The Controversy Surrounding the ULEZ Expansion

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Few mayoral policies have courted as much controversy as Sadiq Khan’s plan to expand the Ultra-Low Emission Zone (ULEZ). Currently, the ULEZ Zone comprises Central London and other parts of the capital which fall within the North and South Circular Roads. Within the zone, a £12.50 daily charge is applied to cars which fail to comply with certain emissions standards. By adopting a ‘polluter pays’ principle, the scheme seeks to incentivise drivers to purchase more environmentally friendly cars and, in the process, reduce emissions. It is estimated that over four fifths of cars are already ULEZ compliant. The mayor now intends to further expand the ambit of the scheme by extending it to all 32 London Boroughs on 29th August 2023. The plans, which have proved to be extremely divisive, will affect approximately 1.3 million vehicles. 

The mayor is a major advocate of the ULEZ expansion and suggests that it will ameliorate air quality in Outer London. He contends that the existing scheme has had a “transformational” effect on Inner London air quality. Supporters frequently point to a report which was peer reviewed by Imperial College London’s Dr Gary Fuller; it found that nitrogen oxide emissions are 23% lower across London than they purportedly would be if the scheme had not been introduced. In Fuller’s view, the scheme has “brought about measurable and sustained improvements to air quality from traffic”. Advocates argue that reduced pollution levels could facilitate better health and with it, fewer premature deaths. Professor James Kelly contends that London fails to adhere to WHO air quality guidelines and that “absolutely expanding ULEZ will benefit health because ULEZ will lead to an improvement in air quality and traffic emissions”. Khan himself notes that this is a key motivation underpinning the proposed expansion. 

However, the scheme has generated a number of well-founded concerns; it has been the subject of considerable unpopularity in Outer London, where 70% of residents are reportedly opposed to it (according to the findings of a public consultation). Primarily, there are doubts that the ULEZ expansion will have a tangible impact upon Outer London air quality. Jacobs was tasked with reviewing the scheme and developing an official independent assessment report; it found that the proposed expansion could have a limited effect. Indeed, the “proposed scheme is modelled to result in a minor reduction (-1.3%) in the average exposure of the population of Greater London to No2 and a negligible reduction (-0.1%) in average exposure to PM2.5”. This undermines the suggestion that the expansion will orchestrate a substantial improvement in air quality. The Mayor’s chief justification for extending the scheme can therefore be met with significant challenge. 

Moreover, the scheme may further exacerbate the already challenging cost of living crisis. In Outer London, a number of households own vehicles (the figure stands at 76% in the London Borough of Richmond for instance), with many relying on cars to travel to work. In view of the testing economic circumstances, many households may be unable to replace non-compliant vehicles. They would subsequently be subjected to a daily charge of £12.50 if they continue to use their existing vehicles. This may well prove necessary for a number of these households, particularly considering the limited public transport connections which characterise certain parts of Outer London. In turn, households costs would increase, potentially placing an unwelcome and unsavoury burden on already pressured household incomes. These concerns are echoed by the leader of Hillingdon Council (Councillor Ian Edwards) who argues that “the predominant effect of ULEZ will be to financially cripple already struggling households, further isolate the elderly and harm our local economy with negligible or no improvement to air quality”. The leader of Bromley Council (Councillor Colin Smith) depicts it as a “socially regressive tax” which will create a “completely avoidable spike in the cost of living locally, at a time when some households are already struggling to make ends meet”. The Unite Union has further fuelled this criticism, noting that the expansion is “profoundly anti-worker”. Advocates argue that the £110 million scrappage scheme will support eligible households to scrap or retrofit non compliant vehicles, enabling them to circumvent the charge. Under the car and motorcycle scrappage scheme, Transport for London will provide up to £2,000 for eligible vehicle owners to scrap non adherent cars. Alternatively, individuals could receive a payment of £1,600 as well as an annual adult rate bus or tram pass. Crucially, these individuals should be claiming certain forms of benefits in order to qualify. Hence, the scheme is likely to exclude other individuals who could encounter substantial financial difficulties in replacing vehicles. The implications that it may have for the cost of living are therefore stark, notwithstanding the Mayor’s utterances. 

The scheme has been strongly opposed by many in Outer London. Five local authorities – Harrow, Hillingdon, Bromley, Bexley, and Surrey County Council – are seeking to challenge the proposed expansion through judicial review. Legal avenues are being pursued here. In the meantime, the Mayor plans to press ahead with what is undoubtedly a highly divisive and fiercely contested proposal to extend the charge to Outer London.


by Dara Foody

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