ULEZ and the Dark Green Transition

Two weeks ago, the Ultra-low Emission Zone (ULEZ) was extended to the outer London boroughs, which now includes our service area at work. This extension is enforced through over 3000 cameras and carries heavy penalties. However, it has proven unpopular among certain sectors of the community, leading to protests, acts of vandalism targeting the cameras, and resistance from specific political camps, along with legal challenges.

From our perspective at Little Oak, this ULEZ extension will result in an additional annual cost of £7200 unless we upgrade all our vehicles to compliant ones, which would entail an approximate expense of £100,000. This cost will either need to be passed on to our customers or absorbed by our company, depending on market conditions. Given the current challenges of high inflation, high interest rates, and a faltering economy, the ULEZ will undoubtedly place an extra financial burden on small businesses like ours. This also holds true for affected individuals and families who are already grappling with the escalating cost of living.

However, it's important to acknowledge that air pollution is a serious issue in London that demands attention. If we are to meet Net Zero targets, there will inevitably be associated costs. According to the Mayor of London, only about 10% of vehicles in London are non-compliant, so the environmental benefits of this extension may be somewhat limited. Nevertheless, it does represent a step forward in addressing environmental concerns.

Taking a broader perspective, there are several aspects of this situation that seem incongruous:

1.     Prioritizing Polluters: In our service area, the most significant contributor to air pollution is the Beddington Farmlands incinerator, responsible for emitting 300,000 tonnes of CO2 annually along with other pollutants. Surprisingly, incinerators like this one are not taxed for their carbon emissions or regulated through mandatory carbon credit markets. This unmitigated pollution remains the largest single source of CO2 emissions in our London Borough.

2.     Loss of Green Spaces: The continual destruction of green spaces, such as Beddington Farmlands, the de-designation of Metropolitan Open Land (MOL) and green belt areas, the removal of trees and carbon-absorbing plants, and the reduction of garden biodiversity, including the proliferation of non-permeable surfaces, collectively contribute to a loss of carbon sequestration in South London.

3.     Vehicle Replacement: The wholesale replacement of working vehicles with new ones for carbon accounting gains is a subject of debate. Manufacturing, engineering, and transporting brand new vehicles across the global market incur a substantial carbon footprint. It may make more sense to replace older fossil fuel vehicles only after maximizing their use, as they too contribute to a carbon footprint legacy. With only 10% of vehicles in London being non-compliant, this transition was already underway as older vehicles were being replaced with Euro 6-grade compliant vehicles.

4.     Financial Impact: Channeling significant funds into City Hall and bearing the associated costs of monitoring and enforcing the ULEZ does not directly alleviate air pollution. Essentially, those who pay daily fees are essentially paying for the privilege to pollute, with the funds potentially disappearing into bureaucratic channels rather than being invested in actual environmental improvements.

5.     Environmental Tax and Financial Pressures: This environmental tax adds to the financial pressures faced by Londoners. It reduces their ability to afford environmentally friendly products or invest in natural capital, such as tree planting and biodiversity improvements, as well as supporting charities and participating in natural capital markets. The funds diverted to manufacturers and City Hall represent missed opportunities for investments in eco-social projects and land for nature preservation.

Given these considerations, we believe that our London Borough (Sutton) could benefit from

the following actions:

1.     Prioritize Major Polluters: Address the biggest polluters first, such as KKR Inc. & Co./Viridor/Valencia, a billion-dollar global asset management company responsible for significant ecological and environmental damage at Beddington Farmlands. The incinerator, a major CO2 and air pollutant source, remains unregulated and untaxed, despite its significant impact. KKR should fulfill its obligations to create wetlands and plant trees to mitigate its environmental impact.

2.     Protect Green Spaces: Halt the destruction of green spaces by preventing the de-designation of protected lands that are being sold to industrial interests. Local examples include the de-designation and sale of Beddington Lane frontage to Beddington Farmlands for warehouse use.

3.     Promote Biodiversity: Introduce regulations to safeguard garden trees and biodiversity, limiting non-permeable surfaces and astro-turf in private gardens. Encourage private tree planting and biodiversity net gain.

4.     Plant More Trees: Invest in tree planting initiatives throughout the borough, including parks and streets, and incentivize private tree planting and carbon sequestration.

5.     Support Sustainable Markets: Develop sustainable markets and shift more responsibility for the green transition to manufacturers and businesses, those better equipped to afford it. Continue the development of carbon and natural capital markets to reflect environmental costs in product prices, discouraging unsustainable goods while incentivizing sustainable ones. Londoners need the financial means to support these sustainable markets, making taxes a less effective means of achieving environmental goals.

6.     Assist Small Businesses: Provide additional support to small companies and individuals struggling to adapt to the ULEZ.

In conclusion, the current approach of taxing regular people to achieve environmental objectives can perpetuate inequality and allow major polluters to continue their practices unchecked. We don't need a Dark Green Transition that is oppressive and counterproductive, we need a just and fair Green Transition that holds the most powerful entities accountable. The primary responsibility for the Green Transition should rest with Big Business and those with the means to enact meaningful change. Placing the burden on the most vulnerable in society is oppressive and counterproductive. In our borough, KKR & Co. Inc., as a major polluter and source of environmental destruction, should be a top priority. We need a Green Transition that is both effective and equitable, ensuring that the biggest polluters are held accountable.