Justification for Changing the Diesel Surcharge

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1 APPENDIX C Justification for Changing the Diesel Surcharge 1. Introduction 1.1. Concentrations of nitrogen dioxide (NO 2 ) in the Royal Borough exceed national health-based targets and we declared the whole borough an Air Quality Management Area in Diesel vehicles, especially older ones, also release high levels of fine particulates which can exacerbate breathing problems such as asthma. Collectively, these vehicle exhaust emissions harm people s health and the local environment In 2008 we introduced a 5 surcharge on the annual cost of a residents parking permit for diesel vehicles. In 2007, diesels accounted for 15 per cent of the total number of residents permits. They now account for around 12,400 (35 per cent) of the 35,300 resident permits currently on issue. Around 7,800 diesel vehicles (22 per cent) currently attract the surcharge and 4,600 (13 per cent) do not as they meet the Euro 5 standard. All of the 7,800 vehicles that attract the surcharge are at least four years old. 2. Background 2.1. In 2008 we introduced a graduated pricing structure for residents parking permits, based on the polluter pays principle that vehicles with high carbon dioxide (CO 2 ) emissions should attract a higher permit fee than those with low emissions In the past, diesel engines were perceived to be more environmentally friendly than petrol engines. Being more fuel-efficient than their petrol equivalents they tend to produce less CO 2 per mile. The UK s diesel car fleet has grown sharply in recent years, encouraged by vehicle excise duty rates that encourage consumers to purchase vehicles with lower carbon dioxide emissions. This pattern is reflected in the Royal Borough However, diesels, in particular older models, emit much higher levels of Nitrogen Oxides (NO x ), which forms NO 2, and particulate matter than petrol engines contributing to poor local air quality. In order to avoid the CO 2 banding in the graduated permit charge giving a perverse incentive to use diesels, we also introduced a permit surcharge for diesel vehicles in In 2011 we exempted diesel cars that met the Euro 5 emission standard from the surcharge. All diesel vehicles first registered after September 2010 meet the Euro 5 emission standard The 2008 Key Decision justified the diesel surcharge on the grounds of: raising residents awareness that diesel cars create more particulates and NO x than petrol cars dramatically so for particulates with the associated negative impact on local air quality sending a signal to residents to encourage them to consider purchasing a less polluting petrol or alternatively fuelled vehicle when they next change cars; and,

2 reflecting the polluter pays principle The only other London borough that currently applies a diesel surcharge for resident s parking permits is Camden, at Islington Council is currently considering applying a diesel surcharge of Local authorities are statutorily obliged to implement measures to improve local air quality. In 2000 we declared the whole borough an Air Quality Management Area. One of the four main aims of our current Air Quality Action Plan 2009 to 2014, which we are currently reviewing, is to reduce emissions from road transport - this includes encouraging alternatives to the car, reducing emissions from vehicles on the road and encouraging the uptake of alternative low emission vehicles The Mayor of London s Transport Strategy (MTS) (May 2010) states that The Mayor, through TfL, and working with the London boroughs and others, will take further action to reduce private vehicle emissions, by: Supporting the uptake of low emission vehicles, such as electric cars and vans Incentivising the take up of low emission vehicles through pressing for changes to vehicle excise duty and parking regulations 2.8. The MTS identified parking controls as one of the key measures that can be implemented at a local level to encourage the purchase and use of road vehicles with low CO 2 and air pollutant emissions. The Mayor therefore wishes to develop and promote the concept that parking charges vary not only by location and duration of stay, but also by the environmental impact of the vehicle Most recently, the Mayor of London s Transport Emissions Roadmap September 2014 (TERM) sets out how the Mayor intends to reduce emissions from groundbased transport in London significantly, including proposals for an Ultra Low Emission Zone. The TERM also encourages the use of parking controls to improve air quality In February 2014 the European Commission launched formal legal proceedings against the UK Government for not meeting pollution limits by According to the latest Government estimates London will not be compliant until after This could lead to fines of up to 300 million annually. The Government is responsible for complying with EU pollution targets, although local authorities are legally required to work towards achieving national targets. Under the Localism Act, the Government is likely to require responsible London authorities to pay all or part of the fine. 3. Pollutants, Health Impacts and Sources 3.1. The effects of the two pollutants of greatest concern in the Royal Borough, NO 2 and particulates, are described below Nitrogen Dioxide (NO 2 )

3 Oxides of nitrogen react in the atmosphere to form nitrogen dioxide (NO 2 ) which can have adverse effects on health, particularly among people with respiratory illness. High levels of exposure have been linked with increased hospital admissions due to respiratory problems, while long term exposure may affect lung function and increase the response to allergens in sensitive people. It can also increase asthma symptoms. Recent research suggests that children are most adversely affected, with high NO 2 concentrations restricting lung growth Particulate matter (PM 10 and PM 2.5 ) These are fine particles that can be inhaled deep into the respiratory system and have an adverse effect on human health, particularly among those with existing respiratory disorders. Particulate matter is associated with increased hospital admissions due to respiratory and cardiovascular problems, bringing forward the deaths of those suffering from respiratory illnesses and a reduction in life expectancy. Road transport gives rise to particles from engine emissions, tyre and brake wear and other non-exhaust emissions PM 10 is particulate matter smaller than 10 micrometres, widely recognised as the size threshold below which particulates can be drawn into the lungs. PM 2.5 is that smaller than 2.5 micrometres and is considered an even greater risk to health as it can get deeper into the lungs and bloodstream A report published earlier this year by Public Health England (PHE) estimated the number of deaths in UK local authorities that may be attributed to long term exposure to particulate air pollution. A number of newspapers reported the figures highlighting that people living in central London are three times more likely to die early due to air pollution than those in greener areas of the UK Premature deaths are most commonly defined as those occurring, from any cause, before the age of 75 years. Deaths attributable to air pollution, are rarely, if ever, recorded on death certificates but occur through causing or worsening a variety of conditions, such as heart disease, stroke and respiratory disease. The report estimates that 8.3 per cent of deaths (equivalent of 68) in the Royal Borough in 2010 are attributable to particulate air pollution this figure is the highest in London (a position shared Westminster) as shown in the table below; Area Attributable Fraction (PHOF* Indicator) Number of attributable Deaths Associated years of life lost England 5.6% 25, ,749 London 7.2% ,404 WCC 8.3% RBKC 8.3% LBHF 7.9% *Public Health Outcomes Framework 3.7. Sources

4 TfL s estimates of the source apportionment of NO 2 and PM 10 from road based transport in central London is summarised in the charts below; NO 2 <1% 5% 5% Taxi TfL Bus 16% <1% 34% Diesel Car Petrol Car Van Motorcycle 29% 11% HGV Non-TfL Bus and Coach PM 10 4% 6% Taxi 19% TfL Bus 11% 3% 13% 14% Diesel Car Petrol Car Van Motorcycle HGV 9% 21% Non-TfL Bus and Coach PHV 3.8. It is clear from the above charts that diesel cars emit far more of these two main pollutants, and NO 2, in particular, than petrol ones TfL s analysis of NO x emissions data on a section of Cromwell Road estimates that diesel cars are responsible for 22 per cent of km travelled but 19 per cent of NO x emissions, whilst petrol cars account for 41 per cent of km travelled but only 10 per

5 cent of NO x emissions. 4. Emission Standards 4.1. Across Europe, maximum exhaust pipe emissions for both diesel and petrol engined passenger cars are governed by EU Emissions Standards. The table below summarises the standards and demonstrates the difference in levels of NO x and PM produced by petrol and diesel powered vehicles. Euro Standard Implementation date NOx (g/km) PM (g/km) Diesel Euro 1 July Euro 2 January Euro 3 January Euro 4 January Euro 5 September Euro 6 September Petrol Euro 1 July Euro 2 January Euro 3 January Euro 4 January Euro 5 September * Euro 6 September * * Applies only to vehicles with direct injection engines 4.2. The Euro 3, 4 and 5 NO x emissions standards for petrol are three or more times more stringent than for diesel. The PM 10 emission limit for petrol cars only applies to a small number of vehicles (that employ diesel type technology) as normally PM 10 emissions would be expected to be low. The PM 10 Euro 5 diesel standard is nearly as low as for these petrol cars, hence the exemption from the diesel surcharge However, cars rarely meet these emission standards under real world driving conditions. Testing of vehicles under real life driving conditions in London by carried out by King s College on behalf of the City of London and funded by the Department for Environment, Food and Rural Affairs confirms that modern petrol vehicles are very low emitters of NO x and NO This research also reveals that on NO x, diesel cars are not performing as well as their Euro Standard suggests. It argues that there is little real world difference in the NO x emissions between Euro 4 and Euro 5 diesels. For example Euro 4 diesels should emit around 5 grams of NO x per kilogram of fuel used and Euro 5 diesels around 4 grams. In practice both standards were found to be emitting between 15 and 17

6 grams Besides more stringent emissions standards, the main difference for Euro 6 is the revised test procedures which mean that the engine must be compliant over a broader range of speed and load conditions. This should ensure that the expected emissions standards of vehicles are realised in real world driving. Testing of a limited sample of Euro 6 diesel cars currently available shows an encouraging reduction in real world NO x emissions compared to previous standards Euro 6 passenger cars will be available from 2015 and all newly registered diesel cars need to be Euro 6 compliant by September This research confirms that older diesel cars perform worse in terms of exhaust pipe pollutants than older petrol cars, but suggests that the performance of the next generation of diesel cars should be nearer that of newer petrol cars. 5. Other proposals to encourage a shift away from diesels 5.1. In response to the recent legal proceedings for not meeting EU pollution limits the Mayor of London recently announced the Transport Emissions Roadmap. This included the creation of a central London Ultra Low Emission Zone (ULEZ) by He has also called on central government to alter Vehicle Excise Duty, capital allowance deductions and company car tax to take greater account of the vehicle s contribution to air pollution The ULEZ is still subject to full consultation, but it is likely to cover the existing Congestion Charge Zone area. The ULEZ proposals will require diesel cars to be Euro 6 standard (i.e. no more than 5 years old in 2020) or at least Euro 4 petrol (i.e. no more than 14 years old) to avoid being subject to a 'ULEZ' charge in addition to the Congestion Charge (currently per day) Another emerging proposal is to introduce a national scrappage scheme similar to that operated in 2009 primarily intended to boost new car sales but which also had the effect of removing older, less efficient vehicles from the national fleet to be replaced by greener cars. Earlier this month the Mayor of London announced support for such a scheme stating a national scrappage scheme for diesel and other polluting vehicles is now needed as a priority in order to compensate people who have bought polluting diesel vehicles in good faith, as well as to drive forward air quality improvements. 6. Issues 6.1. As noted in paragraph 1.2, we introduced the diesel surcharge to mitigate the risk that the CO 2 bands in the graduated permit scheme could encourage residents to switch to diesels. We increased the surcharge to 15 in 2011 to match the differential between band tariffs. We do not know the level at which we would need to set the surcharge to provide sufficient incentive to switch to non-diesel. This will vary by individual. For some, it may be more than the current highest permit charge.

7 Arguably, in order to raise awareness, the surcharge need not be more than a nominal amount. However, it is clear that a modest surcharge, as at present, does not send a strong enough signal that the Council is very concerned about the longterm effects of diesel vehicles on air quality and public health The surcharge is currently 18, less than 12 per cent of the price of the most popular (Band 6) annual permit ( 155). By contrast, the current second or subsequent permit surcharge ( 65), which we introduced to discourage multiple car ownership and reduce stress on our limited on-street parking stock, is 42 per cent. There is clearly a disparity between the surcharge to discourage the purchase of diesels on air quality grounds, and the surcharge to discourage multiple car ownership to reduce parking stress.

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