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Badgers Mount Parish Council

Badgers Mount ULEZ extension consultation response

1st August 2022

Badgers Mount ULEZ extension consultation response

ULEZ Consultation



Mayor of London


Badgers Mount Parish Council would like to formally respond to your ‘cleanairyourview’ campaign and advise you of our strongest objection to the proposed expansion of the ULEZ Zone scheduled to commence in August 2023. With the greatest respect, TfL is absolutely not the right body to be carrying out this consultation. TfL is familiar with, and indeed responsible for, the excellent public transport system within Greater London. But TfL has no familiarity with the abysmal public transport system outside Greater London, which is a crucial consideration when examining the impact of the new ULEZ proposals and how they will affect the residents of Badgers Mount.

For context, Badgers Mount from the Sevenoaks District is located right on the border along Bromley and Orpington and are therefore hugely impacted by this proposal to charge ULEZ. Badgers Mount is also situated on the upper slopes of the North Downs within the Kents Downs AONB and largely within the London (Metropolitan) Green Belt. With a population of 500, local residents are entirely dependent upon cars since there is no public transport service whatsoever which serves the parish. Not a single bus service serves the parish! Whereas residents living within Greater London have the option of travelling by bus, residents of Badgers Mount have no such option.

The residents of the Parish are very passionate about the preservation of the Green Belt and thereby maintain not just the Air Quality but also the sustainable & harmonious life in the area and beyond.

The Parish Council believes that the ULEZ extension has not adequately taken into consideration, the adjoining areas and the Economic and Social implications that can wreak havoc to people’s way of life and businesses. Here are a few implications that are specific to our location:

  • Economic 
    • As a result of our location a majority of the residents of Badgers Mount work in London and commute to work. Due to the complete lack of public transportation here, with bus routes having been terminated, residents are forced to travel via cars to the closest station – Knockholt (for slow trains), Orpington (for fast trains) or St Mary Cray or Chelsfield Stations (for better connections to London offices). Taking cars to any of this Greater London Stations would incur the ULEZ charges on a daily basis. This will add considerable strain on individual residents who are already struggling due to the cost-of-living crisis
    • Knockholt is a little rural station and closest to the Parish, with only 2 trains an hour from Orpington. One can envisage that Knockholt station will become even more popular for commuters; it is already popular by virtue of being the last station in Zone 6, but it will increase in popularity with commuters many of whom currently drive into Chelsfield/Orpington but will be unwilling to pay £12.50 a day for the privilege. So Knockholt station will become inundated with commuters, but parking is limited and already at capacity, and the train service is very limited.
    • A large number of self-employed professionals residing here have clients in Orpington/Bromley (both in the ULEZ charge proposed) area. They will no longer be able to service these clients due to non-viability not just resulting in personal financial impact but also impact to the area of Bromley/Orpington etc from reduced services from such professionals. Some of the tradespeople (i.e., plumbers/mechanics/consultants) servicing the larger London area will find it unviable to service the city of London leading to large scale shortage of staffing and/or amenities. All these tradespeople are already under strain from Congestion Charge, fuel tax, Tolls (Dart Charge) extraordinary parking charges and will be further hit daily which will throttle the local economy by a considerable amount.
    • A number of workers travelling to nearby areas like Orpington/Bromley/Sidcup and working in the Public Sector (specifically Police)/Care/ Finance etc. will no longer find it viable to travel and will have to look for employment elsewhere leading to further staff shortages
    • Local businesses in Orpington/Bromley/Green Street Green in the Greater London area including Petrol Stations, Hospitality (Restaurants & takeaway), Supermarkets receive a lot of patronage from the residents of Badgers Mount. It will make it unviable for the residents to support the neighbouring local London businesses

  • Health & Well-being and Education
    • Nearest GP surgeries/Dentists and Vets for most residents are in Green Street Green or Chelsfield (both within the ULEZ Charge area). So, a trip to the GP or Dentist or to the Vet will result not only in additional charges but added stress and anxiety. Residents suffering from multiple health issues or undergoing Cancer treatment/follow-up will have to make multiple trips and paying for that. GP referrals are generally to hospitals within the ULEZ – the PRUH or other London Hospitals. Our closest hospital is Orpington Hospital or PRUH in Bromley.
    • Given the location, many Residents have friends and family members staying in the Greater London area. When visiting Badgers Mount by train they arrive at Orpington Station! To collect a visitor from the Station will cost more than collecting an overseas visitor from Gatwick. There are many buses from Orpington Station, but not a single one serves Badgers Mount.
    • A lot of our children attend school in Orpington and Bromley and/or attend extra-curricular activities there. Several residents’ children attend special needs schools that fall in the proposed ULEZ extension. Perhaps TfL is unaware of the complete lack of school bus services in this area. With no bus service, the only means of getting to and from school is by car. A cost of £12.50 a day just for attending school would be completely intolerable. The additional charges for any social activities will have a negative impact on the mental well-being, and potentially, children being left behind in their development.
    • We have a significant proportion of pensioners and vulnerable people in our community, who are already financially challenged by the cost of living and fuel crises. It is not feasible for them to change their vehicles to newer models in order to access health and wellbeing services.

  • Environmental 
    • TfL seems to be currently working on AQ data from inner London Boroughs which necessarily do not extend to the outer London Boroughs. So, it is unclear as to how adding financial burden on the Parishes bordering the outer London Boroughs will have a positive impact on the environment. Tfl has not shared any compelling data proving that the expansion of the ULEZ will benefit the environment & Air Quality. We are located in the midst of farmland and ancient woodland, enjoying clean quality of air already, and providing green cover to our nearest borough of London, Bromley

  • Supply shortages 
    • The global chip shortage has severely impacted the supply of Electric Vehicles, as also new petrol or hybrid vehicles. This is amply evidenced by media reports. The used car market has boomed due to the shortage, and therefore, does not necessarily provide a supply of affordable ULEZ compliant vehicles. The massive increase in demand for Electric Vehicles as well as parts have resulted in waiting times of over 18 months for the cars to be delivered. Common sense would dictate that those who can afford to upgrade to newer cars would switch to Electric Vehicles but that will not be possible for at least the next 18 months

In short, the Badgers Mount Parish Council would like to urge the Mayor of London to abort this stealth taxation until they have managed to sort out the following issues:

  • Provide clearer & specific information on exact zone boundaries where the charges would be applicable along with installing control systems that are fair and transparent
  • Study & publish more representative Environment impact & AQ data of outer London Boroughs & surrounding Counties
  • Improvement of public transportation network especially in the semi-rural areas adjoining the outer Boroughs of London. TfL must amend the routes of the R5 and R10 so as to visit Badgers Mount.
  • Improving the supply of affordable Electric Vehicles along with their ancillary infrastructure, including Charging stations and parking spaces

Given that everyone is going through a Cost of living and fuel cost crises, the introduction of ULEZ surcharges will have a hugely detrimental impact on the life of the residents of Badgers Mount. The ULEZ will provide no benefits whatsoever to Badgers Mount or its residents. On the contrary, it will cost our residents a huge amount of money. If the ULEZ extension is introduced, special arrangements must be made for residents of Badgers Mount, similar to the 90% discount given to Dartford residents who use the Dartford Crossing.

We recommend that the ULEZ charges should only apply to residents of Greater London, who at least have the option of avoiding the charge by using public transport, and not to people living outside Greater London, who have no such option for avoiding the charge.

Badgers Mount benefits from being largely covered by woodland, and hence benefits from good AQ, despite the fact that the M25 passes through the parish.

The people who benefit from the ULEZ scheme are the residents of Greater London. Non-residents of Greater London derive no benefit from the scheme. Therefore, it is the residents of Greater London who should be paying, and not the non-residents, who should therefore be exempt.

We strongly object to the proposed extension of the ULEZ Zone. Therefore, we urge the TfL & the Mayor of London to reconsider the decision, consult a wider group of people beyond the boundaries of London (but who are massively impacted) and look for more creative solutions to solving this problem.

Yours faithfully

Sejuti Roy

On behalf of the Badgers Mount Parish Council

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Montclare, Orpington Bypass, Badgers Mount, Sevenoaks, Kent TN14 7AG

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