ULEZ exemption for older cars pre Euro4/2006

jimjames

I'd posted in another thread relating to someone selling to get a car that meets ULEZ but thought this worth having its own thread. With the ULEZ zone being extended later this year it could affect even more people and cars that could be compliant instead getting sold or scrapped.

The TFL website allows you to check if your car is exempt from the ULEZ charges but this only uses the DVLA info showing if the car is Euro4 compliant or no. The actual criteria for ULEZ is not Euro4 compliance but meeting a very specific part of the requirement for Nitrogen Oxide emissions known as NOx. I know quite a few people who have got cars classed as exempt as a result of submitting the manufacturer spec (known as Certificate of Conformity) to TFL.

Even some Euro3 petrol cars are compliant so it can stretch the date back to around 1997 for some cars. TFL are very evasive on their website but the criteria for ULEZ is actually the NOx emission levels not the requirement to meet the full Euro4 spec. The key number is NOx emissions under 0.08g/km so if your .emission level is below this your car should be classed as exempt if it's petrol. Diesel is more difficult as the particulate level also needs to be compliant with Euro6 and that's not easy without the fitment of devices such as DPF/Adblue etc.

https://youtu.be/bmkNpuMPPmw

Goudy

I know of a few motorcycle owners that have had their pre Euro 3 bikes tested and passed the NOx test so they are compliant.
(Euro 3 is the minimun level for bikes)

Those have passed have then been added to TFL's database so other owners of the same bike haven't had to pay the testing fee (which is quite steep and the test only available at one garage).

Oddly most old two strokes seem to have a very high pass rate.

Grumpy_chap

jimjames said:

The actual criteria for ULEZ is not Euro4 compliance but meeting a very specific part of the requirement for Nitrogen Oxide emissions known as NOx. I know quite a few people who have got cars classed as exempt as a result of submitting the manufacturer spec (known as Certificate of Conformity) to TFL.

TFL are very evasive on their website but the criteria for ULEZ is actually the NOx emission levels not the requirement to meet the full Euro4 spec. The key number is NOx emissions under 0.08g/km 

Thank you.

This is excellent to know.  The TFL website is, as you say, unclear (at best) on this and the checker only checks against full EURO 4 / 6 status.  It is not obvious that all TFL staff would be aware of the finer details either.

Is there a clear statement somewhere that gives the actual rules (by-law, legislation - I am aware that LA cannot pass legislation, but whatever the equivalent would be called).

It seems to be that the request for the manufacturer to confirm emission level and provide the CoC should be relatively straightforward. 
If that is favourable, it would be great if we can simply write to TFL along the lines of "The rules, document X, clause Y state Z.  Please see attached CoC evidence of compliance.  Please process my vehicle exemption and confirm.  Thank you."
What is missing is the relevant document, clause, etc.

This seems like a really big thing as there could be a high number of cars indicated for sale / scrap at the moment based upon misleading criteria. Very surprised none of the motoring press have cottoned on and shouted this from the rooftops.

facade

Goudy said:

I know of a few motorcycle owners that have had their pre Euro 3 bikes tested and passed the NOx test so they are compliant.
(Euro 3 is the minimun level for bikes)

Those have passed have then been added to TFL's database so other owners of the same bike haven't had to pay the testing fee (which is quite steep and the test only available at one garage).

Oddly most old two strokes seem to have a very high pass rate.

Not surprising, NOx is produced by the heat & pressure of combustion, the visible smoke from a two stroke is nothing to do with it - it would increase the HCs.

I don't know what speed they measure at, but  two strokes tend to run cooler than four strokes at low speeds, which would reduce NOx even further.

jimjames

Grumpy_chap said:

jimjames said:

The actual criteria for ULEZ is not Euro4 compliance but meeting a very specific part of the requirement for Nitrogen Oxide emissions known as NOx. I know quite a few people who have got cars classed as exempt as a result of submitting the manufacturer spec (known as Certificate of Conformity) to TFL.

TFL are very evasive on their website but the criteria for ULEZ is actually the NOx emission levels not the requirement to meet the full Euro4 spec. The key number is NOx emissions under 0.08g/km 

This seems like a really big thing as there could be a high number of cars indicated for sale / scrap at the moment based upon misleading criteria. Very surprised none of the motoring press have cottoned on and shouted this from the rooftops.

Even the motoring press don't seem to be aware. My car was listed as non compliant in an article in one of the magazines but that was purely on the basis of the Euro4 website checker rather than actually looking at the vehicle emissions. I'm planning to contact one of the paper's motoring teams but there is a worry that stoking too much awareness might backfire

I've eventually found the document that enforces/enables ULEZ, TFL really don't make it easy to find this info!

https://content.tfl.gov.uk/lez-scheme-order.pdf

The key part is the annex 2, part 2. For pre Euro4 petrol cars the section is under part c. 

 A vehicle meets the standards set out in Tables 2 to 6 if—
c) in respect of all other vehicles— (i) the limit values for the emission of NOx specified for the vehicle in column (e) would not be exceeded during the appropriate test or tests specified in column (g) of the Table

Grumpy_chap

Thank you @jimjames

My request to Ford has been passed to the CoC Department.  Hopefully, they will respond in a reasonable timeframe.  Once I have that, I'll know whether I need to write to the lovely friends of Mr Khan.

Grumpy_chap

I must say that Ford have been very efficient on this.

I sent an e-mail yesterday evening (Sunday).  It was sent to the correct team to action, who got in touch with the details they required on the car (V5 plus VIN plate) and they've now confirmed that a CoC will be sent by post in the format required to satisfy DVLA / ULEZ enquiries.  I am expecting that will be in the post once I return from holiday.

Ford have not expressly confirmed the NOx ratings either way - maybe the fact they are sending the CoC is a positive indication, maybe not (could just be that Ford simply send the CoC and leave it for the vehicle owner to look up the required data).  Either way, the prompt attention by Ford is impressive.  They certainly have a system set up and in place for managing these enquiries.

Grumpy_chap

I have received the CoC today (very quick response from Ford )
I think it is ambiguous:

How does this work if there is no stated value for NOx?

How much of the combined HC + NOx 0.126 is NOx?  If 0.05 is HC, then the car is compliant.

Grumpy_chap

The more I consider this, the more the details seem to have the hall-marks if a scandal.

The rules are that a car must have NOx <=0.08.
Any petrol car that is EURO 4 complies
Any diesel car that is EURO 6 complies
However, not all compliant cars are within the EURO 4 / 6 subsets
There is no reliable database of cars that are compliant (NOx <=0.08), only database of EURO 4 / 6 classification.

I wonder how many scrappage compensation payments have been paid out in lieu of compliant cars?  Misuse of public funds.

I wonder how many fines for contravention have been issued against compliant cars?  Eventually, this will come to light and all these fines will be cancelled and have to be refunded.

Them, the case of my car (and others like it) which were authorised for sale (type approval) and the requirements then did not require a NOx classification.  There simply is no data to assess whether these cars are compliant or otherwise.  I don't see how a fine can be applied against such vehicles when there simply is inadequate data to determine the validity of that penalty.

jimjames

It would be interesting to see the outcome of an appeal against a ULEZ fine for a car that was compliant but had incorrectly been flagged as not. I don't want to test it out but it should be possible to prove the car is compliant with the correct info even if TFL don't show it as such. There does seem to be a deliberate policy of making the rules as unclear as possible to limit the number of cars that are able to use the ULEZ for free and even the media aren't helping that perception.

jimjames

Grumpy_chap said:

I have received the CoC today (very quick response from Ford )
I think it is ambiguous:

How does this work if there is no stated value for NOx?

How much of the combined HC + NOx 0.126 is NOx?  If 0.05 is HC, then the car is compliant.

I think it really needs the NOx value on its own. My car is NOx + HC of 0.187 but HC is 0.152 and NOx 0.035. So if your car follows the same proportions it should be below the limit.