Summary Section. London Sustainability Exchange response to the Clean Air Zone (CAZ) Consultation

Transcription

1 London Sustainability Exchange response to the Clean Air Zone (CAZ) Consultation Section Detail - Pledge London Sustainability Exchange (LSx) Comments Summary Section CAZ Boundary (P4) We are proposing a Clean Air Zone, where the most polluting vehicles will have to pay to enter the city centre: all the roads within the A4540 Middleway ring road. The communities are glad to see that Birmingham is proposing introducing the highest class of CAZ (Class D) for the city centre to reduce pollution levels and aid its citizens' health. It was felt that this could go further as our pollution monitoring has indicated that there are also high pollution levels outside the city centre and we would urge the council to take action in a wider area. This could be by implementing an additional CAZ covering the surrounding areas of the city centre zone at a lower class or by incrementally increasing the size of the zone to encompass a wider area of the city. CAZ Charging Model (P4) Other Actions to reduce vehicle pollution (P4) Charges would apply to most vehicles whose engine does not meet specific pollution standards: including buses and coaches, lorries, vans, cars and taxis and specialist vehicles like bin lorries. Vehicles with a clean enough engine would not be charged. We are also suggesting other ways to reduce the air pollution caused by motor vehicles, including improving public transport, upgrading engines and building more low-emission refuelling stations (e.g. electric charging points), making changes to roads and reviewing charges for parking. We would hope that Birmingham Council will guarantee that the funds collected will be used to improve air quality through activities such as improving public transport and cycling infrastructure and reducing fares for public transport to encourage shifts away from private cars. We would also request that existing funding for those areas will not be cut as a result. Currently Birmingham has one tram. In terms of light rail infrastructure Birmingham is way below similarly sized or even smaller cities in the major European economies. What are the plans to increase (not just extend) the light railway network to replace buses and increase the overall use of public transport? Page 1 of 10

2 Consultation Content NO2 Targets and predictions by hotspot (P5) No level of NO2 is safe, but our first goal is to bring the average levels lower than 40μg/m3 as soon as possible. The hotspots where the problems are worst are:location / Level of NO2 in 2020 if we take no actiona4540 Lawley Middleway to Garrison Circus / 46.9μg/m3A4100 Digbeth / 46.4μg/m3A38 Lancaster Circus to Dartmouth Circus / 46.6μg/m3Suffolk Street Queensway near Beak Street / 48.8μg/m3 Community groups in the Ward End and Sparkbrook areas of Birmingham took measures around the city area and found the following high results: New Coral Street, 01/05/18-20/05/18, 74.21μg/m3 Keely Street B9 4HQ, 30/04/18-22/05/18, 50.49μg/m3 Bromford Lane, 05/05/18-23/05/18, 93.33μg/m3 Stratford Road, B11 1QS, 03/05/18-18/05/18, 62.80μg/m3 Stoney Lane Balsall B12 8AW, 03/05/18-22/05/18, 42.50μg/m3 Although these results are only results from a single period of a few weeks, these results have been annualised and indicate that outside the proposed CAZ are areas that exceed the limits and should therefore also be considered in air quality actions. The NO2 measurements taken by the council are primarily in the city centre but the results we have found suggest that more monitoring needs to be done to locate traffic hotspots outside the city centre to assess whether the CAZ area needs to be expanded. In addition, the council needs to ensure that the creation of a CAZ does not lead to migration of traffic and pollution to other areas currently outside the CAZ. Areas such as Balsall Heath and Sparkbrook that are already close to the legal NO2 limit may exceed it once the CAZ is introduced, as is indicated in our results from these areas: Mary Street B12 9ST Balsall Heath, 03/05/18-16/05/18, 37.39μg/m3 Court Road Balsall Heath B12 9LQ, 03/05/18-16/05/18, 32.62μg/m3 Colville Road Sparkbrook B12 8EH, 08/05/18-22/05/18, 38.15μg/m3 Runcorn Road, Sparkbrook B12 8RQ, 02/05/18-16/05/18, 36.88μg/m3 Any location with risk groups (i.e. hospitals, schools etc.) in and outside the CAZ area should be constantly monitored for pollutions levels to ensure levels are reducing or actions are taken to protect those areas. Page 2 of 10

3 Current Actions (P8) We have already started Birmingham s journey to cleaner air: Public charging points for electric vehicles. More park and ride spaces. Improvements to buses, including approved plans to try running buses fuelled with hydrogen. New and improved cycling routes. A new policy on taxi emissions and registration. Massive investment in public transport in the coming years, including new SPRINT rapid bus routes, extensions to the Metro network, improvements to local rail services and the construction of High Speed Rail between Birmingham and London. To ensure that the council is leading by example the council should ensure that particularly the council fleet should be environmentally friendly, therefore it would be important to share the emission levels of the current public transport and council fleet. The 'Current Actions' should be rolled out across the whole of Birmingham, not just the city centre. There are concerns expressed by community members that the cycle highway is unsafe. This indicates that more needs to be done to tackle these concerns. Page 3 of 10

4 Where? (P8) When? (P9) When setting a boundary for our CAZ, we need to make sure that: Areas of high pollution are dealt with. The CAZ is big enough so that we don t simply move the pollution further downthe road. It is a sensible boundary and clear to everyone where it starts and ends.for this, we think that the CAZ should include all the roads within the A4540 Middleway ring road, but not the Middleway itself. Looking at figure 1, the worst hotspots are in this area, although there are still some high levels of NO2 on the east side of the ring road and on the motorway near Gravelly Hill Interchange (M6 junction 6, Spaghetti Junction). We think that CAZ charges should be in place all day every day. Although there are fewer people around in the middle of the night, pollutants take time to disperse so some will still be in the air the following morning. Our targets are also measures of the maximum average amount of pollution in the air, so every emission counts. The results indicated above demonstrate that there may be more pollution hotspots outside the proposed zone which also need to be addressed. It is vital that a CAZ does not displace the pollution to areas outside of the zone. Therefore, actions need to be taken to mitigate this. For example, improving the flow of traffic and reducing congestion on Stratford Road and at the Washwood Heath Road/Bromford Lane crossroads, promoting and providing suitable and safe infrastructure to encourage cycling and walking throughout the whole city. It is commendable that Birmingham is proposing implementing a Class D CAZ - the only city of the five cities currently mandated to implement a zone by 2019 who has opted for this class of zone. However, the area is small. As illegally high levels of pollution are not only in the city centre, we would recommend a couple of options to mitigate this: - A two-phase implementation of the CAZ - similar to that of the Ultra Low Emission Zone (ULEZ) in London. The initial ULEZ will be implemented in central London and will then be expanded to the North and South Circular roads from Therefore, using this model, Birmingham could aim to expand the zone over the next two or three years to reach more pollution hotspots. - A two-part CAZ. This could comprise of a Class D zone in the proposed area of central Birmingham alongside a Class A-C zone in the wider area. For example, both Leeds and Southampton have opted to focus their CAZ on a wider area of the cities which is likely to have a broader impact, although fewer vehicles have been included in the zone - a Class D zone in central Birmingham would still be recommended. We agree that the CAZ should be in place at all times and, given this, it would be important to ensure that there are then available transport options at all times (for example 24/7 buses) Page 4 of 10

5 Who? (P9) Who - Type of Engine (P9) Who - Type of Vehicle (P9) CAZ charges are based on the vehicle and not the person driving or any passengers or goods being carried. Charges depend on the type of vehicle (e.g. car, bus, taxi, lorry) and what sort of engine it has. Engines can be sorted by fuel type (e.g. petrol, diesel, electric) and by Euro standard, which describes how much pollution the engine may emit. The higher the Euro number, the newer and cleaner the engine. The engine standards for a Clean Air Zone are set nationally, this is not something which we can decide for Birmingham. You will not have to pay to drive in the Clean Air Zone if your vehicle has: A diesel engine of Euro 6 (VI) standard or better (most new registrations after 1 September 2015). A petrol engine of Euro 4 standard or better (most new registrations after 1 January 2006). A hybrid, electric or LPG engine. For motorcycles/moped, the engine needs to be Euro 3 or better. We tested a number of options for which types of vehicle should have to pay a charge and found out that to make a measurable difference to air quality, all vehicle types will have to pay to enter the Clean Air Zone (if their engine isn t clean enough), including buses, lorries, vans, taxis and private cars.so far, we have not considered whether motorcycles/mopeds should be charged. CAZ charges do not impact everyone equally and, in the extreme, can free up the roads for those who can afford to pay. This needs to be taken into consideration. We support the proposal of a CAZ Class D. Excluding mopeds / motorcycles from the CAZ charge may lead to a shift away from car to those less pollution modes of transport.since mopeds / motorcycles have different types of engines (2 stroke or 4 stroke) it would be interesting to understand what their actual pollution levels are and how they compare to a half loaded bus (Would that be a representative average load factor?) on a passenger count basis. Such research may support a decision on whether to charge or not or what type to charge. Page 5 of 10

6 How Much? (P10) Support for organisations and individuals to Help (P10/11) Remember that a vehicle whose engine is clean enough will not have to pay anything. Vehicle type / Daily charge Bus/Coach / 50 to 100 Lorry (HGVs) / 50 to 100 Taxi and private hire / Van (LGVs) / Private car / 6 to Small and medium sized enterprises (SMEs) operating in the CAZ area: Discounted charges for business vehicles registered to SMEs which enter the CAZ on regular (e.g. twice or more per week) basis. Businesses and organisations in Birmingham: Travel planning support to review fleet vehicles and deliveries, and to help staff change their travel habits. Taxi operators: A council run scheme for leasing Low Emission Vehicles, e.g. electric taxis. Financial incentives to upgrade engines or replace vehicles. People living in or close to the CAZ area and having limited income: Extra time before being charged to use the CAZ. Day Pass Metro & Bus: Peak: PAYG / Off-Peak (after 9:30): Parking in the city centre is: Up to 1 hour: 3.00, Up to 90 Minutes: 3.50, Up to 2 hours: 5.50 In order to disincentivise driving private vehicles into the city centre (arguably the most convenient mode of transport being door to door, able to transport heavier goods such as shopping and not restricted to a timetable etc.), public transport should be a cheaper alternative. However, given the current costs of a day pass for metro and bus compared with proposed CAZ charge and city centre parking, private cars still work out cheaper if more than one passenger is travelling. This is an important consideration and indicates that either city centre parking or the CAZ charge could be higher. The discount should only available for a period of time for those businesses to consider less polluting vehicles in the future How will that be managed? What are the targets set for those businesses / organisations? What are the repercussions if behaviour does not change? Should only be for a limited period of time for adoption Had similar considerations been given when parking charges had been introduced? Should only be for a limited period of time for adoption - we would however understand if this period is longer than for businesses. Had similar considerations been given when parking charges had been introduced? Page 6 of 10

7 CAZ costs and income (P12) Disabled people who find it difficult to use public transport: Extra time before being charged to use the CAZ. Financial incentives to improve wheelchair accessible Hackney taxis, by upgrading the engine or replacing the whole vehicle. Disabled, older and younger people: Extra time before being charged to use the CAZ. People attending worship in the CAZ area: Travel planning support for places of worship to help worshippers change their travel habits. Parents and guardians of patients at Birmingham Children s Hospital:Time limited and/or means tested discounts on charges for long stay patients (as currently in operation for parking). Ask for funds from Gov'ts Clean Air Zone Implementation fund 1) Income used to fund the scheme 2) Remainder to further improve Air Quality (Public Transport, Cycling, Waling and support for local businesses and individuals) We agree It is important to know how 'older' and 'younger' are defined and how this will be monitored particularly if they use vehicles that are not registered in their name or if parents start using the vehicle registered in their child's name... Will this work similarly to the young persons and senior railcards? It is unclear why those visiting places of worship should be exempt. If there are concerns about suddenly applying charges to those attending worship, perhaps a sunset period within which support was offered to encourage modal shifts would be more appropriate? We agree with this consideration but it needs to be clear how this can be monitored. It needs to be guaranteed that the funds collected will be used further improve the air quality of Birmingham. Furthermore, it needs to be guaranteed that existing funding into public transport and air quality initiatives won't be cut due to the "new" income. Page 7 of 10

8 What else? (P12) We could (P13) Play Your Part (P14) When we tested what is likely to happen if we introduce a Clean Air Zone, we found that levels of NO2 in the air will come close to the goal of 40μg/m3, but this is still not quite enough. We need to consider other ways to get the most polluting vehicles off our roads and to make sure that all vehicles give out as little pollution as possible. Work with bus companies and Transport for West Midlands (TfWM) to improve vehicles and services and to encourage more bus travel, e.g. lower fares. Build more low and zero emission refuelling stations, including charging points for electric vehicles. Work with partners to develop approved schemes for upgrading the engines of taxis, buses and lorries. Make changes to roads, e.g. build more bus lanes and cycle routes, change junctions or roads to encourage people to take a different route. Review charges for parking, e.g. charge for parking which is currently free. Review traffic management e.g. how road space is used, sequencing of traffic lights, direction signs. Change the way you travel: by leaving your car at home and choosing to cycle, walk or use public transport, you can help reduce air pollution by 20%. Would the council consider banning certain vehicles - A phased approach could be considered A fairer diesel scrappage scheme could assist, if suitable funding could be provided. This would mean individuals not only qualifying when buying a new car but also when selling a car to use public transport (to receive discounts on public transport) or to only use car from car club for occasional use (to receive discounted membership or discount on hiring electric vehicles?) As per the Clean Air Strategy 2018 issued by DEFRA, councils need to commit to meet WHO guideline levels by 2025 and outline how they plan to achieve that, therefore more needs to be included with CAZ to explain how these guidelines will be met within the timeframe. This would be an opportunity to make it more cost effective to use public transport over a car. All these actions are good and should be rolled out, particularly improving public transport services and cycle infrastructure to encourage modal shifts We support the initiatives and would like to understand how Birmingham council plans to engage with its citizens to change their behaviour Page 8 of 10

9 What Happens Next? Change the time you travel: if you must use the car, avoid morning and evening rush hours: this will reduce congestion and produce less pollution as a result of you not idling in traffic jams. Change the routes you travel: if you are cycling or walking, avoid main roads and choose routes using quieter back streets, parks or canals. Even walking on the side of the pavement furthest from the road can help reduce your exposure to air pollution. Change the way you drive: driving economically, such as accelerating gently and sticking to speed limits, uses less fuel, saves money, reduces the risk of having an accident and reduces air pollution. The school run: cycling or walking to school with your children will help reduce the impact of air pollution. If you do have to drive, then turn your engine off when waiting. We will read and consider all your feedback. We have to present plans for improving Birmingham s air quality and introducing a Clean Air Zone to the Government in September Your responses to this consultation will help us write those final plans. We will also publish a report on everything we have learnt from you in this consultation. The Clean Air Zone will be built in 2019, installing cameras and preparing and testing all the systems. We would start charging vehicles in January Yes, these points are important - we can all do our part. We would recommend that in order to achieve this, investment should be made to encourage behaviour change through effective social marketing campaigns, particularly to discourage no idling outside schools and cycle/walk to work/school schemes Page 9 of 10

10 Timescale Consultation into Clean Air Zone proposals begins Tyseley Energy Park opens Electric vehicle charge point network partner appointed 2018 Erfington Compressed Natural Gas refuelling hub opens Hydrogen bus pilot begins A34 and A38 cycle routes completed Clean Air Zone approved Council fleet vehicles continue to switch to greener alternatives Metro Centenary Square extension opens 2019 Taxi emissions policy takes effect Commercial vehicle electric vehicle charge point network completed Clean Air Zone implementation Perry Barr CNG refuelling hub opens Metro Edgbaston extension set to open 2022 New Sprint Rapid bus routes launch Metro Eastside extension set to open We recommend requiring a re-assessment period in 2022, when a complete evaluation of the boundaries of the Clean Air Zone, the charging rates and the vehicles included can be undertaken to ensure continued improvement of air quality within all areas of high pollution. This is particularly important given that current actions are not anticipated to meet WHO targets before About LSx London Sustainability Exchange (LSx) ( ) is a think and do charity which creates collaborations that address the complex barriers to sustainability. Our projects provide action-based community development and research to develop, and in turn share the lessons from our work and, most importantly, influence policies for a sustainable future. Response informed by discussions with residents in Ward End and Sparkbrook. Contact us For more information contact Alice Vodden on or A.Vodden@LSx.org.uk Page 10 of 10