Request ID: FOI-1354-2122 Date published: 01 November 2021
You asked
Follow-up to 1036-2122:
Response is very generic with no factual evidence and real statistics over the years, therefore it is misleading.
On what basis admissions to hospitals in Greater London over the next 30 years are calculated?
Please list the most deprived areas of London and how they are related to ULEZ?
How this is calculated when small businesses,sole traders are forced not to go to London and/or to accept ULEZ by stealth and struggle to break even?
What are the legal limits for the air pollution?
Where is the evidence Londoners have responded positively?
Please provide the list of those roads and why they are exceeding legal limits?
Please provide the evidence air pollution is linked to COVID 19?
How did you prove and to whom did you prove that emission charging works?
What are 8% of London roads that do not comply with legal limits for NO2 and why these roads do not comply with legal limits?
What are the tools and statistics used to predict the above numbers?
There is a difference between willing and mandatory (forced).Please clarify?
Does it mean cars are to be changed every 5 years if they are to fall within ULEZ levels?
How and why do you corelate households with cars with ULEZ?
As you used in your response the term “own a car” explain legal difference between registered keeper and the owner of the car?
What does it mean in legal terms? Extract from SI you referred to further below in your response
(2) For the purposes of these Regulations the registered keeper shall be presumed to be the owner of a vehicle registered under the Vehicle Excise and Registration Act 1994(3).
Why the registered keeper shall be presumed to be the owner of a vehicle?
Please provide the figures (amounts) for the cost benefit analyses and who carried them?
Where the surplus will be invested?
Please provide evidence in surplus from previous years is invested in London’s air quality?
If it is not about making money why charging is introduced and forced on the drivers who live and come to London?
Do all TfL buses and trains comply with ULEZ and if not who is financing the change?What are the sources of finance?
Statutory Instruments are Orders in Council,never debated by Parliament,passed by Privy Council,which has more then 700 members,all unelected individuals like Justine Trudeau,George Osborne,Tony Blair,Camila Parker Bowles….
These instruments are perceived to be the law Transport for London and Mayor's office use to “legally”enforce the fines,when Parliament (MP’s elected by the people for the people) is the law maker.This is unconstitutional,unjust and unlawful.
We answered
TfL Ref: EIR-1354-2122
Thank you for your further request received by Transport for London (TfL) on 22 September 2021 asking for information about the Ultra Low Emission Zone.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations and our information access policy.
I can confirm that we hold the information you require. Your requests for specific, recorded information are addressed in turn below:
Question 1: On what basis admissions to hospitals in Greater London over the next 30 years are calculated?
Please see the document ‘Modelling the long-term health impacts of changing exposure to NO2 and PM2.5 inLondon’ that is published here:
As you can see, this study estimates the long-term health impacts of exposure to air pollution in London from 2016 to 2050. The study finds that by 2050 policies in the London Environment Strategy (including the central London Ultra Low Emission Zone and its expansion to the North and South circular roads), will result in:
almost 300,000 Londoners avoiding new diseases attributable to air pollution, such as coronary heart disease, lung cancer and dementia. This is a reduction of around one in every four air pollution related diseases
a cost saving to London’s NHS and social care system of £5 billion
one million fewer air pollution related hospital admissions in London
Question 2: Please list the most deprived areas of London and how they are related to ULEZ?
Analysis carried out on behalf of the GLA and published in 2016 shows the health effects of air pollution are seen disproportionately in the most vulnerable and deprived communities. Among the top 10 per cent of London’s most deprived areas, half have NO2 levels exceeding legal limits. For the 10 per cent of least deprived areas, only one per cent experience illegal NO2 concentrations. Please see the document published here for the source of this analysis, and which lists the deprived areas referred to: https://www.london.gov.uk/sites/default/files/analysing_air_pollution_exposure_in_london_-_technical_report_-_2013.pdf
This report was updated in 2019 to identify the impact the Mayor’s air quality policies, as set out in his London Environment Strategy, will have on social inequalities in London. You can read the Air Pollution Exposure in London report here:https://www.london.gov.uk/what-we-do/environment/environment-publications/air-pollution-london-impact-environment-strategy Question 3: We wrote in our previous response: “Research from the Confederation of British Industry (CBI) has shown that cleaner air could boost the UK economy by £1.6 billion per year. Improving air quality in London would provide an economic benefit of almost £500 million per year to the local economy.” You asked: How this is calculated when small businesses, sole traders are forced not to go to London and/or to accept ULEZ by stealth and struggle to break even? The CBI research to which we referred can be found here: https://www.cbi.org.uk/articles/what-is-the-economic-potential-released-by-achieving-clean-air-in-the-uk-1/ Question 4 What are the legal limits for the air pollution? Legal limits for air pollutants are decided at the national level and can be found on the Department for Environment, Food and Rural Affairs website here: https://uk-air.defra.gov.uk/air-pollution/uk-eu-limits Question 5: Where is the evidence Londoners have responded positively? Londoners have responded positively to the central London ULEZ by upgrading their vehicles. As of July 2021, 87 per cent of vehicles driving in the central zone met the ULEZ standards. Many Londoners have also taken action to prepare for the recently expanded zone and now 80 per cent of vehicles seen in the expanded zone on an average day are compliant, up from 39 per cent in 2017 when the plans for the larger area were first announced. Question 6: We wrote in our previous response: “However, 24 per centof roads in inner London still exceed legal limits for NO2 and 99 per cent of London still exceeds the WHO recommended limits for PM2.5, which is thought to be the air pollutant which has the greatest impact on human health. There is also emerging evidence linking air pollution with an increased vulnerability to the most severe impacts of COVID-19.” You asked: Please provide the list of those roads and why they are exceeding legal limits? Please see table 1 in the “Air Quality in London 2016-2020 report” published here: https://www.london.gov.uk/sites/default/files/air_quality_in_london_2016-2020_october2020final.pdf The GLA and Transport for London (TfL) work in partnership to produce a comprehensive set of air quality datasets. The London Atmospheric Emissions Inventory (LAEI) is the key tool for air quality analysis and policy development in London. It is a regularly updated database of pollutant emissions and sources including geographically referenced data and maps. The LAEI 2016 is the latest version of the London Atmospheric Emissions Inventory and replaces previous versions of the inventory. Emissions estimates of key pollutants (NOx, PM10, PM2.5 and CO2) by source type are included for the base year 2016. This includes a breakdown of the relevant contribution from petrol and diesel vehicles. You can access the data here: https://data.london.gov.uk/air-quality/ Question 7: Please provide the evidence air pollution is linked to COVID 19? A recent report by Imperial College London found that there is evidence that long-term exposure to air pollution increases susceptibility to worse outcomes from COVID-19. You can find the report here: https://www.london.gov.uk/WHAT-WE-DO/environment/environment-publications/investigating-links-between-air-pollution-and-covid-19 Question 8: We wrote in our previous response: “We’ve proved that emissions-based charging works, but there is more still to do. We now need to build on this success to deliver cleaner air for millions more Londoners.” You asked: How did you prove and to whom did you prove that emission charging works? Please see:
Question 9: What are 8% of London roads that do not comply with legal limits for NO2 and why these roads do not comply with legal limits? Officers are currently reviewing the remaining locations across London that are predicted not to meet legal compliance with NO2 limits after ULEZ expansion and identifying targeted solutions spanning Government, Mayoral and borough powers to address them quickly and effectively. This requires updated modelling due to be completed later this year. Question 10: We wrote in our previous response “We predict that with the expanded ULEZ, over 100,000 fewer people in London will be living with illegal levels of air pollution by the end of 2021 than would otherwise be the case, with continued improvements in later years. Also that NO2 concentrations along most roads within the zone will drop by 3 – 5 micrograms/m3 (about 5 to 10 per cent) and along larger more strategic roads, including the boundary roads, NO2 concentrations will drop by up to 10 or even 15 micrograms/m3 (about a 20 per cent reduction).” You asked: What are the tools and statistics used to predict the above numbers? The answer to this question can be found in the “Integrated Impact Assessment” for ULEZ Expansion and LEZ tightening. See here:https://tfl.gov.uk/corporate/publications-and-reports/ultra-low-emission-zone#on-this-page-1 - appendices J and K to the Report to the Mayor.
Question 11: We wrote in our previous response: “Real experience with the central London ULEZ shows that Londoners are willing and able to change their travel habits or their vehicles, which gives us additional confidence that the benefits of the scheme will be realised in practice”
You asked: There is a difference between willing and mandatory (forced).Please clarify? Does it mean cars are to be changed every 5 years if they are to fall within ULEZ levels?
Londoners have shown they are willing to upgrade their vehicles rather than pay the charge and have done so ahead of time, with high levels of compliance seen ahead of ULEZ expanding (as evidenced above in answer to Q5). Positive attitudes towards addressing air quality are evident, with 68 per cent of Londoners in a YouGov survey carried out for environmental law firm ClientEarth thinking high-polluting vehicles should pay more than other vehicles for travelling through the Capital and a majority (51%) saying they support an extension of the ULEZ compared with 33 per cent opposing it (see here: https://www.clientearth.org/latest/press-office/press/majority-of-londoners-support-expansion-of-the-ultra-low-emission-zone/).In addition, see the central London ULEZ reports published here:https://www.london.gov.uk/WHAT-WE-DO/environment/environment-publications?order=DESC and Travel in London 13 published here: https://content.tfl.gov.uk/travel-in-london-report-13.pdffor further information about how Londoners have changed their travel habits or their vehicles.
The standards chosen for ULEZ were selected because they would deliver the optimum emissions savings, balanced with being achievable with minimal negative impact. They have already proven to be very effective in the central zone. While the Mayor’s Transport Strategy includes a policy to keep all the road user charging schemes (including ULEZ) under review to ensure they are proving effective, we have no plans to make any changes to the emission standards or vehicles subject to the scheme. If in future any changes to schemes were to be proposed, would need to be fully consulted on before a decision was made to proceed. Question 12: We wrote in our previous response: “The expanded ULEZ will cover an area 18 times larger than the central ULEZ. 3.8 million people live within the expanded zone, but 6 in 10 households in the expanded zone do not own a car. Londoners are already doing their bit, with four out of five cars seen driving in the zone already meeting the ULEZ emissions standards. We now need the owners of the remaining older polluting cars, motorcycles, lighter vans and minibuses to take action because every Londoner should have the right to breathe clean air.” How and why do you corelate households with cars with ULEZ? Six out of ten households in the zone do not have a car. It is illustrative of the number of households who will not have to take action to change their vehicle, because they do not own one. Consequently, the people in those households breathe in pollution from road vehicles that they are not responsible for. Question 13: As you used in your response the term “own a car” explain legal difference between registered keeper and the owner of the car? The figures are taken from the London Travel Demand Survey (LTDS) where respondents are asked if they own a car. More information on the LTDS is published here: https://tfl.gov.uk/corporate/about-tfl/how-we-work/planning-for-the-future/consultations-and-surveys Question 14: What does it mean in legal terms? Extract from SI you referred to further below in yourresponse (2) For the purposes of these Regulations the registered keeper shall be presumed to be the owner of a vehicle registered under the Vehicle Excise and Registration Act 1994(3). Why the registered keeper shall be presumed to be the owner of a vehicle? We do not hold this information. We only have access to registered keeper information because this is what is recorded with the DVLA.However, on the substantive issue of why we refer to the registered keeper as the presumed owner of the vehicle, please see below an extract from a West Yorkshire Police summary of the difference between registered keeper and car-owner ‘A registration document (V5) is not proof of ownership. The registered keeper should be the person who is actually using / keeping the vehicle and this is not necessarily the owner of the vehicle or the person who is paying for it. That person is the person responsible for the vehicle so far as official communications from the police/DVLA etc., but the owner is the person who put up the cash (or was given it as a gift). The DVLA make a point of saying that the person named on the registration document is not necessarily the owner. This is particularly true with a company car which is owned by the company, however the registration document should show the registered keeper, i.e. the day-to-day user (this may be an employee who has it as a permanent perk with his/her job). In the case of a car used by a married couple, ownership of any property is usually classed as joint and if the husband/wife was stopped driving the vehicle without insurance the police would probably accept that he/she was the joint owner and not look to the other partner for additional offences, such as owner permitting no insurance. A registered keeper will usually be regarded as responsible for parking tickets etc. so it would be wise to have the registration document changed if you are the owner, but not the user/keeper. Additionally, as the owner/registered keeper of a vehicle, there might also be some circumstances where you could be prosecuted for an offence, e.g. if you are permitting someone to use the vehicle knowing full well it is not insured or roadworthy.’
The above information was sourced here: https://www.westyorkshire.police.uk/ask-the-police/question/Q743 The registered keeper in law is presumed to be the day to day user and so the person most likely to be driving or in charge of the vehicle, and therefore responsible for any contraventions arising from its use e.g. speeding tickets, road charges and Penalty Charge Notices. The owner of the vehicle is not necessarily the registered keeper (e.g. someone who paid for it but allows someone else day to day use). The regulations say it is a presumption and so can be displaced by evidence that shows someone else is the owner of the vehicle and therefore liable.
Question 15: We wrote in our previous response: “The cost benefit analysis that was done in the Business Case shows a Benefit Cost Ratio (BCR) of 2.03:1”
You asked: Please provide the figures (amounts) for the cost benefit analyses and who carried them?
TfL uses a uniform framework to prepare, evaluate and present business cases.The Benefit Cost Ratio (BCR) is calculated by dividing the Net Present Value of passenger benefits by the Net Financial Effect.Costs are calculated for the whole life of the assets involved in the project.All benefits and disbenefits are quantified - for ULEX this includes pollution and health benefits from physical activity as well as wider economic, social or external impacts.Costs and benefits are calculated in comparison with the base option at constant prices and costs and benefit streams over the life of the project are discounted to give present values in the base financial year over the whole appraisal period. The figures for this calculation are shown in the table below:
Economic Impact - Comparison of Options
INCREMENTAL NPV Values (Preferred Option - Base)
Evaluated from 2017-18 to 2025-26
1E+14
999999999
£m (in millions)
Option 2
ULEX 2021
Project Costs - Capital cost
-£103.87
Project Risk
-£25.95
Project EFC
-£129.82
Project Optimism Bias (takes account for the systematic tendency for appraisers to be overly optimistic about key parameters
-£10.39
Operating cost ULEX
-£252.50
Other Income from Private Sector
£306.61
NFE (to public purse)
-£86.10
Fin Neg
Payback Period (from 2019)
n/a
-
Other - Local Air Quality
£432.50
- Physical Activity
£48.63
Total Social Benefits
£481.13
Other Private Sector Costs
-£306.61
Net Social Benefits
£174.52
Net Benefits
BCR / DCSR
BCR = 2.03 : 1
Question 16: Where the surplus will be invested? As a public body we are able to reinvest every pound of income into the transport network. All the money received from the ULEZ will be reinvested into improving London’s roads, cycleways, buses and tube – and making London’s air cleaner. Question 17: Please provide evidence in surplus from previous years is invested in London’s air quality? This information can be found in our Annual Reports, the latest copy of which is published online here: https://content.tfl.gov.uk/tfl-annual-report-9-august-2021-acc.pdf Question 18: If it is not about making money why charging is introduced and forced on the drivers who live and come to London?
ULEZ aims to reduce harmful emissions from vehicles and is designed to strike the best balance between maximising the health benefits for Londoners and minimising the cost to drivers in London. The £12.50 daily charge has been set at a level that will enable occasional trips to be affordable, while at the same time encouraging those who frequently travel into the zone to upgrade their vehicle as they contribute more to harmful emissions, or to switch to walking, cycling and public transport where possible. The Mayor and TfL would prefer that all drivers used vehicles that met the ULEZ standard rather than paying the daily charge.
Question 19: Do all TfL buses and trains comply with ULEZ and if not who is financing the change? What are the sources of finance?
Yes, all buses operating scheduled services do meet the ULEZ standard. Trains are not covered under the ULEZ scheme. It is a road user charging scheme. However, note that TfL does not operate any diesel passenger trains on its network.On 11 January 2021, TfL released its Financial Sustainability Plan which focuses on a green recovery and sets out how it can achieve financial sustainability after fare income was decimated by the pandemic – covering costs of day-to-day operations, maintenance, and financing by 2023/24. You can read more about these plans here: http://content.tfl.gov.uk/financial-sustainability-plan-11-january-2021.pdf
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Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
Yours sincerely,
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
