The fact that community transport groups (CTGs) operating under Section 19 or 22 permits do not need to worry about the effects of LEZs and ULEZs until 2023 – as their vehicles, no matter how old they are and what emission specification – is like some Alice in Wonderland situation.
These groups have an operating cost base which is lower than a commercial operator’s, and this exemption will make the gap even wider.
Out of 32 London boroughs, 14 operate their own fleets of minibuses on a S19 permit and the rest contract the work out either to arm’s length companies or CTGs. There is also 25 CTGs who are operating in the London boroughs, earning substantial sums of money.
TfL has said that, while it does not have any permit operations itself, it contracts the transport to nine London-based CTGs and this has a current value of £3,400,000pa.
If you factor in all the CTGs working on the edge of London who travel in every day to the ULEZ, you are talking about many thousands of vehicles that are going to be exempt from all of this.
I would say that it is very important that CPT and LTCOA start lobbying TfL without delay.
Ian Ashman, Tyne & Wear