26 Jun Consultation on the Central London ULEZ – Medact Response

Medact is a London-based public health charity that works on environmental health, amongst other things. Medact is the lead organiser of the Doctors Against Diesel campaign which comprises a wide range of academics and clinicians who are concerned about the particularly harmful impacts of diesel vehicle emissions on the health of children. Among the members of Doctors Against Diesel are clinical scientists who are at the cutting edge of research on the health impacts of air pollution caused by particulate matter and nitrous oxide.

1) Do you support the principle of the Ultra Low Emission Zone to improve air quality in London?

Medact strongly supports the principle of ULEZ.

Air pollution is now a leading cause of death worldwide and London is now the most polluted city in the UK.  Air pollution has been shown to have harmful effects on the lungs, heart and brain, particularly in children whose organs are still under development.  In addition to children, the elderly the and infirm are also particularly affected.

The principal aim of ULEZ is to improve the quality of air in London which we support wholeheartedly. However, we would like to see the following four suggestions be made central to the Mayor’s plan for ULEZ:

1. Implement the ULEZ as soon as possible
2. Expand the area to include the North and South Circular road, and beyond into Greater London
3. Include a charge on Euro 6 Diesel Cars in all  ULEZ as these cars have clearly been shown to be neither safe nor clean.
4. Invest in and support alternatives to car travel such as public transport, walking and cycling; and encourage greater car sharing

These suggestions would allow for an expanded and integrated approach to improving air quality that includes a shift away from private car use.  A shift away from car use has multiple other advantages including the reduction of greenhouse gas emissions, increasing physical activity (and therefore improving health outcomes), reducing overall traffic (and therefore reducing PM2.5 related to braking and tyres), and reducing congestion (benefiting both the air quality and businesses).  Supporting alternatives to private car ownership is also fairer for drivers on low incomes who will struggle to upgrade to a cleaner vehicle.

2) To what extent do you support bringing forward the implementation of the ULEZ in central London from 7 September 2020 to 8 April 2019?

Medact strongly supports bringing forward the implementation of the ULEZ in Central London. The negative effects of air pollution on health and children’s development should be mitigated as soon as possible.

We are disappointed that the plans to extend the ULEZ beyond the North South Circular have been delayed to the next Mayoral term.  The urgency and severity of the problem should dictate a more ambitious and speedier response. The government’s own national air quality plan identifies that Clear Air Zones (CAZs) as being the most cost-effective way of dealing with urban pollution.  Therefore, there is no convincing reason for why expansion should be delayed.

As noted under Question 1, we would like to see the ULEZ expanded to include the North South Circular and beyond into Greater London soon after.

3) Do you support keeping a 3 year resident’s sunset period so it is from 8 April 2019 to 11 April 2022?

Yes

4) Do you support keeping the present end date of the sunset period for disabled tax class vehicles so it is from 8 April 2019 to 11 September 2023?

Yes.

5) To what extent do you support introducing a Particulate Matter (PM) standard for diesel vehicles within the ULEZ standard?

Medact strongly supports the inclusion of a particulate matter standard for the ULEZ.

6) If you have any further comments about the proposals, please write these in the box below.

Medact values Mayor Sadiq Khan’s determination to tackle this preventable cause of damage to child health and premature mortality.  The Mayor’s plans to introduce the world first ULEZ in Central London from April 2019 is an important first step towards cleaner air.  However, we believe that delaying the plans to cover the North South Circular and excluding Euro 6 diesel cars from the charging zones to be significant deficiencies.

We believe that action on Euro 6 cars is of paramount importance because modelling studies conducted by King’s College London show that diesel cars need to be phased out almost completely across London in order to ensure legal compliance to NO2 levels. Furthermore, Real World Driving emissions standards Euro 6 cars are set to allow vehicles to emit over 2 times the legal limit of NOx.

Charging new Euro 6 diesel cars would also be fair as anyone buying a new diesel car would be forewarned about the charges.

We also believe that government intervention should be considered to speed up the shift in market preferences towards electric and hybrid vehicles.

In the longer run, diesel and petrol need to be phased out altogether to tackle the threat of climate change.