“The Court of Appeal yesterday (September 12) upheld a planning permission refusal on air quality grounds for 330 homes in Kent, making it the first time a planning appeal has been refused due to concerns over air pollution and public health.” Air Quality News
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.
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.
ClientEarth has warned 100 local authorities their plans for air quality must be robust.
Lawyers from ClientEarth are putting 100 local authorities across England on notice, warning them that they will violate their legal obligations and risk legal challenge if they do not introduce proper climate change plans. The environmental lawyers are writing to each local authority that is currently developing a new local plan, giving them eight weeks to explain how they will set evidence-based carbon reduction targets and ensure these targets are then central to their new planning policy. Amid growing pressure for local governments to declare ‘climate emergencies’, ClientEarth launched the campaign in light of the massive shortfall in compliant local planning policy across the country and to advise authorities of their legal duties under planning and environmental law. ClientEarth climate lawyer Sam Hunter Jones said: “There is a collective failure by local authorities across England to plan adequately for climate change. Too often climate change is perceived to be just a national or international issue and therefore solely the responsibility of central government. “Clearly central government needs to do more, as the recent Committee on Climate Change (CCC) progress reports stress. Yet so many of the daily decisions around new and existing infrastructure – such as new buildings, roads and utilities – are made at the local level. All of these decisions will ‘lock in’ an area’s future emissions and its resilience to climate change.
This should be particularly concerning to Portsmouth City Council since they are ignoring High Court rulings by making statements such as:
In developing a solution to exceedances in nitrogen dioxide levels in the city there is a balance 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. It is considered that the proposed preferred approach strikes this balance.
The High Court rejected DEFRA’s argument that their plans were proportionate based on the balance of various priorities.
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.
The law already takes into account what is a reasonable action. With their current attitude, PCC risks people’s health and lives, not to mention wasting time and tax payer money in a potential legal battle.
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.
Part of Francis Avenue, Southsea, was closed for 3 hours to traffic on Sunday 21st July for children to play in their local area. This was organized by local mum Laura Mellor of Play Out Pompey. This follows recent roadworks to install speed tables which enabled children to use the usually busy street as a play space. This allowed friendships between local children to form, and then between neighbours who were more often at the front of their houses. After the roadworks were removed, local residents decided to try make the streets safe for play again. This is great for community relationships and a great example of what is possible if we claim space back from car usage. It also raises awareness of the air quality problem and some of the measures that can be used to tackle it. We need to make car usage less convenient and make our urban spaces more pleasant for pedestrians and cyclists.
Organizing such a road closure is quite an achievement and involves quite a bit of work. Permission was needed from Portsmouth City Council (PCC) to close the road. I understand Suzy Horton, Steve Pitt and the Active Travel Team were very helpful in overcoming bureaucratic challenges. Then every household on the Francis Avenue was asked for their opinion on the scheme, even though only a part of the road was to be closed. The vast majority of residents were supportive of the scheme. The diversions needed to be planned. Signs were borrowed from PCC. Contacting the residents found several other parents willing to help organize and steward on the day. About six stewards kept watch on the road and answered motorists questions as needed. A stewarding rota was organized so people could take a break. The organizers had to get public liability insurance to reduce their personal legal risk.
At the designated time, road closure signs and cones were positioned. Local residents who wanted to park in the closed section were escorted at walking speed to a parking space, which only occasionally happened. After about an hour, the road was full of children playing, often with parents. I thought about cycling through the area but it was simply too busy!
Not all residents were happy with the event. They were concern over congestion and possible car damage. Using nearby school playgrounds out of school time was suggested, but this is still not as local as playing outside your own house and making friends with neighbours.
The event was attended by the Mayor, and local councillors Suzy Horton, Darren Sanders and two PCSOs. Suzy said she was looking for an opportunity to do this kind of road closure for some time but felt it was best for an apolitical organizer to take the initiative. Play Out Pompey was the first such road closure and was a learning process for the council, as well as the organizers. There is a good chance the process will be streamlined for future events. Laura hopes to repeat the event some time soon. It might be good to do this kind of event as part of the annual clean air day, perhaps on a road that has not been previously closed.
Playing Out is a small charity that helps parents organize road closures for children’s play.
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.
Portsmouth needs a Clean Air Zone to tackle our air pollution problem because the City Council has been unable to propose an effective alternative. Councillor Vernon-Jackson claims that a charging Clean Air Zone (CAZ) will hit hardest the poorest families in Portsmouth. #LetPompeyBreathe argues that a CAZ will have greatest health benefit for the poorest in our city.
forget the harm caused by air pollution
In 2017 DEFRA explained that “Air pollution predominantly affects those living in our major towns and cities due to the concentration of vehicles and other sources of pollution. This continues to have an unnecessary and avoidable impact on people’s health, particularly amongst the elderly, people with pre-existing lung and heart conditions, the young, and those on lower incomes“
In March this year Public Health England reported “air pollution… is the largest environmental risk to the public’s health in the UK with estimates of between 28,000 and 36,000 deaths each year attributed to human-made air pollution.”
In Parliament on 1 May this year Secretary of State for the Environment Michael Gove stated “The environment belongs to us all” and Jeremy Corbyn pointed out that “Working-class communities suffer the worst effects of air pollution …. Children should not have to pay with their health for our failure to clean up our toxic air.” Baroness Jones of the Green Party has campaigned for clean air to be a human right saying “Air Pollution is a public health emergency responsible for hundreds of thousands of premature deaths” London Mayor Sadiq Khan has explained “Tackling toxic air pollution is about saving lives. Every year thousands of Londoners die prematurely, or contract horrific illnesses and diseases because of pollution. But it’s also a fundamental issue of social justice, because those who suffer most from toxic air are the poorest Londoners who have the fewest cars“.
PCC’s Air Quality Strategy refers to 95 deaths each year in Portsmouth attributable to air pollution. Alternatively, this can be expressed as “Air pollution from man-made particles is currently estimated to reduce average UK life expectancy (from birth) by six months“. This figure refers to the harm caused by solely one type of air pollutant, small particulates PM2.5 (such as emitted by diesel vehicles).
over 2 years ago, 72 people died in the Grenfell Tower tragedy. If
in Portsmouth we had 95 people dying every year in a tower block fire
there would be a national outcry. But our political leaders seem
strangely quiet on the appalling statistic of an estimated 95 people
dying in Portsmouth every
from just one type of air pollution. We would like Councillor
Vernon-Jackson to affirm that people’s health is his top priority.
Clean Air Zone will give most benefit to the poorest in Portsmouth
There is convincing evidence that a CAZ will benefit poorest families the most. The most recent national census in 2011 showed that the poorest families in Portsmouth endure the worst levels of air pollution, the lowest levels of car ownership and the highest levels of urban deprivation (employment, education, health & disability, and housing). Replacing polluting modes of travel with sustainable alternatives will improve air quality, which together with more active travel will greatly improve public health.
For example, Charles Dickens ward is on the border of the highly polluted Fratton Road and Kingston Road (AQMA6) and in this ward 63 per cent of households have no access to a car or van. People who already can’t afford a car aren’t in a position to ‘upgrade’ to an emissions-compliant vehicle. Instead, nearly two-thirds of these city centre residents have no option but to walk, wait for a bus or cycle in highly polluted streets, all the time breathing in the harmful traffic fumes produced by others. A charging CAZ is expected to provide a rapid reduction in air pollution. Everyone in Portsmouth will benefit from cleaner air but the health improvements will be greatest for those who can’t afford cars anyway.
Professor Paul Cosford, Director of Health Protection and Medical Director for Public Health England, believes that actions to reduce air pollution do not run counter to economic growth and development; rather, there is an opportunity for better air quality and economic prosperity to go hand in hand.
blame DEFRA for PCC’s lack of action to tackle air pollution
is likely to impose a CAZ in Portsmouth in order to achieve the legal
and moral imperatives of delivering clean air for everyone in the
shortest possible time. This bold measure is the consequence of
PCC’s long-term failure to take effective action. Many of the
measures planned by the Council in recent years have been too little,
too late, with little evidence of
their effectiveness before introduction
and with minimal effort to quantify the effectiveness once they have
been introduced. Measures are
seemingly designed more to create a smokescreen of activity instead
of focusing on the necessary measurements of the effectiveness of
actions to deliver clean air to benefit everyone in our city. The
levels of NO2 around the city have been approximately constant for
the last 6 years despite directives since 2010
requiring swift action. The Council should not try to blame central
government for the need for a CAZ when many of the causes are the
Council’s ineffective actions.
needs to change
We need our
political leaders in all parties to admit that previous measures by
both administrations to reduce air pollution have been inadequate.
Our councillors must
demonstrate leadership in championing the radical measures needed to
deliver clean air.
Councillors need to
show courage in giving people the stark truth that we must end the
car-centric priority in our city and scrap the assumption that in
our congested city there is a need to plan for increased capacity
for private car travel.
become a place where it is more attractive not
to use a car and people prefer to use public transport or active
There is a great opportunity for Portsmouth to attain cleaner air, better public health and boost economic prosperity, but only if our councillors and senior council officers have vision and give leadership.
A CAZ will provide the necessary impetus to accelerate the long-overdue improvements to the active travel network to provide safe, convenient and attractive walking and cycling routes, and to deliver greater investment in reliable, clean and cheap public transport.
Businesses may need support to introduce sustainable transport options.
My first impression is that sites with long term readings are about the same as 2017, for example London Road remains about the same. Known problem areas of Queens Road, St Michael’s gyratory and the bottom of M275 are back out of compliance. However, the expanding monitoring introduced recently have picked up several new locations that are out of compliance (above 40ug/m3). This includes Albert Road, Market Way (behind Cascades) and Fratton Bridge. The busy road by the Catholic Cathedral has a very high NO2 level of 50ug/m3. Areas barely within compliance including the top of Milton Market, the junction at the bottom of Velder Avenue, Cosham (Northern Road & Tudor Crescent) and Port Solent.
Earlier this year Portsmouth City Council announced we need to join the fight for cleaner air as early indications showed air pollution was getting worse. Like other cities across the UK, Central Government also requires that improvements are made to air quality in Portsmouth the shortest possible time.
Your views on a charging clean air zone for Portsea Island are really important. They will inform part of our strategy that has to consider all the options for reducing air pollution and any future consultation we may need to carry out.
The survey takes around 10 minutes to complete and is open until 5:00pm on Thursday 4 July 2019. Thank you in advance for your feedback.