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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.

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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.

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Key Quotes from CAZ Debate

Quotes from the CAZ debate on Monday 9th Sept.

I don’t want to see a charging zone, it would be damaging for business, it would hit the city centre, it would undermine the Isle of Wight ferry and it would make Portsmouth as a whole a less attractive place for business. […] The other thing which I found quite interesting from the outline strategic case, which is actually quite worrying, you have some outline costings, is the vast cost of any sort of scheme. £10-20 million just in order to monitor vehicles and send out bills. Well there is only three roads in and out of Portsmouth and on the face of it, the geography makes it a simple problem. So I can only assume this is to have monitoring all over the city, not just vehicles that remain on Portsea Island for the entire journey. Isn’t that a massive amount of money to spend? On the face of it, there ought to be a better solution. […] £10-20 million might take you some way towards solving the problem, rather than just measuring it. […] This is EU red tape.

Luke Stubbs (Conservative)

This [CAZ] is not something that the council is choosing to do. This is something that government is choosing imposing on us. And it’s having to work through their methodology, which is at times deeply unhelpful. This is a government plan, which the government are forcing on Portsmouth. And I’m sure Luke [Stubbs] as a spokesman for the [Conservative] government, as they are your lot, that you will be able to support and justify it. […] If we end up with a clean air zone, this will be at the decision of the government. Full stop, nobody else. […] We will always refer to it as a government imposed plan […] If all it does is somebody in a lorry who is trying to get to London, starting in Ryde, drives across the Isle of Wight to Yarmouth, to pick up the ferry to get to Lymington, drives through the new forest, on that route, that will produce more air pollution than if they come through Portsmouth. And yet they are likely to be charged in this government imposed scheme by going through Portsmouth but not if they go through the New Forest and across the Island and that is clearly barking [mad] but it’s his [Luke’s] government. The other bit that really worries me is the effect on the retail sector. We know that almost all the parking in our main retail areas is private. We have no control over that at all. But the government is trying to keep high streets alive. But this government imposed plan is likely to cause people to not shop in Portsmouth, but to shop at Hedge End and out of town retail parks, where they can only get to by going down motorways and driving further. […] We wrote to government in March about lots of different things and so far, Luke, there has been a deafening silence. [… Central] Government are very keen on imposing things, they are not very keen at coming up with any solutions. […] I have a real worry for those people who are the poorest in our city, for whom a car is an essential for work, for whom it will become now too expensive to go to work because they are the least afford to change their cars. […] This is a government imposed scheme, with a government imposed methodology, which we have to do in their way, even though we know it will be ineffective, we could do it much better if they didn’t impose things in this way.

Gerald Vernon-Jackson (Lib Dem, Leader of Council)

Getting people to get out of their cars is very difficult […] If you get people out of their cars, you’ve got to have an alternative mode of transport. And we are working hard with the bus companies to improve the services. It’s a catch 22 situation, people don’t use certain parts of the bus services, therefore the bus companies cut those services, therefore fewer people use the buses. […] We are working on a fully integrated transport strategy. […I told a resident] “if you haven’t got off road parking, you only have room for one car”. He said “you are taking away my civil liberties”. And I said “there are people dying in the city because there are too many vehicles.” […] There are on average 1.37 cars per household in Portsmouth. It’s a city of terraced houses, you only have room for one car outside most houses […On pollution and congestion:] this is not unique to Portsmouth, it’s true for every major city in the country.

Lynne Stagg (Lib Dem, Transport)

This is a very difficult situation. It would be a mistake to think that CAZs are a solution that is in any way considered and thought through. Unfortunately, CAZs are a sledgehammer the government uses because they have no real understanding of what needs to change in terms of improving air pollution. They just see it as charging people. Charging people might have some effect but its something that very much affects everyone and most severely poorer people in the city because they do not get any relief from it whatsoever. […] What needs to happen from central government, in the same way they are imposing what we have to do on the city council, they should “impose” a load of money on us, so we can fund these kinds of things.

Matthew Winnington (Lib Dem, Public Health)

[…] We have to look at the wider approach the council is taking. Let’s remind ourselves, if we may, Leader, that Portsmouth has been crowned council of the year for energy efficiency. Particularly looking at people in poor homes. The city boasts the largest in house energy team, no in the south east region, but across the United Kingdom. We put in over 400 solar panel systems in Portsmouth, amounting to 20,000 solar panels. […] This is all being done here in Portsmouth. The council gets rocked[?] left right and centre sometimes but it’s doing a very good job. […] Portsmouth is being held up as a good model for reducing carbon […]

Lee Hunt (Lib Dem, Community Safety)
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LetPompeyBreathe At Youth Strike 4 Climate

The protest on Friday 20th Sept was huge and we had plenty of interest at our air quality stall.

We were invited because the solutions for air pollution from NO2 and particulates are very similar to climate breakdown. Also, air pollution has an immediate impact on people which can make it more politically urgent. Of course, the measures we need to prevent climate change are much larger than just solving air pollution.

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Court of Appeal upholds housing planning refusal on air quality grounds

“The Court of Appeal yesterday (September 12) upheld a planning permission refusal on air quality grounds for 330 homes in Kent, making it the first time a planning appeal has been refused due to concerns over air pollution and public health.” Air Quality News

PS I’m busy preparing for a stall at tomorrow’s Youth Strike 4 Climate, Guildhall Square, Portsmouth.

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My statement to Council Cabinet meeting

It is unlikely that a class B Clean Air Zone will bring air pollution within legal limits in the short term. Cars are the main source of pollution, which is ignored under this CAZ plan, so it misses the most obvious opportunity to address the problem. [Thinking about it, I’m not sure that is true.] No other cities have seen big changes in NO2 after introducing a class B CAZ. Portsmouth also has a track record of over optimistic air quality predictions. For example, in the 2010 plan, PCC states they will reach legal levels by 2012-2016. This many be due to unrealistic assumptions, bad traffic data or a mistake in the analysis. Why should we trust the latest modeling when the older predictions were very wrong? The proposed city centre road scheme will ruin any chance of legal compliance. Is the traffic from this and other future developments included in the air quality model? Will the council commit to stop any plan that violates air quality limits? Given the experience of similar cities, CAZ Class D should be modelled and planned, as well as a “do nothing” option, and the option of a class D CAZ with a ban on older diesel vehicles. This is the only way we can be reasonably certain to meet legal requirements and provides a stepping stone towards PCC’s commitment to go net zero carbon by 2030.

There is an issue with the legality of the council’s plans. The council report states that “a balance [needs] to be struck between achieving compliance with legal requirements to reduce harm to people’s health and the impact that such measures could have on the local economy and resident’s livelihoods.” End quote. The High Court rejected that argument saying cost is not to be considered in planning, only efficacy is to be considered. Quote: “I reject any suggestion that the state can have any regard to cost in fixing the target date for compliance or in determining the route by which the compliance can be achieved where one route produces results quicker than another. In those respects the determining consideration has to be the efficacy of the measure in question and not their cost.” End quote. The current air quality plans should be opposed until they meet legal standards.

Portsmouth lacks a safe cycling and pedestrian network, such as seen in Rotterdam and other cities. It is not clear that PCC is prioritizing active travel as a means to tackle air pollution. For instance, Portsmouth Cycle Forum recently objected to the proposed Seafront cycle route saying it was not safe. The proposed city centre road scheme is also overly focused on private vehicles and only does the bare minimum for active transport.

PCC’s plans only seem to extend to 2022. While achieving short term legal air pollution levels is important, it is also necessary to put in place a long term plan for continuous improvement of air quality. Council modelling seems to ignore the possibility of improvements to public transport, which should be a key part of an air quality strategy, to provide people with a practical alternative to car use. A credible air quality plan would have long term ambitious measures, as well as help for residents and businesses to adapt.

My interview on BBC Solent on impact of proposed CAZ

Video of air quality debate. My deputation is at 16 min.

MP Raises Concerns About Isle of Wight Impact of Portsmouth’s Clean Air Zone

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Clues To Portsmouth’s Air Quality Plan

Portsmouth City Council are going to vote on the following motion on Monday 9th Sept:

Approves the proposed preferred package as set out in paragraph 5.12 as the preferred option to be taken forward to outline business case development; that is a 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.

A class B CAZ covers buses, coaches, taxis, private hire vehicles and heavy goods vehicles. I doubt that this will be sufficient based on other cities that have introduced similar schemes. For example, the London Low Emission Zone had minimal impact on NO2 levels (before it was upgraded to a ULEZ). Cities in the Netherlands with a LEZ have also seen minimal impact. Only when light goods vehicles and cars are included in the CAZ, such as schemes introduced in Germany, do we see significant changes in NO2 levels.

PCC says they have selected a class B CAZ based on modelling. Given case study evidence suggests this will have minimal impact, I am immediately suspicious of their model. They have a track record of predicting drops in NO2 levels that fail to materialize. For example, in their 2010 plan, they state they will reach legal levels by 2012-2016:

5.9. What is the likely date for compliance with the NAQO? With no additional remedial measures being implemented, an estimate of the likely date for compliance with the NAQO has been made. This estimate has been calculated using the approach described in LAQM TG09. The results of this approach are listed in Table 6.

Table 4: Estimated Year of Compliance with NAQO

AQMA Year of Compliance – Annual Mean NO2 Objective
AQMA6 2016
AQMA11 2012

In reality, NO2 levels have been roughly unchanged. My suspicion is they are using unrealistic traffic projections. More traffic means more pollution. Why should we trust their modelling if they have been wrong before? Another factor is that the consultants hired to do the analysis are only likely to be rehired by the council if they provide a report that says what the council wants to hear, which might bias their thinking.

I downloaded and plotted the local authority traffic levels based on data from the department of transport.

Over this 23 year period, Portsmouth seems to have had a 7% increase in motor traffic. That is less than I would have expected. This is about 0.4% per year. Reports by PCC used in road planning have used 4.1% per annum. Their air quality reports have used 0.5%, which is contradictory but perhaps more reasonable. Perhaps the growth in traffic they expect is highly localized? I need to think about this! Their model prediction of 2022 still doesn’t match the case study evidence.

It is not entirely clear that the council intends to introduce a charging CAZ based on their reports. I suspect this is just a lack of clarity in the language.

The council should be benchmarking various options against both a charging CAZ, as well as option of doing nothing. This allows us to check if their model is realistic since we want to know the impact of each measure separately.

The report is also very focused on measures that will deliver results in the short term. While this is important, PCC should also be looking at continuous improvement and to go beyond the legal standards. However, PCC’s track record of failing to do even the legal minimum shows their priorities do not include public health.

Whilst none of these measures alone was considered sufficient to bring forward compliance, implementation of all three measures in combination was predicted to bring forward compliance from 2020 to 2019 for A3 Mile End Road and from 2023 to 2022 for A3 Alfred Road.

Most of the measures proposed by PCC are difficult to quantify. However, I hope that they attempted to do so using realistic estimates.

Work is continuing to develop Portsmouth’s Air Quality Local Plan for submission to JAQU by 31st October 2019.

This should be circulated to the public as well, since they are the ones affected by it. Hopefully we don’t need to force PCC’s hand unlike their draft plan which they refused to circulate but did after a freedom of information request was sent.

The air quality situation being handled as an inconvenience by PCC rather than a public health crisis reminds me of the last scene in Chernobyl.

To be a scientist is to be naive. We are so focused on our search for truth, we fail to consider how few actually want us to find it. But it is always there; whether we see it or not, whether we choose to or not. The truth doesn’t care about our needs or wants, or governments, or ideologies, or our religions. It will lie in wait for all time and … this, at last, is the gift of Chernobyl.

Also, see the earlier post on legal concerns. Coverage in the local paper.

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Portsmouth City Council takes Legal Risks on Air Quality

ClientEarth has warned 100 local authorities their plans for air quality must be robust.

Lawyers from ClientEarth are putting 100 local authorities across England on notice, warning them that they will violate their legal obligations and risk legal challenge if they do not introduce proper climate change plans.
The environmental lawyers are writing to each local authority that is currently developing a new local plan, giving them eight weeks to explain how they will set evidence-based carbon reduction targets and ensure these targets are then central to their new planning policy.
Amid growing pressure for local governments to declare ‘climate emergencies’, ClientEarth launched the campaign in light of the massive shortfall in compliant local planning policy across the country and to advise authorities of their legal duties under planning and environmental law.
ClientEarth climate lawyer Sam Hunter Jones said: “There is a collective failure by local authorities across England to plan adequately for climate change. Too often climate change is perceived to be just a national or international issue and therefore solely the responsibility of central government.
“Clearly central government needs to do more, as the recent Committee on Climate Change (CCC) progress reports stress. Yet so many of the daily decisions around new and existing infrastructure – such as new buildings, roads and utilities – are made at the local level. All of these decisions will ‘lock in’ an area’s future emissions and its resilience to climate change.

Extract from a Press release from ClientEarth

This should be particularly concerning to Portsmouth City Council since they are ignoring High Court rulings by making statements such as:

In developing a solution to exceedances in nitrogen dioxide levels in the city there is a balance to be struck between achieving compliance with legal requirements to reduce harm to people’s health and the impact that such measures could have on the local economy and resident’s livelihoods. It is considered that the proposed preferred approach strikes this balance.

Air Quality Plan, Progress Report, (Due to be voted on) 9th Sept 2019

The High Court rejected DEFRA’s argument that their plans were proportionate based on the balance of various priorities.

I reject any suggestion that the state can have any regard to cost in fixing the target date for compliance or in determining the route by which the compliance can be achieved where one route produces results quicker than another. In those respects the determining consideration has to be the efficacy of the measure in question and not their cost. (and) That, it seems to me, flows inevitably from the requirements in the Article to keep the exceedance period as short as possible.

High Court Ruling, Feb 2018

The law already takes into account what is a reasonable action. With their current attitude, PCC risks people’s health and lives, not to mention wasting time and tax payer money in a potential legal battle.

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XR Portsmouth Air Quality Protest

Extinction Rebellion Portsmouth organized a procession and die-in protest on 17th August. It attracted more people than any air pollution protest to date, and helped raise awareness of the problem of air pollution in Portsmouth. I’m worried most people are not aware of the danger they face from pollutants like NO2 and particulates. The walk started at the North End junction by the library, and passed through several severely polluted roads including Kingston Crescent. We also passed by the birthplace of Charles Dickens near the end of the M275, which is also a pollution hot spot. The walk stopped at several monitoring sites along the away and at each stop we had a short talk by a volunteer on the harm caused by pollution, and the social justice aspects of the campaign (the most deprived areas have the lowest car ownership but the highest pollution). The talk on pollution during the time of Charles Dickens was very interesting. I gave a talk on potential solutions to the crisis which revolved around improving public transport, active travel and restricting car usage. XR erected a number of signs along the route to warn people of the danger to public health.

The event was covered by The News, which is appreciated!

PS Progress report by PCC on the air quality plan. And this too.

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Play Out Pompey

Part of Francis Avenue, Southsea, was closed for 3 hours to traffic on Sunday 21st July for children to play in their local area. This was organized by local mum Laura Mellor of Play Out Pompey. This follows recent roadworks to install speed tables which enabled children to use the usually busy street as a play space. This allowed friendships between local children to form, and then between neighbours who were more often at the front of their houses. After the roadworks were removed, local residents decided to try make the streets safe for play again. This is great for community relationships and a great example of what is possible if we claim space back from car usage. It also raises awareness of the air quality problem and some of the measures that can be used to tackle it. We need to make car usage less convenient and make our urban spaces more pleasant for pedestrians and cyclists.

Organizing such a road closure is quite an achievement and involves quite a bit of work. Permission was needed from Portsmouth City Council (PCC) to close the road. I understand Suzy Horton, Steve Pitt and the Active Travel Team were very helpful in overcoming bureaucratic challenges. Then every household on the Francis Avenue was asked for their opinion on the scheme, even though only a part of the road was to be closed. The vast majority of residents were supportive of the scheme. The diversions needed to be planned. Signs were borrowed from PCC. Contacting the residents found several other parents willing to help organize and steward on the day. About six stewards kept watch on the road and answered motorists questions as needed. A stewarding rota was organized so people could take a break. The organizers had to get public liability insurance to reduce their personal legal risk.

At the designated time, road closure signs and cones were positioned. Local residents who wanted to park in the closed section were escorted at walking speed to a parking space, which only occasionally happened. After about an hour, the road was full of children playing, often with parents. I thought about cycling through the area but it was simply too busy!

Not all residents were happy with the event. They were concern over congestion and possible car damage. Using nearby school playgrounds out of school time was suggested, but this is still not as local as playing outside your own house and making friends with neighbours.

The event was attended by the Mayor, and local councillors Suzy Horton, Darren Sanders and two PCSOs. Suzy said she was looking for an opportunity to do this kind of road closure for some time but felt it was best for an apolitical organizer to take the initiative. Play Out Pompey was the first such road closure and was a learning process for the council, as well as the organizers. There is a good chance the process will be streamlined for future events. Laura hopes to repeat the event some time soon. It might be good to do this kind of event as part of the annual clean air day, perhaps on a road that has not been previously closed.

Playing Out is a small charity that helps parents organize road closures for children’s play.

Reporting in The News: Francis Avenue in Southsea is closed for the afternoon to become the city’s first ‘play street’

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