ULEZ Compliant?

[RICHARD MANSFIELD2]

Hi the reply we were all expecting.


Mansfield
Our Ref: TFL-2711067-1696588000
Customer Account Number: N/A

Thank you for your recent correspondence received 4 October 2023, about the Ultra Low Emission Zone (ULEZ),
vehicle registration X798ARX.
Based on the information that you have provided we can confirm that your vehicle, registration X798ARX does not
meets the ULEZ standards. This means you will have to pay the ULEZ charge to travel in the zone.
The Ultra Low Emission Zone (ULEZ) applies to diesel and petrol vehicles that do not meet:
Euro 3 for motorcycles, mopeds, motorised tricycles and quadricycles (or Nitrogen Oxides (NOx) less than
0.15g/km)
●
● Euro 4 for petrol cars, vans, and minibuses (or Nitrogen Oxides (NOx) less than 0.080g/km)
Euro 6 for diesel cars, vans, and minibuses (or Nitrogen Oxides (NOx) less than 0.080g/km and Particulate
Matter (PM) less than 0.005g/km)
●
● Euro VI for buses, and coaches and heavy goods vehicles
Generally, the date of 'first registration' can be used to determine the Euro standard:
● Euro 3 became mandatory for all new motorcycles in 2007
● Euro 4 became mandatory for all new cars and light vans in 2006
Euro 6 became mandatory for all new heavy-duty engines for goods vehicles and buses from January 2014,
September 2015 for cars and light vans, and September 2016 for larger vans up to and including 3.5 tonnes
gross vehicle weight
●

This means you will need to pay the appropriate ULEZ charge and if applicable, the Congestion Charge and/or Low
Emission Zone charge. If you do not pay the charge(s) you will receive a Penalty Charge Notice for one or more
schemes.
Once we received it, we will be happy to proceed with your request.
If you have any questions, please visit tfl.gov.uk/driving.

Yours sincerely

D. Milton

 

[den67]

Hi the reply we were all expecting.


Mansfield
Our Ref: TFL-2711067-1696588000
Customer Account Number: N/A

Thank you for your recent correspondence received 4 October 2023, about the Ultra Low Emission Zone (ULEZ),
vehicle registration X798ARX.
Based on the information that you have provided we can confirm that your vehicle, registration X798ARX does not
meets the ULEZ standards. This means you will have to pay the ULEZ charge to travel in the zone.
The Ultra Low Emission Zone (ULEZ) applies to diesel and petrol vehicles that do not meet:
Euro 3 for motorcycles, mopeds, motorised tricycles and quadricycles (or Nitrogen Oxides (NOx) less than
0.15g/km)
●
● Euro 4 for petrol cars, vans, and minibuses (or Nitrogen Oxides (NOx) less than 0.080g/km)
Euro 6 for diesel cars, vans, and minibuses (or Nitrogen Oxides (NOx) less than 0.080g/km and Particulate
Matter (PM) less than 0.005g/km)
●
● Euro VI for buses, and coaches and heavy goods vehicles
Generally, the date of 'first registration' can be used to determine the Euro standard:
● Euro 3 became mandatory for all new motorcycles in 2007
● Euro 4 became mandatory for all new cars and light vans in 2006
Euro 6 became mandatory for all new heavy-duty engines for goods vehicles and buses from January 2014,
September 2015 for cars and light vans, and September 2016 for larger vans up to and including 3.5 tonnes
gross vehicle weight
●

This means you will need to pay the appropriate ULEZ charge and if applicable, the Congestion Charge and/or Low
Emission Zone charge. If you do not pay the charge(s) you will receive a Penalty Charge Notice for one or more
schemes.
Once we received it, we will be happy to proceed with your request.
If you have any questions, please visit tfl.gov.uk/driving.

Yours sincerely

D. Milton

D Milton needs a rocket up their ar**!!! Can't even manage to quote their own standards correctly. The Euro 4 limit for NOx for petrol cars, quoted on their own website, is "LESS THAN OR EQUAL TO 0.08 g/km", not "less than 0.080 g/km" !!!

 

[yippeekiay]

Seems to me that the guy who replied in that letter wasn't being thorough in checking his details or was lazy & couldn't be ar$ed checking.
Or the sceptical part of me says he put the extra zero on the end of them to fail the car & any other vehicles that could otherwise be rounded to comply.

I say the latter

What is more than likely is that everyone in the TFL office that processes this information have likely not been advised/updated of the exact criteria & are basically using a carte blanche approach of their own making instead of using facts. The managers of that office should be ensuring the information used is correct & what to do in the case of cars like the Puma which is at 0.083 thus qualifying.

I've seen this confusion arising often in my own experience where dumba$$es use oudated or incorrect sources, but mostly through tardy/lazy work practices. Most of the time it was copy/pasting wrong info in the first place & not f'in checking!!!

GRRRR, I'm getting pi$$ed off just thinking about the f'in idiots I've worked with/for in the past, f'in lazy, bone idle, dumb f's

*Calm down grandpa, you'll give yourself a hernia

 

[ulezpuma]

Wow. Clumsy or deliberate? I suspect TFL are deliberately trying to move the goalposts on the standards which is a more serious matter in my view,

This is the wording I received about the standard at exactly the same stage in the initial rejection response from TFL

The required amount of NOx emissions equal to, or less than, 0.08 grams per kilometre for Petrol vehicles

So I would go back and say that this contradicts your own previously quoted standard for Euro 4 of equal to or less than 0.08 grams per kilometre, in other words you are challenging what may be a deliberate misquotation of the actual standard.

What would be even better if someone can find the actual wording of Euro 4 emissions standard for avoidance of any doubt.

 

[ulezpuma]

D Milton needs a rocket up their ar**!!! Can't even manage to quote their own standards correctly. The Euro 4 limit for NOx for petrol cars, quoted on their own website, is "LESS THAN OR EQUAL TO 0.08 g/km", not "less than 0.080 g/km" !!!

Indeed. Do you have the link to the website stating this, but also take a clear screenshot of the entire page (with URL if possible) in case they try to take it down. I did take a screenshot myself previously but not of the entire page, just for the purpose of documenting the process. It didn’t occur to me that they’d actually try to move the goalposts

 

[ulezpuma]

Below is a freedom of information request someone else was involved with that I also dug up as part of my research

FOI request detail

….The standard for compliance with the ULEZ for M1 passenger cars is 0.08g/km NOx. This applies to both petrol and diesel engines and is equivalent to the Euro 4 standard for petrol cars and the Euro 6 standard for diesel cars. (There is an additional requirement to not exceed 0.005g/km particulate matter for diesel engines). These limits are measured over the type approval ‘type 1’ test and the results are declared at the time of type approval and recorded by the DVLA. The type 1 test consists of a chassis dynamometer test over a prescribed drive cycle….

Note the wording stating 0.08 and also does not exceed in the response. Ignore the fact that that particular statement refers to diesel, the ‘does not exceed’ applies to everything, the author is just stating the additional diesel requirement, so is implied for petrol also.

This clearly contradicts what @RICHARD MANSFIELD2 has received today.

Best would still be to find the official Euro 4 standard wording. But other than that if TFL have taken down the original wording from their site, use the above link from their legal team to show the contradiction.

 

[ulezpuma]

Here you go. Official directive 98/69/EC (Euro 4) wording. Page 19.

Attached screenshot of page 19 for easy reference also. Clearly 0.08, two decimal places and also the three decimal place particulate matter emissions shown for reference too.

In summary, TFL response to @RICHARD MANSFIELD2 contradicts not only their own previous wording of the standard, in addition to a FOI response from their own legal team but also the official Euro 4 two decimal place notation representation of NOx at 0.08g/km

You should have plenty to be able to go back to them with now. Good luck, don’t give in.

 

[den67]

Can't find original page on TfL website at moment (maybe they have removed it), but here's another interesting FOI request and response:

https://tfl.gov.uk/corporate/transp.../foi-request-detail?referenceId=FOI-3195-2223
The original TfL document for ULEZ standards is:

https://content.tfl.gov.uk/lez-scheme-order.pdfSee Annex 2, Part 2, Table 5 (on page 33) showing limit value for NOx for M1 vehicles as 0.08 g/km.

 

[ulezpuma]

Nice work! So now we have at least four points of reference for @RICHARD MANSFIELD2 to throw back to TFL

BTW your first link to the FOI goes to a page not found, is that the correct link or did they take it down that quickly

 

[den67]

Try FOI link again - looks like it's working now....

 

[RICHARD MANSFIELD2]

Found this

Emission Standards​

EU emission standards are summarized in the following tables. All dates listed in the tables refer to new type approvals (TA). The EC Directives also specify a second date—one year later, unless indicated otherwise—which applies to first registration (FR, entry into service) of existing, previously type-approved vehicle models.

Table 1
EU emission standards for passenger cars (Category M1*)
�

Stage	Date	CO	HC	HC+NOx	NOx	PM	PN
g/km	#/km
Positive Ignition (Gasoline)
Euro 1†	1992.07	2.72 (3.16)	-	0.97 (1.13)	-	-	-
Euro 2	1996.01	2.2	-	0.5	-	-	-
Euro 3	2000.01	2.30	0.20	-	0.15	-	-
Euro 4	2005.01	1.0	0.10	-	0.08	-	-
Euro 5	2009.09b	1.0	0.10d	-	0.06	0.005e,f	-
Euro 6	2014.09	1.0	0.10d	-	0.06	0.005e,f	6.0×1011 e,g
Compression Ignition (Diesel)
Euro 1†	1992.07	2.72 (3.16)	-	0.97 (1.13)	-	0.14 (0.18)	-
Euro 2, IDI	1996.01	1.0	-	0.7	-	0.08	-
Euro 2, DI	1996.01a	1.0	-	0.9	-	0.10	-
Euro 3	2000.01	0.64	-	0.56	0.50	0.05	-
Euro 4	2005.01	0.50	-	0.30	0.25	0.025	-
Euro 5a	2009.09b	0.50	-	0.23	0.18	0.005f	-
Euro 5b	2011.09c	0.50	-	0.23	0.18	0.005f	6.0×1011
Euro 6	2014.09	0.50	-	0.17	0.08	0.005f	6.0×1011
* At the Euro 1..4 stages, passenger vehicles > 2,500 kg were type approved as Category N1 vehicles † Values in brackets are conformity of production (COP) limits a. until 1999.09.30 (after that date DI engines must meet the IDI limits) b. 2011.01 for all models c. 2013.01 for all models d. and NMHC = 0.068 g/km e. applicable only to vehicles using DI engines f. 0.0045 g/km using the PMP measurement procedure g. 6.0×1012 1/km within first three years from Euro 6 effective dates

 

[ulezpuma]

Try FOI link again - looks like it's working now....

Perfect. This is an even more direct reference to equal to or less than 0.08g/km on their own site. Great work.

 

[RICHARD MANSFIELD2]

Hi.
Thanks for all your effort guys.
Tomorrow I will start drafting my reply stating the four points. When you appealed to get your Puma's compliant did you just send your reply as a direct reply to the letter similar to the one I recieved? I will probably do it in word then copy and paste to the email. If successful I can send the draft to anyone else who in future goes down this route.

Regards,
Richard

 

[ulezpuma]

Well before I had time to screenshot it, it’s gone again. Hmmm. if anyone else can still bring it up, do screenshot it and share

 

[ulezpuma]

Hi.
Thanks for all your effort guys.
Tomorrow I will start drafting my reply stating the four points. When you appealed to get your Puma's compliant did you just send your reply as a direct reply to the letter similar to the one I recieved? I will probably do it in word then copy and paste to the email. If successful I can send the draft to anyone else who in future goes down this route.

Regards,
Richard

 

[ulezpuma]

It would only work when I replied direct to the email.

 

[Ruaraidh]

Perfect. This is an even more direct reference to equal to or less than 0.08g/km on their own site. Great work.

What does the certificate of conformity say for NOx? Because if it’s 0.083 then that’s greater than 0.08….. so the “equal to” bit doesn’t matter

Arbitrarily rounding it down doesn’t count if the letter from Ford says 0.083

 

[ulezpuma]

What does the certificate of conformity say for NOx? Because if it’s 0.083 then that’s greater than 0.08….. so the “equal to” bit doesn’t matter

Arbitrarily rounding it down doesn’t count if the letter from Ford says 0.083

0.08 is a two decimal notation. 0.083 is three decimals. In order for a three decimal number to become two decimals as used in euro 4 notation you have to round it. Anything less than 0.085 according to standard maths rounding rules is 0.08. Anything 0.085 and above is rounded to 0.09. So if the rule is that the emissions must be equal to or less than 0.08 then 0.083 rounded to two decimal places is 0.08.

 

[kevinh]

I'm horrified by the TfL behavior described in the last strand of messages about @RICHARD MANSFIELD2 's rejection.
In case it helps, there is one more line of reasoning you could pursue, and I would now recommend that anybody who has yet to apply to ULEZ applies to DVSA first:
From my original rejection by TFL (based on my submitting only the CoC and not the V5C). I resubmitted from scratch after first getting DVSA compliance confirmed. I don't know if this made any difference since my Puma is only 0.033 and clearly compliant.

"We should also like to clarify that as the details currently held by the DVLA reflect that your vehicle is not compliant,​

updating this vehicles compliance record directly with DVLA, so that ULEZ Compliance Registration with us is not​

required is also an option for you.​

Once DVLA certfies compliance status of your vehicle, it is automatically registered with us with no input from yourself."​

 

[Sam75]

You are compliant. My Puma NoX is the same, 0.083, and I am now compliant.