What is the ULEZ?

With an estimated 9,000 Londoners dying early every year as a result of toxic air, and over 400 schools being in areas exceeding legal limits for air pollution, this week sees the roll-out of the latest initiative to tackle London’s polluted air.

Beginning Monday 8th April, the Ultra-Low Emission Zone (ULEZ) will cover the area in central London where the Congestion Charge currently applies, before being expanded in October 2021 to cover the area bounded by the North and South Circular roads.

The ULEZ will apply 24 hours a day, seven days a week, and vehicles not meeting the tougher emission standards will have to pay an additional £12.50 charge, on top of the £11.50 congestion charge. Lorries will have to pay £100 a day. There are substantial fines for failing to pay the charge.

Generally, many pre-2015 diesel cars and pre-2006 petrol cars will not be compliant with the new standards. The Mayor of London, Sadiq Khan, hopes the ULEZ will reduce nitrogen oxide (NOx) emissions by 45%. This naturally leads to a discussion of what additional steps could cut even more NOx emissions in London, and also particulate matter (PM) emissions.

Could the ULEZ be stronger?

One such step, as the Mayor’s transport strategy has rightly highlighted (pg 115, proposal 36), is tackling emissions from auxiliary engines.

The auxiliary engines that power diesel transport refrigeration units (TRUs) are regulated not by the Euro emission standards, but by the weaker non-road mobile machinery (NRMM) standards. As a result, a diesel TRU can emit six times as much NOx and 29 times as much PM as a Euro 6 diesel engine. What does this mean? Across Greater London, all TRUs emit 164 tonnes of NOx and 22 tonnes of PM per year, equivalent to driving a family car almost 450 million kilometres – which equates to 2.4 million laps around the M25.

The ULEZ, and indeed other equivalent clean air zones around the country, could be greatly strengthened by incorporating TRUs too. However the clean tech sector is waiting on the Department for Environment, Food and Rural Affairs (Defra) to set out how this will be done through the existing environmental permitting regime. As set out in government guidance, the regime “requires operators to obtain permits for some facilities, to register others as exempt and provides for ongoing supervision by regulators”.

Until tougher action is taken on diesel TRUs, users of other diesel vehicles will feel unfairly penalised given that weaker regulation allows diesel TRUs to emit a disproportionate amount of NOx and PM. Tougher regulation here from Defra is long overdue, and with the ULEZ about to begin operation, we hope it will have the level of impact that is expected. To go even further, incorporating diesel TRUs is surely a must.

Mo Saqib
Policy & Communications Officer, Dearman

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