Consultation for Portsmouth Clean Air Zone Announced

Portsmouth City Council has announced the consultation about a clean air zone (CAZ) will run from now until 26th August (some places they say 28th August). While older lorries, buses, coaches and taxis will be charged to drive in the south west of the city, the details still need to be decided. The consultation was postponed due to the planned local elections in May, but these were cancelled due to COVID-19. I would encourage people to respond and that may encourage the council to stop dragging their feet. I have concerns that the small area of the CAZ and that it does not include private cars may be insufficient to reduce air pollution within a reasonable time. There is some uncertainty if light goods vehicles will be included in the scheme. As we are likely heading into a COVID-19/Brexit recession, people are less likely to replace old vehicles which are more polluting with newer less polluting ones. This means the council may need to take additional steps to reach legally compliant air quality than previously thought.

The timeline was also published:

  • Oct 2019:  Outline local air quality plan was submitted to government
  • Mar 2020: Government approval of the outline local air quality plan
  • 16 July to 26 Aug 2020: Clean air zone public consultation
  • Winter 2020: Full clean air zone plan submitted to government
  • Spring 2021: Government approval for full clean air zone plan
  • Summer 2021: Zone cameras and signage installed
  • Autumn 2021: Zone charging starts
  • Autumn 2022: Target date for compliance of pollution hotspots

The council has also announced that 97 of 105 buses have been upgraded to the Euro 6 pollution standard. They are also looking for suggestions for new electric vehicle charging locations.

Exemptions or ‘sunset periods’ could be granted for such vehicles where it can be shown that this will not delay the year in which levels of air pollution are brought within legal limits.

Quote from the Consultation information

The council says we must not “delay the year” for reaching compliance. That is not what the law says – which is to reach compliance as soon as possible. These exemptions are probably illegal. This reminds me of the time they claimed 40.5 ug/m3 was within the limit of 40ug/m3 because we can round it down

I’m not completely against exemptions of certain vehicles, however I am in favour of air quality as soon as possible. The focus should be on providing sustainable alternatives.

Therefore central government has confirmed that they will not provide funding for a CAZ D that would charge cars.

Isn’t it self funding? Once you have the cameras in place, and billing mechanisms, how can this cost any more to upgrade to class D? I suspect political reasons are more more likely.

We would be particularly interested in hearing from those who drive, or whose businesses rely upon the use of buses, coaches, taxis, private hire vehicles and heavy goods vehicles.

Portsmouth Clean Air Zone Update, 16th July

PCC is biasing the consultation already… *sigh*. What about people affected by the CAZ because they breathe (polluted) air?


Plans for Cycling and Walking in Portsmouth

COVID-19 may have provided an opportunity for improving sustainable transport in Portsmouth, but that opportunity is already slipping through our fingers. Central government announced funding to help social distancing by improving walking and cycling routes. Portsmouth City Council has bid for £192,000 in the first round of funding. Some or all of the measures are temporary, it is not exactly clear. The measures include:

  • Funding the existing partial closure of the seafront
  • Creating a bus and cycle only through route through Isambard Brunel Road, Guildhall Square, Guildhall Walk ( 2-way cycling) and the Terraces
  • Cycles only in the southern part of Palmerston Road
  • Creating a continuous cycle path on Elm Grove

As well as:

  • two temporary toucan crossings on Eastern Parade in Southsea, pop-up cycle lanes and some parking suspensions in Ordnance Row and Elm Grove and traffic filters in Castle Road and Canal Walk.”
  • “A low traffic neighbourhood is also proposed between Highland Road and Goldsmith Avenue, creating one-way systems and no-through roads.” I think this is Maxwell/Languard/Hunter/Methuen Road.

UPDATE/CLARIFICATION 24 June, the council has not been forthcoming with what specific schemes are contained in the bid. I’ve asked for information under FOI to try to clear this up.

UPDATE 29 June, the confirmed list of funded changes is now available.

UPDATE 15 July, FOI request for the tranche 1 bid was successful.

The transport cabinet member for PCC claimed “We must build on [the improvements] and not allow our roads to return to the pre-COVID situation”, however they seem to have already allowed that to happen. The council stated: “The cycling and walking activities included in the bid aim to create safer cycling and walking routes whilst also maintaining the flow of traffic”. These mixed messages that claim to both maintain and reduce car usage immediately throws the ambition of the plan into doubt. The road system is already massively biased toward car travel, and the council has no plans to change that. The measures are focused on the south of the city which neglects transport in the northern part.

Also, many of these steps are in already quiet areas, while most benefit can be gained by ambitious changes to the main transport routes. Just making quiet roads like Maxwell/Languard/Hunter/Methuen Road one way is not going to achieve very much. Many of these measures temporary but we need long lasting change in the city to address congestion. The plans don’t form a continuous cycle network and seem to be more ad-hoc quick fixes that don’t annoy the car lobby.

There was a proposal to close a lane of the Eastern Road to form a cycleway. The existing cycling way is very close to fast moving traffic and widened cycle route would be safer. However, a petition was started against the plan by a group called Keep Pompey Moving, founded by a local car dealership owner. After discussions, the plan was abandoned by the council, citing value for money concerns. The cost was thought to be around £100,000. The general idea was quite bold but the cycle lane would have only been temporary which seems rather weak and short sighted. It could have also displaced traffic on to Copnor Road.

Widen My Path is a website that collects suggestions for improvements to walking and cycling around the UK, and for users to up vote ideas. This allows many ideas to be collected from a wide audience. Many of them are ambitious and some gaining support from the website users. Among the most popular ideas are: making the seafront traffic closure permanent, and protection for cyclists going over Copnor Bridge. If you have ideas for improvements, please add them to the site! The council should pay attention and take the best ideas forward to implementation.

For cycling to be popular in the city, it has to be an efficient way to get around. This requires a network of safe, fast routes for cyclists to reach popular destinations. The current cycle network is highly fragmented since it prioritizes traffic in most places. Rapid Cycleway Prioritisation Tool was created by Institute for Transport Studies at the University of Leeds. It identifies routes that would complete a cycle network if they were converted to cycle ways. The analysis included Portsmouth and found London Road, Copnor Road and Queens Street to be ideal places for upgraded cycle routes. Ideally, these would be segregated and protected cycleways. While some cycle infrastructure exists along Eastern Road (which is of questionable safety), south of Winston Churchill Avenue and along the sea front, the rest of the city needs connecting for cyclists. Ideas from the RCPT are intended to assist councils in bidding for Tranche 2 of the Emergency Active Travel Fund.

The council needs to be ambitious and think seriously about supporting active transport, which inevitably means de-prioritizing private cars. This in turn helps address the air quality problem and the climate crisis.

UPDATE: Conservative councillor calls for the seafront to be reopened to traffic. 🙁

UPDATE 2: Portsmouth clean air charge zone ‘may include vans and minibuses’ (changing from class B to class C)


Pompey Street Space: Make Portsmouth Streets Safe

Portsmouth residents are walking and cycling in record numbers; this is good for controlling COVID-19, good for health, good for reducing congestion, and good for air quality.

However, as lockdown eases, we need to ensure that residents can keep walking and cycling safely.


Acting now is important: the more that traffic levels rise, the more dangerous it is to cycle and for pedestrians to keep 2 metres apart by using road space.

Our requests

To keep us all safe, we are asking that, with immediate effect, the council:

  1. Widen narrow pavements in busy streets so that people can keep 2 metres apart whilst walking, queuing, etc.
  2. Create a network of roads throughout the city that are cycle and pedestrian priority
  3. Create commuter cycle routes to allow people who usually travel by public transport to get quickly and safely to work by bike.

Croydon, Manchester, Brighton and other cities have shown these changes can put be in place quickly using low cost ‘pop up’ measures such as footway extension, thermoplastic tape, bollards and planters.

Please sign our petition asking Portsmouth City Council to do the same using the temporary powers granted to them.

Who we are

Pompey Street Space is a joint campaign by Portsmouth Friends of the Earth, Portsmouth Cycle Forum, Let Pompey Breathe, XR Portsmouth, Portsmouth Green Drinks, and Portsmouth Playing Out.

Portsmouth News: Calls made to ‘act quickly ‘ to transform Portsmouth into a cyclist and pedestrian friendly city

Portsmouth Politics Podcast: I was on talking mainly about transport.

In the news: Air pollution has made the COVID-19 pandemic worse. Both attack our lungs and incite a similar response by the immune system.


DEFRA Approves Portsmouth’s Class B CAZ plan

Last year, Portsmouth City Council proposed a class B CAZ to deal with it’s air pollution problem by charging lorries, coaches and taxis to enter the south west of the city. After a month’s delay, DEFRA has now approved those plans and will provide £6.2m funding to implement it. I have already expressed concern that this plan might not be sufficient to bring pollution to within legal levels, let alone within the required “as quickly as possible” time scale. Private cars and light goods vehicles will not be charged under the scheme. The leader of the council, Gerald Vernon-Jackson, has called the introduction of a clean air zone heavy handed:

A Clean Air Zone is not our preferred approach to addressing air pollution in Portsmouth

However, all past air improvement plans have been found to be insufficient, forcing stronger measures to be enacted. The time for less drastic measures to take effect has been squandered.


Covid 19 Lock down Sees Drop In Pollution

In The News: Coronavirus: Portsmouth sees highest drop in nitrous dioxide pollution in England during lockdown

The reduction in traffic will cause a small improvement in some people’s health during the lock down, along with a small drop in other infectious diseases. In contrast, air pollution is estimated to cause the equivalent of 40,000 deaths a year in the UK. Although it is difficult to estimate the exact impact at this stage, COVID-19 looks to be a larger problem but not by a huge degree. It is important to remember that air quality impacts us continually, year in year out, while COVID-19 may be eliminated if a vaccine becomes available. We have taken action to reduce the risk of COVID 19, but this has also shown that air quality improvements are possible in principle, if we have the political will.

Another factor is that both air quality and COVID-19 are public health issues that have been de-prioritized due to short term economic considerations. Fortunately, the government’s response to COVID-19 has improved but there is still little progress on improving air quality. Part of the problem is that most pollution is invisible and the problems caused by air quality are not directly attributable to the cause. People are simply not aware of the risk they are exposed to due to traffic and other emissions. We have also seen similar lack of action on climate break down, which is a greater threat to health and the future economy that either of these two issues.


Sustainable Transport Stagnates In Portsmouth

Sustainable transport is an important part of tacking both the air quality crisis and the climate emergency in Portsmouth. Here are the per-capita local bus rates for various regions in south-east England. Flying high is Brighton and Hove, as well as Reading. Third place goes to Southampton although they have not improved in a while. Portsmouth is down at 6th place (more or less) and has hardly changed in 10 years. What is striking is the contrast between the best and worst areas. Of course, London has far higher rates of bus usage because investment in Transport for London has produced a decent bus network. Source data is BUS0110 by DfT.

Next, on cycling rates in Portsmouth:

This considers monitoring locations that have a measurement 2003 or before, as well as 2017 or after. I then use linear interpolation to get a rough measurement for every year (not all locations are monitored continuously). Then I take the total to get a rough city wide score. Data originally from DfT (average daily flow). One major shortcoming with this approach is that monitoring locations tend to be on busy routes which are often unpopular with cyclists.

From the data we have, cycling seems to have improved from 2003 to 2014, but then cycling rates have fallen back considerably by 2017. Another way of looking at it is we are still at the same rate as 15 years ago!

In both of these charts, more recent data is not available which is a pity since sustainable transport has moved up the political agenda in recent years. However I would not expect much improvement as recent measures by the council are still tinkering around the edges rather than the radical action we need. Part of the problem is central government is limiting funding to enable the council to address this important issues.

PS Portsmouth found to have worst PM2.5 particulate pollution outside of London.

Update: DEFRA has doubts about class B CAZ?

Clean Air Day is on 18 June 2020.


Portsmouth Already Planning To Remove CAZ

Portsmouth City Council are discussing beefing up their air quality monitoring systems including a continuous monitoring station by the Catholic Cathedral. The motivation seems to be they want to know when the proposed Clean Air Zone can be removed(!?) after air quality improves.

The CAZ will remain in force until there is firm evidence that an improvement in NO2 levels below limit value requirements have been achieved and maintained. PCC will therefore need to undertake appropriate monitoring and assessment of air quality levels in order to evaluate whether the measures implemented through the LAQP are having the anticipated impact, need adjusting, or are still needed if they have accomplished their air quality improvement outcomes.

Again, focusing on doing the absolute minimum rather than protecting public health. It seems reckless to be spending money on removing air quality measures when what they propose is far from certain to work at all! 😠 Perhaps spend the money on actually fixing the problem?

PS. I am told that DEFRA/JAQU will be responding to the proposed clean air zone (plus other measures) by the end of the month.

UPDATE: I am now told the DEFRA response has been delayed until the end of Feb.


December News

Tories, Labour and Lib Dems ‘have no plan for tackling transport emissions’ Manifestos fall short of action needed to address biggest source of UK emissions, campaigners say

It’s almost like they are not taking it seriously…

Impact of air pollution on health may be far worse than thought, study suggests Results chime with earlier review indicating almost every cell in the body may be affected by dirty air

Any the evidence of harm keeps mounting…


New Air Quality Plan for Portsmouth: First Impressions

So after more than a year’s wait, we have the Portsmouth air quality plan (technically called the outline business case or OBC). There are several associated reports along with this document. Portsmouth City Council are now waiting for approval from DEFRA before going to public consultation. Here are my first impressions:

The UK Plan states that local plans should seek to target measures so as to minimise their impact on local residents and businesses. […] Proposals that request government funding support demonstrate value for money; […] All short-listed and the preferred option must pass a Critical Success Factor test on whether the option proposed would deliver compliance in the shortest possible time. Additional factors, such as cost, can only be considered when options are equally effective at achieving compliance in the shortest possible time.

Mixed messages from the council but the last sentence reflects the actual legal situation, based on High Court rulings.

For most vehicle types (except LGVs), the Portsmouth fleet is older than the national average (see Figure A-7). […] The ANPR data shows that 45% of vehicle movements 13 in the city are undertaken by older, more polluting vehicles that would not meet the emissions criteria for a charging Clean Air Zone (Table A-5) 14 . Some 24% of fleet movements are undertaken by non-compliant diesel cars, 9% by non-compliant petrol cars, 9% by non-compliant diesel LGVs, and 2% by non-compliant taxis. The remaining 1% of non- compliant vehicle trips relate to petrol LGVs, HGVs and diesel buses. […] In 2019, some 70% of diesel car trips are made by non-compliant vehicles (in 2019). However, by 2022, this proportion is predicted to reduce to 47%, due to natural evolution of the fleet. However, as described above, changes in other vehicle types means that overall contribution of diesel vehicles is actually higher in 2022 than 2018.

It’s interesting to see the results of the automatic number plate recognition study, which says we have a relatively old fleet of vehicles.

the following vehicles are considered non-compliant and are therefore required to pay the charge levied on non-compliant vehicles travelling within the CAZ

Assumption made here without clear justification. There are various ways to setting up a CAZ but this document fails to consider these alternatives.

Over time, it is expected that all roads will achieve statutory NO 2 limit values due to the natural upgrade of the national vehicle fleet to cleaner models.

We have been hearing that for years… we still have illegal levels of pollution.

Charging Clean Air Zones aim to accelerate this turnover and thus need to be maintained only for as long as the statutory NO 2 limit values are exceeded. As soon as it is possible to do so while maintaining legal compliance, these Clean Air Zones can be removed.

Huge unjustified assumption made here! It could be that people switch to public transport and then switch back to cars once the CAZ is removed.

Car ownership in Portsmouth has been growing steadily in recent decades, from 90,200 licensed cars in 2009 to 103,154 licensed cars in 2018, placing additional pressure on the road network and parking provision for residents, visitors and workers.

…caused by Portsmouth City Council and central government failure?

Risk that problem will simply be displaced to other parts of the city (and neighbouring authorities), if inappropriate options are shortlisted. The M275/A3 ‘western corridor’ route is the most attractive route into Portsmouth and there is a risk that any measures to discourage vehicle trips simply free up space for other vehicles to route away from less attractive routes currently being used.

This is a risk particularly for Copnor, Milton and Albert Road. Can this be modelled?

Overall the [public survey] results show that the introduction of even a daily £5 charging point has a marked impact upon non-compliant car travel within and through Portsea Island; 41% would avoid the charging area (changed their destination or not made the journey), 29% would either replace their vehicle or travel using a different mode although 30% would still make the journey in their non-compliant car and just pay the charge.

Around half of the 26 businesses with LGV fleets said they would relocate their business out of the CAZ; and just under half of the 16 businesses with HGV drivers said they would do the same. It is thought that these responses are indicative of the concern businesses in Portsmouth have about a potential CAZ, but that in practice the level of relocation would be much lower.

Interesting survey results here, which underscore the effectiveness of a class D CAZ.

Portsmouth International Port has been excluded from the charging zone due to the potential negative economic impacts.

Lucky them, but is that legal in terms of compliance? How does one get an arbitrary exemption from CAZ?

There are also five road sections on the A27/M27 Strategic Road Network (operated by Highways England) where NO 2 concentrations are forecast to exceed the EU limit in 2022. The highest exceedance is on the section of the A27 immediately north of Portsea Island, requiring a reduction in road NOx of 30% to achieve the EU limit. These are Highways England’s responsibility, but PCC is expected to communicate with Highways England as local plans are developed and ensure local measures do not adversely impact on these sites. […] Under both scenarios there are outstanding exceedances on the Strategic Road Network, but to a lesser extent than in the baseline scenario.

Strategic Road Network exceedances seem to be dismissed since they are Highways England responsibility. Don’t these locations matter? Massive buck passing between government agencies going on. Is this legal?

Finally, a CAZ D (covering all vehicle types) would be most effective, achieving a much greater reduction in road emissions than a CAZ C (29% and 34% on Alfred Road and Commercial Road respectively). This is not surprising as cars (compliant and non-compliant) account for 57% of road emissions on Alfred Road and 61% on Commercial Road (see Figure 2-3). […] Given the forecast proximity of the Alfred Road concentration to the EU limit in a CAZ B scenario, a Level C CAZ applied at a cordon around Portsea Island, as shown in Figure 3-1, is taken forward as the benchmark CAZ against which other options are compared.

CAZ D is highly effective, so why was this not considered as part of the short list? This is a serious omission.

Table 3-5 shows that the Small Area CAZ B performs as well as the Portsea Island CAZ B at exceedance locations on the PCC network. […] While a Portsea Island CAZ B and Small Area CAZ B would both achieve compliance in 2022, a Small Area CAZ achieves a greater reduction in NO 2 concentration and would be implemented more quickly due to the smaller geographical scale. A Small Area CAZ B is therefore shown to deliver compliance in the shortest possible time, without significantly worsening emissions elsewhere, meeting the Primary Critical Success Factor for this element of the Alternative Package. It is also expected to have less of an adverse economic impact on individuals and businesses than the other CAZ B options. A Small Area CAZ B has therefore been taken forward as the basis for the Alternative Package.

The small area CAZ being better seems illogical and counter intuitive. How does the council explain how this could be true? Such a remarkable claim should be discussed in the plan. (Also, a small area CAZ cannot be both the same and better than an entire island CAZ.)

I’m thinking Table 3-4 and Table 3-5 is where the document claims to reach compliance with CAZ. Table 3-8 shows CAZ class B with non-charging additional measures. These are the central claims of the document. These tables show a class B won’t reach compliance, with or without non-charging measures.

From the above quote, PCC are proposing a small area class B CAZ without non-charging measures. That doesn’t meet the critical success criteria of legal compliance (although they say it does). This is literally planning to fail (even with non-charging measures).

There is no table with small area CAZ with non-charging measures, which I imaging will be the council’s first fall back position. We can’t be taking such important decisions based on vague assurances.

Exceedances (>40.49μg/m 3 ) shown in bold […] the concentrations of NO 2 on Alfred Road are very close to the EU limit of 40.49μg/m 3 […] Table 3-8 shows that both packages deliver compliance with the EU limit for NO 2 concentrations in 2022, which is considered the shortest possible time and is a year earlier than predicted through natural fleet upgrades.

In Table 3-5 and others, why is the air quality values being rounded down? That is not legal! The limit is 40.0000 ug/m3 and not any other number the authors invent. Therefore, Table 3-8 doesn’t show “both packages deliver compliance” as full island CAZ B + non-charging is out of compliance! (40.1 ug/m3)

But which approach is faster? The plan talks mostly about 2022. The law doesn’t say choose an approach that has roughly the best compliance timescale, it says to achieve compliance as quickly as possible. No rounding!

Climate change is barely mentioned in the document, which shows a complete lack of joined up, long term thinking. There is no discussion of optimism bias, which is needed “to ensure the Plan meets the requirements of the HM Treasury Green Book methodology”. My previous concerns about the validity of the modelling, etc still remain.


Portsmouth proposes a mini-CAZ: A Bare Minimum OR Simply Inadequate Scheme?

Portsmouth City Council is proposing a mini-Clean Air Zone class B which just covers the city centre. According to their computer models, this will be sufficient to get the city with legal pollution limits by 2022, which is assumed to be “as soon as possible” to comply with the law.

Area of the proposed mini-CAZ

The council are relying on predictions by computer models to determine what course of action to take. However, the quality of the predictions depend on the validity of their assumptions. There is a well known saying that if you put “garbage in” to a model, you will get “garbage out“. PCC has made many predictions over the years that have turned out to be false. For example, in the 2010 plan, PCC states they will reach legal levels by 2012-2016. In 2015, it was supposed to be below the legal limit by 2020. In 2017, it was expected by 2021. Their predictions have repeatedly failed. Now we are expected to believe their latest estimate that they will be legally compliant by 2022, but it does not seem that lessons have been learned from past failures. Policy making is suppose to take it to optimism bias but that apparently has not been used in air quality planning. The most likely sources of error are traffic growth estimates (driven by new developments), and the predicted shift to more efficient vehicles, but regardless of the specific cause, it is clear that something is very wrong.

Apart from the repeated failure of modelling, the case study data of similar class B clean air zones have shown only a slight improvement after their introduction. This does not meet the challenge that Portsmouth faces which requires around a 10-15% cut in NO2 pollution.

The computer models are not solely produced by PCC, but are done under a DEFRA (Department of the Environment, Fisheries and Rural Affairs) mandated methodology by an outside consultant. PCC has described some of the instructions by DEFRA as “deeply unhelpful“. It could be that DEFRA is using faulty models that are optimistic and will avoid central government having to tackle the problem, which saves them money. It is also likely that air quality consultants that involved model analysis are selected based on their willingness to tell the government what they want to hear. I have had private discussions with well placed people in which they have expressed concern over the validity of the modelling. Looking back that a recent debate, even Gerald Vernon-Jackson, the head of the council, said the scheme was being done “even though we know it will be ineffective“. Did Gerald just let the cat out of the bag? This contrasts with PCC’s public pronouncements that they have a workable plan. PCC is actually in a difficult position because they don’t seem to have the resources to tackle the air pollution problem independently and DEFRA will only fund the minimum scheme needed to reach legal pollution levels. If they go along with the mini-CAZ class B, which is the minimum based on DEFRA specified modelling, they are likely to fail in achieving legal pollution levels any time soon. If they object to DEFRA’s methodology, they fear they may get no funding at all. It’s either crumbs or nothing for poor Portsmouth!

The council has not done themselves any favours by repeatedly failing to explain the need of a CAZ and the benefits. In fact Gerald Vernon-Jackson was very clear that the CAZ scheme is not done by choice but rather that “this is a government imposed scheme“. This is going to leave people feeling more victimize rather than helped. A CAZ is primarily being introduced to improve public health after all! However, I must take issue over the claim it is being imposed. Strictly speaking, Portsmouth has a choice of implementing a CAZ or other measures that are at least as effective. The council, under various administrations, has had many years to tackle the problem had made no progress in reducing pollution levels. It is only due to their repeated failure that considering a CAZ has now been mandated. However, central government has also caused problems by dragging their feet on encouraging compliance and defusing to produce funding for schemes that would make a positive difference.

PCC are regarded by DEFRA to be a good example of how to plan to reduce air quality. Given the questionable effectiveness of PCC’s plan, it throws DEFRA’s judgement into doubt. This is further compounded by DEFRA trying to do a very targetting scheme back in 2018, again lead by dodgy modelling, which did not appreciate the city wide problem we face. Thankfully, due to PCC persuasion, we are looking at the city wide implications now.

The council has been busy for the last year on producing a new air quality plan that will be submitted to central government at the end of October 2019. In it they have modelled various types of clean air zones, such as a class C including light goods vehicles, and a class B excluding light goods vehicles. They make the claim that:

Class B CAZ is combined with a number of non-charging measures to ensure that compliance is achieved within the shortest possible time i.e by 2022. The alternative to this is to go to the Benchmark option of implementing a Class C CAZ which it is anticipated will achieve compliance in all locations by 2022, however it is anticipated that this will have a greater negative impact on Portsmouth’s residents and the local economy.

It seems absurd to suggest that the stricter class C will be no more effective than a class B CAZ. They get around this by rounding to the nearest year, so a false equivalence can be made. This is another trick by PCC to get out of achieving compliance “as soon as possible”, as required by law. It is also not clear why a class D, which covers private car usage, was not modelled. Common sense would seem to indicate that this would be even more effect and therefore be legally required. PCC better have good justification for this…

An additional annoyance caused by PCC is their self-congratulatory attitude given the air quality crisis and the climate emergency. When campaigners like myself point out the scope of what needs to be done, some councillors fall back on the tactic of listing their achievements. In some ways this is understandable because they have a very hard job and any progress seems to them like an epic win. In one case, a councillor was keen to point out how many solar panels have been installed and how we are one of the best in the county. Listening to their rhetoric, one might even thing they had the situation under control. However, progress so far has been just a drop in the bucket compared to what needs to be done. When considered in context, their attitude seems very complacent.

A concern with the restricted area of the proposed CAZ is it is less effective when compared to a city wide scheme. It also risks having traffic switch to routes outside the CAZ, making their pollution worse. I’d expect a significant increase in traffic down Copnor Road, the Eastern Road and possibly Albert Road as people avoid the charging area. Some of these roads are already over the legal limit or barely compliant, including Velder Avenue, Milton Market, Fratton Bridge, etc. PCC seems to be trying to redistribute pollution so the total remains the same but it is evenly distributed around the city!

As if we need further evidence of the harm cause by air pollution, additional studies have found a strong link between air pollution and heart attacks, strokes and acute asthma. It’s time to take the problem seriously!

The air quality plan is due to be submitted by PCC at the end of October. However, it is unclear when it will be available to the public. This needs to be circulated as soon as possible, because the measures will have a significant impact on the residents and businesses in the city. People need time to plan and adapt.

UPDATE: A version of this story was published in the Star and Crescent.