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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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Air Quality Steering Group Has Its First Meeting

Let Pompey Breathe was invited to the first meeting of Portsmouth Air Quality Steering Group. Created by Portsmouth City Council to collect feedback on the air quality situation, it includes community groups, transport managers and PCC planners. Cabinet member members for environment and transport were also there. They aim to share local knowledge and contribute to the next air quality action plan. The compliance manager Richard Lee even said PCC aims to go beyond just reaching compliance and do continual improvement of air quality. This is very welcome it I am concerned that the political will to achieve this is lacking.

In the meeting, council officers claimed that Portsmouth was only out of compliance in one AQMA zone, along London Road. They probably saw the latest annual air quality report which stated:

The 2017 ASR results indicate that NO2 have exceeded the NAQO at 3 locations with in AQMA6 during 2017. No other exceedances of the NAQO, in any pollutant, have occurred.

This seems to ignore site 116 at the Catholic Cathedral on Alfred Road! In 2017, this site recorded 42.6 ug/m3, which is above the legal limit. Ignore data makes it seem like PCC is still in denial about the scale of the problem. UPDATE 27th July: PCC told me that this sites does not count because it is not a site “where members of the public might be regularly exposed” under the DEFRA guidance.

In discussions, either a holistic or focused approach could be used. The worst pollution is concentrated in a few areas, such as the bottom of Mile End Road, and the London Road corridor. The trouble with the focused approach is the causes and potential solutions involve the entire city. Some approaches can easily displace traffic from one neighbourhood to another. Also, the council seem to be focused too much on compliance in the worst areas, rather than trying to improve public health city wide.

In response to the High Court telling DEFRA to improve their air quality plan, they have asked Portsmouth City Council to perform a “Targeted Feasibility Study” to quickly reduce air pollution. DEFRA has strangely told PCC to focus on the Mile End Road area, which is odd since measured pollution is worse along London Road. PCC said DEFRA found Mile End Road is an area of concern based on computer modelling based on the EU’s Pollution Climate Model. It is rather strange that DEFRA is focusing on an area which seems to be (just) within compliance while ignoring an area that is above the legal pollution limit. This is particularly worrying since government funding often follows DEFRA guidance. DEFRA needs to be clear on how their plan will get PCC to achieve compliance in all areas by 2020/2021.

On the other hand, perhaps PCC monitoring along Mile End Road is deficient and there may be a pollution black spot that has remained undetected. The continuous monitoring station on Mile End Road (near Charles Dickens birthplace) is adjacent to a bus lane, which means the data is not acceptable by DEFRA.

Apparently DEFRA is not asking for a Clean Air Zone (CAZ) at this time, which makes it difficult for PCC to reach compliance as soon as possible.

It is unclear if the city centre road (CCR) scheme has been included in the DEFRA models, but it seems like they rely on national data, which is only approximate. Also, the model is apparently in 1km grid, which is relatively low resolution. DEFRA is concentrating on Mile End Road but it is only 500-800 metres from London Road. They seem to be focusing resources based on a model that can’t distinguish between these two areas.

The recent air quality grant to PCC will apparently fund a Portsmouth Clean Air Network. This will invite people to sign a pledge to improve air quality and will keep people informed of developments. This somewhat overlaps the mission of the blog but we welcome constructive competition!

The meeting split into three groups to discuss ideas for specific areas around the city. I raised the possibility of a city wide CAZ. We discussed ways to change people’s attitude to air quality measures. Putting adverts on Colas vehicles was suggested. Lynne Stagg thought it was appropriate to put messages to encourage people to use sustainable transport. I suggested using stronger language because of the national health emergency. Lynne Stagg said that would risk a panic and we should win hearts and minds to bring people along with PCC. I think that attitude is rather over-reacting, and the public needs to be better informed about the health risks they face.

I mentioned the problems with the city centre road scheme and how it increased pollution overall city wide. Lynne Stagg seemed surprised by this claim, which is worrying since she manages transport for the city. She emphasised that traffic will flow will improve in some areas, which is true. I pointed out the overall impact is still negative.

The steering group plans to meet again in several weeks, with the air quality action plan being published by PCC by the end of the year.

In short, it is good that PCC is listening to feedback. However, the PCC councillors don’t seem to recognize their legal obligations or how current plans are vague and insufficient. It is also worrying that DEFRA seems to be distracting from addressing the area of most concern. They need to help focus PCC’s attention on rapid effective solutions rather than distract efforts to less important matters.

PS One major issue we need to resolve is how do we measure if PCC is in compliance with air quality laws: using modelled or measured pollution levels?

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Anti-Idling Signs To Reduce Pollution Outside Schools

Tracey designed these rather awesome anti-idling signs for use outside schools. This is to encourage parents doing their school run to switch off their engines while waiting. This should reduce pollution for children (and adults!) entering and leaving the school gates.

High quality PDF file: LPBidlingfreezoneV2

While “Stationary idling is an offence under section 42 of the Road Traffic Act 1988″, it is a common habit and it is difficult to inform drivers about this issue. The act enforces rule 123 of the Highway Code “You MUST NOT leave a parked vehicle unattended with the engine running or leave a vehicle engine running unnecessarily while that vehicle is stationary on a public road. Generally, if the vehicle is stationary and is likely to remain so for more than a couple of minutes, you should apply the parking brake and switch off the engine to reduce emissions and noise pollution. However it is permissible to leave the engine running if the vehicle is stationary in traffic or for diagnosing faults.”

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Air Quality Campaigners Present Petition to Portsmouth City Council

I presented the Let Pompey Breathe air quality petition to Portsmouth City Council meeting today (video stream is available starting at 15m 30s):

Signatures for this petition were collected by the Let Pompey Breathe campaign group in just 8 weeks. It calls for Portsmouth City Council to “commit to reducing air pollution in Portsmouth to ensure compliance with legal limits and World Health Organisation guidelines as soon as possible, certainly no later than December 2020, and therefore urgently publish its Air Quality Action Plan for consultation, incorporating quantifiable outcomes to address the city’s illegal and unhealthy air pollution levels”. I’d like to provide some legal background.

The Air Quality Standards Regulations 2010 states that “The air quality plan must include measures intended to ensure compliance with any relevant limit value within the shortest possible time.” The word “ensure” is critical as plans need to be realistic, specific and quantified. Also important is the phrase “within the shortest possible time”, which reflects the urgency of the situation. Previous air quality policies have met neither of these requirements.

According to the High Court ruling published in February 2018, “steps are [to be] taken to achieve compliance as soon as possible, by the quickest route possible and by a means that makes that outcome likely”. They also stated “A list of measures which have been carried out, are underway, are promised or are being investigated, does not constitute compliance with [the act]”.

DEFRA has argued that their existing plans were proportionate to the pollution problem. The judge dismissed this argument, saying “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.” This confirms Portsmouth is legally required to take decisive and rapid action to improve air quality to within legal limits as soon as possible.

According to Schedule 8 of the Air Quality Standards Regulations, air quality plans are to include “estimate of the improvement of air quality planned and of the expected time required to attain these objectives.” To achieve compliance within the shortest time, it is necessary to produce a list of scenarios, and model each based on effectiveness, confidence, speed of implementation, cost and political difficulty. The comparison will identify the most effective and rapid solution, which should then be selected. Without this exercise, Portsmouth City Council cannot claim they are “ensuring” compliance or if it will occur “as soon as possible”.

In the ClientEarth High Court case, it was generally recognized that a clean air zone is among the most effective and rapid ways to reach compliance. Therefore, if Portsmouth plans to achieve legal compliance, it needs to include this option as one of the modelled scenarios. While the modelling exercise is necessary, it is unlikely any other solution will achieve the local authority’s legal obligations, so I call on the council to seriously consider a clean air zone for some or all of the city. While these measures will be difficult to achieve, it is vital for the good of public health.

For more information, please see the Let Pompey Breathe Blog, which can be easily found using a search engine. Thank you for your time.

Kimberly of Keep Milton Green then spoke:

Currently, nitrogen dioxide and particulates (PM2.5 and PM10) are a cause of concern in Portsmouth. Most nitrogen dioxide comes from traffic, particularly diesel cars, lorries and buses. Air pollution has been linked to a number of serious health conditions, including cancer, asthma, stroke and heart disease, diabetes, obesity and changes linked to dementia. The situation has been described by some MPs as a public health emergency.

Health concerns should be an important thought when it comes to the consequences of poor air quality in a congested city. COPD (Chronic Lower Respiratory Disease) is the 4th most frequent cause of death in Portsmouth and we have a significantly higher rate of premature mortality due to respiratory disease and of premature mortality considered preventable. COPD early death in Portsmouth is significantly worse than the England average and these rates tend to come from the city’s most deprived and poor areas where life is already hard.

Maximum permissible pollution levels are specified in UK law and are called the National Air Quality Objectives. Many local authorities, including Portsmouth, have been in breach since the rules were introduced in 2010 for nitrogen dioxide. The situation is particularly bad in North End and Fratton along the London Road-Kingston Road-Fratton Road corridor, and also in Lord Montgomery Way by the University. Meeting these air quality objectives as soon as possible is a legal requirement for Portsmouth City Council. However, in North End, nitrogen dioxide levels are actually getting worse.

On a personal level, my youngest son caught bronchitis when he was less than 6 months old which did mean a scary trip to the hospital and has left him with some health concerns and the potential of asthma developer as he grows up. This means for us, frequent trips to the doctor and hospital for his hearing issues as well as frequent chest infections and other issues. For us, this means walking through heavily congested areas such as the junction of Velder avenue, Rodney Road and Milton road with traffic idling. It is absolutely awful to hear him coughing and gasping for air whilst walking through the areas, particularly if he is already ill with a chest infection and struggling without the added toxic air.

Although the Council is reporting Pollution levels are reducing, in 3 of the last 4 months of reporting on AQMA 9 in 2016 nitrogen dioxide levels exceeded safe levels if annualised and in January 2017 the NO2 level was over 50 µg/m3. The current proposal seems short-term and a longer-term coherent plan to reduce human, and especially children’s, exposure to air pollution is what’s needed. Take for example the School-place deficit solution. We have been told that the Council is proposing to expand school-places at Portsmouth Academy where pollution levels breach national safety limits whereas a more sensible option, albet more expensive, would be to build a new school in an environmentally safer location.

The roads in and around the city centre are known to be congested at peak times. Portsmouth City council has proposed a City Centre Road Scheme to increase road capacity. While this scheme claims to promote sustainable transport, it is still too centred on private car usage. According to the scheme’s environmental statement, it will also worsen pollution city wide by 3.4% and will increase polluted air to above legal limits in Commercial Road shopping precinct. The scheme is also unlikely to solve congestion as it will simply relocate it to other areas nearby. Without a major redesign, this scheme should be rejected.

Although disputed by PCC, Portsmouth Friends of the Earth kindly provided an air quality monitor near to Milton Park School which provided the worrying results of levels of pollution of up to 39.7 µg/m3 (please bear in mind that toxic levels are 40 µg/m3 and above!). This is right near to a school with children walking to and attending from the age of 3 right up to 11 years old. This is the air that our children are breathing on a daily basis. This is why Keep Milton Green, the Milton Forum and the Milton Neighbourhood planning team support the Let Pompey Breathe petition.

Portsmouth needs a long-term and coherent strategy to reduce exposure to pollution especially for children. The CCR Scheme requires redesigning immediately with a greater emphasis on sustainable transport to reduce car-dependency. Greater priority should be restored for pedestrians and cyclists at road crossings.

So therefore, as well as being here to support this petition for the 3 Milton groups, I am here for a purely selfish reason. I am here in the hope that this is the beginning of a big change in Portsmouth in regards to air quality but also, in the hope that my children, yours and others across the city will not have to breathe in these toxic fumes on the way to visit a doctor, on their way to school or just being healthy and out and about. We owe our children that and to try to prevent more early deaths, so please consider this petition.

The administration’s response, passed by a unanimous vote of PCC after the debate:

The Council sincerely thanks Mr Tim Sheerman-Chase for submitting the petition to PCC and further raising awareness of air pollution.

PCC recognises the unquestionable public health benefits associated with improving air quality. Air quality is a significant public concern and Portsmouth City Council (PCC) commits to reducing air pollution in Portsmouth to ensure compliance with all legal limit and target values and to work towards achieving World Health Organization guidelines in the shortest possible time.

PCC is actively working on an update to the Air Quality Action Plan (AQAP) and the 2018 progress report contained with the 2018 Annual Status Report (ASR) which will identify actions aimed at reducing levels of air pollution in Portsmouth.

Whist PCC is focusing on all pollution hotspot locations and areas of concern, particular attention is being given to targeting improvements within AQMA6 (Fratton Road / Kingston Road / London Road corridor) as it is within this central corridor where exceedances of the EU and National Air Quality Objectives (NAQO) for nitrogen dioxide are still occurring.

In delivering solutions, we will continue working with Defra on a targeted feasibility study to identify interventions which will promote improvements to air quality within AQMA 11 (Mile End Road corridor) in the shortest possible time. However, in line with our own identified local needs, we have already commissioned an extension to this targeted feasibility study to focus on AQMA 6. Both of these two studies will help to inform the development of a new city-wide AQAP to continually improve pollution levels.

Over the last few years the City Council has significantly increased the number of sites within the city where air quality is monitored. This has allowed the City Council to be able to have real readings for the air quality at the southern end of Mile End Road and be able to show the projections by the Government of air pollution in his location is significantly lowering reality than the Government projections. Further down the road into the city there are no active data points and we will need to introduce them here, so we can find out if the Government figures are right.

Perversely the area of main concern to the City Council – the area north of Kingston Crescent up to Stubbington Ave, is not highlighted by Government. To help public transparency on this issue I have asked the City Council to show on its webpages the map of where all the air quality testing stations are, and the results from each of these. This has been done and I am for the readings to be kept up to date and public so we can monitor progress towards being within both UK/EU legal limits and also WHO limits by the end of 2020 or earlier.

A critical part in the development in the AQAP is consultation and communication with our key stakeholders as tis will enhance the legitimacy and effectiveness of our decision making processes. A Steering Group involving residents’ groups, interest groups, key employers and transport operators has been established to guide the development of the AQAP. Invitations to the first meeting, to take place later in July, have been sent. PCC commit to completing the action planning process by the end of December 2018. Thereafter actions will be quantified and appropriately delivered.

In respect to WHO compliance, our monitoring shows that in 2017 levels in 4 out of the 5 AQMA’s are achieving compliance with the annual average NAQO for nitrogen dioxide. We know that only 1 AQMA, AQMA 6, is currently exceeding the NAQO and the WHO guideline levels as these standards are numerically the same.

PCC is currently meeting the WHO annual average PM10 guideline values at all 4 of its monitoring locations and, whilst the monitoring annual average levels at out 3 monitored sites for PM2.5 are close to the guideline, we acknowledge the fact we are not meeting them and so continue to commit to achieving these as quickly as possible.

The Council acknowledges the actions that the Administration has taken and what action the Cabinet is planning in respect to improving air quality.

Proposed Councillor Ashmore

Seconded Councillor Vernon-Jackson

First to speak in the debate was the former Environment Cabinet member, Councillor Robert New:

First thing to say is a big well done to Dave [Ashmore] for inheriting this. Where the intrastructure of this city is so old, the width of the roads and the congestion, etc, it’s very difficult in dealing, in the short term, with many of these issues and it’s very much a long term goal. I welcome lots of things I’ve heard here today.

I thought it was really important to thank the officers who are working on this, because it requires a joined up approach and its happening though this city council. It’s continuing under this administration. I wanted to say a special thanks to Richard Lee [unaudible], and also to Pam [Turton] and Martin Lavers, who are working hard on this directly with DEFRA. They have far more sopisticated monitoring equipment than environmental groups have, so I understand where some of the friction comes from and people are skeptical. But please do believe us, and I think I speak on behalf of everyone here that they are doing everything they can within realistic time scales to ensure that we do have better air quality. And I think it’s a very small team doing a lot, working with government, working will all politicians, and we should thank them.

Then Councillor Matthew Winnington, Cabinet Member for Health, Wellbeing and Social Care:

I’d like to thank the petitioners for bringing the petition before us. I signed the petition myself. I think it is a really good one to see [for] the councillors today and I think the response we got has full support across the council, as Councillor New has just said. I’d like to say, with my hat on as the Health, Wellbeing and Social Care, obviously good air quality is important for people’s wellbeing and people’s health. What we can do to involve local residence, local groups into this, I think is going to be really good, I’m looking forward to having our air quality action plan being sorted by the end of the year. And go forwards and make it as good as it possibly can be, so not just for the next 12 months but much further into the future, we are going to have air quality in this city that is much better for everyone.

Then Councillor Ben Dowling, Cabinet Member for Planning, Regeneration and Economic Development:

I want to share a couple of things with members that some people are aware of, others aren’t. Myself, councillor Stagg and councillor Ashmore invited the team from Let Pompey Breathe campaign into the council last week. They met with ourselves and senior officers relevant in terms of air pollution. And that meeting was primarily to start a dialog. The Let Pompey Breathe campaign had specific concerns around the City Centre Road Scheme that is currently with planning. [inaudible]

I’ve taken away an action that I properly look at the air pollition side of the City Centre Road scheme. But one of the other actions that came out of it was around publishing all of our data with the guidelines along side them. So currently if you look at how we publish things, we publish them with only the EU levels. But we have now said we will publish alongside the WHO guidelines as well. That makes for easier comparison, with three lines on a graph instead of two. Or three columns in a table instead of two. Hopefully that should make things a bit more transparent as well.

Councillor Luke Stubbs, Deputy Group Leader for the Conservatives:

Just one or two words that have not come out in the debate. In terms of the City Centre Road, the whole point of that scheme is to drive economic growth and economic development. And yes, economic growth and economic development does mean more vehicle movements. That is partly having a population increase, we’ve got to accomadate extra housing growth somewhere, and the city centre is the natural place to do that. And also, if we want the shopping centre to improve, if we want extra office jobs in the city centre, that is going to generate some vehicle movements. That is going to be a trade off, you can’t be absolutist on this. If you’re just going to say we are not going to have economic growth unless it has no impact on the environment and people are going to have to cycle, we are not going to get the growth. So I think we have to be very mindful of what the trade-off is.

Councillor Dave Ashmore, Cabinet Member for Environment and Community Safety, summed up:

I’ve very heartened to see that everyone is happy with that and on board with that. It’s very good going forward, obviously it’s a very important subject. And my predicessor councillor Rob New is right we should be thanking the officers for that and their hard work they put into this. And we have a good working relationship [inaudible] I hope we can have a good working relationship and we can do this cross party. Thank you very much to Let Pompey Breathe, and everyone, for bringing the petition so we can have this debate about air quality in the city and we’ve all had our say.

While PCC has taken some steps in tackling the problem, it is difficult to have confidence in their approach when they have not yet published a timetabled plan to reach compliance and we have not made significant progress in years. More analysis coming soon.

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Air Quality Campaigners Meet With Portsmouth City Council

Big news: The air quality petition has been accepted as being over 1000 signatures and the issue will be debated at the next full Portsmouth City Council (PCC) meeting on 10th July. I’m (Tim) giving a 6 minute deputation. We have been also been covered in The News.

I’ve been talking to local neighbourhood groups which are already very active in campaigning for clean air in Portsmouth. They set up a meeting with Ben Dowling (Cabinet Member for Planning, Regeneration and Economic Development and Lib Dem councillor) which happened 4th July. Also present were Dave Ashmore (Cabinet Member for Environment & Community Safety), Lynne Stagg (Cabinet Member for Traffic & Transportation), and several PCC staff members including Tristan Samuels (Director of Regeneration), Pam Turton (transport planning),  Kirsty Routledge (senior transport planner), Richard Lee (Regulatory Service Manager, runs the council’s air quality monitoring). Cabinet members have only recently taken on their respective roles since the Lib Dems have just taken control of PCC. I’d say most of the key people were present from the council, except perhaps the project board overseeing the City Centre Road (CCR) scheme.

Rod Bailey (Milton Neighbourhood Planning Forum) started by introducing our concerns. The CCR scheme is harmful and missed opportunity because it re-enforces car dependence, it worsens the air quality situation and does not prioritize sustainable transport. While the scheme claims to improve things, it fails because it retains dangerous cycle routes and congestion will occur in other areas of Portsmouth. While the road scheme is currently awaiting a planning decision, it is troubling because PCC is both the applicant and evaluator of the scheme. He recognized the need to make more areas of Portsmouth suitable for development but claimed the CCR scheme was the wrong approach.

Mike Dobson (Friends of Old Portsmouth Association) then spoke at more length about the details. In different planning documents, PCC has used different traffic growth figures, an inconsistency he has raised several times but not heard a satisfactory response. He pointed out the CCR scheme was intended to make traffic flow freely but planning only accounted for a small area of Portsmouth. The traffic would quickly arrive at locations like Anglesea Road heading towards Gunwharf Quays, which is already highly congested. The CCR scheme will only make congestion in the surrounding areas worse. (This is shown in the WSP Consultants Environmental Statement on the CCR scheme which indicates an overall increase in traffic.) The CAPIT tool, which is a set of interactive maps (and actually hosted on this blog: CCR impact, current NO2 levels), was introduced and explained to PCC. Using this tool, Mike realised that pollution will significantly increase at the southern end of Commercial Road (and all along Stanhope Road). This is a major shopping area which is already very polluted and will make the environment much worse for pedestrians and cyclists that choose to visit the area. Mike introduced the parking survey results, which highlights the need for cheap reliable buses and safe cycle routes. He then went on to question the effectiveness of some air quality initiative of PCC, such as road signs shown around Clean Air Day encouraging sustainable transport. He showed traffic count data indicating it had had a minimal effect. He then moved on to the legal implications on PCC of the February High Court/Client Earth ruling in that “steps are taken to achieve compliance as soon as possible, by the quickest route possible and by a means that makes that outcome likely.” In a recent council report, the PCC solicitor highlighted that the council was legally liable (“there is nothing in law to prevent such private applications being aimed at local authorities either failing to engage or failing to achieve compliance suitably interested individuals or groups could mount significant challenges”) but would have a defence if they can show they committed fully and acted reasonably. Mike called for a range of options to be modelled covering “do nothing”, “do something” (continuing present course) and “do everything” (charging Clean Air Zone) options, as well as evaluating measures of effectiveness, confidence, speed of implementation, cost, political difficulty, and the most effective to be selected based on the evidence. However, most measures taken by PCC have effects that are either difficult to quantify or have minimal impact. Mike showed a RAG (red-amber-green) chart as a starting point.

Lynne Stagg (Traffic & Transportation) then spoke, firstly recognizing that car ownership is too high in Portsmouth. She plans a series of parking control zones which limits the number of cars in the city. This will be gradually introduced because of the lack of resources at PCC (Tim observation: due to cuts by central government). Replacement services need to be provided such as buses – however bus service providers are planning to cut their services. We also need to encourage use of the park and ride service. She also hopes to gradually change public opinion on the issue of air quality and sustainable transport. She was doubtful that compliance could be achieved by 2022, and was thinking 2026 was a more realistic date because of shortness of officers to do the work. In the end, she promised to do everything possible “within our constraints”.

This is perhaps a key point of difference between us air campaigners and PCC: they expect that taking well intentioned (but limited) actions within normal day-to-day business of the council will be sufficient, but without attempting to quantify the effect this will have. Rod described this approach as based on “hope” or what I might call “wishful thinking”. What PCC don’t seem to grasp is their legal obligation to ensure compliance “by a means that makes that outcome likely.” Politicians are wary of adopting policies that could be unpopular since their careers and personal influence are at stake. PCC is also short of money so every solution seems financially problematic. They also are worried about impacting economic growth in the Portsmouth area. Air campaigners call on PCC to think outside of the box and re-evaluate their priorities. Air quality levels are a legal requirement on PCC and this takes precedence over most of their usual priorities. The hidden health cost of air pollution has not been properly balanced with more easily measured economic activity, not to speak of the human cost. Based on the High Court ruling, I suspect PCC is also legally required to take measures that are at least as effective as a Clean Air Zone, which would again require modelling work to be conducted.

Given the potential impacts on individuals and businesses of CAZs and other measures, the [Government’s] Plan provides that if [the most polluted] local authorities [excluding Portsmouth] can identify measures other than Charging CAZs, which are at least as effective at reducing NO2, then such measures are to be preferred. However, the local authority must demonstrate that these will deliver compliance as quickly as a Charging CAZ. […] no real point is taken on the assertion […] that Charging CAZs are the most effective means of addressing NO2 exceedances. […] But the Government cannot sensibly, or lawfully, substitute the application of its [more lenient 3 year compliance] benchmark [for areas including Portsmouth], however rational in respect of areas where a CAZ is the most efficacious solution, for the requirements of the Directive and the Regulations in areas where it is not.

In my view, PCC also admitted that they are not aiming to achieve this as soon as possible i.e. by 2022, citing the lack of staff/financial constraints as the reason. This is a dangerous admission to make because it is breaks the law: “steps are taken to achieve compliance as soon as possible“. The High Court ruling dismissed the argument that financial constraints are a valid excuse. (Not all the air quality campaigners present think PCC went so far as to admit non-compliance until 2026, so this is definitely my own view.)

Nor is it an answer to this point to say […] that the current plan […] is a “proportionate” response by the government to the issue raised by NO2 emissions. Implicit in that submission is a suggestion that cost may play a part [in planning…] I reject that argument. […] the obligations imposed by the 2008 Directive are not qualified by reference to their cost

Pam Turton advised that planning and evaluation of options is being conducted in AQMA6. This is welcome but should be conducted on a city wide basis. PCC seems to be believe that pollution is limited to a handful of hot spots. Mike suggested that the range of measures considered will still not be sufficient to meet PCC’s legal obligations. I’m concerned that PCC are again focusing too narrowly on compliance and not enough on public heath. AQMA6 is not the only area of concern since many other AQMAs are only barely within legal limits.  Also, if I’m reading the reports correctly, AQMA7 is also above legal NO2 levels in the most recent annual report.

Ben Dowling again reiterated the Lib Dem administration’s commitment to air quality. They mentioned the creation of a new steering group on air quality including local groups, transport operators and council officials.

Cycle routes in the CCR were discussed. PCC councillors said they thought the scheme will have excellent cycle routes, which drew derision from most air quality campaigners present, including from Anna Koor (Friends of Old Portsmouth/Let Pompey Breathe). The CCR is primarily focused on road capacity upgrades, while having what is effectively spare land given to pedestrians and cyclists. The cycle route along the dockyard wall is currently very dangerous, but under recently published plans it will be widened in the CCR to only the minimum recommended width. Air campaigners pointed to this as an example of PCC’s lack of ambition in encouraging sustainable transport, since it will remain a daunting route alongside fast moving traffic. If PCC reallocated an additional metre width from the road to the shared cycle/pedestrian route, that might show PCC is willing to take sustainable transport seriously. It is startling just how low bar the PCC has set for what constitutes a good scheme. The air quality campaigners referred PCC to the Portsmouth Cycle Forum’s objection to the CCR as a starting point for further information. (See also FOOPA’s objection.) Sustrans have even threatened to delete route 22 of the national cycle network because it is dangerous, which shows the lack of PCC’s commitment to sustainable transport.

Rod raised the concern of too many junctions being optimized for motor users rather than cyclists and pedestrians. Mike discussed the impact of the removal of a pedestrian crossing at the Anglesea Road/Park Road junction near the university, requiring pedestrians to walk further and wait longer in traffic fumes at three other crossings to make the same journey. Ben mentioned at least one crossing on this route will prioritize pedestrians. More investigation of the current situation by air quality campaigners is probably needed. Rod called for the PCC to adopt the Precautionary Principle, which calls for greater caution in decision making particularly when there is uncertainty about the impact on public health.

PCC also mentioned they are considering measuring particulate air pollution against the stricter WHO limits. This is a welcome move since the law does not seem to have kept pace with scientific understanding.

Also in the news: BBC, “Illegal levels of air pollution linked to child’s death“, 3rd July 2018

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Traffic & Transportation Cabinet Member Encourages Cycling

Apart from speaking at Portsmouth Cycle Forum, I was also in the audience when Lynne Stagg was also speaking as the city council Cabinet Member for Traffic & Transportation Lynne Stagg. She said some sensible things about encouraging cycling including:

  • She would like to see fewer cars on the road
  • Portsmouth City Council funding from central government has been cut making changes or improvements difficult.
  • She plans to create a strategy for all forms of transport
  • Eastern road upgrade is in progress
  • The East West active route will run along Goldsmith Avenue. (The annual air report says it will run though AQMAs 6, 7 and 12 which is along Queens Road, south of Guildhall Square, Fratton Bridge. £245k is planned for “Physical improvements to key travel routes to improve permeability and encourage use of active travel modes, making walking and cycling more attractive forms of travel. To include greening of routes and tree planting and other public realm where possible”)
  • Contraflow cycling (cycling in the opposite to one way motor traffic) divides opinions of cyclists. It also only can be used if the road wide enough.
  • The council is trialling a cycling near miss reporting tool. This is used for planning safety improvements and they need more data. (News report.)
  • The possibility of using Fratton rail goods yard for transporting goods into Portsmouth without using HGVs, then loading them on to electric vehicles has been mentioned. This is only at the idea stage.
  • Kingston’s Crescent to Stubbington Avenue is a particular area of concern. However if a Clean Air Zone (CAZ) is proposed, the local ward councillors probably (loudly) oppose it.

PCF is also trialling free membership to attract a wider base of cyclists. They plan to fund themselves by donations.

PS. Shout out to our friends at Zero Waste Portsmouth!

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Clean Air Day, 21st June

Today is Clean Air Day. We handed in first batch of ~1150 signatures for the air quality petition to Portsmouth City Council – well done everyone! We will keep collecting them to keep pressure on!

I’m (Tim) speaking later today at Portsmouth Cycle Forum Open Meeting, Starts at 19:00, duration is 02:00 hours, Lecture Theatre 2 of the Richmond Building

As it’s @cleanairdayuk we welcome #letpompeybreathe campaign organisers to present details and facts about their campaign.

New Traffic & Transport Cabinet member Lynne Stagg will also be present to discuss the new Lib Dem administration’s approach to cycling and their plans to implement #ACitytoShare

Another reminder that our next open meeting is at 7.00pm Thursday 21st June at the University of Portsmouth Richmond…

Posted by Portsmouth Cycle Forum on Tuesday, 19 June 2018

Update: Slides from PCF presentation .odt, .pdf

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2017 NO2 levels draft report published but figures misinterpreted

Big news: we have around 1200 signatures for our air quality petition. We should be able to hand in what we have so far to the city council on Clear Air Day (21st June).

News about air quality is arriving thick and fast! It’s hard to keep up some times. However, this post is going to focus on what has claimed to be news, but actually isn’t. The latest NO2 levels have been published in draft form. This has lead to reporting in The News saying:

…in the past 12 months there have been significant improvements recorded, with two-thirds of the island’s 28 monitor stations showing cleaner air compared to 11 per cent the year before.

The errors in this statement are many but subtle. The first thing to remember is that pollution levels not only depend on emission of pollution, but also on weather patterns. Each year the wind blows in different directions for varying amounts. This makes the entire regions pollution levels increase or decrease in a broadly similar way. This becomes clear if we look at the average city wide NO2 levels for the last 6 years:

While each year the level changes, the levels have actually stayed around 32μg/m3 throughout. While the 2017 level is slightly below, this is not outside of the typical natural variation due to weather. The emission levels could be thought of as a “signal” while the effect of weather could be considered as “noise”. Although it is certainly possible that emission levels have changed, the change is within the range caused by natural weather fluctuations. This means we can’t say if the slight reduction seen in 2017 is due to weather or emissions. While we welcome favourable weather, this is not a long term solution and does not make enough of a difference.

Another problem is reporting that “two-thirds of the island’s 28 monitor stations showing cleaner air”. Since all the monitoring stations are subjected to the same weather, and that weather effects have a similar or greater effect than changes to emissions, we would expect most monitoring stations to show a change in the same direction from year to year. The exact proportion tells us almost nothing about the air quality situation in Portsmouth.

Some people might remember the game show “Play Your Cards Right“. The game involves guessing if a hidden card has a higher or lower value than the previously drawn random card. The average numerical value of a card is 7, so if the previous card was a 10 it is usual to choose lower. If the previous card was a 2, the contestant should pick higher.

Similarly, if an NO2 reading is particularly high in one year (as it was in 2016, and subject to noise like weather effects), we would expect a lower value the following year (which it was in 2017). (This might be a form of regression toward the mean but I’m still trying to understand the concept.) The only way around this, apart from somehow accounting for the effect of weather, is to wait for additional data in subsequent years.

On the other hand, some individual sites show large changes. I am hesitant to call the changes significant until further analysis has been conducted, except when the pattern is in the opposite direction to most other monitoring stations. This does hint at a worsening situation in London Road, unfortunately.

This again shows a broadly constant level of pollution, with a handful of large changes in at a few sites. Here is the same data shown on an interactive graph that we named the CAPIT tool:

This clearly shows The News is wrong to claim “The only area to still be below par is the London Road corridor, in North End”. The pollution is also above the legal limit near the Catholic Cathedral (site 116).


In other news, the latest report reveals the City Council has added new NO2 monitoring tubes to many new locations: 16 in 2017 and 59 in 2018, up from 28 sites in previous years. This is very welcome as it allows Portsmouth City Council and the public to see the scale of the problem. The 2018 additions were due to DEFRA commenting on the 2017 air quality report. (Thanks DEFRA!)

The report mentions £245k being spent on an “East-West Active Travel Corridor”, which sounds promising.

The recent Parking Consultation report provides interesting reading:

An overwhelming majority (82% of respondents) view parking as problematic whereas 16% of respondents do not view parking as a concern in Portsmouth.

This is fairly obvious to anyone who has tried parking in Portsmouth. It is another symptom of Portsmouth’s over reliance on private car transport. In terms of encouraging sustainable transport:

The two main ways that bus use could be encouraged among respondents is ‘lower travel costs’ and ‘more frequent/reliable sources’ with 52% and 48% of respondents respectively.

The responses for ways of encouraging cycling across Portsmouth show that ‘Improve cycle routes’ is the most popular response with 34% of respondents selecting this option and ‘Increase/install cycle routes’ is second most common with 27% of respondents.

It seems a shame this were not sufficiently prioritized in the City Centre Road scheme.

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