LEZs: Highly eruptive areas!

Paris ZFE


The LOM, acknowledging France's international commitments to improve air quality, has required that LEZs (low-emissions zones) be established in an increasing number of cities. Whether newly established or established for a longer period of time, these LEZs announce measures for next year or the following years which, although they go somewhat unnoticed, are nonetheless extremely binding in the short term. They seem so out of step with the provision of passenger cars and light commercial vehicles to households and businesses on the one hand, and with the ability of both to renew their fleet on time on the other, that they risk placing elected officials on political volcanoes. LEZs would then become highly eruptive zones.

While Boris Johnson announced that his country will ban the registration of thermal vehicles as of 2030 (instead of 2035), France - like Spain - maintains for the moment this objective at the 2040 deadline and seems, as a manufacturing country, to have heard the industrialists.
When we know how much the sector has already suffered from the decline of diesel for the past five years and when we know the road of the cross that will have to be travelled when petrol engines cease to provide the relay and become scarce in their turn, we can only welcome what will appear as "laxity" in the eyes of the most radical ecological circles.
However, just as in the United States, where Trump's climate scepticism and his regulatory translations had been challenged by many states, including California, this national calendar is now tending to collide with the emerging decisions on LEZs.
It should be recalled in this respect that the LOM - adopted on 24 December 2019 - in its Article 86 provided that, in order to meet its air quality commitments, France would multiply the LEZs by adding to the four already existing LEZs those that would be imposed on local authorities to set up in the event of "regular non-compliance with air quality standards giving rise to an obligation to establish a low emission mobility zone" (LEZ-m).
In order to make the LOM effective, a decree was published in the OJ on 17 September last, inserting two new articles into the General Code of Local Authorities (CGCT) to specify which municipalities are concerned. The new Article D. 2213-1-0-2 specifies that "administrative air quality monitoring zones, defined pursuant to Article R. 221-3 of the Environment Code, in which one of the limit values relating to nitrogen dioxide (NO2), PM-10 particles or PM-2.5 particles mentioned in Article R. 221-1 of the Environment Code is not complied with at least three years out of the last five years" are considered to be in breach of the air quality standards. 
The Ministry of Ecological Transition then specified in a press release that, concretely, the application of the decree implied that "seven new LEZ-m will have to be obligatorily set up by French metropolises: Aix-Marseille-Provence metropolis, Nice-Côte d'Azur metropolis, Toulon-Provence-Méditerranée metropolis, Toulouse Métropole, Montpellier-Méditerranée Métropole, Strasbourg Eurometropolis and Rouen-Normandie metropolis". The ministry specified that, by 2025, all conurbations with more than 150,000 inhabitants, i.e. 35 territories, will have to create a low-emission zone.  
For the latter and for those already under study (13) that could be imposed before 2025, households and businesses still have a few months or years before being affected, but for the 11 LEZs that will be effective on 1 January 2021, things are becoming clearer and we are beginning to know how the perimeter of each one will be defined and what measures and timetables elected representatives will decide on concerning them.

F. Lagarde reported on 2 December on the measures taken by the Grand Paris. Things are becoming clearer concerning Lyon and Toulouse. In almost all cases, the overbid is on the march and each will want to be stricter and faster than the other, with Paris playing the leading role in this case.
In Lyon, for example, where the metropolis is now EELV, the restrictions still only concern professional vehicles, but from 1 January 2021, Crit'Air 3 will be banned from driving and parking in the EPZ. This means that LDVs that are not Euro 5 or Euro 6 are banned and/or that vehicles registered before 2011 are no longer allowed: in the evaluation of the French LDV fleet that we were able to make with ANFA on the basis of figures from the French Insurance Federation, this would correspond on 1 January 2021 to some 1.95 million of the 7.34 million LDVs in the fleet (26.5%).
With annual registrations of LCVs which, over the last 10 years, have only exceeded 400,000 in one year (in 2011) and are on average around 350,000, it would take between 5 and 6 years of registrations for the measure to be "neutral". The steering committee of the LEZ of the Metropolis of Lyon does not intend to stop there and indicates that, several tracks will be studied such as :
- reinforcing the conditions of access to the zone and banning Crit'Air 2 stickers, i.e. all Diesel ;
- extending the geographical perimeter of the LEZ to new municipalities;
- extending the LEZ - which for the moment only concerns professionals - to private individuals.
In Toulouse, the LEZ has just been created and it is on 11 December that the first provisions were voted. Jean-Luc Moudenc, LR mayor, wanted measures spread over four years and indicated: "Because we do not practice punitive ecology, we have chosen to spread out the restrictions so that everyone has time to get used to them". 
In concrete terms, by 2022, Crit'Air 4 and 5 vans and heavy goods vehicles will no longer be allowed to circulate in Toulouse. In 2023, this will be the case for all motorised vehicles with stickers 4 and 5. Then, in 2024, all those with stickers 3, 4 and 5. According to our estimates, on 1 January 2024, there will be 2.9 million LCVs (39% of the fleet) in France and 13.6 million passenger cars (33% of the fleet). 
One can certainly try to convince oneself that the old car parks are not in the metropolises but in the urban and peri-urban zones, but, in front of these short term bans of Euro 4 vehicles, this defence does not hold.
As for professionals, one only has to go through the streets of the big cities or their close suburbs to see that building craftsmen have LCVs that are very often registered in the neighbouring departments and which are rarely Euro 5 and always Diesel.
Deliveries are not all assured, far from it, by gleaming commercial vehicles less than five years old chartered by large courier companies or the giants of distribution: online commerce has used up a large part of its logistics chain and it is with VPs or LCVs that will be banned in the future that we are being delivered. On the private individual side, the LEZ is becoming a grant that leaves people with undesirable vehicles at the gates of the peripherals.
The extent of the renewal of the fleet required by the measures that are being taken does not seem to have been evaluated and, even if this renewal did not come up against the household accounts or the operating accounts of the companies concerned, it would be industrially out of reach in time.
In the prospective fleet that we have produced, in a scenario in which battery EV registrations would reach 75% of passenger car registrations and 80% of light commercial vehicle registrations by 2035, we arrive at a structure of light vehicle pacs on 1 January 2036 in which thermal vehicles still account for 60% of the fleet, almost half of which would still be diesel vehicles.
Since the public authorities will not be able to subsidise, even to the extent that they do today, the purchase of new vehicles for more than a decade, taking thermal vehicles out of a fleet that is 11 years old on average, will continue to age and is renewed each year in a proportion of less than 5% cannot take less than 25 years. 
If the operation were planned by significantly lowering vehicle prices and/or by proposing to finance the purchase of these vehicles with long-term loans at low interest rates, relying on the reliability of EVs and taking advantage of the drop in user costs, this cycle could undoubtedly be accelerated, but nothing of the sort is taking shape. For the time being, clean vehicles are still more expensive than dirty ones, and on both the household and business sides, new vehicles are in the minority in terms of equipment. 
In this context, and in view of the political situation that has emerged in recent municipal elections and the criminalisation of attitudes that are insufficiently protective of air quality, elected representatives in both old and new LEZs are taking decisions that are rarely violent from a social point of view and could well transform the LEZs into highly eruptive areas from a political point of view. 



The weekly column by Bernard Jullien is also on www.autoactu.com.

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