NO REDUCTION IN AGE LIMITS
Click here to read, Transport for London Ultra-Low Emission
Zone proposal: A response from the trade
Boris Johnson has announced his plans to tackle air quality in London through the creation of an Ultra Low Emission Zone (ULEZ). The ULEZ will operate within the congestion charge zone in Central London and vehicles not meeting the ULEZ standards will be fined. But once again taxis have been disproportionally hit by the proposals, whilst there is no parity in the proposals for private hire with those for taxis. TfL have just finished the consultation process and we are awaiting the outcome to be published in the summer. But it seems certain that TfL are once again going to try to force through a reduced age limit for taxis at a time of immense pressure for taxi drivers.
The main thrust of the ULEZ proposals for taxis is a reduction in the age limit from 15 years to 10 years from September 2020. There will be a requirement that all new taxis presented for licensing from the 1st January 2018 would need to be zero emission capable (ZEC). This would apply to taxis London-wide.
Private hire will retain a 10 year age limit (same as taxis even though taxis are purpose built), and all newly licensed vehicles would need to meet the ZEC requirements, but newly licensed vehicles over 18 months will just need to meet the ULEZ standards of Euro 6 for diesel and Euro 4 for petrol engines. This is clearly wrong and completely unfair on the taxi trade. There should be parity between the taxi and private hire trades over newly licensed vehicles.
A zero emission capable vehicle considered to:
• Utilise plug-in / battery electric technology or equivalent to achieve a maximum output of 50g/km CO2
• Achieve a minimum zero emission range of 30 miles to ensure capability of operating in the ULEZ for extended periods whilst in zero emission mode.
As the ULEZ consultation acknowledges there will be more ZEC vehicles available for private hire than for taxis. So far there are only three taxi manufacturers who could potentially produce ZEC vehicles; LTC, Karsan and Metrocab. The cost of these vehicles is likely to be far in excess of a LTC taxi today and will need to be heavily subsidised by grants from the Office of Low Emission Vehicles (OLEV), not only to pay for the increased cost of the vehicle but to compensate drivers for the loss of residual value on their taxi with the reduction of the age limit. So although there will be more ZEC vehicles available to private hire they will have far less stringent licensing conditions than taxis. This assumes, of course, that ZEC vehicles will be available to purchase in 2018.
Although Unite welcomes the ULEZ consultation and supports better air quality in London, after all taxi drivers are driving in the most polluted parts of London, we believe that taxi drivers are being hit harder than any other group. A 10-year age limit is unnecessary, as NOx emissions could be reduced by other methods, particularly by the availability of grants to increase the take up of new ZEC Vehicles. A 15-year age limit should be retained as a 10-year age limit will increase the financial strain on taxi drivers and lead to over 7,500 taxi being taken off the road in 2020. A minimum grant of £10,000 per driver will be needed to ensure the successful migration to ZEC vehicles along with a network of charging infrastructure to enable drivers to maximise the benefits of owning a ZEC vehicle. Parity between the Taxi and Private Hire trades is essential to ensure that all newly licensed vehicles after 2018 should meet the ZEC requirements.
Having a 10 year age limit would make it likely to be in excess of 12,000 vehicles (almost half of the taxi fleet) that would be upgraded to ZEC taxis from 2018 to 2021. Even this conservative estimate of the number of drivers that would need to purchase a ZEC taxi by 2021 there would need to be grants available of at least £120 million.
From 2018 to 2021 there are likely to be in excess of 12,000 vehicles (almost half of the taxi fleet) that would be upgraded to ZEC taxis. Even this conservative estimate of the number of drivers that would need to purchase a ZEC taxi by 2021 there would need to be grants available of at least £120 million. In addition we would expect drivers purchasing a ZEC taxi for the first time after 2021 to have grants available, as these drivers would have been affected by the 10-year age limit and have lost residual value. This would mean at least another £120 million up until 2028, at which point all taxis be compliant with the ULEZ conditions. This would indicate that over £240 million would be required in grants. This is never going to happen; no Mayor or government is going to guarantee that amount of money so far into the future.
On top of this millions of pounds will be needed for a charging infrastructure to be put in place. To make the most of the fuel savings a ZEC vehicle will bring, the battery will need to be fully charged when the driver starts work. But to cater for every driver a huge network of on-street and home charging infrastructure will be needed. When the cost of this is added to the grants that will be required the amounts become mind blowing. At the moment TfL have no strategy on how they will fund this.
Their plans are ill thought out and are just leading to uncertainty and worry for many drivers. At a time when LTC is picking up production and about to launch a new Euro 6 taxi, TfL are telling drivers that the new, low polluting taxi will only have a 10 year life. So LTC are expected to produce a new taxi that drivers are going to be nervous to buy whilst building a new factory and developing a very expensive vehicle. Nothing TfL does makes sense, but nothing new there.
We cannot accept any reduction in the 15 year age limit. There is no reason for such a reduction, except it is the easiest solution for TfL. There are lots of alternative methods they could use to reduce NOx emissions by 2020. If the Boris persists with anything less than 15 years then he can expect angry drivers, garages and proprietors to want to show him what they think of his decision. His decision will affect every taxi driver he needs to listen to the trade now, or Boris can expect the biggest show of unity the taxi trade has ever seen.
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