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Air Quality Steering Group 16th Jan – Promising TALK FROM Council but Will They Follow Through?

I went to the 3rd Air Quality Steering Group (AQSG) on 16th Jan. DEFRA has instructed Portsmouth City Council (PCC) to perform various air quality related actions, including a new draft plan by end of Jan 2019. This plan is hugely important for the future of Portsmouth air quality and I hope PCC will take the necessary strong actions.

After a quick introduction by David Ashmore, regulatory services manager Richard Lee outlined recent events. The format was slightly different than previous sessions with Portsmouth City Council (PCC) giving a series of presentations. With the air quality political situation changing rapidly in the last few months, they felt they needed to update everyone. Lee said PCC are committed to take measures that will ensure compliance (in line with the law). The main motivation for this is improvement of public health. He re-iterated the terms of reference for the AQSG were slightly broader than I remembered: to share knowledge, to assist in creating an action plan and to champion improvements. PCC are currently short-listing measures for inclusion in the new plan, which they say will involve “hard choices”. The final plan will be published by the end of Oct 2019. Richard Lee says they will have a programme of continuing improvement after that (but I’m not sure PCC has the political will to follow through considering their lack of progress on air pollution to date). Richard Lee also mentioned that PCC has other objectives such as new developments, but these must “dovetail” with air quality measures.

PCC has been operating under various ministerial directives, supervised I think by DEFRA. March 2018 saw a directive to produce a Targetting Feasibility Study (TFS) to address areas of pollution identified by DEFRA found using modelling. For the two areas of concern, PCC produced a report to bring forward legal compliance in air quality by 2021/2022 respectively. However, the areas did not match the worst pollution areas found by monitoring. Monitoring is generally superior to modelled data (since the model is based on the monitoring and is only ever an approximation). DEFRA seems to be sending PCC on a wild goose chase on where to focus effort. However, Lynne Stagg has recently said PCC have argued that DEFRA needs to focus on London Road (AQMA 6) and other areas based on actual measurements. (Doesn’t DEFRA trust PCC air quality monitoring? Slightly worrying.) The TFS has identified various measures including a bus retrofit programme and expanding electric vehicle (EV) charging points.

The EV charging points will be a lamp post based solution. The lamp post will be at the back of the pavement away from the road. The power cable travels under the pavement to another bollard at the road side for vehicles in a marked bay to use. This raises the issue of clutter on pavements, which if not done well, could discourage walking in the city. PCC plans 40 by the end of the year, mainly located by requests from the public. The possibility of anti-hogging of EV charging points was discussed but no measures are in place at this time. Three car parks are currently trialling EV charging points (Clarence Pier is one). More publicity of these EV points was requested by Rod Bailey (Milton Neighbourhood Planning Forum).

PCC are also conducting an anti-idling campaign. This runs for 4 weeks with radio adverts, social media, online resources and publication of resources (Tracey’s poster was mentioned!) Market research about types of trips and reasons for idling have been conducted. Lamp post banners have appeared on the most polluted roads encouraging drivers to turn of their engines if stationary for more than a minute. Some junctions in Portsmouth have more than a 1 minute wait for traffic e.g. the junction of Priory Crescent/Goldsmith Avenue. Some AQ campaigners in the audience pointed out PCC seem to be watering down their campaign by not mentioning the legal aspect of engine idling. PCC acknowledged that engine idling is illegal but it is not enforced, since resources are better spent elsewhere.

PCC are also running Monster Walk at various schools, encouraging walking and discouraging the “school run” by car. They have designed cute characters to spread awareness and free keyrings awarded for successful completion.

PCC are planning a clean air day for 2019 after the previous day in 2018. Air quality campaigners questioned the effectiveness of the event. PCC officers responded that they were measuring effectiveness using marketing measures such as social media engagement. Campaigners pointed out actual air quality would be a more relevant measure since it should result in a direct behavioural change. Richard Lee noted out that weather plays a role in air pollution, so even a direct measurement would not be a definitive indicator. (Mike Dobson of FOOPA previously observed that the 2018 clean air day produced no benefit based on the councils on continuous monitoring sensors.)

Bus Retrofit programme is beginning, with changes made to buses less than Euro 6 in certain areas of AQMA 9 around the bottom of M275 (why not AQMA 6/the rest of the city?). I thought that bus engines cannot be simply be swapped, but apparently the retrofit can be done at the rate of 1 bus per day. This probably involves a change to engine emission filtering rather than the engine itself. The target date might be Oct 2019, as far as I remember.

PCC only hinted at some of the measures under consideration, such as pedestrianising certain areas of London Road (near Kingston crescent?) or making it one way. Other hints were “reducing car usage” and “encouraging” increased EV usage, both of which are quite vague. I think compliance by 2022 was mentioned as being a DEFRA requirement.

One major development was that PCC announced that measures under consideration will be compared to the effect that a charging Clean Air Zone (CAZ) would have on air quality. This was a DEFRA requirement. This is great news as this encourages more ambitious measures to be taken that are quantitatively predicted to be effective. Well done DEFRA and PCC! Our campaign as been calling for this for some time.

Worryingly DEFRA has advised that measures other than a CAZ will be preferred. Also worrying, PCC have said that some of their ideas were considered to be “too ambitious” by DEFRA, being concerned by the cost to taxpayers. DEFRA have told PCC to produce a number of reports by Oct 2019: an overview of the strategic situation with current measurement data, an economic case (to the city residents and businesses?), a commercial case (that PCC can fund the plan?), financial case (?), and a management case that will show the plan will actually achieve compliance. PCC will produce a number of scenarios with different combinations of measures, so the predicted effectiveness and cost can be compared. (Will there be a consultation? Will that further delay implementation?)

PCC are planning an Automatic Number Plate Recognition (ANPR) survey of traffic in the city. This will be able to check, at certain locations, what journeys vehicles are taking and what types of vehicles are being used. The survey will be run for 7 days, 24 hours a day, possibly in Feb. PCC’s initial plan of a city wide was scaled back on DEFRA’s request to focus mostly on AQMA’s, involving around 60 ANPR camera locations.

Development and growth of the city was briefly mentioned but no specialist PCC officer was available to comment. More development generally means more demand on the transportation systems which is currently too car oriented. Richard Lee claimed future PCC plans would ensure the city remained within legal compliance.

Analysis

My main concern is that PCC considers measures that are ambitious enough, and they don’t mess up the analysis. The report at the end of January will be very significant. Rod Bailey pointed out to me after the meeting that the specific measures were hardly discussed but I think this is unsurprising given PCC are probably working actively on the plan.

The air quality petition conducted earlier this year called for a urgent publication of an air quality plan. This has not happened yet because DEFRA required various actions, including a draft plan by end of Jan 2019.

What Richard Lee said was very promising: PCC are making a serious attempt to reach air quality legal compliance without the shortest possible time. However, I have my doubts that the councillors responsible (or some group in PCC) have the political courage to take strong actions. (If they had the courage, we would not be in the situation we face. Sorry but true).

PCC is right that we need to focus on the city wide situation and not get side tracked by a quick fix caused by DEFRA confusion. I’m still wondering why DEFRA is using their model when it most likely does not have the spatial resolution required. Apart from focusing on the wrong area, the TFS focus on bus pollution is questionable given buses only produce a smaller proportion of NO2 pollution. This suggests that DEFRA are looking for quick fix solutions rather than looking at the bigger picture. However, without DEFRA putting pressure on PCC, I doubt the council would be taking air quality as seriously as they are. Well done DEFRA on this! (although it is really just following the law)

Regarding clean air day, one audience member, from the University of Portsmouth I think, mentioned textures that respond to pollution which is a way for people to understand the usually invisible problem. There was no mention of a temporary road closure as I previously suggested.

As I mentioned, PCC have said that some of their ideas were considered to be “too ambitious” by DEFRA, which is concerned by the cost to taxpayers. This comment is perhaps more dangerous than PCC realizes because DEFRA has previously argued in the High Court that their old plans were “proportionate” considering available resources; the High Court rejected that argument, at least in the planning phase, saying what was proportionate has already been considered by lawmakers, who had specified compliance as soon as possible without reference to cost. I wonder what measures have been privately rejected by DEFRA as too costly… (and ClientEarth will be interested in this little fact I’d expect.)

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

PCC will be comparing the various options to a charging CAZ. However, I’ve since realized that DEFRA has a rather optimistic view of what a CAZ can achieve. They are only moderately effective at reducing NO2 pollution with several German cities finding they result in a one of drop of several percent NO2 levels. We need at least a 10% drop in NO2 in certain areas, which a realistic CAZ might not achieve in the short term. However, I get the feeling DEFRA’s models might overestimate their effectiveness. So the question remains: is the CAZ that PCC models going to be an optimistic or realistic model? An over optimistic CAZ model might actually lead to radical but necessary non-CAZ measures being adopted. This is going to get interesting…

PCC still have not clarified if realistic traffic projections are being used, and if future developments are included or excluded. Air quality planning has previously used lower traffic predictions, while road building has used higher predictions. Consistency on this will be an essential part of PCC’s future plans.

PS I hear Southampton is dropping their CAZ plan, which is probably not good…

PPS The next Portsmouth Climate Extinction Rebellion meet 21st Jan.

Anti-idling signs along London Road (AQMA 6)
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