Leaders of four councils, including Harrow, have written to the Mayor of London today stating that air pollution statistics he shared were ‘misleading’ and outlined their commitment to fighting the ULEZ expansion plan.
On Sunday, Sadiq Khan wrote to the leaders of Bexley, Bromley, Harrow and Hillingdon citing mortality rates as a key ground for justifying the ULEZ expansion across the capital.
The letter from the council leaders in response, dated today (8 Feb), reads in full:
Dear Mayor of London,
Your letter of 5th February makes assertions that we refute about air quality in outer London and that the expansion of ULEZ is necessary to protect the lives of Londoners.
We share your commitment to improve air quality but our outer London boroughs enjoy good air quality with NOx and PM2.5 levels considerably below the levels in inner and central London.
Your repeated reference to Imperial College London research gives the impression that it forms the primary justification for the expansion of ULEZ to our boroughs. In our opinion the modelling of the effect of air quality on health is not sufficiently robust to substantiate your claims about excess deaths in our boroughs.
In their research paper ’Has the ultra low emission zone in London improved air quality’ Imperial College London concluded “ULEZ on its own was not effective in the sense that the marginal effects caused by the ULEZ on improving air quality were small, either at particular locations or averaging across London”.
The conclusion was shared by your own Integrated Impact Assessment that states “The Proposed Scheme is estimated to have a minor (NO2) to negligible (PM2.5) beneficial impact on exposure to air pollution and achieving WHO Interim Targets across Greater London”.
It also concluded “The Proposed Scheme is estimated to have a negligible beneficial impact on carbon emissions in Greater London.”
With such little benefit to be gained from the expansion of ULEZ, very careful consideration must be given to the adverse impacts it will have on residents and businesses, and we believe that you have failed to give sufficient weight to this.
Your expectation that residents in outer London boroughs without ULEZ compliant cars should use public transport as an alternative is disingenuous.
Your own London Plan acknowledges that car use is necessary in areas with low Public Transport Assessment Level (PTAL) and your own map shows that this applies to the majority of our boroughs.
With public transport not being a realistic alternative, many elderly and low-income residents and small businesses, are likely to lose their mobility and livelihood. Your
Integrated Impact assessment identified many adverse impacts including:
- adverse impact on health (through stress, anxiety and isolation) that will be caused to people on low incomes, and older and disabled people
- poorer health outcomes for people who receive domiciliary care, mobile healthcare services, and/or informal care in outer London – particularly disabled people, older people, pregnant and maternal women, and people with underlying health conditions
- disproportionate financial impact for people on low incomes who travel by non-compliant private vehicle in outer London to access employment (particularly in night time economy)
- differential impact on young people and/or their carers and families on low incomes due to implications of increased cost of providing dedicated SEN travel to schools in outer London.
- increased cost for some older people, disabled people, people with underlying health conditions and people on low incomes who travel by non-compliant private vehicles to access regular medical appointments at specialist facilities in outer London (and outer London residents accessing healthcare outside London), which may result in adverse health outcomes for these groups.
- contraction of the local labour market due to fewer commuters entering Greater London
- loss of retail spend by those living outside Greater London
Increased cost of operating LGVs for a significant proportion of tradespeople, street markets, delivery companies and similar.
Although you claim that the extension of ULEZ is not a ‘money making’ venture, the evidence is to the contrary. Why else would you extend ULEZ when its social and economic cost is so clear and its benefits so small?
And even if your assertion is right, the question will surely be asked, who would sensibly place upon low-income households the total cost of the negligible improvement in air quality that your scheme might deliver? We believe that the £270million that it will cost to expand the scheme can be better spent to improve air quality that will not add to the financial burden on Londoners during the cost of living crisis.
We shall continue to defend the interests of residents and businesses and your letter has not weakened our resolve. We remain willing to work with you to help improve even further the air quality in outer London but the expansion of ULEZ is not the solution and you should pause its implementation if you are genuine in wishing us to work together.