DEFRA / DFT Air Quality Consultation – May 2017


The Consultation outcome has been published online including a summary of responses. The SPACE for Gosforth submission is set out below.

Following this consultation the Government set out its ‘Air quality plan for nitrogen dioxide (NO2) in UK (2017)‘ including the requirement for local authorities to produce local plans. We have written about the plan for Newcastle here. Official air quality figures for Newcastle’s two air quality management areas in 2016 are here.

Following the publication of this plan, the Parliamentary Environment Food and Rural Affairs, Environmental Audit, Health, and Transport Committees re-launched their joint inquiry into improving air quality and SPACE for Gosforth also submitted evidence to that enquiry.

The SPACE for Gosforth Response to DEFRA/DFT consultation May 2017: Tackling Nitrogen Dioxide in our towns and cities

[Qus 1-6 are admin questions]

Q7. How satisfied are you that the proposed measures set out in this consultation will address the problem of nitrogen dioxide as quickly as possible?

Very dissatisfied

Please provide comments to explain your answer

This response if from Space for Gosforth (SPACE) which is a group to promote and campaign for a Safe Pedestrian And Cycling Environment for Gosforth in Newcastle upon Tyne. We are residents of Gosforth, most of us with families and we walk, cycle, use public transport and drive. We are not affiliated to any other campaign group or political party.

The aim of the organisation is to promote healthy, liveable, accessible and safe neighbourhoods where

  • Walking and cycling are safe, practical and attractive travel options for residents of all ages and abilities.
  • Streets are easier and safer to navigate for residents or visitors with limited mobility and for residents or visitors with disabilities or conditions for whom travel is a challenge.
  • There is good walking and cycling access to local community destinations including schools, shops, medical centres, work-places and transport hubs.
  • Streets are valued as places where people live, meet and socialise, and not just for travelling through.
  • The negative consequences of excessive vehicle traffic including injury and illness from road traffic collisions, air pollution, community severance, noise pollution and delays are minimised.

We are pleased to have the opportunity to respond to this consultation on air quality which is a real issue for our community as evidenced by the designation of Air Quality Management Areas in Newcastle, including in Gosforth. Our response follows.

  • The High Court has recognised air pollution to be a public health crisis that kills tens of thousands of people each year in the UK and has required that legal limits, which should have been met by 2010, must now be achieved “as soon as possible”
  • We therefore expected the government to produce a plan to achieve compliance as soon as practicable to safeguard the health of our communities, with compliance to be achieved no later than the end of 2018 consistent with the High Court’s judgment. The proposed measures do not include any new concrete actions to achieve NO2 levels within the shortest possible period. We are therefore not satisfied with the measures.
  • Within the plan, where we expected firm proposals, there were merely proposals to consider what should be done. The government is dithering while expecting local authorities to take prompt action. Examples of actions that are proposed for consideration but which should already have been concluded and resulted in firm proposals include
  • “Engaging with car manufacturers to see what role they could play”
  • “Pressing car manufacturers to develop options for recalling existing vehicles to improve their real world emissions performance”
  • “Exploring tax treatment for diesel vehicles”
  • This is not an executable plan that has been put forward for consultation: it is a plan to develop a plan. With the UK already 7 years late in achieving compliance and with hundreds of thousands of unnecessary deaths during that time, this further delay is not acceptable. The government has been breaking the law on air pollution for 7 years and we need effective actions to be implemented quickly, without further delay.
  • The plan is also misleading and confusing. The accompanying technical report makes it clear that a Charging Clean Air Zone (CAZ) is the most effective way to reduce emissions in a locality, but the plan says that they should only be considered as a last resort, despite the evidence showing that they are the most effective measure to achieve compliance and protect people’s health. The government should have been much clearer in explaining that Charging CAZs are the quickest way to clean up our air and that there is no evidence that CAZs without charging could make the rapid reductions in NO2 that are needed. Any plan that does not mandate the application of the most effective measures would clearly be in violation of the High Court judgment to achieve compliance as soon as possible.
  • Conversely, the plan includes measures which the government knows are not effective. It suggests ‘Improving road layouts and junctions to ‘optimize’ traffic flow, for example by considering removal of road humps’ despite this not being included in the shortlist of most effective measures in the Technical Report. If such measures induce additional vehicle traffic, or cause more people to drive because they don’t feel safe walking or cycling, then there is a high risk they will lead to more pollution in other nearby locations.
  • The plan also defers the responsibility that the government has for controlling to poor air quality (e.g. through its policy on vehicle tax regime), instead pushing responsibility onto local councils. It’s not clear whether new funding will be available to implement the plan or how the proposals would be funded in any case. There is very little detail and it pushes responsibility to deliver clean air to local councils without giving them any resources to do so.   The plan does not put any onus onto manufacturers who helped get us into this situation in the first place and whose cheating on emissions has resulted in NO2 emissions from diesel cars being several times higher than expected.
  • The plan needs to include a clear governance framework that sets out the responsibilities of Central Government and of Local Authorities including who is responsible for ensuring air quality targets are met for a given location, when those targets should be met, how they should be measured, and a set of mandatory emergency measures that must be applied if targets are not met in the mandated timescales.
  • Section 6 of the plan defines ‘the solution’, rightly noting that it is road transport that is the largest contributor to poor air quality in our urban areas but goes on to focus on high technology, high cost, long term solutions based on the unconstrained use of road transport when the only quick way to reduce air pollution and protect public health is to have fewer vehicle movements of the most polluting vehicles in our most polluted areas.
  • The measures do not address the transport market failures that lead people to choose high cost personal vehicle transport with large negative externalities, such as air pollution, rather than choosing very low cost alternatives such as walking and cycling which have no negative external costs. These inefficiencies in the use of capital, materials and road-space, if resolved, could provide a significant economic boost to the UK as a whole in addition to resolving air quality and other related public health issues.
  • It is therefore our conclusion that this plan is not fit for purpose.


Q8. What do you consider to be the most appropriate way for local authorities in England to determine the arrangements for a Clean Air Zone, and the measures that should apply within it? What factors should local authorities consider when assessing impacts on businesses?

  • The technical report is clear that Charging CAZs are the most effective measure, being more effective than Non-Charging CAZs. As local authorities have had over 10 years to achieve compliance using other means, and this must be met as soon as practicably possible, we believe that the Charging CAZs should be mandatory where the limits are exceeded.  The arrangements need to be designed to achieve compliance as soon as practicably possible whilst supporting people and businesses to use less polluting forms of transport, including cycling, walking and public transport to mitigate the impact.
  • The High Court was clear that the economic impact is not a reason to defer actions which would reduce NO2. Instead, the government should seek to address this impact through mitigating actions in a separate plan to run alongside the introduction of Charging CAZs. Additional measures can be used alongside the Charging CAZs to lessen the impact on those least able to adapt to the change.
  • The plan is not clear on how these measures will be funded.



  • How can government best target any funding to support local communities to cut air pollution?
  • What options should the Government consider further, and what criteria should it use to assess them?
  • Are there other measures which could be implemented at a local level, represent value for money, and that could have a direct and rapid impact on air quality? Examples could include targeted investment in local infrastructure projects.
  • How can government best target any funding to mitigate the impact of certain measures to improve air quality, on local businesses, residents and those travelling into towns and cities to work? Examples could include targeted scrappage schemes, for both cars and vans, as well as support for retrofitting initiatives.
  • How could mitigation schemes be designed in order to maximise value for money, target support where it is most needed, reduce complexity and minimise scope for fraud?


  • In the short term, the only ways to achieve legal limits for air pollution are to have fewer vehicle miles driven and cleaner motor vehicles.
  • While the primary purpose of the plan is to reduce ambient NO2 levels, there are still other pressing transport related concerns that need to be addressed. While the most effective change is to restrict car use, at the same time alternatives are needed and we need a holistic response to all the transport related health challenges. The 2009 Cabinet Office report “The wider costs of transport in English urban areas” identified and quantified six types of societal costs of transport: excess delays, accidents, poor air quality (particulates as well as NO2), physical inactivity, greenhouse gas (GHG) emissions, and noise. This report estimates each of these six types of societal cost as being of a similar order of magnitude.
  • The focus in the draft plan is on high technology, high cost solutions based on the use of private road transport. It is weak on considering investing in public transport and active travel and includes no reference to any new actions for this for England going forwards. However these are effective methods of reducing NO2 emissions while also delivering multiple other positive outcomes (such as health and economic benefits, CO2 emission reduction, improved local accessibility).
  • Specifically, the plan aims, in the medium to long term, to make the diesel fleet less polluting (through retrofit or scrappage) and in the longer term to switch to electric vehicles or other new technologies. Of the six wider societal costs of transport, the plan would deliver in the medium term some improvement in the NO2 element of poor air quality, and in the longer term reductions in noise and GHG emissions. It would fail to deliver any improvement in excess delays, accidents, the particulate element of poor air quality and physical inactivity.
  • In contrast, local measures can reduce the need for private road transport, such as increasing active travel (walking and cycling) and the number of journeys made by public transport, and through planning, development and transport decisions that focus on reducing the need for private car journeys.
  • Measures to reduce traffic levels including reducing road capacity (‘road diets’), congestion charging zones or increased parking charges should all be considered as part of the plan. Simple measures like preventing through traffic using residential streets would be cheap, improve the livability of local neighbourhoods and make roads safer and more attractive for non-polluting modes such as walking and cycling.   Similarly, parking charges can be implemented quickly and set in a phased manner to manage traffic levels. Plans based on these two interventions could be both extremely effective and quick to meet air quality targets.
  • Actions which enable (not just encourage) people to use active travel and public transport would make urban areas less dependent on private car transport and could also result in significant air quality improvements whilst having other economic, social, environmental and health benefits, including reduced GHG emissions.
  • In terms of the potential for active travel to improve health, current estimates suggest 40,000 per year die early because of poor air quality, and another 85,000 due to sedentary lifestyles. These are on top of 200,000 deaths due to cancer and heart disease. Studies have shown that those that walk or cycle have a significantly lower risk of death of both cancer and heart disease compared to those that do not. If cycling and walking continues to be funded at only 1.3% of the total transport budget then millions will die earlier than they need to and millions more will suffer poorer health and quality of life. Walking and cycling need to be safe on major routes to link up residential areas, provide fast through routes and make these modes viable transport choices for everyone, while also addressing air quality and the wider health issues (inactivity, cancer, heart & lung disease etc.) which result from how we travel.
  • In order to deliver the best value for money, the government should seize the need to reduce NO2 as an opportunity to also address other transport-related societal costs. When the government comes to assess the value for money of CAZ plans that deploy improvements in public transport and infrastructure for active travel (walking and cycling), it should give due consideration to these other benefits which are in addition to the legally required NO2 reductions.
  • However, without action to make public transport and active travel more attractive, seeking to increase these is relying on behavior change without changing the framework within which people make decisions about how to make their journeys. This will not be effective since it relies on expecting people to make changes and/or to choose higher personal cost or inconvenience now in return for wider public benefits in the future. Shockingly, over the last 30 years in real terms the cost of motoring has fallen by 20% and the cost of public transport increased by 67%.
  • The cost and non-cost barriers to these travel choices need to be understood and addressed as a public policy priority so that the balance of cost, convenience, ease and comfort between private car travel and other options needs can be rebalanced so that public transport or active travel are more attractive options for more people for more of their journeys. This will require significant increase in investment in active travel infrastructure and in public transport, plus a far reaching review of how public transport is planned, operated and paid for, and the powers that local government have to improve public transport so it can be planned to meet local needs for mobility, for improved air quality and to play its part in achieving wider environmental benefits i.e. GHG reduction.
  • At present there are multiple barriers to public transport in our region of Newcastle upon Tyne and surrounding areas: fragmentation, uncoordinated routes, cost, complexity, and no single ticketing scheme. It will therefore take more than warm words of encouragement to achieve a modal shift towards public transport. We need an overhaul of the approach to how public transport is organized and funded. The deregulation of buses outside London has not delivered an attractive cost effective alternative to private transport. This needs to be addressed as a matter of urgency. The Buses Bill does not go far enough in this respect and makes it difficult for local authorities to make use of franchising. Both a re-think of central government funding for public transport and an overhaul of the transport appraisal methodology is needed to ensure the social and environmental benefits of public transport are weighted highly when assessing any scheme. Additional benefits from improving the public transport service are increased mobility and access to employment and educational opportunities for disadvantaged groups- young people who can’t afford a car. It is important to note that approximately half of households in Newcastle upon Tyne do not have a car.
  • Newcastle upon Tyne is a compact city so there is a lot of scope to reduce short car journeys, and we would expect this to be the case in many other urban areas too. As with public transport, it will take more than warm words of encouragement to achieve a modal shift to active travel. Poor infrastructure for cycling is specific barrier that needs to be addressed, in particular to provide safe and direct routes separate from motor traffic.
  • The national British Social Attitudes Survey 2013 identified a significant potential to increase the number of journeys being cycled instead of driven, but that the fear of traffic is a major barrier to people taking up cycling.
  • When asked about the journeys of less than two miles that they now travelled by car
    • 33% said that they could just as easily catch the bus
    • 37% said they could just as easily cycle (if they had a bike)
    • 40% of people agreed that they could just as easily walk.
    • 61% of all respondents felt it is too dangerous for them to cycle on the roads, rising to 69% for women and 76% for those aged 65 and over.
  • Research in our home city of Newcastle upon Tyne in 2015 tells a similar story: 54% of people in the city said they could begin to ride a bike or ride their bike more often. When non-cyclists were asked about what kind of bike routes would help them to start cycling, 90% said traffic-free routes and 85% said bike lanes protected by a kerb.
  • This evidence shows that the lack of quality of cycling infrastructure, in particular routes that are convenient and feel safe for cycling, is a key barrier to people taking up cycling. The plan should therefore include a significant increase in annual investment on cycling infrastructure to overcome this barrier to cycling. This should be ongoing and at a level equivalent to that which has delivered quality infrastructure and high rates of cycling in other climatically similar northern European countries such as Denmark (19% of trips are cycled) and the Netherlands (27%): these countries spend £24/person per year.
  • Seville is a great example of what can be done very quickly and gives a benchmark for ‘the shortest possible timescales’ as required by the court. Seville built enough connected, safe lanes to lead to the number of bike trips multiplying 11-fold in a just few years.
  • In comparison, the government’s Cycling and Walking Investment Strategy commits to investing £1.2bn over 5 years, equivalent to £3 per person per year for walking and cycling together. However, there is widespread public support for a significant increase in public expenditure on cycling infrastructure to levels that match those in the Netherlands and Denmark; a survey showed that 75% support more investment in cycling, with £26/person per year the average amount people want governments to be investing. Newcastle’s twin town of Groningen invests 85 Euros per person per year in cycling alone.
  • The Department for Transport’s assessment of a sample of cycle schemes found a benefit cost ratio (BCR) of 5.5:1 i.e. for every £1 of public money spent, the schemes provide £5.50 worth of benefit, meaning these “deliver very high value for money”. In comparison, the BCR for HS2 is between 1.4:1 and 2.5:1. We are therefore confident that investment in quality cycling infrastructure will be a very good investment of public money in itself, as well as a way of achieving NO2 reductions.
  • To ensure that this investment delivers the quality of infrastructure that will provide people with a safe, easy to use and comfortable cycling experience, we recommend adoption of best practice in design and construction of cycling infrastructure, for example as documented in the London Cycling Design Standards 2014. This documents six core outcomes which ‘together describe what good design for cycling should achieve: Safety, Directness, Comfort, Coherence, Attractiveness and Adaptability. These are based on international best practice and on an emerging consensus in London about aspects of that practice that we should adopt in the UK.
  • The additional benefits of achieving higher levels of active travel are increased mobility and access to employment and educational opportunities for disadvantaged groups including young people who can’t afford a car, and the many households without a car. In addition, the increased levels of activity will improve mental and physical health, with direct personal benefit and related wider economic benefits (fitness for work, reduction in costs to the taxpayer of dealing with poor health). A recent study of 250,000 people over 5 years has shown that even limited amounts of cycling and walking can both make a massive difference to life expectancy and, in addition to the benefits to health and wellbeing, the potential financial savings for the NHS and social care will also be massive. Cycling in particular has a large effect in reducing the risk of death from cancer (by 45%) and heart disease (by 46%). These are two of the five key health issues of our time along with obesity, inactivity and air quality – all three of which can also be improved by ensuring that walking and cycling are safe and attractive travel choices.
  • We agree with the accompanying Clean Air Zone Framework’s assertion that E-bikes can provide an easy zero emission alternative for some journeys and support its proposal that local authorities should also seek to support an increase in the relative share of E-bikes. We note that this represents good value for money as the cost of an E-bike would be hundreds of pounds compared to the proposed car scrappage fee of £6,000.
  • In addition to implementing Charging CAZs, urgent and highly targeted interventions are required and should be targeted at the categories of vehicles that the most polluting: Figure 4 of the consultation document indicates that this means buses & coaches, HGVs and diesel LGVs. These are also the types of vehicles that spend the most time on the road.
  • The government should implement robust diesel scrappage and retrofit schemes to get the worst polluting vehicles off our roads (Euro 5 or earlier) or to clean the up to Euro 6 standard. These schemes should be directed to buses & coaches, HGVs and diesel LGVs with priority given to buses in areas where the NO2 limits are exceeded or close to being exceeded. Newcastle upon Tyne has an ageing bus fleet which includes the most polluting vehicles that have been retired from London where they are no longer permitted to operate. Any expansion of bus services should be on the condition that older more polluting vehicles are taken out of service or retrofitted.
  • Another option for addressing the levels of pollution from HGVs in urban areas could be freight consolidation: unloading freight at a distribution centre on the periphery with distribution within the urban area by cleaner forms of transport.
  • The government should alter the vehicle tax regime so that it does not incentivize diesel vehicles and use it to encourage a move towards cleaner forms of transport. Vehicle tax should be set at a level that covers the full cost externalities including actions required to manage or reduce those external costs. This will ensure that tax-payers who do not use polluting vehicles are not required to subsidize those that do in addition to paying for their own transport costs. Taxes should focus tax on usage rather than ownership to incentivize efficient driving styles.


Q10 How can governments work with local communities to monitor local interventions and evaluate their impact?

The Government and the devolved administrations are committed to an evidence-based approach to policy delivery and will closely monitor the implementation of the plan and evaluate the progress on delivering its objective

  • Monitoring air quality should be carried out by a statutory body and the information presented in a way that enables people to understand what it means and how much progress has been made in reducing NO2 and other pollutants and how this compares to legal limits.
  • The best approach would be for government to proactively engage with the relevant authorities and the general public to ensure local interventions are being delivered and are having the expected effect. This should be part of a comprehensive national public engagement strategy that proactively raises awareness of the problem and the actions being carried out to tackle it.
  • Current information sharing via government and local authority websites are not user-friendly for the general public, lack information and are often out of date. The government should facilitate a national system that ensures transparency and allows local communities to directly access relevant and up to date information at a national and local level.
  • The UK government should also ensure that the general public is proactively alerted about high pollution events when they are forecasted and as they happen using a range of channels including on street signage, local radio and TV, and the internet. This will help people protect their health and consider how they can reduce their contribution to the problem. The current system is based on thresholds that are too high and don’t cover all pollutants. It is also a passive system that relies on individuals looking for the information on line. An air pollution alert system could use the similar systems in place for heat waves and cold weather warnings


Q11 Which vehicles should be prioritised for government-funded retrofit schemes?

We welcome views from stakeholders as to how a future scheme could support new technologies and innovative solutions for other vehicle types, and would welcome evidence from stakeholders on emerging technologies. We currently anticipate that this funding could support modifications to buses, coaches, HGVs, vans and black cabs

  • The government should prioritise retrofit schemes according to the effectiveness of the available technology to have the greatest impact towards reducing NO2 pollution in the shortest possible time.
  • These schemes should be targeted on areas where the NO2 levels are highest (not a national programme) and on the most polluting types of vehicles (i.e. buses & coaches, HGVs and diesel LGVs) and which operate in those areas.
  • It is critical that the government ensures that retrofitted vehicles in real world driving achieve the expected level of emissions and that there is no cheating.


Q12 What type of environmental and other information should be made available to help consumers choose which cars to buy

  • Consumers should be provided with the information that assures them that the vehicles they purchase are as clean on the road as the legal limits allow in the laboratory tests. The information should help the consumer understand how well the vehicle performs in the real world for both air pollution and GHG emissions compared to other similar vehicles. The information should also help consumers understand whether their vehicles comply with air pollution measures, such as CAZs and any future changes to the vehicle tax regime. A labeling system similar to that used for energy ratings for domestic appliances could be helpful for consumers.


Q13 How could the government further support innovative technological solutions and localised measures to improve air quality

  • The UK government could help support innovative technological solutions and localized measures by providing a comprehensive, long term, strategic and funded plan to improve air quality beyond the current legal limits. Nationally coordinated measures, such as a national network of Charging CAZs and changes to the vehicle tax regime will help send a clear signal to businesses, local authorities and the general public of what investments they should be making. The government should accelerate implementation of an industrial strategy that will make the UK a world leader in clean technology, creating the jobs and industries that will help us, and others, clean up our air.


Q14 Do you have any other comments on the draft UK Air Quality Plan for tackling nitrogen dioxide?

  • The draft UK Air Quality Plan is weak and illogical. Firstly the government’s plans and consultation do not match what its own evidence says needs to happen. If the evidence shows that taking certain measures will be necessary to tackle the public health crisis of polluted air, then the plan needs to make that clear. Secondly, this is a plan to make more plans later when we need action now. We want to see a national network of Charging CAZs to protect people’s health alongside measures to help people switch to cleaner forms of transport.
  • By failing to identify measures to enable a shift from private motoring towards walking, cycling and public transport, the draft plan is a missed opportunity both in respect of improving public health but also to reduce the cost burden of travel for the benefit of families and businesses. It would continue to keep us locked into a high cost, highly car dependent way of life in urban areas but it is within our grasp to create an alternative and in so doing reduce not just NO2 levels but also the many wider societal costs of high rates of private motoring and to achieve a healthier and happier society. In conjunction with a move to ultra-low emission vehicles, such a plan could lay the foundations for achieving the government’s longer term target of zero NO2 transport emissions.
  • The draft plan does not acknowledge or address factors limiting a local authority’s capacity to deliver improved air quality and issues of equity. Although Newcastle is the business driver for the North East in many ways, it’s also a poor city. As a regional centre, it has air quality problems imposed on it by residents and businesses in other local authorities and by poor public transport, but the air quality health burden falls on Newcastle residents. The cost burden should not fall on its residents too.
  • Traffic from outside the city is a key factor in our pollution, but people may not have an alternative, or if they do have one, they are not incentivised to use it. For example, there is a lack of commuter rail routes into the city, but that isn’t an issue that the Council has any control over. These residents of neighbouring authorities don’t have the pollution where they live nor will they face any penalties if Newcastle City Council is fined for breaching air quality. Local authorities need to have some comeback when their neighboring authorities behave irresponsibly, and wider area action on planning and public transport is needed to ensure that actions of other local authorities don’t create air quality problems for Newcastle residents. The suggestion in the plan that local authorities should “work with neighbouring authorities to ensure a consistent approach” is inadequate to address these challenges and will not deliver the consistent approach that the government is seeking.
  • The draft plan refers to local authorities encouraging local transport operators to buy ultra-low emission vehicles but at present this is unrealistic as local authorities do not have the necessary powers over public transport.
  • As well as setting the framework for local action and monitoring progress, the government should help local authorities to develop, implement, monitor and adjust their plans by facilitating sharing of experience how what works well and what doesn’t.
  • While it may be appropriate for drivers of dirty vehicles to pay to pollute in a Charging CAZ, it is not fair that residents in those local authorities with CAZs (and which bear heaviest burden of poor air quality) pick up the remaining costs of reducing NO2 and which are not covered by drivers paying to enter a Charging CAZ. This is particularly true in Newcastle with high levels of deprivation and where half of all households do not have a car. Any other funding needed to implement local measures should be socialized on a national basis through support from national government, not from local taxes.
  • The draft plan largely addresses the various measures that might be most effective in quickly reducing NO2 pollution. There is another critical question of where this cost burden should fall: driver, taxpayer, vehicle manufacturer. We need an equitable approach.
  • Any tax or incentivisation scheme should be based on the principle that the polluter pays and not require that non-drivers subsidise Where real-world emissions are markedly worse than those advertised then vehicle manufacturers should be responsible for making up the difference.