Request ID: FOI-2079-2324 Date published: 26 September 2023
You asked
A. Public Health
1. What asthma data have you been using to support your argument that asthma:
a. is higher in London (ULEZ and/or NULEZ) than elsewhere
b. is caused by air pollution from cars
2. Since ULEZ was introduced, what changes within the ULEZ Zone have there been in:
i. levels of asthma
ii. the number of deaths attributed to asthma
iii. levels of lung cancer
iv. the number of deaths attributed to lung cancer
3. How has your figure of 4,000 deaths been compiled?
4. What data sits behind the Mayor’s 2016 statement “With nearly 10,000 people dying early every year in London due to exposure to air pollution, cleaning up London’s toxic air is now an issue of life and death”
5. How many of these deaths had, as the cause of death:
i. Air Pollution
ii. Asthma
iii. Lung Cancer
6. How many deaths in NULEZ in the last 5 years (or for whatever dates you have available) have been/you attributed to Air Pollution, and how has that figure come about?
7. How many of these have been attributed to (or, how have they been allocated as between):
i. Vehicle emissions (private ownership)
ii. Public transport (tube, train and bus)
iii. Industry and factory emissions
iv. Household emissions
v. Aircraft emissions
vi. Other
8. What methodologies have you used in calculating the figures in Q1 to Q6 above?
9. How do these figures compare with those relating to the ULEZ area?
10. What evidence do you have that any deaths in London in the last 10 years were due to car (or vehicular) emissions?
B. Air Pollution
1. What are the current levels in:
a. London Borough of Barnet?
b. NULEZ generally
c. ULEZ
2. How much will this be reduced in NULEZ specifically by the Extension?
3. What is the timeframe for this?
4. What proportion of air pollution in NULEZ do you consider to come from:
i. Vehicle emissions (private ownership)
ii. Public transport (tube, train and bus)
iii. Industry and factory emissions
iv. Household emissions
a. Aircraft emissions
b. Other
5. What proportion of air pollution in ULEZ do you consider to come from:
v. Vehicle emissions (private ownership)
vi. Public transport (tube, train and bus)
vii. Industry and factory emissions
viii. Household emissions
ix. Aircraft emissions
x. Other
6. How do these compare with the Camden Council’s figures (sourced from the GLA) published in 2013?
7. What are the current air pollution figures on the London Underground for:
a. CO2
b. NOx
c. Particulates
8. How have these figures changed over the last 10 years?
9. What is the rationale – if pollution is the issue being addressed – for charging drivers to pollute “legally”, rather than an introduce overall ban?
C. Emissions
1. What are your current emissions figures for compliant cars in terms of:
i. CO2
ii. NOx
iii. Particulates from tyres
2. With reference to your 2013 published figures (attached), how much heave emissions since gone up or down:
a. in NULEZ
b. in ULEZ
3. Which areas in NULEZ now exceed the 40ug limits, and would therefore have a different (yellow/orange/green) colour on the attached map?
4. What impact (numerically) will the Extension’s removal of non-compliant petrol cars from circulation have by 2030, considering the Government’s and NAEI’s findings (prior to the announcement of NULEZ), that “NOX emissions are predicted to decrease by 65% by 2030 relative to 2017 levels but remain dominated by diesel cars and LGVs (79%).”
5. Why have you chosen to focus on nitrous oxide and nitrogen dioxide (together “NOx”) over:
iv. Emission of tyre particulates, or
v. carbon footprint?
6. What percentage of emissions are from cars rather than truck, lorries and other commercial vehicles?
7. What figures are you using for tyre particulate emissions and how does that impact your emissions data?
8. To what extent have you taken into consideration cars’ weight when determining particular emissions? In particular, what figures are you using for typical/average weight of:
a. non-compliant cars
b. new EVs
9. How many more EVs will there be on the road as a result of the Extension?
a. How much increase in emitted particulates will be due to these new EVs?
10. Can you confirm that:
a. no compliant car’s official emissions figures exceed and non-compliant car’s figures?
b. (according to official manufacturers’ figures) all compliant diesel cars emit less than all non-compliant petrol cars?
11. If not, what is your official justification for allowing modern “compliant” diesel SUVs over older “non-compliant” petrol cars, where the former emit far more pollutants than the latter
12. How do you know the NOx levels of cars that were not manufactured in accordance with Euro standards (eg. imported from Asia where Euro standards do not apply)?
D. Cars in Circulation
1. How many current working vehicles will be scrapped due to the Extension?
2. How many new cars due you anticipate being bought as a result the Extension?
3. How many cars do you believe will be removed (net) from circulation as a result of the Extension?
4. If you anticipate a net reduction, how do you reconcile that with the number of cars in circulation in London remaining static for 15 years, despite various scrappage schemes?
5. When you say the “last scrappage scheme, which saw the removal of more than 15,000 polluting vehicles from London's roads”, how many of those were replace with new cars?
6. How has the initial expansion of ULEZ to the north/south circular effected the number of cars owns or in circulation?
E. Climate Change
1. What carbon reduction figures are you using to illustrate that this is a “climate and nature-positive” policy?
2. What data supports your suggestion that the Extension is climate positive, when all the science says the exact opposite?
3. To what extent have you considered the carbon footprint of new cars in your calculations on the climate change impact of the Extension?
4. What plans have been put in place to deal with additional carbon footprint of the Extension?
5. What figure have you used for the carbon footprint of manufacturing a new vehicle?
6. Does this figure include:
a. Manufacturing?
b. Import / distribution?
c. Battery raw materials scrapping?
d. Socio-economic issues and ethics of lithium mining?
7. What figure have you used for the carbon footprint of scrappage?
8. What steps have you taken to deal the carbon footprint of scrappage:
a. Reducing the 70% of scrap car metal that gets shipped to Turkey (UK’s current policy)?
b. Battery recycling?
F. Congestion
1. What are the current congestion figures for Barnet? (or the area covered by NULEZ)
2. How much will this be reduced by the Extension?
3. What is the timeframe for this?
4. Will this comparison be done on a like-for-like basis (ie. no traffic measures implemented just prior to the policy)
5. Do you believe faster or slower moving traffic creates more pollution?
6. What changes have you made to traffic light sequencing in the 12 months leading up the implementation of NULEZ?
G. Revenues and Taxes
1. How much money do you anticipate earning through the Extension for each of the next 5 years?
2. Is this a tax, and if not, how does it differ to the Congestion Charge that US Diplomats are exempt from paying?
3. How much Congestion Charge do you estimate you have lost through non-payment by foreign diplomats over the last 10 years?
4. What percentage of the GLA budget for each of the next 8 years is anticipated to be reflected by income form ULEZ fines (please specify each yearly amount)?
5. What is the GLA’s “Plan B” should there be no such income (ie. full compliance)
6. What is the average cost to the GLA of pursuing a non-paying charge of ULEZ to the point of appointing bailiffs?
H. Consultation and Cameras
1. How many people were consulted regarding NULEZ and the Extension?
2. How were those consultations sent out?
3. What was the wording on the questions?
4. How many responses did you receive?
5. How many people agreed with NULEZ and/or the Extension?
6. How many of these people own non-compliant vehicles?
7. What was the breakdown by borough for each of Q1 to Q6 above?
8. How many cameras have you ordered?
9. When were they ordered?
10. How much did they cost?
11. What was the tender process put in place, and how was this company chosen
12. What are the terms in the procurement contract in relation to what happens if the Extension does not go ahead?
I. ULEZ Compliance
1. Where does the TfL data on compliant / non-compliant cars come from?
2. On what basis would I be “fined” if I do not pay a ULEZ charge?
3. Is this a criminal offense, or a civil matter?
4. Either way, what is the statutory framework sitting behind your/TfL’s right to fine me?
5. Likewise, what happens if I do not then pay the fine, and on what legal basis?
6. How do you/TfL obtain my personal details, and that of my car?
7. How does this meet ICO and DPA requirements?
8. If my car passes MOT emissions requirements, why is it illegal to drive it in anywhere London without paying an additional charge?
9. How do you know if/whether/that my car – which is “non-compliant” because it is older than your arbitrary cut-off date – is in fact less polluting than my neighbour’s compliant car?
10. If the owner of a “legal grey import” (eg. Japanese) car cannot obtain NOx data or a CoC from the manufacturer (eg. because s/he doesn’t speak the language, the data is not available, or the manufacturer has ceased to exist), are they presumed guilty or is there an exemption whereby they can be presumed innocent until proven guilty?
J. Dangers and Annoyances
1. How many electric car fires have there been in London in the last 5 years
2. How many electric bus fires have there been in the last 5 years
3. Is the number of electric vehicle fires higher or lower (in proportion) for EVs than ICE cars?
K. Demographics and TfL Statistics
1. How many households are likely to be affected by the extension by virtue of having non-compliant cars?
2. What percentage of those are eligible for the scrappage scheme?
3. What are the age demographics of those households with non-compliant cars (and how does this compare with the UK and/or London average)?
4. What are the household incomedemographics of those households with non-compliant cars (and how does this compare with the UK and/or London average)?
5. How many days per week does a non-compliant NULEZ-based car typically drive?
6. How many miles do they typically drive per week in NULEZ?
7. How many non-compliant cars driven in London are owned by households outside London?
8. How many days per week do those cars typically drive in London?
9. What exemptions are there for paying NULEZ charges, and what is the rationale behind each exemption?
10. Where were the cameras which were used to calculate your headline figure of “9 in ten cars are compliant” (please provide a map)
11. How many were used, and what proportion of the total cameras available is that?
a. What was the rationale in choosing those specific locations?
b. If “random”, please provide the statistical reasoning of the choice
12. How have you chosen the area covered by NULEZ, considering the Government’s own finding that “Analysis of ambient air pollution concentrations shows that the rate of change in exhaust emissions varies from place to place with no clear pattern”
L. Alternative transport
1. What plans have been put in place for people who are not eligible for the scrappage scheme?
2. If no plans, what do you expect them to do?
3. What specific measures have been put in place for those who are unable to continue using/owning a car?
4. How many bus routes have been removed in the last 8 years in the area covered by NULEZ
5. How many miles (net) of bus routes have been removed have been removed in that time
6. How many miles of new tube network within NULEZ:
a. Have been launched in the last 8 years
b. are committed to for the near future (and to open when)
7. In my earlier example, where I own a roadworthy MOT’d car, and drive it 6 days/wk to visit elderly parents, play football and do the weekly shop (each 15mins drive, no public transport options), and I don't qualify for any of your "help", what am I supposed to do?
M. Will Of Parliament
1. In launching the Extension, what consideration was given to the will of Parliament with regard to:
a. the Right to Repair Act,
b. the Consumer Rights Act 2015
c. the Ecodesign for Energy-Related Products and Energy Information Regulations 2021 (adopting) the EU Circulatory Economy Action Plan (p2 link here)
2. Is that consideration minuted? (If so, please provide)
3. Why is TfL / The Mayor not following the example of white goods, food, consumer electronics, fashion (etc) in moving away for planned and forced obsolescence?
4. In particular, what is TfL’s explanation for a policy that directly conflicts with the will of Parliament?
5. How does TfL reconcile the extension with the following statements by parliament expressing its will to:
a. “ensure that the regulatory framework is streamlined and made fit for a sustainable future, that the new opportunities from the transition are maximised, while minimising burdens on people and businesses”;
b. “establish a strong and coherent product policy framework that will make sustainable products, services and business models the norm and transform consumption patterns so that no waste is produced in the first place [with] key product value chains addressed as a matter of priority. Further measures will be put in place to reduce waste and ensure that the EU has a well-functioning internal market for high quality secondary raw materials”
c. “entire life cycle of products. For example, it targets how products are designed, promotes circular economy processes, encourages sustainable consumption, and aims to ensure that waste is prevented, with valuable resources kept in the EU economy for as long as possible.”
d. “These benefits will help us on our way towards the UK’s Carbon Budget and Net Zero targets”
e. “An important aim of the new Regulations is to extend the life of certain categories of products”
f. “It is hoped that prolonging the life… and delaying the need to buy expensive replacements will prevent unnecessary waste”
g. “New rights … should enable consumers to repair goods when they break down and so continue using them even when their statutory rights to have them repaired or replaced under the have expired”
h. Secretary of State for BEIS: “Our plans to tighten product standards will ensure more of our electrical goods can be fixed rather than thrown on the scrap heap, putting more money back in the pockets of consumers whilst protecting the environment.”
i. “With this legislation we aim to reduce the energy-use, carbon footprint and wider environmental impacts of energy-related products”
We answered
TfL Ref: EIR-2079-2324
Thank you for your request received by Transport for London (TfL) on 13th September 2023 asking for information about the ULEZ scheme.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations (EIR) and our information access policy.
In your request you have asked in the region of 150 separate questions. Before addressing this, please note that TfL has proactively published vast amounts of information about the rationale for expanding the ULEZ scheme, both as part of the consultation exercise and in the subsequent consultation reports. I would point you in particular to the following pages of our website where this information can be found, although note that this does not represent everything that can already be found online about the scheme:
Turning to your specific questions, given the very large number and the broad scope they are being refused under regulation 12(4)(b) of the EIR on the grounds that it would be “manifestly unreasonable” to source and provide all of the answers / material requested. Note that there is no single source for all of this information within TfL, and no single repository from which the material could be extracted, reviewed and collated.It would take a considerable amount of time just to determine exactly what is held and where, and further time still to then source answers. Given this, we are satisfied that the exception is engaged. The use of this exception is subject to a public interest test, which requires us to consider whether the public interest in applying the exception outweighs the public interest in disclosure. We recognise that the release of information would promote accountability and transparency in public services and also help address concerns about the ULEZ extension. However, the time it would take to provide the information you have requested would divert a disproportionate amount of our resources from our core functions and on balance we consider that the public interest currently favours the use of the exception. This is especially the case given the wealth of material that has already been proactively published. If, having reviewed all of the material cited above, you wish to submit a narrowed request then we will consider it accordingly.
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
