Pollution (London)

Part of Oral Answers to Questions — Environment, Food and Rural Affairs – in the House of Commons at 10:30 am on 17th July 2008.

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Photo of Jonathan R Shaw Jonathan R Shaw Parliamentary Under-Secretary (Marine, Landscape and Rural Affairs) and Minister for the South East), Department for Environment, Food and Rural Affairs 10:30 am, 17th July 2008

I am grateful to my hon. Friend, who sets out the concerns of his constituents in Edmonton about air quality. We have an air quality strategy, which sets out its purpose in London and the responsibilities of the Mayor. As I have said, I am more than happy to meet the Mayor to discuss how he, the Greater London authority and the Government can work best to reduce air pollution in London. My hon. Friend will know that London is a heavily polluted city, and that that pollution is principally brought about by traffic. What would life be like without the congestion charge in those parts of London? Pollution would be considerably higher.

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Simon Birkett
Posted on 18 Jul 2008 6:17 pm (Report this annotation)

Dear Minister

Thank you for making clear your willingness to meet Mayor Johnson to discuss London's serious air quality problems and 'ensure that [your] diary is available to him'. Given the importance of this subject, please do more and request formally an urgent meeting.

You have rightly expressed concern about 'what life would be like without the congestion charge in [the western extension of the zone (the WEZ)]'. The excellent London Air Quality Network shows that particulate matter (PM10) air pollution has dropped below the European Union Limit Values in some areas of the WEZ since congestion charging was introduced there.

The United Kingdom (UK) has an obligation under Council Directive 1999/30/EC Article 1 to 'maintain ambient air where it is good and improve it in other cases with respect to sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead'. This obligation has been 'transposed' into UK law in The Air Quality Limit Values Regulations 2003 in Regulation 15, paragraph 2 (see page 8). By referring in the latter to 'zones' it may not have been transposed correctly - perhaps exposing the UK to infringement action by the European Commission.

In the considered view of the Campaign for Clean Air in London (the CCAL), the government has a clear statutory duty (and obligation as a Member State) inter alia to ensure that PM10 air pollution does not rise again above the EU Limit Values in the WEZ where it has fallen below those levels - as it surely would if road pricing was removed from that area (unless simultaneously other measures were put in place to mitigate fully its removal). Please will the Minister confirm that the government will take action to ensure that all its obligations to protect public health will be met fully in the WEZ - if necessary, by forcing Mayor Johnson to keep road pricing in the WEZ?

Please be in no doubt, substantial other measures too must clearly be taken urgently for the UK to comply in London with WHO-based air quality laws.

Please will one of the MPs who participated in this oral debate take up this matter with you again.

I look forward to seeing an early response from you.

With best wishes.

Yours sincerley

Simon Birkett
Pricipal Contact
Campaign for Clean Air in London

p.s. by way of briefing for your meeting with Mayor Johnson, please see below the full text of a letter sent to him on 13 July 2008 by the Campaign for Clean Air in London. The CCAL believes that the current congestion charging zone is the bluntest and therefore worst form of road pricing but that it is much better than no road pricing (e.g. not least as shown by the 10-15% reduction in traffic volumes in the area). The CCAL urges the government to play its full part, not 'hamstring' Mayor Johnson, by: facilitating a 'tag and beacon' scheme in parallel with the current congestion charging scheme (i.e. as an alternative for road users); and setting standards for the abatement of oxides of nitrogen (and particulate matter) to Euro 4/IV equivalent standards - so than an additional, inner, Low Emission Zone can be introduced in London (not unlike those planned in scores of other cities across Europe) to address, most cost effectively, the areas of the city that are actually in breach of World Health Organisation (WHO) based air quality laws. It is irresponsible of the government to fail to set national standards for road pricing or the abatement of emissions when several UK cities are affected by the same problems (e.g. in respect of nitrogen dioxide).


Boris Johnson
Mayor of London
Greater London Authority
City Hall
The Queen’s Walk
More London
London SE1 2AA

By email: mayor@london.gov.uk

13 July 2008

Dear Mayor Johnson,

***Proposals to improve London’s air quality***

You will be aware that the new European Union directive on ambient air quality and cleaner air for Europe (the new AQ Directive) requires sharp reductions in air pollution in London by January 2010.

In this context, it is time that you announced the measures that your administration will take to ensure that air quality laws will be complied with in London. It is not good enough, more than 10 months after you launched your campaign to become Mayor of London, that you have not announced a single, significant, new policy that will ensure London plays its part in ensuring that air quality laws will be complied with fully in London. Worse even than taking no action, you have acted seemingly to withdraw or ‘threaten’ existing air quality measures.

The purpose of this letter is to prompt you to take action to improve London’s air quality.

***Road transport causes all the breaches of air quality laws in London***

The government has admitted that road transport is the cause of all the breaches of air quality laws in the United Kingdom (UK) with diesel emissions being by far the biggest single component. The solutions involve two overlapping ‘circles’ of measures – one for congestion and the other for emissions - that target the most polluted areas with technology-based solutions and create a ‘tipping point’ of behavioural change backed by awareness, persuasion, incentives and regulation (when necessary). Behavioural change offers the most cost effective solutions.

***Proposals to reduce congestion***

In the congestion ‘circle’, road pricing is essential, fair and much needed in areas like central and west London, to tackle congestion and ‘make the polluters pay’ since vehicles produce less than half as much air pollution once their speed reaches 30 kilometres per hour. It should operate seven days per week in the most polluted areas. The Central and Western Extension of the Congestion Charging Zone (together the ‘CCZ’) should operate as two co-ordinated, independent, schemes i.e. people should be charged to cross between zones and resident discounts in each should apply only for one of the two zones.

A fair policy would ensure that the ‘polluters pay’. Trucks and coaches should pay substantially more than cars. Why is it that the ‘icon’ of free markets, New York City, can propose a charge of $21 for trucks and coaches (compared to $8 for cars) while such vehicles in London can pay less than cars through a fleet discount mechanism? Motorcycles should pay a modest amount, perhaps £4, to drive in the CCZ since they are among the most polluting vehicles. The London Atmospheric Emissions Inventory (LAEI) Second Annual Report (for 2003 that was published in August 2006) estimated that motorcycles will generate some 19% of all fine particulate matter (PM2.5) from road traffic in the most polluted areas in 2010 and much higher still proportions of other pollutants, such as benzene (87%), butadiene (65%), non-methane volatile organic compounds 65%) and methane (34%).

A ‘tag and beacon’ road pricing scheme should be offered in parallel with the current Congestion Charging Scheme so that vehicles that drive little and outside the times of congestion can register and pay nothing. If the government will not set inter-operability parameters for a national scheme, London must proceed on its own and blame the government for subsequent problems that arise for road users elsewhere in the UK.

The Campaign for Clean Air in London (‘CCAL’) urges you also to tackle other causes of congestion not least at weekends when it is particularly bad e.g. by removing free parking at weekends in central London. You should also ensure that unnecessary roadworks and unnecessary closures of arterial roads are not allowed e.g. the frequent closure of South Carriage Drive in west London. The CCAL supports a 20 miles per hour speed limit in residential streets.

Please ensure that any consultation or survey conducted about the future of the Western Extension to the Congestion Charging Zone (WECCZ) makes clear not only the substantial benefits that have arisen from this scheme (e.g. in terms of lower traffic volumes and reduced congestion) but also that, without effective road pricing, it is likely to be necessary to ban, by 2010, a much higher proportion of the most polluting vehicles from these areas than would otherwise be the case. As you know, the CCAL wrote to Commissioner Dimas (copying you) on 5 May 2008 pointing out that the removal of the WECCZ could breach Article 12 of the new AQ Directive. You should decide now to keep and toughen the WECCZ.

***Proposals to reduce emissions***

In the emissions ‘circle’, we need urgently an additional, inner, Low Emission Zone (LEZ) at least in central and west London to reduce harmful emissions. This should require all diesel vehicles entering the zone to match Euro 4 engine emissions standards for both particulate matter and oxides of nitrogen by 2010. The CCAL supports requiring petrol engined vehicles to match at least Euro 3 engine emissions standards for both particulate matter and oxides of nitrogen by 2010 (since these vehicles are much less polluting than their diesel counterparts). An inner LEZ must include all vehicle categories to be ‘fair and effective’ e.g. motorcycles, cars, trucks and coaches. It will join dozens of similar schemes around Europe which target the most polluted areas of large cities. See: http://www.lowemissionzones.eu/. London’s existing blunt, broad scheme is not enough on its own.

Please press the government to set urgently national standards for the abatement of emissions of oxides of nitrogen from older, particularly diesel, vehicles (to meet Euro 4 emission standards for diesel and Euro 3 emission standards for petrol) since these standards could then be adopted uniformly across the UK to address expected breaches of air quality laws for NO2 in a number of cities. If the government will not set such standards, London must proceed on its own and blame the government for subsequent problems that arise for road users elsewhere in the UK.

Emissions from taxis are estimated in the LAEI to cause some 37% of the most hazardous road transport emissions (exhaust PM2.5) in the most polluted parts of London in 2010. The previous Mayor’s Taxi Emissions Strategy expires this month with nothing to replace it. Instead of weakening controls on taxis as currently seems to be the case, you should require all licensed taxis driving in the most polluted areas to meet Euro 4 emissions standards for particulate matter and oxides of nitrogen by 2010. Taxi users should contribute financially to the necessary expense.

Please pursue vigorously other measures that might reduce vehicle emissions at source e.g. technology solutions that can be retrofitted to vehicles to shut off engines when idling for more than a few seconds. Such an approach should be combined with action by local authorities to ‘blitz’ unnecessary engine idling. The Royal Borough of Kensington and Chelsea commented in its Local Air Quality Management, Air Quality Action Plan Update 2008 that “in 2007 [its] enforcement officers attended 38 complaints and have warned drivers to switch off their engines and they have done so in every case”. We have asked the City of Westminster whether it operates a similar scheme. Clearly, such action should be taken hundreds of times per annum, not just dozens of times, in each of the most polluted boroughs.

***Other measures to improve London’s air quality***

As well as much needed road transport measures, it is essential that other actions are taken to improve air quality. These include:

• Increasing public awareness of the extent of air quality problems and their health impacts and helping people, through education, to understand the part they can play in improving air quality by the choices they make;
• Encouraging modal shifts to less and non-polluting modes of transport e.g. walking, cycling and public transport;
• Encourage the take-up of more efficient domestic and other boilers;
• Reducing substantially the number of festival bonfires; and
• Ensuring compliance at least with the ‘Best Practices Guidance: For the Control of Dust and Emissions from Construction and Demolition’.

A broad, holistic strategy is needed now that will address fairly and effectively the actual underlying causes of London’s air quality problems. Please ‘aim ahead of climate change’ and do not be a ‘busy fool’ who pursues a myriad of polices that achieve little or nothing.

Only the government and you have the resources necessary to determine the complete, necessary, package of measures and the time by which each element must be implemented to ensure that air quality laws will be complied with fully in London.

***Take action now or others will soon force you to do so***

There are clear environmental, social and economic reasons for improving the UK’s air quality quickly. Despite this, you seem to have shown yourself unwilling, after 10 months, of mustering even the political will needed to tackle London’s air quality problems. Do not listen to the same siren voices that argued against the creation and enforcement of the Clean Air Act introduced in 1956. London needs a new approach from you, by the autumn of this year at the latest, that will give stakeholders of all types, whether from business, the non-governmental sector or citizens generally, the certainty and time necessary to play their full part in delivering the required changes in the most cost effective manner.

Failing urgent action by you, the Campaign for Clean Air in London shall have to urge: the European Commission to take robust action against the UK to defend World Health Organisation-based air quality laws; and the UK government to require you to take action.

I would be pleased to meet you to discuss these proposals. In any event, I look forward to hearing from you.

Yours sincerely

Simon Birkett

Principal Contact
Campaign for Clean Air in London



Commissioner Dimas, Environment DG
The Rt. Hon. Hilary Benn MP, Secretary of State for Environment, Food and Rural Affairs
The Rt. Hon. Ruth Kelly MP, Secretary of State for Transport
David Cameron MP, Leader of the Conservative Party
John Bowis MEP, Conservative
Jean Lambert MEP, Green
Baroness Ludford MEP, Liberal Democrat
Claude Moraes MEP, Labour
Richard Barnes AM, Statutory Deputy Mayor and Leader of the Conservative Group
Len Duvall AM, Leader of the Labour Group, London Assembly
Darren Johnson AM, Green, Chair of the Transport and Environment Committee
Mike Tuffrey AM, Leader of the Liberal Democrat Group, London Assembly
Valerie Shawcross AM, Chair of the Transport Committee, London Assembly
Tim Hockney, Executive Director, Transport, London First
Councillor Colin Barrow, Leader of the Council, City of Westminster
Councillor Merrick Cockell, Leader of Kensington and Chelsea Council

Simon Birkett
Posted on 18 Jul 2008 9:40 pm (Report this annotation)


Please note that the UK was in breach of air quality laws for particulate matter (PM10) in 2005, 2006 and 2007. It will remain in breach until it obtains a 'time extension' from the European Commission under the new EU directive on ambient air quality and cleaner air for Europe that entered into force on 11 June 2008 (the new AQ directive).

Council Directive 1999/30/EC relating to limit values for various air polllutants is repealed by the new AQ directive with effect from 11 June 2010.

Simon Birkett
Principal Contact
Campaign for Clean Air in London

Simon Birkett
Posted on 20 Jul 2008 11:44 am (Report this annotation)

Addendum 2:

By way of example, you will see from the links below to the excellent London Air Quality Network site that annual average levels of particulate matter (PM10) [air pollution] fell from just on the EU Limit Value in 2006 (i.e. 40 micrograms per cubic metre - ug/m3) to 35 ug/m3 in 2007. 2007 included nearly 11 months of the western extension of the congestion charging zone. The number of days exceeding 50ug/m3 fell from 60 to 26 in the same period (with the EU Limit Value for exceedances being 50) i.e. Cromwell Road moved from non-compliance to compliance for PM10 in 2007.





2008 (so far)


Simon Birkett
Principal Contact
Campaign for Clean Air in London