Lorries that do not comply with the proposed early introduction of the London Ultra-Low Emission Zone (ULEZ) should be subject to a sliding scale of penalties that increase over time.
TfL plans to bring in the ULEZ 17 months early would see HGV owners charged £100 for every day their pre-Euro VI vehicles enter the zone after the revised start date of 8 April 2019.
In its response to a consultation on the proposals the RAC Foundation said that if an early start date was chosen then owners of the largest commercial vehicles face being severely disadvantaged. This is because of the long lead time for ordering such vehicles and the length of lease many of the owners will have entered into with little prospect of escaping them early except by a hefty payment:
"Were the decision to be to proceed with acceleration, we would encourage consideration to be given to the level of the charge, moving, perhaps, to a graduated approach over a number of years – say £20 in year 1, £50 in year 2, rising to £100 from year 4, such that the appropriate financial signal is being sent but recognition given to the practical realities of achieving compliance and the broader risks to a well-functioning London if, say, the operators of heavy recovery vehicles find the day 1 ULEZ charge rates uneconomic to swallow for their business."
Both vans and cars will be subject to a £12.50 daily penalty - on top of the Congestion Charge - if, when the zone comes into force, they are either pre-Euro 4 petrol or pre-Euro 6 diesel.
The proposal says a three-year sunset period for owners of domestic vehicles registered inside the zone will still apply, though the start date of that would also be brought forward 17 months.
As an interim measure before the ULEZ is brought into force, the Mayor is introducing the so-called T-Charge which will see high-emitting vehicles paying an environmental fee on top of the Congestion Charge.
This is due to come into effect on 23 October 2017. The ULEZ will replace the T-Charge when it comes into effect.
TfL has already gone some way to greening its bus fleet, partly through retrofitting.