Sunday, May 7, 2017

Govt consultation on air quality

Apologies for the  lengthy post that is intended to provide an angle for those interested in the Government's latest attempt at avoiding legal challenges to its inadequate response to the health' emergency' being caused by road traffic.  It might be an exaggeration to claim that the General Election was called and legal  challenge mounted in an attempt to have this in the public domain after 8 June, but 11 million drivers of diesel vehicles is a significant constituency.  In the event the Government has limited the scope of the proposals to an extent that the Courts might be required again to seek to protect its citizens.  There is also an attempt to saddle local government with the blame for anything potentially unpopular.

Please go to the consultation (see URL below)  and (before 15 June) put the Government straight on the need to take advantage of an opportunity to improve life for all.

7.   Are Clean Action Zones the quickest way?
The quickest way to reduce all the pollutants from road traffic is to implement systemic measures and not singling out NOx in a few areas that apparently fail to meet an artificial standard.  Speed lim its can be reduced immediately, at no cost and with completre fairness. As the Technical Report says "C.6 Speed Limits:  A reduction of 20mph is the most effective in terms of NOx emissions, so a 50mph limit is presented as the maximum technical potential option."  Not only do the proposals ignore the issue of speed limits (eg 20mph being more polluting than 30mph with the current generation of petrol and diesel engines)but what the Technical Report says is an "immediate" problem has now become the "most immediate".  This is a very significant difference both in law and for the people being poisoned meanwhile.  The costs attributed to reductions in speed limits in the Technical Report are down to its very limited viewpoint affecting a few isolated areas and stretches of road rather than the systemic change required.

8. What should local government do about CAZs?
The Government should not be dumping this issue on local authorities.  Local measures could have very limited and local effects without the Government taking responsibility for systemic change.  There are places which fail air quality tests which are not on the Government's list. Everybody deserves to be protected from harmful pollutants wherever they live or visit.  The Government could start by changing the name from "Clean Air Zones" to something more truthful which does not imply the absence of poison gases, which might happen to be coming slowly down to legally acceptable levels. 

The impacts on businesses (and local residents/visitors) of truly effective measures to bring pollutants from road traffic down to harmless levels could be very severe.  This is why the Government needs to have a proper plan for the transition.  The alternative will be a repeat of legal challenges while the health and lives of citizens is impaired.  Local Government should not be expected to take the blame for these profound effects.

9.         Options available to local government?
 First reduce the national speed limits to 50mph(see Technical Report) and 20-mph (see all evidence on safety).  Every area must be equipped with electric car clubs.  A lower national speed limit (ie 50mph) is suited to electric cars where range is a priority.   Such a limit would remove most if not all of the comparative advantage enjoyed by ICEs.

All new residential and commercial developments must pay for charging points and for a number and range of ULEVs for the new and existing residents.  Public money should be used to build this fleet and charging possibilities.   These cars will be privileged in terms of use of lanes (on dual carriageways) and workplace, town centre and retail centre parking.   Public money should  not be spent on scrapping diesel or petrol cars.  Their use will just become more limited and much less convenient than (shared) electric club cars.  It will be up to private car owners how to react; move to clean buses, cycling, walking or the car club.

10.      How can impact be measured?
 It should be relatively easy to have a plan of an area and assess the need/demand for access to electric vehicles.  Some of these can be provided by developer funding from new development.  Where these opportunities are unlikely to arise local government must step in and seek to recover some of the cost from users.   Bans of ICEs from urban areas (and failing stretches of inter urban roads) should be put in place after a reasonable warning/grace period.  These should need limited monitoring other than the level of exceptions allowed for special reasons. It is a fundamental principle that measurements are not designed to gauge whether legal limits are being achieved but that the levels are immediately (ie within 12 months) reduced to de minimis levels so that the measurements are to identify and correct any unintended incidence of unfairness in the new system.

11. Which vehicles to retrofit?
 Buses could be converted to LPG or hybrid LPG/EV.  HGVs should be LPG. Vans and taxis (why only black cabs?) should be LPG and EV or hybrid.  There could be some slow to convert/remove HGVs and a shortage of or cost implications of reliance on LPG.  If there is a reduction of heavy goods movements by road then that would be a very welcome consequence of this power shift.

12.      Information to customers?
 Government should make it clear that the use of privately owned ICEs (no distinction between petrol and diesel) will be limited on the strategic road network (ie lanes reserved for ULEVs), and in urban areas (eg parking reserved for ULEVs).  Individual ULEVs might be purchased but as the Technical Report says, that is a very expensive option.  This story must be justified by the special duty of care which must be shown to children as the most vulnerable to irreversible damage to brains and lungs and to other disadvantage groups (see Technical Report).

13. How could the Government further support innovative technological solutions and localised measures to improve air quality?
The Government should be honest about the challenge of this transition and immediately start to place the health and wellbeing of its citizens (esp children) above the (hyper)mobility of the few.   This good news story should explain that the complementary measures of introducing electric car clubs would improve accessibility for everybody.  The streets would be better for walking and cycling. Reduced congestion would allow public transport and taxis to be more frequent and run on time.   The lower national speed limit will incentivise the research and development of electric vehicles no longer attempting to compete with the performance and allure of ICEs. Vehicles designed for lower maximum speeds (ie ULEVs) are, unlike ICEs, less polluting at lower speeds.
This is the only route to improve air quality to acceptable levels (not standards) and establish the pathway to zero carbon transport by 2050 (or earlier), see Technical Report.
These proposals represent the wrong answer to the wrong question.   The harm being caused by diesel and petrol engines (and dust from brakes, roads and tyres) as well as the noise (engines, wind and tyres) and harm to life and limb will not be removed by targeting NOx reductions at a few isolated areas and roads.  This challenge is actually an opportunity to move quickly to a clean, safe, reliable, affordable and fair transport system - in and between towns.  The trigger for the virtuous circle creating these new conditions would be one of the essential elements of such a system that would be lower maximum speeds in and between urban areas. 
The alternative (as being proposed) would be to continue with a dirty (just clean enough), dangerous, unreliable (eg congested), expensive and inequitable transport system that becomes an increasing burden on people, business and the environment.