RICHARD MANSFIELD2
Active member
Hi Sam.
What process did you go through?
What process did you go through?
ULEZ Compliant?
- Thread starter YOG
- Start date
Help Support ProjectPuma:
Exactly, as am I.. The issue now though is that TFL appear to be moving the goalposts by declaring the requirement as less than 0.080 in their response to Richard. The challenge back is that this is incorrect vs previous wording, wording elsewhere from their legal team in FOI requests and their own and Euro 4 formal documents specifying the limit as 0.08.
ladypenelope7
New member
Hi Sam, did you apply to Tfl or direct to DVLA as suggested in a post above?
RICHARD MANSFIELD2
Active member
Hi.
I have done a draft reply to send to TFL. Please have a read and let me know what you think. I am always willing to hear the opinion and advice from others.
Dear Mr......
I acknowledge your reply of refusal to my request for my Ford Puma to be given ULEZ compliance. I would like to appeal the decision by Transport For London (TFL) on the following grounds. In Your letter of refusal you stated the following;
● Euro 4 for petrol cars, vans, and minibuses (or Nitrogen Oxides (NOx) is or less than 0.080g/km)
I would like to point out that TFL has quoted the incorrect figure of 0.080g/km relating to Euro 4. I support my claim relating to your incorrect value by quoting the following documents.
Greater London Authority Act 1999, Transport Act 2000. Greater London Low Emission Zone Charging Order 2006. Sets out on page 33 that EC emissions standard of 0.08NOx for Euro 4.
Transport for London FIO request ID FOI-3195-2223. Date published 20th March 2023. In answer to question 2 states: Specifically “Petrol cars must be Euro 4 or have NOx emissions equal to or less that 0.08grams per kilometre.
Informal Document no.6 by The European Commission dated 2002. Annex 1. Passenger Cars and Light Commercial Vehicles Directive 98/69/EC states a mandatory tailpipe emission limits of Euro 4 to be the following values. CO 1.0 HC 0.1 NOx 0.08
As you can see from the above documents Euro 4 is valued at two decimal places and not as you have stated as a value to three decimal places. The value of my cars NOx at 0.083 if taken to two decimal places would indeed be a value of 0.08. If the standard rounding system was applied to 0.083 the value would still be 0.08.
Finally I would like to inform you that I personally know of owners of my model of Puma to whom TFL has granted ULEZ compliance. Consistency must be applied.
I therefore submit that there is sufficient evidence and reasoning for my Ford Puma to be granted ULEZ compliance.
I have done a draft reply to send to TFL. Please have a read and let me know what you think. I am always willing to hear the opinion and advice from others.
Dear Mr......
I acknowledge your reply of refusal to my request for my Ford Puma to be given ULEZ compliance. I would like to appeal the decision by Transport For London (TFL) on the following grounds. In Your letter of refusal you stated the following;
● Euro 4 for petrol cars, vans, and minibuses (or Nitrogen Oxides (NOx) is or less than 0.080g/km)
I would like to point out that TFL has quoted the incorrect figure of 0.080g/km relating to Euro 4. I support my claim relating to your incorrect value by quoting the following documents.
Greater London Authority Act 1999, Transport Act 2000. Greater London Low Emission Zone Charging Order 2006. Sets out on page 33 that EC emissions standard of 0.08NOx for Euro 4.
Transport for London FIO request ID FOI-3195-2223. Date published 20th March 2023. In answer to question 2 states: Specifically “Petrol cars must be Euro 4 or have NOx emissions equal to or less that 0.08grams per kilometre.
Informal Document no.6 by The European Commission dated 2002. Annex 1. Passenger Cars and Light Commercial Vehicles Directive 98/69/EC states a mandatory tailpipe emission limits of Euro 4 to be the following values. CO 1.0 HC 0.1 NOx 0.08
As you can see from the above documents Euro 4 is valued at two decimal places and not as you have stated as a value to three decimal places. The value of my cars NOx at 0.083 if taken to two decimal places would indeed be a value of 0.08. If the standard rounding system was applied to 0.083 the value would still be 0.08.
Finally I would like to inform you that I personally know of owners of my model of Puma to whom TFL has granted ULEZ compliance. Consistency must be applied.
I therefore submit that there is sufficient evidence and reasoning for my Ford Puma to be granted ULEZ compliance.
Last edited:
yippeekiay
Well-known member
Ditto - good luck 
Maybe add "many" owners - Might make him get off his arris & actually check
Maybe add "many" owners - Might make him get off his arris & actually check
RICHARD MANSFIELD2
Active member
Hi Guys.
Thanks for your responses. I have sent it off........watch this space. I will leave the draft on the forum as it may be of future use to other members.
Regards, Richard.
Thanks for your responses. I have sent it off........watch this space. I will leave the draft on the forum as it may be of future use to other members.
Regards, Richard.
RICHARD MANSFIELD2
Active member
Hi.
I have received a reply, shown below. As expected just regurgitation of TFL standard mantra that did not answer the points I raised. I don't need to be compliant as I will not be driving in London but it is becoming a point of principle. Do I carry on, or do I draw a line under it?
The next stage is put it in writing and post it. They are trying to make id difficult in the hope people will give up.....Bast..ds. Reply below. Well what do you think guys?
Dear Richard Mansfield
Our Ref: TFL-2735089-1697529399
Customer Account Number: N/A
Thank you for your enquiry received 12 October 2023, about Ultra Low Emission Zone (ULEZ).
The?ULEZ?Scheme requires vehicles to meet the following standards:
● Petrol Vehicles must be Euro 4 or have?NOx?emissions equal to, or less than, 0.08 grams per kilometre.
Diesel Vehicles must be Euro 6 or have?NOx?emissions equal to, or less than, 0.08 grams per kilometre and
Particulate Matter emissions equal to, or less than, 0.005 grams per kilometre.
●
Please note:
● Euro 4 became mandatory for all new cars in 2005 and light vans in 2006
Euro 6 became mandatory for cars and light vans from September 2015 and September 2016 for larger vans up
to 3.5 tonnes.
●
As your vehicle X798ARX NOx emissions are above the ULEZ standards, it remains non-compliant and payment will
be needed when making a journey through the zone.
Different Ultra Low Emission Zone (ULEZ) compliance status rules apply based on a number of criteria.
It will therefore not be appropriate to generalise compliance status by make, model and year.
Vehicles with the same make/model, but with a higher gross weight and date of registration will result in different
vehicle type classification from vehicles with the same make/model and a lower gross weight and registration year.
It is the responsibility of the customer to provide sufficient information to prove a vehicle complies with the ULEZ
emission standards.
If you wish to escalate your complaint further, you will need to follow the Stage 2 complaints procedure.
This can be followed by visiting our website tfl.gov.uk/congestioncharge.
Please choose the "Contact Congestion Charge" tab on the right hand side of the screen.
Once you have chosen this step, a tab for "Congestion Charge Complaints" will then appear.
Following these steps will then advise you on how to take your complaint further.
If you have any questions, please visit tfl.gov.uk/ulez or call us on 0343 222 2222 (or Textphone 0207 649 9123 if you
have impaired hearing).
Yours sincerely
I have received a reply, shown below. As expected just regurgitation of TFL standard mantra that did not answer the points I raised. I don't need to be compliant as I will not be driving in London but it is becoming a point of principle. Do I carry on, or do I draw a line under it?
The next stage is put it in writing and post it. They are trying to make id difficult in the hope people will give up.....Bast..ds. Reply below. Well what do you think guys?
Dear Richard Mansfield
Our Ref: TFL-2735089-1697529399
Customer Account Number: N/A
Thank you for your enquiry received 12 October 2023, about Ultra Low Emission Zone (ULEZ).
The?ULEZ?Scheme requires vehicles to meet the following standards:
● Petrol Vehicles must be Euro 4 or have?NOx?emissions equal to, or less than, 0.08 grams per kilometre.
Diesel Vehicles must be Euro 6 or have?NOx?emissions equal to, or less than, 0.08 grams per kilometre and
Particulate Matter emissions equal to, or less than, 0.005 grams per kilometre.
●
Please note:
● Euro 4 became mandatory for all new cars in 2005 and light vans in 2006
Euro 6 became mandatory for cars and light vans from September 2015 and September 2016 for larger vans up
to 3.5 tonnes.
●
As your vehicle X798ARX NOx emissions are above the ULEZ standards, it remains non-compliant and payment will
be needed when making a journey through the zone.
Different Ultra Low Emission Zone (ULEZ) compliance status rules apply based on a number of criteria.
It will therefore not be appropriate to generalise compliance status by make, model and year.
Vehicles with the same make/model, but with a higher gross weight and date of registration will result in different
vehicle type classification from vehicles with the same make/model and a lower gross weight and registration year.
It is the responsibility of the customer to provide sufficient information to prove a vehicle complies with the ULEZ
emission standards.
If you wish to escalate your complaint further, you will need to follow the Stage 2 complaints procedure.
This can be followed by visiting our website tfl.gov.uk/congestioncharge.
Please choose the "Contact Congestion Charge" tab on the right hand side of the screen.
Once you have chosen this step, a tab for "Congestion Charge Complaints" will then appear.
Following these steps will then advise you on how to take your complaint further.
If you have any questions, please visit tfl.gov.uk/ulez or call us on 0343 222 2222 (or Textphone 0207 649 9123 if you
have impaired hearing).
Yours sincerely
I say keep going.
Interesting now that the wording has changed back to the original equal to, or less than, 0.08 grams per kilometre. You could challenge them on that correction vs their previous response, but keeping to the point:-
It took me 5 attempts before getting a success response. It's basically a matter of repeating the maths and challenging them to otherwise state their reasoning contrary to standard maths, in order for them to have rejected the appeal.
Where 0.083 is a three decimal notation, it has to go somewhere to become two decimal as used in Euro 4 - i.e. it has to be either 0.08, or 0.09 for the reference two decimal notation to determine compliance. Anything less than 0.085 to three decimal places has to become 0.08 to two decimal places by standard maths. I believe that my challenge back to them to otherwise explain their reasoning or else tell me the process to appeal finally did the trick, but there doesn't seem to be any real rhyme or reason to their correspondence
Below is the wording I used for the second to last correspondence (rejected with standard TFL response) and last correspondence which finally resulted in the successfully registered response:-
------------------------------------------------------
Thank you for your response received today.
You have stated in your response to quote:-
The required amount of NOx emissions equal to, or less than, 0.08 grams per kilometre for Petrol vehicles.
As stated on both V5C and Certification of Conformity, the vehicle's NOx standard is higher than the required amount (NOx 0.083 grams per kilometre).
You are correct that the vehicle’s V5C and Certificate of Conformity show the NOx emmissions as 0.083 grams per kilometer. However you are incorrect that this does not meet the reqired amount of NOx emission equal to or less than 0.08 grams per kilometer.
As stated, using standard maths, anything less than 0.085 is considered equal to 0.08 using standard maths rounding to two decimal places as is the notation used for NOx emmisions. Anything 0.085 and above is equal to 0.09. Since my vehicle is 0.083, by standard maths this is equal to 0.08.
As also stated you are working to three decimal places to determine the diesel particulate matter emmissions, so it is no accident that you are using two decimal places for NOx. You cannot simply determine that 0.083 does not equal 0.08 by standard maths, because indeed it does.
If you are not using standard maths to determine your conclusion, then as requested, please explain your reasoning that my vehicle does not have emmissions equal to 0.08 NOx.
Since your conclusion is clearly incorrect, based on standard maths and based on the evidence already provided, please correctly register my vehicle as compliant.
Regards,
------------------------------------------------------------------
------------------------------------------------------------------
Thank you for your response received today.
You have not advised as I have repeatedly requested, how you are concluding that my vehicle is not compliant. My vehicle does meet the NOx emission limit of 0.08 grams per kilometre.
As stated, using standard maths, anything less than 0.085 to three decimal places is considered equal to 0.08 using standard maths rounding to two decimal places as is the notation used for NOx emissions. Anything 0.085 and above is equal to 0.09. Since my vehicle emissions are 0.083 grams per kilometre, by standard maths, this is equal to 0.08 and therefore compliant.
As also stated you are working to three decimal places to determine the diesel particulate matter emissions, so it is no accident that you are using two decimal places for NOx. You cannot simply determine that 0.083 does not equal 0.08 by standard maths, because indeed it does.
Your conclusion that my vehicle is not compliant is clearly incorrect and you have provided no explanation as to how you have reached your conclusion, contrary to standard maths.
Please advise the process and contact details for how to appeal this decision.
Regards
-------------------------------------------------------------------
I say please keep going too.
At least TfL have acknowledged the fact that the standard is indeed less than or equal to 0.08 g/km, not 0.080 g/km as they stated in their previous response to you. I note that no apology has been offered for providing you with incorrect and misleading information though, something to put in your complaint if it gets to that stage.The 'blurb' in their response about not being able to generalise compliance by make, model and year is all 'smoke and mirrors'. They rejected your application based on the NOx value. They have failed to answer why other vehicles with exactly the same NOx value of 0.083 have been registered as compliant on appeal.
I suggest trying ulezpuma's approach first, by challenging them on the maths. If no success, then continue down the complaints procedure. There is then the Ombudsman who, hopefully, will see sense.
I am about to resume my battle with TfL. I got to the stage of four rejections from them, then my Dad died. I couldn't face replying to any more of TfL's inane responses. But I have not, and will not give up.
I also encourage you to keep going.
Incorrect decisions by bureaucrats should never be allowed to win.
Incorrect decisions by bureaucrats should never be allowed to win.
RICHARD MANSFIELD2
Active member
Hi guys, thanks for your support I will battle on. I have just sent a reply to Mr Milton (AKA DH) Reproduced below.
Dear Mr Milton.
Thank you for your response to my last email. I found it of not much use, all you did was to re quote the Euro 4 emissions specifications which I had previously quoted to you.
In a previous email to me you stated that TFL worked to a reading of NOx reading of 0.080 and not 0.08 as specified by Euro 4. Can you explain why it has changed in your last email to me back to 0.08?
Could you also explain to me Transport For London's reasoning of standard maths relating to the Euro4 emission specifications Where the NOx of 0.083 for my vehicle is a three decimal notation, it has to go somewhere to become two decimal as used in Euro 4 - i.e. it has to be either 0.08, or 0.09 for the reference two decimal notation to determine compliance. Anything less than 0.085 to three decimal places has to become 0.08 to two decimal places by standard maths.
In my last email I did inform you that I know of Ford Puma owners with identical emission specifications to my vehicle to whom TFL has granted ULEZ compliance. I know this as I am in regular contact with them. So I will ask why has TFL granted them compliance and refused me equal rights? I believe that on the facts outlined above my vehicle does comply and request TFL to grant ULEZ compliance.
I look forward to a meaningful reply to the specific points I have raised above.
Yours Faithfully
Richard Mansfield.
Dear Mr Milton.
Thank you for your response to my last email. I found it of not much use, all you did was to re quote the Euro 4 emissions specifications which I had previously quoted to you.
In a previous email to me you stated that TFL worked to a reading of NOx reading of 0.080 and not 0.08 as specified by Euro 4. Can you explain why it has changed in your last email to me back to 0.08?
Could you also explain to me Transport For London's reasoning of standard maths relating to the Euro4 emission specifications Where the NOx of 0.083 for my vehicle is a three decimal notation, it has to go somewhere to become two decimal as used in Euro 4 - i.e. it has to be either 0.08, or 0.09 for the reference two decimal notation to determine compliance. Anything less than 0.085 to three decimal places has to become 0.08 to two decimal places by standard maths.
In my last email I did inform you that I know of Ford Puma owners with identical emission specifications to my vehicle to whom TFL has granted ULEZ compliance. I know this as I am in regular contact with them. So I will ask why has TFL granted them compliance and refused me equal rights? I believe that on the facts outlined above my vehicle does comply and request TFL to grant ULEZ compliance.
I look forward to a meaningful reply to the specific points I have raised above.
Yours Faithfully
Richard Mansfield.
Divingtopps63
New member
- Joined
- Apr 12, 2018
- Messages
- 6
It's probably too late now - But I heard some people just tip-ex'd the '3' off of the COC(S) certificate and submitted it...
I agree wholeheartedly and if I was in the same situation I would fight it to the bitter end...
Good luck and hope you are successful in the end - You deserve it
I agree wholeheartedly and if I was in the same situation I would fight it to the bitter end...
Good luck and hope you are successful in the end - You deserve it
RICHARD MANSFIELD2
Active member
Reply received which beggars belief.
Thank you for your recent enquiry received on 19 October 2023, regarding your vehicle's compliance.
There are a number of factors which need to be considered when establishing whether a vehicle is compliant with the
ULEZ standards. These include the Euro standard, vehicle type, fuel type and Nitrogen Oxides (NOx) and/or
Particulate Matter (PM) values.
To update the compliance status of your vehicle, we encourage you to send us a copy of the vehicle's Conformity
Certificate and all four pages of the V5C.
We need the front page of the vehicle's V5C to verify the address - 2nd page has the details and the 3rd page of the
V5C confirms VIN information.
You may wish to contact the vehicle manufacturer's homologation department as they will need to provide you with a
letter signed by a named individual containing the following:
- Vehicle registration mark (VRM)
- Vehicle identification number (VIN)
- Euro standard the vehicle was manufactured to
- Fuel Type
- Nitrogen Oxides (NOx) value
- Particulate matter (PM) value (if diesel)
You can upload your document through an online enquiry form at tfl.gov.uk/ulez.
Alternatively, you can email the attachment to [email protected]. Please also include details of your query when
submitting your documentation.
If you have any questions, please visit tfl.gov.uk/ulez or call us on 0343 222 2222 (text phone 0207 649 9123 if you
have impaired hearing).
Yours sincerely
Thank you for your recent enquiry received on 19 October 2023, regarding your vehicle's compliance.
There are a number of factors which need to be considered when establishing whether a vehicle is compliant with the
ULEZ standards. These include the Euro standard, vehicle type, fuel type and Nitrogen Oxides (NOx) and/or
Particulate Matter (PM) values.
To update the compliance status of your vehicle, we encourage you to send us a copy of the vehicle's Conformity
Certificate and all four pages of the V5C.
We need the front page of the vehicle's V5C to verify the address - 2nd page has the details and the 3rd page of the
V5C confirms VIN information.
You may wish to contact the vehicle manufacturer's homologation department as they will need to provide you with a
letter signed by a named individual containing the following:
- Vehicle registration mark (VRM)
- Vehicle identification number (VIN)
- Euro standard the vehicle was manufactured to
- Fuel Type
- Nitrogen Oxides (NOx) value
- Particulate matter (PM) value (if diesel)
You can upload your document through an online enquiry form at tfl.gov.uk/ulez.
Alternatively, you can email the attachment to [email protected]. Please also include details of your query when
submitting your documentation.
If you have any questions, please visit tfl.gov.uk/ulez or call us on 0343 222 2222 (text phone 0207 649 9123 if you
have impaired hearing).
Yours sincerely
Escalate to complaint. D Milton (Donna Milton) is not competent to do her job.
D Milton handled mine as well. When originally submitted I included the V5 and the CoC. They emailed back to request the CoC. So I sent it again, they then emailed back to request the V5, specifically page 3 to confirm the vin (which is on page 2 and had already been sent). Anyway they eventually approved it. Mine is the lower value of .533 though.
Assume you already sent this information? In which case I agree with @den67 , go back and advise that you have already provided this information, repeat the basis for your appeal (for the record), stating why their opinion that your vehicle is not compliant is incorrect and why you believe this latest response is inadequate and ask them to advise the complaint process.
On the other hand if you haven’t provided specifically what they’ve asked for, do that first, it may be that you are indeed one step away from approval, so it’s probably worth playing their game for one more round before the complaint.
