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Coventry puts NO2 compliance back in Government’s court


Andrew Forster
01 March 2019
Coventry: the council says it won’t implement a charging CAZ even if the Government rejects its funding bid
Coventry: the council says it won’t implement a charging CAZ even if the Government rejects its funding bid


Coventry City Council has ruled out introducing a charging clean air zone (CAZ)  even if the Government rejects the council’s bid for £80m to deliver an alternative package of measures to bring nitrogen dioxide concentrations down to legal levels. 

In 2017 the Government ordered Coventry to draw up an action plan to comply in the shortest possible time with the EU NO2 annual mean limit value of 40μg/m3 . The direction was issued because modelling suggested that, without action, the city would not achieve compliance before 2022.

The Labour-controlled council says its analysis shows that a charging CAZ is unnecessary because a package of other measures can deliver compliance in the same year (2024) as a city centre Class D charging CAZ covering cars, buses, coaches, taxis private hire vehicles, light goods vehicles (LGVs) and HGVs. 

Coventry has just submitted an outline business case to Government for the package, which includes a request for about £80m of grant support. The likelihood of the Government accepting the bid seems slim if Leeds City Council’s experience is a guide. Leeds’ bid for £40m was rejected, with the Government eventually awarding the council £29.3m to support a Class B CAZ covering buses, coaches, HGVs, taxis and private hire vehicles (LTT 01 Feb).

LTT asked Coventry’s cabinet member for city services, Patricia Hetherton, whether the council would switch its focus to a charging CAZ if the Government rejected the funding bid. 

“If we did not get all of the money we have bid for, we would not go back to the idea of a charging zone,” she said.

 A council spokesman added: “The council recognises that the funding requirement is significant, but the guidance has been to identify the package of measures that will address the NO2 levels in the shortest possible time, irrespective of cost. The economic appraisal undertaken by the council has demonstrated that the preferred package provides better value for money than would be offered by the benchmark scenario of a charging clean air zone, and the package would provide a transport legacy for Coventry in the form of improved transport infrastructure, including four new cycle routes and a dynamic traffic management system. 

“Government feedback on the action plan is expected during the next two months, and the city council will respond accordingly to that feedback when received. However, the council’s cabinet has been clear that a charging CAZ will not be introduced in Coventry by the city council.” 

The final line of the statement may acknowledge the possibility of the Government imposing a CAZ on the city. 

With or without a charging CAZ, Coventry says the city cannot become compliant with the EU limit value until 2024  –  two to three?years later than when its close neighbour Birmingham City Council says it can achieve compliance (LTT 18 Jan). Birmingham is planning to introduce a Class D CAZ as a key part of a package to achieve compliance. 

Modelling commissioned by Coventry suggests that, in the absence of any new action,  compliance will not be achieved until 2029.

Introducing a Class D CAZ covering the centre of the city could bring compliance forward to 2024. Modelling assumed a daily charge of £12.50 for non-compliant cars/LGVs and £100 for HGVs and coaches.

But the council believes compliance can also be achieved in 2024 by investing in a package of measures such as:  

• upgrading taxis, public transport, and business fleets to lower emission vehicles 

• real-time air quality monitoring linked to dynamic traffic management that would use variable message signs (VMS) to reroute traffic away from air quality hotspots and onto more suitable routes when required

• travel behaviour change initiatives such as travel planning with educational establishments and employers

• highway improvements to relieve congestion on two problem roads

• four new cycle routes

Colin Knight, Coventry’s director of highways, told councillors: “This package is modelled as achieving NO2 compliance in 2024, which compares with 2024 for the benchmark CAZ (realistic upgrade) scenario. The preferred package therefore meets the air quality objective, provides significant additional transport and economic benefits, helps to promote active travel, and avoids the detrimental economic impacts that a CAZ would have upon the local communities within the city.” 

The council wants £70m-£75m from the Government’s £255m Implementation Fund and £6m-£8m from the complementary  £220m Clean Air Fund. 

The outline business case prepared by consultants SNC?Lavalin Atkins and Waterman, says a Class D charging CAZ would, at £50m, be cheaper to implement, and would also generate income from charges and enforcement. 

But the consultants add: “This scenario would have significant detrimental impacts for some of the more deprived communities within the city. It would also leave no long-lasting legacy for the city, as the system would be redundant by 2027 [elsewhere the report says 2029] when full compliance would be achieved in terms of the vehicle fleet within the city.”

A ten-year economic analysis (2021-2030, discounted to 2018) concludes that Coventry’s preferred package outscores the CAZ proposal. 

The preferred package has costs of £75m, which are partially offset by benefits to road users of £20m, benefits of increased cycling of £5m, and air quality and carbon dioxide benefits of £20m. This results in a net present value (NPV) of minus £25m. 

The charging CAZ would cost £50m and impose costs on road users of £125m through things such as paying charges and upgrading vehicles. These costs would be partially offset by £15m of air quality and carbon dioxide benefits, and £50m of CAZ revenues. The resulting NPV is minus £110m.

The consultants say a Class D CAZ would actually achieve compliance between 2023 and 2026, depending on assumptions used. They express scepticism about the Government’s Joint Air Quality Unit (JAQU) advice on how road users will react to a charging scheme. 

“Initial JAQU advice is that 64 per cent of non-compliant cars and light goods vehicles would be upgraded to a compliant vehicle by owners seeking to avoid paying a charge to enter the CAZ D area. However, the ability of people, or businesses, to be able to afford to trade in their older, non-compliant vehicle for a newer, cleaner one should not be taken for granted, especially as the United Kingdom enters a period of economic uncertainty. 

“A number of factors will influence the upgrade rate that can be achieved, including the amount of disposable income available to residents and businesses, the collapse in the second-hand market for older diesel vehicles (meaning that trade-in values for such vehicles are unlikely to be particularly generous), and a general disinclination for people to commit to major purchases during a period of economic uncertainty.”

The consultants therefore undertook sensitivity tests assuming a lower rate of upgrade. 

Coventry says its traffic data collection shows that older diesel cars contribute approximately 50 per cent of the emitted NO2 at the locations exceeding the legal limit, and that road traffic accounts for 50-62 per cent of the NO2 at these locations. “This indicates that intervention focused on reducing emissions from commercial vehicles, including taxis and buses, will not solely achieve compliance with NO2 legal limits,” said Knight.

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