London's Ultra-Low Emissions Zone: the BMF responds
London has met the European air quality standards for all pollutants except NO2. In this respect the position is that London is currently in breach of agreed legal limits. These pollutants present a very real hazard to those who live, visit and work in London. It is considered that around 4,300 deaths may occur in London each year as a result of air quality related issues.
The area of London which is encompassed by the congestion charging zone scheme has been identified as the area to be addressed. It seems entirely logical that in the area where traffic congestion is the greatest, the air quality will be poorest. It is intended that from 7th September 2020 a charge will be levied on vehicles entering this area which emit pollutants at a rate greater than those defined in the Euro 4 regulations for petrol engine cars and light vans, Euro 3 for motorcycles and Euro VI for Diesel engine vehicles of all types. These Euro emission regulations have been chosen to comply with the emission reduction requirements in an entirely objective-driven manner.
The motorcyclists view
In the past few years the BMF has actively supported the introduction of electrical propulsion for motorcycles, used in the commuting role. The BMF believe that these zero-emission silent machines will become an attractive modal shift option for many folk, whose commute exceeds practical walking or cycling distances but who still require independent transport. In all of our publications and social media activities we never fail to take the opportunity to promote or support this future of clean, quiet independent transport for all.
In common with the other vulnerable road user groups (in road safety terms) motorcyclists are disproportionately exposed to air borne pollutants. Drivers and passengers in motor cars, vans, buses and trucks benefit from on-board filters which will arrest much of the large airborne particulate matter. In addition to this most of these vehicle incorporate passenger cab air recycling as an integral aspect of air conditioning systems etc. Motorcyclists enjoy none of these technologies and simply breathe the air as they find it. In traffic this is often from a point so close to the source that even dispersal has not occurred.
The benefits of an improvement in air quality in London will be welcomed by people who use powered two wheelers to go about their business and social lives in the city.
The figures researched by TfL indicate the powered two wheelers are projected to contribute just 1% of the NO2 pollutants in the ULEZ in 2020. These figures are based on DfT standard values and it seems likely that they do not reflect the shorter running time required for a powered two wheeler to make a journey, compared to any other powered vehicle type.
It is not known how many pre - Euro 3 powered two wheelers will be seeking to use the roads within the ULEZ after 7th September 2020 but it seems likely to be a small number. Motorcycles in London experience what may be described as “a hard life”; used as commuting tools rather than objects associated with a hobby, an interest or passion. In a recent discussions involving officers from TfL on Thursday 8th January the Motorcycle Action Group and the British Motorcyclists Federation it came to light that no organization can confidently put an accurate figure on how many machine > 13 years old are on the road today in London, let alone offer a defendable projection of the situation in 2020. The DfT values used in the TfL projections suggest that 87% should be Euro 3 compliant, with 13% older. In any case, what was agreed in the discussion was that the number of pre- Euro 3 motorcycles involved will be small.
Powered two wheelers which are older than 13 years can include prized classics of course, some of considerable financial value. However the great majority of older machines in use in Central London are unlikely to be worth more than a few hundred pounds each. A large proportion of these will be used by owners who are on small incomes and by students. We believe that this is a reasonable assumption because if they were not in this financial position and held the required credit credentials, these owners would be likely to take advantage of the many finance offers available from the manufacturers of new machines as a means to improve their form of transport. Folk in this economic bracket inevitably include those doing much of the socially valuable work upon which the city depends, often starting or completing their shifts at times which make the use of public transport difficult or impossible. The BMF cannot quantify this but observes that neither can anyone else. This position is not unique to London.
The BMF also considers that any actions which actively discourage the use of motorcycles in urban areas are detrimental to the city as a whole. Casualty rates actually improve with higher ratios of PTWs in the traffic mix, (cf. the original introduction of the congestion charging zone), congestion is at minimum not made worse for other traffic and can be eased. In Central London public transport is currently struggling to cope in the rush hour and while the situation may be somewhat improved by 2020 with the running of CrossRail it has already been admitted that CrossRail is likely to be fully utilised from the start; it makes no sense to take actions which may discourage motorcycle use, even, and perhaps, especially, in the heart of the city.
The BMF welcomes & supports an improvement in the quality of the air in London as a step which will bring benefit to the health and wellbeing of its members. Whilst the BMF recognises that every road user group will see themselves as a worthy exception the BMF believes that, in striving to achieve these benefits a disproportionate impact in the access to the economic and social benefits associated with independent transport could result for those least well placed to face the resultant financial challenges. The group concerned is an unquantifiable but extremely small element of a road a user group, which is considered in the round to be the source of a really tiny proportion of the NO2 emissions. We ask for careful consideration to be given to this group and would welcome the opportunity to work with officers of TfL to achieve an outcome best for all.