Supplement to the UK plan for tackling roadside nitrogen dioxide

concentrations - Consultation response  

1. What is your name? 
Keith Taylor Green MEP for South East England 

2. What is your email address? 

keithtaylor@greenmeps.org.uk 

3. What is your organisation? 

Office of the Green MEPs 

4. Would you like your response to be confidential? 

No 

5. Are there other measures not set out in the consultation

document that should be considered in order to help achieve
compliance with legal limits for NO2 in the shortest possible time in
any of the roads in exceedance in the third wave local authority
areas? Please provide any appropriate evidence to support your
proposal. Any proposals should take into account the assessment
criteria set out in the consultation document. 
The approach set out by the Government, in the initial Air Quality Plan and in this
supplement, is to focus only on the current problem areas. Whilst it is of course an
imperative to bring areas in excess of the recommended limits as quickly as possible,
focusing only on these particular roads is short-sighted and misses the point of
delivering sustainable mobility more generally.

Focusing only on those areas that are in breach of the limits does not tackle the issue
– there are areas where data is missing but are likely to be in excess, there are areas
which are very close to meeting the limits and the dangers here are just as real as in
those areas identified (in 2015) by the Government. There need to be comprehensive
programmes in place which do not trade off particular measures with others, but
seeks to implement all of them in parallel.

We need to tackle air pollution, not just in small fragments of urban areas, but across
the board. For our towns and cities to be cleaner, healthier and greener areas, the
route of the problem – the fuel powering the vehicles needs to change.

When we think about car clubs, we need to be practical – we need point-to-point

services, not back to base – so we need infrastructure in place to meet these
demands. But we also need to see much more emphasis on getting out of cars and
making our public transport more viable, and less polluting too. And we need a much
longer term and holistic view of tackling the problem. Planning and developing for a
future with fewer cars should be also be prioritised – parking scarcity and mixed
modal hubs and streetscapes will all help to deliver, but we need these solutions built
in now or we face decades more automobility.

So this supplement which aims to tackle particular roads in given areas will not have
the requisite effect. Government needs to tackle the issue centrally – it should stop
passing the buck to the cash-strapped local authorities. It should stop investing in
more road building and it should work to get internal combustion engines off the
roads 2 decades earlier.

And it is specious to suggest that Clean Air Zones cannot be implemented in 2 years.
Scotland’s plan to introduce zones into its 4 largest cities demonstrates that it is not
only possible, but is becoming a reality. Local authorities should not be dissuaded by
an apathetic Government, they should be supported in their efforts.

6. Are there other secondary objectives that should be taken into

account when choosing between proposals which deliver
compliance in the third wave local authority areas in the shortest
possible time? 
There needs to be broader consideration of the local context into which measures
are implemented and what the planning horizon looks like in each of the areas.
Measures should be mindful of, and connected to local plans and developments
being proposed. Also, understanding the impact of the measures implemented on
other areas of the city, not just those roads highlighted in the supplement Annex A
would be significant – introducing measures which only address the problematic
roads and leave other areas close to or at risk of exceeding safe limits would be
nonsensical. This approach taken by the supplement needs to be rethought. Town-
or city-wide measures need to be considered so that initiatives which are more
comprehensive and costly aren’t ultimately duplicated in the coming years. 

7. Could encouraging the use of public transport, cycling, walking,

park and ride schemes and/or car clubs help achieve compliance
with legal limits for NO2 in the shortest possible time on the roads
in exceedance in any of the third wave local authority areas? We
welcome views from stakeholders on how government can support
the local authorities in implementing such measures. 
Yes, but it is important that these measures are not considered in isolation. Some of
these low cost measures will be most effective and should be prioritised. Local
government could be supported by Government providing financial support to
implementing the measures, and in investing money in sustainable transport across
the UK and stopping road building and large infrastructure projects like HS2. If all of
the money earmarked to these vanity projects was invested at the local level across
all regions of the country, the positive social, health and environmental benefits
would be tangible.

Moreover, the Government could take a more professional view of the process in
question. Stating that ‘we are not anticipating that significant new evidence will
emerge from this consultation’ flies in the face of societal progress. Policy and
technical innovations are happening all the time. The Government is basing the
needs case of this supplement on 2015 data, things change over time, the roads in
question may already not be the most up-to-date, more areas may need addressing
that are not in the Government’s line of sight. Similarly, advancements may have
taken place which could serve to drastically improve our air. To truly support local
authorities, the Government should be more open-minded, more dynamic, and less
resistant to change. 
 

8. How can any of the third wave local authorities encourage local
people to choose less polluting forms of transport? 
They can offer personalised travel planning across their communities, they could
improve and incentivise local public transport use, cycling and walking provision.
Offering information about the causes and impacts of air pollution as well as the
solutions would be especially useful if it targeted the communities most at risk. Such
‘soft’ measures of awareness raising and information provision are relatively low cost
but can have a large impact in improving air quality.  

9. Could measures to optimise traffic flow help achieve compliance

with legal limits for NO2 in the shortest possible time in any of the
roads with an exceedance in the third wave local authority areas?
We welcome views on how government can support local
authorities in implementing such measures. 
There is a danger when ‘optimising’ traffic flow that the problems can actually be
exacerbated. If you build roads, there is a derived demand and more people use
them. Similarly if you expand or ‘optimise’ the capacity of the existing network, more
people may use it. Unlike the measures that offer alternatives to road-based
transport, these measures are not proven to have impact in improving air quality; they
cannot be guaranteed to help achieve compliance and may indeed make air pollution
worse.  

10. Could working with local businesses and accessing clean

technology help achieve compliance with legal limits for NO2 in the
shortest possible time in any of the roads with an exceedance in
the third wave local authority areas? We welcome views on how
government can support local authorities to work with business to
reduce pollution. 
Yes this is possible, but again it isn’t a guaranteed way of achieving compliance and
will also be context specific to the local areas. Engagement with local businesses can
take time and therefore may not be help in the shortest time possible.

And in terms of ‘accessing clean technology’, there needs to be more information

available about what this is, the cost, where it would be available and the likely
impacts it would have before any informed decisions could be made about it’s use
and usefulness in tackling the problem. 
 
Required Feedback Questionnaire 

11. Overall, how satisfied are you with our online consultation tool? 
Very satisfied 
Satisfied 
Neither satisfied nor dissatisfied 
Dis-satisfied 
Very dissatisfied 
Don't know 
 
Please give us any comments you have on the tool, including suggestions on how we
could improve it.