We refer to your consultation on ULEZ expansion and related matters. The Council’s response is set out below in free text format rather than using the survey form provided. The Council considers that the survey questions are heavily loaded towards eliciting support for the scheme rather than enabling a proper examination of the merits of the proposals. The Mayor has made assurances that this is a genuine consultation seeking views on the expansion of the ULEZ but the survey does not ask if the respondent supports the scheme or would prefer alternative approaches. There is also no effort to try and understand the social and economic implications of the scheme. It is hard to see how the questions do anything other than generate broad support for the Mayor’s approach irrespective of how people actually feel about it. To provide clarity regarding the Council’s position we have structured our response accordingly.

In summary, the Council considers that the expansion of ULEZ into outer London is inappropriate given the character of the area, the poor public transport connectivity, the nature of travel behaviour and resulting interdependencies. By blindly duplicating the approach in central and inner London without properly assessing the implications for outer London or neighbouring areas beyond Greater London the proposals risk causing a series of negative social and economic impacts that are likely to outweigh the benefits.

Such an approach is particularly inappropriate as it did not figure in the Mayor’s recent manifesto and would therefore appear to lack a specific mandate. By contrast ULEZ expansion was a key issue in Bexley’s recent elections with broad support for the local administration’s opposition to the proposals. The issue continues to generate significant interest in the local area with over 10,000 hits on the Council’s web page and significant comment on social media.

The remainder of this response sets out the Council’s concerns in more detail.

Bexley has a high level of car ownership due to the lack of modern public transport links serving the borough

Bexley is one of only two boroughs in London which is solely reliant on heavy rail and bus services for its public transport, having no tram, DLR, underground or river services. This enforced dependency on a limited range of often unreliable services has major implications for transport choices.

The borough also has a low density, dispersed character which makes effective servicing by limited public transport options difficult and daily multipurpose trips by car a necessity for working families and older residents. As a result, borough residents and businesses are very car reliant with one of the highest car ownership rates and the lowest sustainable mode share rates in London. This trend is set to continue with car and van registrations over the last decade outstripping population growth, despite much vaunted investment in active modes and bus services and advances in smart travel and shared mobility technologies1.

1 PP30-31

There were over 114,000 registered cars and vans in Bexley in 20212. ULEZ compliance levels vary across the borough, ranging between 57% and 97%3 but assuming an average of c75% there are potentially over 28,000 non-compliant vehicles in Bexley.

As a result, the borough is likely to see a significant impact from the proposals with many negative consequences.

Key workers in industries such as health and the care sector who rely on their cars to visit patients will be unfairly penalised

Key workers are the lifeblood of the city, providing essential services to all Londoners, particularly the most vulnerable. Nearly a third of all working Londoners are key workers4 but many more also travel in from outside the capital where house prices can be considerably lower e.g., median house prices in the Medway Towns are over 30% cheaper than those in Bexley5.

A recent study by the London Chamber of Commerce suggests that more than half of all ‘blue light’ key workers live outside the city6 underlining the affordability issues experienced by staff. The cost of living in London leads inevitably to issues of recruitment and retention which a ULEZ charge will only make worse, particularly for those working shifts who might start and finish either side of midnight and incur a double ULEZ payment every time they go to work.

Issues of affordability are nowhere more acute than in the health and care sectors. In 2021 there were some 8,500 nursing vacancies in the NHS in London and thousands more in social care7. Bexley has one of the highest proportions of residents over 65 in London and over 3,600 units of specialist older persons’ housing, a third of which are residential care homes8. Recent engagement with care providers in Bexley has highlighted that the patterns of care offered and the nature and location of facilities means that staff are highly reliant on car based travel to deliver the service effectively. This is because in many parts of the borough the lower population density means the distribution of the residences to be visited makes it impossible to efficiently make use of public transport.

Some 90% of care workers nationally use their own cars with many receiving only modest transport allowances The sector is seeing a high level of resignations with vacancy rates running at an all-time high of 13.5% nationally linked to low pay and the increasing cost of travel9. The ULEZ proposals offer no exemptions or discounts for such workers and will be an added burden, likely to exacerbate retention issues and having disproportionate knock-on effects on the old and the sick.

3 Maps 7 and 8 pp104/105 ULEZ IIA Baseline Report

It will put an extra burden on small businesses

Increasing business costs are having a significant impact on SMEs, with over three quarters of those recently surveyed confirming that they are worried about factors such as soaring energy bills and rising inflation10.  

The ULEZ will unquestionably place an added burden on SMEs, particularly the 50,700 estimated outer London businesses in those industries that are heavily reliant on car and light goods vehicle (LGV) trips into and out of London. Bexley has one of the highest concentrations of car and van reliant businesses in London resulting in 68% of all business journeys between Bexley and Outer London being undertaken by car and 84% of all such trips between Bexley and Greenwich. Business trips from outside London are just as reliant with some 74% of business journeys between Kent and Bexley using the car and LGV flows between Kent and Bexley being among the highest in London, at 23,800 trips11.

Compliance figures for LGVs are forecast to be much lower than other modes following the introduction of ULEZ. An assumed compliance rate of 82%12 would see around 1,800 non-compliant vans in Bexley alone needing to pay the charge although this could be much higher if projected rates are not reached. It would also mean thousands of LGVs having to be replaced to ensure compliance at significant cost to small businesses and sole traders.

ULEZ expansion will also impact on those businesses reliant on car borne custom such as town centre retail and leisure uses. Customer surveys within Bexley’s major town centres show that between 60% and 77% of visitors use the car as the main mode of transport to access shops13. Making it more expensive to reach local centres will imperil both their recovery following Covid and their transition in response to changing shopping habits.

The ULEZ charge will deter people from outside the capital who wish to drive into London to work, to shop, to see family, friends or visitor attractions

Approximately 1.3 million vehicles travel into London each week, with 1 million of these travelling to outer London destinations14. They bring in significant spend and essential labour for London businesses as well as enabling important social interaction. 

This is particularly true for Bexley were there are strong functional links with Kent. In fact, Kent to Bexley trips account for the largest proportion of shopping trips into outer London from outside Greater London15. Bexleyheath is Dartford residents’ second choice shopping destination whilst Crayford attracts a 10% market share of Dartford convenience and comparison retail spend. Bexley destinations are also seeing a significant market share of leisure spend from Dartford residents16.

11 Tables 4-10 and 4-11 ULEZ IIA Baseline Report
12 Table 4-1 ULEZ IIA Report
15 Table 4-4 ULEZ IIA Report

Competing destinations for this custom such as Bluewater, Lakeside, Gravesend and the Medway towns will not be affected by a ULEZ charge and will gain a significant commercial advantage resulting in spend being diverted. In fact, it is estimated that some 60% of retail trips undertaken by non-compliant cars into outer London from outside Greater London will be lost to centres outside London and to online shopping as a direct result of ULEZ expansion17.  

The charge could also have a social effect as the severance caused by the increased cost of travelling into London leads to isolation and reduced access to opportunities particularly for vulnerable groups such as the elderly and disabled. This impact will be particularly acute on communities which straddle the boundary of the zone as a continuous urban area, such as that between Bexley and Dartford18.

The ULEZ charge is a regressive tax, disadvantaging lower-income families who cannot afford to pay the charge or buy ULEZ-compliant vehicles

Although access to a car generally declines with income, a significant proportion of low-income households still own cars in London. For example, in 2019 a third of households in London with an income between £10,000 and £14,999 had access to a car, rising to nearly half of all households with an income between £20,000 and £24,99919. These proportions will increase for outer London where public transport options are more limited.

Reliance on the car to access work will also be high for those on lower pay as they will tend to be employed in sectors where working from home is less likely to be an option such as retail, transportation, warehousing and distribution, security and cleaning services.

Moreover, there is a clear correlation between areas of deprivation and low ULEZ compliance. For example, nearly all postcode areas in Bexley within the most deprived quintile are in areas with compliance levels of between 65 and 70 percent.

The poorest households will therefore be faced with the dilemma of relying on poor or non-existent public transport to get around, finding over £4,000 a year to pay the ULEZ charge or finding the money to buy a compliant vehicle. With the average price of an electric car in the UK standing at around £44,000, the cheapest models still over £17,000 and only a nascent second-hand market this latter option is unlikely to be open to the lower paid. Even the cost of reliable second-hand ULEZ compliant petrol and diesel vehicles can be significant, often running into several thousand pounds. 

Although a scrappage scheme would help with these costs, there are currently no details of what this might entail for the proposed extension. The previous scheme offered £2000 for a car which is unlikely to be sufficient to buy a reliable compliant vehicle. The scheme was also only open to those on benefit who had owned their cars for more than 12 months and could affect some individuals' access to means-tested benefits.

It also puts further pressure on household finances, when energy, food and other prices are rising

The cost of living crisis, resulting from inflation outstripping wage and benefit increases, is leading to a pronounced fall in real disposable income so acute that it has led to government interventions to relieve squeezed household budgets.

17 P121 ULEZ IIA Report
18 PP82 and 83 ULEZ IIA Report
20 Section 3.4.6 and Maps 7 and 8 pp104/105 ULEZ IIA Baseline Report

Inflation is set to continue to increase with the Bank of England forecasting a peak of 10.2% in the fourth quarter of 2022 and high inflation continuing for the next couple of years while wages are projected to rise at only half the rate. A key driver for this inflation is the cost of fuel which includes petrol and diesel for transport purposes, with prices the highest on record23.

Again, these changes hit poorer households more as energy costs take up a higher proportion of their household budgets and they have less flexibility as to how to use their available income.

Non-compliant vehicles are likely to be bought by people in areas outside the ULEZ, where they will continue to impact on air quality and climate change

Air quality issues do not respect administrative boundaries and are affected by weather conditions and prevailing winds. As such they are a national issue and should be part of a coordinated, consistent and equitable approach to air quality at a national level. The Council would, therefore, want to see greater coordination between TfL and adjoining authorities outside London to ensure Bexley residents are getting a fair deal. 

We believe that the costs of the ULEZ have not been properly considered and that other options have not been adequately assessed

There is no overall cost shown in the consultation documentation for the implementation of the scheme or any monetised social and economic impacts, with only the value of health impacts calculated. There is also no direct comparison of the negative costs against the benefits in a benefit cost ratio calculation and, therefore, little direct evidence of the value for money being generated.

This needs to be considered in the context of the current air quality situation in outer London. Bexley was one of 12 Boroughs, 11 of them in outer London, that recorded no population exceeding air quality thresholds for NO2 or PM10 in 201924. Additionally, only 8% of the total road length in outer London exceeded the annual mean NO2 limit value in the same year25. Bexley’s own monitoring also confirms that the borough has seen a steady improvement in air quality in recent years across all measures (Air Quality In Bexley Status Report August 2020) and will continue to strive for better air quality in transport and new development though policies in its LIP and Local Plan.

A range of groups are identified in the consultation documents26 as experiencing minor or moderate negative impacts as a result of the scheme including low-income households, small businesses and public sector workers providing essential services. Mitigations are set out but are broadly limited to temporary extensions of some exemptions, the unspecified promotion of public transport and active travel, yet to be concluded discussions with certain groups on potential measures and a new scrappage scheme, the details of which are yet to be decided. It is wholly unclear in the documentation whether these are in an any way adequate to address concerns.

24 Table 2-7 ULEZ IIA Baseline Report
25 Table 2-9 ULEZ IIA Baseline Report
26 ULEZ IIA Report

It is also unclear how TfL will pay for any mitigation given its financial position. The cost of implementing the expansion itself is not specified but we understand that up to £400m has been set aside. Although revenue will be collected and any surplus income ringfenced to deliver transport improvements, this fell significantly for the existing ULEZ zone between 2020 and 2021 from £90m to £38m27. Moreover, wider pressure to make savings within TfL may mean that no net additional spend can be directed to mitigation.            

Only two potential alternative approaches to ULEZ expansion were assessed by the Mayor and these are only touched on briefly in the consultation documentation28. A preliminary assessment of these is referenced but not provided for consideration. There is no detailed explanation of the reasons for the limited alternatives proposed and the reasons why the Mayor chose the current proposal.

The Council needs to understand clearly what consideration was given to non-charging alternatives such as public transport improvements in outer London, enhanced investment in electrification, expansion and greater enforcement of anti-idling measures or higher investment in urban greening measures and how these compared in effectiveness and value for money terms. 

For example, assuming a ULEZ expansion implementation cost of £400m this would be enough to pay for approximately 50,000 electric vehicle charging points (at £4000 per unit) and 80,000 street trees (at £2,500 per unit). In terms of the charging points, that compares to the 7000 points currently available within the M2529 and is enough to meet the projected requirement for such facilities in London to 2030 with a resulting decrease in carbon dioxide emissions of between1.5 and 2.6 million tonnes per year or between 40 and 84 percent of total carbon emissions by cars30 (TfL 2030 Electric Vehicle Infrastructure Strategy). 

In terms of new planting, 80,000 trees will remove a further 1,680 tonnes of carbon dioxide per year when fully grown and around 80,000 tonnes over their combined lifetime31. They are also effective in removing particulates from the air as well as reducing the effects of heating and creating important habitats. 

If the £400m was used to purchase electric vehicles, this would fund around 23,500 cars, enough to replace all non-compliant vehicles in Bexley. The money is, alternatively, enough to provide every home in Bexley with a brand-new boiler or provide 1000 new electric double-decker buses, more than doubling the current fleet. 

Other Matters: Future Road Charging

The Council believes that future road charging should be closely linked to the delivery of improved public transport provision in outer London and should not be implemented until significantly enhanced connectivity and reliability has been achieved.
Implementation should also be timed to ensure the technology has been sufficiently developed to enable an appropriately nuanced approach which reflects the diversity of London’s residents and businesses.

The safeguarding of individual’s privacy should be a primary objective of any scheme to maintain public confidence in the project and ensure any data is appropriately stored, managed and used.

28 Page 5 Our Proposals Document, section 2.4 ULEZ IIA Report
30 Page 13 TfL EV Infrastructure Strategy