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Category: DEFRA

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)

Discussion at East Southsea Neighbourhood Forum with Portsmouth City Council

We have a good sized audience at East Southsea Neighbourhood Forum. I gave an overview of the air quality situation and then we had an informal Q&A session with Lynne Stagg (PCC transport) and Steve Pitt (PCC Culture and Leisure). There were some good questions from the audience on air quality policy and solutions. Both PCC councillors had to step in at short notice as the planned speaker Gerald Vernon-Jackson was unavailable. This was probably for the best as Lynne is probably more familiar with the issue.

Audience question: If 50% of the problem comes from diesel, why doesn’t Portsmouth City Council either tax diesels or put in a plan to ban older diesels?

Lynne Stagg: Now let me correct a few things. We have been working on the air pollution problem for quite a while. DEFRA identified two areas that are not compliant: one is the bottom of the M275 and the other is Alfred Road, and they have been done by modelling. The reality is the bottom of the M275 is compliant and has been for a long time.

[Receptor 30 at the bottom of the M275 has been barely under the legal limit since 2014. The annual average in 2017 was 38.5 ug/m3.]

The data we are worried about, and we have been telling DEFRA for several years, is the Fratton Road, Kingston Road, London Road [area], and we are not compliant there and we have not been for a long while. The reason for that is it is very difficult to actually deal with it because it is a corridor, and the geographical nature of the area makes it worse than it would be anywhere else. There is no where for diesel fumes, etc. to escape.

Although diesel is a bigger offender than cars, there are more cars the HGVs, for example. The greatest volume of emissions is coming from cars as a total rather than individually.

ESNF Panel: So you disagree with Tim?

Lynne Stagg: I disagree on that particular point, about the actual amount.

[Lynne Stagg seems to be questioning the chart I took from the PCC commissioned Source Apportionment Study 2017 by AECOM.]

Lynne Stagg: There are a lot of things we could do, and that we are doing. Between 1971 and 2011, the population of Portsmouth went up by 50%. Car ownership went up by just under 300%. There is your problem. There are too many vehicles on the road, it’s a simple as that. We can do lots of things about getting rid of them. One thing […] which is contentious is resident parking zones. Because, for the majority of houses in Portsmouth, there is only room for one car, if you have no off road parking. A lady three weeks back, she came to me and said “I have three cars, what am I supposed to do?” […] get invented an elastic road. When they do, they can stretch it and you can put extra cars on, you can have it. In the mean time, you only have room for one car outside your house. We can take a lot of parked cars off the road. I am very keen on taking the parked cars off [?] Road, North End, because apart from anything else, I know from the [?], people are trying to park, the traffic is held up behind, we’ve got emissions coming out. Cutting engines in when you are waiting in traffic lights, they do it on the continent, I don’t see why we can’t do that here. There are lots of like that, that we are in the process of doing.

[Tim: Is it possible that the fewer cars that remain would be used more heavily? Is there any evidence that reducing residential parking reduces congestion?]

Coming back to London Road, I think we have convinced DEFRA that it is not compliant, and they are listening to us, because we have real evidence and they are just modelling it. We have lots of things in the pipeline. A lot of these things take a long time to do because it’s a chicken and egg situation, for example: I’d like to see more cars get off the road but where are the buses? I’m frustrated, I could come here by the 17 bus. [?] I waited 25 minutes and the bus didn’t turn up! So I ended up getting a taxi. However, we haven’t got a good bus service because people are using their cars. So it’s a catch 22 situation, so there’s lots of things we need to do.

But coming back to polluted air, there was a brilliant documentary 2 or 3 months ago called “The Air We Breathe” with twin brothers who were adopted. One of them [lived?] in Birmingham on a section of road very similar to North End. He did a lot of work, they were measuring the emissions from vehicles and this is how I know that HGVs, although individually give out more fumes because they are diesel. Because the volume of cars is much greater, the amount of emissions from cars is greater than from diesel [HGVs]. He did a lot of work with local shopkeepers who said we couldn’t possibly take cars off the road, they would lose their trade, etc, etc. Anyway, head on social, it didn’t for 24 hours. In that 24 hours, the NO2 emissions were reduced by 30%. They had the buses and cyclists going through, but all the cars and HGVs […] I stopped those 10 years ago because they used to come down London Road, North End.

So, for particulates, there is no work being done on that. They put in trees in tufts, when they did this road closure. And they then washed the leaves of the trees afterwards, because the particulates settle on the leaves. I had no idea before I saw the programme. And they evaporated the water and the amount of particulates was amazingly high. So we need to have more trees in to take up the particulates, not the NO2 maybe. [?] It’s just a lot of these things, if you do one thing, you’ve got to look at the repercussions elsewhere. And I totally agree with you on planning. Steve [Pitt] will back me up. We put in objections when planning applications come in and if we turn down applications, they then go to appeal to an anonymous individual, the inspector in Bristol, who overturns [?] and then we get fined for having turned down [?].

Audience member: You have a pretty picture on here, Tim, of an idle free zone. Have you got a question that I can ask somebody: I passed two taxis today, both by Tesco giving out diesel fumes. How can I ask nicely for them to turn their engine off? [?] he’d take no notice at all. Could we have a little card or something?

Lynne Stagg: I shout out the window of my car and I tell them to turn the engine off. I often shout at cyclists that havn’t got lights on. [?] I was lord mayor [?] there was a cyclist who went through a red light and I said [to the driver] “slow down” and he said “you can’t lord mayor” and I said “watch me”. So I shouted “you have no lights on, we could have killed you. It’s OK of you want to die that’s up to you but I don’t want it on my conscience for the rest of my life.” So there are a lot of things we can do, if we just have the guts to do it.  But we have a lady in Keep Milton Green [actually Tracey McCulloch of Let Pompey Breathe], and she designed one of these idle free things and we are looking at have them made up and having them outside schools, etc. But I think we need them at traffic lights as well. That is what they do in places like Germany. Not everyone will do it but if we put enough pressure on those drivers, they will start doing it because they will be embarrassed. It’s like those those lights flashing up saying you are doing 30 mph in a 20 mph zone. I’ve gone through some of those not realizing and I’ve felt so guilty when they flashed up that I immediately slowed down. It’s not going to happen immediately but it will happen eventually.

Audience member: We could each have little cards that we could each give to the driver, that would be really useful.

Panellist: Lynne, on that point about “you are exceeding 30 mph” signs that flash up, you can’t get machines that say “the level of particulates is exceeding [?]”

Lynne Stagg: I’m sure you can. I don’t know. It’s not my portfolio. [Lynne deals with Transport, not Environment.] I hold the portfolio that causes all the air pollution problems. [With a note of sarcasm:] I am therefore personally responsible for every traffic problem, every parking problem, every air pollution problem in the city. Hands up, I accept that. It’s not my portfolio but I will ask Dave Ashmore.

Menno: I’ve got a question. I appreciate many things have been done over the years. Small things have been done to improve air quality. But as the graph shows that there hasn’t really been any actual change in air quality. So, isn’t it time to take more drastic measures now, because the measures that have been taken have proven not to be effective enough? They havn’t kept up with the increase in traffic around the city. Sure you can actually reduce traffic. Introducing resident parking zones is all well and good but that doesn’t help unless they are implemented across the entire city because you will just move the cars over to the next area. So, I think we really need to implement something more drastic and why not introduce a charging zone in certain areas of the city or in fact the entire island?

Lynne Stagg: I think a lot of businesses will be against that. We have considered, a bit like London… charging… Our city centre is dying anyway. Lots of city centres and shopping centres are, and that is not going to change. So if you actually stop people from coming in, because they have to pay, they are not going to come at all. They are going to go to Southampton and Chichester and wherever. So there is the objection, so we try to do a balancing act. So I think sometimes you have to go around a problem to solve it, rather than head on. We’ve got to get things done by 2021 and 2022 with two of the Air Quality Management Zones. It has to happen. I’m trying to work with the bus company. For example, all the buses have to be retrofitted with Euro 6 diesel. It’s still diesel but it’s much much cleaner. That is going to cost between £1.5 – 2 million. DEFRA is going to give us some of the money, but [the rest] is coming out of our budget. And we have to save, what is it? $4.5 million this year. And the same next year, and I think more the year after. We have shrinking budgets. I’d love to put resident parking zones up across the city. We haven’t  got the staff to do it. We can’t afford the staff, because we haven’t got the money because we paid for other things like retrofitting buses. There is only so far the money will go. We have to try to work within the budget we’ve got and try to pull in money from outside, like from DEFRA. We’ve put in a bid for $120 million to have bus rapid transport, coming from Waterlooville and Havant. Southampton are doing the same thing. The Eclipse route goes to Gosport and Fareham. It’s taken a lot of traffic off the A32 and therefore a lot of the air pollution but it hasn’t solved it. But you have to have something to replace what was going on. I have ideas and then try to find somebody to fund them. I want to have a bus depot in Portsmouth because our buses mostly come from Fareham. We could get bus companies from Eastleigh for example. But every time you do that, you pay for dead time. You have to pay for the driver and the fuel to get them to Fareham, and the pollution. If we had our own bus depot, we could have more buses, cheaper buses, serve a bigger area and hopefully more people would use them. Then get the cars off the road. But that doesn’t happen tomorrow. So there is a plan there. It’s like a jigsaw puzzle: you have a little picture and you have to get all the bits to fit in.

Menno: The plan you are talking about, there is a plan in place, is that going to be published for consultation?

Lynne: Yes because there is an air quality group that has been set up. [To Tim] And you’re involved? [Yes I am.] We’ve got to send that to DEFRA and have it approved by January [2019]. Yes, it will be, because the more people that feed into it… We’ve had meetings with lots of sections of the city. People come up with ideas that we don’t think of. So yes, it will definitely be published and consulted on. The more ideas the better.

[to be continued…]

My slides: .odp, .pdf

ClientEarth calls DEFRA’s air quality policy a “pitiful plan”

ClientEarth, a legal charity that has held the government to account on air quality, has won a series of legal victories in the High Court against DEFRA. The court has repeatedly found DEFRA’s plan of passing responsibility to local authorities to be insufficient and illegal. DEFRA had to produce a new plan to deal with pollution in 33 local authorities, including Portsmouth. The newly published plan has been strongly criticised by ClientEarth:

ClientEarth clean air lawyer Katie Nield said: “Today’s pitiful plan shows that the government’s strategy to tackle air pollution by passing the buck to local authorities is in tatters. It’s essential that the government takes action on a national scale.

“Amazingly, ministers have now ordered more plans, which means more delays. It shows a shocking lack of leadership on a key public health issue.

She added: “It’s absolutely staggering that only now, eight years after legal limits came into force, the true extent of the problem is being uncovered for large areas of the country. In the meantime, people in these areas have continued to be exposed to dangerous levels of air pollution.”

This is significant since ClientEarth has repeatedly defeated the govenment in court. Since they strongly criticized the new plan, DEFRA should be extremely worried. ClientEarth could take DEFRA back to court and are quite likely to win. For the sake of public health, the government should take stronger action, including decisive actions taken at a national scale.

DEFRA directs Portsmouth to produce a “much more thorough assessment”

Latest from Air Quality News:

Ten local authorities have been directed to take further steps to address nitrogen dioxide emissions from road transport, under supplementary plans outlined by ministers today (5 Oct).

The councils – Dudley, Leicester, Newcastle-under Lyme, Portsmouth, Reading, Wolverhampton, Sandwell, Solihull, Basingstoke and Deane, and South Gloucestershire – will have access to funding to implement measures including bus retrofits, improved road signalling and behavioural change campaigns. […] Defra has revealed today that eight of these 33 local authorities will carry out more detailed study outlining how they will tackle more persistent air quality problems they have identified, to be presented to government by 31 October 2019.

There is a corresponding statement from DEFRA. In it, they announces the new policy document that affects Portsmouth titled “Supplement to the UK plan for tackling roadside nitrogen dioxide concentrations“. In one section, DEFRA provides their view of the recent targeted feasibility study done by Portsmouth City Council.

83. A combination of retrofitting buses to meet higher Euro emissions standards, reducing car use and promoting uptake of cleaner vehicles was modelled to bring forward compliance at Census ID 48196 from 2020 to 2019 and on Census ID 18114 from 2023 to 2022. [Both locations are at the bottom of the M275….]

88. The bus retrofit scheme is estimated to include approximately 100 buses and the local authority estimates that it could be delivered by the end of 2019. […]

89. Even with the bus retrofit, there is still a persistent exceedance with compliance projected to be by 2022. The government has therefore also directed Portsmouth City Council to carry out a more detailed study to develop a plan to bring forward compliance in the shortest possible time. The Direction requires that the local authority produce a final plan by 31 October 2019.

The bottom of the M275 will come into compliance with legal limits by 2022, according to modelling. However, local modelling shows a rather bleaker picture in the London/Kingston/Fratton Road corridor with no way to know if or when Portsmouth will come into compliance. The DEFRA report also doesn’t mention that the city centre road scheme that is expected to push some areas above the legal limit.

In response to the dire situation, DEFRA has instructed Portsmouth City Council to produce further plans by the end of October that will get air quality within legal limits “in the shortest possible time” as the law requires. Interestingly, they mention consideration of a Clean Air Zone (CAZ):

22. For some road links a more persistent exceedance has been identified where the road link is projected to become compliant in 2022 or beyond. For these road links more significant measures could be considered; for example, it is possible that a Clean Air Zone could be implemented. Whilst this measure may not be necessary or appropriate, it is necessary for these local authorities to carry out a much more thorough assessment of the air quality problem and the options available to bring forward compliance. The government has therefore further directed these local authorities to carry out a more detailed study to develop a plan to identify the most suitable measures to address the exceedance.

While DEFRA does not insist that a CAZ needs to be implemented, DEFRA now requires “much more thorough assessment of the air quality problem and the options available to bring forward compliance”, which is very welcome. Portsmouth must consider a Clean Air Zone, if they want to claim they did a “through” consideration of “significant measures”. This is what #LetPompeyBreathe has been calling for, for some time, and is one of the measures that has been so far ignored by Portsmouth City Council.

While DEFRA are moving in the right direction, they could use clearer language that told local authorities to take measures that are at least as effective as a CAZ (as required by the 2nd tier local authorities by the High Court). As a cross-committee report by MPs said (prior to the most recent air quality document):

The Government is failing to provide clear messaging and national leadership on the issue of charging Clean Air Zones (CAZ). Defra’s technical report found that charging zones offer the fastest and most effective route to air quality improvements, yet the 2017 plan requires councils to demonstrate that all other measures will fail to achieve the necessary results before introducing a charging zone. This lack of clarity is causing confusion and hampering councils’ ability to tackle air pollution as quickly as possible.[…] Defra’s modelling already shows that, in many cases, non-charging options will not be as swift or effective as charging Clean Air Zones. If local authorities are regularly exceeding NO2 concentration limits and identify a charging Clean Air Zone as being the most effective mitigation strategy, they should be able to receive Government support for implementing a CAZ without having to go to onerous lengths to demonstrate the inefficacy of other options. If this approach fails to deliver the required improvements as quickly as possible, the Government should consider mandating charging zones in hotspot areas.

The measures currently under consideration at PCC are too weak while a CAZ is a known effective solution. Please PCC, take the air quality situation seriously!

PS FAQ by Friends of the Earth on Clean Air Zones

Update: I just noticed DEFRA has given PCC over a year to produce a plan! That is hardly in line with the urgency of the situation. An initial plan is due by Jan 2019.

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.