To summarise the Forest Hill Society’s response, we would like to see a larger ULEZ, with strong penalties for non-compliance, and as soon as possible. Additionally, we have concerns about impacts on Forest Hill residents from potentially greater numbers of polluting vehicles using the South Circular as a result of your current proposal to exclude this road from the ULEZ. Finally, if the boundary is to be located just inside the South Circular, we think there should be additional consideration given to accessing by car some community facilities which are inside and close to the boundary of the ULEZ.
An additional concern the Society has with regard to the ULEZ is in relation to the siting of enforcement cameras. We expect that TfL will give careful consideration to camera locations to ensure that no camera-free routes inside the South Circular are unintentionally created. Such routes may give rise to rat-running and potentially illegal and dangerous driving, such as going the wrong way along one-way streets. It is important that any scheme will not result in these behaviours.
Below are the detailed responses provided to TfL in their consultation:
1. Do you support tougher vehicle emissions standards in the London-wide Low Emission Zone so that heavy vehicles must meet the Euro VI emissions standards London-wide?
2. Do you support the proposed implementation date of 26 October 2020 for the introduction of tougher standards for heavy vehicles driving in the London-wide Low Emission Zone?
Oppose (should be sooner)
3. Do you support the proposed daily charges to be paid by owners of heavy vehicles that do not meet the required emissions standards?
4. Do you support the principle of expanding the area where ULEZ emissions standards apply to light vehicles beyond central London?
Support an expansion but area should be larger
Additional comments: The North Circular sits almost 9km from the current congestion charging zone boundary, while the South Circular is less than 6km distant. The result of this is that there are large areas of south London with high annual mean NO2 concentrations not falling within the extended ULEZ. That south London will not receive the same benefits from the ULEZ as north London is considered inequitable.
Recognising the need for action to combat poor air quality, the Society would support a larger ULEZ, extending even to the full extent of Greater London.
5. We are proposing that the ULEZ emissions standards would apply to the inner London area, roughly up to but not including the North and South Circulars roads. Do you support this proposed boundary?
Additional comments: The Society has a number of concerns regarding the siting of the southern boundary of the extended ULEZ just inside the South Circular:
• The South Circular is the only Air Quality Management Area (AQMA) in the Forest Hill area. We are concerned that following the implementation of the extended ULEZ, this road may become more heavily trafficked, including a larger number of vehicles which do not meet the ULEZ standards. As a result, the levels of pollution suffered by people living close to the South Circular, an area currently failing to meet legal air quality limit values, may increase.
• In many ways the South Circular is just an arbitrary boundary in the middle of an urban area. Our community would be split with some living within the ULEZ and others outside. Some Forest Hill residents and businesses would therefore have to deal with the ULEZ charges or costs of upgrading their vehicles, while others would not. Rather than face this inequity, we would rather that all residents and businesses face the costs and benefits equally.
• Streets to the south of the South Circular may face increased parking pressure, as residents and businesses to the north may choose to park their vehicles outside the ULEZ rather than pay the associated charges or upgrade their vehicle. As well as increasing pressure on parking, the traffic associated with these additional polluting vehicles may impact the residents of those streets.
In addition, if the decision is made to extend the ULEZ up to but not including the South Circular, the Society would like to see a greater level of consideration given to exactly where the boundary would be located in relation to certain community facilities. For example, within Forest Hill we have a dialysis unit and a GP practice car park (Jenner Practice) within but close to the currently proposed boundary of the ULEZ. These are marked on your ULEZ map number 57. It is our view that facilities of this nature should, where reasonably practicable due to their proximity to the proposed boundary, remain outside the ULEZ
6. Do you support the proposed implementation date of 25 October 2021 for the expansion of ULEZ to include light vehicles in inner London?
Oppose (should be sooner)
7. Do you support the proposed ULEZ daily charge to be paid by non-compliant owners of light vehicles of £12.50?
Additional comments: Although the Society recognises the need for charges for non-compliant vehicles as part of the ULEZ, we have concerns about how equitable the proposals are. Those able to afford the charges or to upgrade their vehicle, or indeed who have been able to afford a more modern vehicle, will be little impacted, while the lives of less affluent people may be adversely impacted. The Society would prefer to see a system of road user charging adopted as soon as possible. This could be along the lines of the system promoted by the Association for Consultancy and Engineering, which appropriately takes account of the driver’s circumstances as well as the impact of the trip on the environment and congestion.
8. Do you support bringing forward the end of the sunset period for residents in the Central London Congestion Charging zone from 7 April 2022 to 24 October 2021 so that all residents of inner London, including the Congestion Charging zone, pay the daily charge for non compliant vehicles from 25 October 2021?
9. Do you support increasing the penalty charge (PCN) level for non-payment of the ULEZ daily charge by owners of non-compliant light vehicles from £130 to £160?