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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