The number-plate recognition cameras are ready. The signs have been up since last year. From next Thursday, any driver taking a car into the Glasgow Low Emissions Zone (LEZ) not either compliant with standards or exempt will be hit by a £60 fine – a penalty that will be halved if paid within two weeks.
But, as tensions have risen in the run-up, critics of the scheme have pointed out that Glasgow’s latest air quality figures are already below the target set. Reductions in emissions achieved during phase one of the Glasgow scheme have brought the area within reach of the 40µg/m3 limit originally set by the EU.
Given this, critics are asking if a low emissions zone is really necessary, particularly in a cost-of-living crisis? And if it’s not about air quality and public health, what is it about?
Nitrogen dioxide emissions have indeed been lowered in the four cities across Scotland - Edinburgh, Aberdeen, Glasgow, and Dundee - in which the LEZ are due to be introduced. At a key pollution hotspot in Glasgow, on Hope Street, levels are now, at 39.1µg/m3, within the 40µg/m3 target - and much better than 55.6 µg/m3 in 2019. Hope Street is also the only testing site in Scotland to exceed these legal limits.
In Glasgow, the success of the first phase of the low emissions zone, which restricted buses, could be said to both simultaneously justify the next phase, and also render it unnecessary.
But emissions on Hope Street are only barely within target limits – and also these are targets that have often been described by experts as merely 'interim' targets.
The World Health Organisation’s air quality guideline for nitrogen dioxide is 10 µg/m3 - with 40 µg/m3 envisioned as such an “interim target” to help countries move in the right direction.
As part of its Green New Deal, the European Union recently announced it was pushing to drop its targets to 20 µg/m3.
Is this part of a Net Zero agenda?
The question of to what degree this has anything to do with carbon dioxide emissions and the Net Zero strategy has been much discussed by critics, particularly those who see it as part of a 'climate lockdown' plan. However, in the run-up to the launch of the LEZ, Glasgow City Council has emphasised that this is really about improving air quality by reducing nitrogen dioxide emissions – with lowering carbon emissions an added benefit.
That said, from the start, NO2 reduction has not been the only goal. A 2021 Consultation document on Phase 2 of the Glasgow emissions zone stated that the plan aimed to “improve public health” by meeting air quality objectives, but also to “contribute towards the emissions reduction targets set out in Part 1 of the Climate Change (Scotland)” as well as “improve the amenity of Glasgow”.
The impact on carbon dioxide emissions however is relatively low. It has been estimated that since 2019, London's ULEZ had led to a reduction of 800,000 tonnes of CO2 emissions – a saving of three percent on what would have been emitted were it not for the creation of the zone.
Three percent isn’t a huge figure in the context of Scotland’s goal of reducing transport-related emissions by 75 percent by 2030.
READ MORE: Scotland's low emission zones: Which cars will be banned?
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Is it about the money?
A further theory is that it’s all about filling Glasgow Council’s coffers. Those hefty £60 fines that would, on repeat entry, into the zone cap-out at £480 for an individual car and £960 for a bus or HGV, could add up to many hundreds of thousands.
Certainly, the gross sum of the charges in the Ultra Low Emission zone in London is huge. Data from the Mayor of London’s Annual Report and Statement of Accounts revealed last year, income from ULEZ (Ultra Low Emission Zone) charges was £225.7 million.
However, Scotland’s LEZ penalty strategy is quite different from London’s daily charges of £14. Its stick (rather than carrot) approach is more extreme.
With fines this steep will drivers be less likely to flout the ban? Or might they be more likely to just try to refuse to pay, as did thousands of drivers of non-compliant cars who entered Birmingham’s Clean Air Zone?
London’s ULEZ, which is set for further expansion, currently covers 236 square miles and is home to 3.8 million and is the largest zone of its kind in Europe – so it’s not surprising that the charges collected were significant. By contrast, Glasgow’s Low emission zone is just around a square mile, and home to 20,000 – though it impacts on the many who work within the area, and particularly strongly impacted are those businesses that use vans.
But, whatever the scale of penalties collected from the Glasgow LEZ, the use of the money is restricted. The Transport (Scotland) Act 2019 states that penalties will be used to support the air quality objectives of the Low Emission Zones and the Glasgow LEZ site states: “All revenue (above that incurred in running the LEZ scheme itself) can only be used for activities that help reduce air pollution and/or contribute toward achieving our climate change targets.”
Or is it about politics? Or even public health?
The Glasgow LEZ is part of a top-down SNP plan proposed in 2015. While Glasgow City Council has been the first to roll out the strategy, this is a four-city plan and is the result of Scotland failing to meet its legal obligations on air quality.
In 2021, the Court of Justice of the European Union ruled that the UK had “systematically and persistently” exceeded legal limits for dangerous nitrogen dioxide since 2010, and failed against its legal duties to put plans in place to tackle the problem in the shortest possible time.
Low emission zones, therefore, are also not just an SNP policy - they are a response to a statutory obligation. There are now 250 LEZs across Europe – the first having been introduced in Sweden in 1996 - and these zones have also been pushed by a wide range of parties across the UK and Europe.
It was Labour’s Ken Livingstone that launched the London zone, the first of its kind in the UK, and now the biggest in Europe. The Conservative Westminster government has pushed Clean Air Zones in cities like Birmingham, Bath, Sheffield, Tyneside, and Bristol, as well as Greater Manchester (which is currently on pause).
Scotland’s LEZ’s, like many policies post-pandemic, are running behind schedule. But even before the pandemic, they had been delayed. In 2018, two air quality experts, from Scottish Environment Link, resigned from the Scottish Government strategy team because of lack of urgency and progress.
In a resignation letter, they said: "For two years the Link representatives have made every constructive effort to inject ambition and urgency into the creation of Low Emission Zones in Scotland. At nearly every single stage they have felt frustrated by lack of progress."
There are reasons to be positive about Scotland's progress on air quality. NO2 levels are dropping in Scottish towns and cities, year on year - in part because older cars are replaced by newer technologies, for instance the Euro 6 standard, and also because of bus upgrades. Away from the busiest streets they are also often less than 10 µg/m3.
But, if Scotland were to follow the EU's proposed new limits, and create new targets of 20 µg/m3, many sites would currently exceed them. Not just Glasgow's Hope Street, but six of the nine testing sites in Glasgow, would lie outside, as would half of Edinburgh's sites. This compares with 84 percent of European cities whose air is already within these limits.
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