
Reducing emissions from taxis and private hire vehicles
New Taxi and Private Hire Vehicle (PHV) licencing conditions were confirmed by TfL last year. These require taxis from 2018, newly manufactured PHV’s from 2020 and newly licenced PHV’s from 2023, to be Zero Emission Capable (ZEC). In summary, ZEC vehicles are plug-in hybrid and zero emission vehicles. The Mayor has recently published his action plan to improve taxis and private hire vehicles, which includes measures to reduce emissions and can be found by visitinghttp://content.tfl.gov.uk/taxi-and-private-hire-action-plan-2016.pdf
Low Emission Neighbourhoods
We have taken significant steps to reduce air pollution from our bus fleet. All buses in Greater London currently meet Euro IV standards or better for NOx. To support the ULEZ, all double-decker buses operating in the Congestion Charging zone will be hybrid electric vehicles and all single-decker buses in the zone will emit nothing from their engine exhaust (eg they will be full electric or hydrogen models). In response to the Mayor’s ambition for TfL buses to do more, we are proposing the following additional improvements to reduce emissions from the TfL bus fleet:
- Ensuring all of our buses in central London are compliant with the ULEZ emission standard ahead of its introduction (by 2019) and a commitment that our double-decker buses operating in the area will be hybrid
- Implementing up to 12 ‘Low Emission Bus Zones’ across London – tackling the worst pollution hotspots by concentrating cleaner buses on the dirtiest routes. The first zones will be delivered in Putney High Street and Brixton/Streatham from 2017;
- Expanding an innovative Euro VI bus retrofit programme to 3,000 buses by 2020 (up from 800) and to over 5,000 by 2021; and
- An ambition to purchase only hybrid or zero emission double deck buses from 2018
The new ES (more commonly known as the ‘T-Charge’) is proposed in central London to discourage the use of older, more polluting vehicles. It is also intended to act as a stepping stone ahead of the full introduction of the ULEZ (see section below), when tighter vehicles emissions standards would come into force.
This consultation is the formal statutory consultation on the ES proposals.
The ES will be an additional daily £10 supplement to the Congestion Charge payable by owners of older, more polluting, vehicles that drive in the Congestion Charging zone during charging hours
. It will cover older diesel and petrol vehicles that do not meet the Euro 4/IV emissions standard for NOx and PM emissions. Pre-Euro 4/IV vehicles are generally those registered in 2005 and older.
It will mean that:
- All vehicles subject to the £11.50 (or £10.50 for autopay) Congestion Charge (ie not entitled to an exemption or discount) that do not meet the Euro 4/IV standard would qualify for an additional daily £10 ES when entering the Congestion Charging zone within operational hours (Monday – Friday, 7am – 6pm, excluding Bank holidays and the period between Christmas and New Year)
- All vehicles that receive a ‘9 or more seats’ 100% Congestion Charge discount (eg minibuses, coaches) and do not meet the Euro 4/IV standard would need to pay a daily £10 ES
- There are some additional discounts and exceptions to the ES, as described below under Discounts and Exceptions
Hours of Operation
The ES would form part of the existing Congestion Charge scheme, with the same operational hours. This allows the Surcharge to be implemented quickly and efficiently, making use of existing signage and operation systems. It will also apply to the time of day when people are most exposed to poor air quality.
The ES is part of the Congestion Charge scheme and therefore would apply to the same area.
It is proposed that the same discounts and exemptions that apply to the Congestion Charge will also apply to the ES, except for:
- Non-TfL buses, coaches and other 9 + seater vehicles, will be subject to the Emission Surcharge. We are seeking views on whether discounts for light duty 9+ seater vehicles such as minibuses should be considered;
- Vehicles with a historic tax class (40 years and older) and/or commercial vehicles manufactured prior to 1973, that currently qualify for the congestion charge would be exempt from the ES; and
- Specially constructed or modified Showmans Vehicles, that currently qualify for the congestion charge will get a 100% discount from the ES
Residents with non-compliant vehicles who pay via Congestion Charge Auto Pay would only pay £2.05 per day (90 per cent discounted Surcharge of £1 plus 90 per cent discounted Congestion Charge of £1.05) to drive in the Congestion Charging Zone in charging hours.
Vehicles that are parked all day will not be charged for that day. Residents with non-compliant vehicles registered for the Congestion Charge discount will automatically be registered for the ES discount.
The table below shows the additional discounts and exemptions proposed
Emission Surcharge Standard
The proposed minimum emissions standard will be Euro 4/IV for both petrol and diesel vehicles and Euro 3 for category L vehicles. This has been set as an introductory or transitional standard ahead of the ULEZ starting – adopting the same petrol standard, but acknowledging that 2017 is too soon to expect high levels of compliance with a diesel Euro 6/VI standard as proposed for the ULEZ. The table below shows the average number of vehicles per day that currently do not meet the Euro 4 and Euro 6 emissions standard.
L-Category vehicles (excluding motorcycles, mopeds and scooters)
The Euro standards for L-Category vehicles (motorised three-wheeled vehicles and quadricycles) are less advanced than for other categories. Euro 4 is the latest standard for them, only introduced from 2017. In recognition of this, the minimum ES standard will be set as Euro 3 for L-category vehicles that currently pay the Congestion Charge. This is in line with the agreed standards for the ULEZ.
Two wheeled motorcycles, mopeds and scooters are currently exempt from the Congestion Charge. It is proposed they will also be exempt from the ES.
Proposed Start and End Date
It is proposed that the ES will commence on 23 October 2017. It is expected that the Mayor will be requested to decide in February 2017 whether or not he wants the proposed ES proposal to proceed (with or without modification). He will take this decision taking into account feedback from this consultation. This provides an eight month advance notice ahead of the proposed ES scheme starting.
Under the current approved ULEZ scheme, residents living in the zone and registered with TfL will receive a three-year time-limited 100 per cent discount (from September 2020 to September 2023). This is referred to as a “sunset period” and means they will not have to pay the ULEZ charge. After September 2023, residents will pay the full charge of £12.50 if they drive a vehicle in the ULEZ that does not meet the relevant ULEZ emissions standards.
To align these schemes, we are proposing that the ES will continue exclusively for residents at the discounted rate (90 per cent) until the expiry of their sunset period for the ULEZ . This is to provide continuation during the threes period where the ES ends and the residents ULEZ sunset period is active.
Paying the ES
The ES will use the same payment and operational systems as the Congestion Charge. We will identify whether a vehicle is subject to the ES and the driver will pay for both the Congestion Charge and ES (if applicable) in the same transaction. This includes drivers registered for Congestion Charge Auto Pay.
Checking your vehicle
Your registration document (also known as the V5C) will show if your vehicle will be subject to the ES. The emission standard can usually be determined by the date it was first registered with the Driver and Vehicle Licensing Agency, which can be found in section B of the document. If you do not have this, you can check the date by visiting https://vehicleenquiry.service.gov.uk/
For newer vehicles, the Euro standard may be listed on the V5C in section D.2. The ES will apply for vehicles that do not meet at least the Euro 4/IV standard (Euro 3 for L-Category vehicles). Pre-Euro 4 vehicles are generally those registered up to and including 2005.
The table below shows the date from which all manufacturers needed to meet the Euro standard
A small number of vehicles registered prior to these dates will also have NOx emissions that meet Euro 4/IV or better. These are referred to as ‘early adopters’ and would not be subject to the ES. Prior to the implementation of the scheme we would offer a means of identifying compliant vehicles on the TfL website.
Impact on Emissions
Our most recent data from indicates that 8,000 vehicles per day entering the Congestion Charging zone during charging hours are likely to be impacted by the ES on average:
We expect the numbers of affected vehicles will have reduced by 2017 as the vehicle fleet evolves.
The £10 charge could encourage some vehicles to stop travelling into the zone. Equally, the charge level is intended to encourage some owners of light vehicles to consider purchasing a newer vehicle i.e. one that is likely to be compliant with the forthcoming ULEZ standards.
We estimate that the charge will result in a 2 per cent reduction in NOx from cars and a 0.5 per cent reduction in total road transport NOx.
Ideas for the future of the ULEZ
ULEZ will require all vehicles driving within the zone to meet particular emissions standards, or pay a daily charge. The current scheme was confirmed by the previous Mayor in 2015. As things stand, the ULEZ will come into force in September 2020 and cover the same area as the Congestion Charging zone
The Mayor considers that far-reaching action is needed to address London’s poor air quality, and while the current ULEZ scheme will make a valuable contribution, he thinks it can be significantly improved.
This consultation puts forward the Mayor’s current thinking on the future of the ULEZ and reflects engagement with Londoners on the topic of air quality since his election.
No formal proposals for the future of the ULEZ are being put forward at this stage. Instead, the Mayor wishes to develop his proposals with the active involvement of Londoners and relevant stakeholders by considering:
- Bringing forward the introduction of the Ultra Low Emission Zone (ULEZ) to 2019 instead of 2020;
- Extending the ULEZ from Central London to Londonwide for heavy vehicles (heavy goods vehicles (HGVs), buses and coaches) as early as 2019, but possibly later; and
- Extending the ULEZ from Central London up to the North and South Circular roads for all vehicles as early as 2019, but possibly later.
Depending on feedback from this consultation, and continuing feasibility work, the Mayor will decide whether these options should be pursued. If so, he will ask us to develop definitive proposals which the public and stakeholders can comment on during consultation 2017. The public and stakeholders will therefore have a further full opportunity to be consulted on a detailed proposal in addition to their feedback to this consultation.
Summary of idea for the future of ULEZ.
Bringing forward the ULEZ in Central London
Currently, the ULEZ will apply in the same area as the Congestion Charging zone and is scheduled to start in September 2020. It is likely we can improve air quality in London sooner by bringing forward this launch date.
It is likely we can improve air quality in London sooner by bringing forward the implementation date for the ULEZ.
An earlier implementation of the ULEZ would mean Londoners see the emissions and health benefits sooner. If the scheme was introduced in 2019, there would be a 25 per cent reduction in NOx in 2018, as people started to comply early in preparation for the launch, then a 40 per cent reduction in 2019 on top of what would already be achieved by ULEZ implementation in 2020.
Expanding ULEZ London wide for heavy vehicles, buses and coaches
We are also considering options for expanding the ULEZ London-wide (to the same boundary as the existing Low Emission Zone) for all heavy vehicles. This is being considered because they are, on average, the most polluting and, unlike in central London, the locations of high pollution in outer London mostly occur along the main roads, where most heavy vehicle kilometres are driven, and where there is a higher proportion of these vehicles.
These vehicles would need to comply with Euro VI standards or pay a daily charge.
Currently, the LEZ sets only PM emissions standards for all commercial vehicles. The table below shows the vehicle classes that are defined as heavy vehicles.
Again, we are seeking your views on when the appropriate implementation date for an extended zone could be.
Subject to the results of this consultation, the possible charge levels and interaction with the existing Low Emission Zone and the ULEZ will be considered as part of the development of detailed policy options over the next year.
We anticipate that, assuming levels of compliance on par with those predicted for the central zone, the Londonwide ULEZ for Heavy vehicles will lead to a 30 per cent reduction in NOx emissions across London. The impacts of the proposal on concentrations and the resulting health impacts will be determined in time for the statutory consultation in 2017.
Expanding the ULEZ up to the North and South Circular roads
The Mayor is considering expanding the ULEZ to inner London for all vehicles. Emissions standards that apply for the central London ULEZ would therefore be extended across a wider area, broadly speaking up to the North and South Circular roads (A205 and A406).
We are seeking your views on when the appropriate implementation date for an extended zone could be.
Early indications are that the inner zone would lead to an estimated 40 per cent reduction in NOx emission from road transport the area boundary by the North and South Circular roads, when combined with the London wide heavy vehicle ULEZ.
Subject to this consultation, the impacts of this on NO2 concentrations and the resulting health impacts will be determined in time for the statutory consultation in 2017.
Direct Vision Standard
The Mayor has now launched TfL’s first Direct Vision Standard along with proposals for how it might be applied including banning the most dangerous ‘off-road’ lorries from the capital’s roads by January 2020. The standard assesses and rates how much an HGV driver can see directly from their cab in relation to other road users. The Standard will categorise HGVs using a five star rating system, ranging from zero stars for vehicles with the lowest direct vision, three stars for good levels of vision, to five stars for the highest levels. The plan is that only HGVs meeting 3 stars as part of the new standard will be allowed on London’s roads by 2024.
There will be a policy consultation on the Direct Vision Standard prior to the start of any statutory consultation. We will continue to work with vehicle manufacturers, regulators, the Department for Transport and freight operators to ensure that the proposed Direct Vision Standard is as far reaching as practicable within current legislation. This standard is the key to getting ever greater numbers of safer lorries operating on the streets of London.
This announcement should be borne in mind when considering the air quality proposals set out in this consultation as it has relevant implications for decisions about vehicle and fleet replacement.