MAY 8, 2017
London's conspicuously bad air has got right down the lungs and under the skin of Lofthouse recently, and he's taking an interest.....
Follow me on Twitter, @richloft, where I regularly post on this subject in an individual capacity. Useful hashtags to follow, #AirQuality, #cleanair, #NO2Plan, #TRUEemissions
The idea here is to present a few responses to the publication on May 5, 2017, of the UK government's new, revised plan for tackling illegal levels of polluted air in Britain...
WHICH IS HERE:
...noting for a kick-off that you can respond as an individual to the Consultation - follow this link:
www.gov.uk/government/news/new-air-quality-plan-published-for-consultationThere are in fact two different things going on here. There is a legal fight over the scale and timing of government action, with Client Earth taking the government repeatedly into the courts to force it to act over illegal levels of Nitrogen Oxide in our air. And then there are all the many government ideas for how to address the problem, some of which are great (but will they be applied and enforced?).
On the first issue, the legal fight and timing, the central point to note is that the government's revised plan has not impressed any of the different groups who want cleaner air (including me).
It's very hard not to imagine James Thornton and his colleagues at Client Earth drinking very strong espresso today and deciding to drag the government back to the High Court for the umpteenth time, for not acting quickly enough as prescribed by law, to bring down illegal levels of Nitrogen Dioxide levels in our air.
I note that in Paragraph 2 of the preamble to the consultation launched on May 5, 2017, Tackling nitrogen dioxide in our towns and cities, there is a tightening up of words, from the permissive ('Local authorities already have the powers to implement Clean Air Zones') to the might be mandatory, ('This consultation proposes that, where the evidence shows persistent air quality exceedences, local authorities must develop plans to achieve compliance within the shortest time possible.') [my italics]
However, the following sentence will make a lot of blood boil among parents, cyclists, pedestrians, bus and tube users and indeed motorists, recently shown to be subject to very high levels of pollutants inside their cars:
'We expect that implementation of Clean Air Zones will take up to three years, but Government will ensure the plans achieve compliance within the shortest possible time.'
That's a real brass neck sentence, for its insouciant contradiction, the sort of utterance that raises the pulse and creates melt-down rage. But it also defies the High Court and anyone else who wants to see air quality reform.
Turning to the second issue, the many government ideas for how to address the problem and the content of the revised plan, I'd stick my neck out and venture to say that there are lots of intelligent and good ideas.
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| Yes, diesel is the main culprit, contrary to what some people are claiming |
a. Scrappage. I'm not as bothered as others are that there was no commitment of the government to a scrappage scheme. Most people got on board this exciting little rocket, even the Guardian. But scrappage is very expensive and its precise impact on air quality would be small. I note from the 252 page technical report accompanying the revised air quality plan, that the government considered the 'theoretical maximum potential' of a scrappage scheme for all pre-EURO 6 (i.e. pre-2015) diesel cars. Scrapping a quarter of the UK fleet (about 9 million cars from a UK PARC of 37 million (SMMT)), would cost £60 billion they say (about £6,500 a car - there's no explanation for how this figure was arrived at). Scrappage generates good headlines and lavishly pays off the car makers and some consumers, as before in 2009-10, but for the same reasons it is a very controversial deployment of tax payer money that could instead target the real culprits for emissions, buses, coaches, taxis and commercial vehicles. Finally, if you take a deep ecology perspective, scrappage is pretty ruinous. It epitomises the throwaway society. It scraps perfectly good cars, squandering the huge emissions (CO2 I mean - let's not forget climate change) that were created in the manufacturing of that car and in the materials that were dug up and smelted in its making.
b. ...that's why the Government's emphasis on Retrofitting of older vehicles with new scrubbing equipment or alternative fuels is welcomed. It might not be as sexy and it might not generate the same headlines, but if there is one policy area where successive UK governments have been consistent, it is in encouraging cheap Liquefied Petroleum Gas (LPG). Around this a significant cottage industry has grown. LPG is not the electrified or hydrogen future that is visible down the road, but it's a lot cheaper and actually achieves the drastic cuts in emissions that we need as a matter of urgency. Other city authorities have mandated switches of whole, discrete fleets such as taxis (Delhi) to alternative fuels. This has been trialled with Hackney cabs in Birmingham. Why it wasn't rolled out across the whole London black cab fleet as long ago as Mayor Livingstone will always remain a source of huge regret to me. It was a no-brainer. It should have happened. It didn't. Returning to the document in hand, I take encouragement at least from the explicit suggestion of the government that local authorities link licensing requirements to emissions, for all manner of taxis and private hire vehicles. On p23 (section 3.4.2) of the revised Clean Air Zone Framework, one of the accompanying documents to the current consultation, the government says that it expects its new Clean Vehicle Retrofit Accreditation Scheme (CVRAS) 'to be in place in 2017.' This all makes sense to me, but I hope that it will also accommodate fuels such as compressed natural gas, a current favourite of AUDI (just to re-connect here with a bit of glamour) --- who recently launched a whole gas-powered car initiative in Germany. Britain lives off gas. It wouldn't take much to apply it extensively to commercial fleets, with immediate and extensive benefit to particulate and NOX emissions.
In the Consultation document, Tackling nitrogen dioxide in our towns and cities, p16/section 51, a strong sentence: 'The Government expects [my emphasis] local authorities to consider scope to retrofit vehicles as part of development of their proposals for Clean Air Zones.'
c. While I initially thought that the government had no blue sky 'aspirational objective', I was wrong. p4 (2.1.24) of the CAZ Framework, '...a clear long term ambition for all new cars and vans to be zero emission by 2040, and for nearly every car and van to be zero emission by 2015.' I welcome the goal even as the suggested timetable is far slower than it needs to be with no good reason.
d. There is a ray of hope for Last Mile Delivery outfits like Pedal and Post in Oxford and Outspoken!Delivery in Cambridge.
CAZ Framework p13 (2.4.2) '...enable the 'last mile' [of deliveries] to be provided by ULEV and/or e-cargo bikes.' That's a particular enthusiasm of mine so forgive the particularity - but delivering Amazon Prime stuff by cargo bike has a vast and rapid implication for emissions.
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| Pedal and Post is a fledgling Last Mile Delivery (LMD) company in Oxford. Its team of riders are subjected to high diesel emissions all day long, the sort of detail that society doesn't care to admit. |
e. The government claim to have put £870m towards Ultra Low Emissions Vehicle technology and development, to help generate the alternatives to diesel and ultimately, to internal combustion engines, across 2016-2020, with £270m of that coming out of the autumn 2016 budget. Certainly it would be great if the UK could be a leader in alternatives to internal combustion (BREXIT is a shadow).
f. If the number of potential Clean Air Zones has shot up from 5 to 37 (all illegal levels of nitrogen dioxide) London is totally off the scale, stand-out bad, as this graphic shows:
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| London is standout bad, almost twice as bad as the next worst (Glasgow) |
g. In the Consultation document, Tackling nitrogen dioxide in our towns and cities, p17/section 55, The government will change its procurement strategy '...to avoid purchasing diesel vehicles wherever possible.' This policy will extend out to local authorities.
Now that's interesting because it shows that the government has conceded in private that diesel vehicles have no part in the future fleet. Extrapolate for yourself. If you buy a diesel going forwards you're on the wrong side of history.
CONCLUSION
The government's apparent commitment to ban all public sector diesel purchases shows that they have not been convinced by the car industry/ EU claims about the merits of EURO VI/6 emissions data. In other words, if there is an alternative to diesel everyone from private motorists to commercial fleets should be pursuing it.
That brings out the real tension in the various consultation documents here.
Early in the Technical report, for example, a footnote has been inserted that says, 'The latest EURO 6 standard is projected to deliver a significant reduction in NOx emissions from vehicles.' No research or evidence is cited. In fact the main research put forwards by the government in both the Consultation document and the Draft Plan, divulges that the problem is far worse than previously thought, regarding diesel emissions but not petrol. Under Euro 3 scope in 2000, the discrepancy between claimed emissions and actual real emissions was about double, or x2; under Euro 4 (200%) this became a 3x discrepancy; under Euro 5 (2009) this became a 4x discrepancy; under Euro 6, the supposedly golden standard that will have unfettered access to any Clean Air Zone - even charging ones such as London's ULEZ - the discrepancy if a whopping 7.5x.
Euro 6 mandates nitrogen dioxide emissions of 0.08 grams per kilometre driven, but the real world average measurement is coming out at 0.6 g/km, approximately 7.5 times more. The government knows this, and while it is politically impossible to suddenly ban diesels, that is the implication of the government's own evidence on the subject and reflected in its proposal to '...to avoid purchasing diesel vehicles wherever possible' in all public sector and local authority purchasing.
The key graphic to the revised Air Quality Plan is this one:
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| Scoop: The government shows the problem to be much worse than it has ever admitted in the past. |
I'd like to know what evidence the government has used to generate these figures, but recent real world testing by the consultancy Emissions Analytics, commissioned by the International Council on Clean Transportation (ICCT - the US group who busted VW), suggests that this data is exactly correct. EURO 6 is not worth the paper it is written on. As such we would entirely expect the government to stop using it as the basis for Clean Air Zones, where concerning diesel engines, as soon as the new World Light Duty Test Procedure (WLTP) comes to bear later this year. In other words there are plenty of filthy cars being sold right now that have somehow scraped Euro 6 certification, and they will need to be banned from entry to any CAZ unless the whole zoning fall into disrepute before it has even taken off.
On a final note, while there is too much devolving of responsibility by central government to cash-strapped local authorities, whose vast range of clean air 'scope of action' is not being supported even by the mildest tweaks to the Vehicle Excise Duty (VED) regime, I accept that in some sense local authorities are best equipped to make what are ultimately local decisions. We don't really go for structured, French style 'massive change from above' here in the UK.
Viewed by a pedestrian or a cyclist or even as another motorist, tackling air quality does mean paying huge attention to detail. I leave you with one example. Ice Cream vans. They idle antiquated diesel engines with next to no emissions control all day long to keep the ice cream frozen. I can already see the local newspaper stories about how Mr Smith is going to be 'put out of business' by a fiddling local authority. But next time you are near an ice cream van consider the noisome cloud of particulate NOX-rich emissions that it produces and think about its primary customer base, children. We do have to tackle this stuff. If there is to be a scrappage or retrofit scheme it'd do well to start with ice cream vans and black cabs and other niche baddies like generators.
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| IT SHOULD SAY: CAUTION CHILDREN'S LUNGS |
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