A RESPONSE
TO
THE
TRANSPORT
STRATEGY
Many people in the borough believe that the current
levels of traffic in South East London are already excessive and
the recently released D.O.T. traffic volume maps (obtained by
the R.A.C.) reveal that trunk roads in many parts of the country
will be gridlocked by 2005. In addition air pollution levels already
provide grounds for serious health concern and many pollutants
are known causes of heart diseases, respiratory illnesses and
cancer. For this reason we find the fact that table 13.1 of the
E.I.A. reference tono mitigating measures proposedunacceptable,
particularly as para 11.26 forecasts an increase in nitrogen dioxide,
para 11.28 forecasts an increase in carbon monoxide, para 11.32
forecasts an increase in benezene and para 11.35 forecasts an
increase in particulate concentrations when comparing the use
of the site for the exhibition as against no development.
We also have serious reservations about the presentation
of the data. The data must be compared with the objectives set
out in the United Kingdom National Air Quality Strategy Document
issued in draft form in August 1996 and in final form in March
1997. The objectives for nitrogen dioxide is 200 pg/m3, 104.6
ppb as an hourly mean. These are meant to be interim standards
in advance of the E.P.A.Q.S. report. The pacific objectives for
policy will be the adoption of this value as a 99.9th percentile
of hourly means in a calendar year by 2005. However the E.I.A.
refers to 98th percentile readings of as much as 279 pg/m3, this
the equivalent of ignoring the top 175 hourly readings in a year
as against the top 9 readings as well as accepting a more relaxed
guide value. E.P.A.Q.S. has recommended a standard for carbon
monoxide of 10 ppm as a running 8 hour average. However though
table 11.8 refers to maximum 8 hour concentrations in pg/m3 and
using the recommended conversion rate of 10 ppm equals 11.7 pg/m3
the forecast is that in four of the five sites where measurements
were taken, carbon dioxide levels will exceed the objectives by
between 28% and 360%.
E.P.A.Q.S. has recommended 5 ppb running average
annual mean for benzene. This is equivalent to 16 pg/m3 for this
known genotoxin, carcinogen. However table 11.9 of the E.I.A.
forecasts levels of benzene at 3 of the 5 receptors at between
40% and 280% above the stated objectives.
The government has proposed to adopt a specific objective
for particulates of 50 pg/m3 running 24 hour mean as a 99th percentile,
that is to allow exceedences on four days per year. Though particulates
are linked to 10,000 deaths in the UK, 2,000 in London alone (research
by Scwartz et al 1991) table 11.10 prevents any direct
comparison of how the event would contribute to the levels of
particulates because it only provides forecasts of suspended particulate
concentrations, and for a mean and 95th percentile value.
In conclusion G.A.S.P. would urge the adoption of
the following remedial measures each of which is intended to directly
reduce air pollution arising from the event:
- 1. The designation of the peninsula site
and surrounding area as an air quality management area.
- 2. Franchises to be issued for vehicle engine
tuning on the site and kerbside vehicular emission testing to
act as an incentive for poorly maintained vehicles to use the
service.
- 3. Taxis and coaches could be allowed to
park on the site only if they can be considered to be minimal
street level emission vehicles, examples of these are as follows:
- a. fitting an ecoflow online fuel conditioner
to diesel engines larger than 3,000 cc.
- b. ensuring that buses and taxis in particular
are fitted with SPA air/steam inspirator which on heavy diesel
polluters can reduce total hydro carbons including particulates
by 39%, Carbon Monoxide by 38.1%, Carbon Dioxide by 8% and Nitrogen
Oxides by 19%. The effect on petrol cars can be even more striking
due to the greater volatility of petrol.
- c. Liquid Petroleum Gas powered coaches and
buses
- d. electric powered site service vehicles
- e. fitting Hyperlube VX2 emission control
units on to the fuel system of engines making regular trips to
the site. The system can deliver reductions in emission of up
to 80%
- f. use buses, coaches and taxis powered by
natural gas, these vehicles can eliminate the emission of particulates
and reduce benzene emissions by 97% in comparison with petrol
and diesel engines
- g. encourage coaches to fit battery guards
to prevent flat batteries so that there can be no justification
for coach drivers leaving their engines running when waiting to
pick up passengers
- h. compel heavy goods vehicles to be fitted
with C.R.E.T. systems to reburn the combustion products prior
to them becoming exhaust emissions.
June 1998