Transport for London’s new Ultra Low Emission Zone (ULEZ) will be in force 24/7 within the current Congestion Charge (CC) or T-Zone area from 8 April this year. Motorcycles are not subject to congestion charging but most vehicles, including all powered two-wheelers, will need to meet the ULEZ’s exhaust emissions standards or be subject to a daily £12.50 charge. Or, worse still, a £160 fine (originally £130), reduced to £80 (originally £65) if paid within a fortnight. This is despite TfL’s own data showing that motorcycles and scooters are responsible for less than 1% of London’s traffic pollution.
So what makes a moped, scooter, motorcycle, trike or quad ULEZ compliant? If your machine meets Euro3 emissions standards – mandatory for all machines sold new from 1 July 2007 – then you won’t be subject to the ULEZ charge, and nor will you be if it’s in the Historic Vehicle taxation class by being 40 years old or more. If you’re resident within the current CC zone then there’s a ‘sunset period’ during which you’ll not be liable for the ULEZ charge until 24 October 2021, assuming your bike is non ULEZ-compliant.
To check your machine’s compliance, TfL has a handy online registration checker which quickly informs you as to whether you’ll be subject to the ULEZ charge or not. Except that it doesn’t, at least not in all cases.
TfL’s website states, “The ULEZ will be enforced based on the declared emissions of the vehicle rather than the age – but generally speaking Euro3 engines as those registered with the DVLA after July 2007.” In terms of emissions, the Euro3 standards for two-wheelers are Carbon Monoxide (CO) 2.00g/km, Hydrocarbons (HC) 0.80g/km (≥150cc) or 0.30g/km (<150cc) and Nitrogen Oxides (NOx) 0.15g/km.
With the words “generally speaking” indicating that things were less than crystal clear, last year owners of pre-Euro3 machines (this writer included) entered their registration numbers into the checker to find that they were indeed compliant. This is possibly because the bikes were, in terms of emissions, Euro3 compliant prior to July 2007 anyway.
Then late last year and early this year those same owners entered the same numbers into the checker again, to find that their bikes were no longer ULEZ compliant. Unannounced, and for reasons known only to TfL, the goalposts had moved, although TfL offers an explanation in a letter it sent in June 2018 which says ”we are in the process of compiling vehicle compliance data and refreshing our database on a regular basis between now and the introduction of the ULEZ 8 April 2019”.
Another letter from TfL, sent in early January this year (see below) doesn’t address the shifting goalposts issue, but it does provide evidence that it is only the NOx figure that is applicable to ULEZ and not the CO or HC values.
Frustratingly for TfL, it can’t enforce full Euro3 emissions compliance for ULEZ as NOx alone was part of an EU directive which later became legally binding in the UK. According to a letter by London’s Mayor Sadiq Khan dated 10 Nov 2017, “The ULEZ standards need to be set on a legally recognised and approved engine test cycle, such as those required to achieve the European emissions standards”.
Without knowing every pre-Euro3 model’s NOx figure, it’s likely that a significant number of pre-Euro3 two-wheelers, big BMWs and Harley-Davidsons included, will be sub 0.15g/km NOx and therefore be ULEZ compliant despite recent registration checker results.
So, if you intend to ride into the ULEZ zone on your pre July 2007/Euro3 machine without forking out £12.50 a day then here’s what to do:
- Even if you’ve checked before, check your registration number again with TfL’s online checker. If it’s not subject to ULEZ then no further action required (although it’d be wise to check again prior to 8 April).
- If it does show as subject to the charge then check your V5C for an NOx figure if quoted, and if under 0.15g/km then submit a copy of it to TfL (see letter below).
- If an NOx figure isn’t quoted on your V5C then you’ll need a Certificate of Conformity (CoC) and you should follow the advice in TfL’s letter.
At the time of writing, manufacturers are dealing with emissions/CoC requests in different ways, while some are still formulating their procedure. Some are providing owners with CoCs free of charge (eg. https://wiki.mag-uk.org/images/6/60/Honda_form.pdf) while others require a significant admin fee (up to £180), although for daily commuters the varying fees would soon be recouped, and a CoC is likely to be much less costly than trading your machine for a newer one. Best to contact the manufacturer’s customer services dept and ask.
If for whatever reason those steps aren’t applicable to your bike then you may choose to obtain Motorcycle Single Vehicle Approval, although this process is more involved so you should be confident in advance that your machine will be compliant.
It would be much less hassle for all concerned if TfL’s registration checker results were based solely on the NOx figure, but it could be that not even the DVLA’s database contains emissions info for all pre-Euro3/July 2007 machines that are under 40 years old.
The process could also be greatly simplified if once one model has been exempted then all those models of similar age could also become exempt. Alternatively, if manufacturers were to provide TfL with all their relevant models’ NOx values then those that complied could then show up as ULEZ-exempt, as was possibly the case previously. As things currently stand though, all requests are being handled by TfL on an individual basis.
Looking ahead, and subject to London’s Mayor Sadiq Khan being re-elected in May 2020, it’s planned that the ULEZ will extend to cover the 170 square miles within the North and South Circular roads on 20th October 2021, so countless more owners and their vehicles will be affected.
Meanwhile the Motorcycle Action Group is on the case, talking to manufacturers with regard to provision of emissions data, and asking TfL for greater clarity with the ultimate aim of all powered two wheelers becoming ULEZ exempt, as MAG has already achieved with Birmingham’s Clean Air Zone due Jan 2020.