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We expect the council’s Clean Air Neighbourhoods policy to be a well-intentioned and researched policy, with its implications and unintended consequences carefully considered. There are good things in here, such as planting more street trees, improvements to street safety, and some incentives intended to discourage car use. However, on examination, few measures actually relate directly to ‘the name on the tin’ – air quality – and the one that does, only relates to around 12% of the air quality problem in Hammersmith according to Public Heath England’s figures below. This week’s smell of wood-burning stoves reminds us that the main problem here is PM2.5 particulates. Rather than deal with that, this policy would concentrate nitrogen oxide pollution where it’s highest – on main roads.
Welcome to the infamous Low Traffic Neighbourhood (LTN) debate that dare not speak its name – our council knows how toxic that is. Instead it has decided to use a heavy-handed mix of Fear, Uncertainty and Doubt, deployed with highly inflammatory headline-grabbing phrases such as TOXIC, SILENT KILLER, DEATH, in a decades-old ‘big stick’ approach. The claim of 40,000 UK annual deaths is a misappropriation of the data, which actually relates to life expectancy. Privately the council still uses the term ‘LTN’, and funds them instead of schools, with Section 106 contributions.
Along with a proposed bridge toll, this binary “clean” vs. “dirty” social-media style campaign is beginning to make us look like Fortress Hammersmith, rather than the well-connected borough we appreciate, predicated on the idea that other boroughs wouldn’t think of putting up their barriers similarly… would they? Hounslow’s so-called South Chiswick Liveable Neighbourhood is one such controversial and euphemistically named control scheme already on our doorstep, which points to Hammersmith bridge closure as part of the problem.
Evidence from the controversial South Fulham Traffic, Congestion & Pollution Reduction (TCPR) scheme shows that the policy of diverting traffic can make it worse overall, particularly on main and boundary roads such as the A4, or to places not measured, out of sight and out of mind. This was confirmed recently by widely-reported DfT figures showing that total vehicle miles driven in the ten inner London boroughs that introduced LTNs or equivalent schemes in 2020 rose by an average 11.4% in 2021 vs. 8.9% where they hadn’t. This is one of the reasons the TCPR has had to be extended to the western side of Wandsworth Bridge Road, but the recent extension is already reported to be causing gridlock in Wandsworth itself and on Wandsworth Bridge and New Kings Roads.
Kings College and the council’s own data shows that our backstreets are already as much as 50% less polluted than main roads. Clean Air Neighbourhoods might therefore be seen as a divisive and discriminatory policy addressing the wrong target, by aiming to improve air quality in areas where it’s not a significant problem, and diverting traffic to main roads, where it would worsen the sometimes already sub-standard air quality, slowing the movement of public transport and other traffic, reinforcing last year’s similarly ill-conceived bus lane removals, and concentrating any pollution on those trying to “do the right thing” by using active travel modes – the bus, walking or cycling – or perhaps living alongside. The deeper dive at the foot of the article provides more detail.
It’s not very useful claiming that H&F residents will be unaffected, as some councillors have, with oddly mixed messaging, potentially encouraging residents’ car use. Let’s look past our own noses, and imagine other councils following suit and imposing their own set of rules, having had H&F traffic displaced to them.
Lock-down London would be divided up into a competing patchwork of complicated and differently administered fiefdoms, that no business or occasional visitor would want to, or in many cases be able to, cross – at least at any reasonable level of administration or cost – and Fortress London would become ever more a playground for the super-rich.
This represents a spectacular own goal from a council claiming to be “Doing things with residents, not to them”, and for whom it takes over 3700 words to explain just their South Fulham TCPR scheme (that’s 50% longer than this article, which is hardly short!). Unsurprisingly, the TCPR now has its own 7000-signature petition.
In an era rapidly going electric (50% of new vehicles are projected to be electric in 3 years time), rather than the council’s retro big-stick approach, a far more effective policy would involve the carrot of improving public transport from it’s pitiful speeds by ungumming the main roads, and making it cheaper and more accessible, as they do in Germany. TfL has just done the exact opposite.
Instead, this policy would make it worse in the hotspots: the five most polluted spots measured in the 2022 air quality report are Hammersmith Road East/West (HF11/46), The Town Centre, Wood Lane (HF16), and of course the Broadway, all locations where traffic is already largely at a standstill. Amazingly, for a supposed ‘clean air’ policy there appear no exceptions for EV’s; this is actually an anti four-wheel policy – ‘clean air’ is a marketing ploy.
In the month of COP27, the council conflated air quality with climate change in order to ‘make it relevant’, and then casually targeted predetermined usual suspects, fitting a tired and over-politicised narrative. The two don’t always overlap, especially geographically as we wrote before, and sometimes even work in opposition, as described below. But where the effects of climate change and air pollution do collide is in the ‘global south’ as the map above clearly illustrates, and, by encouraging pollution exports, this policy helps reinforce the situation. Do we want those countries, recently awarded ‘loss and damage’ payments from the developed world for climate change, to need to add loss and damage from our exported air pollution too?
There are also Orwellian mass-surveillance aspects, well documented elsewhere, and in some cases ruled illegal. As for the related tree planting policy, we awarded the council a wooden spoon again this year for failing to water its own newly planted street trees, provide water storage via tree bags, or even to add Arboricultural Society labels to encourage those living nearby to do so as we suggested in the ‘year of the tree’. In the last couple of years, a good percentage, sometimes more than half, of newly planted street trees have died of neglect, even before this summer’s heatwave.
If our local bureaucracy can be defeated by such a simple administrative task, how might they reasonably and effectively address the complex subject of worldwide air pollution? Not well by this measure.
The council’s ‘toxic’ mantra comes directly from a hyperactive City Hall media machine. But we’re fans of Tim Harford’s More or Less, in which the first question always asked is: Is that a big number?, or here, Is air pollution a big problem? With specific exceptions – which this policy would worsen – not in our backyard, and this is why. On the day the council’s ‘toxic’ message arrived in your correspondent’s inbox, London was the 92nd least polluted city in IQAir’s list of cities that can provide real-time data. Out of 93.
Only Oslo was less polluted. Bern in Switzerland, Berlin, Paris, Milan… all cities in Europe were worse. On annual averages, London is the 3739th most polluted city in IQAir’s world rankings, as amply illustrated in the graphic above – in green. How can this ever be described as TOXIC?
Two years ago we took a thorough look at this subject, and since then, the local situation has actually improved. Though the council, via a breathtakingly innumerate stunt, decided to compare lock-down 2020 with 2021 so as to be able to declare a (small) rise in NO2 in their graphic adjacent. But using a comparable pre-pandemic year, 2019, to 2021 in the same graphic – as everyone else does – the average level of NO2 pollution has fallen by as much as 40% in two years.
Long term AQ improvements are a result of international and national legislation, improvements in shipping, industry, technology, and road fleets, including EV’s displacing older more polluting vehicles. The very specific examples of DPD, Hermes/Evri and Amazon electric vans replacing diesels come to mind, and TfL’s welcome gradual phasing out of older diesel-powered buses – hybrid or not.
It’s notable that the 23 and 94 bus routes passing through the borough are now almost all electric, and some of the no. 7 buses from East Action to the West End are hydrogen powered: TfL has a policy, stated or otherwise, of putting such buses on central London routes first, for fairly obvious reasons. However that means that most, if not all, buses going West from Hammersmith along King Street – now stripped of it’s bus lane – are still diesel powered as of today, adding local pollution on main roads. In spite of data already available from the South Fulham TCPR, this policy, on top of last year’s constriction policy illustrated above, would make matters worse.
So where are the council getting it wrong? Firstly, having established that NOx is falling significantly and quite quickly, but that PM2.5 is sometimes above the PHE recommended threshold, (listed as Hammersmith’s main pollutant by IQAir), the target is the usual suspect, not the actual villain. Road transport of all sorts, including those old trucks, vans, buses and old 2-stroke food delivery motorbikes with really no emissions controls at all, only contribute 12% on average to the (locally problematic) PM2.5 pollution according to PHE figures in the adjacent graphic. This source has actually fallen by 90% since 1996.
If we wanted to achieve something useful here, we’d be looking at the causes of the 88% first. But Mayoral Dogma, not the data, sets a last-century agenda before catalytic converters, Euro IV, V and VI regulations and, particularly recently, widespread EV take-up. The rapid fall in NO2 levels began when catalytic converters were legislated in 1993, yet – thirty years later – our council is still using NO2 as its principal AQ measure. Similarly, according to this BBC report, ULEZ expansion has made little improvement, despite City Hall rhetoric to the contrary. That’s because it’s working way behind the curve, the actual achievement is the result of the far more effective national and international measures listed, for which City Hall likes to takes credit.
Sixty-nine pages of the council’s 2022 air quality report includes a great many words and numbers – raw and adjusted – but not a single graph that would show a trend that doesn’t fit the predetermined narrative. So we made one for you, using its numbers, and had Excel add a linear trend line. Since the Air Quality commission first reported in 2016, average NO2 levels in the borough have nearly halved, and there’s an obvious trend in line with the Chief Medical Officer’s 2022 report above (turquoise line). Of course these are averages, there are hotspots, so we’d address those as described, not take a brickbat to the entire borough and business community, making it worse where it’s highest, never mind in adjoining boroughs. There’s more analysis in the deeper dive below.
Though TfL can take significant credit for starting to get the diesel buses off the road, there’s another article to be written about recent over-investment in hybrid buses which are advertised as ‘cleaner’. As regular bus users know, the hybrid diesel engines often run 90% of the time on real London streets (as opposed to in the simulator). The associated costs have the double consequence: a historic delay in introducing greener electric or hydrogen buses, and a potential increase in emissions, as poorly performing hybrids such as ‘Boris buses’ with heavy batteries to lug around, can actually pollute more than cheaper, simpler and lighter Euro VI class diesels, especially at pitiful London speeds.
TfL couldn’t provide comparative diesel consumption figures to backup their claim when requested under FOI, because amazingly they claim not to measure them! Even American cities ran less NOx polluting Compressed Natural Gas (CNG) buses over 25 years ago, and this is where climate and pollution collide. CNG buses produce slightly more greenhouse gas emissions, but less NOx. Suboptimal decisions have been made with inadequate real-world testing. Before the era of electric buses (err… trolleybuses, 1911?), a bus producing less NOx might have been better, depending on the headline being chased. They worked that out Stateside over 25 years ago, but perhaps we should have kept those electric trolleybuses after all? They could be coming back!
Constricting people and businesses’ movements in H&F, means that bit by bit we do less and get poorer, costs go up, and slot machine arcades replace more useful businesses. While ‘clean’ electric delivery vans or cargo bikes mask the polluting air or ship miles accrued in getting goods across the oceans to us, we export our pollution invisibly to the yellow, red, orange, or brown parts of the ‘global south’ and into other people’s backyards.
We might like to think long and hard about our total pollution footprint, and the air we share with the rest of the world, before shutting up shop locally at the behest of the dogma, take a long hard look at the actual sources relevant to Hammersmith (domestic heating being the major one for PM 2.5, according to the PHE graphic), and act accordingly.
By segregating the borough into little fiefdoms, with penalties for boundary-crossing for those that haven’t or can’t complete the appropriate chit beforehand – trade vehicles, friends from other parts of town, or visiting relatives from out of town for whom public transport may be unavailable or unrealistic – in EV’s or otherwise – the council would add to mental dystopia just as we recover from 2020’s lock-downs. This, while barely, if at all, improving the air, and worse, forcing traffic onto main & boundary roads or other boroughs, again by it’s own admission, making it worse there.
As we’ve said many times and TfL’s figures confirm, the least advantaged are the biggest users of buses and more likely to live on or near main roads. The tragic death of Ella Kissi-Debrah, on which far too much City Hall propaganda is predicated, even triggering the recent “Ella’s law“, occurred on exactly such a main road (the South Circular). This policy would make it worse, as has ULEZ in that specific case, as a boundary road. The Mayor’s solution is move the goal posts boundary! An own goal, making it trivial to argue that this is a discriminatory move to keep the great unwashed away from our leafy, and to many, unaffordable, side-streets. For Mayoral reference, of all European subway systems, London Underground has the highest measured concentration of PM2.5, according to Chief Medical Officer’s 2022 report. ULEZ expansion is another distraction technique with unnecessarily discriminatory overtones.
The council only has two electronic sampling points, HF4 at Shepherds Bush Green, and HF5 at the Broadway, which contribute to its air quality report (and the IQAir map). The report has little real time data, and where it exists, it’s roadside only, so one cannot ascribe general pollutant levels to temperature, traffic levels, roadworks or other such time-related factors, borough wide. Only HF5, right in the middle of the Broadway, was capable of measuring PM2.5 according to the 2022 report, and has only been measuring it since 2019, during which time levels have decreased by 27%. The council is largely flying blind, which would appear a major shortcoming when making policy and setting draconian borough wide rules as a result.
The rest of its 56 sampling points are ‘diffusion tubes’, taken to a lab to be analysed monthly. We’re most interested in people’s typical long term exposures at home, where stats show we spend 80% of the time, rather than sniffing roadside emissions, so we selected out the 9 “urban background” readings and plotted them adjacent. An average 41% reduction in NO2 2017-2021, to mostly less than half the WHO 2005 recommendation of 40ug/m3.
PM2.5 turns out to be a complicated problem – there are both primary and secondary sources. The long-term picture of almost unchanging ammonia levels above, largely from agricultural sources, is a problem that leads to secondary PM2.5 though chemical reactions elsewhere (including in your boiler). There are many sources of primary PM2.5, several generated in the home, including wood burning stoves mentioned above, but also several everyday activities, such as cooking. Blocking roads would have minimal effect.
Breathe London, as part of Imperial, has recently installed some electronic monitoring stations, mainly at schools and community centres. Though they only provide recent data, it’s instructive to look at the huge peaks generated on the Fri/Sat evenings of 9th/10th December at many locations – one example shown – as temperatures dropped below zero for the first time. Wood burners or World Cup?
You may also be aware that the WHO reduced recommended thresholds by huge factors of 4 or 5 (i.e. 400-500% reductions) in 2021, compared to 2005 recommendations. It’s inconceivable that levels change so far and fast, and shows problems with the premise. If the world had to (legally) adapt that far and that fast, the guidance would necessarily have been better conceived. It remains controversial, and not even the council or government uses it – yet.
The real problem is that there are so many pollutants of different types that are inseparable in the real world. We don’t really know which are key, so the WHO are playing it super ‘safe’. They were either guessing before, or are doing so now, which is not a great place from which to make sweeping policy decisions.
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