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Category: Air Quality Steering Group

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.


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)

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.

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?