Sutton Council calls on the Mayor of London to rethink his expansion of ULEZ

Sutton Council has formally responded to the Mayor of London’s ULEZ expansion proposal saying it cannot back the ULEZ expansion as currently proposed. 

Councillor Barry Lewis, Chair of Sutton Council’s Environment & Sustainable Transport Committee wrote to the Mayor of London, Sadiq Khan on Friday outlining the Council’s objections.

“Whilst we welcome initiatives which may improve air quality and people’s health, any expansion of the ULEZ to Sutton must be accompanied by significant investment in public transport, better cycling and walking infrastructure, a fair and comprehensive scrappage scheme and an extension of the planned implementation date”. 

In the letter to the Mayor, Councillor Lewis highlighted the concerns of local residents about the scheme that must be considered and responded to before any expansion is agreed. This included the lack of investment in Sutton’s sustainable travel infrastructure compared to the extensive investment in inner London before the ULEZ was implemented there.

“We have not had our fair share of investment in public transport infrastructure and services from the Government and London’s Mayors. Greater London Authority research* shows that the London Mayors have invested less money in Sutton than any other borough. Sutton has received the lowest amount of transport investment per resident of any London Borough since Mayor Khan was first elected in 2016. Even excluding those Boroughs that have benefited from Crossrail, or those in Inner London, other boroughs such as Richmond upon Thames have received £1,911 investment in transport per resident while Sutton has received just £73”. 

In light of the costs the proposal will impose on those travelling from outside London to shop, work and do business in Sutton, Councillor Lewis added “The proposal needs to demonstrate that it is being fair on Sutton, with any potential economic impacts on our town centre, district centres, the London Cancer Hub and industrial centres being fully assessed”. 

The letter from Councillor Lewis, Chair of Sutton Council’s Environment & Sustainable Transport Committee

Dear Mayor Khan, 

Thank you for the opportunity to comment on the proposed ULEZ expansion. We cannot back the ULEZ expansion as currently proposed. Whilst we welcome initiatives which may improve air quality and people’s health, any expansion of the ULEZ to Sutton must be accompanied by significant investment in public transport, better cycling and walking infrastructure, a fair and comprehensive scrappage scheme and an extension of the planned implementation date. 

We have always been committed to protecting and improving the environment for future generations, we have made a climate emergency declaration and are committed to delivering a climate emergency response plan across the borough. This includes a wide range of programmes such as tree planting, delivering sustainable and award winning school buildings, directly engaging with business, residents and schools on education and pledges to support our ambitious plans. We are investing in electric vehicle charging with TfL’s support and have also introduced ten school streets, with a second phase to follow soon. 

With the current cost of living crisis and higher fuel costs, due consideration must be given to adding to residents financial burdens, so any proposal must reflect the equity issues about affordability of new vehicles, which is more likely to hit those on lower wages hardest. 

This will also apply to our staff and contractors who deliver key services within the borough and as such may incur the daily charges, for example the NHS, social workers, care staff, emergency services personnel and waste collection operatives.This will include people who travel between London and Surrey, where we know areas are even less well served by public transport than the borough is. 

Our key concerns are set out below, which must be considered and responded to before any expansion is agreed. 

Investment in public transport 

We have not had our fair share of investment in public transport infrastructure and services from the Government and London’s Mayors. Greater London Authority research ('Mapping the Mayor's Strategies' 2019) shows that the London Mayor’s have invested less money in Sutton than any other borough. Sutton has received the lowest amount of transport investment per resident of any London Borough since you were elected in 2016. Even excluding those Boroughs that have

benefited from Crossrail, or those in Inner London, other boroughs such as Richmond upon Thames have received £1,911 investment in transport per resident while Sutton has received just £73. 

The borough is relatively inaccessible by public transport, as shown by poor Public Transport Accessibility Levels. This is due to the lack of underground, overground or tram services, poor orbital rail links and large areas with low train and bus frequencies. 

People need affordable, accessible and safe modes of public transport so that they can get around the borough, to be able to work and to study and to take advantage of the huge cultural benefits that our borough has to offer. For our part, we demand that any expansion of ULEZ must be accompanied by investment in Sutton’s public transport. We expect to see a real and sustained improvement in the frequency and quality of our public transport system to support residents to make the transition to cleaner modes of transport, as they were able to in central/inner London before the ULEZ was introduced there. 

Projects like the Sutton Tram and the on-demand Go Sutton bus have been shelved and for many years our borough has received a tiny amount of Local Implementation Plan (LIP) funding compared to other London boroughs, which has made it impossible to develop plans for more sustainable ways of travelling. We are bidding for Levelling Up funds to improve the train route and frequency to Belmont, where we will see the London Cancer Hub evolve in the coming years, so this investment is vital. 

Better cycling and walking infrastructure 

The proposals need to be supported by significant investment in cycling and walking schemes to give those who are able alternative choices for short journeys, to encourage people to reduce their reliance on the motor vehicle. When TfL moved to a formula based approach to allocating LIP funding to the boroughs we were a big loser, receiving the smallest allocation of all the boroughs across London, limiting our ability to deliver the infrastructure to support step changes needed in modal shift. 

Our annual settlement for the LIP programme has been just over £1M, with variable levels of funding for workstreams to support the Cycling Network and Bus Priority measures, and whilst we are encouraged by TfL to support borough-wide lower speed limits and Vision Zero and Healthy Streets programmes it is vital that to achieve significant changes in modal shift, particularly for shorter trips, an increase in funding levels above those recently awarded are needed. 

A fair and comprehensive scrappage scheme 

It is considered that as a minimum, a scrappage scheme for cars needs to be easy to access and should be targeted at key groups such as those Londoners on low income and people on non means tested disability benefits. Any scheme must also involve an extensive awareness campaign for everyone but especially disability groups and those who provide informal care to older and disabled people. There will need to be assistance with applications for the scrappage scheme available to all who need it. TfL should also consider greater targeting of a new scrappage scheme

for vans by focusing eligibility on micro businesses (up to 9 employees) to allow more business owners to benefit, including those who have businesses in Surrey but operate in Sutton. 

For many people in Sutton, until the appropriate investment in public transport is made, car use is the only reliable way to access employment and learning opportunities, and for them a ULEZ introduced without an adequate scrappage scheme risks being a retrograde step. Our residents are unfairly penalised because they are more likely to own a car, more likely to need a car, and less able to find alternatives with many non compliant vehicles owned by those on lower incomes. It is essential that any proposal provides comprehensive details of a fully funded, easily accessible scrappage scheme. 

TfL estimates that vehicle compliance rates, across the whole of outer London, at time of introduction will be 92% within the ULEZ. Current figures indicate that approximately 70% of the cars in Sutton are compliant, which suggests that 22% of car owners across the borough will need to change their car in the next year to meet the currently proposed start date of the scheme. Given the factors set out around the cost of living crisis, availability of public transport and a suitable scrappage scheme, this is an unreasonable and over ambitious target. 

An extension of the planned implementation date 

It is clear that the proposal is being rushed and there has been insufficient time to prepare for the proposed expansion of the ULEZ scheme to outer London. If the scheme is to go ahead, subject to the requirements and issues highlighted in this letter, more time is needed to enable residents and businesses to prepare and where necessary change their vehicles. The wait times for many electric and other zero emission vehicles will already extend beyond the proposed implementation date and the global shortage of the essential computer chips and electrical components mean these wait times will only become longer as demand increases, with trade magazines reporting that some manufacturers have suspended taking new orders until backlogs are cleared. It is, however, noted that other compliant vehicles are available, but clearly the lack of electric and zero emission vehicles will undermine the transition towards the targets set out in this consultation. The implementation date must be extended. 

Other concerns 

The proposal needs to demonstrate that it is being fair on Sutton, with any potential economic impacts on our town centre, district centres, the London Cancer Hub and industrial centres being fully assessed. 

It is important to fully understand how the ULEZ will change the chemistry of the local atmosphere as a whole. Whilst we bring down the levels of one pollutant, we do not want to create any adverse effects on others. In order for any ULEZ expansion to be successful, there is a need to monitor PM2.5 more closely and gain a better understanding on how the ULEZ will affect concentrations. The consultation document does not reveal any statistics on the concentrations of PM2.5, which is considered to be the most harmful pollutant to human health.

The proposal will require a large number of new CCTV ANPR cameras to be installed at the entry points to the zone, and inside the zone this may lead to some clashes with existing infrastructure (wireless connections) so it is vitally important that the design phase allows time to assess and address any potential conflicts. 

There will need to be clear information on exemptions; who are they for and how will they work, and how will they tie in with other schemes operating in London. 

Yours sincerely, 

Councillor Barry Lewis 
Chair of Environment & Sustainable Transport Committee