Despite focus on how PSVAR is applied to coaches and almost weekly news surrounding Clean Air Zones and Scotland’s Low Emission Zones (LEZs), it should not be forgotten that the London Low Emission Zone will see significant change to how it is applied on 26 October 2020.
Its physical size will not alter. It will continue to encompass almost all roads in Greater London, with a small number of exceptions that are principally motorways.
But the emission standard that must be met by “heavy vehicles” – including coaches and buses with a GVW of over 5,000kg – will be tightened from then. Euro VI will be required if hefty daily charges are to be avoided.
London Low Emission Zone: Euro VI required in 2020
Euro VI is already required in London’s Ultra Low Emission Zone (ULEZ). If your coach or bus does not meet this higher standard for the LEZ from next year, but does satisfy either Euro IV or Euro V, it will be liable to a daily charge of £100 to enter the LEZ.
If it does not meet Euro IV, then the daily charge to access the future LEZ will be £300. That represents a £100 increase over the charge for such a coach or bus to enter the LEZ in its current form.
If your vehicle is liable for charges to enter the future LEZ, and then continues into the ULEZ, no additional fee will be levied.
Penalties for late payment of charges
Penalties for the forthcoming London Low Emission Zone – which are applied when a charge is not paid by midnight of the next working day after travel – will remain £1,000, or if settled within 14 days, £500.
It should be remembered that two major draws for coach traffic – Heathrow Airport and Wembley Stadium – are within the LEZ. Coaches that serve them will thus need to be Euro VI compliant from October 2020 if charges are to be avoided.
Like the ULEZ, the LEZ day runs from midnight to midnight. As a result, if your non-compliant vehicle is driven in the zone across that time point, two daily charges will be payable. Vehicles that park within the zone, but are not driven for the duration of the day, will not attract a charge.
No part of the M25 falls within the LEZ, meaning that non-Euro VI coaches circumnavigating London will not be subject to charges.
Minicoaches and minibuses with a GVW of 5,000kg or below will see no change to their current LEZ entry requirements. As a result, restrictions around the majority of small PCVs will continue as is.
However, they will be subject to changes to the ULEZ from 25 October 2021, when it is extended to (but not including) the North Circular Road and South Circular Road.
NOx comes into scope in updated LEZ
Currently, LEZ standards are concerned only with particulate matter (PM). There is no measurement of NOx. That will change when controls alter next year. At that point, NOx measurements will come into scope of the LEZ.
That will have no impact on operators. If they have a vehicle that is Euro VI compliant – either as OEM or via exhaust retrofit – it will automatically satisfy the ‘new’ LEZ.
The benefit of the current LEZ’s measurement only of PM is that it allows a relatively easy upgrade using a particulate filter. Much more than that is required to achieve Euro VI, so the addition of NOx standards to LEZ requirements is moot.
Worries about enforcement method
Where conflict may arise is with how records are kept of vehicle emissions compliance. It is not yet known which database against which charges will be issued.
Two exist: One for the current LEZ and the other for the ULEZ, reflecting the variance in standards that are required between the two. Because the tightened LEZ effectively represents an extension of the current ULEZ, it has been suggested that the ULEZ database may be used for LEZ enforcement come October 2020.
As is well known, implementation of the ULEZ has not been without problem. Many coaches that comply with Euro VI have received incorrectly issued penalty charges and they continue to be issued in error.
While in most cases Transport for London (TfL) accepts operators’ appeals when that happens, the time implication for them of having to submit appeals is significant.
However, it is understood that in a handful of cases TfL has pushed for payment despite the operator having proved Euro VI compliance by using the vehicle’s V5. Only after the intervention of an outside body has it backed down.
Operators will hope that such a charade does not extend to the LEZ in October 2020.
routeone comment
Changes to the London LEZ have been known about for some time, but they have not been seized upon in the same way as the capital’s ULEZ was at its introduction earlier in 2019.
But October 2020’s change is an important one. It has been suggested that a significant proportion of coach movements within London do not access the ULEZ. As a result, when the requirement for Euro VI grows to take in almost all the area within the M25, many more will come into scope of potential charges.
A £100 daily fee may be acceptable to operators that visit places like Heathrow, Wembley and central London on an occasional basis. The £300 that will be chargeable for pre-Euro IV coaches will be more difficult to justify; it will equate to around £6 per seat.
