Request ID: FOI-2601-2324 Date published: 08 November 2023
You asked
Dear TFL
Under FOI please confirm the following:
• Are the relevant permissible NOx levels relating to EURO standards which TFL are using as a basis for compliance / non compliance with ULEZ based on a per metre cubed M/3 figure or based on the actual emissions each specific vehicle emits? My understanding is the figure is based on per M/3 but please confirm this?
• On the basis the point above is correct, is it true that many expensive larger (compliant) single vehicles despite a lower per M/3 emissions figure will actually be emitting more Nox (and probably other pollutants) than many smaller, older (non-compliant) vehicles?
• Have 4000 actual people died prematurely as a direct result of air pollution in London last year?
• If the answer to the point above is NO (which it is), please explain why Sadiq Khan is claiming this to be the case?
I look forward to hearing from you.
We answered
TfL Ref: 2601-2324
Thank you for your request received by Transport for London (TfL) on 19 October 2023 asking for information about the ULEZ scheme. 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. You asked:
Are the relevant permissible NOx levels relating to EURO standards which TFL are using as a basis for compliance / non-compliance with ULEZ based on a per metre cubed M/3 figure or based on the actual emissions each specific vehicle emits? My understanding is the figure is based on per M/3 but please confirm this?
On the basis the point above is correct, is it true that many expensive larger (compliant) single vehicles despite a lower per M/3 emissions figure will actually be emitting more NOx (and probably other pollutants) than many smaller, older (non-compliant) vehicles
The Euro standards for NOx emissions are based on a limit of grams per kilometre (g/km). The standard for compliance with the ULEZ is 0.08g/km NOx. This applies to both petrol and diesel engines and is equivalent to the Euro 4 standard for petrol cars and the Euro 6 standard for diesel cars. (There is an additional requirement to not exceed 0.005g/km particulate matter for diesel engines). These limits are measured over the type approval ‘type 1’ test and the results are declared at the time of type approval and recorded by the DVLA.
Have 4000 actual people died prematurely as a direct result of air pollution in London last year?
If the answer to the point above is NO (which it is), please explain why Sadiq Khan is claiming this to be the case?
The statistic relating to 4,000 deaths is taken from the following report: https://www.london.gov.uk/sites/default/files/london_health_burden_of_current_air_pollution_and_future_health_benefits_of_mayoral_air_quality_policies_january2020.pdf The report was commissioned by City Hall and undertaken by Imperial College and it is based on the report finding that ‘in 2019, in Greater London, the equivalent of between 3,600 to 4,100 deaths were estimated to be attributable to air pollution, considering that health effects exist even at very low levels. This calculation is for deaths from all causes including respiratory, lung cancer and cardiovascular deaths’. The report goes into detail as to how the statistic was calculated and provides a breakdown by borough in the summary tables. The report describes the methodology to estimate the number of attributable deaths in London and confirms that it uses the Office of National Statistics information on the number of deaths in London as the starting point (this is described in section 8.5 of the report and specifically references in footnotes 48 – 51).
The method then follows the UK Government’s independent advisory group (COMEAP) recommendations to estimate the proportion and number of deaths that would be attributable to air pollution. The forecast number of deaths that would be prevented by London-wide ULEZ is set out in Chapter 6.2 of the Integrated Impact Assessment (IIA). You may also want to look at the Air Quality Health Impact Assessment (AQHIA) which can be found in Appendix A of the IIA: https://haveyoursay.tfl.gov.uk/15619/widgets/58629/documents/34537
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 FOI Case Management Team General Counsel Transport for London
