low emission zones ------------------ detailed description of the initial objectives of the measure modern vehicles have much lower emi

Low Emission Zones
------------------
Detailed description of the initial objectives of the measure
Modern vehicles have much lower emissions due to European vehicle
emissions legislation (‘Euro standards’). The legislation was
initially introduced in 1993 (Euro 1) and were tightened in 1996-1997
(Euro 2) and in 2001 (Euro 3). Legislation is also in place for
further controls in 2006 (Euro 4) and in later years. The faster
adoption of cleaner road vehicles therefore offers opportunity for
reducing emissions. One of the more promising options to introduce
greater numbers of cleaner vehicles, and reduce the numbers of older,
more polluting vehicles on the road network, is through the
introduction of a low emission zone (LEZ). An LEZ is a defined area
that can only be entered by specified vehicles meeting certain
emissions criteria or standards, e.g. certain Euro standards. An LEZ
prohibits older vehicles from operating in an area, and so accelerates
the turnover of the vehicle fleet (or requires operators of older
vehicles to fit abatement equipment to their vehicles). Although
traffic volumes do not necessarily change, vehicles travelling in an
area have lower emissions, and this leads directly to air quality
improvements. LEZs for freight vehicles have already been successfully
implemented and run for many years in Sweden, where they have led to
improvements in air quality levels, see box below.
Box 1. Swedish Experience with Low Emission Zones
Low Emission Zones have been in place in Sweden since 1996, when
Stockholm, Gothenburg and Malmo introduced ‘Environmental Zones’ in
their city centres, with the purpose of improving air quality and
reducing noise. The zones target all diesel lorries and buses over 3.5
tonnes. On introduction, the scheme required all these vehicles to
meet the Euro 1 standard. Vehicles between 9 and 15 years old were
also allowed to operate in the zone if they had been retrofitted with
a certified emissions control device or new engine. There was also a
special permit for vehicles that only travelled rarely in the zone.
The zone is enforced using a permit system for older vehicles
(windscreen stickers) with visual inspections. Vehicles driving
illegally in the zone are subject to a fee, enforced by police
authorities. The zone does not have any signage. The compliance rate
is around 90% (based on visual inspections). The zone is simple and
has low costs to administer.
From January 2002, the environmental zones (Stockholm, Gothenburg,
Malmo and Lund) introduced an 8 year age limit from date of first
registration on all heavy-duty vehicles (>3.5 tonnes). Older vehicles,
with first year of registration after 1993 (i.e. minimum Euro 1) may
enter the zone with the approved after treatment device. A two-tier
system was introduced. Level B, which requires the retrofit technology
to reduce emissions of particulates and hydrocarbons by 80%, and level
C, which requires an additional 35% reduction in NOX. For both levels,
no increase in noise levels is allowed with the retrofit technology.
Level B corresponds with a particulate filter and catalytic converter
and level C with current NOX reduction equipment. Vehicles meeting
level B requirements are allowed to operate for another 4 years in the
zone (i.e. until 12 years old). Vehicles meeting level B+C
requirements are allowed to operate for an additional 2 years on top
of this (i.e. until 14 years old). Special conditions are set out for
vehicles with a special body. For these vehicles (even if pre-Euro),
vehicles over 8 years old are allowed to enter the zone with relevant
emissions after-treatment equipment. In addition, vehicles meeting the
level B emissions requirements are permitted to operate for longer
(vehicles between 8 and 15 years are allowed to in the zone if they
meet level B emission requirements and an additional 2 years on top of
this if they meet B+C requirements). Vehicles are also allowed to
enter if they re-engine. For example, if a new engine is put into a
vehicle after January 2002, the vehicle may enter the zone for a
maximum of 6 years from the year of manufacture of the engine
(provided the engine meets the most severe European environmental
class at that time). It may also enter the zone for longer if the
level B and B+C emission requirements are met through additional
approved abatement equipment.
LEZs are also being widely considered by other UK and European cities,
with advanced plans in London. Indeed there is now a commitment to
press ahead with the London scheme. Details of the scheme are outlined
in the box below.
Box 2. The Proposed London Low Emission Zone
A feasibility study was undertaken (reporting in 2003) on the
potential for a London Low Emission Zone (Watkiss et al, 2003). This
considered the costs and benefits of the LEZ, what it could achieve
and how it could be implemented, with the aim of informing whether low
emission zones would work towards meeting London’s air quality targets
and whether they should be taken forward to implementation. The study
considered a very large number of different options for a low emission
zone in London. The conclusions from the study, should a low emission
zone for London be taken forward, were:
Area. The study recommended that the most appropriate option for a
London LEZ would be a scheme including all of the Greater London area.
Vehicles. The study recommended that the low emission zone started
with a scheme that targeted lorries, London buses and coaches. These
vehicles have disproportionately high emissions per vehicle and
targeting them produces greatest emissions reductions for least cost.
However, the study recommended that the zone be potentially extended
in later years to include vans (subject to further investigation of
the socio-economic effects of such a scheme on small companies/owner
drivers) and taxis (though taxis should be addressed earlier through
the licensing process). The study did not recommend that cars should
be included in the scheme, but did recommend that some action is
needed, alongside any LEZ, to target the removal of very old cars in
London (those built before 1993).
Legislation and Enforcement. The study recommended that a manually
enforced scheme, targeting heavy vehicles only, would enable the
quickest introduction of an LEZ (where offenders are pursued through
the courts). However, automatic enforcement using cameras would ensure
higher compliance and so greater air quality benefits. The study
concluded that an automatic approach would be needed if the LEZ were
to include vans to ensure adequate detection rates.
Implementation Date. The work necessary to set up the legal basis for
a London LEZ would make it extremely difficult to implement a fully
operational scheme before the middle of 2006, and more realistically
before late 2006.
Emission Criteria. The emission criteria set for a London low emission
zone will dictate the air quality benefits and the costs to operators.
The study recommended that for lorries, buses and coaches the criteria
were based on Euro standard (age) and other emission standards (the
Reduced Pollution Certificate (RPC)). The study recommended that
vehicles should meet an initial criterion of Euro 2 plus RPC (or
equivalent) in 2006/7. It also recommended that this criterion be
tightened to Euro 3 plus RPC (or equivalent) in 2010. However, there
were two additional conclusions put forward alongside this latter
recommendation. Firstly that a NOx based RPC scheme would help the
effectiveness of the scheme and could allow greater NO2 improvements.
Secondly that it might be beneficial to introduce the Euro 3 plus RPC
criterion earlier than 2010 using a rolling approach (applying the RPC
to Euro 3 vehicles based on age). The study recommended a different
approach for vans, should these vehicles be included, using a rolling
ten-year-old age limit. A similar age-based standard was also
recommended for licensed taxis and private hire vehicles.
The emission criteria above would impact on an estimated between
22000-59000 heavy goods vehicles or approximately 37% of HGVs
travelling in Greater London. No buses would be affected as they must
already comply with the emission criteria by 2005. However, an
estimated 5800 coaches would be affected which represents 56% of these
vehicles travelling in Greater London. The approximately 4 million
cars, taxis, light goods vehicles and private hire vehicles that
travel in Greater London each year would be unaffected. Heavy Goods
Vehicles will be responsible for 34% of the London road transport
total for NOx and 25% for PM10 in 2005. While it possible to indicate
the contribution of the road vehicles potentially affected by the LEZ
towards London emission totals there are no data available to indicate
the contribution towards ambient air quality levels currently
experienced.
There are also other area access control measures such as
‘home-zones’: these are focused on residential areas where safety and
community enhancements are the primary drivers, rather than road
transport emissions and indeed such schemes may actually increase
emissions by decreasing vehicle speeds. These residential schemes are
not considered further in this study.
‘Ex post’ data does exist on the Swedish LEZs (though we have found
little ‘ex ante’ analysis for the schemes that would be transferable
to the current study). There is also a very detailed ‘ex ante’
analysis of the proposed London scheme. Both are summarised in the
following sections. Note much of the background information on
emissions and vehicle numbers in London was presented in the previous
section.
Road transport accounts for approximately 58% of NOx emissions and 68%
of PM10 emissions in London. Furthermore, HGVs of all kinds in 2005
will be responsible for 34% of the London road transport total for NOx
and 25% for PM10. While it possible to indicate the contribution of
the road vehicles potentially affected by the LEZ towards London
emission totals there are no data available to indicate the
contribution towards ambient air quality levels currently experienced.
Environmental Impacts (Emissions and Air Quality)
The Swedish LEZs (Ex Post)
In Stockholm, the environmental zone covers around 30% of the total
population of the city (i.e. an area with around 220,000 people). An
assessment of the air quality benefits of the scheme in 2000
(Johansson and Burman) found that emissions of NOX from heavy vehicles
within the zone were reduced by 10% and emissions of particulates by
40%. These benefits are relative to the emission reductions that would
have occurred from heavy vehicles (only) without the zone. The
corresponding reductions in air pollution concentrations were
estimated at 1.3% reduction for NOX (with a range of 0.5% - 2%) and 3%
for particulates (with a range of 0.5% to 9%), compared to the
predicted concentrations without the zone. The values are much lower
than with emissions because of the importance of other road vehicles
and other sources to total air quality concentrations. The analysis
also concluded that the effect of the environmental zone was large
when compared with other actions that it was possible for the local
city administration to implement.
London LEZ (Ex Ante)
The London analysis undertook very detailed analysis on emissions and
air quality.
It concluded that a London low emission zone would have modest
benefits in improving overall emission levels and absolute air quality
concentrations in London, but it would make a larger contribution to
reducing exceedences of the air quality targets. The recommended LEZ
would have greatest impact in targeting PM10 emissions and air quality
exceedences. It is estimated that the recommended scheme would achieve
a 23% reduction in total London PM10 emissions in 2010. It would also
achieve a 43% reduction in the area of London exceeding the relevant
PM10 air quality target in 2010, and a 19% reduction in the area of
London exceeding the relevant NO2 air quality target in 2010. The
emissions and air quality improvements are summarised below.
Table 1 Air Quality Benefits of the Recommended London LEZ.
Reduction in Emissions
(relative to baseline)
Reduction in Area Exceeding Targets
(relative to baseline)
Pollutant
2007
2010 A)
2010 B)
2007
2010 A)
2010 B)
NOx (NO2)
1.5%
2.7%
3.8%
4.7%
12%
18.9%
PM10
9.0%
19%
23%
0%*
32.6%**
42.9%**
* London should meet the relevant air quality for PM10 in this year
without any additional action for an average year’s weather. **
Exceedence of the annual meanPM10 objective.
The 2007 scheme only includes lorries, buses and coaches. In 2010: A)
includes lorries, buses and coaches and B) includes lorries, buses and
coaches, vans and taxis. Source: Watkiss et al, 2002.
The comparison of the Swedish and London studies provides some
interesting conclusions. The Swedish schemes have achieved very large
emissions improvements, because they were introduced early, when the
fleet had higher emissions (i.e. by targeting pre-Euro vehicles).
Essentially, because the London scheme is being introduced in later
years, the benefits are mitigated by the ongoing improvements in the
vehicle fleet as a result of the Euro standards: by 2007, emissions
from road vehicles will be significantly lower than they are today,
and much lower than the early years of the Swedish scheme (introduced
in 1996).
Interestingly, the London study also found that a London low emission
zone would have a greater impact in improving air quality
concentrations than it would in reducing emissions, at least in
relation to the specific air quality targets set by the UK Government
and the European Union. This happens because many locations in London
are likely to be close to the air quality target levels for future
years. Even small changes in emissions can significantly affect the
area of exceedence, so that an area that previously exceeded the air
quality target could drop below the threshold level with the
introduction of a low emission zone in place.
An analysis of costs and benefits of the measure
Some analysis was made of the population weighted exposure from the
London LEZ, and the likely improvements in health, as a reduction in
mortality and morbidity.
The analysis showed that a London LEZ would have a relatively small
improvement in reducing the number of PM10 related acute deaths from
air pollution (more accurately known as the deaths brought forward).
It would also lead to a relatively small reduction in the numbers of
severe hospital admissions from PM10. For both of these health
endpoints, the improvements would be measured in only several cases
avoided each year. However, the LEZ would also reduce down the number
of total health effects (including less severe air pollution related
health impacts) very significantly from PM10, i.e. by tens of
thousands of cases each year. It would also lead to an increase in
years of life gained, with perhaps a thousand extra years of life per
year gained from the scheme1. The relatively modest improvement in
health is due to the relatively small changes in background ambient
concentrations from the scheme. Note the scheme only assessed the
direct effects of PM10, and only considered pollution benefits in
London: there would be additional benefits from NOX and from all
pollutants outside London from regional air pollution transfer. We do
not report the detailed analysis here, because the methodology used is
different to that recommended in the CAFE CBA health impact
assessment.
The Swedish Schemes (Ex Post)
Some analysis of the costs of the Swedish low emission zones
(environmental zones) has been compiled. The zone works by excluding
heavy goods vehicles that are older than eight years old, or have
approved emissions control technology fitted if older. However,
Swedish cities are much smaller than London and a much lower number of
total vehicles is affected – for example the Swedish Stockholm scheme
affects 7,000 heavy vehicles, whereas the London scheme (potentially)
affects as many as 30,000 to 70,000 heavy vehicles. While small
businesses were identified as being affected by a potential Swedish
zone, no special measures were introduced to assist these businesses.
The cost of compliance of the Stockholm scheme was estimated at around
37 M crowns, with other schemes in Gothenburg and Malmo estimated at
14 M crowns and 11M crowns respectively for 1997. The actual costs in
Stockholm were actually found to be around half the estimated value,
while the costs in the other two cities were about the same as those
predicted. No attempt was made to estimate the social and economic
costs of the schemes. The Swedish scheme did consider a five-year,
rather than an eight-year cut-off for eligible vehicles (the
recommended proposals for the London LEZ effectively introduce a 5
year age limit). However, this tightened age limit was ruled out in
Sweden because most vehicles had an eight-year warranty and a
feasibility study indicated that the 5-year age limit would result in
very high costs to business.
The London Scheme (Ex Ante)
The costs of setting up and running a London low emission zone vary
with the exact scheme and the types of vehicles included. A manually
enforced (permit) scheme for lorries would have the lowest cost to
set-up, at an estimated £2.8 million to set-up, with running costs of
around £4 million each year (4.2 million Euro set-up, 6 million Euro
running costs). There are a number of ways an automatically enforced
scheme (based on vehicle recognition through cameras) could be
introduced. The costs of introducing a network of fixed cameras across
London are prohibitively high. Therefore, should an automatic
enforcement approach be adopted, the LEZ feasibility study recommended
the use of the existing Central London Congestion Charging Scheme
(CCS) infrastructure, combined with the use of mobile ANPR cameras,
and possibly a small number of additional fixed cameras outside this
area. This type of scheme is estimated to cost £6 million to £10
million to set-up (9 to 15 million Euro), with running costs of around
£5 million to £7 million each year (7.5 to 10.5 million Euro), but
might generate revenues of £1 million to £4 million per year (1.5 to 6
million Euro). Note the revenue raised should not be included in a
cost-benefit analysis as it is a transfer. It is stressed that none of
the London LEZ schemes considered in the study would be likely to be
self-financing. The costs of different schemes are shown below.
Table 2 Estimated Costs (£ Million) of the Recommended London LEZ
Schemes.

Note: automatic enforcement and any revenues are conditional on a
decriminalised regime being introduced. The revenues shown are those
likely to arise initially on scheme introduction, but would be
expected to fall in later years as compliance improved. Source:
Watkiss et al, 2002.
It is stressed that there is a trade off between the levels of
non-compliance, the revenues generated, and the air quality benefits
of a scheme. The estimated revenue streams arise because a small
proportion of vehicle owners would continue to use their vehicles on
an irregular basis in the zone and pay penalty charges, rather than
invest in a new vehicle or abatement equipment. These vehicles would
not be generating anticipated air quality benefits, which is the
primary reason for introducing the scheme. It is also expected that
operators would change their behaviour as the scheme progressed, i.e.
compliance rates would increase in later years (which would be good
for air quality), and so revenues would decline. When all capital
costs and operating costs are considered, even with potential revenues
in early years, it is clear that a London LEZ would not be
self-financing, i.e. it would require funding.
It is also important to recognise that a low emission zone would have
significant cost implications for vehicle operators. The study has
clearly shown that the costs to operators are likely to exceed the
costs of setting up and running a London LEZ (presented in an earlier
section). Indeed, the total costs of many LEZ options to vehicle
operators could be extremely high. These costs are relevant in any
cost-benefit analysis.
Estimating these costs is very difficult, not least because it depends
on the behavioural response of vehicle operators. The study undertook
stakeholder consultation and industry surveys to get some indications
of possible behaviour. The conclusions were:
*
For many national/larger operators, with larger fleets, a low
emission zone might not have a large impact, as many of these
companies only keep their vehicles for 5-6 years.
*
Even for operators with a mix of older and newer vehicles, there
would be a zero cost option, which would be to alter their fleet
logistics so that their older vehicles were moved to other parts
of the country(25% of those questioned expected their companies to
adopt such a strategy). The impacts of a LEZ would therefore be
greatest on London registered vehicles, particularly specialist
vehicles that have longer lifetimes.
For relatively new heavy vehicles, it is possible to fit relatively
low cost equipment that can improve vehicle PM10 emissions, such as a
diesel particulate filter. Operators can also refit a new engine into
an existing vehicle to improve the emissions performance to a similar
level to modern vehicles.
Operator may also decide to replace a vehicle – buying either a second
hand or new vehicle. All fleet operators have a natural cycle of
vehicle replacement and in any given year, around 10% of the vehicle
fleet are replaced with new vehicles. For relatively new vehicles,
this is generally a more expensive option than retrofitting. For older
vehicles, bringing forward the purchase of newer vehicles can actually
lead to an economic benefit to the operator because of the improved
fuel efficiency and lower maintenance of a modern vehicle.
The potential costs to operators from the recommended low emission
zone are shown in Figure below, based on the consultation response. It
is stressed that the costs for individual vehicles are not high – but
the total costs are large because of the very large number of vehicles
that operate in London each year. The costs of introducing the
recommended LEZ in 2007 could have a cost to industry of £64 million
to £135 million (96 to 203 million Euro), depending on the number of
vehicles that operate in London.
Figure 1 The Potential Costs of the Recommended LEZ to Vehicle
Operators.

The figure shows present value costs, taking account of the capital
costs and changes in maintenance, fuel efficiency, etc over the
lifetime of the vehicles. The low and high values for lorries and vans
reflect a range of the number of vehicles operating in London. Figures
assume full compliance with the LEZ (though the figures for freight
vehicles are adjusted down by 25% to take account of fleet
redeployment, in line with the industry consultation). The same
assumption has been used for the coach fleet. The analysis assumes
that all Euro 2 vehicles are retrofitted with abatement equipment to
meet the emissions criteria, but does not include potential grants
(CleanUp) or VED rebate for this action. The range in the values
presented for TfL London buses in 2010 reflects the uncertainty over
the potential responses available to the LEZ. Source: Watkiss et al,
2003.
However, more recent work on costs, taking into account revised
technical costing for abatement measures, indicators a lower range
from £37 million to £95 million for the first phase of the scheme to
operators.
The potential costs to operators would be less if current Government
grants continue or are extended. They would also be lower than shown
above if the current Government vehicle duty rebates were maintained
in future years. At present, lorry operators who achieve the RPC are
entitled to a discount on annual Vehicle Excise Duty (VED) of £5 to
£500 per year (depending on the type of vehicle).
The study also found that the costs of the scheme would rise very
dramatically if the emissions criteria were stricter for two reasons.
Firstly there are many more vehicles affected, and secondly, operators
would need to take greater action (more expensive retrofit equipment
or new vehicles) to meet the stricter emission criteria. The
recommended LEZ (above) would allow operators of most relatively new
heavy vehicles to continue operating in the zone provided they took
some action to improve emissions (i.e. it would preserve the asset
value of the vehicle). A stricter zone would significantly reduce the
value of these vehicles, or require expensive abatement options, and
it is clear that a strict scheme would have a very large detrimental
impact on vehicle operators.
Benefit to Cost Ratio Sweden (Ex Post)
A CBA was undertaken for the Swedish environmental zones and the
analysis estimated that 80% of the costs of the zone had been offset
by direct gains for the environment. Unfortunately the data is not
available to re-assess the cost benefit ratio with the new unit
pollution values used in other areas of the report.
Benefit to Cost Ratio London (Ex Ante)
The London study also undertook a cost-benefit analysis. This found
that the benefits were broadly comparable to the full costs of the
scheme (i.e. the costs of implementation and the costs to industry).
The London LEZ feasibility study conclusions were:
The benefits of health improvements have been estimated to be £26
million (39 million Euro) from the recommended LEZ in 2006/7 in the
first year of introduction alone, and just under £100 million (150
million Euro) in total, based on the net improvement to the vehicle
fleet. The benefits for the two recommended schemes in 2010 are £32
million (heavy only) and £40 million (including vans and taxis) in the
first year of introduction, and £122 million and £143 million
respectively in total.
A London low emission zone would improve the health of Londoners by
reducing air pollution related impacts. The economic benefits of these
environmental improvements would more than offset any costs of
introducing and operating the scheme, for example the estimated health
benefits in London from the recommended scheme for 2007 are estimated
at £100 million (£150 million Euro). Moreover, these benefits are a
sub-total, as they only include the air quality improvements in London
- there would also be benefits outside London from cleaner vehicles
affected by the London LEZ travelling elsewhere. Overall, the study
concludes that the benefits of the schemes are likely to be broadly
similar to the overall costs (including the costs to vehicle
operators). The recommended heavy vehicle LEZ has greatest benefits,
relative to costs.
We have reanalysed the study findings with the approach presented in
the methodology section, reflecting the CAFE CBA unit pollution costs.
The analysis is based on the emissions reduction in London. The
analysis shows that the benefits of the 2007, in the first year, are
estimated at 9.5 million to 18.7 million Euro.
Of course, there are benefits from the scheme in later years, but
these decline over time (unless the LEZ scheme is tightened in later
years). Based on the estimated marginal benefits of the scheme over
and above the baseline, the total benefits of the LEZ scheme (first
phase) are estimated at 30.5 million to 55.4 million Euro. Note these
benefits may underestimate the benefits of the scheme, as they do not
adequately take into account the full population weighted increment
from PM emissions in London.
This compares to estimated costs of the scheme of:
*
Costs of introduction of 9 to 15 million Euro (assuming an
automatic scheme), with running costs of 7.5 to 11 million Euro
(but possible revenue generation of 1.5 to 6 million Euro).
*
Total costs to operators of 56 to 143 million Euro.
Consistent with the LEZ conclusions, we find that the benefits of the
scheme outweigh the costs of introducing and operating the scheme (a
high benefit: cost ratio), but that the total costs of the scheme,
including costs to operators, are probably broadly similar (and the
upper range of cost estimates is potentially higher than the
benefits).
The scheme is potentially tightened in 2010. The benefits analysis for
the scheme to heavy vehicles only (Euro III plus RPC) is shown below.
An additional scheme was considered which also included vans. The
benefits of the revised heavy vehicle scheme rises to 15.4 to 25.3
million Euro in the first year. Based on the estimated marginal
benefits of the scheme over and above the baseline, in the four years
from 2010 – 2013, and using the same values as above, the total
benefits of the LEZ scheme (second phase) are estimated at 59.5 to 98
million Euro.
This compares to estimated costs of the scheme of:
*
Running costs of 7.5 to 11 million Euro (but possible revenue
generation of 1.5 to 6 million Euro).
*
Total costs to operators of 182 to 551 million Euro.
The possible extension of the scheme to cover vans would increase the
benefits (by an additional Euro 4 to 8 million), but increase the
costs more significantly (by some Euro 90 to 120 million) and so the
benefit to cost ratio would fall. This reflects the higher relative
abatement costs needed to tackle smaller vehicles.
Other evaluation criteria
A large number of other criteria are important for a Low Emission
Zone.
Public and Political Acceptance
The feedback that exists in Sweden indicates a fairly positive
response to the scheme. The London study explicitly undertook
stakeholder surveys to elicit views on the scheme.
The study investigated the likely response to a London LEZ by freight
operators. It undertook face-to-face and telephone interviews, and a
questionnaire survey with hauliers/fleet operators. This found more
concerns amongst smaller operators, who often have longer replacement
cycles, and owners of vehicles with specialist bodies (e.g. cement
lorries), which also have longer replacement cycles as these vehicles
are more expensive and tend to do less mileage. Most people questioned
responded that they would comply with an LEZ. The most likely
responses in what this response would be were to fit exhaust
modification or buy new vehicles, though a very clear message came
back that operators would use newer (compliant) vehicles in London and
displace older vehicles outside London. There was a wide range of
responses to the potential costs of an LEZ, with a general reaction
that smaller companies were more concerned about costs, as they
typically had older vehicles and less capital to modify or change
their vehicles.
Overall, the survey indicated that operators would be broadly
supportive of a London low emission zone, as shown in Figure 2 below,
which reports the results of the survey questionnaire. Operators
stressed the need for adequate notification (as early as possible) of
any forthcoming LEZ, so that they could take this into account in
planning their vehicle replacement strategies.
Figure 2 The Attitude of Freight Vehicle Operators Towards a London
LEZ.

A survey of 50 companies asked ‘ Which of the following best describe
your views on the low emission zone concept for London?’ Answers were
a mix of personal and company views. Source: Watkiss et al, 2002.
The additional positive and negative effects from LEZs are summarised
below.
GHG reduction
The introduction of an LEZ can lead to changes in greenhouse gas
emissions from road vehicles, due to improvements or reductions in
fuel consumption (fuel efficiency) from modern vehicles or from the
introduction of abatement equipment. However, these changes are not
necessarily positive (i.e. an LEZ would not necessarily lead to
greenhouse gas emissions reductions, and it could actually lead to
increase in emissions).
This occurs because there remains some debate on the fuel consumption
changes when replacing an older vehicle with an equivalent vehicle of
a newer Euro category, either when replacing the engine or when
replacing the whole vehicle. There also appear to be fuel efficiency
penalties with certain abatement equipment.
For heavier vehicles, data shows that average fuel consumption of HGVs
has decreased by over 1% per year over the last 10 years for
articulated HGVs and medium sized rigid HGVs (between 17 and 25
tonnes). For smaller rigid HGVs there has been no change. The fuel
efficiency improvement for heavier vehicles reflects changes in the
engine technology and control systems, the use of lighter materials,
better transmission systems and other improvements. However, fuel
efficiency penalties also arise from the increased use of pollution
control devices in later Euro standards. In practice, many
manufacturers and operators report fuel efficiency penalties when
moving to newer heavy good vehicles. Fuel efficiency penalties have
also arisen for modern buses due to increases in the weight due to
safety engineering and the switch to low floor buses (although these
have been partially compensated by engine improvements). The fuel
consumption of Euro 4 vehicles is unknown, though they could
potentially be up to 8% more fuel efficient if manufacturers fit
selective catalytic reduction (SCR) technology.
For light vehicles, data shows little change in fuel consumption over
the last decade. Whilst the increased use of pollution control devices
in later Euro standards tends to increase fuel consumption, this has
been matched by accompanying improvements in engine technology. Moves
to larger vehicles (such as 4x4s and multi-purpose vehicles for cars)
and increased use of auxiliary equipment such as air conditioning,
might increase overall fuel use. However, European carmakers are now
bound by the ACEA (Association des Constructeurs Européens d'
Automobiles) voluntary agreement on maximum greenhouse gas emissions
from cars and so, in future, cars are likely to have fuel efficiency
benefits. These benefits would also be reflected for car-derived vans,
but not larger vans, which are excluded from the ACEA agreement.
The London study concluded that there would be no greenhouse gas
emission benefits for most LEZ options, and indeed in many cases there
may be a small dis-benefit for options in 2005 and 2007. However, the
introduction of Euro 4 vehicles would change this. Heavy Euro 4
vehicles are likely to have better fuel efficiency (as SCR is likely
to be fitted to reduce NOX emissions). Smaller light goods vehicles
and cars will have better fuel efficiency (because of the ACEA
agreement). LEZ options in 2010 would therefore be likely to reduce
greenhouse gas emissions.
Noise reduction
Transport noise affects amenity and numerous surveys have shown it to
be a major nuisance. Changes in vehicle noise legislation have not
followed those of exhaust emissions, but Euro 2/3 vehicles are quieter
than older vehicles. Noise limits are in place, and it is clear that
pre-Euro (and some Euro 1 vehicles) will only comply with noise limits
enforced in 1988/9 whereas Euro 2 and 3 vehicles will comply with
noise limits set in 1996. An LEZ should therefore have noise benefits.
However, as traffic noise is the combination of engine, exhaust system
and transmission noise, and noise generated from the interaction of
the tyres with the road surface. Only the first of these is affected
by an LEZ. The London study modelled the noise benefits of an LEZ
which required all commercial vehicles (i.e. excluding cars) to be
Euro 2/3 compliant (i.e. so that they would comply with 1996
legislation). It found that traffic noise levels would not be
significantly altered after implementing such a scheme i.e. the
reductions are less than 0.5 dB(A). The main reason that there is very
little effect on noise levels is that the proportion of the noisier
heavy vehicles in the traffic stream only accounts for about 0.3% of
the total flow. Replacing these noisier vehicles has little effect
despite a difference of 4 dB(A) in pass-by levels. However, this is a
function of LAeq energy averaging and people could actually notice and
appreciate a reduction in the maximum noise level of some of the
pass-by ‘events’.
The study therefore concluded that whilst modern vehicles (i.e. those
permitted to operate in an LEZ) are quieter, in practical terms, the
net change in noise levels would be low for all options. However,
people could actually notice and appreciate a reduction in the maximum
noise level of some of the pass-by ‘events’.
Others
The London study also assessed the potential socio-economic effects
from a London LEZ, summarised below. It stressed that the impact of
any LEZ is likely to have a disproportionate impact on certain fleet
operators, notably those with specialist vehicles, rather than the
larger conventional fleet operators. These specialist vehicles are
much more expensive to purchase and therefore tend to have longer
replacement cycles, i.e. they are operated for longer before being
replaced. Ideally, existing and future grants should be prioritised
towards such vehicles. An alternative, which is present in the Swedish
scheme, is to allow specialist vehicles to operate for longer periods
in the zone, provided they have some abatement equipment fitted (i.e.
provided they have PM10 abatement equipment).
Figure 3 Potential Socio-economic Effects from a London Low Emission
Zone.

There were some particular concerns over the issue of diverted traffic
from the scheme. This would include changes in travel time and
potential congestion effects, arising from increases in transport
distances (as well as increases in fuel consumption and emissions
outside of the LEZ area). It might also have effects through changes
in accident rates and with certain routes, community severance effects
due to the physical/social perception of changes in HGV traffic. For
the London wide scheme, these effects are likely to be low.
Advantages and limitations of the measure
The main limitation with a low emission zone is that it only
accelerates the introduction of new vehicles, therefore it only moves
forward emissions and air quality improvements that would have
occurred (in time) anyway. The London study showed that most LEZ
schemes would have a modest reduction in emissions and improvement in
air quality. The reason is that the air quality benefits of any LEZ
have to be seen in the context of a significant decrease in emissions,
year on year, as a result of the ongoing, normal replacement of older
vehicles by newer vehicles in the fleet. By 2005, emissions from road
vehicles will be significantly lower than they are today. Nonetheless,
when compared to other options in London, the potential for an LEZ was
seen as one of the most cost-effective methods of achieving
(relatively) large-scale improvements.
Analysis of possibility of extension to other cities
The Swedish system has shown that LEZs can be applied in different
cities successfully.
As with the congestion charging scheme, there are specific issues with
the boundary of the scheme. The London scheme proposes existing
orbital roads around London. This should help to address the issues of
diverted traffic. Schemes in other cities would have to assess the
potential for these traffic issues.
The existing Swedish schemes, and the proposed London scheme,
concentrate on targeting heavy-duty vehicles. This was shown to be the
most cost-effective approach (and had the highest benefit to cost
ratio). London has a high proportion of heavy vehicles – it is a major
hub for public transport – it has high influx of tourists and it has a
large number of heavy goods vehicles movements. Other cities might
have lower HDV levels, and this might reduce the effectiveness of the
scheme.
This is also important in relation to the scheme used to register and
enforce the LEZ. The existing London scheme is proposing to use the
existing CCS infrastructure and extend. Other cities would face high
capital costs in pursing a camera based enforcement system.
Alternative systems, such as permits, have been successful in
Scandinavia, but they might achieve lower levels of compliance.
There is also an issue of timing. The continual replacement of the
vehicle fleet and the introduction of successive Euro standards mean
that emissions benefits from an LEZ are likely to decline in future
years. In order to maximise the benefits, schemes are needed to be
introduced quickly, and also tightened in later years (though this
then introduces additional compliance costs for operators). This is
important in considering the transferability of the scheme to other
cities.
The scheme has most benefit in targeting urban areas, particularly
larger cities. There is less justification for introducing motorway
based schemes, and the costs of setting up and enforcing the schemes
are prohibitive for smaller urban areas. There has been some calls for
national based schemes, though these are difficult to justify, because
of the low benefit to cost ratio (i.e. the benefit to cost ratio would
be low for rural areas and most highway driving). However, once
several cities in a country have schemes, or for an important city
such as London that influences such a large proportion of the vehicle
fleet, schemes effectively become national and so benefits accrue at a
national level.
The road transport fleet is important across Europe, in all major
cities. The LEZ schemes tend to target diesel vehicles and so they
will have a primary benefit in reducing PM10 in major urban areas,
where pollution exposure is highest. The extension of the scheme to
include vans is potentially important, as some of the CAFE baseline
analysis shows a growing proportion of PM10 emissions from these
vehicles, as a percentage of overall emission.
Note, the London scheme made a detailed analysis of the extension of
the LEZ scheme to cars. This was found to have very low
cost-effectiveness, and a very low benefit to cost ratio. As a result,
the inclusion of cars in the scheme was not recommended. However, the
analysis did highlight that action on pre-Euro cars might be
cost-effective. A number of different options exist to target these
vehicles, including scrappage subsidies, and the report concluded that
these other schemes might offer more cost-effective ways to target
this section of the fleet.
Both the permit system, and the ANPR camera technology, used for the
scheme have been proven and demonstrated. There are some political
barriers, in that the scheme has a potential impact on some businesses
or sectors. The London study found high acceptance for the scheme
amongst large fleet operators. The main potential barriers are over
smaller fleets (usually smaller companies) and other industries that
operate specialist vehicles. This includes coach operators, waste
vehicles, cement lorries, etc, as these vehicles have high capital
costs and have longer lifetimes.
There are potential legal barriers, for example, in London, the use of
camera technology would require new legislation (though the permit
system would not). This can increase the time taken to introduce the
scheme, as well as increasing the costs of introduction.
Contact for more information (air quality related)
Ms Lucy Sadler
Air Quality Lead Officer
GLA
City Hall
The Queen’s Walk
London SE1 2AA
United Kingdom
Telephone: +32 (0)20 7983 4309
Email: [email protected]
Website http://www.tfl.gov.uk/tfl/cclondon/cc_intro.shtml
1 We do not report the detailed analysis here, because the methodology
used is different to that recommended in the CAFE CBA health impact
assessment.

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