Oxford City Council Air Quality Action Plan 2013 Consultation
Although we are pleased there is an attempt at an Air Quality Management Plan, we consider that given EU safety limits, this plan is inadequate given the scale of the pollution problem. We also consider that the problems of increased traffic and increased carbon emissions are hardly dealt with at all in any manner that would deliver adequate and beneficial targets or reductions in traffic. As an Action plan it needs to spell out in detail all possible means for reducing pollution rapidly long before 2025.
We have examined this plan and have the following more detailed comments to make.
In overall terms given the severity of the effects to health we feel that 2025 is far too late a date to bring levels mean concentrations of NO2 down to European safety levels of 40μg/m3. Action needs to be taken now to bring about safe levels rapidly.
Although pollution in the City centre is a major problem, we are unhappy of the coverage in the report on other hotspots and the resulting inattention to any specific measures that might improve the situation in those areas. We are thinking particularly of district shopping centres and major junctions on the road network. Great attention needs to be paid to readings along all the radial routes into the City centre. Looking at the map of diffusion tube sites the inadequacy of information becomes very apparent. A pollution concentration target for the city centre as well as the overall mean is not enough. Pollution must be measured at all major junctions, at all shopping centres – Cowley Road, Headington, Summertown, Cowley centre and along the radial roads leading into Oxford and all known hot spots. We do not think it is adequate to state that “the extent and location of our monitoring sites will be reviewed to ensure that they are appropriate for extent and scale of our AQMA, are fit for purpose and meet best practice approaches in line with other Councils and cities in the UK”. This should be done as part of this plan and of urgency.
We believe there should be a sustainable city wide travel strategy but the measures in our view are not in any sufficient to achieve this. They must go beyond LTP walking and cycling and bus and park and ride strategies and the development of travel plans with organisations. The City and County’s role and powers as a planning and transport authorities need to be exercised beyond the measures put forward. They need to ensure the transport implications of significant developments do not increase as a result of development. The City should be committed to out rightly refusing planning permission for developments that will lead to levels of pollution over EU safety limits in the roads and areas affected by the proposals.
To bring this about we consider air quality assessments should be a mandatory part of consultations on major planning applications and planning applications in pollution hot spots or likely to lead to higher levels of pollution. We were disappointed that this information was not required for the Tesco development at the Fox and Hounds, a pollution hot spot and a development that would lead to more cars queuing at peak times to access the car park that polluted junction. We understand a planning application was refused at appeal in Sheffield which would have led to increased pollution levels (Appeal Ref: APP/J4423/A/10/2143547 180 Archer Road, Sheffield, South Yorkshire, S8 OTD). The coming Westgate outline application is one where a thorough assessment of the effects of traffic on all roads accessing the site and where at no point should it be attempted to be argued that possible reductions in one area merit increases in pollution levels in another.
Further measures such as road pricing and low emission zones covering a much wider area of the city and a wider range of vehicles (especially diesel powered vehicles) need to be seriously considered. Real reductions in the volume of traffic need to be brought about and reductions in one area that lead to increases in other areas should also be curtailed. We are very concerned again about developments like the Westgate that are likely to increase the frequency of traffic movements into Oxford. The focus should also be not just on reducing pollution from buses in the city centre and on radial routes; reduction in car traffic is required in many areas. Here we can mention in the city centre itself amongst many other streets, Hythe Bridge Street (to and from Station and highly used), Worcester Place (used by locals and students on foot and bicycle), Saint Giles (where pedestrians are the highest uses of the street.
In view of the considerable dangers to health of pollution the City Council should ensure that the locations of this pollution throughout the City and widely publicised and made known to the general public which is more likely to ensure that effective measures are taken to reduce pollution in the worst affected areas. We do not think it is enough for this document to state it is also considering the extent to which this information is communicated to Oxford residents and wider stakeholders. It needs to put forward specific proposals about how this can be carried out. We would suggest readings our displayed regularly at all hot spots and that there are warnings displayed when pollution is over danger levels. We also thought the electronic postings in council office that occurred formerly were good and that are possible opportunities for schemes of this type in other public buildings. There also needs to be much more media coverage of pollution in Oxford and its effects on public health.
Although the plan also mentions a target of 35% reduction in transport CO2 emission from 2005 to 2020, as well as the unsatisfactory reduction targets in pollution levels, we are not at all sure that this problem has been explored in any way that could effectively tackle the problem or achieve the target.
We have been concerned about this problem for many years and attach in our appendix ten ways we put forward for tackling pollution in 2004. Although some of these measures have been adopted, there is still some way to go. We note particularly in you plan that “Direct emissions of nitrogen dioxide from diesel vehicles fitted with Continuously Regenerating Traps(CRT’s) has been shown to increase, particularly in larger slower moving vehicles “ Executive Summary. This is a disappointment and may account for the lack of progress despite the initiatives that have been taken with buses. Hence the reference to NOx absorption filters on exhausts in our ten point plan is significant.
Extract from Oxford Mail Archive 28th Aug. 2004
Oxford's Green Party has drawn up a pollution-busting 10-point plan after the city topped the UK's pollution league in a survey.
TEN WAYS TO TACKLE PROBLEM
- More roadside emission checks of taxis and private vehicles to catch heavy polluters
- All buses to be fitted with emission reduction technology such as particulate traps and NOx absorption systems. Buses to switch off engines when stationary
- Stricter enforcement of city centre vehicle restriction points, including High Street
- Promotion of alternative, low emission fuels such as bio-diesel and LPG
- More trees and other planting to mitigate pollution
- Introduction of centres on outskirts of city to avoid need for heavy delivery lorries to enter city centre. Smaller, low emission vans would take goods into city instead
- Better promotion of cycling and walking
- Expansion of pedestrianised area of city centre to include Queen Street.
- Introduction of citywide 20mph speed limits
- Increase city centre car parking charges in line with inflation to encourage more use of bus, train and park-and-ride car parks.