A message from Friends of the Earth
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Friends of the Earth’s views on the Mayor’s autumn 2016 air
pollution consultation
November 2016
The London Mayor is consulting on “New
proposals to improve Air Quality - Have your say on the introduction of a new
Emissions Surcharge and ideas for improving Ultra Low Emission Zone” which
closes on 18th December 2016
Context and timeframe
The government’s recent defeat in the High Court (http://www.clientearth.org/major-victory-health-uk-high-court-government-inaction-air-pollution/
) found that the government’s plans for Nitrogen Dioxide air pollution did not
include the measures necessary to bring air pollution within EU legal limits
“as soon as possible” as is required. So now stronger measures will be needed
to clean up our air quicker, and the government will also have to re-model air
pollution on more realistic and less optimistic assumptions.
Along with the rest of the UK, there will need to be
measures adopted so that London will meet EU legal limits sooner than the
government had originally planned – which for London was previously 2025 (when
these limits should have been met by 2010 or 2015 at the very latest).
In other UK cities Clean Air Zones will need to be in place
to ensure legal limits are met as soon as possible, and rather than 2020 as
previously planned, this must be earlier now - we understand that 2 cities have
said Clean Air Zones can be in place 2018.
And to avoid Londoners having to be exposed to illegal
levels of air pollution longer than other parts of the UK, London must evaluate
what measures, including having a strengthened and widened ULEZ in place, would
be needed for to it to comply by 2018 too.
The Mayor must look at what possible measures could be
introduced by which earliest possible dates – the law requires that this must
be irrespective of cost or any political difficulty. Critical judgements must
be made on how best to protect the health of Londoners and avoid as many as
possible of the nearly 10,000 premature deaths a year air pollution is responsible
for in the capital.
Emissions Surcharge
(ES) or T-Charge
The Mayor proposes this additional charge for the dirtiest
vehicles using the Central London Congestion Charge Zone as an interim measure
before the Ultra-Low Emission Zone comes in.
We support this charge as it is important to take immediate
steps to improve air pollution, but think that this should also include the
newest diesels, at least for cars. We also think that private hire vehicles
should not be exempt.
Ideas for the future of
the Ultra-Low Emission Zone/ULEZ
The Mayor must
strengthen the ULEZ so that it is London-wide for all vehicles including cars –
not just as is currently proposed to stop at the North and South Circular roads,
and with ULEZ standards only applying London-wide for heavy vehicles. The ULEZ
should effectively replace and strengthen the existing London-wide Low-Emission
Zone. With a London-wide scheme in place for all vehicle types all the necessary
levers would be in place and the scheme could be progressively adjusted as
needed.
Bringing forward the ULEZ in Central London
Plans to bring forward the ULEZ from 2020 to
2019 are welcome but even earlier introduction must be evaluated, including for
it to be in place by 2018 – including as strengthened and widened as per the
below.
Expanding ULEZ London wide for heavy
vehicles, buses and coaches
This is welcome, but the Mayor must set up
the ULEZ to be London-wide for all vehicle types including Light Goods Vehicles
(LGVs) and cars, so that all the levers are in place and adjustments can be
made as necessary.
Expanding the ULEZ up to the North and South
Circular roads
This is welcome, but the Mayor must expand
the ULEZ out to be London-wide, where the current Low-Emission Zone / LEZ
boundary already is, so that all the levers are in place and adjustments can be
made as necessary.
Complementary measures needed
Action is needed in London to ensure vehicles
are cleaner, but also that there are fewer of them – all vehicles produce air
pollution from tyre and brake wear, and cause congestion which is bad for
business.
This will require a mix of measures including
planning our communities so that people don’t need to travel unnecessarily to
reach key amenities and work opportunities, making cycling safer and public
transport more affordable, consolidating the myriad freight movements in our
city, and not adding to the air pollution problem such as with new
road-building.
The Mayor has reviewed plans for Thames river
crossings in East London which included 3 road crossings, and while
improvements have been made, he is still currently pursuing at least a new 4-lane
Silvertown road tunnel. This would mean worse pollution for some places which
would not be acceptable – instead a comprehensive package of non-road crossings
and complementary measures must be considered.
The government also
needs to do more to enable London to do more, both directly such as restricting
the sale of dirty vehicles, changes to road-tax to discourage diesels, a
scrappage scheme for the dirtiest vehicles, and also to enable more powers for
the London Mayor and for Local Authorities.
Contact: Jenny Bates, Friends of the Earth
Air Pollution Campaigner: jenny.bates@foe.co.uk
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