CorrespondenceEnvironmentInfo

LTC – ULEZ

The Mayor of London, Sadiq Khan has announced that the Ultra Low Emission Zone (ULEZ) is to be expanded London-wide from the 29th August 2023.

There have been mixed feelings about the ULEZ expansion, but obviously as a group we have very serious concerns about air quality and emissions.

What would happen in regard to the ULEZ, if the proposed Lower Thames Crossing goes ahead?

Well the maps of the ULEZ expansion clearly show that both the existing M25 and the proposed Lower Thames Crossing, if it goes ahead, would be exempt from the ULEZ.  Not only do the maps show this fact, but it is also apparent that his would be the case because the M25 and LTC are both National Highways roads and part of the Strategic Road Network, which the Mayor of London and Transport for London (TfL) have no control over.

North Ockendon is outside of the M25, but is also part of the London Borough of Havering.  North Ockendon would fall within the ULEZ expansion area.

If the proposed LTC goes ahead it would run right alongside North Ockendon too.

This means that residents living in places like North Ockendon would be subject to the ULEZ charges, even if it were to just do their weekly grocery shop at the nearest shops.  Yet the traffic constantly driving by their homes all day and night on the M25 and LTC would be polluting the area, but exempt from the ULEZ charge.

History also shows that when the congestion zone in London was bought in, it simply pushed a larger amount of traffic to the perimeter of the charging zone.  If similar happens with the ULEZ expansion then we could see an increase in traffic on roads outside of the charging zone. too.

Areas like Thurrock and Dartford , who are already suffering from illegal levels of air pollution and heavy traffic would also be in a position of being on the border, potentially being charged for some of the regular routes they might take in day to day life, yet still suffering with the illegally high levels of air pollution themselves.

In October 2019 the Mayor of London, Sadiq Khan committed London to reduce fine particulate matter (PM2.5) pollution in line with World Health Organisation (WHO) guidelines by 2030.  We wrote to him about the proposed LTC at the time, and the response we got from the Deputy Mayor for Transport advised that Transport for London had asked NH to set out why they deem assessment of PM2.5 unnecessary, based on the impacts of the LTC scheme.

As now know Government will be enshrining new laws on air pollution levels, including for PM2.5, and the whole proposed LTC route would fail against those levels.

In light of this latest news about ULEZ expansion we have taken the time to write to the Mayor of London again, to bring to his attention the issue of the M25 and LTC running through ULEZ but being exempt because they are NH roads, not TfL roads.  We also asked if NH had ever responded to TfL’s question regarding the lack of PM2.5 assessment for the LTC.

 

Our letter
TCAG to Mayor of London Nov 2022

You can scroll through using the arrows

If you are having any issues with viewing our response above it can also be downloaded as a pdf file here.

 

Response on behalf of the Mayor (Feb 2023)

We have now received a response on behalf of the Mayor:

Thank you for writing to the Mayor again with your concerns about the Lower Thames Crossing (LTC) scheme being promoted by National Highways (NH). He has asked me to reply on his behalf, apologies for the delay in providing a response.

As you note, the Mayor has been dedicated to improving air quality for Londoners and that is why he has committed to expansion of the ULEZ to all of Greater London, including North Ockendon, helping ensure the local community can share in the significant reductions in air pollution the scheme is forecast to deliver.

The LTC is possibly the largest highway scheme in the southeast since the construction of the M25, so it is right and proper that TfL has been fully engaged with the planning process, including submitting responses to all its consultations to date.

As you will be aware, NH has now submitted its application for a Development Consent Order (DCO), which has been accepted by the Planning Inspectorate. TfL is currently in the process of scrutinising the material submitted, including to understand whether issues previously raised have been fully addressed. We have been clear that we cannot support the scheme unless it demonstrates that any adverse environmental and transport impacts are mitigated – including with regard to air quality. We are prepared to make representations to that effect during the examination of the DCO if such concerns have not been adequately addressed.

Thank you again for writing to the Mayor and your ongoing concern for the health and well‑being of your local community.

We have now sent a further response, since the ULEZ expansion consultation documents stated there would be very little, if any reduction of air pollution in Havering.

We focus on Havering due to the fact the M25 and LTC (if it goes ahead) pass through Havering, but traffic using such NH roads would be exempt from ULEZ charges.  We recognise that people in other surrounding areas also have concerns about the ULEZ expansion.

We also wish to make it perfectly clear that we support moves to improve air quality for all.  However, we cannot see how the ULEX expansion will reduce air pollution in areas like Havering, hence us asking for further clarification.

We do however, appreciate TfL’s position of opposition to the proposed LTC, and have stated as such in our response!

 

Related

TCAG response to ULEZ consultation (July 2022) – click here

The Havering Daily – Havering’s message to London Mayor-NO to ULEZ as every councillor votes against it click here

TCAG letter to Mayor of London (Oct 2020) – click here

Check if you would be charged to use your vehicle in ULEZclick here