Consultation: Implementation of Clean Air Zones

Image from Greenpeace of baby in pushchair next to exhaust fumes.

DefRA (The Department for Environment, Food and Rural Affairs) is consulting on plans to implement clean air zones in 5 cities across the UK, including Birmingham. Birmingham City Council is generally welcoming the proposals, and has stated that following the national consultation, there will be a local consultation in Birmingham on what a clean air zone will be like in Birmingham. Doing something about air pollution is vitally important because there are around 900 extra deaths in Birmingham every year from this. It is not yet clear where Birmingham's Clean Air Zone would be, but it is likely that it would cover much of the city centre.

First of all we should clarify what the Clean Air Zone wouldn't be: they would not cover private motor vehicles, so there would not be any 'congestion charge', so to speak, in the London sense. Both the national consultation by DefRA and Birmingham City Council have spent time making it clear that the Clean Air Zone would not affect private drivers, but rather would be focused on commercial vehicles, including private hire cabs and taxis. This may not be as bad as it sounds - there will be less of a political backlash if private cars are excluded, and the figures for nitrogen oxides (NOx) by DefRA state that 39% of NOx on UK roads come from HGVs, LGVs and buses in the traffic on the road in question, as opposed to 24% from local cars and taxis. Yes, as you've noticed, DefRa really didn't separate the figures for taxis and private cars in their document, despite deciding to exclude private cars but not taxis from their figures. However it is clear that eliminating NOx emissions from heavy motor vehicles would have a very significant impact on air quality in Birmingham city centre.

The biggest failing of the Clean Air Zones, however, is that they are a 'zone', rather than the entire urban area. DefRA's figures show that 18% of NOx pollution is from 'Urban Background Traffic', that is, NOx blown into a particular street from the surrounding urban area. DefRA state in their document that the Clean Air Zones must be signposted properly on the approach to them, and that adequate diversions for vehicles wishing to avoid them should also be signposted. In Birmingham, that will mean that polluting vehicles will be directed to go around the ring-road, rather than through the city centre and the tunnels on the A38. While this would reduce the immediate air pollution, some of the pollution from the diverted vehicles would still drift into the city centre. In addition the shift in some motor traffic from the city centre to the ring road may encourage more private motor vehicles to shift from the ring road to the city centre. The West Midlands Integrated Transport Authority in 2015 responded to another DefRA consultation on air quality by pointing out that "the West Midlands motorways are the principal sources of exceedances affecting the metropolitan area with the vast majority of the traffic are undertaking non-local trips." It could be argued that a Clean Air Zone in Birmingham City Centre will have little impact on the air pollution affecting many of Birmingham's inhabitants.

The biggest benefit of the implementation of a Clean Air Zone would not be directly from the zone itself, but in the ways in which the up-take of Ultra Low Emission Vehicles (ULEVs) would be encouraged. Item 49 (page 8) in the draft framework document says "Local authorities and other public bodies operating within a Clean Air Zone should ensure the fleet they operate, or is operated on their behalf, in a Clean Air Zone, and ideally in the wider authority, meets the standards for the zone." Items 73 and 101 also discuss ways to ensure that the bus fleet and taxis comply with the Clean Air Zone standards, through putting requirements in the licensing agreements, etc. If the implementation of a Clean Air Zone encouraged a significant increase in the adoption of ULEVs which were then used across the rest of Birmingham, this would have a very significant impact on the air quality in Birmingham as a whole. There is a danger that the older, dirtier, vehicles would simply be used for work outside of the city centre, but if the licensing and contract stipulations covered vehicles to be used anywhere in Birmingham, that could be largely avoided.

The draft framework document, in item 68 suggests that ULEVs should get special treatment in order to encourage their use, including the use of bus lanes, exemptions from one-way systems and priority at traffic lights. While measures such as turning over parking bays to ULEVs are acceptable because they simply re-allocate space that is already there for cars, it is silly to allow ULEVs into public transport space or permit them to ignore traffic management measures simply because they are ultra-low emission. An ultra-low emission car is still a car, taking up space inefficiently on the highway, creating congestion. ULEV uptake needs to be encouraged through licensing and contracts, because they are needed across the whole of Birmingham, not just in the Clean Air Zone. Provision of charging points at parking locations is a sensible move, in order to mitigate some of the drawbacks of slow-charging times, but this needs to be done across Birmingham, not just in the city centre.

Of course, I'm now going to argue that promoting cycling is an essential part of tackling air pollution. Roughly two thirds of car journeys are less than 5 miles, and if we want to tackle the air pollution created by private motor vehicles, then shifting more of those journeys to cycles is essential. So far I've just referred to NOx pollution, using it interchangeably with 'air pollution', but in fact air pollution also consists of sulphur dioxides and particulate matter, which can be absorbed into our bodies through our lungs. While fine particles are created by petrol and diesel engines, they are also created by braking and tyre wear, with some research suggesting that brake wear contributes roughly 20% of particulate matter pollution from vehicles. The DefRA consultation states that it is hoped that by 2040, all new vehicles will be ULEV, and by 2050 almost all vehicles on the roads will be ULEVs. This is a long time-line for phasing in ULEVs, compared with the Netherlands who are debating a motion to ban the sale of new petrol and diesel cars from 2025 onwards. But even with widespread ULEV adoption, particulate matter from cars will still be polluting the air. Shifting journeys away from private cars to cycles is essential for reducing air pollution in the long-term as well as the short-term, along with the other benefits such as increased health and fitness, more freedom for children and safer local roads.

Measures to increase cycling are presented in the draft framework document. Section 2.5.2 is titled 'Encouraging Healthy and Active Travel', with item 99 suggesting that the provision of "safe, convenient, attractive and continuous cycling and walking facilities and routes" could be a potential action to reduce barriers to taking up active travel. This message was also put across in item 47, on the optimisation of traffic management, which also included safe and convenient cycling and walking networks as an option. The encouragement of e-bikes is also covered, in item 70, and even e-cargo bikes are included, in item 74. These snippets, though, are minor parts of a much larger consultation document that is focused more on how to encourage the uptake of ULEVs through the implementation of Clean Air Zones, yet while insisting that private motor traffic will not be affected.

Push Bikes does not suggest that private motor car users should be subject to charges for entering Clean Air Zones - we see this as a diversion that will not have any impact on the rest of Birmingham. Instead we argue that this consultation document should insist on, not just suggest, the implementation of a 'safe, convenient, attractive and continuous' cycling network covering the whole of Birmingham, along with equal funding to encourage the uptake of e-bikes and e-cargobikes to match the funding provided to encourage e-cars. These measures could tackle the two-thirds of car journeys that are under 5 miles, greatly impacting the roughly 30% of air pollution from private motor vehicles (24% from local cars and taxis, plus 6% estimated contribution to the 18% from urban background traffic). We have outlined how this could be done in our submission to the national Urban Congestion Inquiry that is collecting evidence now, so I won't repeat those point here.

In conclusion, while we support the implementation of a Clean Air Zone in Birmingham, we feel that the two most important things are:

  1. The insistence that local authorities build safe, convenient, attractive and continuous cycle networks, with national funding provided to support this.
  2. The use of measures such as contract agreements and licensing to encourage the uptake of ULEVs by public transport companies, local authority fleets and the fleets of their contractors, and by taxis and private hire vehicles. This should include insistence on the use of telematics to discourage excessive accelerating and braking and compliance with 20mph speed limits.

All of this must be accompanied by central government funding to ensure that local authorities are able to carry this out.