Can London’s industrial core survive the ULEZ expansion?

London – a hub of creativity, industry and opportunity. However, the “Big Smoke” is also known for its other attributes: grey skies, heavy congestion and polluted air. Over the last decade, the knowledge and visibility of air quality issues have increased on the political, academic and public agendas.

Ultra Low Emission Zones (ULEZ) were introduced in London in April 2019 to combat air pollution

Legal air quality limits for NO2 and PM10 are regularly exceeded across London, mainly as a result of transport emissions, wood burning stoves, construction activities and domestic heating. The health repercussions related to exposure of those living in the areas where these limits are exceeded are well-documented and ever growing.

As of 1 April 2019, two million Londoners live in areas with illegally poor air quality, 400,000 of which are children.

Sadiq Khan, Mayor of London, 2019.
The latest data shows that two million Londoners are living with illegal toxic air.

To address these issues, authorities across London including Transport for London and the Mayor of London have worked collaboratively to develop and implement the Ultra Low Emission Zone (ULEZ).

First introduced in April 2019, vehicles within the zone must meet stringent emissions standards or pay a daily charge. The ULEZ operates across the existing congestion charge zone (covering most of Central London, and areas of the City and Westminster) and operates 24 hours a day, every day of the year. Vehicles that do not meet emission standards must pay a daily charge:

  • £12.50 for cars, motorcycles and vans
  • £100 for lorries, buses and coaches
  • Additional £100 for diesel HGVs, specialist vehicles, coaches and buses (a result of the separate Low Emission Zone, which covers Greater London areas within the M25).

In October 2021, a considerable expansion to the ULEZ will include all areas of inner London bounded by the North/South Circular, alongside the introduction of a Low Emission Zone (LEZ) that covers Greater London within the M25.

The Covid-19 pandemic led to the ULEZ charges being temporarily paused, but its reintroduction is a requirement for the recent TfL bailout. The bailout urges TfL to bring forward proposals to widen the scope and levels of these ULEZ charges. This may lead to an increase in the fees polluting vehicles are subject to, as well as further expansion to the zone.

A research project has been undertaken by Buro Happold’s Air Quality team, exploring the impacts of the ULEZ, how development in London is preparing for the extension to the zone, and what this may mean for future schemes. Nine interviews were conducted with planning consultants to inform this work.

Across all interviewees it was clear that the ULEZ had not been a material issue or consideration for any projects at this stage. However, it was widely agreed that as the zone extends, this issue will become more problematic. Generally, the impacts were not understood or considered, despite the zone extension happening by the end of 2021.

One interviewee noted that more schemes are moving towards cleaner industrial use, distribution centres and warehousing facilities with electric vehicle options, and that this trend may continue. Another interviewee felt that the extended ULEZ puts the value of industrial land at risk, stating:

Employment uses have become viable for the first time since I’ve been working in planning. It used to be the case, if it was an employment site, you could make an argument that would never be occupied again and there was no market for it. Now, certain locations are of high value, in fact, they are competing with residential use in certain places. For these businesses to be hit with new costs, the impact could be significant.

Research project interviewee, Buro Happold Air Quality Report

Another issue raised in the interviews was the risk of relocating the air quality issues. If businesses choose to relocate out of the zone, will areas just outside of the North/South Circular be disproportionately impacted? Many of these areas are already exceeding legal limits, and an increase in vehicles circumventing the ULEZ may lead to significantly higher concentrations of pollutants.

Heavy industries could be forced to relocate outside of London and expand into greenbelt areas

The effectiveness of the ULEZ in terms of air quality improvements is difficult to gauge, given the short period of time for which it has been operational. However, early signs are showing considerable improvements to pollutant concentrations and numbers of polluting vehicles entering the zone:

  • For the period July to September 2019, NO2 concentrations at roadside locations in central London were on average 24µg/m3 lower, equating to a reduction of 29%
  • From March to September 2019 there was a large reduction in the number of older, more polluting, non-compliant vehicles detected in the zone: some 13,500 fewer on an average day, a reduction of 38%. 

The ULEZ will have significant impacts on businesses, especially those that require larger vehicles. Whilst there is an abundance of ULEZ compliant alternatives for smaller vans and private vehicles, these alternatives become increasingly limited and expensive as vehicle size increases.

Industries that rely on heavy goods vehicles that may have low profit margins and significant overheads. For example, waste consolidation, aggregate storage, and manufacturing plants are left with two options; move out of the zone or pay the daily ULEZ charge. It is not difficult to envisage these industries relocating out of the ULEZ. Ultimately, this does not decrease the air quality impacts of their operation, it merely displaces them.

Meanwhile, the “Intend to Publish” London Plan requires the protection of industrial land through the “Strategic Industrial Land” (SIL) and “Locally Significant Industrial Sites” (LSIS) land classification. Policies within the document promote “no net loss of industrial floorspace within designated land classes” including SIL and LSIS. Does this lead to a conflict between the ULEZ and the London Plan? Where does this leave industry that cannot afford to operate in the ULEZ, or industries that require vehicles without low emission alternatives? Will only industries that use smaller vehicles remain?

Does this suggest those living in central areas in London have the right to clean air, whereas those on the outskirts do not? There is also the issue that many of the impacted industries will have a client base solely located within the ULEZ, but as they are pushed away from their clients, those outside of the ULEZ will begin to suffer as a direct result of their emissions.

The new ULEZ charges will improve air quality issues and congestion in Central London

There are many questions that remain unanswered around the impacts of the ULEZ on industry and planning. Early signs are demonstrating that it will help to address the air quality issues in the capital, but at what cost to heavy industries and services for Londoners? Will emissions be reduced or merely relocated?

Buro Happold is continuing to explore this issue as the ULEZ expands and our research will ensure that we are in a position to offer meaningful advice to clients that address the environment, health, and day to day needs for all Londoners.


Written by

Peter Henshaw and Connor Rusby

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