Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) 1

Transcription

1 Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) Sustrans response to Transport for London ULEZ consultation 3b Contents 1. Summary Full Response Survey Response... 4 Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) 1

2 1. Summary Air pollution affects all Londoners and visitors to the capital. It worsens quality of life and shortens life expectancy. Every year approximately 9,500 deaths are brought forward as a result. 1 This impact is unevenly spread across London with the greatest health burden of pollution borne by the most vulnerable in society; both old and young; those with existing respiratory and cardiovascular conditions and those on low-incomes. 2 Furthermore, people from deprived areas are more likely to travel less, live without a car and contribute least to the problem, yet they suffer disproportionately more. 3 The majority of London s illegal nitrogen oxides (NOx) and particulate matter (PM) pollution is generated by motor-traffic, particularly from diesel engines. Up to 80% of nitrogen dioxide (N02) where legal limits are broken is from road traffic. 4 Across London 51% of nitrogen oxides are emitted as a result of road transport, 87% of which are from commercial vehicles that typically run on diesel. 5 Shifting travel to walking and cycling while encouraging a shift toward cleaner modes and vehicles for the remaining essential commercial journeys is vital to reduce pollution at source and help clean London s air. We believe that the proposed Ultra-Low Emission Zone is a key means to do so. The case for mode shift is more robust given that a cleaner, greener vehicle fleet will only deal with part of the problem. A major source of particulate matter - and the smallest and most harmful particulate matter (PM2.5) in particular - arises from the erosion of tyres and brake pads. 6 We therefore need a major shift to walking and cycling alongside fewer, cleaner motor-vehicles in all parts of London. While the Ultra-Low Emission Zone is a critical part of any strategy to achieve this, it must be supported by major investment in alternatives to car use and planning policies that make sustainable and active travel the natural choice. Summary survey response Sustrans supports proposals to set higher emissions standards for heavy vehicles operating within the London-wide Low Emission Zone by 2020 and measures to encourage compliance; Sustrans supports proposals for an expanded Ultra-Low Emission Zone in 2021 for light vehicles up to, but not including, the North and South circulars; However, we urge the Mayor to develop an Ultra-Low Emission Zone proposal that covers as much of Greater London as practicable at a sooner date than proposed. Continued investment that delivers an increase in the proportion of trips made by cycling, walking or public transport is critical to reduce air pollution. Furthermore, the Ultra-Low Emission Zone s expansion should be accompanied by steps toward zero-emission zones by 2025, particularly in central London and other town centers, as part of an effective strategy to achieve a zero emission transport system in London. The long-term damaging impacts of air pollution on Londoners health, particularly the most vulnerable, require measures to change the way we travel and major shift Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) 2

3 away from fossil-fueled motor-vehicles, particularly diesel. Sustrans strongly supports the Ultra-Low Emission Zone as planned and proposals to expand its geographical reach to change travel behavior and incentivise the uptake of cleaner vehicles for essential journeys. 2. Full Response About Sustrans Sustrans is the charity making it easier for people to walk and cycle. We are engineers and educators, experts and advocates. We connect people and places, create liveable neighbourhoods, transform the school run and deliver a happier, healthier commute. Sustrans works in partnership, bringing people together to find the right solutions. We make the case for walking and cycling by using robust evidence and showing what can be done. We are grounded in communities and believe that grassroots support combined with political leadership drives real change fast. The case for action on Air pollution Air pollution from both Nitrogen Oxides (NOx) and Particulate Matter (PM) affects every Londoner at all stages of life, shortening life expectancy and diminishing quality of life. It has been linked to stunted development of children during pregnancy, and contributes to a range of cardiovascular and respiratory diseases as well as some cancers. 7 Through this direct link to health and wellbeing, pollution is estimated to bring forward over 9,500 deaths every year in Greater London. 8 We believe that these deaths with the associated impacts on quality of life and the burden of care are preventable. The case for action on motor-vehicle emissions Road transport accounts for the largest share of air pollutant emissions across London. Approximately half of all NOx emissions and around 60% of PM10 are created by motor-vehicles. 9 Streets and roads also represent the places where Londoners are most exposed to air pollution, with road transport responsible for 80% of the pollution where legal limits are being broken. 10 Diesel vehicles are a major source of pollution and must be phased out. 87% of NOx emissions from road transport are emitted by commercial vehicles, which typically run on diesel. Diesel vehicles emit at least four times as much NOx and 22 times as much particulate matter when compared to an equivalent petrol engine. 11 However, shifting away from dirty to cleaner fuels only represents part of the solution. Particulate matter - and particularly the finest or smallest particulate matter,pm2.5 is acknowledged as having the most detrimental impact on human health. The World Health Organisation (WHO) state that there is no safe level for the Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) 3

4 smallest particulate matter pollution (PM2.5) and all Londoners are exposed to concentrations higher than existing WHO air quality guidelines. 12 PM2.5 in London is associated with around 4,000 deaths brought forward 13 and a major source of this pollution, over half, is not from the combustion of fuel in engines, but the erosion of tyres and brake pads and re-suspension caused by traffic movements. 14 Even zero-emission motor vehicles, therefore, contribute to particulate matter pollution. In conclusion, Sustrans strongly supports the development of charging schemes in polluted areas to deter driving and encourage the uptake of cleaner vehicles, including the current Ultra Low Emission Zone proposals and London-wide Low Emission Zone proposal (this consultation). In addition, this must be supported by significant investment to enable travel by other modes, and walking and cycling in particular Survey Response Part 1: Proposals for a stronger Low Emission Zone (LEZ) 1. Do you support tougher vehicle emissions standards in the London-wide Low Emission Zone so that heavy vehicles must meet the Euro VI emissions standards London-wide? Strongly support 2. Do you support the proposed implementation date of 26 October 2020 for the introduction of tougher Euro VI standards for heavy vehicles driving in the London-wide Low Emission Zone? Strongly support 3. Do you support the proposed daily charges to be paid by owners of heavy vehicles that do not meet the required emissions standards at: 300 for those that do not meet Euro IV PM standards and; 100 for those that do not meet Euro VI NOx and PM standards? Part 2: Proposals for an expanded Ultra Low Emission Zone (ULEZ) 4. Do you support the principle of expanding the area where ULEZ emissions standards apply to light vehicles beyond central London? Strongly support 5. We are proposing that the ULEZ emissions standards would apply to the inner London area, roughly up to but not including the North and South Circulars roads. Do you support this proposed boundary? Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) 4

5 an expansion but the area should be larger 6. Do you support the proposed implementation date of 25 October 2021 for the expansion of ULEZ to include light vehicles in inner London? Oppose (should be sooner) 7. Do you support the proposed ULEZ daily charge to be paid by non-compliant owners of light vehicles of 12.50? Part 3: Proposals for residents 8. Do you support bringing forward the end of the sunset period for residents in the Central London Congestion Charging zone from 7 April 2022 to 24 October 2021 so that all residents of inner London, including the Congestion Charging zone, pay the daily charge for non-compliant vehicles from 25 October 2021? Part 4: Proposals for penalty charges 9. Do you support increasing the penalty charge (PCN) level for non-payment of the ULEZ daily charge by owners of non-compliant light vehicles from 130 to 160? Part 5: Other comments 10. If you have any further comments about the proposals, please write these in the box below. Sustrans strongly supports proposals for the geographical expansion of the ULEZ and higher standards for the existing London-wide LEZ. This should be supported by major investment in sustainable travel alternatives; mode shift is the most effective tool for reducing emissions at source and, importantly, the most harmful PM2.5 emissions from tyre and brake wear and re-suspension due to road traffic. The Ultra-Low Emission Zone s expansion should be accompanied by a number of zero-emission zones, particularly in central London and other major town centres, as part of an effective strategy to achieve a zero emission transport system in London. The Mayor should set out next steps toward delivering zero emission zones as soon as possible in the boroughs that wish to develop them, supported by overall traffic reduction strategies. We are seriously concerned that the Euro Standards are not sufficiently robust to deliver the expected benefits. A report by Which? found that of the diesel cars we ve tested, nearly a quarter would exceed Euro 3 limits (passed in 2001) when Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) 5

6 faced with our more realistic tests. This means these cars don t pass the earliest emission regulations from this century. 15 Given the widely accepted discrepancies between vehicle emissions performance in lab situations and in real-world conditions, the Mayor must lobby UK Government and the European Commission for a more robust, real-world emissions standards regime. We believe the Ultra-Low Emission Zone should cover as much of London as practicable to benefit all Londoners. There are a number of major road corridors and town centres in outer London that suffer excessive pollution. In addition the North and South Circular is a major source of pollution itself. The Mayor should develop a longer-term road pricing strategy sensitive to emissions and other factors across all of London. We are concerned that the planned implementation dates raise political risk and uncertainty given that both proposals (London-wide LEZ and inner London ULEZ) in late 2020 and late 2021, respectively, would take place after the next Mayoral election. The Mayor should provide greater certainty by delivering the scheme before the election in We support the proposed charge levels and penalty charge levels on the premise that these have been determined as a deterrent rather than to cover the costs of the scheme. CONTACT Nicholas Sanderson, Senior Policy Officer: Nicholas.Sanderson@sustrans.org.uk Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) 6

7 Sustrans is the charity making it easier for people to w alk and cycle. We connect people and places, create liveable neighbourhoods, transform the school run and deliver a happier, healthier commute. Join us on our journey. w w w.sustrans.org.uk Sustrans February 2018 Registered Charity No (England and Wales) SC (Scotland) VAT Registration No King s College London (2015) Understanding the Health Impacts of Air Pollution in London 2 Royal College of Physicians (2016) Every breath we take: the lifelong impact of air pollution. Report of a working party. London: RCP 3 Sustainable Development Commission (2011) Fairness in a car dependent society 4 Department for Environment, Food and Rural Affairs (2015) Improving air quality in the UK: tackling nitrogen dioxide in our towns and cities, UK Overview Document, December N0x 2013 GLA (LAEI2013 Update) as shown on: 6 Greater London Authority / Transport for London (2017) PM2.5 concentrations and exposure in London 7 Royal College of Physicians (2016) Every breath we take: the lifelong impact of air pollution. Report of a working party. London: RCP 8 King s College London (2015) Understanding the Health Impacts of Air Pollution in London 9 Transport for London (2013) Roads Task Force Technical Note Department for Environment, Food and Rural Affairs (2015) Improving air quality in the UK: tackling nitrogen dioxide in our towns and cities, UK Overview Document, December Transport for London (2013) Roads Task Force Technical Note Greater London Authority / Transport for London (2017) PM2.5 concentrations and exposure in London 13 Transport for London (2014) Improving the health of Londoners: transport action plan 14 Greater London Authority / Transport for London (2017) PM2.5 concentrations and exposure in London Changes to the Ultra-Low Emission Zone (ULEZ) and Low Emission Zone (LEZ) 7