Limbo dancing under the legal limit

We gave a short speech at the Overview and Scrutiny Committee Management meeting today on the proposed Clean Air Zone:

Thank you, Chair, for giving me the opportunity to speak to the Committee. Last year, we responded to the consultation on the proposed Clean Air Zone by saying that there was too much uncertainty in the modelling. The modelling has since been re-run and we still see uncertainty. We have submitted a report to this Committee, written by Dr Claire Holman, who is an air quality consultant. Her analysis suggests that the Council is still running the risk of failing one of Justice Garnham’s three tests, as established during the cases brought by ClientEarth – that the hoped-for improvement in air quality should be likely, not just possible.

Today you are looking at a proposal which is an attempt at limbo-dancing under the legal limit for nitrogen dioxide, in order to avoid a fine. This proposal is asking you to put your trust in data produced using certain assumptions. One of these is that diesel cars will be as clean in real life as in laboratory tests.  Another is to accept the idea that the limited options proposed by the City Council will effect lasting change and protect our health.

As you know 40ug/m3 of nitrogen dioxide is the legal limit. Unfortunately it is not a safe limit. The Committee on the Medical Effects of Air Pollution (COMEAP) last year advised the Government that there is, indeed, no safe limit for exposure to nitrogen dioxide.

We recognise that the City Council has been put in this position by the Government’s attempt to comply with the legal limit. The pressure to act has resulted in an inadequate and sadly underfunded instruction from the Minister.

When you look closely at the points of exceedance on the map of Southampton, it becomes obvious that it is not sufficient to work solely within the City boundary. 50,000 people leave the city each day for work and 50,000 come in to Southampton to work. One million containers arrive in the city each year. Over three million cruise and ferry passengers come here each year. Air pollution has no boundaries and many people who live along the city boundary and may be in a neighbouring authority are receiving no consideration at all. This is because the M27 and M271, the most polluted locations, are under the management of Highways England. A major failing in this proposal is that there is no clear plan for working with Highways England, who have a £100m Air Quality fund, and who could benefit the city enormously if they could think of solutions for the roads they manage.

We will be writing to our local MPs to ask them to raise a Parliamentary Question to find out what Highways England are doing to ensure compliance along the motorways, as this is so important for the City.

Ironically, the proposed Class B Clean Air Zone would, according to the Council’s own analysis, have helped to reduce the pollution problems on the surrounding motorways and ultimately benefitted us all by offering more of a chance of delivering a healthier environment. The cost-benefit analysis shows the net benefit of implementing a Class B Clean Air Zone is in excess of £15m over the period 2020 to 2030 and also avoids the deliverability risks of non-charging options. Why was this dismissed during the decision-making process?

The list of actions proposed by the City Council are acknowledged in their report to have a negligible effect on air quality. We would have wished for more imaginative and effective ways of intervening than those presented. We strongly urge this Committee to reconsider the whole proposal and suggest measures which would have more impact on air quality in the City be added. It will be 2021 before we know if these limited proposals have had any effect on air quality in Southampton and our children and grandchildren are relying on us to take wise decisions.

We have further outstanding questions about the modelling used and have asked the relevant authorities for further information. We hope to receive this in the next few days. We will be happy to share this with you.

Thank you.

Liz Batten, Mandi Bissett, Colin MacQueen

Clean Air Southampton

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