LEZs: Finally on a realistic path for itinerant professionals ?

The implementation of Low Emission Zones (LEZs) is not a smooth sailing journey ! The flexibilities granted by the government and the establishment of consultation bodies allowing professionals to make their voices heard are leading to more realistic timelines. But are all obstacles truly cleared ?

Currently being deployed in 11 major cities*, the LEZ system must be extended by 2025 to all urban areas with over 150,000 inhabitants not meeting air quality standards. For both individuals and professionals, traffic restrictions on certain categories of vehicles translate into the concrete implementation of low emission zones. The timing of these restrictions is at the heart of the issues and social acceptance of LEZs. It determines the date by which both individuals and professionals will be compelled to replace their vehicle(s) to continue operating within restricted areas.

* Paris, Lyon, Aix-Marseille, Strasbourg, Rouen, Reims, Saint-Etienne, Grenoble, Toulouse, Montpellier, Nice.

A more flexible but still complicated timeline…

However, the originally set timeline as per the Mobility Orientation Law (LOM) of 2019 and the Climate and Resilience Law of 2021  was deemed too ambitious from the outset and frankly untenable considering the composition of the French automotive fleet, especially the prominence of diesel vehicles and/or those classified as Crit’Air 3 and Crit’Air 2, which are subject to the upcoming traffic bans in the existing 11 LEZs.

Faced with citizen opposition, professional mobilization, and the challenges encountered by elected officials responsible for LEZ implementation, the government has relaxed the timeline, emphasizing the improvement in air quality observed in most cities. Building on this criterion, a new typology has been established, distinguishing between territories consistently exceeding regulatory air quality thresholds and those not meeting them. The former are renamed “LEZ territories” and subject to stringent timelines; the latter, renamed “vigilance territories,” enjoy greater flexibility, whether the LEZ is already in place or in the planning stage. Consequently:

>> on July 10, 2023, LEZs in Reims, St-Etienne, Grenoble, Montpellier, and Nice were exempted from the ban on Crit’Air 3 vehicles by January 1, 2025.

>> on March 19, 2024, this exemption was extended to Aix-Marseille, Strasbourg, and Rouen.

As of now, the exclusion of Crit’Air 3 vehicles by January 1, 2025, only applies to Greater Paris and Greater Lyon. However, despite being exempted, Strasbourg, Montpellier, and Grenoble have announced their intention to maintain their timeline and therefore ban Crit’Air 3 vehicles by 2025. Ongoing negotiations with various stakeholders could lead them to reconsider their positions and postpone this ban to 2028 or 2030, as other exempted territories have done.

The ban on Crit’Air 2 vehicles, the most controversial as it practically corresponds to the elimination of all diesel vehicles, is left to the discretion of each local authority. It is likely that all urban areas planning to exclude them before 2028 will backtrack.

Persistent issues for itinerant professionals

The postponement of ban deadlines has been hailed as a victory by citizen associations and politicians critical of LEZs. However, environmental advocates see it as a retreat because, as highlighted in March 2024 by the president of the Respire association :

«Yes, air quality is improving, but it remains poor. The levels measured in France still far exceed WHO recommendations. Moreover, the reference levels are completely outdated and will be drastically lowered as part of the revision of the European directive on air quality. »**

For professionals, the adjustment of LEZ timelines falls short of solving everything. In fact, LEZs were not designed with the transportation and logistics professionals in mind, and more broadly, for all those whose professions require them to travel—by car, van, or truck—within regulated areas. The mobilization of industry stakeholders today tends to impose a distinction between “Logistics LEZs” (or freight LEZs) and “Individual LEZs.” Absent from legislative texts, this distinction is justified by differences in stakes and implementation modalities highlighted by Xavier-Yves Valère, Head of Freight and Logistics Mission at DGITM (General Directorate of Infrastructure, Transport, and Mobility, Ministry of Ecological Transition and Territorial Cohesion).

« What we do for individuals is what I call a ‘sweeping car policy’: we assist those who have the most difficulty meeting air quality standards. And if the diesel fleet does not decrease, if we notice affordability issues, we are tempted, for social acceptability reasons, to postpone the date.

For freight transportation, it’s entirely different. A professional investing in a clean vehicle does not do so based on LEZ deadlines. It could be 3 years before the deadline, which means that for 3 years, they will compete with those offering the same service but with well-amortized diesel vehicles that cost them three times less to operate. There is no market mechanism to value virtuous transport. »

Faced with the market’s inability to inherently value virtuous investments, professionals express three closely related expectations:

1 – Adherence to announced deadlines, as those who invest in a timely manner must be assured that everyone will be checked and those not meeting the standards will be penalized. As of now, not only have the dates been changed multiple times, but also, no automatic LEZ control system has been deployed yet. The radar system currently being evaluated by national authorities will not be approved before 2026.

2 – Taking into account the vehicle supply when establishing timelines. If the supply to meet air quality standards does not exist or is quantitatively insufficient, it is simply impossible for all stakeholders to comply with the scheduled dates. Consultation with manufacturers of “clean” vehicles is therefore an essential prerequisite for establishing realistic prohibition schedules for professionals.

3 – The municipality must offer benefits/facilities to those who invest. While lamenting the proliferation of local exemptions, transportation professionals demand privileges to valorize their investments. This could include the possibility of nighttime deliveries or access rights to pedestrian areas if you have an electric truck without a compressor (thus silent). Such facilities provide a tangible commercial advantage to those bearing higher operating costs.

« To create a freight LEZ, we need to agree on the rules and create conditions that correct what the market won’t do on its own. We are in the process of inventing the rules of the game making freight LEZs acceptable for professionals and therefore effective. »

Harmonization of rules is underway

Leaving it up to local authorities to define the schedule, scope, and rules of their LEZs has resulted in an unreadable situation in space and time, with multiple temporary or permanent exemptions posing countless operational problems for itinerant professionals. The Union TLF, which brings together 2,000 transport and logistics companies, has constantly reminded that, by nature, transporters operate in several territories and called for harmonization of LEZ rules at the national level. This is one of the tasks of the ministerial committee for urban air quality established at the end of 2022, to which professional unions, local authorities, and DGITM have been associated. This collective work has allowed stakeholders to agree on observations regarding:

• the operational realities of transporters;
• industrial production of vehicles;
• fleet renewal rates, which vary significantly depending on whether you are a self-accounted transporter or a transporter for others.

« We feel, thanks to this collective work, a form of awareness from local authorities and public decision-makers. In addition to more realistic timelines, what is beginning to emerge is a common set of regulations and notably exemptions that could apply nationwide and simplify everyone’s lives. »

Transporters who play the game

Clear, stable, and homogeneous rules are all transporters are waiting for. They are ready to fully embrace the LEZs, provided they are economically supported in transitioning their fleets. Hence their request for simplification of aid through the establishment of a one-stop-shop. As Pierre Lefevre, Head of Indirect Purchasing at the Pomona Group (2350 trucks) explains: « Economic support is essential because alternative energy trucks are significantly more expensive than thermal trucks. In view of the widespread implementation of LEZs, we are gradually integrating biofuels (B100, HVO) and starting to look at 100% electric, with a more difficult economic equation to solve. There are multiple types of aid. Some are reserved for smaller businesses. Projects launched by ADEME require the preparation of a specific file to hope for some form of aid. It’s hit or miss, and it doesn’t always align with our fleet renewal and greening plans. Combining all this with contract end dates is not always easy. »

« The transition to electric also implies adapting the available electrical power on our sites. Economically, today, we have more to lose than to gain. But we have a low-carbon trajectory to respect, and we must move forward. With LEZs, it’s somewhat under duress, but ultimately, it’s also an opportunity. »

>> To find out exactly which vehicles can circulate in existing LEZs, we remind you of the existence of the zfe.green platform, which lists all current exemptions.

>> We also remind you that LEZ perimeters and restrictions are integrated into the graphs used by Nomadia’s route planning and optimization solutions. And because the implementation of LEZs is essentially in its infancy, this data is and will be updated as necessary, without you having to worry about it.

** All quotes were collected during the conference « LEZ: From Controversy to Implementation » held on March 21, 2024, as part of SITL 2024.