Clean Air Southampton’s response to Southampton City Council’s Clean Air Zone consultation 2018
On this page is our submission to the Southampton City Council (SCC) Clean Air Zone (CAZ) consultation 2018. It comprises a large number of comments and questions based on the background documentation provided by SCC and guidance documents from the DfT/Defra Joint Air Quality Unit (JAQU) (only available via a request under the Environmental Information Regulations). In order to be able to formulate these (as yet unanswered) questions, it has taken a significant amount of time for 2 people to read all the documents; a 2 hour meeting with the Chief Scientific Officer & Senior Communications Officer at SCC; plus attendance at 2 Open Meetings on the CAZ consultation. We have worked on air quality issues for Clean Air Southampton for over 3 years and as such are not laypeople with respect to the topic of air quality.
Our questions and concerns document is available here: https://cleanairsouthampton.files.wordpress.com/2018/09/questions-concerns-re-caz-consultation-4-sep-18-web-v3.pdf
In view of the large number of questions, we commissioned an expert review of the consultation documents. This is available here: https://cleanairsouthampton.files.wordpress.com/2018/09/1863-techncial-note_southampton-caz_31_aug_2018.pdf
We submit these comments, questions and the expert report as evidence that the consultation process was:
(a) not transparent;
(b) not accessible to laypeople; and
(c) does not meet Justice Garnham’s three tests of compliance.
We would also like to highlight the following:
- The scope of the consultation is almost entirely concerned with a discussion of the ‘preferred option’ (a city-wide Class B zone) and does not provide evidence or analysis for a more stringent class of Clean Air Zone (a Class C or D zone).
- The decision to remove a Class C or D CAZ from consideration, at some point prior to the launch of the consultation, is not clearly explained in any way in the consultation documents. Also no documentation is provided which shows the process that was followed for this decision.
- The removal of more stringent classes of CAZ as an option prior to instructing Ricardo to carry out air quality modelling (both of the current and projected situation) fails to provide a full assessment of the costs, benefits and efficacy of each of the potential options.
- The Government’s clean air policy, expressed through advice from the Joint Air Quality Unit, has forced Southampton City Council to work exclusively on meeting the EU 40ug/m3 target, in one location in the city, with no regard to the health of all citizens and the many other hot spots affecting health.
- The preferred option appears to be based on optimistic modelling, out of date data and a lack of agreement with major stakeholders (Highways England, ABP) as to emissions reductions in areas under their responsibility. To adopt an air quality plan based on such assumptions and uncertainty is unlikely to lead to compliance.
- The lack of ambition inherent in the preferred option is not only likely to lead to the EU limit value not being achieved for Southampton, but also worsening of public health outcomes for a city which already has the highest rate of emergency admissions to hospital for asthma in the whole of the South.
 Asthma UK has data showing that Southampton has a higher rate of emergency admission for asthma than anywhere else in the south of England: https://www.asthma.org.uk/get-involved/campaigns/data-visualisations#Hospitalisations (take the slider on the right of the page up to 140)