AIR QUALITY: REPLACING ULEZ
This chapter sets out the most technically demanding commitment in this manifesto: the abolition of the Ultra Low Emission Zone and its replacement with a programme that delivers better air quality outcomes without a daily flat charge on London’s drivers. Scrapping ULEZ is a commitment I intend to keep in full.
I have given this chapter more space than any other because it is where I will be attacked hardest, and rightly so. Anyone proposing to remove an air quality measure owes London a serious answer on what replaces it. What follows is that answer.
3.1 The two things that are both true
London’s air is dangerously polluted. Long-term exposure to nitrogen dioxide and fine particulate matter is associated with thousands of premature deaths in this city annually, with respiratory illness in children, with cardiovascular disease, and with the aggravation of asthma. No serious person disputes this and I do not dispute it.
The Ultra Low Emission Zone, as designed, is a regressive charge. It costs the same to a person earning twenty thousand pounds as to one earning two hundred thousand. It changes the behaviour only of the first. The second simply pays and carries on. It is, in truth, a stealth tax on working Londoners dressed as an environmental measure, and taxing people out of their livelihoods is indefensible.
Consider who actually pays this charge daily. The self-employed tradesman whose van is fifteen years old and whose replacement cost exceeds his annual profit. The care worker driving between eight clients across three boroughs at hours when no bus runs. The family with one ageing car and a disabled child who cannot use public transport. The small business running a fleet it cannot refinance. These are not people making a discretionary choice about their commute. For them the vehicle is the job.
A policy that charges them daily and indefinitely for a vehicle they cannot afford to replace is not an environmental policy. It is a revenue policy with an environmental justification attached. And its regressive character is not an administrative flaw that could be fixed with better design. It is structural. A flat daily charge is regressive by construction.
The argument I am not making
I want to separate my position from one it will deliberately be confused with. I am not arguing that London’s air is acceptable. I am not arguing that vehicle emissions are harmless. I am not arguing that nothing should be done.
I am arguing that the instrument chosen was the cheapest to administer rather than the most effective, that its burden falls on the Londoners least able to carry it, and that better instruments exist which this city has declined to fund because a charging zone generates revenue while the alternatives cost money.
3.2 What actually produces London’s air pollution
Effective policy requires knowing what produces the harm. London’s air pollution has four principal components, and a charging zone addresses part of one of them.
Exhaust emissions from road transport
Nitrogen dioxide and particulates from combustion engines. This is the component ULEZ targets, and it is the component falling fastest anyway through ordinary fleet turnover. Every year older vehicles leave the fleet through attrition. The counterfactual question rarely asked honestly is how much of the improvement attributed to the charge would have occurred regardless.
Non-exhaust emissions
Brake dust, tyre wear and road surface abrasion. This is a large and growing share of particulate pollution. It is entirely unaddressed by an emissions-standard charge, and it is worse from heavier vehicles. Electric vehicles, being heavier, produce more of it, not less. A policy that charges by engine standard while ignoring non-exhaust particulates is aimed at a shrinking portion of the problem.
Freight, construction and machinery
Heavy goods vehicles, construction plant and non-road mobile machinery contribute disproportionately relative to their numbers. Construction sites generate substantial local particulate concentrations and are governed by a mayoral regime that is materially under-enforced.
Buildings and domestic sources
Gas boilers, commercial heating and domestic wood burning. Wood burning in particular is a significant and rising particulate source in residential London, it is worst in exactly the affluent areas least affected by a vehicle charge, and no charging zone touches it.
The conclusion follows directly. A scheme charging private cars by emissions standard addresses one part of one of four sources, and the part declining fastest without intervention. A serious air quality strategy addresses all four.
3.3 The replacement: the London Clean Air Programme
What follows replaces ULEZ with seven measures. Together they address all four pollution sources rather than one, and they do not levy a daily flat charge on Londoners who cannot avoid driving.
They are more expensive to deliver than a charging zone. That is precisely why they have not been done. A charge earns money; clean air costs money. This manifesto chooses to spend it, and to fund it through discipline elsewhere rather than through a tax on drivers.
Measure one: a scrappage scheme that actually works
Previous scrappage schemes failed because grant levels sat below the real cost of replacement. Offering two thousand pounds towards a vehicle costing twelve thousand does not change behaviour. It subsidises people who were replacing anyway and leaves everybody else paying the charge indefinitely.
- A scrappage scheme with grant levels set at the actual cost of a compliant replacement vehicle, targeted at low-income drivers, carers, disabled Londoners, sole traders and small businesses.Grant tiers set against real market prices for compliant used vehicles and reviewed annually. Eligibility by household income and business turnover. Indicative cost: provisionally two hundred and fifty million pounds across the term.
- A vehicle replacement loan guarantee for small businesses and sole traders, so that fleet renewal can be financed rather than deferred indefinitely.Delivered through the GLA in partnership with lenders. Indicative provision: thirty million pounds across the term.
The principle is straightforward. Remove the polluting vehicle from the road permanently rather than charging its owner to keep driving it. A scrapped vehicle stops polluting on the first day and stays stopped. A charged vehicle pollutes every day and generates revenue while doing so, which is a poor incentive to design into a public authority.
Measure two: a targeted heavy vehicle and freight regime
Where charging is justified, it is justified against commercial operators who can plan, finance and pass on the cost, not against individuals who can do none of those things.
- The existing Low Emission Zone for heavy goods vehicles retained and strengthened, with tightened standards on the largest and most polluting vehicles.The LEZ predates ULEZ, targets vehicles doing disproportionate harm, and falls on commercial operators. Retained in full.
- Freight consolidation centres established at the edge of London, with final-mile delivery consolidated into low-emission vehicles.Reduces total vehicle kilometres on residential roads. Indicative cost: forty million pounds annually.
- Off-peak and night-time delivery expanded through relaxed servicing hours where noise conditions permit.Removes freight from peak congestion, cutting emissions and journey times together. Delivered with boroughs.
- A London Freight Standard made a condition of every GLA and TfL contract and of major planning consents.The purchasing power of the GLA group applied to fleet standards across its supply chain. No direct cost.
Measure three: clean air where children breathe
- School Streets at every London primary school where the road layout permits, with the programme completed within the term.Timed restrictions on motor traffic at opening and closing. Indicative cost: fifteen million pounds annually.
- Air quality monitoring installed at every London school, with readings published live and in public.Parents should be able to see what their children are breathing. Indicative cost: provisionally twelve million pounds capital and three million annually.
- Anti-idling enforcement outside schools, hospitals and care homes, with civil enforcement officers empowered and funded.Indicative cost: four million pounds annually.
Measure four: the fleet the Mayor owns
The most direct lever any Mayor holds over London’s air is the vehicle fleet the Mayor already controls.
- The entire TfL bus fleet zero-emission by 2032, accelerating the existing programme.Indicative capital: provisionally nine hundred million pounds.
- Every TfL support and maintenance vehicle zero-emission by 2031.A direct fleet decision requiring no consultation. Indicative capital: forty million pounds.
- Bus priority and reliability improvements on the corridors with the worst air quality, so that the alternative to driving is genuinely usable.Indicative cost: sixty million pounds annually.
This is where the argument for charging usually collapses. Charging people out of their cars is legitimate only if there is something else for them to travel on. In outer London, at the hours worked by the people the charge falls hardest on, frequently there is not. Building that alternative is the precondition for reducing car dependency, and it has been consistently skipped because it costs money rather than raising it.
Measure five: non-exhaust and construction emissions
- The Non-Road Mobile Machinery regime enforced properly across every London construction site, with inspection resourced and penalties applied.The regime exists and is barely enforced. Indicative cost: five million pounds annually, substantially recovered through penalties.
- Dust suppression and site emissions conditions attached to every major planning consent granted or called in by the Mayor.Policy instrument through the London Plan. No direct cost.
- A London programme on non-exhaust particulates covering brake and tyre emissions, with research commissioned and standards pressed for nationally.Vehicle construction standards are set nationally and internationally. London can generate the evidence base and lead the argument.
Measure six: domestic and building sources
- Smoke Control Area enforcement resourced across London, targeting domestic wood burning in residential areas.The powers exist under the Clean Air Act 1993 and the Environment Act 2021 and are barely used. Indicative cost: six million pounds annually.
- A public information programme on domestic wood burning, which most Londoners do not know is among the largest particulate sources in residential areas.Indicative cost: two million pounds annually.
- Zero-emission heating required in all major new development through the London Plan.Policy instrument. No direct cost.
Measure seven: transparency and accountability
If I remove a charging scheme and my replacement fails, London must be able to see that it has failed. That requires data I do not control and judgement I do not appoint.
- London’s air quality monitoring network expanded, with every reading published live, openly licensed and machine-readable.Indicative cost: provisionally eight million pounds capital and four million annually.
- An annual external audit of the Clean Air Programme, commissioned from a body I do not appoint, published in full including its criticisms.Indicative cost: one million pounds annually.
- A published air quality trajectory for the term, against which this programme is measured and reported annually.If the trajectory is not met, I will say so and set out what I intend to do about it.
3.4 The transition
ULEZ cannot responsibly be switched off on day one with nothing in its place. The sequence matters and is set out here in full.
Days one to fourteen
- ULEZ enforcement suspended and charging ceases. Zone infrastructure retained pending transition, not dismantled.
- The Clean Air Programme published in full and put out to statutory consultation.
- The expanded scrappage scheme opened to applications, funded from retained scheme reserves.
Months one to twelve
- Scrappage operating at full scale with grant levels set against real replacement costs.
- Low Emission Zone standards for heavy vehicles tightened.
- School Streets and school air quality monitoring programmes begun.
- Bus fleet replacement accelerated and bus priority works started on the worst corridors.
- Construction site and smoke control enforcement teams stood up.
- First external audit commissioned and the air quality trajectory published.
Years two to four
- Freight consolidation centres operating.
- School Streets programme completed.
- Bus fleet fully zero-emission by 2032.
- Annual audits published and the programme adjusted where the evidence requires it.
3.5 The finances, stated honestly
ULEZ generates net revenue for Transport for London. Abolishing it removes that revenue. The Clean Air Programme costs money rather than raising it. Both sides of that ledger are real and I will not pretend otherwise.
The gap is closed from four sources. The retained and strengthened Low Emission Zone continues to generate revenue from commercial operators. The enforcement measures in this chapter, on construction sites, idling and smoke control, are substantially self-funding through penalties. The operating and enforcement cost of running ULEZ itself, which is considerable, ceases entirely. And the balance is met from the war on waste in Chapter 2 and from reallocation within the Transport for London budget, on the argument that clean air is a core transport function rather than a discretionary extra.
The programme is designed to be revenue-neutral to Transport for London across the term, and it is paid for without a penny of new charges on London’s drivers. The full modelling will be published with the costed budget before polling day, and it will be published whether or not it flatters this argument.
3.6 What I am accountable for
This is the commitment that matters most in this chapter and the one I expect to be held to.
If the Clean Air Programme does not deliver air quality outcomes at least equal to the trajectory the previous scheme was projected to achieve, that will be visible in published data I do not control, audited by a body I do not appoint, and reported annually. I will not be able to conceal it and I will not attempt to.
I am not asking London to accept dirtier air in exchange for lower charges. I am asking London to accept that a scrappage scheme which removes a polluting van permanently is better than a charge which lets it keep driving, that a zero-emission bus fleet does more than a levy on private cars, and that people who cannot afford to comply should be helped to comply rather than billed indefinitely for failing to.