Under the current guidelines set out by Transport for London (TfL), the ULEZ (Ultra Low Emissions Zone) charge has a rigid timeline that requires non-compliant vehicle owners driving into London to pay £12.50 per day if they access specific areas of the city between a midnight-to-midnight window.
Non-compliant vehicle owners, whose shifts cross over the midnight threshold, will be charged twice – both for the 24-hour period pre- and post-midnight.
Recent industrial action has also seen train and underground services axed across the city as workers from Aslef and RMT strike over pay and working conditions.
This means public transport has not been available on strike days after 7pm, leaving many more night workers forced to pay ULEZ charges for driving in the specified areas.
What's more, the Mayor of London, Sadiq Khan, and TfL have announced the expansion of London's ULEZ from the 29th August 2023 in order to cut pollution around the capital. The expansion is mapped to cover all 33 boroughs of Greater London, in some places bordering the M25.
Call for review
NTIA chief executive Michael Kill said the potential impact on the workforce at night was “quite considerable”.
He urged the Mayor and TfL to consider reviewing the scheme to account for a rolling 24-hour period within its charge structure to create a “fair and considered” fee that did not penalise night staff for their hours of work.
London has an estimated population of around 8.6m according to 2023, with around 1.4m working at night within the capital in industries including hospitality.
According to Transport Statistics Great Britain (TSGB) & Department of Transport London has the lowest commuter numbers accessing the capital by car, compared to other regions at around 70%, only 27% access London by car.
This means 369,900 people working at night in the capital travel in by car to work. Recent estimated figures from GLA also suggested only 10% of those travelling by car will be in vehicles that are non compliant, resulting in a potential 36,990 night workers potentially being subject to multiple ULEZ charges.
Michael Kill said: "As we move towards expanding the ULEZ scheme across London, and the implementation of a scrap-page scheme which has the right intention, but does not consider the current climate, particularly for low income workers.
"It is clear that for some time now the ULEZ system limitations has exposed thousands of night workers to additional costs disproportionately for working at night."
Kill continued: "The night-time economy sector has struggled to maintain a consistent workforce for the past three years, with many workers already stretched and under considerable financial pressure.
“Exposure to these additional charges will substantially lower people's pay and will not help businesses to recruit people within the sector in the future.”
He also called for consideration of the impacts of industrial action on workers who may have no other option but to get to work via car or alternative modes of transport at a time when the cost-of-living crisis was pushing people to breaking point.
A spokesperson for the Mayor of London said: “The Mayor has been clear that the decision to expand the Ultra Low Emission Zone London-wide was not an easy one, but necessary to tackle toxic air pollution. Around 4000 Londoners die prematurely each year due to air pollution, children are growing up with stunted lungs and thousands of people in our city are developing life-changing illnesses, such as cancer, lung disease, dementia and asthma.
“The ULEZ is a very targeted scheme – nine out of ten cars driving in outer London are already ULEZ compliant and will not have to pay the charge. The Mayor has introduced a £110m scrappage scheme to help eligible Londoners, including those on low incomes, to replace their old polluting vehicles.
"Having listened to feedback from Londoners, this month the Mayor expanded the scrappage scheme eligibility to tens of thousands more Londoners, including all those receiving child benefit and small businesses and charities in the capital, from the end of July.”
- Figures estimating the number of night workers have been revised by the NTIA from 58,000 to 36,990