Detailed briefing on Clean Air Zone

The proposal for Sheffield to have a Clean Air Zone will be debated by a full meeting of Sheffield City Council at 2pm on Wednesday 5 December, and then go to public consultation in January to February 2019.

Chris Broome, a member of Sheffield Climate Alliance has read the proposals in detail and produced the briefing below.

Briefing on Sheffield’s Clean Air Proposal – By Chris Broome   22/11/18

The actual details of the new plan are given in a report to the Council Cabinet and are at :-

http://democracy.sheffield.gov.uk/documents/g6989/Public%20reports%20pack%20Wednesday%2021-Nov-2018%2014.00%20Cabinet.pdf?T=10 (pages 29-60 or PDF pages 33-64). Quotes from the document are denoted in these notes by the pdf page number, eg “[pdf 48]”.

The proposal

The most significant proposal is to set up a charging Clean Air Zone (CAZ) [ ie not a “congestion zone” as the Sheffield Star has stated – it is not primarily designed to ease congestion.] Private cars would not be charged:-

[pdf 45 ] “the Sheffield CAZ will cover the area bounded by the inner ringroad. The inner ringroad itself would be included in the CAZ and therefore non-compliant buses, coaches, taxis (London-style hackneys and private hire), HGVs and LGVs would be charged a daily rate for entering and moving within the zone.”

Charges likely to be £50/day for non-compliant buses and HGVs and £10/day for all commercial cars and vans [pdf 47]. Compliance means meeting “Euro” emissions standards as follows, except for taxis that will need to be low-emission (ie electric, hybrid or LPG).[pdf 39, point 7]“CAZs generally charge “diesel vehicles that are older than Euro 6 (around 2016) or petrol vehicles that are older than Euro 4 (around 2006).” Note that car manufacturers devised ways to cheat on emissions tests that worked for many years. Hence, cars built to Euro 6 standard have never been as clean as they were supposed to be, such that the standard is much more effective for heavy vehicles than for cars and vans.

[pdf 47] “Any revenue raised locally through the charging CAZ …may only be used to support further work to improve air quality.

Sheffield City Council (SCC) will consult on the proposals in early 2019. The CAZ would be introduced in 2021, the earliest feasible time.

The reasoning

Background papers are listed at [pdf 36-7]. Various papers by SCC, Govt (DEFRA), medicals reports, AQ data etc.

Essentially, SCC has been lobbying Government for many years to mandate CAZs in all the towns and cities that needing them to meet EU limits for NO2 pollution. However, it is taken several legal cases before the Government has been basically forced to require affected Local Authorities to carry out research to find out if CAZs are required and apply for funding to enact them.

Last December, The Sheffield Clean Air Strategy [https://democracy.sheffield.gov.uk/documents/s29124/Clean%20Air%20Strategy%20Dec%20Cabinet%202.pdf ] committed to investigating the need for CAZ(s) in Sheffield. In the meantime, it proposed measures to clean up buses and taxis and encourage a move away from private cars, such that NO2 limits might be met anyway. This would avoid the politically difficult step of introducing CAZs. However, in my view, it was obvious from the fairly sparse figures stated in that document, that a CAZ was essential.

The new report to cabinet seems to be based on results from better computer models than December’s Clean Air Strategy. The measures including the CAZ (it is a CAZ C+ type), are estimated to be able to bring NO2 concentrations down to 39.2 micrograms/m3 in the most polluted location, the train station, against a legal limit of 40 [pdf 34].

A breakdown (pdf 41) explains the NO2 pollution is “Disproportionately caused by particular vehicle types – whilst private cars make up the majority of vehicles on our roads, diesel and older petrol buses (1% of the vehicles but 5% of emissions), London-style Hackney taxis and Private Hire taxis (3% of vehicles but 4% of emissions and trips heavily focused on the city centre), HGVs (3% of vehicles but 15% of emissions) and LGV vans (13% of vehicles but 26% of emissions) are disproportionately responsible for the level of NO2 emissions from road transport”. Half of all emissions are from local road transport, with some of the other sources regulated by other means. The Clean Air Strategy stated that this figure rises to 80% in areas of illegal AQ, though this figure is not repeated in this report.

Note especially how 41% of NOx emissions come from goods vehicles (LGVs plus HGVs). (The CAS (page 58) had estimated it was just 29%). This explains a lot of the thinking and more than any other factor, makes it credible that the Council can meet legal limits without charging private cars to enter the CAZ. What they have had to do is propose that taxis must convert to electric, hybrid or LPG – rather than just Euro 6 diesel standard – to avoid the charge.

Charging private car drivers is a really thorny issue. It is owners of old diesel cars that would be worst hit. They are likely to be relatively poor and unable to afford to upgrade to a modern Euro 6 car, (unless there is a hugely generous scrappage scheme). A possible answer is to propose offering public transport tokens as an alternative. But these would rarely compensate for the convenience – or perhaps necessity – of a car, especially if they are used to transport heavy items or people with limited mobility.

However, there is likely to be continued controversy as SCC seeks to persuade the Government to provide comprehensive financial support to commercial drivers. A section is included on this [pdf 49 onwards], here are some main points:-

[pdf 51] “How we will support drivers

…As part of our Outline Business Case (OBC) to Government, we are likely to set out a support package for taxi drivers in Sheffield that will provide a mix of grant funding and interest-free loans to enable drivers to change their vehicles to meet the new standards. This is in-line with proposals in other cities. We are likely to seek Government funding to cover the cost of the loans through our OBC and we will set a limit on how much funding is available per driver. “

[pdf 52 on] outlines how companies using HGVs and LGVs will be supported. Mainly grants and loans but will consult.

The SCC hope to win Government funding such that all buses will meet Euro 6 standards over time and so be exempt from charging.

Some points that are missing

There is no legal limit for small particulates, which cause comparable health problems but are not expressly covered by these plans. The Government is now looking at measures to tackle particulates, such as regulating wood-burning stoves and promoting research on cleaner materials for clutches and brakes.

The CAZ will not do much to reduce illegal NOx levels in Tinsley so SCC have committed to press the Government to act to reduce the main culprit there, emissions from traffic on the M1. There are also a number of other areas, outside the city-centre with illegal air quality eg Burngreave, Ecclesall Road, Penistone Road and Queens/London Roads. The report does not appear to detail measures that would substantially reduce NO2 levels in these.

The report states that the plan is for both Rotherham and Sheffield. This document does not detail Rotherham’s proposals and I know nothing of them.

I have not found any reference to measures to discourage city-centre parking, such as higher charges or a Workplace Parking Levy for larger employers. This may be because the Government guidelines require Local Authorities not to introduce measures that go beyond what is required to meet the law.

Chris Broome November 2018