I've sent an e-mail to KL:
'Dear Sir,
I have been looking at the draft proposals for the proposed emissions based congestion charge and found the paragraph below (Section 3.2.1):
'The proposals would introduce a 100 per cent discount for the category of lowest CO2 emitting cars – those certified as emitting 120g/km of CO2 or less (VED bands A and B) that also meet the Euro 4 standard for air quality emissions. As stated above, TfL would consider that any car registered on or after 1 January 2005 met the Euro 4 air quality standard. Therefore any car in VED band A or B registered after this date would qualify for the low CO2 discount. The air quality element to the low CO2 discount has been included to encourage drivers to also use cars with lower levels of those emissions that degrade air quality.'
I own 2 cars, a 2001 VW Lupo 3L and a 2001 Audi A2 1.2Tdi. Both these cars were designed as 3L (or almost) 3L fuel/100 km (around 95mpg). Both were only built as LHD cars and were never sold in the UK. They both have the same engine and automated manual gearbox. They both have very low CO2 emissions, this being one of the main reasons for purchase, 81g/km for the Lupo and 86g/km for the Audi. Both cars nominally meet the Euro 3 emissions standard but only as the Euro 4 standard did not exist in 2001. In fact, both cars also meet the Euro 4 standard as their Certificates of Conformity show:
g/km CO HC+NOx NOx Particulates
Euro 4 Standard 0.50 0.30 0.25 0.025
2001 VW Lupo 3L 0.202 0.242 0.22 0.019
2001 Audi A2 1.2Tdi 0.228 0.261 0.24 0.021
According to your proposals, one of these cars, and, incidentally the one with the lower emissions, does not qualify for the low CO2 discount because it was registered in 2001. The other car presumably does qualify because it will be registered in the next month or so! Common sense tells me that both cars should qualify but common sense was never a strong point of the current scheme so why should I expect any for the next? Under the current scheme, neither car qualifies for any discount but Leviathans like Lexus SUV hybrids and LPG powered Range Rovers do! A study by the Harvard Centre for Risk Analysis has found that vehicles powered by LPG produce large amounts of ultra-fine exhaust particles.
http://www.rac.co.uk/web/knowhow/bu...g;jsessionid=A30F25C100D7E3BDF60F00D76DD6E60F
I suppose all the 'zero emission'/ zero charge electric cars in Central London are 100% charged by solar or hydroelectric power - considering the typical efficiency of a coal power station (30%), losses in the transmission system (20%) and the efficiency of charging a battery (10 to 20%), their true emissions are probably higher than a small (or big!) conventional car! It's just that the emissions are made somewhere outside Central London.
At the very least I would like some clarification of the above. However, as we normally only travel into London about once a year (usually to a concert from which we cannot get home to East Sussex by train) it might be cheaper if neither qualifies as it costs £10 a year just to register! But you have no excuse for getting it wrong this time. Perhaps you should get some decent scientific advice and hire some lawyers to check your drafts!'
My local farmer will deal with the reply (assuming I get one!).
RAB