ULEZ expansion: damaging, dishonest, and a disgrace to democracy

From: Neil Lock

To: Jeremy Hunt MP, South-West Surrey (jeremy.hunt.mp@parliament.uk)

Copies to:

11 September 2023

Dear Mr Hunt

ULEZ expansion: damaging, dishonest, and a disgrace to democracy

I write to protest in the strongest possible terms about the recent expansion of the ULEZ ultra-low emissions zone to the whole of Outer London. This is already causing serious damage to the lives and livelihoods of many innocent people. Having bought their cars in good faith, they deserve to be able to run them without any penalty, all the way to the end of the lifetimes they were built for. And yet, this ULEZ expansion will take away entirely the mobility of many older or poorer people in Outer London, who cannot afford either to pay the charges or to upgrade their cars. As well as harming, or even bankrupting, tradesmen who are themselves, or whose customers are, in the same situations. It’s often not feasible for such people to use public transport; and for some, the public transport isn’t even there. As Cllr Colin Smith of Bromley Council has put it: “ULEZ has very little, if anything, to do with health and is nothing less than a barely disguised socially regressive tax which is now set to destroy businesses, jobs and vital social and support networks.”

I myself lived in outer London in the early 1980s, when air pollution was far worse than it is now. With the exception of diesel buses, I did not notice any significant air pollution. And I was a cyclist in those days. Measurements of pollutants on the roads of outer London now show no problems at all relative to current air quality standards. (Except, perhaps, for pollution from Tube trains!) Most people are now aware of these things. So, we know that the ULEZ expansion is objectively unjustified, and no more than a money-grab by Sadiq Khan.

Moreover, prime minister Rishi Sunak said recently: “I just want to make sure people know that I’m on their side in supporting them to use their cars to do all the things that matter to them.” And yet, he has failed to follow this up by acting to postpone or cancel the expansion. This calls into serious question whether Sunak is dealing in good faith with the people he is supposed to serve. It also raises concerns about the directions in which government, of whatever party, wishes to take us in the future.

And let’s not forget the history. In 2017, ULEZ was only a gleam in Khan’s kleptocratic eye. In 2019, it came into effect in central London only. Only the “city slickers” were affected, so why should ordinary people worry? Then in 2021, Khan extended it everywhere inside the North and South Circulars. Making inner London a “no go” area for those of us who live outside. Now in 2023, he has extended it to all the London boroughs. If Khan is allowed to get away with this, what will stop ULEZ or similar schemes being extended to the whole of the Home Counties in 2025, every town and city in the UK in 2027, and nationwide in 2029?

There seems today to be a political agenda to make car driving unaffordable and all but unfeasible for ordinary people. While enriching both government as a whole, and activist elements within it, particularly at the local level.

As if the damage caused by ULEZ expansion, now and in the future, was not enough, there have also been many instances of dishonest behaviour shown by those on the pro-ULEZ side. For example, the deputy mayor, Shirley Rodriguez, attempted in 2018 to get changed the conclusion of a scientific study that found no evidence of benefits to child health from the original LEZ (Low Emission Zone) that had been launched in 2008. Fortunately, the professor who led the study, being a true scientist, had the integrity to refuse her request.

That same deputy mayor, in 2021, set out to whitewash an Imperial College study that showed that the ULEZ had made only a marginal difference to air quality after its introduction in 2019. As revealed by the Independent, Rodriguez colluded with Prof Frank Kelly, head of Imperial College’s “Environmental Research Group”, to issue a statement that contradicted the findings of the study. Kelly did not help his cause when, in June of this year, he wrote to prime minister Sunak alleging that politicians were “not believing the science” on air pollution. But whose science? Proper science, done with total honesty and according to the scientific method? Or Kelly’s brand of politicized “science?”

Would you not agree, Mr Hunt, that individuals funded by taxpayers’ money, who behave dishonestly in any part of their jobs, are acting in bad faith towards the people they are supposed to be serving? And that they ought to be subjected to sanctions, and even dismissal?

Then there is the case of Dr Gary Fuller’s “peer review” of a paper written by a team from City Hall, which Khan hailed as a “landmark report” and tried to use as justification for the recent ULEZ expansion. The report attempted to compare emissions since the ULEZ expansion to the North and South Circulars with a hypothetical scenario in which there had been no ULEZ. I have not read this particular report, but I know enough about science to be aware that such a methodology is fraught with huge dangers.

As I see it, science, when done properly, is fundamentally honest. Politics, on the other hand, is almost without exception fundamentally dishonest. And so, politics and science cannot mix, any more than oil and water can.

But I looked up a bit more about Dr Fuller. Having been one of those who set up the London Air Quality Network (LAQN) in the 1990s, he has a strong background in the measurement of air quality. I applaud him for that. But he is also a “Clean Air Champion” for the “Strategic Priorities Fund Clean Air Programme.” Which is led by the Met Office and NERC (the Natural Environment Research Council), which describes itself as “the driving force of investment in environmental science.” All this is co-ordinated by something called UKRI (UK Research and Innovation), and funded by the “Strategic Priorities Fund” out of the “National Productivity Investment Fund.”

This is a politicized rabbit-warren of quangos, no? What good does any of this do for the people who pay for it, the taxpayers? The minister currently responsible for all this, so I understand, is George Freeman MP. I wonder how aware he is of what is being done to us out of his budget and on his watch.

I looked a bit further back into the past, too. Knowing a fair bit about the history of COMEAP, I was not surprised to see, as another “Clean Air Champion,” the name of Professor Stephen Holgate. Holgate was involved in COMEAP’s 2009 and 2010 reports, which together set out to get a handle on just how big a problem pollution from PM2.5 and nitrogen oxides was. (And, in my opinion, failed to produce a result that was in any way credible). Holgate was also chair of the working group that produced the 2016 Royal College of Physicians report, which spawned the infamous “40,000 deaths a year from air pollution” meme. It was, simply, the most politicized “scientific” report I have ever read.

Oh, and who was the chair of COMEAP just a couple of years later, in 2018? Professor Frank Kelly. What’s down there isn’t just a rabbit-warren. It’s one inhabited by snakes.

Meanwhile, Sadiq Khan calls critics of ULEZ expansion nasty and false names like “conspiracy theorists,” “COVID deniers” or “vaccine deniers.” A sure sign that he has no arguments with which to rebut the criticisms. He is also chair of an extremist international “climate action” organization of city mayors, called C40. Oh, and Khan claims the power to tax people who live outside London. How can that be possible in a democracy, if they have no opportunity to vote him out?

So: We have damage, serious damage, that is being caused to innocent people by the ULEZ expansion. We have dishonesties, of many kinds, by those in and paid by government. These include attempts to manipulate science to support a political agenda. And some, perhaps many, of these attempts have been successful. The whole farrago is a disgrace.

But there’s more yet. The UK is supposed to be a democracy. That means that government is supposed to serve the governed. And that what it does is only legitimate, when it operates for the benefit of, and with the consent of, the governed.

I will quote from the Second Treatise of Government, written in the late 17th century by John Locke, father of the Enlightenment. “The great and chief end, therefore, of men uniting into commonwealths, and putting themselves under government, is the preservation of their property.” “The end of law is not to abolish or restrain, but to preserve and enlarge freedom.” “Their [government] power in the utmost bounds of it is limited to the public good of the society. It is a power that hath no other end but preservation, and therefore can never have a right to destroy, enslave, or designedly to impoverish the subjects.” The “public good” he defines in the First Treatise: “the good of every particular member of that society, as far as by common rules it can be provided for.” He also says: “Wherever the power that is put in any hands for the government of the people and the preservation of their properties is applied to other ends, and made use of to impoverish, harass or subdue them to the arbitrary and irregular commands of those that have it, there it presently becomes tyranny.” These words, I think, are of great relevance to our case.

The tale of the “judicial review” of the ULEZ expansion, in response to a case brought by four London boroughs and Surrey County Council, is a very sad one. Here is Hillingdon Council’s statement of its grounds for challenging the ULEZ expansion:

  1. Failure to comply with relevant statutory requirements.
  2. Unlawful failure to consider expected compliance rates in outer London.
  3. The proposed scrappage scheme was not consulted upon.
  4. Failure to carry out any cost benefit analysis.
  5. Inadequate consultation and/or apparent predetermination arising from the conduct of the consultation.

Was the process a proper judicial review? Did the judge go over again, with an unbiased eye, all aspects of the case, and make a considered judgement on each of the challenges? (Is that not what “review” means?) Not a bit of it. The judge did not even accept for consideration the two most important grounds for challenge: the lack of cost-benefit analysis, and the lack of adequate and fair consultation. He went full-on with the establishment line, looked for small “points of law” which supported Khan’s side of the case, and ruled against the councils. I have read the judge’s ruling, and it comes over to me as a “snow job.”

As to consultations, I have noticed that in recent years government has again and again failed to consult the public properly on environmental matters. An example of this was the 2020 “consultation” on the proposed ban on petrol and diesel cars. All submissions that did not conform to the establishment line – do it, and do it super-quick! – were completely ignored. On this ULEZ expansion consultation, I am aware that there were accusations of impropriety, notably those made by Crispin Blunt MP. I have not been able to find any refutation of Mr Blunt’s allegations. That Hillingdon Council’s challenge to this consultation was not even considered by the judicial review, makes me very concerned indeed.

On cost-benefit analysis, the trail is even more confusing. In fact, I haven’t been able to find anything even purporting to be a cost-benefit analysis for the ULEZ expansion into Outer London. I did find a reply to an FOI request, which suggested that a “business case” was made for the 2021 expansion to the North and South Circulars. Such a thing might, perhaps, have been a “cost-benefit” analysis from Transport for London’s point of view. But I have seen no evidence that anyone in government has tried, in an objective and unbiased way, to compare the costs to the people of ULEZ expansion to Outer London against the benefits.

The costs to the people are not only the direct ULEZ charges, but also the knock-on effects which, in the words of Cllr Smith, “destroy businesses, jobs and vital social and support networks.” The putative benefits come from the improvement in air quality, which is to be expected. The two ought to be compared. In theory, the air quality benefits should be estimated by DEFRA, based on recommendations made by COMEAP as to how to do the calculations. But COMEAP, looking at their latest (2018) report, seem unable to agree on how to combine the “risk factors” for different pollutants. (Even if the risk factors were accurate in the first place!) As a result, I can only conclude that no proper cost-benefit analysis has been done, or even attempted, on the expansion of ULEZ to Outer London.

Recall that according to Locke, government has no right “to destroy, enslave, or designedly to impoverish the subjects.” What that means today is that all government projects, of any significant size or reach, ought to undergo rigorous and unbiased analysis, to check that the benefits of the project to the people actually will outweigh the costs to them. And, because the “public good” is “the good of every particular member of that society,” no individual may be unjustly harmed, by being saddled with more costs than they receive benefits. Where costs versus benefits are unclear for a project, then the true version of the precautionary principle, “Look before you leap,” should be applied. And the project should not even begin.

Next, Mr Hunt, I feel the need to address you, not just in your role as “my” MP, but also in your official capacity as Chancellor of the Exchequer. You are the current custodian of the government’s “green book,” the set of procedures meant to guide cost versus benefit analyses carried out by the UK government. In March 2020, a review was instituted which resulted in changes to the green book. I quote from the government’s web page describing the change: “The 2020 review of the Green Book concluded that it failed to support the Government’s objectives in areas such as ‘levelling up’ the regions and reaching net zero. The review said this was because the process relied too heavily on cost-benefit analysis, also known as the benefit-cost ratio (BCR).” And there was “insufficient weight given to whether the proposed project addressed strategic policy priorities.”

All this seems to imply that policies that the politicians in power deem to be “strategic,” including “net zero” and – presumably, given UKRI’s funding source – ULEZ, are to be exempted from cost-benefit analysis! No matter how nett damaging the effects of those policies will be on the people the government is supposed to be serving. You of course, Mr Hunt, will be well aware which of your predecessors was responsible for this gross betrayal of the duty of government to act for the benefit of the governed. But for everyone else, I will simply say that his name has already appeared in this letter.

And that isn’t all. There are wider issues of human rights, too. We have a human right to freedom of movement. Article 13(1) of the UN Declaration states: “Everyone has the right to freedom of movement and residence within the borders of each State.” Our basic right to be able to move around freely should not even be questioned, let alone suppressed.

Of course, this freedom must be tempered by our responsibility, if our chosen means of movement causes a negative externality (side-effect) to others, to compensate those who are harmed by it. But the process of assessing such an externality must begin by working out the aggregate costs of the externality to all those affected by it. And in the case of air pollution from cars, this is precisely the “social cost” of the pollution, for calculating which DEFRA, guided by COMEAP, are responsible, and which appears not to have been done at all in the assessment of the ULEZ expansion.

Now, I was trained as a mathematician. So, I know how to do calculations. Back in 2017, I calculated the social costs of the PM and NOx pollution from cars in the UK, based on COMEAP’s reports and guidelines up to 2015. (https://wattsupwiththat.com/2017/08/11/the-social-costs-of-air-pollution-from-cars-in-the-uk/.) The ULEZ charges were at least an order of magnitude higher than the actual social costs per car per year. So, ULEZ was a scam from the very start. And who came up with the ULEZ idea? A certain Boris Johnson.

We also have a human right to privacy. Article 12, first clause: “No-one shall be subjected to arbitrary interference with his privacy.” Now, the network of cameras, which has been installed to police ULEZ, constitutes, in my opinion, serious interference with our privacy. For government, or anyone else, to track every journey made by a car in an area, without good and provable reason (for example, a reasonable suspicion of real criminal activity), is to trash our right to privacy altogether. Even if these cameras were not being used to enforce Khan’s thieving scheme, I would still think of them as like a criminal “stalking” me. That is, persistent and unwanted attention that makes me feel pestered or harassed.

There is a wider issue yet: the relationship between government and the governed. In recent decades, successive governments of all parties have taken to treating us more and more harshly, more and more aggressively, more and more dishonestly, and with less and less of the dignity which is due to us as human beings. We have been taxed ever more stringently. Ever more restrictive rules have been imposed on us, including ever tightening “targets” and “limits” on air pollution, and government overreach on COVID lockdowns, and vaccination passports and mandates. And the claimed “benefits” of these things never seem to materialize. All the parties that have been in government in the last half century and more have done, and are doing, similar bad things to us. And we’re just about at breaking point.

Then there is the matter of the side-lining of democracy. Democracy has many faults; for example, when there is no-one worth voting for, you are in effect disenfranchised. But a vote becomes of no value at all when policies and the direction a country takes are being set, not by the people, but by external forces. The EU, the United Nations, the World Economic Forum, the World Business Council for Sustainable Development, C40, and others: all are seeking to drive (no pun intended) the world in a direction that is diametrically opposed to the nature, the needs and the desires of us human beings. They clearly hate, and have contempt for, Western civilization, and want to destroy our prosperity and everything we have achieved.

In the case of air pollution, the ultimate problems lie with the UN and its WHO. The UN is also, as you will know, the driving force behind the monstrous scam that is the green agenda as a whole, including “sustainable development” and “net zero.” In a democracy, should it not be the people who determine the direction in which a country moves? Not unelected, unaccountable third parties with agendas hostile to human civilization? And is it not part of your remit, Mr Hunt, as MP for South-West Surrey, to defend the people of South-West Surrey against all attempts to impose on us any such policies, which go against our interests?

Many people, particularly in the media, seem to be surprised by the level of anger that is being shown, not only by those directly affected by this ULEZ expansion, but also by those outside London who, like me, are opposed to anti-car policies. The reason is not just because we have sympathy for our fellow human beings in their troubles. It is also because we know that, if this is allowed to go any further, we are likely to be next on the chopping block.

Personally, I don’t expect the ructions over ULEZ expansion to die down any time soon. I expect them to escalate, at least to the level of the poll tax protests, maybe to another Winter of Discontent or even another 1642. These are “interesting times” indeed.

Mr Hunt, you are my supposed representative in parliament. (I say “supposed,” because you have often supported policies to which I am adamantly opposed, such as EU membership, “climate change” levies and restrictions, IR35, and wars in places like Syria.) To be brutally frank, I don’t expect that you will want even to try to do anything to help me or people like me. But at least I have managed today to put on record some of the real issues that plague us human beings in this country. It behooves you, and all other politicians, to start working for the people you are supposed to represent, instead of against us.

I will leave you with more words of my 17th-century almost-namesake and intellectual father, John Locke. “But if a long train of abuses, prevarications and artifices, all tending the same way, make the design visible to the people, and they cannot but feel what they lie under, and see whither they are going, it is not to be wondered that they should then rouse themselves, and endeavour to put the rule into such hands which may secure to them the ends for which government was at first erected.”

Yours sincerely,

Neil Lock


  1. ULEZ and Air Pollution

    Living in London or any city, you would not necessarily experience any symptoms – even if you were a cyclist. But you will be affected dramatically by particles and gasses. Those with health conditions like asthma will be seriously, often fatally, affected.
    The traffic in London is horrendous. I recently had to move my son and was sat in traffic stationary for hours.
    Personally I’d ban all cars and bring in great technology – moving sidewalks, trams, busses and underground systems. I’d make most of the place a pedestrian only zone with cycle lanes. I would allow delivery and maintenance only. I think that would be great for everybody and Londoners (and all big city dwellers) would get around faster and healthier.
    The only concession I would make is that I would compensate people for their polluting old bangers.

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