Regulatory Impact Assessment for charging non Euro 3 compliant motorcycles in the London ULEZ
Request ID: FOI-1747-1819
Date published: 17 October 2018
You asked
I wish to make a Freedom on Information request to receive a copy of the Regulatory Impact Assessment (RIA) undertaken by TFL in compliance with Government guidance (see https://www.gov.uk/government/publications/impact-assessment-template-for-government-policies) into the costs and benefits associated with the decision to charge non Euro3 compliant motorcycles £12.50 a day to enter the London Ultra Low Emission Zone (ULEZ) in April next year. The sharp increase in costs to those affected, many of whom I believe are lower income people who currently ride quite serviceable but older motorcycles to commute to essential jobs, will be disproportionate to the very small difference in emissions between continuing to use these machines and the emissions output of Euro 3 compliant models. The overall mileage covered by this class of vehicle in the ULEZ area is relatively small but the immediate economic impact on many riders, particularly those working at or close to the minimum wage, will be very high, as would the burden on their slender finances associated with buying a more modern second hand Euro3 compliant machine to avoid paying the charge.
I would like to see the data that TfL have used to assess the balance of costs and benefits for this class of road user as I believe that such a consideration ought to have formed part of the TfL’s overall RIA.
Given the stated objective of stimulating a shift in commuting from road to public transport, has an assessment also be made of the costs and benefits of such a shift for a lower income person currently commuting say 50 miles a day in and out of London on a small pre 2007 motorcycle?
If it did not make these assessments, I would like to see TfL’s rationale for excluding consideration of this sort of social impact from their overall RIA process.
Birmingham City Council have recently decided to exempt all motorcycles from their proposed Clean Air Zone. It would be interesting to compare the science and economics underlying this decision with similar data and reasoning used by TfL to include non Euro3 compliant motorcycles in the ULEZ charging regime.
We answered
TfL Ref: 1747-1819
Thank you for your email received by us on 1 October 2018 asking for information about the inclusion of motorbikes in the Ultra Low Emission Zone (ULEZ).
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 some of the information you require.
London is currently breaching legal limits for NO2 concentrations, and 443 schools in London are in areas exceeding legal air quality levels. The ULEZ is a key part of our efforts to tackle London’s appalling air quality, and an essential step to improving the air we breathe.
Transport for London’s (TfL) modelling indicates that expanding ULEZ beyond central London, in combination with strict standards for heavy vehicles across the capital will result in a 28 per cent reduction in NOx London-wide in 2021, which will reduce the number of Londoners living in areas exceeding legal air quality limits by over 100,000. Evidence suggests those on the lowest incomes are disproportionately affected by air pollution, and ULEZ will help reduce the health inequalities faced by this group.
Whether a vehicle is ULEZ compliant is determined by its Euro emission standard. Euro standards have been used as they represent vehicles that have been tested using a legally recognised and approved engine test cycle. Any vehicle ages given are simply an indication of when the relevant Euro standard came in to force.
All vehicles contributing to London’s illegal levels of air pollution are required to meet emissions standards; this is why motorcycles have been included in the ULEZ. While motorcycles are often smaller than cars, they emit emissions at a similar level. Motorcycles must meet the Euro 3 standard, which is in fact a lower Euro standard than those set for other vehicle types. This is because exhaust emissions regulation for motorcycles began later and have since lagged behind the trajectory of emissions controls used for other vehicles. As a result, compliant motorcycles are actually able to pollute at a higher level than cars - compliant motorcycles (meeting Euro 3) are permitted to emit 0.15 g/km of NOx. In comparison, compliant petrol and diesel passenger cars (meeting Euro 4 and 6, respectively) are only permitted to emit 0.08 g/km of NOx.
The £12.50 daily charge for cars, vans and motorcycles has been set at a level to encourage drivers to switch to more sustainable forms of transport such as walking, cycling or public transport, or where they need to use a motorised vehicle, to ensure it meets the required minimum emission standard. The vast majority of motorcycles already meet the Euro 3 standard and our forecasts indicate that over 80 per cent of motorcycle kilometres travelled in the ULEZ zone in 2019 would meet the ULEZ standard.
We understand the difficulties that some people on low incomes may face as a result of having a non-compliant vehicle, however, it is important to note that ULEZ does not require the purchase of an expensive new vehicle; Euro 3 compliant motorbikes have been manufactured from around 2007, meaning there is a large selection of affordable second-hand vehicles available.
And finally, in terms of enabling people to switch to more sustainable modes, particularly for those on low incomes, the Mayor of London has frozen TfL fares until 2020, to help make public transport more affordable after years of fare increases for London passengers. Approximately four million journeys a day across London are the same price as they were in 2016. By 2020, this will have saved the average London household around £200. The Mayor has also introduced the Hopper fare, which allows Londoners to take unlimited bus and tram transfers within one hour for £1.50. TfL figures show that around 350,000 journeys are being made every weekday using the ‘Hopper’ fare.
Regulatory Impact Assessments (RIAs) are used to assess government legislation and are not used by Transport for London. An integrated impact assessment was undertaken for the ULEZ proposal in 2014, and updated for the proposal to bring forward the implementation date of the ULEZ. All information is available on the TfL website via: https://tfl.gov.uk/corporate/publications-and-reports/ultra-low-emission-zone
Original ULEZ documentation can also be found via the links to our website below:
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-supplementary-information---final-291014.pdf
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-iia-report_final.pdf
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-iia_hia_final.pdf
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-iia_ea_final.pdf-1
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-iia_eqia_final.pdf
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-iia_ebia_final.pdf
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-consultation-report-to-the-mayor.pdf-1
For information on changing the start date of the ULEZ, please see the following links:
https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-3a/
https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-3a/user_uploads/appendix-i-2.pdf
https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-3a/user_uploads/ulez-proposed-changes_iia-updated.pdf
https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-3a/user_uploads/report-to-the-mayor-2.pdf
If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.
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
Jasmine Howard
FOI Case Officer
Information Governance
Transport For London
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