One of the big topical issues in London is air quality, particularly as there is an allegation that the Low Traffic Neighbourhoods (LTNs) that have been introduced have made air pollution worse.

One of the justifications for introducing LTNs including road closures in boroughs such as Lewisham was the need to improve air quality. However it is alleged that the diversion of traffic onto main roads has actually made matters worse in some locations.

Lewisham has now published a Draft Air Quality Action Plan which is now open to public consultation (see link below). It gives some more data on the air pollution issue and what the council plans to do on this subject in 2022-2027. It’s well worth reading and commenting on by Lewisham residents and is probably typical of many other London boroughs.

Some comments before you respond to the consultation: This report and the associated consultation contain a mass of data and a few recommendations, but the information is hardly presented in a clear way. It is hardly the kind of document that an uninformed general member of the public will find digestible. I will try to pick out some of the salient points.

Firstly is there an air quality problem in Lewisham that is affecting the health of the general population? That’s opposed to those such as Ella Kissi-Debrah who was the subject of a recent inquest (i.e. the particularly vulnerable or suffering from other medical conditions), or children.

The report says: “An assessment of air quality in Lewisham has shown a decreasing trend in the levels of two pollutants, nitrogen dioxide (NO²)) and particulate matter (PM) in recent years. However more needs to be done to meet the guidelines set out by the World Health Organisation”. The report repeatedly refers to WHO guidelines which are not the legal limits set by EU and UK regulations (see link below). The WHO limits are much lower and are not necessarily those justifiable by scientific data on health impacts.

The report emphasises the health effects of exposure to nitrous oxides (NO2) despite the fact that there is no clear consensus on the long-term impacts of NO2 – see the latest COMEAP report from the Government Committee on the Medical Effects of Air Pollution (see link below). However it does say that “On average, annual mean NO2 concentrations at both roadside and urban background monitoring locations have decreased between 2014 and 2020 by an average of 42% and 37% respectively”. You can see the trend in NO2 emissions in Lewisham in the chart above.

Particulates (PM2.5 and PM10, particularly the former) are probably more of concern although here again Lewisham is within UK legal limits where the air quality is measured. Similarly here also the trend has been falling. It is difficult to see from the report that air quality is a substantial problem in Lewisham so far as health impacts are concerned. The data is not there to show that.

The air quality has clearly been improving in the last few years, but this is not obviously down to any actions by the local council but from changes to the vehicle fleet, central government regulations, improved heating systems, etc.

However the Council has clearly taken up the public clamour by attempts to reduce car use, making walking and cycling the preferred choice of travel, reducing children’s exposure by such measures as School Streets, and of course the LTNs.

Page 3 of the council’s report attempts to provide further justification by mixing up air quality and the council’s response to the alleged “climate emergency” as if improving NO2 or PM will have any impact on climate, when the latter is allegedly more related to CO2 emissions. There is no such link.

The council is adopting targets to reduce PM2.5 despite the fact that much of those pollutants come from outside the borough – indeed outside of London, even outside of the UK altogether, over which the council has no control.

The council’s proposals for action include an expansion in monitoring activities (more diffusion tubes to monitor NO2 and new PM2.5 monitors) and raising public awareness by more social media activity. They also propose:

1. Reducing pollution in and around schools and extending school audits to other schools in polluted areas.
2. Enforcing the Non-Road Mobile Machinery (NRMM) Low Emission Zone.
3. Promoting and enforcing Smoke Control Zones.
4. Promoting and delivering energy efficiency retrofitting projects in workplaces and homes.
5. Installing Ultra-Low Emission Vehicle (ULEV) infrastructure.  
6. Improving walking and cycling infrastructure
7. Regular Car Free days/temporary road closures in high footfall areas.
8. Reducing emissions from Council fleets.

Some of these measures may be beneficial but how much so is unclear.

In summary this report from Lewisham Council is a typical one. Policies are proposed with no clear cost/benefit justification and no obvious measures of success. Just as with the Lee Green LTN, there is no clear outcome that will indicate whether the scheme is a success and justify the expenditure on implementation.

Neither will it satisfy Lewisham residents who are being affected by worse air pollution because there are no specific actions proposed to tackle their complaints (for example air pollution near the South Circular).

Even the proposed actions are unspecific and the on-line consultation form asks wishy-washy questions rather than specific ones. Do Lewisham residents, or their visitors, actually support “car-free” days for example?

But residents should certainly respond to the consultation.

UK and EU Air Quality Limits: https://uk-air.defra.gov.uk/air-pollution/uk-eu-limits

COMEAP https://www.gov.uk/government/groups/committee-on-the-medical-effects-of-air-pollutants-comeap

Air Quality and Vehicles: FFDF Report: https://www.freedomfordrivers.org/_files/ugd/8ec181_ab00306f347f4046b6a950cdcaa2cdc6.pdf

Lewisham Air Quality Consultation: https://lewisham.gov.uk/airqualityconsultation

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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