1. Air Quality Presentation to KOVF Meeting by David Boardman
Chair of Planning Group
27 April 2017

2. Structure Air quality – why the big fuss? What is in the air?
What does it do?
Where do the main toxins come from?
What is to be done about it?
The Government, GLA and Lambeth response
Community response – Archbishop Sumner School
Community response – Lambeth Cycling
The KOV Neighbourhood Plan

3. Air quality – why the big fuss?
UK air quality in many big cities regularly exceeds EU legal limits for particulate matter and oxides of nitrogen (PMs and NOx in the jargon)
Bad air quality kills people prematurely
UK in long term breach of its EU obligations – likely to be fined by EU and “up before the judge” in UK, currently trying to put off saying what it will do to bring levels down (probably unpopular heavier taxation of diesel vehicles) until after the election [Subsequently: Government submits to judge’s order and publishes draft proposals, widely criticised as still inadequate]
For us in the KOV area, the Vauxhall Gyratory is, on average over a year, one of the worst air pollution hot spots in London

4. What is in the air? I
Main pollutants are ozone, carbon monoxide, sulphur dioxide, nitrogen oxides (NOx), and two sizes of “particulate matter” (PM10s and the smaller and more far reaching PM2.5s)
Current health concerns focus on NOx and PM2.5s
World Health Organisation (WHO) sets guideline levels for these, taken up by EU (so issue doesn’t vanish when leave EU, and EU levels for PM2.5s are laxer than WHO’s)
Annual average threshold for NOx is set at 40 microgm/cubic metre – yellow to red on the attached map exceed this level

6. What is in the air? II
That looks admirably detailed – but is actually modelled, based on no more than three sensors in Lambeth, at Vauxhall, Brixton and Streatham, along with others across London, eg at Elephant and Castle.
So we could have hotspots elsewhere, we have no live monitoring of sensitive locations like schools, and you cannot prove (though you may suspect) that air quality is significantly better in the middle of green spaces.

7. What does bad air quality do?
It makes existing health problems worse and shortens lives, particularly for the vulnerable
The most recent 2015 King’s College study identified the combined effects of NOx and PM2.5s combined (roughly two-thirds NOx and one third PM2.5s) for Lambeth’s 165, year olds and above as years of life lost, concentrated as a premature death rate of about 2 per thousand of this population each year.
This level of loss of life years is seven times higher than the HSE upper limit for the tolerability of risk of catastrophic accident from eg a chemical works, but the public seems to tolerate a higher level of risk (in these terms) from gradually operating causes than from catastrophic ones.

8. Where do the main toxins come from?

9. What is to be done about it? I The Government
The Government –December Action Plan highlights:
£2bn past funding to help upgrade bus fleets, support cutting edge technologies to reduce pollution and introduction of cleaner fuels like LPG
Introduction of Clean Air Zones in 5 cities outside London, with congestion charging
Welcome for private sector firms upgrading their fleets
Securing more stringent vehicle emission testing in the EU
Support for the Mayor of London’s efforts
But response silent on major issue of current bias of Vehicle Excise Duty in favour of diesel vehicles.
Government has had to be prodded by Supreme Court to improve response – currently claiming air quality is “not an emergency”, and should be allowed to defer (probably tough taxation) announcement until post Election.

10. What is to be done about it? II The GLA
The GLA – now more activist under new Mayor:
The existing Congestion Charge, with exemption for low emission vehicles
Emissions Surcharge (‘T-Charge’) coming in from October 2017
The existing London Low Emission Zone (LEZ) for commercial vehicles
The proposed Ultra Low Emissions Zone (ULEZ) from 2019 or 2020
The bus fleet
Taxis (black cabs)
Private hire vehicles (PHVs)
Freight emissions
Ultra low emission vehicles (ULEV)
Low Emission Neighbourhoods
Healthy Streets
Car clubs
Increasing public transport capacity
Diesel scrappage scheme urged on Government
Vehicle Excise Duty devolution and reform called for
Research into non transport sources
Lambeth – Air Quality Action Plan identifies three priorities:
Priority 1: To continue to encourage modal shift in Lambeth to more sustainable transport and to promote sustainability during and after construction
Priority 2: To reduce exposure to air pollution and to raise awareness
Priority 3: To work in partnership with residents, community groups, Business Improvement Districts (BIDs), Transport for London and other organisations to concentrate on local pollution problems in Lambeth

11. What is to be done about it? III Lambeth
Lambeth – Pollution levels mandate an Air Quality Action Area with an Air Quality Action Plan which identifies three priorities:
Priority 1: To continue to encourage modal shift in Lambeth to more sustainable transport and to promote sustainability during and after construction
Priority 2: To reduce exposure to air pollution and to raise awareness
Priority 3: To work in partnership with residents, community groups, Business Improvement Districts (BIDs), Transport for London and other organisations to concentrate on local pollution problems in Lambeth

12. Priority 1: To continue to encourage modal shift in Lambeth to more sustainable transport and to promote sustainability during and after construction
The three main sources of emissions in Lambeth are road transport, construction, and domestic and commercial gas use. To achieve this aim we are looking at:
Topic: Emissions from Developments and Buildings
 Develop planning policy to continue to reduce emissions during and after construction (action 1)
 Raise awareness and work with developers to use low-emission equipment in construction (action 2)
 Ensure the policies to reduce pollution, which we already have in place, are respected and promoted wherever possible (actions 3 to 7)
 Promote to residents and take advantage of Greater London Authority funding to replace boilers (action 8)
Topic: Delivery Servicing and Freight
 Reduce emissions from deliveries in Lambeth (actions 19 to 21)
Topic: Borough Fleet Actions
 Council officers to use vehicles only when absolutely necessary and Lambeth to change its fleet to low emission. Council officers to walk and cycle more, and use other sustainable transport as much as possible (actions 22 to 24 and 26)
 Investigate using low emission street sweeping equipment, which can also help to clean the air (action 25)
Topic: Highways & Transport
 Raise awareness of the dangers from idling and encourage drivers to switch-off their engines when stationary (action 34)
 Work with car clubs to increase the amount of electric, hydrogen and ultra-low emission vehicles in their fleet (action 35)
 Encourage citizens to walk and cycle more (action 36)
 Examine whether to introduce emission based parking charges, so vehicles which pollute more pay more (action 37)
 Introduce more electric charging points and rapid chargers (actions 38 and 39)
 Reprioritise our road space, such as restricting parking on congested high streets to improve bus journey times and the cycling experience to encourage more sustainable travel (action 40)
 Pressure TfL to do more to improve air quality, by extending the Ultra-Low Emission Zone (ULEZ) and make all buses in Lambeth low emission (action 41)

13. Priority 2: To reduce exposure to air pollution and to raise awareness
We are limited in what we can do to reduce poor air quality, as it is estimated that up to 40% of air pollution in Lambeth is from sources outside the borough. But we can help our citizens to reduce their exposure by travelling differently, etc. We can also help citizens to understand how they can make positive changes in their own behaviour to reduce pollution. This will be delivered through:
Topic: Public Health and Awareness Raising
 More joint working with Public Health colleagues to tackle the effects of poor air quality and make more information about health risks available to citizens (actions 9 to 13)
 Work with businesses to improve air quality and reduce exposure (action 14)
 Promote apps and websites which give air pollution information and advice on how to travel sustainably (action 15)
 Work with schools to raise awareness and reduce exposure to pollution (actions 16 and 17)
 Encourage other council departments to consider air quality when making decisions (action 18)

14. Priority 3: To work in partnership with residents, community groups, Business Improvement Districts (BIDs), Transport for London and other organisations to concentrate on local pollution problems in Lambeth
The only way to ensure our AQAP is successful is to work closely with those the plan was written for, who know their local area better than anyone else and where the problems are. This aim will be realised through:
Topic: Localised Solutions
 Protecting and increasing green infrastructure wherever possible (action 27)
 Looking at measures in local areas to improve air quality, such as creating Low Emission Neighbourhoods (LEN). A LEN is a series of measures to improve air quality in an area, such as building green infrastructure and giving priority to bicycles on roads (action 28)
 Investigate whether to install Santander bikes outside Brixton station (action 29)
 Increase working with neighbouring boroughs to jointly reduce pollution (action 30)
 Continue working to reduce pollution from idling taxis at Waterloo station (action 31)
 Investigate building a green wall at Lambeth North station (action 32)

15. What is to be done about it? IV
The KOV Neighbourhood Plan:
Has to “generally conform” to higher plans, and is limited to planning land use, so cannot ban diesel vehicles. But can propose more detailed measures specific to local circumstances, like the Gyratory hot spot, and the generally adverse air quality north of the congestion charge boundary
Is minded to
Insist on full environmental appraisal for any major development (TfL is trying to duck this for its Gyratory proposals)
Make it a CIL priority to fund more air quality detectors in strategic and sensitive locations
Require developers in areas exceeding EU air quality limits to acknowledge publicly the likely rates of premature death from living in their areas
Insist that developers mitigate the impact of air quality eg by filters or other ventilation methods, so that their developments are not occupied till average air quality within the development is below EU limits

16. Will the ULEZ save us? Prediction – ULEZ starts 2020
Prediction – ULEZ brought forward to 2019

17. TfL Vauxhall Gyratory Proposals
Tfl’s latest proposals for making the Gyratory two way are contained in Lambeth planning application 17/00562/EIASCR
This is a request by TfL to be let off doing a full Environmental Impact Assessment, which would make TfL reveal which alternatives it had considered, and what they would have meant for absolute levels of air quality
KOVF thinks this is ludicrous, when dealing with one of the worst hot spots for air quality south of the river, in an area of ever higher density housing
KOVF representation for a full EIA is on our website xhall%20Gyratory%20Proposals%20KOV%20%20%20Rep%2017_00562_EIASCR.docx
Following slides show proposed road layout, and estimated air quality changes, not levels, at selected modelling points. Note that the air quality at the nearest modelling point to the proposed new town square gets worse.

20. References
UK Government Air Quality responses – dioxide
WHO Air Quality Fact Sheet -
London Air Quality website -
2015 King’s College London Health Study - projects/HIAinLondonKingsReport final.pdf
HSE Tolerability of Risk Framework - , especially pages 44 to 52
GLA April 2017 ULEZ Bring Forward Consultation - phase-2/user_uploads/ulez-changes---stage-3a---con-and-info-doc---final-v1.0.pdf
Lambeth Draft Air Quality Action Plan - consultation-document.pdf
KOVF Neighbourhood Plan Air Quality Exposure Draft -
TfL Vauxhall Gyratory Proposals and Request to omit Environmental Impact Assessment - Application 17/00562/EIASCR -