Publication from Caroline Russell: Mayor’s air pollution plans – consultation response

Sadiq Khan
Mayor of London
City Hall
London SE1 2AA

Dear Sadiq

Mayor’s air pollution plans – consultation response

Thank you for giving me the opportunity to comment on your proposals for a wider Ultra Low Emission and range of other measures to tackle London’s air pollution. I have set out my views under each of the questions in your consultation and also included additional points not covered in the questionnaire.

Compliance
The Mayor’s plans should show how the whole of London will achieve full compliance with air pollution limits as soon as possible and by 2020 at the latest. The Mayor and TfL must ensure that the ULEZ makes the necessary contribution to this goal.

Traffic reduction
Traffic reduction should be a priority intervention with measures for modal shifts to buses, trains, walking and cycling to complement it. With the right interventions, further traffic reductions could be achieved. For example car journeys declined substantially, whilst London’s population rose by 20 per cent between 1991 and 2011. Furthermore, travel measures implemented during the 2012 London Olympics resulted in less traffic with freight operators re-timing deliveries and reducing their transport activities; and nearly two third of Londoners altering their usual travel behaviours or switching to cycling and walking.

Private Hire Vehicles (PHVs) and Taxis
I would support scrapping the exemption from the congestion charge for all PHVs in 2017 since they do not guarantee accessibility as taxis do. I would also support requiring all PHVs to match or exceed the emission standards for licensed taxis i.e. Zero Emission Capable in 2018 and 2020. Around 14,000 Private Hire Vehicles are registered each year in London.

Implementation of the ULEZ with a road pricing scheme
I am surprised that there is no element of road pricing in the ULEZ implementation plan. Road pricing is a tool to reduce traffic. Charges can vary by time of day, distance travelled and the level of emissions from the vehicle being driven. This allows fairness issues to be addressed with exceptions for essential workers eg midwives and care workers who carry heavy equipment. I would hope that the mayor will consider a London-wide road pricing scheme.

Delivery of the ULEZ
The wider ULEZ must be implemented in this mayoral term.

Other sources of pollution
There are places in London suffering persistent air pollution from commercial river vessels. Whilst the GLA Act does not give the Mayor powers to include commercial vessels as part of the ULEZ, the Mayor should lobby the Government in any reviews of the Clean Air Act and similar legislation.

Projects creating major new sources of air pollution, such as the Viridor Energy from Waste incinerator in Sutton, with a 300,000 tonnes per annum capacity, should be mothballed.

A new Clean Air Act
To ensure that all the current standards and responsibilities on air pollution are clearly embodied in UK law, and potentially improved on in some respects, the Mayor should be involved in promoting a new Clean Air Act and in its development.

Caroline Russell’s answers to Mayor’s ULEZ Consultation questions

Q1. Thinking about air quality, how much of a problem, if at all, do you think the cleanliness of the air is in each of the following locations?

The cleanliness of the air and the health impact of pollution affects all Londoners not just those in central London. It is unfair that older people feel chesty walking to the shops along main roads, that children are growing up with reduced lung function and that adult onset asthma is increasingly common.

If the ULEZ is limited to the North and South Circular then the area around Heathrow airport, hotspots in east London and major arterial routes must be included.

Q2. To what extent do you think each of following is responsible for air pollution in London?

All diesel vehicles make a contribution to London’s polluted air including Euro 6 standard diesel. 63 per cent of NOx emissions in Greater London are from transport sources. The main priority should be on reducing the use of diesel vehicles of all types (including Euro 6). Other sources of pollution which the Mayor and Transport for London have direct control or influence over should also be addressed.

Q3. To what extent do you agree or disagree that the 2020 ULEZ implementation date should be brought forward to September 2019?

The health impact on Londoners is an emergency and should be treated as such. The introduction of an expanded ULEZ at least across the whole of inner London (bounded by the north and south circular roads) should be brought forward to 2018, and by 2019 at the latest. The health case for action should outweigh the impact on vehicle owners. Tough action is required along with measures to help people choose public transport and walking and cycling rather than car use for their everyday transport needs.

Q4. Which of the following areas do you think should be covered by the ULEZ for light vehicles (e.g. cars, motorbikes and vans)?

All Londoners should be protected from the health impact of traffic pollution. The ULEZ for light vehicles (cars, motorbikes and vans) should extend London wide rather than being limited to the North and South Circulars.

Q5. Which of the following areas do you think should be covered by the ULEZ for heavy vehicles (e.g. lorries, buses and coaches)?

The ULEZ for heavy vehicles should cover the existing LEZ area – the whole of London.

Q6. To what extent do you agree or disagree that the government should fund a scrappage scheme to help people scrap their car or van and replace it for a cleaner equivalent?

The Government needs to urgently fund a diesel scrappage scheme to accelerate the removal of all diesel vehicles and in particular the dirtiest pre Euro 6 diesel vehicles. However, in order to avoid diesel car owners from simply upgrading to newer diesel models strict criteria need to be in place, limiting the scheme to zero emission vehicles or other measures to encourage people to go car-free such as car share schemes, free public transport passes, cycle hire voucher schemes, bike hangar funding for their street etc.

Q7. To what extent do you agree or disagree that London should be given greater control over Vehicle Excise Duty?

The revenue generated from Vehicle Excise Duty needs to be devolved to London to ensure it is reinvested in the capital’s road system and measures to tackle air pollution. Priority should be given to schemes that provide direct protected cycle routes, decent pedestrian crossings and a reduction in rat-running in residential neighbourhoods.

The Vehicle Excise Duty tends to favour diesel purchase and has been one of the key incentives for the large numbers of pre-Euro 6 diesel cars on the roads that have contributed to London’s stubbornly high NO2 levels. This needs to be reformed to reflect emissions of local pollutants such as particulates and Nitrogen Dioxide, as well as CO2.

Q8. Pedestrianisation involves closing streets to motorised through traffic including cars, buses and taxis. Traffic is rerouted either permanently or at certain times of the day or week.

I fully support the pedestrianisation of Oxford St and think that car-free days make a brilliant contribution to city life especially when combined with area-wide cultural events.

I fully support play streets and temporary car free days in central London and all boroughs.

Q9. High Pollution Alerts. Would you like to receive information when air pollution is high, in order to take action that would protect your health?

In the run up to and during pollution episodes, alerts should be communicated through all options open to the Mayor, including electronic road signs and social media. These should come into operation when air pollution is expected to be ‘moderate’ for two or more consecutive days or ‘high’ or ‘very high’ for one or more days, and supplemented with messages actively discouraging car use.

Q10. Domestic Boilers. To what extent do you agree or disagree that the Mayor should fund a boiler scrappage scheme?

The Mayor should continue to support the new boiler scrappage scheme from the GLA, which will help reduce air pollution and fuel poverty.

Q11. Emissions Surcharge. To what extent do you agree or disagree that a new Emissions Surcharge should be introduced to discourage the use of older, more polluting vehicles in central London?

I strongly agree that emissions charges should be added to the congestion charge in the Central zone as soon as possible.

The T-charge proposal to apply a £10 surcharge on all vehicles with pre-Euro 4 emission standards does not go far enough. It should be applied to all diesel including Euro 6 vehicles. Ideally diesel vehicles would be banned from central London.

Q12. Do you agree or disagree that the Emissions Surcharge should operate between 0700 – 1800, Monday to Friday?

The emissions surcharge should apply 24 hours a day and seven days a week

Q13. Do you agree that vehicles that do not meet at least the Euro 4/IV emissions standard should be required to pay the Emissions Surcharge?

I agree but think that all diesel vehicles should pay an emissions surcharge.

Q14. Do you agree that the daily charge should be set at £10 to reduce the number of polluting vehicles travelling in central London?

A £10 charge is not sufficiently punitive to deter diesel use and encourage a swift transfer to other modes.

Q15. Do you think that residents should receive a 90% discount from the Emissions Surcharge?

Residents should pay the full charge as their use of diesel will impact on their own health and the health of others. Exemptions should be made in hardship cases for example vehicles owned by people registered disabled or key workers who carry heavy equipment eg midwives.

Q16. Do you agree or disagree that vehicles with nine or more seats such as buses and coaches should also pay the Emissions Surcharge? Yes.

Yours Sincerely

Caroline Russell AM

London Assembly Member - Green Party Group