Letter to LTDA and UNITE RE: ULEZ meeting on 19/1/2015


The LCDC did not attend the trade ULEZ meeting at the LTDA on Monday.
This has caused many rumours to circulate within the Trade.
This is the email which was sent out to both the LTDA & Unite.21st January 2015

ULEZ, age limits and zero emission capable taxis

Dear Jim and Steve

We have reviewed the notes and comments that have been issued from Monday’s meeting between yourselves and some of the representatives from the other organisations and we would like to clarify our own position on these matters.

Age limits

Naturally, and because the members of the committee of the LCDC are all working cab drivers, we fully support the need to retain the 15‐year age limit.

As you know from our own response document submitted to TfL we also concur that the economic hardship that a 10‐year age limit would impose on the taxi trade would be impossible to bear.

Frankly the subsidies available from TfL, OLEV or government would in no way come near to covering the cost of £200 million to scrap all over 10 year old cabs. The most has been mentioned in all the ULEZ meetings we have attended has been £40 million.

Fundamentally we believe that the only reason TfL proposed a 10‐year age limit is because they believe there will be zero emission capable cabs in 2018. If they did not believe there would be zero emission capable cabs then they would find it much harder to justify reducing the age limit to 10 years.

It is this link between age limits and zero emission capable taxis which we feel is most critical. Break the link and you break the argument for a 10‐year limit.

Zero emission capable taxis

We at the LCDC do not believe there will be zero emission capable taxis, properly tested and available as working taxis by 2018. You can see our detailed rationale for this in our response document. We also thought that the rest of the taxi trade organisations subscribed to that view as well.
This point was voiced most strongly by Mike Hedges, Peter Bond and Steve McNamara at the ULEZ meeting at 55 Broadway on 10th December 2014. And then again, in front of the GLA Environment Committee on 4th December, Steve also said that he believed that zero emission capable taxis wouldn’t happen when he said “The reality is that we’re probably going to be in a situation on 1st January 2018 when there isn’t a vehicle available.” It is also forcefully argued by Barry Hooper in his last article in TAXI on 9th December and we have quoted his comments extensively in our response to TfL. If we are wrong and zero emission capable taxis are available as proven taxis by 2018 then we are wrong.

But what we believe is that the Mayor should not make policy on a few vehicle manufacturers’ promises and a few prototype vehicles. The manufacturers involved have either no track record or a poor track record of delivering what they say when they say. We’ve already seen one of them, Nissan, drop out and yet they had been promising so much for years.

What the taxi trade should be saying to the Mayor is that he should only bring in this policy of zero emission capable taxis when the manufacturers have demonstrated that they are really capable of doing so. This should be measured by the fact that at least 2 manufacturers should be capable of producing 1,000 taxis each when the policy is approved.

It is also important that these zero emission taxis are really capable of achieving properly the agreed set targets. For example, we have issues with TfL proposing to set a measurement of CO2 emissions (the 50g/km) when it is not the CO2 but the NOx that causes the real respiratory problems for Londoners.

We also firmly subscribe to the view that there should be a separate, independently tested, taxi drive cycle which is used as the measurement for emissions and not the New European Drive Cycle.
This NEDC is still nowhere near reflective of real taxi driving conditions. That’s why Kings College has been able to produce research which could show that older cabs produce fewer NOx emissions.
We note that it was considered to be urgent to understand what the OLEV subsidies will be on the zero emission capable taxis.

This is difficult to justify on two counts. First, OLEV stated at the ULEZ meeting on 10th December that any extra grants would not be available until 2020. Second, even if there was a £10,000 grant, that would still not be relevant until we knew the price of the taxi. What if the price was £70,000?


The lack of availability of super‐fast charging points was a good point made by Jim. What’s the point in having over 22,000 taxis chasing the 150 charging points which Elliot Treharne said would be made available for taxi drivers (Elliot Treharne, GLA Environment Committee on 4/12/14) – that’s just nowhere near enough.

Another significant technical flaw in the argument to introduce zero emission capable taxis is that there is no way that you can determine where a vehicle will undertake its 30‐ miles zero emissions on battery only. You might have a taxi using only its internal combustion engine in the ULEZ, causing more emissions, because its battery power has been exhausted. It has even been admitted by Matthew Pencharz at the Environment Committee meeting that this would require geo‐fencing, something which TfL are not capable of implementing.

Parity with private hire or others
Be careful about what you ask for. Asking for parity plays into the hands of TfL asking for a 10‐year age limit. Let me explain.

On the face of it, it seems sensible that private hire should have parity with taxis for newly licensed vehicles. By this you refer to the fact that although TfL require newly licensed PHV’s to be zero emission capable from January 2018, second hand vehicles (older than 18 months old) to be licensed as PHV’s need only be to Euro 6 standard. You say that all new or second hand PHV’s should be zero emission capable.

I have heard the phrase “ZEC’s for all!” However, what is ignored is the reason why TfL made this proposal: they say it’s because there is a far higher turnover of vehicles in the PHV sector (see TfL Consultation ‐ Supplementary Information, page 19), over 14,500 newly licensed per year.

The average age of PHV’s is only 5 years, which has been reduced by the current policy of a 10 year age limit. Therefore, by arguing for parity with PHV’s you end up strengthening the argument for taxis also having a 10‐year age limit.

By contrast the LCDC argue that taxis should have parity with the rest of the commercial vehicle industry in London.

In our response document (Point 16) we highlight the fact that coaches, HGV’s and LCV’s need only be Euro 6 to enter the ULEZ. Yet HGV’s, coaches and LCV’s contribute 34% to ULEZ emissions whereas taxis and PHV’s contribute only 22%. We believe that taxis should be just the same as commercial vehicles – i.e. Euro 6. The new Euro 6 vehicles have 84% lower emissions that Euro 5’s.

What TfL should be doing is encouraging taxis, PHV’s and commercial vehicles to get into Euro 6’s as soon as possible. That will reducing emissions faster than delaying implementing and unachievable policy of zero emissions for another 5 years.

Kind regards

Darryl Cox Secretary, the LCDC

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