Age Limit Exemptions.

Letter sent to: Luke Howard. With copies to: Peter Hendy, David Brown and Boris Johnson

Mr L Howard
Senior Strategy & Integration Manager
London Taxi & Private Hire, TFL
4th Floor 
Palestra
197 Blackfriars Road
London
SE1 8NJ
07 February 2011


Dear Mr Howard

Further to my email to you dated 14 December 2010 and your subsequent reply dated 20 December 2010 (attachment 1), could you confirm to me exactly who will be making the decision on what the exemptions to the taxi age limits will be, and who will be undertaking/formulating the recommendations to that person.


Obviously, as a working “emissions conscious” Licensed London Taxi Driver, I would like to have my input into the process as would some of my LPG Licensed London Taxi Driver colleagues. I have only used a LPG fueled Licensed London Taxi since earning my badge in May 2008.


In particular, I feel we LPG Taxi Drivers and owners have been overlooked in the whole process of the Mayor's Air Quality Strategy, despite my/our input/replies during the consultation process.


I see no mention of LPG in any part of the consultation, draft, or policy, despite LPG being the only clean, current, readily available option to diesel and petrol fueled taxis. LPG fueled taxis will meet the present and future Euro emission standards required through to 2020, and on that basis I see no logical argument that LPG fueled vehicles should to be excluded by age.


Brake and tyre emissions are not a factor for consideration in this process either, simple physics would suffice my argument in this area. The brake linings and tyres are of the same fabric/materials on all vehicles new or old, so the only logical factor for consideration in the brake linings and tyre emissions argument is kerb weight of the vehicle, a heavier vehicle is likely to produce higher emissions for brake and tyre wear. 


I know my LPG fueled Fairway taxi's kerb weight is less than all currently available taxis as follows:

Fairway Driver 1670 kg
Metrocab 1900 kg
TX 1 1800 kg
TX 2 1863 kg
TX4 1815 to 1975 kg
Mercedes Vito 2160 kg


Stopping and steering is reliant on three main areas (tyres, brakes, steering joints/suspension joints) and as taxi kerb weights have steadily increased over time, the emissions from brakes and tyres would obviously increased for the newer heavier taxis, thus, there is no argument in favour of limiting the age of taxis due to it's tyre and brake wear, in this instance quite the contrary, the older the taxi the better it's brake and tyre emissions are likely to be due to their lower kerb weight.


Therefore, this whole argument for the Mayor's Air Quality Strategy comes down to one area only, emissions from the engine. 


The age of taxis at present should have no bearing in any part of the strategy, engine/exhaust emissions should be the only factor considered if the Mayor's Air Quality Strategy is to be viewed by all concerned as creditable.


Retro-fitting those taxis not meeting the Euro standards by the required dates with abatement systems, pure LPG fueled engines, or part LPG and part diesel systems could be the most cost effective and viable option to all drivers at present, this combined with insistence that all new taxis from 2015 be fitted with LPG only fueled engines should meet the Mayor's Air Quality Strategy for emissions faster than that currently in place. 


London could have one of the cleanest public service taxi fleets in the world if it were to embrace LGP, whilst meeting the required Euro standards, and would go further towards the Mayor's vision of a zero emission taxi by 2020 than a diesel fueled taxi, when technology may well have caught up with the “Mayor's Vision”.

Battersea auto gas provide the following conversion for petrol engines full webpage link at:

http://www.lpg-car-conversion-london.co.....ry100613-113537

The following is an extract from their website (Attachment 2):


LPG Autogas Stag 300 PLUS new development with great results 

– Choosing LPG kitSTAG-300 plus 
Microprocessor sequential injection controller STAG-300 PLUS, was born out of renowned and reliable controller STAG-300. Modernized controller is equipped with updated software including the additional 3D graphics map allowing precise gas injection dosage with the relation to the engines' RPMs. With STAG-300 PLUS you have an option to manually correct the settings, depending on the temperature of the injected gas as well as injector warm up option. Because of the software update enabling an accurate gas injection dosage, STAG-300 PLUS passes EURO 5 emission norms. STAG-300 PLUS is designed for all vehicles equipped with 1 to 8 cylinder petrol engines, including turbo, full group, semi-sequential and sequential petrol injection as well as variable valve timing system „valvetronic” used e.g. in BMW. STAG-300 PLUS is equipped with petrol injection Emulator with Europa/Bosch connection and is compatible with AcGasSynchro software.

Advantages:
» 3D graphics map, injection dosage with the relation to the RPMs
» Digital graphics visualization
» RPM signal filter
» Injection type option
» Engine overload option
» Injector warm up
» Post-injection cut off level 
» Gas injection additional settings
» New CNG algorithms 
» Precise view of parameters in oscilloscope
» Intuitional controller calibration 
» Waterproof casing 
» Unnoticeable petrol to gas transition 
» Automatic switch to petrol on empty gas tank (sound signal)
» P/G switch with gas level indicator 
» Build in petrol injection Emulator
» Keeps the key engine settings e.g. power, torque identical to the petrol settings
» Fulfills the EURO 5 emission requirements
» Compatible with all reducers and gas injectors
» Available with Rail, Valtek, Reg, Zavoli injector type connections
» 3 year manufacturer warranty
The highlighted text confirms any petrol engine can fulfil Euro 5 emissions by fitting of the above conversion, take a look at the website and speak to the conversion company if need be.


If the Mayor's Air Quality Strategy is truly about emissions then please reconcile the following scenarios for me.

Diesel fuelled 2001 LTI TX1s, accredited with Euro 3 emissions are allowed to continue in service until 2016, whilst, LPG fuelled 1997 Fairway, with emissions as good as Euro 5 emissions has to be scrapped in 2012.

Diesel fuelled 2006 LTI TX2s, accredited with Euro 3 emissions are allowed to continue in service until 2021, whilst, LPG fuelled 1997 Fairway, with emissions as good as Euro 5 emissions has to be scrapped in 2012.

Diesel fuelled 2005 LTI TX4s, accredited with Euro 4 emissions are allowed to continue in service until 2020, whilst, LPG fuelled 1997 Fairway, with emissions as good as Euro 5 emissions has to be scrapped in 2012.

Diesel fuelled 2011 Mercedes Vito Taxis, accredited with Euro 4 emissions are allowed to continue in service until 2020, whilst, LPG fuelled 1997 Fairway, with emissions as good as Euro 5 emissions has to be scrapped in 2012.


I am sure you are aware of the recent High Court decision to over turn the imposition of an age limit on taxis in Newport: The Queen (on the application of Mr Lionel Morris) v Newport City Council

Similarly, I feel the imposition of such an age limit in London equally unlawful, on the following grounds:


• No age limit should be imposed on purpose built hackney taxis. These vehicles are built for taxi purposes and as long as these vehicles are kept in reasonable/good condition then there should be no reason for an age limit.

• Six monthly MOTs will be sufficient to ensure taxis are both emission and maintenance compliant to the current Euro standards and Ministry of Transport standards.

• The practical effects of this decision would mean that Licensed London Taxi Drivers who fell foul of the new age restrictions would go out of business if they could not afford new taxis.

• LPG Taxi Drivers have not been offered a chance to make their representation to you on this matter, there is no mention anywhere in the Mayor's Draft proposal or subsequent policy statements despite my direct replies to the draft strategy. In effect I feel my responses have been ignored.

• The exemptions to the age limits have not been defined to date, therefore we would be accepting an age limit without knowing the parameters or extent to which that decision would affect LPG Taxi Drivers.

• Many drivers are not members of trade organisations and were not represented in the consultation process, their interests being ignored by the licensing authority, and Licensed London Taxi Drivers were not balloted on whether they wish to accept the the imposed age limit. 

• Manufactures of taxis have a interest to impose age limits by way of sales of new taxis, and as manufacturers were included in the consultation process obviously they would be biased and in favour to of age limit, what better way to increase their sales. This being without any mention that manufacturers could clean up future emissions immediately by introduction of the relevant Euro standard LPG compliant engines. Manufacturer's introduction of Euro Standard LPG fuelled taxis would prevent the currently perceived necessity to impose age limits, natural wastage would determine age limits.

• If the Mayor's Air Quality Strategy is truly about emissions then LPG fuelled vehicles should be exempt from the imposed age limits, due to their extremely low exhaust emissions. 

• If one taxi with a Euro 3 emissions compliant engine is allowed to operate until 2021 then all Euro 3 taxis should also be allowed to operate until 2021. 

• Retro fitting older taxis with emissions abatement systems has not been considered, yet this option will be available for London Buses.

• Many local authorities around the country do not impose age limits on their taxi fleets, and chose to let Euro emission standards dates and MOT testing be the defining factors on whether a taxi is fit for continued use. I see no reason why this should be any different for London.

• Some ground work is already in place in regard to retro-fitting for both LPG and diesel fuelled taxis, which would bring all current taxis up to date with emission standards by way of an engine management/exhaust system. Two specialist London based companies have confirmed they are prepared to fund and formally test their own research/systems in this area, and on first view the companies believe such systems would be both attainable and financially viable, with a ball park figure ranging from £500 to £1200 for an installed system.


LPG fuelled cars are widely recognised as the cleaner option to diesel and petrol, and as such more suited to city driving. The following table obtained from
 http://www.p-i-fuelsystems.co.uk/lpg_conversions.htm
(Attachment 3) further demonstrates the emissions benefits derived from using LPG when compared to petrol and diesel fuelled engines.

LPG vs Petrol 
75% less Carbon Monoxide
85% less Hydrocarbons
40% less Nitrogen Oxides
10% less Carbon Dioxide
87% less Ozone forming potential
LPG vs Diesel 
90% less Particulates
90% less Nitrogen Oxides
60% less Carbon Monoxide
70% less Ozone forming potential

I would be highly surprised if a legal challenge was not brought against the policy to remove taxis over the age of 15 years from the London fleet.


Finally, with reference to PCO notice 16/03 which states (Attachment 4) -

"those vehicles that have been converted to LPG or re-engined to Euro III standard or better prior to March 2004 will be permitted to remain in service until the vehicles concerned are at least 20 years old"

I look forward to confirmation that my correspondence is being taken into consideration when the strategy for exempt vehicles is being formulated. In particular, I look forward to confirmation that my taxi a 1997 Carbodies Fairway converted to LPG in 2002 will be exempt from the 15 year age limit until at least 2017 as per PCO notice 16/03, during which time I expect a front-end replacement injection system will be fitted to my taxi (due to eventual injector wear/failure) which, will give Euro 5 emissions norms as per the LPG Autogas Stag 300 PLUS system available above, which should even negate the need to remove it from service as a Licensed London Taxi in 2017, especially as there will be Euro 3 taxis still in service until 2021.

In the meantime, if you have any queries please do not hesitate to contact me.


Yours sincerely


A Licensed London Taxi Driver

Attachments:
1. Email Correspondence
2. Battersea Auto Gas - LPG Autogas Stag 300 Plus system
3. P.I. Fuel Systems Ltd. - LPG vs Petrol - LPG vs Diesel - Emissions Comparison
4. PCO Notice 16_03 Taxis Converted to LPG

Copies to:
Boris Johnson, Mayor of London
Peter Hendy, Commissioner of Transport for London
David Brown, Managing Director of Surface Transport

****************************************************

REPLY from John Mason

14 February 2011

Mayors Air Quality Strategy - Age Limit Exemptions

Thank you for your detailed letter of 7 February 2011 addressed to Luke Howard. As Director of London Taxi and Private Hire I hold overall responsibility for the delivery of the initiatives relating to the strategy announced by the Mayor on 14 December 2011 for taxis and private hire vehicles.

I'm sorry your feel that the consultation and the final strategy did not cover the issue of exemptions, in particular, exemptions that may be provided to taxis with LPG systems. I can assure you that we are fully aware of the LPG systems fitted to a small number of taxis in the London taxi fleet and are currently in the process of finalising what exemptions, if any, may be provided.

With regard to your comments on the further retrofitting of taxis with equipment that would bring LPG and diesel fuelled vehicles "up to date with emissions standards". I have to inform you that having recently been approached by one such company who are at a very early stage of development we do not believe that such systems are capable of bringing taxis to full Euro V standard and as such we are not considering any exemptions for taxis fitted with such systems should they be brought to the market.

However, you outline some interesting points on the benefits of taxis currently converted to LPG and I am happy to confirm that such comments will be taken into consideration.

We will make a formal announcement on the exemptions as soon as possible.

Yours sincerely,

John Mason
Director - TFL, London Taxi & Private Hire
***************************************


Doesn't look good... I will write to him asking for clarification of whether, "taxis only fuelled by LPG" are not being considered if currently only Euro III, or whether "taxis fuelled by a combination of LPG and Diesel" are not being considered if currently only Euro III




Editorial Comment 


It is noted that Mr Mason completely side stepped the issue of the court case in Newport. This is the trend that has led to the trade rebelling against this administration. The truth will always prevail, it can not be ignored.


We would also like to take this opportunity to remind drivers that the time limit for making a legal objection to the Mayors proposed age limit is fast approaching. 
If you have not already done so, we would urge you to make a donation to Alan Fleming's Fighting Fund. Details of how you can donate can be found on the top right hand column.