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Viewpoint: Issue 542 1 Apr 2010

Too many councils are sleepwalking their way towards Low Emission Zones

Gordon Telling, Freight Transport Association

With the advent of the DfT’s new Urban Challenge Fund comes the prospect of a rash of new Low Emission Zones across the country. But with local authorities and central government alike growing increasingly anxious about meeting European Union air quality targets it’s time to debunk the Low Emission Zone (LEZ) as a panacea for clean air.

When the concept of Air Quality Management Areas emerged in 1997, reducing high levels of particulate matter (PM10), oxides of sulphur (SOx) and...

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Your Comments:

9 Apr 2010

This is a useful contribution but rather than debunking LEZ there are unfortunately a number of errors that should be highlighted to help readers in the transport community.

According to government data Gordon is absolutely correct to say that there have been highly significant cuts in UK total and transport emissions of SOx, NOx and PM from the 90's onwards. So much so that SO2 is no longer a local pollution problem so I'm not sure why this is even mentioned.

However, concentrations of NOx, NO2 and PM10 while reducing have not reduced to the required extent such that the air quality objectives can be achieved in many urban areas. One thing that must be corrected is that in fact background NOx and PM concentrations HAVE reduced. It is the concentrations (NO2 in particular) found near roads where people live that have not experienced reductions that were anticipated from the introduction of the Euro standards. This is the rationale for LEZs.

Where Gordon is on firmer ground in my opinion is on the potential pitfalls of LEZs.

1. Consistency - TfL wants all LEZs to follow their model (they would say that wouldn't they). Other commentators agree that consistency would be helpful. However, the London scheme does not achieve compliance with objectives and the required focus of LEZs (frieght, buses, others and which standards?) varies across the country. There is nothing in the national stategy nor legislation that compels any authority to act in any way other than self-interest.

2. Costs - Of course compliance with the objectives implies very large costs due to writing off assets and early replacement investment. But Gordon does not mention the existing public health costs from transport pollution. Both need to be weighed in decisions.

3. Effectiveness - Related to point 2 are the emerging data that later Euro standards for HDVs, while achieving type approval under test cycle conditions, have apparently much worse performance in real life conditions. There is not much point replacing a vehicle if the new one has the same emissions. If true this tends to undermine the cost-benefit arguments used to introduce the Euro standards in the first place. The EU is looking at this issue and in my opinion it is high time to revisit the national cost-benefit analyses.

4. Timing - Gordon is incorrect to say that the debate has moved on from noxious emissions. In the last 12 months it is more correct to say that the debate has swung back towards air quality in urban areas. This is driven by the fact that the UK's initial application for an extension to comply with PM10 objectives was refused (since it did not demonstrate ultimate compliance) and the forthcoming application for a similar extension for NO2 is likely to be an even more complex issue. Compliance matters in law and the media, Ministers and the Audit Commission are all concerned. Compliance needs to be achieved by 2015 at the latest and costs on the primary sources of the problem are now unavoidable. However, this being the case we are in danger of forcing replacement costs twice on the freight industry - once to comply with air quality legislation and a second time (when?) to make progress with climate change legislation. This issue is in my view entirely created by governments (home and abroad) that refuse to properly align climate change and air quality transport policy.

This comment unavoidably skims the issues but fully detailed information would go on for pages. However I hope that this has been a useful and thought provoking response.