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Discussion with Portsmouth City Council, Part 2

Continuing from Part 1

Steve Pitt (Culture and Leisure): Lynne, you are absolutely right first of all: there are too many cars on the island. It is a grave[?] situation. I know of a three bedroom house that’s got nine cars, which is absolutely ludicrous. So I’ve got three points. The first one is that there are solutions. 30% of all car journeys in the city centre, right around the world, are people looking for parking spaces. There are technological solutions to that. And I know the officers in Portsmouth City Council have known about at least one of these for at least four[?] years. So that is going to take people with an app to a parking space.

The second point is that in the future we are going to be going electric. Government policy includes[?] diesel/electric so that should solve a lot of the pollution problem. And the third point is that, again, in the future as we get more driverless vehicles, we are going to have fewer cars owned by individuals. Cars spend 90% of the time sitting at the inelastic roadside are [in future] going to be pick-up-and-go cars, that are going to be electrically driven, pollute less, and there will be far fewer on the road. So there is a good long term outcome and that is coming towards us a lot faster than predictions even three or four years ago.

Lynne Stagg: The parking scheme is called AppyParking. That really only applies to places where you pay for parking because you have to have the sensors in the road.

Audience member: You can do it with non-pay parking.

Lynne: Yes I think you can but [we are tackling it] bit by bit. We are putting electric charging points in. We have put in 50 so far. That again is a chicken and egg situation because as well as putting in electric charging points, they have to go in lamp posts because you can’t have trailing flexes into people’s houses. Those will be parking bays specifically only for electric charging of electric cars. But you have got to have enough people wanting electric vehicles, or buying them. They are not cheap. Nick [?] you’ve got one and they are not cheap are they, Nick?

Nick: Well they are not and they’ve reduced the subsidy. 

Lynne: But the more people that get them, the prices will probably go down. So we are reacting as people are asking for them. We have the next list of those wanting to go in. And it’s specifically outside people’s houses or as close as possible, because obviously that is the most sensible thing. I don’t know what will happen if you have a whole street of electric cars but we will look at that as we go along, bit by bit. That is part of the grant, rolling it out as demand comes in.

Alec: I think it is important that Tim mentioned the harbour. That ships themselves are polluters, and therefore I think it would be a good idea to consider the shipping companies and the navy contributing something to this issue.

Lynne: That is already being done. The navy actually plug in. They put in this big electric cable about 18 months ago. So the naval ships aren’t. It’s the ferries, we are having difficulty persuading them, because the reason for that is swift turn around. They tend not to cut their engines because they come in and they’ve got about an hour or so, before they turn around. But we are certainly working with them.

Panellist: Not wishing to be rude, and thank you for doing this unannounced, there were some challenges by Tim. Do you know what year Portsmouth expects to come into legal compliance?

Lynne: 2021 for one of them and 2022 for the other, but I can’t remember which way round it is.

Panellist: And on what basis are you confident of that?

Steve Pitt: I got a briefing from environmental health about a week ago. Please do be assured that the council is going to be held very strongly to account for getting this right. It’s not something we can do, and say “we’ve done the best we can so that will have to do”. There are very, very strict guidelines being laid down by DEFRA, who is now sending a member of their department to Portsmouth every single week, to work with us on this plan. In January [2019], we are expected to come up with a draft plan. If they do not believe it is credible, they can take control of how we manage vapours[?] in the city. If they do not believe in the full business case that we put together at the end of next year is credible, they have the ability to step in. So this is not something that a couple of people are working on to try and tinker around the edges. We are talking it deadly seriously. And we want to make sure that we hit those targets as soon as we can. The deadlines are 2021 and 2022, but if we can get them earlier then we need to do that. But in order to do that, we are going to have to make some very… clear choices around some of those things, for example, on there Tim you have Clean Air Zone. If we don’t do it [reach compliance], it won’t be a choice. That’s how clear this is. Will strong measures be considered in planning? That little list there, that’s not things that might happen, that’s things that DEFRA will do, in Portsmouth, to us, unless we get this right. So please don’t think that we are not taking this seriously, we have to take this deadly seriously. Apart from anything else, we don’t want people breathing air that’s not safe, obviously, because we live here too. We don’t live on a planet elsewhere and beam ourselves down to be councillors in Portsmouth. It’s our home as well. So we are really really clear that we will deliver this. The head of environmental health is working with a big group of officers in the council and we are having to draft in extra people to work on making sure we deliver this. It’s a serious thing and it has to be resolved.

Panellist: Tim, are you reassured? It sounds very convincing.

Tim: What has been said sounds quite interesting. I am definitely looking forward to the January report. So, yeah, fingers crossed. And thanks for filling in because DEFRA seems to get hung up on the wrong area. Thanks for clarifying that.

Lynne: Can I just say I used to teach geography and environmental studies, so I am very keen on improving the environment, right across the board. I’m back this 100%.

Matthew Winnington: I’m also on the cabinet. I’m the health, well-being and social care cabinet member and councillor for this area. So to add on the importance of what both Steve and Lynne have been talking about, because it is a knock on from this, it’s all very well for doing these things for clean air now but what it’s also about is the effects beyond the situation, in terms of people’s public health.  So as the cabinet member in charge of public health, this is all feeding in to what we are doing as well. But in particular, one of the interesting things that has come out in terms of the research that has been going on, on the public health side, on the CCG on the hospitals[?] on the public health as well, is that actually a lot of areas in the city with the worst air pollution issues are also the areas with the worst obesity issues, for adults and children. So something that the council is bidding funding for, is actually to get [?] obesity and activity for children and adults. We should also have additional help for areas with high air pollution, because then we will have people going around, rather than getting a car or getting a taxi or whatever. They will actually be walking and cycling and getting about in a healthy way. Because that is going to have a really good outcomes in the future as well. One of the interesting things about air pollution in the city is that it is giving us a kick to do things in a more wholistic way. Which is about, “let’s get this air clean”, it’s also saying to us “it’s not just about that. Let’s try and help people so they are not in a situation that they are thinking about using polluting things in the first place.” They go about their business in a way that is better for them because it is going to keep them healthier, but also better for the environment because they are not going to be driving around in their cars. And as Lynne as said earlier, if we don’t do anything about cars in the city, we are going to have utter and complete gridlock. So those have to come done. But the best way to do that is by encouragement, and an even better way is for people to make the choice that they are happy to get around using other forms of transport, and keep themselves healthy, rather than “I’ll just go down the road an pick up the children and do my shopping in the car”. So, that’s some of the work that is going on at the edges, but that is really key to making sure we have something sustainable as well. Because otherwise we could just sort this thing out now and ten years down the line, we will just end up doing it all over again.

Audience member: [What would DEFRA do to us if we didn’t produce a credible plan?]

Steve Pitt: They would take control of the policy themselves. And that means instead of us having the ability to draw up a plan that we think works best for Portsmouth, they could do things, for example, enforce a clean air zone on the city. So it is in all of our interests to get this right and do a good job of it, because we need to make sure the decisions we take are also best, economically for Portsmouth, because the economy matters a lot as well to all of us. So the work is crucial. We don’t want DEFRA coming in and saying we are not happy with that, you have not done a good enough job of it, so we are going to take extreme action, we’ll say there’s no cars allowed down that stretch of road. They have that ability.  The government are taking it seriously. DEFRA are taking it seriously. We are taking is seriously but we want to lead on it and come up with a plan that works best for the city, not having government agencies coming down here telling us what to do. [We have enough of that already.]

Analysis coming soon…

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Discussion at East Southsea Neighbourhood Forum with Portsmouth City Council

We have a good sized audience at East Southsea Neighbourhood Forum. I gave an overview of the air quality situation and then we had an informal Q&A session with Lynne Stagg (PCC transport) and Steve Pitt (PCC Culture and Leisure). There were some good questions from the audience on air quality policy and solutions. Both PCC councillors had to step in at short notice as the planned speaker Gerald Vernon-Jackson was unavailable. This was probably for the best as Lynne is probably more familiar with the issue.

Audience question: If 50% of the problem comes from diesel, why doesn’t Portsmouth City Council either tax diesels or put in a plan to ban older diesels?

Lynne Stagg: Now let me correct a few things. We have been working on the air pollution problem for quite a while. DEFRA identified two areas that are not compliant: one is the bottom of the M275 and the other is Alfred Road, and they have been done by modelling. The reality is the bottom of the M275 is compliant and has been for a long time.

[Receptor 30 at the bottom of the M275 has been barely under the legal limit since 2014. The annual average in 2017 was 38.5 ug/m3.]

The data we are worried about, and we have been telling DEFRA for several years, is the Fratton Road, Kingston Road, London Road [area], and we are not compliant there and we have not been for a long while. The reason for that is it is very difficult to actually deal with it because it is a corridor, and the geographical nature of the area makes it worse than it would be anywhere else. There is no where for diesel fumes, etc. to escape.

Although diesel is a bigger offender than cars, there are more cars the HGVs, for example. The greatest volume of emissions is coming from cars as a total rather than individually.

ESNF Panel: So you disagree with Tim?

Lynne Stagg: I disagree on that particular point, about the actual amount.

[Lynne Stagg seems to be questioning the chart I took from the PCC commissioned Source Apportionment Study 2017 by AECOM.]

Lynne Stagg: There are a lot of things we could do, and that we are doing. Between 1971 and 2011, the population of Portsmouth went up by 50%. Car ownership went up by just under 300%. There is your problem. There are too many vehicles on the road, it’s a simple as that. We can do lots of things about getting rid of them. One thing […] which is contentious is resident parking zones. Because, for the majority of houses in Portsmouth, there is only room for one car, if you have no off road parking. A lady three weeks back, she came to me and said “I have three cars, what am I supposed to do?” […] get invented an elastic road. When they do, they can stretch it and you can put extra cars on, you can have it. In the mean time, you only have room for one car outside your house. We can take a lot of parked cars off the road. I am very keen on taking the parked cars off [?] Road, North End, because apart from anything else, I know from the [?], people are trying to park, the traffic is held up behind, we’ve got emissions coming out. Cutting engines in when you are waiting in traffic lights, they do it on the continent, I don’t see why we can’t do that here. There are lots of like that, that we are in the process of doing.

[Tim: Is it possible that the fewer cars that remain would be used more heavily? Is there any evidence that reducing residential parking reduces congestion?]

Coming back to London Road, I think we have convinced DEFRA that it is not compliant, and they are listening to us, because we have real evidence and they are just modelling it. We have lots of things in the pipeline. A lot of these things take a long time to do because it’s a chicken and egg situation, for example: I’d like to see more cars get off the road but where are the buses? I’m frustrated, I could come here by the 17 bus. [?] I waited 25 minutes and the bus didn’t turn up! So I ended up getting a taxi. However, we haven’t got a good bus service because people are using their cars. So it’s a catch 22 situation, so there’s lots of things we need to do.

But coming back to polluted air, there was a brilliant documentary 2 or 3 months ago called “The Air We Breathe” with twin brothers who were adopted. One of them [lived?] in Birmingham on a section of road very similar to North End. He did a lot of work, they were measuring the emissions from vehicles and this is how I know that HGVs, although individually give out more fumes because they are diesel. Because the volume of cars is much greater, the amount of emissions from cars is greater than from diesel [HGVs]. He did a lot of work with local shopkeepers who said we couldn’t possibly take cars off the road, they would lose their trade, etc, etc. Anyway, head on social, it didn’t for 24 hours. In that 24 hours, the NO2 emissions were reduced by 30%. They had the buses and cyclists going through, but all the cars and HGVs […] I stopped those 10 years ago because they used to come down London Road, North End.

So, for particulates, there is no work being done on that. They put in trees in tufts, when they did this road closure. And they then washed the leaves of the trees afterwards, because the particulates settle on the leaves. I had no idea before I saw the programme. And they evaporated the water and the amount of particulates was amazingly high. So we need to have more trees in to take up the particulates, not the NO2 maybe. [?] It’s just a lot of these things, if you do one thing, you’ve got to look at the repercussions elsewhere. And I totally agree with you on planning. Steve [Pitt] will back me up. We put in objections when planning applications come in and if we turn down applications, they then go to appeal to an anonymous individual, the inspector in Bristol, who overturns [?] and then we get fined for having turned down [?].

Audience member: You have a pretty picture on here, Tim, of an idle free zone. Have you got a question that I can ask somebody: I passed two taxis today, both by Tesco giving out diesel fumes. How can I ask nicely for them to turn their engine off? [?] he’d take no notice at all. Could we have a little card or something?

Lynne Stagg: I shout out the window of my car and I tell them to turn the engine off. I often shout at cyclists that havn’t got lights on. [?] I was lord mayor [?] there was a cyclist who went through a red light and I said [to the driver] “slow down” and he said “you can’t lord mayor” and I said “watch me”. So I shouted “you have no lights on, we could have killed you. It’s OK of you want to die that’s up to you but I don’t want it on my conscience for the rest of my life.” So there are a lot of things we can do, if we just have the guts to do it.  But we have a lady in Keep Milton Green [actually Tracey McCulloch of Let Pompey Breathe], and she designed one of these idle free things and we are looking at have them made up and having them outside schools, etc. But I think we need them at traffic lights as well. That is what they do in places like Germany. Not everyone will do it but if we put enough pressure on those drivers, they will start doing it because they will be embarrassed. It’s like those those lights flashing up saying you are doing 30 mph in a 20 mph zone. I’ve gone through some of those not realizing and I’ve felt so guilty when they flashed up that I immediately slowed down. It’s not going to happen immediately but it will happen eventually.

Audience member: We could each have little cards that we could each give to the driver, that would be really useful.

Panellist: Lynne, on that point about “you are exceeding 30 mph” signs that flash up, you can’t get machines that say “the level of particulates is exceeding [?]”

Lynne Stagg: I’m sure you can. I don’t know. It’s not my portfolio. [Lynne deals with Transport, not Environment.] I hold the portfolio that causes all the air pollution problems. [With a note of sarcasm:] I am therefore personally responsible for every traffic problem, every parking problem, every air pollution problem in the city. Hands up, I accept that. It’s not my portfolio but I will ask Dave Ashmore.

Menno: I’ve got a question. I appreciate many things have been done over the years. Small things have been done to improve air quality. But as the graph shows that there hasn’t really been any actual change in air quality. So, isn’t it time to take more drastic measures now, because the measures that have been taken have proven not to be effective enough? They havn’t kept up with the increase in traffic around the city. Sure you can actually reduce traffic. Introducing resident parking zones is all well and good but that doesn’t help unless they are implemented across the entire city because you will just move the cars over to the next area. So, I think we really need to implement something more drastic and why not introduce a charging zone in certain areas of the city or in fact the entire island?

Lynne Stagg: I think a lot of businesses will be against that. We have considered, a bit like London… charging… Our city centre is dying anyway. Lots of city centres and shopping centres are, and that is not going to change. So if you actually stop people from coming in, because they have to pay, they are not going to come at all. They are going to go to Southampton and Chichester and wherever. So there is the objection, so we try to do a balancing act. So I think sometimes you have to go around a problem to solve it, rather than head on. We’ve got to get things done by 2021 and 2022 with two of the Air Quality Management Zones. It has to happen. I’m trying to work with the bus company. For example, all the buses have to be retrofitted with Euro 6 diesel. It’s still diesel but it’s much much cleaner. That is going to cost between £1.5 – 2 million. DEFRA is going to give us some of the money, but [the rest] is coming out of our budget. And we have to save, what is it? $4.5 million this year. And the same next year, and I think more the year after. We have shrinking budgets. I’d love to put resident parking zones up across the city. We haven’t  got the staff to do it. We can’t afford the staff, because we haven’t got the money because we paid for other things like retrofitting buses. There is only so far the money will go. We have to try to work within the budget we’ve got and try to pull in money from outside, like from DEFRA. We’ve put in a bid for $120 million to have bus rapid transport, coming from Waterlooville and Havant. Southampton are doing the same thing. The Eclipse route goes to Gosport and Fareham. It’s taken a lot of traffic off the A32 and therefore a lot of the air pollution but it hasn’t solved it. But you have to have something to replace what was going on. I have ideas and then try to find somebody to fund them. I want to have a bus depot in Portsmouth because our buses mostly come from Fareham. We could get bus companies from Eastleigh for example. But every time you do that, you pay for dead time. You have to pay for the driver and the fuel to get them to Fareham, and the pollution. If we had our own bus depot, we could have more buses, cheaper buses, serve a bigger area and hopefully more people would use them. Then get the cars off the road. But that doesn’t happen tomorrow. So there is a plan there. It’s like a jigsaw puzzle: you have a little picture and you have to get all the bits to fit in.

Menno: The plan you are talking about, there is a plan in place, is that going to be published for consultation?

Lynne: Yes because there is an air quality group that has been set up. [To Tim] And you’re involved? [Yes I am.] We’ve got to send that to DEFRA and have it approved by January [2019]. Yes, it will be, because the more people that feed into it… We’ve had meetings with lots of sections of the city. People come up with ideas that we don’t think of. So yes, it will definitely be published and consulted on. The more ideas the better.

[to be continued…]

My slides: .odp, .pdf

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Unboxing of Flow air quality sensor by Plume Labs

Available here, Price: $179

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#LetPompeyBreathe speaking at East Southsea Neighbourhood Forum

I’m speaking right before the leader of Portsmouth City Council. This is going to get interesting! 7pm, Thursday, November 22 , 2018, at the Royal Beach Hotel.

Clean-air campaigner Tim Sheerman-Chase runs the Let Pompey Breathe blog and a petition for cleanup action at https://greenpompey.org.uk/let-pompey-breathe/petition/ Tim will give us the uncomfortable environmental perspective on our situation, how the city is increasingly choking up, and what consequences we may have to live with.

I’m also attending “Air pollution – time for change” with Hampshire Climate Network.

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Impact of Charging Clean Air Zones: Saviour of Cities or a Red Herring?

Given the lack of progress by Portsmouth City Council in addressing air pollution, I began wondering how a Clean Air Zone (CAZ) might be implemented in the city and what effect it might have. There are several types of Clean Air Zones but most interest has been in charging older vehicles that enter busy areas. Since less polluting vehicles attract lesser or no charges, this intended to encourage a shift to less polluting vehicles. This has an impact on residents and businesses that have to replace their vehicles. The revenue from charges is typically invested in sustainable transport.

Arguably, this approach does not go far enough. As even the Portsmouth transport cabinet member says, “We simply have too many vehicles in this city“. Punitive prices could be used to quickly force a change in transport usage, but this is hardly going to be popular.

It is important to remember that our current transport situation is unsustainable. A significant chunk of pollution is created by diesel cars. To comply with air quality law, these vehicles need to be replaced. The question is how we go about doing that in a fair manner considering many people can barely afford the essentials. Studies have found that the economic benefits to health may outweigh the cost of updating vehicles. The necessity to act has already been established in the High Court and for the benefit of public health.

Predicting the impact of CAZ is complicated because people may switch to other forms of transport or cancel their trip completely. Local and national government often use computer models to try and predict the impact on air quality. Alternatively, we can look at how other cities have implemented CAZs however other air quality initiatives and different transport usages complicate the picture. DEFRA has presented a rosy picture of the effectiveness of CAZ. According to a 2017 DEFRA technical report:

From the options considered, establishing Clean Air Zones (CAZs) is the most effective way to bring the UK into compliance with NO2 concentration levels in the shortest possible time (Table Ex.3). […] CAZs are predicted to have their greatest impact on air quality in the year of implementation […], leading to an 18% reduction in NO2 concentrations. […] These projections have been produced from the SL-PCM model.

Birmingham has been told to implement a CAZ. Their projections are slightly less optimistic with a 9% NO2 reduction for a CAZ covering Buses, coaches, taxis, HGVs and LGVs (in jargon, a “class C-CAZ”), up to a 13% NO2 reduction in a CAZ that also covers private cars (“a class D-CAZ”). These are smaller but still significant improvements. However, these predictions don’t seem to match the experience cities that have already implemented similar zones. According to other DEFRA reports, CAZ projects around Europe have been effective in reducing particulate pollution but have a limited impact on NO2 levels. Germany has been most successful in reducing NO2 pollution using CAZ probably because their schemes include private cars. Outside of Germany, most CAZ schemes ignore private cars and have generally seen no NO2 improvements. Lisbon is also an exception which has reduced NO2 by 1-7% because they including private cars in their CAZ scheme. According to a review of CAZ schemes:

In German cities reductions in annual mean PM10 and NO2 concentrations up to 7% and 4% respectively due to the implementation of an LEZ have been reported. […] In other countries the picture is much more mixed with no effects [on NO2] generally being observed. This may be explained by the German LEZs restricting passenger cars, particularly diesel cars as well as HDVs.[Heavy Duty Vehicles …] Many of the studies, however, have used simple statistical methods that have not taken sufficient account of the confounding factors that affect urban air quality.

This finding is repeated in the London Low Emission Zone, which did not include cars in their scheme and have seen no appreciable drop in NO2. (London has recently started charging older vehicles which might help.) Similar results were seen in the Netherlands. A study of CAZ in Beijing, which only included light duty goods vehicles, predicted a fairly minor drop of 2% in NO2 levels.

In summary, Clean Air Zones are only effective in tackling NO2 levels if private cars are included in the charging scheme. This targets diesel cars, which are a major source of pollution in cities. Even if private cars are included, the impact of a charging CAZ may be less than predicted by current modelling. This might be due to different vehicle usage in the UK compared to European cities, but I doubt that is significant enough to account for the discrepancy. Portsmouth needs about a 10% drop in NO2 to come into legal compliance.

Given that we need a strong tool to improve air quality, we can look at cities that have banned older diesel vehicles. Older diesel bans are being introduced in some London neighbourhoods, as well as several German cities. We should watch their progress closely to see if improvements can be achieved elsewhere.

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ClientEarth calls DEFRA’s air quality policy a “pitiful plan”

ClientEarth, a legal charity that has held the government to account on air quality, has won a series of legal victories in the High Court against DEFRA. The court has repeatedly found DEFRA’s plan of passing responsibility to local authorities to be insufficient and illegal. DEFRA had to produce a new plan to deal with pollution in 33 local authorities, including Portsmouth. The newly published plan has been strongly criticised by ClientEarth:

ClientEarth clean air lawyer Katie Nield said: “Today’s pitiful plan shows that the government’s strategy to tackle air pollution by passing the buck to local authorities is in tatters. It’s essential that the government takes action on a national scale.

“Amazingly, ministers have now ordered more plans, which means more delays. It shows a shocking lack of leadership on a key public health issue.

She added: “It’s absolutely staggering that only now, eight years after legal limits came into force, the true extent of the problem is being uncovered for large areas of the country. In the meantime, people in these areas have continued to be exposed to dangerous levels of air pollution.”

This is significant since ClientEarth has repeatedly defeated the govenment in court. Since they strongly criticized the new plan, DEFRA should be extremely worried. ClientEarth could take DEFRA back to court and are quite likely to win. For the sake of public health, the government should take stronger action, including decisive actions taken at a national scale.

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DEFRA directs Portsmouth to produce a “much more thorough assessment”

Latest from Air Quality News:

Ten local authorities have been directed to take further steps to address nitrogen dioxide emissions from road transport, under supplementary plans outlined by ministers today (5 Oct).

The councils – Dudley, Leicester, Newcastle-under Lyme, Portsmouth, Reading, Wolverhampton, Sandwell, Solihull, Basingstoke and Deane, and South Gloucestershire – will have access to funding to implement measures including bus retrofits, improved road signalling and behavioural change campaigns. […] Defra has revealed today that eight of these 33 local authorities will carry out more detailed study outlining how they will tackle more persistent air quality problems they have identified, to be presented to government by 31 October 2019.

There is a corresponding statement from DEFRA. In it, they announces the new policy document that affects Portsmouth titled “Supplement to the UK plan for tackling roadside nitrogen dioxide concentrations“. In one section, DEFRA provides their view of the recent targeted feasibility study done by Portsmouth City Council.

83. A combination of retrofitting buses to meet higher Euro emissions standards, reducing car use and promoting uptake of cleaner vehicles was modelled to bring forward compliance at Census ID 48196 from 2020 to 2019 and on Census ID 18114 from 2023 to 2022. [Both locations are at the bottom of the M275….]

88. The bus retrofit scheme is estimated to include approximately 100 buses and the local authority estimates that it could be delivered by the end of 2019. […]

89. Even with the bus retrofit, there is still a persistent exceedance with compliance projected to be by 2022. The government has therefore also directed Portsmouth City Council to carry out a more detailed study to develop a plan to bring forward compliance in the shortest possible time. The Direction requires that the local authority produce a final plan by 31 October 2019.

The bottom of the M275 will come into compliance with legal limits by 2022, according to modelling. However, local modelling shows a rather bleaker picture in the London/Kingston/Fratton Road corridor with no way to know if or when Portsmouth will come into compliance. The DEFRA report also doesn’t mention that the city centre road scheme that is expected to push some areas above the legal limit.

In response to the dire situation, DEFRA has instructed Portsmouth City Council to produce further plans by the end of October that will get air quality within legal limits “in the shortest possible time” as the law requires. Interestingly, they mention consideration of a Clean Air Zone (CAZ):

22. For some road links a more persistent exceedance has been identified where the road link is projected to become compliant in 2022 or beyond. For these road links more significant measures could be considered; for example, it is possible that a Clean Air Zone could be implemented. Whilst this measure may not be necessary or appropriate, it is necessary for these local authorities to carry out a much more thorough assessment of the air quality problem and the options available to bring forward compliance. The government has therefore further directed these local authorities to carry out a more detailed study to develop a plan to identify the most suitable measures to address the exceedance.

While DEFRA does not insist that a CAZ needs to be implemented, DEFRA now requires “much more thorough assessment of the air quality problem and the options available to bring forward compliance”, which is very welcome. Portsmouth must consider a Clean Air Zone, if they want to claim they did a “through” consideration of “significant measures”. This is what #LetPompeyBreathe has been calling for, for some time, and is one of the measures that has been so far ignored by Portsmouth City Council.

While DEFRA are moving in the right direction, they could use clearer language that told local authorities to take measures that are at least as effective as a CAZ (as required by the 2nd tier local authorities by the High Court). As a cross-committee report by MPs said (prior to the most recent air quality document):

The Government is failing to provide clear messaging and national leadership on the issue of charging Clean Air Zones (CAZ). Defra’s technical report found that charging zones offer the fastest and most effective route to air quality improvements, yet the 2017 plan requires councils to demonstrate that all other measures will fail to achieve the necessary results before introducing a charging zone. This lack of clarity is causing confusion and hampering councils’ ability to tackle air pollution as quickly as possible.[…] Defra’s modelling already shows that, in many cases, non-charging options will not be as swift or effective as charging Clean Air Zones. If local authorities are regularly exceeding NO2 concentration limits and identify a charging Clean Air Zone as being the most effective mitigation strategy, they should be able to receive Government support for implementing a CAZ without having to go to onerous lengths to demonstrate the inefficacy of other options. If this approach fails to deliver the required improvements as quickly as possible, the Government should consider mandating charging zones in hotspot areas.

The measures currently under consideration at PCC are too weak while a CAZ is a known effective solution. Please PCC, take the air quality situation seriously!

PS FAQ by Friends of the Earth on Clean Air Zones

Update: I just noticed DEFRA has given PCC over a year to produce a plan! That is hardly in line with the urgency of the situation. An initial plan is due by Jan 2019.

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2nd Air Quality Steering Group Meet – Is Portsmouth Being Ambitious Enough?

I just attended the 2nd Air Quality Steering Group meeting. It had more people in attendance then the inaugural meeting. Councillor Dave Ashmore welcomed everyone and Richard Lee (regulatory service manager) reminded everyone the purpose of the group was to share knowledge and ideas for solving the air quality problem in Portsmouth. They said the “focus points” were addressing the London Road corridor and bottom of M275 AQMA areas. This is already a cause for concern as any very local solution might displace traffic to nearby streets; a more holistic approach may be needed for tackling these two areas.

The tone from Richard Lee was the most constructive I’ve heard so far, saying “we need a plan”, that we need to make “difficult decisions” and we need to address the crisis in the “shortest possible time frame”.  This is in line with UK law and recent High Court rulings, which is great.

The meeting was scheduled to discuss solutions on a shortlist of 12 created by Portsmouth City Council (PCC). Rod Bailey (Milton Neighbourhood Plan) spoke saying we might be missing the bigger picture since new development could easily balance or overtake improvements to transport. We might end up in an even worse place then now, unless this is addressed. Claire Upton-Brown (City Development Manager) then spoke saying the relevant plans are considering air quality and the in-place processes would deal with it. I have my doubts in these assurances since these processes and planning methods led us into the current crisis! PCC shows little sign of realizing they need to do things differently than in the past. Claire also said some planning requests could be refused if they adversely affected air pollution, which was met with skepticism judging by reaction of a few people in the room. (Most likely, PCC will add an aspirational statement in an obscure report about air quality, which is then ignored in planning decisions.) Richard Lee concluded the response to Rod saying we need to improve air quality despite new growth. However, the attitude that we can deal with problems caused by new development at some later time is part of the short term thinking that permeates PCC.

Notably, they did not say that new developments have been refocused on reducing pollution, or they had modeled the overall effect of new developments. For this reason, I have little faith that Portsmouth City Council have really understood that development and air quality need to be treated holistically and quantitatively. As far as I know, the polluting city centre road scheme is still going ahead. Instead, we should be considering a halt on development until we can ensure any new development is within the “air quality budget”. We might need to take drastic action now to allow for new developments later.

PCC had collected and tabulated the ideas from the previous meeting. (I had an annotated copy by the wonderful Mike Dobson.) They listed 30 ideas they considered good, with a further 23 deprioritized as either impractical or already in progress. The first thing I did was to check which list contained the proposal for a charging CAZ. PCC saw fit to put in the impractical category saying:

Due to cost, timescales and resources that would be required to set up and run a congestion charging scheme, this would only be considered as a last resort. At this stage, priority is being given to robust measures which will bring about a reduction in air pollution, rather than looking to develop a congestion charge or Clean Air Zone.

This is problematic on several levels. Firstly the PCC has a legal requirement to bring air pollution down “as soon as possible” and a charging CAZ is recognized by DEFRA as the most effective means to do it. Any proposal must be at least as effective as a charging CAZ to be legal according to the High Court. A charging CAZ is the benchmark by which other measures are evaluated and therefore should be included as an option an any future plan.

Secondly, PCC cites cost as a reason not to implement a charging CAZ. The High Court specifically ruled out lack of resources as a reason not to comply as soon as possible with legislation, so this justification may be open to legal challenge. (Not to mention that a charging CAZ brings in revenue.)

Thirdly, saying the timescale of a charging CAZ is too long is nonsensical since without it, it is unlikely Portsmouth will reach compliance within the 2-3  years it would take to implement it. Again, PCC seem to be using wishful thinking to justify half measures.

Fourthly, they omit the real reason: political difficulty. People don’t like their routines disrupted. However, we need to constantly remind ourselves that our current lifestyles are not sustainable. Disruption is needed (and inevitable). My first thought is local politicians should just say “it’s the law”, pass the buck to central government, and implement a robust plan. I guess they worry their political positions could be taken by denialists, which is very unfortunate (for all of us).

The 30 “good ideas” were pre-selected to 12 prioritized ideas by PCC before the meeting. They were:

  • Investigate introduction of Car Club scheme for the city
  • Bus priority throughout the city
  • Incentivize the use of electric delivery vehicles, especially for goods yards
  • A freight distribution centre outside the city
  • Use of freight at Fratton Station
  • Consider incentives to encourage greater number of EV or hybrid taxis
  • Remove street parking to improve traffic flow
  • Designated loading/delivery times for businesses
  • Ban traffic except buses and bikes from AQMAs, either completely or at peak times/different points of the year
  • Introduce filtering measures such as bollards and trees for traffic-less areas
  • Consider one-way traffic systems
  • Pedestrianize precincts in AQMA6

Almost all the measures attempt to optimize vehicle usage rather than directly reduce it. Our group’s discussions mainly focused on pedestrianization, vehicle limits at certain times, and improvements to bus services. Things that did not make the priority list (apart from charging CAZ) include:

  • Infrastructure changes, such as priority for cyclists at junctions and improvements to support pedestrians, to encourage greater levels of walking and cycling (although PCC claims this is a work in progress)
  • More bike storage/lockers in the city (PCC says they will improve where possible)

So PCC will improve cycling but it is not a priority. This is a bad sign since cycling is one of the key ways to reduce car usage. Other ignored options include:

  • Consider workplace parking levies (within SME exemptions) – PCC gives no coherent reason why this has been discounted
  • Tramlines in key areas of the city – PCC cites cost and lack of space
  • Incentivize the installation of living roofs and green walls to help filter particulates in the air – already in progress
  • Greening the urban environment to make living streets – missing completely from PCC options list! This was proposed multiple times at the last meeting.
  • Charging CAZ

Most of these options have been discounted without proper thought and analysis. In one case, PCC seems to have dropped an option completely without tabulating it. We can add a few new ideas to PCC’s list as well:

  • A ban on new development unless they are pollution neural or better, at least until a quantitative plan has been produced for air quality.
  • A total/non-EV/diesel/older diesel vehicle ban on Portsea Island
  • Using resident parking schemes to limit car ownership (an idea from Lynn Stagg)

These are the most extreme options but we must think outside the box. Hamburg is banning older diesel cars so it is not without precedent.

My biggest concern is the doubt that the 12 priority measures are able to address the problem within a short enough time scale. Local pedestrianization and vehicle limits will just displace the problem. Many other proposals are just tinkering around the edges. PCC should be looking at broader and stronger solutions. Richard Lee said they plan to summarize the feedback they received at the meeting and shortlist about 5 top measures. These will then be modeled and checked for effectiveness before being put into a future air quality plan. Since the other measures have questionable effectiveness, we should include an option known to be effective in the modeling exercise i.e. a city-wide charging CAZ. Without that, I wonder what happens if the modeling report comes back at says none of the measures are ambitious enough?

I asked Dave Ashmore how he manages to balance the needs of voters with legal and financial constraints. Without directly answering the question, he implied that (in my interpretation) we need to educate the public to help reach compliance. This is similar to a comment by Lynn Stagg (at the first meeting) that we need to “bring the public along with us” rather than force them along the right path. I disagree since this is a public health crisis that needs to be urgently addressed. Educating the public about air pollution will take 5-10 years at least (and has already been tried with little success), while we need a solution in 2-3 years. Some compulsion will probably be needed.

One thing that was not discussed was DEFRA’s instructions about need for a Targeted Feasibility Plan, what PCC has sent as a response and what the next stage in the process might be. I am concerned (along with Mike and Rod) that DEFRA is distracting PCC by focusing on just the M275 rather than London Road and overall the big picture.

In conclusion, I welcome the clear language and direction Richard Lee used in introducing the issues but I am concerned that the measures under consideration are too weak.

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Isle of Wight Objects to Southampton Charging Clean Air Zone

Southampton is planning to introduce a charging Clean Air Zone (CAZ) in an effort to reduce air pollution. This is generally accepted to be the fastest and most reliable method to improve air quality. However, the Isle of Wight council has objected to the plans saying it would badly affect manufacturing and tourism.

This is a tricky problem because Southampton is one of the main routes to the Isle of Wight. If the charges go into effect, the cost will eventually be imposed on consumers and tourists. However, the people of Southampton (and Portsmouth) are exposed to traffic fumes, mainly from diesel cars and HGVs, of people traveling to the ferry terminal. Shipping itself also worsens air pollution, although Wightlink has just introduced a hybrid power ferry for the Portsmouth route.

I think what is important to remember is that the status quo is not sustainable. We can’t have tens of thousands of people (UK wide) dying each year from preventable causes. Yes, jobs may be lost but people will shop and do leisure activities more locally, which will create different jobs.

Also, the money generated from the CAZ should be (will be?) used to subsidize public transport, which will make getting around easier and more sustainable.

A problem for Portsmouth residents is that the most polluting vehicles will be threatened with the biggest charges, and be most incentivized to find another route. The most obvious route at this time is via Portsmouth. So we might be seeing the quantity of the most polluting vehicles increase in Portsmouth because of the Southampton clean air zone! This effect is called “displacement”. What we need is a charging CAZ in Portsmouth as well, to balance the scales.

In the long term, ferry ports constructed within major cities might need to be relocated (or existing ferries need to be low emission and only take cargo/passengers moved sustainably).

PS. 19th September, I’m going to the second air quality steering group at PCC.

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What does the Annual Air Quality Limit Actually Cover?

I was talking to Portsmouth City Council about Albert Road and if it was in breach of the legal limits. In 2017, this site recorded 42.6 ug/m3, which is above the legal limit of 40 ug/m3. However, PCC tells me that the site does not come under the legal limits under the DEFRA guidelines. The guidelines state:

Averaging
Period
Objectives should apply at:
Objectives should generally not apply at:
Annual mean
All locations where members of the public might be regularly exposed. Building façades of residential properties, schools, hospitals, care homes etc.Building façades of offices or other places of work where members of the public do not have regular access.

Hotels, unless people live there as their permanent residence.

Gardens of residential properties.

Kerbside sites (as opposed to locations at the building façade), or any other location
where public exposure is expected to be
short term.

It states the annual mean should be applied at “All locations where members of the public might be regularly exposed.” The first curious issue is the limit only applies to members of the public. People at a place of work are not being protected, based on the DEFRA guidelines, even though a considerable amount of time is spent in the workplace. This is perhaps because DEFRA can’t control local pollution sources within the workplace. However, in an office environment, most pollution probably blows in from outside.

The second strangeness is the examples seem to include most places of residence (+ hospitals and schools), but exclude (in practice) just about every other building. Parks, libraries, community centres, churches, beaches, sports grounds and universities are not necessarily included and Portsmouth City Council have not sited any detectors at these locations. This seems to be a serious omission because people, particularly children, can spend a significant time at these locations. This seems to be part of the council’s strategy: to redirect traffic from residential areas and through commercial zones. This is particularly bad for the University of Portsmouth which will see a significant increase in pollution after the City Centre Road scheme road capacity upgrade.

On the other hand, other air quality objectives apply at these sites which might be more appropriate. However, the council has a much weaker monitoring system for these short term limits. With this in mind, they might want to rigorously apply the annual standard since that is what they are capable of monitoring on a large scale.

The guidelines begin with “All locations where members of the public might be regularly exposed.” The “regular” exposure could be interpreted as being exposed at regular or frequent intervals of time i.e. daily or weekly, including short exposures. However, local authorities seem to be interpreting this as “All locations where members of the public might have significant exposure.” This has some sense because the air quality limit is an annual mean and any exposure of a few minutes is not going to make much difference. However, some locations have the public stay regularly for hours, and would contribute several hours of exposure a week. This is a significant exposure and the annual mean should be applied. Of particular concern are parks and community centres which have younger, more pollution sensitive people regularly visiting. I am concerned about Victoria Park which is surrounded by busy roads. I’ve also heard concerns about Hilsea Jubilee Splash Pool near the Portsbridge roundabout.

Portsmouth City Council needs to take air pollution seriously, including controlling dangerous levels around the University of Portsmouth, Victoria Park, St Agatha’s church, St John’s Cathedral since the public has regular exposure to air pollution at these locations.

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