CAMPAIGN RESPONSE: 28 January 2010

The Rt. Hon. Hilary Benn MP
Secretary of State
Department for Environment Food and Rural Affairs
Nobel House
17 Smith Square
London SW1P 3JR

By email: hilary.benn@defra.gsi.gov.uk and euairquality@defra.gsi.gov.uk


28 January 2010


Dear Secretary of State

Secretary of State warned of need to take action after hourly limit value for NO2 breached today

Response to consultation on draft Air Quality Standards Regulations 2010 and Impact Assessment

Secretary of State reminded he would be in breach of statutory duties if Mayor of London removes WEZ without full and simultaneous offset of air quality impacts

I am writing on behalf of the cross-party Campaign for Clean Air in London (CCAL) to respond to the consultation on the transposition of Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and cleaner air for Europe (the Directive) which closes on 29 January 2010. Thank you for the opportunity to do so.

CCAL understands the Department for Environment Food and Rural Affairs (Defra) intends to transpose the new Directive into English law under the draft Air Quality Standards Regulations 2010 (draft AQSR 2010). The consultation documents can be seen at:

http://www.defra.gov.uk/corporate/consult/airquality-transposition/index.htm

Details of CCAL’s Mission and a list of its supporters can be found at www.cleanairinlondon.org.

CCAL supports strongly all the comments made by the ClientEarth and Environmental Protection UK in their responses to this consultation (except if in conflict with this letter in which case this letter prevails).

Summary

The current consultation takes place against a background of legal action and public concern over the UK’s failure to comply with air pollution deadlines it has known about since 1999. Awareness of the scale of the public health crisis is also spreading rapidly.

As you know, the European Commission launched legal action against the UK in January last year for breaching limit values for dangerous airborne particles (PM10) that entered into force in January 2005. On 11 December 2009, the European Commission rejected the UK’s application for a time extension until 11 June 2011 to comply with these obligations in London. London is the only place in the UK still in breach of the daily limit value for PM10. The government has said it wishes to reapply for a time extension. However, when doing so, the government will need to address a consequence of it changing the monitoring of PM10 (which reduced the number of reported daily exceedances in Marylebone Road last year from 110 to 39 days i.e. just over the legal limit of 35) i.e. that widespread areas of the south east UK are likely to breach the daily limit value during warm years (such as 2003 or 2006). Please see the excellent presentation given by David Green of King’s College London in December 2009 which explains this important change:

http://www.cleanairinlondon.org/_attachments/4426048/CCAL%20080%20D%20Green%20at%20RSC%20December%202009.pdf

Limit values for annual mean and hourly concentrations of nitrogen dioxide (NO2) entered into force on 1 January 2010 to protect public health further. With London having the highest mean concentrations of NO2 of any capital city in western, or eastern, Europe, it is shocking but not surprising that London breached - in less than two weeks - the hourly limit value of 18 exceedances in a whole year (in Kensington and Chelsea, Lambeth and Wandsworth). The government’s main monitoring site for London, in Marylebone Road, breached that limit value today for the first time by reporting 25 exceedances in the year to date (after 18 yesterday for the year to date). See:

http://www.londonair.org.uk/london/asp/publicstats.asp?statyear=2010&mapview=NO2b®ion=0&site=MY1&postcode=&la_id=&objective=All

CCAL hereby formally brings the breach of the hourly limit value for NO2 in London to your attention, as the responsible Secretary of State, and requests and requires that you take urgent action as you are required to do to ensure full compliance with this standard. These standards have the same legal force as those for PM10 that you are also required to meet this year.

The primary purpose of this letter is to respond formally to Defra’s consultation on the draft AQSR 2010 and associated Impact Assessment. CCAL has a number of detailed comments on these documents which are set out in later in this letter. However, CCAL’s general impression is that the draft AQSR 2010 have been faithfully transposed except in the most important areas where the government has failed to transpose the most essential elements and/or weakened the wording to make it ambiguous e.g. which pollutants are covered, what standards must be met, where they apply, when they must be met and what happens if a time extension is obtained. Furthermore, the draft AQSR 2010 omit completely the need for penalties that are ‘effective, proportionate and dissuasive’ if the Secretary of State fails to comply fully with his obligations. The Impact Assessment quantifies the risks of long term exposure to particulate air pollution represented by PM2.5 but then fails to accept advice from its own scientific advisory body to include in any such report a wider interval up to 15% (i.e. relative risk 1.15).

In CCAL’s view, these are serious and unacceptable failings which must be addressed before the AQSR 2010 are finalised. The proposed transposition of the Directive into the draft AQSR 2010 does not yet meet the minimum requirements of the Directive.

In CCAL’s considered view, Defra’s assessment of the impacts of transposing the Directive, as set out in the consultation Impact Assessment, is not thoroughly considered. CCAL has therefore provided you with additional information that it thinks must be considered i.e. herein and CCAL’s letter to the Environmental Audit Committee dated 13 December 2009 (attached) (which forms part of this submission).

CCAL wishes separately to bring to your attention that the Mayor of London would put the Secretary of State in breach of his statutory duty (to ensure that the daily limit value for PM10 is not exceeded having been attained in west London) if the Mayor removes the Western Extension of the Congestion Charging Zone (WEZ) without offsetting fully adverse air quality impacts. CCAL’s analysis shows the position very clearly and confirms the situation beyond reasonable doubt.

With the government and the Mayor failing in so many ways to comply with their duties to improve air quality, CCAL hereby requests and requires the government comply immediately and in full with its obligations to protect public health.   more »

CAMPAIGN RESPONSE: 22 February 2009

Consultation on the draft UK notification to the European Commission to secure additional time to meet the limit values for particulate matter for certain zones/agglomerations in accordance with the Council Directive 2008/50/EC on ambient air quality and cleaner air for Europe

UK fails to satisfy in London any of the three conditions for a time extension to comply with legal standards for dangerous airborne particles (PM10)

European Commission should ‘throw the rule book’ at the UK, and reject its application, unless the UK submits a wholly convincing plan to improve air quality in London

London needs one or more additional inner low emission zones implemented by early 2010 backed by a fully funded government ‘green deal’

The purpose of this letter is to respond on behalf of the Campaign for Clean Air in London (CCAL) to the consultation (the Consultation) being carried out by the Department for Environment, Food and Rural Affairs (Defra) on the draft United Kingdom (UK) notification to the European Commission (the Commission) to secure additional time to meet the limit values for particulate matter (PM10) for certain zones/agglomerations in accordance with the Council Directive 2008/50/EC on ambient air quality and cleaner air for Europe (the new AQ Directive). The consultation documents can be found at:

http://www.defra.gov.uk/corporate/consult/air-quality/index.htm

This letter is addressed jointly to the Secretary of State for Transport because CCAL understands that the Department for Transport (DfT) has joint responsibility with Defra for the UK meeting its legal obligations in respect of air quality.

The Prime Minister has been copied, given the cross-departmental issues raised, and all London’s MEPs and others have been copied given that the Commission has already started legal action against the UK for failing to notify a time extension by the deadline set by the Commission of 31 October 2008.

As you know, only the UK, Cyprus, Estonia, Portugal, Slovenia and Sweden out of some 24 countries have failed so far to submit any time extension notification plans to the Commission.

Summary

In CCAL’s carefully considered view, the UK does not satisfy either of the pre-conditions for it to obtain a time extension to comply with limit values for PM10.

In particular, the UK fails to pass either the ‘First condition’ – measures to achieve compliance by the initial attainment date; or the ‘Specific condition for PM10’ – site-specific dispersion characteristics, adverse climatic conditions or transboundary contributions. Both of these pre-conditions must be met if the UK is to obtain a time extension to comply with limit values for PM10.

CCAL would need to be completely wrong on every point made in this letter in connection with the above pre-conditions if the UK is to be eligible for a time extension to comply with limit values for PM10. This seems highly unlikely given that the questions are ones of fact.

Furthermore the UK has made no reasonable effort yet to satisfy the ‘Second condition’ – measures to achieve compliance before the new deadline. It has not been helped in this regard by: its reliance on measures that the Mayor of London says he plans to scrap or suspend; its vague words about committing to work with the Mayor of London; and/or its obvious non-compliance over at least part of the London road network even by 2011 (i.e. six kilometres or is it 12 kilometres with modeling errors?).

CCAL will therefore urge the Commission to ‘throw the rule book’ at the UK and reject its time extension notification (TEN) for failing to meet the conditions necessary for such a time extension unless the UK submits a wholly convincing and timely plan by the deadline set by the first written warning (i.e. Letter of Formal Notice). To be wholly convincing, such a plan must be backed by all necessary funding and immediate action to ensure that limit values for PM10 will be complied with sustainably throughout London by no later than 11 June 2011.

CCAL will urge the Commission to progress vigorously legal action, in parallel with any consideration of a belated TEN from the UK, against the UK and the five other Member States that failed to submit a TEN by the Commission’s deadline of 31 October 2008. These countries are clearly in need of ‘encouragement’. Otherwise, what incentive would there be in future for any country to comply within the first six months of a deadline set by the Commission? CCAL understands that the fines against the UK could total £300 million just in respect of PM10. The Commission is not on some ‘frolic’: all the fault sits at the government’s feet after more than 10 years of inaction and disregard for deadlines and/or repeated warnings.

CCAL urges the government to learn now from its serious failings to comply with limit values for PM10 – including the current difficulties it faces in applying for a time extension – and to propose and implement rapidly plans to comply fully with limit values for NO2 by January 2010.

In CCAL’s carefully considered view, the UK is likely currently to miss - by a large margin - not just the limit values for NO2 due to be met since 1999 by January 2010 but also the limit value plus margin of tolerance which must not be exceeded if the time extension provisions are to be used. CCAL considers currently therefore that the UK should not waste everyone’s time by submitting a TEN on NO2 – it should instead focus all its energies on complying urgently with the limit values for NO2 (as it will need to do when legal action is surely launched against it). The UK needs a convincing action plan for NO2 now.

Finally, the UK seems to be one of the least compliant countries and worst ‘free-riders’ in the whole of Europe when it comes to complying with air pollution legislation. We need urgent and energetic cross-departmental action, lead personally by the Prime Minister, if sustainability issues are to be addressed holistically.   more »

CAMPAIGN RESPONSE: 25 October 2008

Consultation responses required by 28 October 2008

The Rt. Hon. Hilary Benn MP
Secretary of State
Department for Environment, Food and Rural Affairs
Nobel House
17 Smith Square
London SW1P 3JR

The Rt. Hon. Geoff Hoon MP
Secretary of State
Department for Transport
Great Minster House
76 Marsham Street
London SW1P 4DR

By email to: euairquality@defra.gsi.gov.uk

25 October 2008

Dear Secretaries of State for Defra and DfT (and Defra consultation team),

Consultation on UK report regarding plans and programmes to meet EU air quality limit values for nitrogen dioxide (NO2) (reporting year 2006)

Government is making no meaningful effort to comply with limit values for NO2 by January 2010 and has no date planned for eventual compliance

Government has no contingency plans to address time extension obligations that will arise under the new Air Quality Directive if it breaches limit values for NO2 in 2010. For example, airports are not mentioned in the whole draft report

Government is seeking to comply ‘selectively’ with reporting timetables

The purpose of this letter is to respond on behalf of the Campaign for Clean Air in London (CCAL) to the consultation being carried out by the Department for Environment, Food and Rural Affairs (Defra) on the United Kingdom (UK) and Devolved Administrations’ draft report on plans and programmes to meet European Union (EU) ambient air quality limit values (limit values) for nitrogen dioxide (NO2). The consultation documents can be found at:

http://www.defra.gov.uk/corporate/consult/air-limitvalues2006/index.htm

The letter is addressed jointly to the Secretary of State for Transport because CCAL understands that the Department for Transport (DfT) has joint responsibility for the UK meeting its legal obligations in respect of air quality.

The Prime Minister has been copied, given the cross-departmental issues raised and all London’s MEPs and others have been copied given the imminence of the related deadline of 31 October 2008 for notifying requests to the European Commission (the Commission) for time extensions to meet the corresponding limit values for PM10.

Summary

The Campaign for Clean Air in London notes the obligation under EU legislation referred to in the consultation document for the government to produce plans and programmes to ensure compliance with the limit values “within the required timescale”. CCAL considers the last few words unnecessarily vague since the obligations must be met by January 2010 (under 1999 legislation) or January 2015 (if the UK is granted a conditional time extension under the new EU Directive on ambient air quality and cleaner air for Europe (the new AQ Directive) that entered into force on 11 June 2008).

CCAL has three main concerns with the draft report which is the subject of this consultation. First, it does not show or refer to any expected date by which the UK will ensure compliance with either of the limit values for NO2. Second, the plans and programmes currently proposed together are clearly insufficient to achieve the limit values for NO2 or indeed to make any reasonable effort to do so by the required date of January 2010 (or January 2015). Third, the report includes no contingency plans to comply with the time extension obligations for NO2 under the new legal regime if the UK fails to meet the limit values for NO2 by January 2010 (as currently seems likely) e.g. Article 22 paragraph 3 and/or the January 2015 deadline. CCAL is disappointed that the first two points have not been addressed in the current report when it raised them in the identical consultation some 12 months ago.

In CCAL’s view, the report does not meet the requirements of Annex IV of the relevant EU Directive. CCAL is therefore copying this letter to Commissioner Dimas and urging him please to reject the UK’s report and to commence necessary enforcement action against the UK for failing to meet its reporting requirements - unless these points are addressed fully in the submission as required by 31 December 2008.

In CCAL’s view, the Commission could commence legal action against the UK for breaching limit values for NO2 as soon as there is sufficient evidence that breaches of the hourly limit value have occurred. Results from 2008 indicate that this could happen as early as 31 January 2010.   more »

CAMPAIGN RESPONSE: 18 October 2008

Boris Johnson
Mayor of London and Chair of Transport for London
Transport for London
12th Floor Windsor House
42-50 Victoria Street
London SW1H 0TL

Taxi and PHV Licensing Inspection Consultation
Public Carriage Office (PCO)
15 Penton Street
Islington
London N1 9PU

By email: PCO.Consultation@tfl.gov.uk and mayor@london.gov.uk

18 October 2008

Dear Mayor Johnson and the PCO,

Consultation on Taxi and Private Hire Vehicle Licensing Inspections

‘Encourage’ taxi drivers to reduce harmful emissions from Taxis and PHVs

This response to Transport for London’s (TfL’s) public Consultation on Future Arrangements for Taxi and Private Hire Vehicle (PHV) Licensing Inspections, which is due to close on 24 October 2008, is sent on behalf of the Campaign for Clean Air in London (CCAL). Refer to:

http://www.tfl.gov.uk/businessandpartners/taxisandprivatehire/8832.aspx

Taxis are the most polluting form of road traffic in Central London

According to the London Atmospheric Emissions Inventory 2003 (LAEI), taxis are forecast to contribute some 36.5% of particulate matter (PM10) and 24.6% of nitrogen oxides (NOx) from road traffic in Central London in 2010. See pages 78 and 79 of the relevant report:

http://www.london.gov.uk/mayor/environment/air_quality/docs/laei_2003.pdf

Page 4 of the same report makes clear that road traffic is forecast to be the major source of NOx (36%) and PM10 (65%) emissions in the LAEI area in 2010. This means that taxis are the most polluting sub-category of the most polluting emissions category in London.

The consultation document states that only 62% of vehicles passed first time the taxi mid-year inspections in the first six months since their introduction in October 2007. Vehicles failed for a variety of reasons, primarily due to emissions test and vehicle suspension systems, with a wide variety of other causes. CCAL understands that 2,389 taxis failed pollution tests and 513 had brake problems in the past year.

This means that taxis have been contributing unnecessarily to pollution levels in London.

CCAL considers therefore that the proposal to abolish or weaken the current regime of taxi mid-year inspections cannot be justified on the basis of the facts or proposals presented by TfL. CCAL urges Mayor Johnson and the PCO instead to strengthen, rather than weaken, emission control measures for London’s Taxis and PHVs.

The Mayor has a duty to ‘work towards’ Limit Values

The Mayor of London has a statutory duty to ‘work towards’ the Limit Values for particulate matter (PM10) and nitrogen dioxide (NO2). In CCAL’s view, Mayor Johnson would breach this statutory duty if taxi mid-year inspections were removed without fully, directly and robust offsetting measures being in full operation. CCAL notes that no such measures are currently proposed.

Principles to adopt in reducing pollution from Taxis and PHVs

CCAL considers that the following principles should be considered as a package as Mayor Johnson and the PCO consider how best to deliver a sharp reduction in harmful emissions from Taxis and PHVs.

1. Taxis and PHVs provide a vital service: Please take full account of the importance of the public service provided by Taxis and PHVs.

2. The polluter must pay: The polluter must pay the full environmental cost of his/her actions. In this case, the polluter is the user of the service i.e. the passenger. Please raise fares therefore to cover the cost of necessary action to reduce sharply harmful emissions from Taxis and PHVs. CCAL would support fare rises to compensate fully operators for the ‘opportunity cost’ of a Taxi or PHV being off the road for testing.

3. Euro IV or better: Taxis should be required to meet no less than Euro IV engine emissions standards for particulate matter and NOx by the earliest possible time. Euro IV engine emission standards are, in general, half as polluting as the current Euro III engine emission standards. CCAL encourages the government (copied) to offer massive incentives to accelerate the adoption, at least, of such standards by 2010. Low emission taxis would presumably exceed such standards.

4. PHVs must meet or exceed Taxi emission standards in the most polluted areas: All PHVs carrying fare paying passengers in the most polluted parts of London should be required at least to match the highest emissions standards applying to Taxis e.g. currently Euro III or better. This could be implemented through the use of colour-coded stickers with one colour allowing say London-wide access for PHVs and another prohibiting the most polluting PHVs from the most polluted parts of London. CCAL would support measures to ban older diesel-engined PHV’s from the most polluted parts of Central London.

5. Apply Taxi testing standards to PHVs: PHVs should be subject to mid-year, full year and spot check inspections in the same way that Taxis are. These should replace MOT only inspections. They should be set at the ‘higher emissions standards’ applicable to either.

6. Effective enforcement is essential: Effective enforcement must play an important part in regulating Taxis and PHV. In CCAL’s view, TfL’s facts show that taxi mid-year inspections are currently essential. If first time pass rates for taxi mid-year, full year and spot check inspections indicate in future that there is a very high level of day to day compliance with emission standards (say 90-95%), CCAL would support then a trial of reverting to annual inspections.

7. Systemic solutions: Such a low first time pass rate indicates that there is likely to be a systemic problem with compliance with emissions standards. What is the cause of this serious problem and what will be done about it and when? With Taxi and PHV drivers amongst the most exposed to harmful air pollution, the majority of them should welcome (at least in private) tighter emission standards paid for (rightly) by their passengers. A systemic problem must be addressed through systemic action.

8. Taxi Emissions Strategy: It is essential that an ambitious new Taxi Emissions Strategy is put in place within weeks to succeed that which expired on 30 June 2008.

http://www.london.gov.uk/mayor/environment/air_quality/mayor/taxi_emissions.jsp

In CCAL’s view it is essential that measures are included within this Strategy that take account fully of the need to comply with air quality laws. Such a Strategy should address fully all the principles outlined above.

Response to Consultation Options

These responses must be considered in conjunction with the rest of this submission.

In respect of the current, narrow, consultation Options, CCAL has the following responses.

Option 1 Oppose.

By TfL’s own admission this Option could result in ‘higher levels of pollution’ [from the most polluting form of road traffic in the most polluted areas] with no effective offsetting mechanism(s) proposed.

Option 2 Oppose.

The positive and negative incentives proposed would not necessarily ensure that ‘vehicles are well maintained at all times’ as TfL suggests. Rather they may simply encourage unofficial checks immediately before formal testing!

Option 3 Oppose.

As TfL states, ‘vehicle age is not necessarily an indicator of the standard of maintenance or state of repair’.

None of the above Options seems likely to achieve the third of the main aims of the consultation i.e. ‘To simplify arrangements and reduce the administrative burden on owners without compromising safety standards or reducing the overall condition of licensed vehicles throughout the annual licensing cycle’.

CCAL considers that the consultation is biased towards removing mid-year inspections since all Options put forward would represent a weakening of the current regime and none would tighten the existing regime as seems needed.

CCAL considers that TfL’s consultation is set too narrowly to consider just the need to ‘allow TfL to cover its costs and safeguard London’s travelling public’. What about the health of hundreds of thousands of Londoners who are exposed to levels of air pollution that are well in excess of the maximum levels recommended by the World Health Organisation?

CCAL is concerned that Mayor Johnson does not seem to appreciate yet the scale and urgency of the action he needs to take if air quality laws are to be complied with in London. CCAL would be pleased therefore to meet Mayor Johnson and/or his advisers to discuss these proposals as proposed in his letter dated 31 July 2008.

Please confirm receipt of this letter.

With best wishes.

Yours sincerely


Simon Birkett

Principal Contact
Campaign for Clean Air in London

By hand: Winston Fletcher, Chair, The Knightsbridge Association
Carol Seymour-Newton, Honorary Secretary, The Knightsbridge Association

Cc:
The Rt. Hon. Hilary Benn MP, Secretary of State for Environment, Food and Rural Affairs
The Rt. Geoff Hoon MP, Secretary of State for Transport
Lord Hunt, Minister for Air Quality
Sir Simon Milton, Deputy Mayor
ORGANISATIONS
Helen Ainsworth, EU and International Air Quality, Defra
Jenny Bates, London Regional Campaigns Co-ordinator, Friends of the Earth
Patricia Brown, Chief Executive, Central London Partnership
Simon Davies, Department for Transport
Nick Fairholm, Transport for London
Tim Hockney, Executive Director, London First
Professor Frank Kelly, Kings College London
Sarah Legge, GLA Principal Policy Adviser – Air Quality
Blake Ludwig, Campaign Director, Alliance Against Urban 4x4s
Professor Bob Maynard, Health Protection Agency
Philip Mulligan, Chief Executive, Environmental Protection UK
Derek Picot, Chairman, The Knightsbridge Business Group
Dragomira Raeva, EU Policy Unit, European Environmental Bureau
Dr Martin Williams, Head of Air Quality and Industrial Pollution Programme, Defra
Tim Williamson, National Air Quality Assessment, Defra
LEADING POLITICIANS
John Bowis MEP, Conservative
Jean Lambert MEP, Green
Baroness Ludford MEP, Liberal Democrat
Claude Moraes MEP, Labour
Richard Barnes AM, Statutory Deputy Mayor and Leader of the Conservative Group
Len Duvall AM, Leader of the Labour Group, London Assembly
Darren Johnson AM, Green, Chair of the Transport and Environment Committee
Mike Tuffrey AM, Leader of the Liberal Democrat Group, London Assembly
Valerie Shawcross AM, Chair of the Transport Committee, London Assembly
Councillor Colin Barrow, Leader of the Council, City of Westminster
Councillor Merrick Cockell, Leader of Kensington and Chelsea Council   more »

CAMPAIGN RESPONSE: 27 September 2008

Councillor Robert Davis DL
Deputy Leader of Westminster City Council
Cabinet Member for Built Environment
City of Westminster
P.O. Box 240
Westminster City Hall
64 Victoria Street
London SW1E 6QP

For the attention of Nina Miles 27 September 2008

By email to: airqualitystrategy@westminster.gov.uk

Dear Councillor Davis and Nina Miles

Developing a new Air Quality Strategy and Action Plan

The strategy needs a clear vision – backed by measurable objectives - and must recognise the urgency and major work needed for London to comply, belatedly, with air quality laws

This response to the City of Westminster’s (WCC’s) consultation on ‘Developing a new Air Quality Strategy (AQS) and Action Plan’, which closes on 30 September 2008, is sent on behalf of the Campaign for Clean Air in London (CCAL).

http://www.westminster.gov.uk/environment/pollution/airpollution/strategy.cfm

This response follows an excellent meeting of the Westminster Amenity Society Forum (WASF) earlier this week, at which CCAL thanked WCC, and Nina Miles in particular, for the excellent work done to date in preparing this initial consultation document.

CCAL is supported by all amenity societies that are members of WASF any of whom may wish to make separate additional submissions to WCC on the AQS.

The Campaign for Clean Air in London

CCAL has only one aim which is to achieve urgently and sustainably at least World Health Organisation (WHO) recommended standards of air quality throughout London. Our immediate priority is to ensure that air quality laws, based on WHO recommendations for particulate matter (so called PM10) and nitrogen dioxide (NO2), established by the new European Union directive on ambient air quality and cleaner air for Europe (the AQ Directive) are rigorously enforced in each of the next four years leading up to the London 2012 Olympic and Paralympic Games.

CCAL has received support from Mayor Johnson, leading politicians from the four main political parties in London as well as leading business and community groups including the Central London Partnership, London First and The Knightsbridge Business Group. We have also received a pledge of support from Environmental Protection UK (formerly the National Society for Clean Air and Environmental Protection).

Comments on the draft AQS

CCAL’s key comments are:

1. Air quality is the top environmental concern for WCC’s residents: CCAL was not surprised to see on page 7 that the highest number (35%) of respondents to a recent survey undertaken by WCC to determine residents’ attitudes to noise, found that poor air quality topped the list of problems that personally affected them. Furthermore, those residents who said they are affected by four or more environmental problems, when asked which three problems they are most affected by, cited rubbish and litter (46%), dog fouling (40%) and poor air quality (39%). This highlights the importance that WCC should attach to improving air quality in Westminster.

2. The AQS needs a vision and a sense of urgency: CCAL’s most important comment is that the AQS needs a clear vision – backed by timescales, measurable objectives and appropriate resources – that recognises the urgency and major work needed for London to comply belatedly with air quality laws. For example, the vision could be “To achieve urgently and sustainably at least World Health Organisation recommended standards of air quality throughout Westminster through direct measures and the lobbying of others”. At a minimum, WCC should commit to use its best efforts to implement successfully actions to improve air quality in Westminster, when it exceeds Limit Values, which are meaningful when judged in the context of all its available powers and the deadlines applicable under UK and European law.

In this context, CCAL applauds WCC’s aim to re-establish Westminster as an exemplar ‘green’ authority. However, the strategy says nothing about what achievements this will require or within what timescale. Please set clear milestones in the AQS. It is possible that WCC has fallen from its position as an exemplar ‘green’ authority by not setting and achieving such milestones in the past.

3. WCC should match resources to the top concern of its residents: CCAL believes that WCC may only have only one full-time person allocated to air quality matters, compared to many people and much money, say, for noise matters. CCAL urges WCC to prioritise air quality more appropriately and allocate sufficient resources to the issue of most concern to residents. Not least, air quality laws will continue to be broken in Westminster unless WCC plays a leading role in the successful implementation of suitable measures.

4. Air pollution near Westminster’s busiest roads must be reduced by over one-third in 15 months to comply with air quality laws: The AQS should take account of the need under Article 22 (paragraph 3) of the AQ Directive for the UK to ensure that the Limit Value plus a Margin of Tolerance are not exceeded if the time extension provisions are used i.e. average annual levels of particulate matter (PM10) must not exceed 40 micrograms per cubic metre (ug/m3) (if no time extension is granted) or 48 ug/m3 (if it is). Similarly for nitrogen dioxide (NO2), average annual levels of NO2 must not exceed – from January 2010 - 40 ug/m3 (if no time extension is granted) or 60 ug/m3 (if it is). Both are important but Figure 2.1 on page 9 shows the many places (all roads) where NO2 is forecast to exceed 60 ug/m3 still in 2010 – this will be illegal since air quality laws allow no derogations for such breaches.

5. ‘The London Principle’: Please apply ‘The London Principle’ (or perhaps ‘The Air Pollution Trade-off Principle’) when assessing climate change and air quality trade-offs (e.g. when considering the graph on page 40). Tackling air pollution holistically requires difficult trade-off decisions between air quality and climate change issues. CCAL encourages policy makers, like WCC, to accept a disbenefit of say 5% in climate change terms provided there is an associated benefit of say 50% in air quality terms (and vice versa) i.e. one to 10. Such an approach should be considered acceptable since large benefits may be hard to find and small disbenefits can be rectified relatively easily through a combination of other policy measures. An example of the former would be slightly increased fuel consumption and emissions of carbon dioxide while an example of the latter would be sharply reduced hazardous emissions.

6. One or more additional, inner, Low Emission Zones are needed: CCAL urges WCC to lobby vigorously for the adoption by early 2010 of one or more additional, inner, low emission zones to reduce sharply air pollution in Westminster since this is likely to be the most cost effective means of complying with air quality laws (as dozens of other cities in Europe have decided). CCAL urges WCC also to adopt measures set out in its letter to the Mayor of London dated 13 July 2008 (on which WCC was copied). That letter is attached to and forms part of this submission. It recommends, for example, the removal of free parking at weekends in central London, since such concessions contribute to heavy congestion at weekends, and the charging of motorcycles (since they are estimated to contribute 18% to PM10 road traffic emissions i.e. just more than cars).

7. Create a ‘tipping point’ of behavioural change: CCAL urges WCC to create a ‘tipping point’ of behavioural change in Westminster that will result in people taking steps to reduce sharply their hazardous emissions. For example, many Councils with serious air quality problems are introducing emissions related parking charges. In CCAL’s view, these should target particularly older diesel vehicles since these are the most polluting vehicles in cities. The omission of such parking measures from the AQS is very surprising.

8. Don’t be a ‘busy fool’: Finally, CCAL urges WCC to quantify the expected impact and cost effectiveness of the measures it is considering to improve air quality in Westminster (not least in relative terms) to ensure that WCC will play its full part in the UK complying fully with air quality laws. Please prioritise the most cost effective measures, which will most likely require behavioural change, even if that requires bold political leadership from WCC. A lack of such work, or a lack of political will, would probably cause WCC to be a ‘busy fool’ in respect of air quality i.e. many inputs but few, if any, worthwhile outputs.

CCAL would be pleased to discuss this response with you or your colleagues.

With best wishes.

Yours sincerely

Simon Birkett
Principal Contact
Campaign for Clean Air in London   more »

CAMPAIGN RESPONSE: 27 September 2008

Boris Johnson
Mayor of London and Chair of Transport for London
Transport for London
Western Extension Consultation
12th Floor Windsor House
42-50 Victoria Street
London SW1H 0TL

Congestion Charging
Western Extension Consultation
Chiswick Gate
598 – 608 Chiswick High Road
London W4 5RT

By email: westernextension@tfl.gov.uk and mayor@london.gov.uk

Dear Mayor Johnson,

Consultation on the future of the Congestion Charge Western Extension (CCWE)

Keep the Congestion Charge Western Extension or an even tougher, additional, inner Low Emission Zone will be needed by early 2010

This response to Transport for London’s (TfL’s) public consultation on the future of the Congestion Charge Western Extension (CCWE), which is due to close on 5 October 2008, is sent on behalf of the Campaign for Clean Air in London (CCAL). See:

http://www.tfl.gov.uk/tfl/roadusers/congestioncharging/westernextension/default.aspx

In your letter to CCAL, dated 31 July 2008, you requested that CCAL submit a formal response to this consultation in September.

Summary

Government maps, recently published by CCAL, highlight yet again, that road transport is the biggest single cause of all breaches of air quality laws across London. The solutions needed involve two overlapping ‘circles’ of measures – one for congestion (since vehicles are about half as polluting once they reach speeds of 30 kilometres per hour) and the other for emissions (such as low emission zones) – that target the most polluting vehicles in the most polluted areas.

CCAL urges the Mayor of London (the Mayor) to keep the CCWE primarily on the grounds that traffic levels would rise significantly without it, leading to increased pollutants from vehicles. In CCAL’s view, it would be foolish of the Mayor to remove the CCWE when he would then need to toughen further additional measures, such as one or more additional inner low emission zones, that are already long overdue to reduce sharply hazardous vehicle emissions to comply with air quality laws in the same area of London.

CCAL urges the Mayor to pursue vigorously stronger measures to reduce congestion across London. Instead of weakening (or removing the CCWE), the Mayor should build on the current ‘blunt instrument’ by offering dynamic (or ‘intelligent’) road pricing, such as ‘tag and beacon’ or better, in parallel with the current CCWE and Congestion Charge Central (CCC). This would give people the choice of paying a fixed congestion charge or opting to pay a flexible charge i.e. such that they might pay nothing to drive short distances outside the hours of congestion. In due course, once dynamic road pricing is shown to work well, it should take over fully from the current ‘blunt’ scheme and be extended to operate, where necessary, across London.

CCAL is concerned that a relatively small number of vehicle owners, who are primarily responsible for congestion, are - at little or no cost to themselves - having a disproportionate, negative impact on the health of hundreds of thousands of Londoners. Those causing congestion should pay the full environmental cost of their actions as part of a much wider ‘polluter pays’ strategy in London. CCAL supports measures to reduce congestion, in their own right, as a means of increasing road capacity and improving quality of life for the vast majority of Londoners.

Last but most importantly, CCAL emphasises the need for the Mayor to work closely with the government to implement measures urgently to ensure that air quality laws are fully complied with throughout London not just in the CCWE area.

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CAMPAIGN RESPONSE: 26 September 2008

The Rt. Hon. Hilary Benn MP, Secretary of State for Environment, Food and Rural Affairs
Department for Environment, Food and Rural Affairs
c/o 3C Ergon House
Horseferry Road
London SW1P 6AL

By email to: air.quality@defra.gsi.gov.uk

Dear Secretary of State

Consultation on draft Local Air Quality Management Guidance

The purpose of this letter is to respond to the consultation by the Department for Environment, Food and Rural Affairs (Defra) on draft Local Air Quality Management Guidance:

http://www.defra.gov.uk/corporate/consult/airqualitymanage-guidance/index.htm

The Campaign for Clean Air in London (CCAL) welcomes Defra’s continuing commitment to the Local Air Quality Management process as shown by the consultation on the updated guidance.

CCAL is seriously concerned that there appears to be no transparent, effective and readily enforceable mechanism under United Kingdom (UK) laws (e.g. through unambiguous statutory duties) that will impose similar or the same duties on the Mayor of London and/or local authorities to those imposed on the government on behalf of the UK as a Member State under European laws for ambient air quality. As CCAL understands it, the Mayor of London and/or local authorities need only “work towards” the Limit Values set. This allows such entities, in some cases, to pursue “busy fool” inputs without achieving any worthwhile outputs. In contrast, the government has clear duties, with objectives and precise deadlines, and can face legal action and unlimited lump sum and daily fines if it does not comply with relevant laws.

CCAL considers that there must be clear and meaningful ‘pass through’ from the government’s legal duties through to the Mayor of London and/or local authorities since the latter will be responsible, in practice, for implementing many of the most necessary solutions on the ground e.g. modal shift, low emission zones and local parking measures. CCAL urges the government to use all its existing powers (e.g. through the Environment Act and/or the Environment Agency), and new ones if necessary, to ensure that air quality obligations are enforceable at a local level (as well as nationally) including by private citizens. For example, CCAL considers that the Mayor of London and/or local authorities should each be under a clear statutory duty to implement successfully actions to improve local air quality, when it exceeds Limit Values, which are meaningful when judged in the context of all their available powers and the deadlines applicable under UK and European law. CCAL urges the government to establish and publicise widely such a mechanism within the next three months, perhaps at the time the new LAQM Guidance is issued.

Please will you or your officials clarify, fully and in writing, the above situation and the relevant obligations that do and will exist on the Mayor of London and/or local authorities to improve air quality. An email address for correspondence is provided separately to this letter.

CCAL supports fully the submission by Environmental Protection UK in its response to this consultation except as noted above.

With best wishes.

Yours sincerely

Simon Birkett
Principal Contact
Campaign for Clean Air in London   more »

CAMPAIGN RESPONSE: 13 September 2008

The Rt. Hon. Ruth Kelly MP
Secretary of State for Transport
Department for Transport
Great Minster House
76 Marsham Street
London SW1P 4DR

13 September 2008

Dear Secretary of State

Euro VI emission limits for heavy duty vehicles: ‘The London Principle’ should be used to guide decisions on trade-offs between air quality and climate change

This response to the Department for Transport’s (DfT’s) public consultation on the European Commission’s (EC’s) proposals for a new European Regulation setting emission standards for heavy duty vehicles (Euro VI), which is due to close on 17 September 2008, is sent on behalf of the Campaign for Clean Air in London (CCAL).

http://www.dft.gov.uk/consultations/open/euroviconsultation/

CCAL would not normally comment on a consultation by the DfT about Euro emission standards but we consider that this consultation raises vitally important questions, the answers to which can set a powerful framework for all aspects of the difficult and important trade-offs that will be necessary in coming years between climate change and air quality matters (and vice versa).

The Campaign for Clean Air in London

CCAL has only one aim which is to achieve urgently and sustainably at least World Health Organisation (WHO) recommended standards of air quality throughout London. Our immediate priority is to ensure that air quality laws, based on WHO recommendations for particulate matter (so called PM10) and nitrogen dioxide (NO2), established by the new European Union directive on ambient air quality and cleaner air for Europe are rigorously enforced in each of the next four years leading up to the London 2012 Olympic and Paralympic Games.

CCAL has received support from Mayor Johnson, leading politicians from the four main political parties in London as well as leading business and community groups including the Central London Partnership, London First and The Knightsbridge Business Group. We have also received a pledge of support from Environmental Protection UK (formerly the National Society for Clean Air and Environmental Protection). Our campaign website is shown in the letterhead above.
 
‘The London Principle’ (or perhaps ‘The Air Pollution Trade-off Principle’)

Tackling air pollution holistically requires difficult trade-off decisions between air quality and climate change issues. CCAL encourages policy makers, like the DfT, to accept a disbenefit of say 5% in climate change terms provided there is an associated benefit of say 50% in air quality terms (and vice versa) i.e. one to 10. Such an approach should be considered acceptable since large benefits may be hard to find and small disbenefits can be rectified relatively easily through a combination of other policy measures. An example of the former would be slightly increased fuel consumption and emissions of carbon dioxide while an example of the latter would be sharply reduced hazardous emissions.

The European Commission’s Proposals

CCAL has the following key comments on the government’s view on the EC’s proposals for a new European Regulation setting emission standards for heavy duty vehicles (Euro VI):

General - The government is right to be supportive of the aims of the EC’s proposal.

Air quality/Climate change trade-offs - The EC’s proposals offer substantial benefits in air quality terms for small disbenefits in climate change terms. CCAL believes that the fuel consumption penalty of between two and three percent indicated by the EC is more accurate than the eight percent indicated by independent advice commissioned by the government. CCAL believes that the European Environmental Bureau, the International Council on Clean Transportation in the US or others would be able to confirm the more favourable picture.

However, even if the government’s advice turns out to be correct (which CCAL doubts), the EC’s proposals would still be fully consistent with ‘The London Principle’ e.g. an 80% reduction in oxides of nitrogen and a 67% reduction in particulate matter emissions limits by comparison with the Euro V standards they would replace (i.e. about 10 units of improvement to air quality for one unit of fuel consumption disbenefit). Of course, the EC’s proposals have the additional benefit of tackling harmful emissions at their source and ensuring the polluter pays directly.

Setting global standards for technology – CCAL supports the EC’s proposal to bring the requirements in line with the United States (US) Environmental Protection Agency 2010 limits. It is clearly right to seek cost efficiencies through global standardisation and economies of scale. CCAL urges the government not to jeopardise essential, and clearly deliverable (i.e. if the US has the technology standard already planned there is no excuse for delay in Europe), technological improvements by suggesting that mainstream policy should cater for remote or unlikely events e.g. by being overcautious with its assumptions on offsetting improvements. Otherwise, the government would drive industry towards the lowest standards not the highest.

Implementation timetable – CCAL urges the government to press for the earliest possible adoption of the EC’s proposals for a new European Regulation setting emissions standards for heavy duty vehicles (Euro VI). A fast timetable is needed to aid compliance with air quality laws across Europe. It should be possible if: US 2010-like limits are adopted; and the approach of using Regulation rather than a new Directive is pursued to save time and increase certainty. There must be no unnecessary delay in the implementation of the EC’s proposals.

Financial incentives – CCAL acknowledges the government’s long opposition to the principle of including provisions on fiscal matters in Article 95 (Qualified Majority Voting) proposals, rather than proposals requiring unanimity. However, CCAL considers that the government should accept the opportunity to offer financial incentives on a case by case basis. First, the government would gain an option not lose one and second, financial incentives are clearly positive not negative per se to the citizen’s tax burden. For both reasons, CCAL considers that the government should support the EC’s proposals for financial incentives and plan to use them actively to achieve quickly substantial and much needed environmental benefits.

Summary

If the EC’s proposals are not supported fully by the UK government, it will be necessary for less efficient measures to be found to ensure compliance with air quality laws (e.g. the banning from our larger cities of a higher proportion of older diesel vehicles than would otherwise by necessary). In this context, it would be irresponsible of the government to do anything other than support fully or strengthen further the proposals from the EC to reduce sharply hazardous emissions.

CCAL supports fully the detailed response being submitted by Environmental Protection UK.

CCAL would be pleased to discuss or expand on any aspect of this letter if you or your officials consider it worthwhile. We can be contacted at the email address provided separately.

Finally, thank you for taking seriously our concerns about air pollution in London and giving the issues we raise your particular attention.
Please acknowledge receipt of this letter.

With best wishes.

Yours sincerely

Simon Birkett
Principal Contact
Campaign for Clean Air in London   more »

Consultation response: 19 July 2008

Commissioner Dimas
European Commission
Environment DG
B – 1049 Brussels
Belgium

19 July 2008

By email: stavros.dimas@ec.europa.eu

Dear Commissioner Dimas

Public consultation on revision of car labelling directive

This contribution to the public consultation on the revision of the car labelling directive, which is due to close on 28 July 2008, is sent on behalf of the Campaign for Clean Air in London (CCAL).

http://europa.eu/rapid/pressReleasesAction.do?reference=IP/08/835&format=HTML&aged=0&language=EN&guiLanguage=en

We would not normally comment on a consultation by the European Commission about vehicle labelling but we consider that you have deliberately and sensibly raised vitally important questions, the answers to which can set a powerful framework for communication generally in respect of the environmental impact of road transport. Europe needs much greater transparency on environmental performance than currently exists.

The Campaign for Clean Air in London

The purpose of the cross-party Campaign for Clean Air in London (CCAL) is to achieve urgently and sustainably at least World Health Organisation recommended standards of air quality throughout London. The Campaign has received support from Ken Livingstone, leading politicians from all the four main political parties in London and all the amenity societies in Central London as well as leading business groups including the Central London Partnership, London First and The Knightsbridge Business Group. It has also received a pledge of support from Environmental Protection UK (formerly the National Society for the Protection of Clean Air) and the Alliance Against Urban 4x4s. The address of CCAL’s campaign website is shown in the letterhead above.

Consumers need to make ‘trade-offs’ between Air Quality and Climate Change in cities

CCAL considers that Europe is failing currently in its disclosure regime for car labelling and vehicle labelling more generally. Europe gives priority, almost entirely, to vehicle carbon dioxide (CO2) disclosure at the expense of treating vehicle air pollution holistically with the result that many, well intentioned, people are not able to make the judgements they wish when they purchase a vehicle.

We have had several discussions with private individuals who sought to buy the least polluting car for use mainly in the city and ended up buying a diesel engined vehicle because a car salesman ‘bamboozled’ them at the point of sale. Typically, these people have wished subsequently, when they understood the wider picture of climate change and air quality, that they had bought instead a petrol engined vehicle, a hybrid engined vehicle or a zero emissions vehicle. Purchasers of commercial vehicles have reported a lack of available information.

In this context, the United Kingdom (UK) government’s ‘Act on CO2’ calculator has been a lamentable failure. Indeed, it has compounded the UK’s reputation for focussing myopically on vehicle CO2 instead of vehicle air pollution holistically and increased, unnecessarily, diesel pollution in our cities.

Establish best practice based on experience in Europe and the United States

CCAL urges the European Commission, when it is revising the car labelling directive, to base future European disclosure on the best of the practices in Europe and the United States (US) (e.g. those established by the US Environmental Protection Agency and the California Air Resources Board). Information on US best practice can be found at:

United States Environmental Protection Agency’s Green Vehicle Guide (GVG)

http://www.epa.gov/greenvehicles/Index.do;jsessionid=82303c770e15b4c4c6e7

California Air Resources Board proposed amendments to the emission control and smog index label regulations

http://www.climatechange.ca.gov/publications/arb/2007-06-21_notice.pdf

In a nutshell, the Green Vehicle Guide gives environmental scores for cars and trucks based on emission levels and fuel economy values.

• The scores range, for each of Air Pollution (taken to mean hazardous emissions) and Greenhouse Gas, from 0 to 10, where 10 is best;
• The scores can be used to compare all vehicles and all model years against one another; and
• The best environmental performers receive the SmartWay designation, which means the vehicle scores well on both Air Pollution and Greenhouse Gas.

The SmartWay designation is earned by those vehicles that score 6 or better on each of the Air Pollution and Greenhouse Gas scores and achieve a combined score of at least 13 when added together. SmartWay Elite is earned by those vehicles that score 9 or better on each of the Air Pollution Score and the Greenhouse Gas Score. SmartWay Elite vehicles are superior environmental performers.

Recommendations – Air Quality Score and Climate Change Score:

CCAL recommends that the revised vehicle labelling directive should ensure that:

1. each vehicle sold (whether new or secondhand) displays an Air Quality Score and a Climate Change Score – from 0 to 10, where 10 is best - similar to the US EPA’s Air Pollution Score and Greenhouse Gas Score respectively. This should lead to international comparability and efficiencies;
2. there is a designation like the SmartWay designation to show one composite score of overall environmental performance for the best scoring vehicles;
3. emissions at least of each of particulates (PM) and oxides of nitrogen (NOx) are disclosed equally with CO2 and that a common and consistent measure of grams per kilometre is used;
4. the above scores and measures represent meaningfully the actual, not laboratory test, performance of the vehicle, if necessary showing either a range of emissions for city and highway driving or a combined city/highway driving number;
5. the ‘polluter pays’ principle is followed such that vehicle manufacturers bear the full cost of this disclosure, including for historic information;
6. labelling on emissions generally is more prominent than currently such that anyone likely to consider such information useful can find it easily. A ‘culture’ of transparency and reliable information needs to be created;
7. the approach to labelling and its objectives is publicised widely so that the general public is encouraged to use it; and
8. the above approach is mandatory and independently certified.

Please extend this approach quickly from cars to motorcycles, commercial vehicles, trucks and coaches.

CCAL believes that the general public is more than astute enough to make good use of the above information. We are confident that it would ensure well informed consumer decisions and incentivise manufacturers appropriately. The success of Europe’s traffic-light labelling scheme for white goods and the US EPA’s Green Vehicle Guide is ample evidence to support such confidence.

For your information, we had problems on several occasions trying to submit an online reply to this consultation. In particular, the ‘Name of the organisation’ field did not work properly and there was no guidance on field length for additional text. A brief response was submitted eventually online.

Please acknowledge receipt of this letter.

With best wishes.

Yours sincerely

Simon Birkett
Principal Contact
Campaign for Clean Air in London

By hand:

Winston Fletcher, Chairman, The Knightsbridge Association
Carol Seymour-Newton, Honorary Secretary, The Knightsbridge Association

Cc:

The Rt. Hon. Hilary Benn MP, Secretary of State for Environment, Food and Rural Affairs
The Rt. Hon. Ruth Kelly MP, Secretary of State for Transport
Mayor Johnson
Sir Simon Milton, Deputy Mayor, Policy and Planning
ORGANISATIONS
Amenity Societies
Helen Ainsworth, EU and International Air Quality, Defra
Jenny Bates, London Regional Campaigns Co-ordinator, Friends of the Earth
Nick Fairholm, Transport for London
Tim Hockney, Executive Director, London First
Stephen Joseph, Executive Director, Campaign for Better Transport
Professor Frank Kelly, Kings College London
Dr Michal Krzyzanowksi, Regional Adviser, Air Quality and Health, WHO
Sir John Lawton, Chair, Royal Commission on Environmental Pollution
Sarah Legge, Principal Policy Adviser – Air Quality, Greater London Authority
David Lemon, Environmental Industries Commission
Blake Ludwig, Managing Director, Alliance Against Urban 4x4s
Dr Noel Olsen, British Medical Association
Professor Bob Maynard, Health Protection Agency
David Muir, Institute of Air Quality Management
Philip Mulligan, Chief Executive, Environmental Protection UK
Derek Picot, Chairman, The Knightsbridge Business Group
By post: Sir Jonathon Porritt, Chairman, UK Sustainable Development Commission
Tony Travers, Director, Greater London Group
Dr Martin Williams, Head of Air and Environment Quality Division, Defra
Tim Williamson, National Air Quality Assessment, Defra
LEADING POLITICIANS
Peter Ainsworth MP, Shadow Secretary of State, Defra, Conservative
Norman Baker MP, Shadow Secretary of State for Transport, Liberal Democrat
Greg Barker MP, Shadow Minister for the Environment, Conservative
Mark Field MP, Conservative
Jim Fitzpatrick MP, Parliamentary Under Secretary of State, DfT
Tom Harris MP, Parliamentary Under Secretary of State for Transport, DfT
The Rt. Hon. Michael Jack MP, Chairman of the Environment and Rural Affairs Select Committee
The Rt. Hon. Sir Malcolm Rifkind QC MP, Conservative
The Rt. Hon. the Lord Rooker, Minister of State, Defra
Joan Ruddock MP, Parliamentary Under Secretary of State
Jonathan Shaw MP, Parliamentary Under Secretary of State and Minister for the South East
Theresa Villiers MP, Shadow Secretary of State for Transport, Conservative
Professor Steve Webb MP, Shadow Secretary of State for Environment, Energy and Rural Affairs, Liberal Democrat
The Rt. Hon. Rosie Winterton MP, Minister of State for Transport
Phil Woolas MP, Minister of State, Defra
Tim Yeo MP, Chairman Environmental Audit Committee, Conservative
John Bowis MEP, London, Conservative
Chris Davies MEP, Liberal Democrat
Robert Evans MEP, London, Labour
Mary Honeyball MEP, London, Labour
Syed Kamall MEP, London, Conservative
Ms Jean Lambert MEP, London, Green Party
Baroness Ludford MEP, London, Liberal Democrat
Linda McAvan MEP, Labour
Claude Moraes MEP, London, Labour
Charles Tannock MEP, London, Conservative
Richard Barnes AM, Leader of the Conservative Group
Darren Johnson AM, Deputy Chair of the London Assembly, Green
Sian Berry, the Green Party
Len Duvall AM, Leader of the Labour Group, GLA
Mike Tuffrey AM, Leader of the Liberal Democrat Group, GLA   more »

Consultation response: 4 November 2007

UK report regarding plans and programmes to meet EU air quality limit values

The purpose of this letter is to respond on behalf of the Campaign for Clean Air in London to the consultation being carried out by the Department for Environment, Food and Rural Affairs (Defra) on the United Kingdom (UK) and Devolved Administrations’ draft report on plans and programmes to meet European Union (EU) ambient air quality limit values. The letter is addressed jointly to the Secretary of State for Transport because CAiL understands that the Department for Transport (DfT) has joint responsibility for the UK meeting its legal obligations in respect of air quality and the consultation document states that, historically, “In all cases, the exceedances were due to emissions from traffic”.

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Consultation response: 19 October 2007

Proposed Emissions Related Congestion Charging (the CO2 Charge)

The purpose of this letter is to respond on behalf of the Campaign for Clean Air in London to the consultation being carried out by Transport for London (TfL) on your behalf on a proposal to introduce Emissions Related Congestion Charging in 2008.

The Campaign for Clean Air in London (CAiL) fully supports effective “polluter pays” charging schemes. Given that road transport causes between 50% and 75% of the air pollution in London’s busiest roads, and that this pollution is linked closely to the amount on fuel burnt, CAiL welcomes a link being created by Mayor Livingstone between: (i) road pricing and engine size (i.e. the “quantity” of fuel burnt); and (ii) engine efficiency (i.e. the “quality” of fuel burnt).

However, CAiL considers that the current proposal should be expanded substantially and combined quickly with Dynamic Road Pricing (“tag and beacon” or its equivalent) to create a fairer and more ambitious scheme that will ensure that road transport makes its full contribution to the tackling of London’s serious air quality problem. CAiL urges Mayor Livingstone to create a behavioural “tipping point” with this scheme that could be sufficient to avoid the need otherwise for restrictive legislation.

In the week when the European Commission has announced details of the legal steps it is taking against the United Kingdom (UK) for breaching its air quality obligations, CAiL has still not seen any evidence that reasonable efforts are being made by relevant UK authorities to introduce sufficient measures that together can be expected to result in the UK meeting its current or likely future legal obligations under European Union (EU) air quality legislation. It is no good any of us being “busy fools” – introducing measures that achieve little – a much more ambitious air quality plan with bold and decisive action is needed now.

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Consultation response: 18 August 2007

Public Consultation on future Euro VI emission limits for heavy duty vehicles

This contribution to the Public Consultation on the future Euro VI emission limits for heavy duty vehicles, which is due to close on 5 September 2007, is sent on behalf of the Campaign for Clean Air in London.

http://europa.eu/rapid/pressReleasesAction.do?reference=IP/07/1100&format=HTML&aged=0&language=EN&guiLanguage=en

We would not normally comment on a consultation by the European Commission about Euro emission standards but we consider that you have deliberately and sensibly raised a vitally important question, the answer to which can set a powerful framework for all aspects of the difficult and important trade-offs that will be necessary in coming years between Climate Change and Air Quality matters (and vice versa).

“The Air Pollution Trade-off Principle” (perhaps “The London Principle”)

Treating Air Pollution holistically requires difficult trade-off decisions between Air Quality and Climate Change issues. The Campaign for Clean Air in London encourages policy makers, like the European Commission, to accept a disbenefit of up to about 5% in Climate Change terms provided there is an associated benefit of over 50% in Air Quality terms (and vice versa) i.e. one to 10. Such an approach should be considered acceptable since large benefits may be hard to find and small disbenefits can be rectified relatively easily through a combination of other policy measures.

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Consultation response: 13 May 2007

Response to Consultation on Climate Change Bill: Treat air pollution holistically

This letter is sent on behalf of the Campaign for Clean Air in London in response to the Consultation by the Department of the Environment, Food and Rural Affairs (Defra) on the draft Climate Change Bill.

We support fully the need to have Climate Change legislation that sets legally binding limits for carbon dioxide (CO2) within a robust, consistent and ambitious framework broadly in the form of the draft Climate Change Bill. However, in our view, two further points are important:

1. the United Kingdom (UK) will miss a great opportunity to lead the world if it introduces a key piece of air pollution legislation that addresses climate change in isolation. Does the UK want to be the first and only country with a Climate Change Act and the only one that fails to treat air pollution holistically? Or will it adopt a very simple mechanism to include appropriate measures for air quality in the legislation, full details of which are contained in this letter, to ensure that air pollution is addressed holistically? The Intergovernmental Panel on Climate Change (IPCC) recommended such an approach in the last few days; and

2. Annual Budgets for CO2 would be more effective at tackling climate change than five year Budgets. How can the Government, as the Environment and Climate Change Minister was doing in New York on 8 May, encourage companies to treat carbon (i.e. budgeting and) reporting as the same “no-brainer” as proper financial (i.e. budgeting and) reporting as part of the Government’s Carbon Disclosure Project, when it will not set Annual Budgets for CO2 itself?

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Consultation response: 13 January 2007

Response to Second Consultation on the Low Emission Zone

The purpose of this letter is to respond on behalf of The Knightsbridge Association, which represents over 1,000 people and businesses in the area between Hyde Park Corner and Queen’s Gate, to the consultation being carried out by Transport for London (TfL) on your behalf on a proposal to introduce a Low Emission Zone (LEZ) in 2008. This letter is supported fully by the “Campaign for Clean Air in London” which seeks to achieve urgently World Health Organisation (WHO) recommended standards of air quality throughout London noting that most of these were expected to be achieved by January 2010 in 1999 legislation.

Summary

The Knightsbridge Association supports strongly road pricing and emission schemes in general and seeks that they should be ambitious, effective and well thought through. We have been concerned to discover from the consultation documents for the proposed LEZ that a serious problem with particulate matter air pollution (PM10) is still expected in 2010 and that:

1. The Base Case for nitrogen dioxide (NO2) air pollution in London over the next few years is expected now to be more than twice as bad as TfL had thought only last January and with no end now in sight;
2. European Union (EU) legal limits and WHO recommended standards for NO2 are not being given the same priority as the same limits for PM10 even recognising the differences between them;
3. The proposed benefits of the LEZ are now less than they were in early 2006;
4. The latest proposal for the LEZ does not address adequately the major changes that have taken place in the external environment since the first LEZ consultation in January 2006;
5. The consultation documents make clear that the proposed LEZ will have a “negligible” impact on climate change and no “significant impacts on traffic levels or congestion”; and
6. Costs are higher than they would have been if action had been taken as soon as 1999 air pollution legislation was published and will increase sharply if tough action is delayed.

Fresh thinking is need urgently by TfL and the Mayor to deliver a more ambitious LEZ that tackles much sooner and more effectively the serious air pollution problem in London.

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Consultation response: 3 December 2006

London Plan Further Alterations: Climate Change and Air Quality

I am writing on behalf of The Knightsbridge Association, which represents around 1,000 people and businesses in the area between Hyde Park Corner and Queen’s Gate in Central London, to respond, in respect of air quality matters, to the public consultation on the Draft Further Alteration to the London Plan. Separately, we are seeking your commitment to protect local residents, local businesses and visitors (of which there are many) in the Knightsbridge area from high levels of air pollution from nitrogen dioxide (NO2), particulate matter (PM10 and PM2.5) and street level ozone (O3) when you finalise the London Plan.

The Knightsbridge Association is seeking personal commitments from you on behalf of London’s government to:

i. recognise the extent and worsening trend for air pollution in London and that this problem needs urgent action as tough as that, for example, required to reduce road traffic fatalities further;
ii. treat air pollution holistically in the London Plan and in all relevant initiatives (i.e. air quality – mainly PM10 and PM2.5, NO2 and O3 – and climate change – mainly carbon dioxide (CO2));
iii. treat air quality at least as robustly as climate change in the London Plan and all relevant initiatives e.g. in your Climate Change Bill initiative with the Friends of the Earth;
iv. adopt for London the 12 commitments for air quality sought by The Knightsbridge Association in its letter to the Department of Environment, Food and Rural Affairs (Defra) dated 25 June (which is attached and can be downloaded from our website). This letter was supported by almost all the community groups representing Central London, with most of those seeking the same commitments in respect of their own areas, and leading London politicians Angie Bray, Mark Field and Darren Johnson (see later); and
v. include a commitment in the London Plan policy section to specific air quality outcomes with annual action plans, by primary postcode (e.g. SW7), that are independently assessed.

The purpose of the London Plan should be to make unambiguous commitments and establish a robust framework with clearly defined responsibilities and accountability for delivering them. In our considered view, it does not yet pass that test in relation to air quality and particularly so when part of the air pollution “goal posts” are (rightly) moving to meet climate change challenges. We urge you to go much further in the London Plan by making the commitments summarised above.

We request respectfully that you reply personally please to this letter in your capacity as Mayor of London.

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Consultation response: 29 October 2006

Air Quality in England, Scotland, Wales and Northern Ireland

First Consultation: “Consultation on draft AQEG report: Trends in Primary Nitrogen Dioxide in the UK”

Second Consultation: “Consultation on the UK’s plans and programmes to meet limit values set in the First Air Quality Daughter Directive (1999/30/EC) of the European Parliament and Council (2006 reporting year)”

Third Consultation: “Consultation on draft proposals to: (a) transpose Directive 2004/107/EC of the European Parliament and of the Council relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic hydrocarbons in ambient air; and (b) streamline air quality legislation by consolidating existing air quality legislation with proposed legislation”

Introduction: Response to three Defra consultations on air quality

I am writing on behalf of The Knightsbridge Association, which represents around 1,000 people and businesses in the area between Hyde Park Corner and Queen’s Gate in Central London, to seek again your commitment on behalf of HM Government to protect urgently local residents, local businesses and visitors (of which there are many) in and around the Brompton Road, Knightsbridge and Sloane Street area from high levels of air pollution from nitrogen dioxide (NO2) and particulate matter (PM10 and PM2.5). We wrote to you on 25 June seeking twelve (12) specific commitments and have still not received a reply from you to that letter. We request respectfully again that you reply personally please to that letter and to this one in your capacity as Secretary of State.

Air pollution in Brompton Road is worse already in 2006 than in the whole of 2005. As at today’s date, annual mean levels of NO2 for 2006 are 95 ug/m3 compared to 90 ug/m3 in 2005 and there have been 310 exceedances of the hourly limit of 200 ug/m3 in just under 10 months compared to 288 exceedances for 12 months in 2005 (compared to World Health Organisation (WHO) recommended levels of air quality for NO2 of 40 ug/m3 and 18 exceedances respectively). These readings are taken nearly 400 metres (where the road is narrowed to one lane in each direction by the road configuration) from the site of the worst local air pollution, where 12 lanes of traffic merge at the top of Sloane Street, and, although PM10 is not measured at the Brompton Road monitoring site, the broad correlation between the two air pollutants indicates very high levels of PM10 (and probably ozone) here too.

I am also now writing on behalf of The Knightsbridge Association in this letter to respond to three technical consultation documents issued by the Department of Environment, Food and Rural Affairs (Defra) in August and September 2006 on various aspects of air quality and in particular issues relating to NO2. Given the interconnectedness of the subjects, this letter represents our formal reply to each of the three current consultations with detailed responses shown separately below. This letter should be read in conjunction with our letter submitted to Defra on 25 June 2006.

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Consultation response: 25 June 2006

The Air Quality Strategy for England, Scotland, Wales and Northern Ireland

EU Directive on ambient air quality and cleaner air for Europe COM (2005) 447

Response to Defra’s consultation on air quality

I am writing on behalf of The Knightsbridge Association, which represents around 1,000 people and businesses in the area between Hyde Park Corner and Queen’s Gate in Central London, to seek your commitment on behalf of HM Government to protect urgently local residents, local businesses and visitors (of which there are many) in and around the Brompton Road, Knightsbridge and Sloane Street area from high levels of air pollution from nitrogen dioxide (NO2) and particulate matter (PM10 and PM2.5). Twelve (12) specific commitments are sought later in this letter.

I am also writing on behalf of The Knightsbridge Association in this letter to respond to the consultation document issued by the Department of Environment, Food and Rural Affairs (Defra) in April 2006 on options for improvement in air quality. For that reason, I am sending this letter jointly to Eko Deinne as The Knightsbridge Association’s formal response to the Defra consultation. We request respectfully that you reply personally please to this letter in your capacity as Secretary of State.

The Knightsbridge Association understands that Defra plans to publish an updated Air Quality Strategy by the end of 2006. We encourage Defra to do so on the basis of current European legal limits (which the European Commission recommends should be retained) and to seek stronger, more flexible powers to implement a wide range of possible solutions and to press devolved and local authorities to deliver results. Only when a new EU Directive comes into force, which you expect in 2007, should Defra amend UK air quality objectives or limit values i.e. for PM2.5. Otherwise, Defra will create confusion by trying to prejudge the outcome of hypothetical changes.

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Consultation response: 9 April 2006

Low Emission Zone consultation

I am writing on behalf of The Knightsbridge Association, which represents over 1,000 people and businesses in the area between Hyde Park Corner and Queen’s Gate, in response to the consultation being carried out by Transport for London (TfL) on your behalf on a proposal to introduce in 2008 a Low Emission Zone (LEZ).

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