ULEZ Expansion Consultation: GLA Conservatives Response

Shaun Bailey AM: “We want to make it clear, improving air quality is vital, but expanding the ULEZ is the wrong way to go about it. My child suffers with asthma, I understand how important cleaning up London’s air is, but this is not the way.

It should not fall on the poorest in our communities to bear the biggest burden, many low-income Londoners are reliant on their cars in order to get to work and live their lives. We worry that this Mayor will cost people their jobs.

The London-wide expansion is an expensive endeavour with low environmental benefits. £200m is a lot to spend on a camera network and could be put to better use elsewhere, by expanding the zero emission bus fleet or even by putting a significant amount into scrappage schemes.

We are only just seeing the initial data from his most recent ULEZ expansion in October 2021, the conclusions are limited and it makes any money spent on similar schemes difficult to qualify. The accelerated timeline of a further expansion, does not give Londoners - recovering from the economic costs of Covid - enough time to prepare for change.

We don’t believe going ahead with further expansion, at any speed, is a prudent or reasonable course of action. It only makes sense if the Mayor’s priority is to squeeze money out of Londoners, when his priority should be improving London’s air quality, and there are far better ways.”

Having studied the proposal in detail and considered alternative options to improve London’s air quality, the GLA Conservatives are firmly opposed to any expansion of the Ultra-Low Emission Zone (ULEZ).

Improving London’s air quality is of the utmost importance, and it is entirely reasonable that there is a role for the Mayor in seeking to improve it. The Mayor should make it a priority to clean up London’s air, but the cost of doing that should not fall on the backs of the many Londoners who cannot afford to replace their vehicles or pay an additional £12.50 per day to drive in London. If this proposal goes ahead it is clear that it is those Londoners who would be disproportionately impacted.

The Mayor should also recognise that inner and outer London are very different to each other and that there are many policies that might be reasonable and effective in the former and unsuitable for the latter. Trying to impose a uniform solution and to pretend that one size fits all shows a Mayor out of touch with many of the people he presumes to represent and suggests an unwillingness to consider how individual Londoners actually live their lives.

The GLA Conservatives supported the previous Mayor’s plans for a central London ULEZ for four main reasons. First, it effectively targeted central London, which was and is the area in London where the problem of poor air quality is at its worst. Secondly, central London, the area the ULEZ was targeting had excellent public transport so there were viable alternatives to driving for the vast majority of people. Thirdly, Londoners were given a reasonable amount of time to adapt and plan. The central London ULEZ was confirmed on 26th March 2015 and the plan was for it to be introduced on 7th September 2020. This meant residents, Londoners, small businesses and manufacturers knew they had 5.5 years to adapt. Fourthly, given the central London ULEZ had exactly the same boundaries as the Congestion Charge, introducing it was inexpensive and straightforward.

There are two further issues worth noting. The first is that giving Londoners a reasonable lead time to make significant changes to their lives is not a cop out or a weak option. The evidence shows that the very act of confirming a change in the future leads to improvements almost immediately as people act to ready themselves for that change. That is not to suggest that ULEZ expansion would have been acceptable, if only it had been further in the future – there are many other problems with it – but rushing it through exacerbated many of its inherent problems. The second issue is that, shortly after he became Mayor, Sadiq Khan brought the date for the introduction of the central London ULEZ forward by 17 months to April 2019. This was to little real benefit, but did make life harder for people who had planned their change of vehicle to fit with the original timetable.

When the Mayor also chose to expand the ULEZ to the North and South Circulars in October 2021 the GLA Conservatives strongly opposed that decision. This was a blunt instrument that has caused real hardship to Londoners who struggled to afford to upgrade their vehicle but who have little choice but to drive in London. In so doing, Sadiq Khan’s decision did not meet any of the four reasons why the original ULEZ made sense. First it was poorly targeted, covering some areas with poor air quality but many others with relatively good air quality. Secondly, although some parts of the expanded ULEZ have very good public transport, there are other parts which do not. Thirdly, Londoners were given far less time to adapt. Fourthly, the expansion necessitated the introduction of a significant amount of new infrastructure at a not inconsiderable cost.

Having pushed through such a contentious and unjust decision in the middle of a pandemic which had severely damaged many Londoner’s finances, the very least the Mayor could have done was to ensure that he did nothing further to worsen the cost of living for those Londoners. However, on 4th March 2022, he announced his intention to consult on expanding the ULEZ to make the scheme London-wide.[1] He did this less than six months after the previous expansion – refusing to learn lessons from its many shortcomings. Not long afterwards he stated that his current plan is to expand the ULEZ in August 2023.

Moreover, by rushing ahead with this consultation, the Mayor has chosen to launch it without a proper data pack from October’s expansion. This means there is a lack of evidence to support the proposal. Even beyond this there is no final figure on what further expansion would cost and the Mayor is proceeding without telling Londoners what would be the size of any scrappage scheme. The absence of such detail fundamentally undermines the entire consultation.

It is no exaggeration to say that all of the problems with the expansion to the North and South Circulars would be worsened by expansion to cover almost all of Greater London. A London-wide ULEZ would cover many more areas with good air quality and poor public transport. It would include many more outer London residents for whom owning a car is a necessity. Meanwhile, given the greatly increased area, the cost of expansion would be higher whilst the potential environmental benefits would be lower.

This was despite the GLA Environment team estimating that only a total of between 20,000 and 40,000 polluting vehicles will be taken off the roads because of further expansion of the ULEZ. Expanding the ULEZ to make it London-wide would result in just a 10% reduction in NOx emissions[2]. Given this, it would not be unreasonable to conclude that making the ULEZ London-wide is more of a money-making scheme than an environmental one – having a disproportionate impact on London’s least well off. Contrary to the Mayor’s frequent assertions, many low-income Londoners are reliant on their cars in order to get to work and live their everyday lives. We worry that this Mayor will cost people their jobs.

Furthermore, expansion has already been incredibly damaging to many small businesses and charities. For many, the ULEZ expansion to the North and South Circulars undermined their ability to serve their customers and carry out their duties. Further expansion would threaten their very existence. ULEZ Expansion would be particularly difficult for disabled Londoners, with the Mayor being clear that he has no intention of granting exemptions to blue badge holders, and for those elderly Londoners who are less mobile. Given that these are some of the most vulnerable Londoners, it is clear the Mayor should reconsider.

This proposal would also have a considerable impact on those who live outside London, but who regularly travel in to work, visit family or use shops, restaurants or leisure facilities in London. Such artificial dividing lines always have unintended consequences, and we hope that the Mayor is not deliberately seeking to push through a decision that would have such a negative impact on those Londoners who are these people’s friends, family, colleagues or whose businesses rely on their custom. Is the Mayor really content to make it harder for nurses, fire fighters and police officers who live outside but work within London to get to work? He should certainly tell us.

The decision on whether or not to expand the ULEZ should not simply be – as the Mayor appears to view it – determined by whether or not it would reduce emissions. Instead, the Mayor should be seeking to improve air quality in a way that produces the maximum benefit as efficiently as possible and with the minimum impact on Londoners’ cost of living. There are

many better ways to cut emissions and improve London’s air quality. The Mayor has set aside around £200 million to spend on expanding the ULEZ. That money should instead be spent on funding better, fairer, more imaginative alternatives. Whilst this is not the place to go into excessive detail on those alternatives, here are just three examples that would improve London’s air quality without penalising those Londoners who can least afford it:

• A scrappage scheme, funded by Transport for London. The Mayor has called for "the biggest car scrappage scheme feasible”. However this pledge is extremely weak, as he has also suggested that the size of the scrappage scheme is heavily dependent on what the Government will contribute and has published a begging letter, asking the Government for £180 million.[3] Instead of spending hundreds of millions of pounds on the cameras and infrastructure needed to expand the ULEZ, the Mayor could spend that money on a scrappage scheme to help Londoners replace their vehicles.

• The Mayor’s predecessor introduced a boiler scrappage scheme that provided £400 cashback to households that replaced the oldest, most polluting boilers with the newest and cleanest models. Funding of £2.6 million was allocated to the scheme, which provided for 6,500 owner occupiers. Sadiq Khan swiftly scrapped this scheme once he became Mayor. Bringing it back and spending a fraction of the money set aside to fund the ULEZ expansion would lead to both cleaner and cheaper heating systems for many more Londoners.

• The Mayor could also invest money saved by cancelling the ULEZ expansion into speeding up efforts to make London’s bus fleet zero emission and bringing forward the Mayor’s current target of 2034.

For all of these reasons, we believe the Mayor should scrap his plans to expand the Ultra-Low Emission Zone.

[1] https://www.london.gov.uk/press-releases/mayoral/mayor-sets-out-london-wide-ulez-plans [2] Ibid [3] https://twitter.com/mayoroflondon/status/1499849555076075537?lang=en