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Category: Road scheme

My statement to Council Cabinet meeting

It is unlikely that a class B Clean Air Zone will bring air pollution within legal limits in the short term. Cars are the main source of pollution, which is ignored under this CAZ plan, so it misses the most obvious opportunity to address the problem. [Thinking about it, I’m not sure that is true.] No other cities have seen big changes in NO2 after introducing a class B CAZ. Portsmouth also has a track record of over optimistic air quality predictions. For example, in the 2010 plan, PCC states they will reach legal levels by 2012-2016. This many be due to unrealistic assumptions, bad traffic data or a mistake in the analysis. Why should we trust the latest modeling when the older predictions were very wrong? The proposed city centre road scheme will ruin any chance of legal compliance. Is the traffic from this and other future developments included in the air quality model? Will the council commit to stop any plan that violates air quality limits? Given the experience of similar cities, CAZ Class D should be modelled and planned, as well as a “do nothing” option, and the option of a class D CAZ with a ban on older diesel vehicles. This is the only way we can be reasonably certain to meet legal requirements and provides a stepping stone towards PCC’s commitment to go net zero carbon by 2030.

There is an issue with the legality of the council’s plans. The council report states that “a balance [needs] to be struck between achieving compliance with legal requirements to reduce harm to people’s health and the impact that such measures could have on the local economy and resident’s livelihoods.” End quote. The High Court rejected that argument saying cost is not to be considered in planning, only efficacy is to be considered. Quote: “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.” End quote. The current air quality plans should be opposed until they meet legal standards.

Portsmouth lacks a safe cycling and pedestrian network, such as seen in Rotterdam and other cities. It is not clear that PCC is prioritizing active travel as a means to tackle air pollution. For instance, Portsmouth Cycle Forum recently objected to the proposed Seafront cycle route saying it was not safe. The proposed city centre road scheme is also overly focused on private vehicles and only does the bare minimum for active transport.

PCC’s plans only seem to extend to 2022. While achieving short term legal air pollution levels is important, it is also necessary to put in place a long term plan for continuous improvement of air quality. Council modelling seems to ignore the possibility of improvements to public transport, which should be a key part of an air quality strategy, to provide people with a practical alternative to car use. A credible air quality plan would have long term ambitious measures, as well as help for residents and businesses to adapt.

My interview on BBC Solent on impact of proposed CAZ

Video of air quality debate. My deputation is at 16 min.

MP Raises Concerns About Isle of Wight Impact of Portsmouth’s Clean Air Zone

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.

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

Responding to Planning Permission for Portsmouth City Centre Road Scheme

What follows is my response to the city centre road scheme planning application. They seem to have a 2000 character limit via their online portal, which seems rather limited.

While the road scheme does includes commendable objectives such as providing cycling infrastructure, reducing traffic congestion, and improving public transport, the current design only pays lip service to the sustainable transport objectives while focusing on capacity increases for private car usage.

In UK law, the Air Quality Standards Regulations 2010, Regulation 26 requires that “measures intended to ensure compliance with any relevant limit value within the shortest possible time” are enacted. The High Court also added “steps are taken to achieve compliance as soon as possible, by the quickest route possible and by a means that makes that outcome likely.”

Portsmouth City Council has an opportunity to greatly improve the city centre and comply with the law, but instead has proposed a road scheme that will increase air pollution by 3.4% city wide, according to the Environmental Statement produced by wsp. This is counter productive and possibly illegal. The design needs to be completely changed to encourage sustainable transport and reduce private car usage. The scheme should also be postponed until PCC produces an ambitious air quality action plan.

Building additional road capacity will simply move the traffic congestion problem to other parts of the city and, for this reason, the scheme is flawed.

The road scheme also needs to form part of an overall city wide transport plan, that provides an overall modal shift in transportation. The scheme should incorporate the eventual total ban of new non-electric cars, expected to happen by 2040. Other European cities, including Paris, Madrid and Oslo have had success in reducing car usage by car bans in certain areas.

The opportunity to improve pedestrian and cycle safety has not been fully realized, with narrow paths often running alongside fast moving traffic.

The deadline for comments is today, 8th June.

As always, sign our petition!

Predicting the Local Impact of Portsmouth Centre Road Scheme

This post is about the local impact of city centre road scheme on NO2 pollution levels in 2026, which is the year the scheme is expected to be completed. The scheme’s effect on pollution was predicted by wsp consultants for Portsmouth City Council using computer models.

Upward (red) arrows indicate an increase in pollution, downward (green) arrows indicate a reduction in pollution. Circles indicate negligible impact. Traffic levels and vehicle efficiency are expected to change over time but this map simply compares the “with scheme” 2026 scenario with the “no scheme” 2026 scenario. This shows is the effect of the scheme itself, rather than these other traffic changes.

References: wsp consultants, City Centre Road Project, Addendum to Environmental Statement, Appendix A.6, April 2018, Revision 3

As can be seen, pollution decreases in a handful of areas, particularly at the north end of Commercial Road, and some parts of London Road/Kingston Road. However, pollution increases in many more areas, particularly around the university and Gunwharf Quays. This scheme should be of particular concern to people living and working in these areas, which are already near the legal limit for NO2 (as shown in a recent post).

The wsp report provides further detail:

The scheme is predicted to cause exceedances of the objective at two receptors (Receptor R20 – B2154 The Hard and Receptor R27 – A3 St Michael’s Road) but will reduce concentrations to below the objective at three receptors (Receptor R64 – A2047 Kingston Road, Receptor R65 – A2047 Kingston Road and Receptor R94 – Old Commercial Street) in this scenario.

The largest increase in concentrations was 5.4μg/m 3 , predicted at receptor R92 (Stanhope Road), however the “With Development” total annual mean concentration at this location was below the objective at 36.2 μg/m 3. The largest decrease in concentrations was 8.8μg/m 3 predicted at receptor R94 (Old Commercial Road), which reduces the total 2026 “Without Development” annual mean NO 2 concentration from 49.3μg/m 3 to 39.3μg/m 3.

It should be noted that although there are a small number of substantial adverse impacts predicted to occur, these all occur in the same geographical location; to the south of the Proposed Development around Stanhope Road/Edinburgh Road and the A29 St Michael’s Road.

The locations at which substantial beneficial impacts occur include receptors near to the junctions of Kingston Crescent and Lake Road. Receptors R89 (A3 Marketway) and R94 (Old Commercial Street) also see a significant drop in concentrations as a result of the new road alignment nearby.

With some areas being pushed above the 40μg/m3 legal pollution, it is arguable that the scheme violates UK air quality law. Areas that are close to or above the limit are at significant risk of health problems. The council needs to reconsider the scheme and attempt to provide significant overall reductions in NO2 levels across the city. This road scheme seems to make things generally worse.

Road Scheme to Cause Overall Increase in NO2 Pollution

I have some more detail from the city centre road scheme and its impact on air quality. The environmental report predicts NO2 levels in 2026 both with and without the road scheme at various locations around the city. This lets us see the impact of the road scheme at specific places, as well as the overall impact.

This graph compares NO2 levels with and without the road scheme. It is a little tricky to interpret, so I will try to guide you around it! Reading along the horizontal (x) axis indicates the predicted NO2 levels without the scheme. Reading along the vertical (y) axis indicates the predicted NO2 levels with the scheme. The orange diagonal corresponds to no impact. Points above the orange line indicate an increase in pollution. Points below the orange line have a decrease in pollution. Each blue point on the graph represents a single location.

It is clear that there are many more points above than below the line. This means that pollution increases in more areas than it decreases.

It is also clear that the points’ distance above the line is greater than the points’ distance below the line. This indicates an overall increase in pollution. Crunching the numbers shows it is a 3.4% increase in NO2 levels distributed around the city (a follow up post on the distribution is planned). This is bad in a city that is grappling with an air quality problem.

A few individual points are significantly away from the orange line, indicating a large localized change in NO2 levels. The location with the biggest drop is 22% and the biggest increase is 14%. This shows the scheme’s effect is quite localized with a significant part of the city being relatively unaffected.

Another interesting observation is the points below the line tend to be on the right of the graph. Also, the points above the line tend to be on the left of the graph. This indicates that most benefit is seen in already polluted areas. Also, increased pollution occurs in areas that have less pollution. Another way of looking at this is pollution is being displaced from a handful of highly polluted areas to many less polluted areas. This raises the question: is pollution better concentrated in a few areas or generally distributed? I am not sure of the answer, but I will try to find out!

As the report text notes, a few locations are pushed from below 40ug/m3 to above that limit (marked with an “A”). This is problematic as that is a legal limit which should not be breached. A handful of locations drop within the legal limit (marked with a “B”), which is a silver lining on a generally worsening picture.

The city centre road scheme is a missed opportunity to tackle the illegal levels of pollution in Portsmouth and the plan should be redrawn to emphasise less polluting options.

PS. Please sign the petition!

Update: an alternative chart of the same data, that is perhaps more intuitive, inserted on the right.


Key Quotes from Portsmouth City Centre Road Scheme (Environmental Statement)

Portsmouth City Council is planning a major capacity upgrade of the city centre roads. Here are some key sections on air pollution from the city centre road scheme environmental statement.

5.7.5. The scheme is predicted to cause exceedances of the objective at two receptors (Receptor R20–B2154 The Hard and Receptor R27-A3 St Michael’s Road) but will reduce concentrations to below the objective at three receptors (Receptor R64–A2047 Kingston Road, Receptor R65–A2047 Kingston Road and Receptor R94–Old Commercial Street) in this scenario.

5.7.7. The largest increase in concentrations was 5.4μg/m3, predicted at receptor R92 (Stanhope Road), however the “With Development” total annual mean concentration at this location was below the objective at 36.2 μg/m3. The largest decrease in concentrations was 8.8μg/m3 predicted at receptor R94 (Old Commercial Road), which reduces the total 2026 “Without Development” annual mean NO2 concentration from 49.3μg/m3 to 39.3μg/m3.

5.7.10. It should be noted that although there are a small number of substantial adverse impacts predicted to occur, these all occur in the same geographical location; to the south of the Proposed Development around Stanhope Road/Edinburgh Road and the A29 St Michael’s Road.

5.7.11. The locations at which substantial beneficial impacts occur include receptors near to the junctions of Kingston Crescent and Lake Road. Receptors R89 (A3 Marketway) and R94 (Old Commercial Street) also see a significant drop in concentrations as a result of the new road alignment nearby.

Table 5.6-2026 Scenario-Impact Significance

ImpactNumber of locations
Substantial Beneficial5
Moderate Beneficial3
Slight Beneficial1
Slight Adverse11
Moderate Adverse21
Substantial Adverse4

5.8.3. Based on the assessment significance criteria, the residual effects of the Proposed Development are considered to range from substantial beneficial to substantial adverse for NO2 and slight beneficial to negligible for PM. However, at the vast majority of assessment receptors the Proposed Development will have negligible residual effects.

The report shows air pollution will remain at dangerous levels for the foreseeable future, unless the issue is taken seriously. This scheme seems to simply ignore its illegality and is a wasted opportunity to make the air we breathe safe. Notice the number of adversely affected areas greatly outnumber the beneficial areas. More details when I read more of the report.

PS. Please sign the petition!