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Clues To Portsmouth’s Air Quality Plan

Portsmouth City Council are going to vote on the following motion on Monday 9th Sept:

Approves the proposed preferred package as set out in paragraph 5.12 as the preferred option to be taken forward to outline business case development; that is a Class B CAZ is combined with a number of non-charging measures to ensure that compliance is achieved within the shortest possible time i.e by 2022.

A class B CAZ covers buses, coaches, taxis, private hire vehicles and heavy goods vehicles. I doubt that this will be sufficient based on other cities that have introduced similar schemes. For example, the London Low Emission Zone had minimal impact on NO2 levels (before it was upgraded to a ULEZ). Cities in the Netherlands with a LEZ have also seen minimal impact. Only when light goods vehicles and cars are included in the CAZ, such as schemes introduced in Germany, do we see significant changes in NO2 levels.

PCC says they have selected a class B CAZ based on modelling. Given case study evidence suggests this will have minimal impact, I am immediately suspicious of their model. They have a track record of predicting drops in NO2 levels that fail to materialize. For example, in their 2010 plan, they state they will reach legal levels by 2012-2016:

5.9. What is the likely date for compliance with the NAQO? With no additional remedial measures being implemented, an estimate of the likely date for compliance with the NAQO has been made. This estimate has been calculated using the approach described in LAQM TG09. The results of this approach are listed in Table 6.

Table 4: Estimated Year of Compliance with NAQO

AQMA Year of Compliance – Annual Mean NO2 Objective
AQMA6 2016
AQMA11 2012

In reality, NO2 levels have been roughly unchanged. My suspicion is they are using unrealistic traffic projections. More traffic means more pollution. Why should we trust their modelling if they have been wrong before? Another factor is that the consultants hired to do the analysis are only likely to be rehired by the council if they provide a report that says what the council wants to hear, which might bias their thinking.

I downloaded and plotted the local authority traffic levels based on data from the department of transport.

Over this 23 year period, Portsmouth seems to have had a 7% increase in motor traffic. That is less than I would have expected. This is about 0.4% per year. Reports by PCC used in road planning have used 4.1% per annum. Their air quality reports have used 0.5%, which is contradictory but perhaps more reasonable. Perhaps the growth in traffic they expect is highly localized? I need to think about this! Their model prediction of 2022 still doesn’t match the case study evidence.

It is not entirely clear that the council intends to introduce a charging CAZ based on their reports. I suspect this is just a lack of clarity in the language.

The council should be benchmarking various options against both a charging CAZ, as well as option of doing nothing. This allows us to check if their model is realistic since we want to know the impact of each measure separately.

The report is also very focused on measures that will deliver results in the short term. While this is important, PCC should also be looking at continuous improvement and to go beyond the legal standards. However, PCC’s track record of failing to do even the legal minimum shows their priorities do not include public health.

Whilst none of these measures alone was considered sufficient to bring forward compliance, implementation of all three measures in combination was predicted to bring forward compliance from 2020 to 2019 for A3 Mile End Road and from 2023 to 2022 for A3 Alfred Road.

Most of the measures proposed by PCC are difficult to quantify. However, I hope that they attempted to do so using realistic estimates.

Work is continuing to develop Portsmouth’s Air Quality Local Plan for submission to JAQU by 31st October 2019.

This should be circulated to the public as well, since they are the ones affected by it. Hopefully we don’t need to force PCC’s hand unlike their draft plan which they refused to circulate but did after a freedom of information request was sent.

The air quality situation being handled as an inconvenience by PCC rather than a public health crisis reminds me of the last scene in Chernobyl.

To be a scientist is to be naive. We are so focused on our search for truth, we fail to consider how few actually want us to find it. But it is always there; whether we see it or not, whether we choose to or not. The truth doesn’t care about our needs or wants, or governments, or ideologies, or our religions. It will lie in wait for all time and … this, at last, is the gift of Chernobyl.

Also, see the earlier post on legal concerns. Coverage in the local paper.

XR Portsmouth Air Quality Protest

Extinction Rebellion Portsmouth organized a procession and die-in protest on 17th August. It attracted more people than any air pollution protest to date, and helped raise awareness of the problem of air pollution in Portsmouth. I’m worried most people are not aware of the danger they face from pollutants like NO2 and particulates. The walk started at the North End junction by the library, and passed through several severely polluted roads including Kingston Crescent. We also passed by the birthplace of Charles Dickens near the end of the M275, which is also a pollution hot spot. The walk stopped at several monitoring sites along the away and at each stop we had a short talk by a volunteer on the harm caused by pollution, and the social justice aspects of the campaign (the most deprived areas have the lowest car ownership but the highest pollution). The talk on pollution during the time of Charles Dickens was very interesting. I gave a talk on potential solutions to the crisis which revolved around improving public transport, active travel and restricting car usage. XR erected a number of signs along the route to warn people of the danger to public health.

The event was covered by The News, which is appreciated!

PS Progress report by PCC on the air quality plan. And this too.

July News

I spoke that the East Southsea Neighbourhood forum giving residents an update on NO2 levels and effective measures to tackle pollution. Dave Ashmore, who oversees Environment and Climate Change at the council spoke before me and we had a good (but brief) discussion with the audience and Gerald Vernon-Jackson (leader of Portsmouth City Council).

An audience member asked Dave if a Clean Air Zone was likely to be introduced. His response:

I’d like to be able to say we will have it sorted by then [2021?]. I’ve got to worry about it. I can’t sit here and lie to people. Obviously, it will be up to the government. They are the ones who will impose it on us. We had the plans; we requested the funds from government. We requested from government to help with all the things like electric vehicles, like the free public transport, like for the scrappage scheme. We have not heard anything back. Make of that what you will. This is something that the government will be in charge of.

He is right that Portsmouth needs more resources to tackle air pollution. However, I think their plans are best as a compliment to a charging CAZ, not as an alternative solution. On their own, they won’t bring us into compliance as quickly as possible.

pollution inside A car vs. Walking and Cycling

Some information based on research by Liz Batten of Clean Air Southampton

There have been loads of small studies done about pollution for inside car vs. outside car, with varying results. But in general, provided you take certain precautions, you are much better off cycling and walking, rather than being in a car. This BBC summary is pretty good and includes a case study of what to expect alongside busy roads vs quiet roads. So the moral of this tale is – when cycling and walking – always take routes that avoid busy roads, especially idling traffic, whenever possible.

Bear in mind that newer diesel cars have filters fitted to remove particulates, but the computer won’t switch it on until the engine has reached a certain temperature. So, on a cold day, by the time you’ve got to the school gate and returned home it might just have switched on. So short journeys are absolutely the worst thing about diesel engines, even Euro 6 standard, because of this. The school run in a car is probably the most polluting thing you can do to yourself, the occupants of your car and those on the pavement.

#LetPompeyBreathe in Air Quality News

Our recent activity was reported by Air Quality News! Why Portsmouth needs a Clean Air Zone

Portsmouth needs to seriously consider introducing a Clean Air Zone to improve the air quality of its poorest residents, writes Tim-Sheerman-Chase of the local Green Party.

Clean air campaigners in Portsmouth welcome Councillor Vernon-Jackson’s appeal for more funds to encourage active travel and sustainable transport. [Continue reading]

UPDATE: Portsmouth Friends of the Earth relaunched their website, which includes their Streets for People report about peoples’ best and worst roads.

Climate Emergency in Portsmouth

The motion that was passed by Portsmouth City Council yesterday:


Proposal to Declare a Climate Emergency in Portsmouth

Proposed by Councillor Judith Smyth

Seconded by Councillor Thomas Coles

We are in the middle of a climate emergency which poses a threat to our health, our planet and our children’s and grandchildren’s future. (Sadiq Khan London Mayor)

The UK exceeded the scientifically agreed safe level of CO2 in the atmosphere (350ppm) sometime in the late 1990s. Since then we have been gambling with the lives of future generations and other species. Today we have reached the point where, even if we stopped all production of fossil fuelled cars, buses, trains, ships and planes and built no more gas or coal power stations, we would still only have a 64% chance of keeping below the 1.5°C target agreed in Paris in 2015.

In Portsmouth we have very high levels of air pollution on some streets where people live, cycle and walk exposing people to dangerous chemicals. Children are particularly vulnerable. We have also had several breaches to sea defences and are vulnerable to flooding.

48 UK local authorities have declared a climate emergency including Cornwall, the Forest of Dean, Bristol, Lambeth, Nottingham, Lancaster, Brighton and Hove, and Milton Keynes. 72 cities around the world have also declared a climate emergency committing resources to address this emergency.

A climate emergency declared by a local authority can be a powerful catalyst for community wide action when paired with a clear action plan. There is no time to waste if we are to avoid the consequences of a rise in global warming above 1.5°C.

We propose that Portsmouth City council asks the Cabinet to Declare a Climate emergency to give a compelling lead to citizens, businesses and other partners of the urgency to reduce our carbon footprint to zero by 2030.

Portsmouth City council has started this journey. CO2 emissions in Portsmouth have reduced from 1243.5 kilotons in 2005 to 817.9 kilotons in 2016 and the City council has recognised that to avoid the worst impacts of climate change further reductions are needed. Several separate initiatives are underway. For example, electric car charging points, tree planting, investment in the new plastics recycling plant required to recycle more plastics jointly with Hampshire and Southampton by constructing a new Integra plant and the ‘cough, cough’ campaign together with reduction of carbon footprint of council premises and services.

However, this is somewhat disjointed and too slow. What is needed is action. Working with local business and other partners we need to develop and agree an ambitious city-wide strategy and clear action plans leading to rapid action which is openly monitored, well led and well governed. We need to enthuse and involve citizens, including young people, in generating ideas and support for green policies, plans and action. We can lead the way as a Green City.

Portsmouth City council will ask the Cabinet to:

1. Declare a ‘Climate Emergency’ then ask partners to sign up including local business, schools and community groups.

2. Pledge to achieve net zero carbon emissions in the Portsmouth by 2030, considering, both production and consumption of emissions according to the Standard provided by the Greenhouse Gas (GHG) Protocol.

3. Require the Leader of the Council to report back to the Council within six months with an action plan, detailing how the Council will work with partners across the City and with central government to ensure that Portsmouth’s net carbon emissions (Scope 1, Scope 2 and Scope 3 emissions as defined by the GHG Protocol) are reduced to zero by 2030.

4. Provide an annual report on Portsmouth GHG emissions, what is working and what is more challenging and progress towards achieving net zero-carbon emissions.

5. Require the Chief Executive to establish a ‘Portsmouth Climate Change Board’ before the end of July 2019, equivalent to that of Manchester, to underpin our efforts to decarbonise Portsmouth.

6. Write to the government requesting (a) additional powers and funding to make the 2030 target possible and (b) that ministers work with local government and other governments to ensure that the UK maximizes carbon reduction by 2030 in line with the overriding need to limit global warming to a maximum of 1.5°C.

7.  Develop and implement a community engagement plan to i) fully inform residents about the need for urgent action on climate change ii) offer a vision of a healthier, more child friendly and greener city that is a model of best practice iii) mobilise residents in the delivery of the action plan.

This motion covers “scopes 1, 2 and 3” for Portsmouth, which basically covers all greenhouse gas (GHG) emissions within the city (including transport), GHG from grid supplied energy and GHG outside the city that are the result of activity in a city (“transmission and distribution losses associated with grid-supplied energy, and waste disposal and treatment outside the city boundary and transboundary transportation”). That is very comprehensive. We are looking at a complete decarbonization by 2030. It will take very ambitious measures to reach this goal – presumably including a fossil fuel vehicle ban, replacement of heating systems and local wind power generation. This in turn will require massive investment in public transport and electric vehicles, and make a CAZ look like a walk in the park!

Looking at the new air quality leaflet to be distributed to all homes in Portsmouth, there is quite a startling statement about how discussions with DEFRA are going:

However analysis shows the measures we are looking at won’t improve the situation as quickly as the government wants, but we’re continuing to work with them to try to find new solutions.

Basically Portsmouth City Council has been told to go “back to the drawing board”. PCC needs to take the issue seriously. From today’s Air Quality Steering Group meeting, they certainly are talking about adopting more radical steps. However, I spoke to Gerald Vernon-Jackson (head of the council) and he was strongly anti-Clean Air Zone. I don’t think this is appropriate since I doubt that the council will be able to identify any package of measures that are as effective as a CAZ (as they are required to do). Without analysis of the alternatives, it is far too early to rule out a CAZ. In fact, a CAZ on its own is unlikely to be sufficient. Any air quality measures will be an important stepping stone towards the zero carbon target. In turn, measures for reducing GHG are likely to help improve air quality.

We were on BBC South Today! Skip to 5.39 in see us outside of Portsmouth City Council protesting alongside Extinction Rebellion.

Letter from Portsmouth to Michael Gove

Letter outlining the situation and what needs funding.

Dear Michael,

I am writing to you about the ministerial directive on air quality which Portsmouth City Council has received.

My understanding is that we received this ministerial direction to produce a plan to improve air quality because of concerns in the Defra modelling about the air quality at the end of the motorway spur into Portsmouth (M275) and then further on the roads towards Unicorn Gate – an access point into the Naval dockyard

The city council has dramatically increased the number of air sampling points in the city and our initial reading were that the actual results at the end of the M275 were significantly lower than the modelling had suggested. we were though very concerned about an area not identified by Defra which is the Fratton Road/London Road central route the the middle of the island, that the city council’s monitoring here suggested that there was a problem with air pollution and we have been working to produce a plan to rectify this.

I am sorry to have to tell you that the readings that we now have for last year show significantly increased areas of air pollution around the city and we therefore need to look at a much wider and much more radical plan to reduce air pollution. There is the possibility that the readings this year may have been affected by atmospheric conditions but we don’t know and we need to plan. I am very concerned about the possibility of an imposition of a Clean Air Zone on Portsmouth and the increased cost this would load onto both the individual and onto businesses in Portsmouth. Portsmouth is a city with economic challenges and for both families and for businesses the extra cost of a Clean Air Zone could be hugely damaging.

I would therefore like to ask for your support in looking at alternative measures to be able to reduce air pollution and therefore remove the need for a Clean Air Zone. The areas I would ask for your help with may be expensive but I would hope that the government would look to fund these to be able to get the dramatic reduction in air pollution that the ministerial directive expects. I understand that the new burdens doctrine applies and therefore we should be looking to the government for funding.

A significant proportion of the air pollution comes from traffic and therefore we need to look at what we can do to significantly reduce this and give people an incentive to use non-car based travel. Some of the suggestions I have heard are as follows:-

1) A free bus pass for each resident of the city all day, every day, to encourage people onto buses and out of their cars.
2) The creation of a trolley bus system like that operatives in our twin city of Caen, as there seems to be a much higher usage of tram and trolley bus systems than of buses.
3) Investment to convert the taxi and private hire fleet operating within Portsmouth to an entirely electric fleet.
4) That Portsmouth receives the same level of government subsidy to encourage people to cycle that is received by the London boroughs/TFL.
5) We would like to look at a transfer station where lorries bringing loads into the city can drop off their loads which are then taken in by electric cabs.
6) The government is currently increasing the number of house completions it expects from Portsmouth from around the 430 houses/flats that we currently complete to around 830 per annum. This is clearly completely incompatible with having to significantly reduce air pollution and I would ask for Portsmouth to be relieved of any housing target so we do not make the air pollution situation any worse.
7) We also need to look at the effect that shipping has both in the commercial ferry port and in Portsmouth Naval Base on these air quality figures and to work with the ship owners on a strategy to reduce this level of pollution.
8) A car scrappage scheme targeted at families on the lowest incomes who often have the most pollution vehicles but the least money to replace them with something modern with low emissions.
9) We would also like to be able to run our own bus service and to have a local bus depot to reduce the pollution of buses having to drive into Portsmouth from Fareham.

We would be very happy to work with you to try to find way in which we can have a dramatic effect in reducing air pollution.

Yours sincerely

Councillor Gerald Vernon-Jackson CBE, Leader of the Council

I’m not sure the measures listed will actually solve the air quality problem but they will provide a means to get around the city by public transport, which is a good start.

Oh yes, the city council declared a climate emergency and to go zero carbon by 2030. This will have a huge impact on air quality.

Comparing the council’s list to Public Health England’s list of proven strategies shows only a … limited overlap.

PS My interview on BBC Radio Solent

Portsmouth calls on government to help with air crisis

Portsmouth city council has called on government to help with tackling air pollution crisis. They have asked for funds to bus travel:

We are asking for the cost of bus passes to be covered because we know that many people say they don’t use public transport due to the cost.

Cllr Vernon-JacksoN

Depending on how much funding is allocated, this is either the start of cheaper bus travel [UPDATE: this would be for everyone!] or a precursor to the council saying “DEFRA forced us to implement a clean air zone”.

The council are ignoring my calls for the draft air quality plans to be published. This is important for public accountability, particularly since the plans will have a large impact on people living and working in the city.

While subsiding public transport is not the most effective way to improve air quality (according to the PHE report), it is very good at addressing social inequalities caused by further restrictions on private car use. Bus subsidies are not enough on their own, so I expect further restrictions on private car use.

One point of concern is that the council mention £8 fee for entering a future clean air zone – perhaps that should be dependent on the type of fuel the car uses, and the age of the vehicle? Older diesels are quite bad for air quality.

In other news,

Air pollution kills 1.6 million more people a year globally than smoking, research suggests. In the UK, 64,000 deaths in 2015 have been linked to air pollution, including 17,000 fatal cases of heart and artery disease

WHO (Sky News, 12 March 2019)

This is doubling of the World Health Organization’s previous estimates. This underscores the need for firmer action is needed to tackle air pollution.

I’m going to the protest to support the climate emergency motion going through the council today. I hope it gets through without being watered down!

PS Two journalists mentioned that 16 sites are above the legal limit, rather than the 4 from last year. This looks like a significant worsening.

PPS I’ve just seen a new council leaflet in air pollution. “Improving traffic flows” is probably counter productive since it increases the road capacity, which in turn increases private car use. The leaflet says even with their planned measures, they won’t be doing it as fast as the government wants – or should I say as fast as the law requires (“as quickly as possible”). It seems like they are priming the public to expect a clean air zone. This could be good if they do it well and target the most polluting vehicles.

PPPS An electric charging point has appeared in a lamp post near my house! The scheme is called SimpleSocket and has a ubitricity logo.

Car charging area

#LetPompeyBreathe meets with Stephen Morgan MP

Together with representatives from Old Portsmouth and Milton neighbourhood forums, I raised concerns over Portsmouth City Council’s weak actions in tackling air pollution with our Portsmouth South MP Stephen Morgan. We described the city wide air pollution situation, as well as the secrecy and inconsistencies of PCC’s actions. One of the most troubling concerns is that PCC cannot give a straight answer to what traffic growth is expected in the next few years. If they say it is 5% per annum, their air quality plans are insufficient. If it is just 0.5%, there is no need for the city centre road scheme. Can PCC get its story straight?

Stephen Morgan seemed to take on the large quantity of information, and said it seems like a failure of governance at PCC, not just a capacity problem (caused by lack of resources). He said he would raise this in the house of commons as a question to the appropriate minister. He also expressed concern that the PCC planning department have been cut back so much as to only be able to be reactive to needs, not proactive.

He also mentioned that the full council is going to debate a motion to declare a climate emergency, if I understood him correctly. I will try to get confirmation.

Other useful documents/news:

What do ClientEarth’s legal cases mean for Feasibility Studies for nitrogen dioxide compliance in England – I suggest PCC memorizes this

Traffic bosses set to switch off traffic lights at major Portsmouth roundabout​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​ in bid to cut air pollution

Apparently, PCC’s Cough Cough Engine Off campaign posters were based on Tracey’s poster design (created for #LetPompeyBreathe)!

PS PCC where is your draft Air Quality Plan sent to DEFRA at the end of Jan 2019?

Quick News

The City Council leader recently stated “This Saturday [1st Decembter] is Small Business Saturday. We have many local small businesses and shops run by Portsmouth families and 1st December is all about celebrating how important they are to our communities and the city as a whole. To support the day, we’re making nearby council car parks free to use for the day! Please do consider going out to support your local high street.”

This is not helpful for air pollution or sustainable transport. The council needs to be encouraging public transport, cycling and walking rather than vehicles that cause congestion and pollution.

The next meeting of Portsmouth Extinction Rebellion is on 7th Jan. The group focuses on climate change and non-violent direct action. Background info to Extinction Rebellion: