From: Neil Lock
To: Jeremy Hunt MP, South-West Surrey (jeremy.hunt.mp@parliament.uk)
Copies to:
·
Rishi Sunak MP, prime minister (rishi.sunak.mp@parliament.uk)
·
Mark Harper MP, secretary of state for transport
(POCorrespondence@dft.gov.uk)
·
Keir Starmer MP, leader, Labour party (leader@labour.org.uk)
·
Cllr Nick Palmer, Waverley Borough Council (nick.palmer@waverley.gov.uk)
·
Cllr Paul Rivers, Waverley Borough Council (paul.rivers@waverley.gov.uk)
·
Cllr Penny Rivers, Surrey County Council (penny.rivers@surreycc.gov.uk)
·
Cllr Steve Williams, Waverley Borough Council (Steve.Williams@waverley.gov.uk)
11 September 2023
Dear Mr Hunt
ULEZ expansion: damaging, dishonest, and a disgrace to democracy
I write to protest in the strongest possible terms about
the recent expansion of the ULEZ ultra-low emissions zone to the whole of Outer
London. This is already causing serious damage to the lives and livelihoods of
many innocent people. Having bought their cars in good faith, they deserve to
be able to run them without any penalty, all the way to the end of the lifetimes
they were built for. And yet, this ULEZ expansion will take away entirely the
mobility of many older or poorer people in Outer London, who cannot afford
either to pay the charges or to upgrade their cars. As well as harming, or even
bankrupting, tradesmen who are themselves, or whose customers are, in the same
situations. It’s often not feasible for such people to use public transport;
and for some, the public transport isn’t even there. As Cllr Colin Smith of
Bromley Council has put it: “ULEZ has very little, if anything, to do with
health and is nothing less than a barely disguised socially regressive tax
which is now set to destroy businesses, jobs and vital social and support
networks.”
I myself lived in outer London in the early 1980s, when air
pollution was far worse than it is now. With the exception of diesel buses, I
did not notice any significant air pollution. And I was a cyclist in those
days. Measurements of pollutants on the roads of outer London now show no
problems at all relative to current air quality standards. (Except, perhaps,
for pollution from Tube trains!) Most people are now aware of these things. So,
we know that the ULEZ expansion is objectively unjustified, and no more than a
money-grab by Sadiq Khan.
Moreover, prime minister Rishi Sunak said recently: “I
just want to make sure people know that I’m on their side in supporting them to
use their cars to do all the things that matter to them.” And yet, he has
failed to follow this up by acting to postpone or cancel the expansion. This
calls into serious question whether Sunak is dealing in good faith with the
people he is supposed to serve. It also raises concerns about the directions in
which government, of whatever party, wishes to take us in the future.
And let’s not forget the history. In 2017, ULEZ was only a
gleam in Khan’s kleptocratic eye. In 2019, it came into effect in central
London only. Only the “city slickers” were affected, so why should ordinary
people worry? Then in 2021, Khan extended it everywhere inside the North and
South Circulars. Making inner London a “no go” area for those of us who live
outside. Now in 2023, he has extended it to all the London boroughs. If Khan is
allowed to get away with this, what will stop ULEZ or similar schemes being
extended to the whole of the Home Counties in 2025, every town and city in the
UK in 2027, and nationwide in 2029?
There seems today to be a political agenda to make car driving
unaffordable and all but unfeasible for ordinary people. While enriching both
government as a whole, and activist elements within it, particularly at the
local level.
As if the damage caused by ULEZ expansion, now and in the
future, was not enough, there have also been many instances of dishonest behaviour
shown by those on the pro-ULEZ side. For example, the deputy mayor, Shirley
Rodriguez, attempted in 2018 to get changed the conclusion of a scientific
study that found no evidence of benefits to child health from the original LEZ
(Low Emission Zone) that had been launched in 2008. Fortunately, the professor who
led the study, being a true scientist, had the integrity to refuse her request.
That same deputy mayor, in 2021, set out to whitewash an
Imperial College study that showed that the ULEZ had made only a marginal
difference to air quality after its introduction in 2019. As revealed by the
Independent, Rodriguez colluded with Prof Frank Kelly, head of Imperial
College’s “Environmental Research Group”, to issue a statement that
contradicted the findings of the study. Kelly did not help his cause when, in
June of this year, he wrote to prime minister Sunak alleging that politicians
were “not believing the science” on air pollution. But whose science?
Proper science, done with total honesty and according to the scientific method?
Or Kelly’s brand of politicized “science?”
Would you not agree, Mr Hunt, that individuals funded by
taxpayers’ money, who behave dishonestly in any part of their jobs, are acting
in bad faith towards the people they are supposed to be serving? And that they ought
to be subjected to sanctions, and even dismissal?
Then there is the case of Dr Gary Fuller’s “peer review”
of a paper written by a team from City Hall, which Khan hailed as a “landmark
report” and tried to use as justification for the recent ULEZ expansion. The
report attempted to compare emissions since the ULEZ expansion to the North and
South Circulars with a hypothetical scenario in which there had been no ULEZ. I
have not read this particular report, but I know enough about science to be
aware that such a methodology is fraught with huge dangers.
As I see it, science, when done properly, is fundamentally
honest. Politics, on the other hand, is almost without exception fundamentally
dishonest. And so, politics and science cannot mix, any more than oil and water
can.
But I looked up a bit more about Dr Fuller. Having been
one of those who set up the London Air Quality Network (LAQN) in the 1990s, he
has a strong background in the measurement of air quality. I applaud him for that.
But he is also a “Clean Air Champion” for the “Strategic Priorities Fund Clean
Air Programme.” Which is led by the Met Office and NERC (the Natural
Environment Research Council), which describes itself as “the driving force of
investment in environmental science.” All this is co-ordinated by something
called UKRI (UK Research and Innovation), and funded by the “Strategic
Priorities Fund” out of the “National Productivity Investment Fund.”
This is a politicized rabbit-warren of quangos, no? What
good does any of this do for the people who pay for it, the taxpayers? The
minister currently responsible for all this, so I understand, is George Freeman
MP. I wonder how aware he is of what is being done to us out of his budget and
on his watch.
I looked a bit further back into the past, too. Knowing a
fair bit about the history of COMEAP, I was not surprised to see, as another “Clean
Air Champion,” the name of Professor Stephen Holgate. Holgate was involved in
COMEAP’s 2009 and 2010 reports, which together set out to get a handle on just
how big a problem pollution from PM2.5 and nitrogen oxides was. (And, in my opinion,
failed to produce a result that was in any way credible). Holgate was also chair
of the working group that produced the 2016 Royal College of Physicians report,
which spawned the infamous “40,000 deaths a year from air pollution” meme. It
was, simply, the most politicized “scientific” report I have ever read.
Oh, and who was the chair of COMEAP just a couple of years
later, in 2018? Professor Frank Kelly. What’s down there isn’t just a
rabbit-warren. It’s one inhabited by snakes.
Meanwhile, Sadiq Khan calls critics of ULEZ expansion
nasty and false names like “conspiracy theorists,” “COVID deniers” or “vaccine
deniers.” A sure sign that he has no arguments with which to rebut the
criticisms. He is also chair of an extremist international “climate action” organization
of city mayors, called C40. Oh, and Khan claims the power to tax people who
live outside London. How can that be possible in a democracy, if they have no opportunity
to vote him out?
So: We have damage, serious damage, that is being caused
to innocent people by the ULEZ expansion. We have dishonesties, of many kinds, by
those in and paid by government. These include attempts to manipulate science
to support a political agenda. And some, perhaps many, of these attempts have
been successful. The whole farrago is a disgrace.
But there’s more yet. The UK is supposed to be a
democracy. That means that government is supposed to serve the governed. And
that what it does is only legitimate, when it operates for the benefit of, and
with the consent of, the governed.
I will quote from the Second Treatise of Government, written
in the late 17th century by John Locke, father of the Enlightenment.
“The great and chief end, therefore, of men uniting into commonwealths, and
putting themselves under government, is the preservation of their property.” “The
end of law is not to abolish or restrain, but to preserve and enlarge freedom.”
“Their [government] power in the utmost bounds of it is limited to the public
good of the society. It is a power that hath no other end but preservation, and
therefore can never have a right to destroy, enslave, or designedly to
impoverish the subjects.” The “public good” he defines in the First Treatise:
“the good of every particular member of that society, as far as by common rules
it can be provided for.” He also says: “Wherever the power that is put in any
hands for the government of the people and the preservation of their properties
is applied to other ends, and made use of to impoverish, harass or subdue them
to the arbitrary and irregular commands of those that have it, there it
presently becomes tyranny.” These words, I think, are of great relevance to our
case.
The tale of the “judicial review” of the ULEZ expansion,
in response to a case brought by four London boroughs and Surrey County
Council, is a very sad one. Here is Hillingdon Council’s statement of its grounds
for challenging the ULEZ expansion:
1.
Failure to comply with relevant statutory
requirements.
2.
Unlawful failure to consider expected compliance
rates in outer London.
3.
The proposed scrappage scheme was not consulted
upon.
4.
Failure to carry out any cost benefit analysis.
5.
Inadequate consultation and/or apparent
predetermination arising from the conduct of the consultation.
Was the process a proper judicial review? Did the judge go over again, with an unbiased eye, all aspects of the case, and make a considered judgement on each of the challenges? (Is that not what “review” means?) Not a bit of it. The judge did not even accept for consideration the two most important grounds for challenge: the lack of cost-benefit analysis, and the lack of adequate and fair consultation. He went full-on with the establishment line, looked for small “points of law” which supported Khan’s side of the case, and ruled against the councils. I have read the judge’s ruling, and it comes over to me as a “snow job.”
As to consultations, I have noticed that in recent years
government has again and again failed to consult the public properly on
environmental matters. An example of this was the 2020 “consultation” on the
proposed ban on petrol and diesel cars. All submissions that did not conform to
the establishment line – do it, and do it super-quick! – were completely
ignored. On this ULEZ expansion consultation, I am aware that there were
accusations of impropriety, notably those made by Crispin Blunt MP. I have not
been able to find any refutation of Mr Blunt’s allegations. That Hillingdon
Council’s challenge to this consultation was not even considered by the
judicial review, makes me very concerned indeed.
On cost-benefit analysis, the trail is even more
confusing. In fact, I haven’t been able to find anything even purporting to be
a cost-benefit analysis for the ULEZ expansion into Outer London. I did find a
reply to an FOI request, which suggested that a “business case” was made for
the 2021 expansion to the North and South Circulars. Such a thing might,
perhaps, have been a “cost-benefit” analysis from Transport for London’s point
of view. But I have seen no evidence that anyone in government has tried, in an
objective and unbiased way, to compare the costs to the people of ULEZ
expansion to Outer London against the benefits.
The costs to the people are not only the direct ULEZ
charges, but also the knock-on effects which, in the words of Cllr Smith, “destroy
businesses, jobs and vital social and support networks.” The putative benefits
come from the improvement in air quality, which is to be expected. The two ought
to be compared. In theory, the air quality benefits should be estimated by
DEFRA, based on recommendations made by COMEAP as to how to do the calculations.
But COMEAP, looking at their latest (2018) report, seem unable to agree on how
to combine the “risk factors” for different pollutants. (Even if the risk
factors were accurate in the first place!) As a result, I can only conclude
that no proper cost-benefit analysis has been done, or even attempted, on
the expansion of ULEZ to Outer London.
Recall that according to Locke, government has no right
“to destroy, enslave, or designedly to impoverish the subjects.” What that
means today is that all government projects, of any significant size or
reach, ought to undergo rigorous and unbiased analysis, to check that the
benefits of the project to the people actually will outweigh the costs to them.
And, because the “public good” is “the good of every particular member of that
society,” no individual may be unjustly harmed, by being saddled with more
costs than they receive benefits. Where costs versus benefits are unclear for a
project, then the true version of the precautionary principle, “Look before you
leap,” should be applied. And the project should not even begin.
Next, Mr Hunt, I feel the need to address you, not just in
your role as “my” MP, but also in your official capacity as Chancellor of the
Exchequer. You are the current custodian of the government’s “green book,” the set
of procedures meant to guide cost versus benefit analyses carried out by the UK
government. In March 2020, a review was instituted which resulted in changes to
the green book. I quote from the government’s web page describing the change: “The
2020 review of the Green Book concluded that it failed to support the
Government’s objectives in areas such as ‘levelling up’ the regions and
reaching net zero. The review said this was because the process relied too
heavily on cost-benefit analysis, also known as the benefit-cost ratio (BCR).”
And there was “insufficient weight given to whether the proposed project
addressed strategic policy priorities.”
All this seems to imply that policies that the politicians
in power deem to be “strategic,” including “net zero” and – presumably, given
UKRI’s funding source – ULEZ, are to be exempted from cost-benefit analysis! No
matter how nett damaging the effects of those policies will be on the people
the government is supposed to be serving. You of course, Mr Hunt, will be well
aware which of your predecessors was responsible for this gross betrayal of the
duty of government to act for the benefit of the governed. But for everyone
else, I will simply say that his name has already appeared in this letter.
And that isn’t all. There are wider issues of human
rights, too. We have a human right to freedom of movement. Article 13(1) of the
UN Declaration states: “Everyone has the right to freedom of movement and
residence within the borders of each State.” Our basic right to be able to move
around freely should not even be questioned, let alone suppressed.
Of course, this freedom must be tempered by our
responsibility, if our chosen means of movement causes a negative externality (side-effect)
to others, to compensate those who are harmed by it. But the process of
assessing such an externality must begin by working out the aggregate costs of
the externality to all those affected by it. And in the case of air pollution
from cars, this is precisely the “social cost” of the pollution, for
calculating which DEFRA, guided by COMEAP, are responsible, and which appears
not to have been done at all in the assessment of the ULEZ expansion.
Now, I was trained as a mathematician. So, I know how to do
calculations. Back in 2017, I calculated the social costs of the PM and NOx
pollution from cars in the UK, based on COMEAP’s reports and guidelines up to 2015.
(https://wattsupwiththat.com/2017/08/11/the-social-costs-of-air-pollution-from-cars-in-the-uk/.)
The ULEZ charges were at least an order of magnitude higher than the actual
social costs per car per year. So, ULEZ was a scam from the very start. And who
came up with the ULEZ idea? A certain Boris Johnson.
We also have a human right to privacy. Article 12, first
clause: “No-one shall be subjected to arbitrary interference with his privacy.”
Now, the network of cameras, which has been installed to police ULEZ,
constitutes, in my opinion, serious interference with our privacy. For
government, or anyone else, to track every journey made by a car in an
area, without good and provable reason (for example, a reasonable suspicion of
real criminal activity), is to trash our right to privacy altogether. Even if
these cameras were not being used to enforce Khan’s thieving scheme, I would
still think of them as like a criminal “stalking” me. That is, persistent and
unwanted attention that makes me feel pestered or harassed.
There is a wider issue yet: the relationship between
government and the governed. In recent decades, successive governments of all
parties have taken to treating us more and more harshly, more and more
aggressively, more and more dishonestly, and with less and less of the dignity
which is due to us as human beings. We have been taxed ever more stringently.
Ever more restrictive rules have been imposed on us, including ever tightening
“targets” and “limits” on air pollution, and government overreach on COVID
lockdowns, and vaccination passports and mandates. And the claimed “benefits”
of these things never seem to materialize. All the parties that have been in
government in the last half century and more have done, and are doing, similar bad
things to us. And we’re just about at breaking point.
Then there is the matter of the side-lining of democracy.
Democracy has many faults; for example, when there is no-one worth voting for,
you are in effect disenfranchised. But a vote becomes of no value at all when
policies and the direction a country takes are being set, not by the people,
but by external forces. The EU, the United Nations, the World Economic Forum,
the World Business Council for Sustainable Development, C40, and others: all are
seeking to drive (no pun intended) the world in a direction that is diametrically
opposed to the nature, the needs and the desires of us human beings. They
clearly hate, and have contempt for, Western civilization, and want to destroy
our prosperity and everything we have achieved.
In the case of air pollution, the ultimate problems lie with the UN and its WHO. The UN is also, as you will know, the driving force behind the monstrous scam that is the green agenda as a whole, including “sustainable development” and “net zero.” In a democracy, should it not be the people who determine the direction in which a country moves? Not unelected, unaccountable third parties with agendas hostile to human civilization? And is it not part of your remit, Mr Hunt, as MP for South-West Surrey, to defend the people of South-West Surrey against all attempts to impose on us any such policies, which go against our interests?
Many people, particularly in the media, seem to be
surprised by the level of anger that is being shown, not only by those directly
affected by this ULEZ expansion, but also by those outside London who, like me,
are opposed to anti-car policies. The reason is not just because we have
sympathy for our fellow human beings in their troubles. It is also because we
know that, if this is allowed to go any further, we are likely to be next on
the chopping block.
Personally, I don’t expect the ructions over ULEZ
expansion to die down any time soon. I expect them to escalate, at least to the
level of the poll tax protests, maybe to another Winter of Discontent or even
another 1642. These are “interesting times” indeed.
Mr Hunt, you are my supposed representative in parliament.
(I say “supposed,” because you have often supported policies to which I am
adamantly opposed, such as EU membership, “climate change” levies and
restrictions, IR35, and wars in places like Syria.) To be brutally frank, I
don’t expect that you will want even to try to do anything to help me or
people like me. But at least I have managed today to put on record some of the
real issues that plague us human beings in this country. It behooves you, and all
other politicians, to start working for the people you are supposed to
represent, instead of against us.
I will leave you with more words of my 17th-century
almost-namesake and intellectual father, John Locke. “But if a long train of
abuses, prevarications and artifices, all tending the same way, make the design
visible to the people, and they cannot but feel what they lie under, and see
whither they are going, it is not to be wondered that they should then rouse
themselves, and endeavour to put the rule into such hands which may secure to
them the ends for which government was at first erected.”
Yours sincerely,
Neil Lock
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