A measured welcome for the launch of London’s ULEZ with a call for more progress, more quickly.
By Massimo Fedeli and Nick Molden, Co-Founders of AIR
2 April 2019: It is both shocking and outrageous that in 2019 we are still breathing poor quality air in towns and cities which is linked to the equivalent of over 40,000 deaths per year in the UK alone. This is despite clear evidence of the problem, its causes and several European directives to fix it. ClientEarth, the environmental law charity has spent more than ten years pursuing national and local governments through the courts, forcing them to confront their responsibilities and raising awareness of the slow pace of change. During this ‘lost decade’ of air pollution, urban NOx emissions have continued to cause health problems for us all in our daily lives.
Vehicle related emissions are a significant contributor to the problem and whilst Europe’s 2050 climate-neutral strategy offers a clear pathway to address the key issue, we can’t wait to fix today’s poor urban air quality. The rate of adoption of zero emission vehicles, even at the most optimistic predictions, will not happen quickly enough to help us, our friends and families, colleagues and citizens who need immediate respite from urban air pollution.
Quite bluntly, it is beyond credibility for both authorities and industry to shield themselves from criticism of inaction behind future technological solutions which are years away from adoption at scale, in the full knowledge that millions will suffer poor health and reduced lifespan in the intervening period. To make rapid progress, we need to make best use of the cleanest internal combustion engine technology available today and deliver a real improvement in air quality immediately. There can be no excuse for failing to use the most effective ways available to us now, to improve urban air quality for everyone.
The launch of the Ultra Low Emission Zone in London on 8 April 2019 is a significant step to reduce urban emissions by controlling access to vehicles based on their emissions. For cars, this means penalty-free access only for petrol engines with a minimum Euro 4 standard rating, and diesel engines with at least a Euro 6 standard rating. At first glance this may appear to be a bold solution by a city which has been amongst the most active and progressive to address the problem of urban NOx emissions caused by the failure of regional and national regulation. But, it arrives almost 10 years late as we have highlighted already, and in reality it could be so much better, and do so much more to help Londoners breathe more easily.
So, what are the pros and cons of the ULEZ?
The fundamental issue for any urban access control policy is the need for a robust framework to base it upon. ULEZ uses the Euro standards as a proxy for urban emissions of the vehicles in the zone, and this is the start of the problem.
The Euro standards are the officially accepted levels of emissions recorded during tests conducted mainly by car makers themselves, on their own products and until recently in laboratory conditions. We now know that emissions recorded during on-road driving in urban conditions including stop-start in traffic, bear little resemblance to the emissions recorded during laboratory tests where vehicles can be optimised to achieve specific results.
Tests conducted using Portable Emissions Measuring Systems (PEMS) equipment by Emissions Analytics since 2011 have shown variances up to 21 times the homologated limit for some vehicles. The issue achieved global attention when Dan Carder, Director of the Center for Alternative Fuels, Engines and Emissions at the West Virginia University led the team which published the earliest evidence that Volkswagen was cheating on US emissions tests uncovering the scandal which became known as Dieselgate.
The fallout from Diesegate highlighted that while all diesel cars sold in the EU did meet the in-laboratory tests, they were emitting massive amounts of NOx when driven on our roads. This led to a number of changes to tighten up the Euro 6 standard, but rather than issue a new Euro 7 standard at the time, the existing Euro 6 standard continued to be used but with suffixes and now (confusingly) straddles a wide spread of permitted emissions.
PEMS tests conducted for us show that a Euro 6 vehicle is legitimately producing over 6 times the officially published NOx limit, with free access to ULEZ, and in many cases producing more urban NOx than an earlier, cleaner Euro 5 vehicle. The results of variations between Euro 6 vehicles, one emitting 20 times more than another, were presented at the launch of the AIR Index in February 2019.
Whilst the latest Euro standard – in this case 6d which includes on-road testing – does set low levels of urban NOx emissions, millions of cars with a pre-Euro 6d standard have been sold across Europe and have potentially unlimited ULEZ access since they fall within the wide Euro 6 range.
The fundamental issue we have with ULEZ access being based upon Euro standards alone, is that is not an efficient or fair way to address the problem of urban NOx emissions from vehicles, since over-emitting newer Euro 6 cars will be allowed in, yet older lower-emitting Euro 5 cars will attract penalty fines. We believe that ULEZ should be based on a better source of data. Without a better source, the positive benefits will be seen more slowly, and the number of car-owners affected will be greater than necessary.
ULEZ + actual emissions is the pragmatic solution
In 2017 we created the Allow Independent Road-testing (AIR) alliance to reduce the harmful effects of vehicle emissions on air quality. The scientists, regulatory experts and organisations within AIR are committed to addressing pollutant emissions from vehicles, and we have created the AIR Index, an independent, trusted, on-road vehicle emissions ratings for cars.
The AIR Index rating categorises vehicles in bands, based upon NOx emissions data measured during on-road tests. Testing each vehicle in urban conditions to the same test provides comparable NOx emissions levels that more accurately reflect the contribution to urban air quality than existing tests performed in a laboratory.
AIR ensures that the AIR Index is only obtained from tests that follow the latest European Workshop Agreement CWA 17379. This was developed in public, by scientists and stakeholders. The methodology ensures that the test procedure is consistently applied to different vehicles so that the data collected from different tests provides comparable emissions data.
The AIR Index is a global first. It is an international, independent and standardised rating system that reveals accurately how much pollution a vehicle produces when it is used in towns and cities.
It has been created to inform and empower car buyers and city policy makers with the real facts about vehicle emissions when making choices about car purchase and usage. A simple A-E colour-coded rating, shows the difference between clean and dirty vehicles based on how much NOx comes out of a car’s tailpipe in urban driving.
We recognise that ULEZ in London has been created in good faith using Euro standards, but it could be (and should be) more effective if used in conjunction with the ratings provided through the AIR Index. This would enable access to only the cleanest vehicles and limit the over-emitting vehicles from adding further to poor urban air quality. Specifically, a B-rated Euro 5 diesel should be let in, but an E-rated Euro 6 should not be.
At the launch of London’s ULEZ we are calling on policy makers across Europe to look at the most effective way to use actual vehicle emissions, not just laboratory standards, as the basis for policies which will bring cleaner air, more quickly to everyone.
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The AIR alliance focuses on four key areas of activity:
Insight: Deepening research and understanding about vehicle emissions, testing and applications to reducing harmful impacts.
Coalition: Encouraging collaboration among industry players, public authorities and relevant stakeholders on key activities to improve air quality.
Campaigning: Supporting the development and improvement of mobility infrastructure to have a positive impact on air quality.
Empowerment: Promoting the link between vehicle choices and air quality with actionable information.
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