London Cab Drivers Club response to TfL Ultra Low Emission Zone consultation issued 27th October 2014
1. The London Cab Drivers Club (LCDC) is one of the main taxi trade organisations in London, actively involved in committees and liaison meetings with TfL at all levels. We have participated in the recent GLA investigation into Taxi and Private Hire services in London and in the TfL consultation meetings on the Cycle Super Highway. We have also attended all the ULEZ consultation meetings organised by TfL, engaged with stakeholders including manufacturers, road users, influence groups and trade organisations. Our Chairman sits on the Mayor’s “Cabbie Cabinet” which meets quarterly to discuss strategic issues. The main strength of the LCDC is that all of its committee members are active and working London taxi drivers. This means our organisation is uniquely close to the key issues and attitudes of London taxi drivers.
2. The LCDC welcomes the opportunity to formally respond to the consultation and proposals for the introduction of the ULEZ in 2020 and the licensing of only zero emissions capable new taxis and private hire vehicles from January 2018. We also totally support the Mayor’s aims of reducing pollution and emissions in London, making our city a safer and more pleasant place to live and work in. In this response we will putting forward a number of positive recommendations to reduce taxi emissions in London.
3. This response concentrates on the effects of the TfL proposals on London’s taxi industry. The standard proposed by TfL for zero emissions capable taxis has been defined as: having an average CO2 emission of 50g/km; a capability of 30 miles continuous on battery power alone; and with a supporting internal combustion engine using petrol only; and the introduction of a 10-year age limit from September 2020. The 50g/km target compares with the EU agreed target of 95g/km by 2020.
4. We agree with Matthew Pencharz (Senior Policy Advisor to the Mayor) when he said that the proposed ULEZ scheme needs to be “fair, proportionate, reasonable andaffordable” (GLA Environment Committee 4th December 2014). Therefore any scheme to reduce emissions for London’s taxis should be: fair and reasonable because it should not disadvantage taxis compared to other businesses in London; it should be affordable for the taxi industry so that it does not put an unreasonable or intolerable economic burden on the taxi trade; and above all it should be proportionate and achievable because it adopts a technology standard that is capable of being supplied by manufacturers offering taxi drivers a choice of purpose built taxis.
5. Through the active involvement and discussions with all the stakeholders involved in the ULEZ meetings we have come to the conclusion that the outcome of the current proposals, if implemented, will be quite the opposite of the intention of the Mayor’s Senior Policy Advisor. The LCDC, along with the other taxi trade organisations as well as Private Hire bodies view the proposals as being: “unfair, unreasonable, disproportionate and certainly unaffordable.”
6. The LCDC makes a series of proposals to the Mayor to reduce emissions in London. These can be seen in our ‘Recommendations’ section. Instead of outlawing older cabs the Mayor should immediately incentivise the uptake of new Euro 6 standard taxis in London. These vehicles, with much lower polluting NOx emissions, promise to significantly reduce taxi pollution. Moreover, it is only sensible to introduce regulations which include hybrid or electric vehicles when those taxis are actually on the market. The Mayor’s policy should not be made on other people’s promises.
7. London’s taxis already have to meet some of the strictest standards in the world: a combination of the 25-foot turning circle requirement and the need to meet defined accessibility standards result in only two vehicles meeting the criteria and at a high average price of circa £40,000. This is more than double the cost of a typical saloon vehicle which is used by private hire drivers in London. The way in which the purpose built taxi driver has been able to make his vehicle economically justifiable has been through the ability to depreciate his taxi over a longer period of time. As a result London taxis are well known for their durability and high quality standards. Historically vehicles have lasted for at least 15 years, although this was capped from 2012 when a 15-year age limit was introduced.
8. However, the proposal to introduce a 10-year age limit will have a significant impact on the viability of the London taxi. In the current market a typical 10-year old taxi can have a re-sale value of £10,000. If the owner/driver is required to scrap or dispose of his taxi after 10-years then the scrappage cost for the total London fleet of 22,500 taxis would be at least £200 million. This is considerably in excess of the £40 million support being considered. At the GLA Environment Committee meeting on 4th December 2014 it was stated by Elliot Treharne of the GLA that the £40 million would be made available to the 7,000 drivers whose cabs would have reached 10 years old in 2020. This works out at £5,700 per taxi, or half the actual depreciation cost to be borne by the taxi owner. Moreover, it is hardly fair or reasonable NOT to also support taxi owners whose taxis become 10-years old in 2021-2024, 10 years after the 10-year age limit was first announced. Surely it cannot be fair to exclude taxi owners who bought taxis in 2013 when they were not aware of the proposed 10-year limit. Furthermore the economic impact on the remaining drivers will be such that it will seriously undermine the ‘business case’ for becoming a taxi driver.
9. Savings of up to £3,000 per annum have been suggested by converting to electric hybrid vehicles (Matthew Pencharz at GLA Environment Committee on 4th December 2014). We are not aware of this calculation and would like to see these being real world savings and not just a forecast. The Osaka syndrome where taxi drivers of electric vehicles tried to conserve energy by switching off their heaters and lights demonstrates the risks of assuming savings on electric vehicles (see report in Japan Today 20/2/13). London’s taxis working in an inner city environment, using more air conditioning, heating and stop/start energy will quickly use up the battery power. Moreover plug-in charge points may well prove to be expensive due TfL’s decision to privatise London’s charging points.
10. Hybrid vehicles meeting the proposed criteria will not be widely available, if at all, by 2018 and therefore will be more expensive due to the high capital investment required by manufacturers aiming to enter the market in 2018.
11. It is estimated by TfL that approximately 30% of London’s taxis would be forced off the road in 2020 (Michelle Dix at Royal Mint Court on 25th November 2014). As the economics argument becomes more difficult to justify in the taxi driver’s own mind then there is a significant risk that there may be a substantial fall in the number of taxi drivers and taxis in London. This would jeopardise accessibility and safety on London’s streets by taking at least 7,000 taxis off the road before they could be replaced. The Mayor and TfL would do well to understand the reasons for the growing tide of protests against TfL by the taxi trade.
Disproportionate and unachievable
12. Vehicle manufacturers have been committed to support the drive towards lower emissions through investing billions in the Euro standards regime with lower emission engines, hybrid technology and light weighting of components. Both the London Taxi Company and Mercedes-Benz will be introducing Euro 6 compliant engine technology during 2015. The Euro 6 standard represents a major shift down in terms of NOx emissions, making diesel emissions equivalent to petrol engines.
13. By 2020 motor manufacturers are aiming that their new vehicles will achieve a European target of average CO2 emissions of 95g/km. Yet the TfL proposed standard of 50g/km, is nearly half that European target level and it is claimed that manufacturers will have this technology ready for January 2018.
14. Of the three manufacturers quoted by Matthew Pencharz on 4th December being capable of producing zero emission capable taxis by 2018 only one is a current manufacturer. The other two do not currently have approved production-intent taxis on the market. We understand and agree with the position that Steve McNamara of the LTDA took on this matter (see his submission to GLA Environment Committee on 4th December 2014): there is too much at risk, too much uncertainty to frame regulations based on what some vehicle designers and manufacturers may or may not be capable of achieving in 2018.
15. We also endorse the late Barry Hooper when he wrote in his last TAXI magazine article (TAXI magazine 9th December 2014. Page 10). Barry cast doubt on the effects of the zero emissions proposal for taxis and the likely outcome with the manufacturers…. “So, where are we now? Nissan is out. Mercedes long term future in the trade is uncertain, but is probably also out……….The new Metro as far as I know is not yet in production and even if it does go into production will not be available for a year or two and the price tag will be very high. That means only one thing, a return to the bad old days at M&O, or LTC as it is now known………This is all down to the Mayor. He is pinning his plan on vehicles that are simply NOT available.” The LCDC would go further: the Mayor will legislate at his peril, and ours, based on the promises made by any vehicle manufacturer. We encourage the Mayor to wait until we see the green vehicles in place before putting the taxi trade at such severe risk.
Unfair and unreasonable
16. It is unreasonable for taxi drivers that TfL has set the Euro 6 standard for coaches, vans and HGV’s, which together account for 34% of London’s emissions, but it has set the zero emissions capable standard for the taxi and private hire industry which account for a lower 22% of London emissions. The TfL reason for only applying the Euro 6 standard to coaches, vans and HGV’s is that zero emissions is not available on these forms of transport (Michelle Dix in answer to questions at ULEZ conference at Royal Mint on 25/11/14). In our view it is reasonable that the same rationale should be applied to taxis and private hire. Or, at the very least, the Mayor and TfL should not consider introducing the zero emission standard until there are vehicles in operation, meeting these standards.
17. The LCDC expects the sales of new Euro 6 taxis to fall because of the fear and uncertainty of the proposed introduction of the age limit tied to zero emission taxis. Where will this leave the manufacturers, like the London Taxi Company who claim to have invested over £10 million* in achieving the Euro 6 standard for their TX4 taxi? Without a return on the Euro 6 investment how can the main supplier hope to carry through its future investments? (* source: claim made by Dave Oriel of LTC at ULEZ meeting, TfL offices, 55 Broadway on 10th December 2014)
Euro 6 standard and the taxi duty cycle
18. The introduction of the Euro 6 standard is recognised by TfL and manufacturers as representing a major change in reducing emissions. Diesel vehicles, including taxis, which will be available from next year will considerably reduce NOx emissions to similar levels compared to petrol vehicles. Our view is that if TfL wish to have a major impact on quickly reducing emissions coming from taxis then there should be an accelerated programme of incentivising the uptake of Euro 6. The table below shows how the NOx levels of a Euro 6 diesel vehicle will be some 84% lower than the NOx levels of a Euro 3 vehicle.
Source: SMMT see: http://www.smmt.co.uk/industry-topics/air-quality/#responsiveTabs3
19. Much has been made of the introduction of the NEDC (New European Driving Cycle) standard of testing which will be applied to new Euro 6 vehicles. This is aimed at overcoming some of the criticism of the previous testing regime because it did not reflect the real world driving. The new testing standard also includes some on road driving. However we believe that even this test is inappropriate and will not reflect the real world in London. TfL’s own road cycle for central London (ref. TfL Travel in London Report 3 fig 4.1) shows much lower speeds than the NEDC R101 test cycle, and even then a significant proportion of the area considered was outside the ULEZ. Moreover the duty cycle of London’s taxi fleet is quite different from a car or van working in London. Taxi work involves much more stopping with engine running or stop/starting (on ranks) and slow ‘trawling’ looking for work; along with acceleration and higher speeds for runs to Heathrow and Gatwick. The LCDC consulted several of its members and these drivers estimate that as much as 30% of their time is ‘dead’ mileage. Therefore it is strongly recommended that TfL understand the real taxi duty cycle and the emissions on any taxi model coming into London by developing a London taxi duty cycle. From this TfL would be able to gauge real world emissions of taxi and develop targeted standards accordingly.
20. The distinction between petrol and diesel, where TfL intend to allow only petrol engines in new taxis from 2018, is inappropriate. Whilst we understand the arguments behind reducing the number of polluting diesels on the road, it is also recognised that the new Euro 6 diesels provide reduced NOx emissions very similar to equivalent to petrol vehicles. Also, diesel engines are inherently more efficient and produce better CO2 figures and economy per vehicle than petrol engines. See SMMT New Car CO2 Report 2014 at http://www.smmt.co.uk/wp-content/uploads/sites/2/SMMT-New-Car-CO2-Report- 2014-final1.pdf
21. 30 miles zero emission capability is specified but the type of hybrid vehicle also needs to be appropriate. Thus, parallel hybrids are more appropriate for inter-city or suburban work, with longer journeys: parallel hybrids are low range EV’s with small batteries. Whereas series hybrids can deliver longer continuous zero emissions but need larger batteries for inner city work. The disadvantage with series hybrids is that the larger batteries require more re-charging to deliver the performance target of 30 miles zero emissions, and may not be achievable when undergoing the normal taxi duty cycle.
22. The aim of achieving 50g/km CO2 emission is incompatible with the requirement to have 30 miles zero emission range. This will require vehicles to have to have substantial and heavy battery packs which will increase weight and therefore also increase the non- electric fuel consumption and CO2 emissions.
23. There is no certainty at all where geographically the 30 miles of battery powered zero emissions will take place. What if the zero emissions occur completely outside the ULEZ zone, when the taxi driver is travelling into or out of work? Unless a most technologically complicated system of geo-fencing is employed then there can be no certainty that any of the zero emissions will be in the ULEZ.
24. The NEDC is short, it allows high use of plug-in hybrid’s battery capacity. Under typical taxi mileage of 70-100 miles per day 50g/km will not be achieved. If battery use is exhausted in ULEZ then the remaining mileage will be significantly higher than 50g/km.
Summary and recommendations
25. The 10-year age limit and new more expensive taxis will be extremely damaging to the taxi trade. Even with the proposed TfL incentives many drivers may leave the trade and new drivers may opt to go to private hire. This will by definition reduce the provision of safe, accessible transport for London’s population.
26. Recommendation 1. We strongly recommend that the Mayor waits until the technology is in place and working before introducing the TfL proposals for zero emission taxis from 2018. There is a significant level of risk that no manufacturer will be able to meet the proposed zero emission requirements and at a true London taxi duty cycle. To frame policy before the technology is available and proven is not responsible. The Mayor should declare his intention to introduce the 50g/km target but only when a minimum of 2 vehicle manufacturers can demonstrate they can produce taxis to at least a volume of 1,000 each per annum. If a zero emission target is introduced then it also must be capable of being programmed so it works in the ULEZ zone.
27. Recommendation 2. TfL should encourage sales of Euro 6 diesel engine taxis as the fastest most practical way of reducing taxi emissions in London. This could be done by providing some level of purchase incentive on Euro 6 taxis.
28. Recommendation 3. The Mayor should require TfL to introduce a standard taxi duty cycle which sets the emissions testing measurement for any taxi vehicle which is introduced into London, to hit the 50g/km target or whatever target is agreed as achievable.