The (In)justice of Clean Air Zones

Presentation by

Graham Parkhurst

Professor of Sustainable Mobility

graham.parkhurst@uwe.ac.uk

CTS Annual ConferenceUWE Bristol, 16 May 2019

Overview

• Historic Context: Political Failure to Respond to Scientific Evidence

• Questions about Clean Air Zone Effectiveness and Fairness

• Conclusion: CAZs may now be a legal requirement but they treat the symptoms of the condition, not the cause, and with side-effects!

Dec 1991 London Pollution Episode

Royal Commission (1994): 160 premature deaths

The diesel problem was already clear in 1993

“On balance… …unless some improvements in the

emissions from diesel vehicles can be achieved,

there must be considerable concern over any

increase in the proportion of diesel vehicles on our

urban streets as their impact on urban air quality is

undoubtedly quite serious”

(Quality of Urban Air Reform Group, 1993: 69).

Stimulation of Diesel Car Sales by VED and BIK Tax Regimes from 2001-2002

0.010.020.030.040.050.060.070.080.090.0

100.02

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20

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t R

egis

trat

ion

s %

Petrol Diesel Other (hybrids, BEV, gas etc.)

Source: Department for Transport (2018) Vehicle Statistics Table VEH0253

Outcome of Transport Policy 1993-2017: 28% traffic growth

DfT (2017) Road traffic (vehicle miles, seasonally adjusted) in GB (Table

TRA2502f)

90

100

110

120

130

140

150

160

1993 1998 2003 2008 2013

ind

ex (

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age

qu

arte

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Evidence of Roadside NO2 Concentrations Persisting has been established for many years

Carslaw, D.C., Beevers, S.D. Westmoreland, E. Williams, M.L. Tate, J.E., Murrells, T. Stedman, J. Li, Y., Grice, S., Kent, A. and I. Tsagatakis (2011). Trends in NOx and NO2 emissions and

ambient measurements in the UK. Version: July 2011.

http://uk-air.defra.gov.uk/reports/cat05/1108251149_110718_AQ0724_Final_report.pdf

NOx source apportionment by vehicle category across Bristol city centre

CH2M (2018) Bristol City Council Clean Air Plan: Strategic Outline

Case. Bristol City Council, Bristol. Figure 2.4.

Priorities n Mean (1-6)

Safety 41 1.46

Congestion 41 2.02

Accessibility 41 2.05

Other Local Priorities 39 2.33

Air Quality 41 2.98

1= very high priority, 6= very low priority

Relative Importance Given to Air Quality by Transport Planning

• Shared not ‘equal’ priorities

“Improving air quality risks conflicting with improving

accessibility in some cases. And we consider

accessibility as vital to the economy.”

[Transport planner]

• Political intangibility.

“From an officer point of view, I can understand the

health impact of air quality but this is difficult to translate

in reality to the public compared to the way traffic

congestion and road safety issues can be

communicated.”

[County transport planner during case study interview]

Shared priorities’ importance based on time,

resources and funding allocation

Olowoporoku et al. (2010) A longitudinal study of the links between Local Air Quality Management and Local Transport Planning policy processes in England. Journal of

Environmental Planning and Management, 53: 3, 385-403

Olowoporoku et al., (2012). The rhetoric and realities of integrating air quality into local transport planning process in English local authorities. Journal of Environmental

Management, 101, 23-32.

Emergence of CAZs• 2015-2018 Government loses series of court cases

brought by ClientEarth

• Mandated existing 2017 guidance

• 36 local authorities to bring forward plans for compliance with NO2 limits by 2020

• CAZs to be pursued if other measures were predicted to be insufficient

Three Interlinked Questions about CAZs

• Will they work?

• Are they politically deliverable?

• Are they a just solution?

How significant is having a CAZ?

Bristol

Small Zone

NO2

Projections

2021-25

How Relevant is the ‘Legal Obligation’?

“Neither the concentration limits set by government, nor the World Health Organization’s air quality guidelines, define levels of exposure that are entirely safe for the whole population.” (p.xii)

“With…a lack of evidence of a threshold where no effects exist for many pollutants, further control policies should seek to decrease pollution exposure, even where limits are met.” (p.12, emphasis added)

“The Committee on the Medical Effects of Air Pollutants estimates 29,000 ‘equivalent’ deaths annually from exposure to PM2.5 in the UK, with only a small fraction of that figure relating to exposures to concentrations in excess of legal limits”. (p.18, emphasis added)

Source: Royal College of Physicians (2016). Every breath we take: the

lifelong impact of air pollution. Report of a working party. London: RCP.

Growing Real-world Emissions Gap

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

Euro 3 Petrol Euro 6 Diesel

Limit Real-world

X3

EEA (2016) Explaining Road Transport Emissions, p28

Emissions Analytics Real-World Data on 221 Euro VI Diesel Models

0%

5%

10%

15%

20%

25%

30%

ExceedsEuro VI

Meets EuroVI

Within 1.5xEuro VI

Euro V Euro IV Euro III < Euro III 8-12 x EuroVI

24% Compliant

8% Near-

Compliant

68% Non Compliant

Equaindex (2019). The EQUA Air Quality Index. https://equaindex.com/equa-air-quality-index/

‘Real World’ Emissions Factors for CAZ Modelling vs Euro Standards

0.15

0.070.08

0.45

0

0.1

0.2

0.3

0.4

0.5

Standard NAEI Factor

NO

x (g

/km

)

Petrol Euro III Diesel Euro VI

So are they a ‘just’ solution?• Accelerate legal compliance with a specific exposure threshold

within a particular zone

• Environmental Risk of increasing emissions on diversion routes

• Political risk as identification of ‘clean’ and ‘dirty’ vehicles for charging purposes is crude

• Political-environmental Risk of signalling (to Euro VI diesel users in particular) that their vehicles are ‘environmentally friendly’

• Weak (and declining?) revenue stream for redistribution

Possible CAZ Enhancements

• More sophisticated identification of vehicle-specific emissions with individual certification

• Identify a forward programme of tighter emissions restrictions

Better to Treat the Wider Cause?

Depending on Scenario…

Traffic up 17 to 51%

Congestion up 8 to 16%

DfT (2018) Figure 25

New Taxation Regime Potentially Fairer

7.7%

4.7%

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%

9.0%

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Fuel Duties as Percentage of HMRC Receipts

Source: HMRC (2018) https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk

4.7% = £28 billion p.a.

Every 1% shift to BEVs

will cost the Treasury of

the order of £300 million

p.a.