APPENDIX 11
Memorandum submitted by Greenwich Action
to Stop Pollution
G.A.S.P. is an environmental action group with
a membership of just over one hundred members, the majority of
whom are amongst the closest residents to the Millennium Dome.
We have held public meetings and house to house interviewing in
the streets adjoining Greenwich penninsula as part of our environmental
work and this activity has had the added advantage in that it
has enabled us to be able to gauge the public mood in East Greenwich
towards the Millennium Dome. This is in contrast with the New
Millennium Experience Company who have ignored the two previous
reports from the Committee and have still not held a public meeting
in Greenwich.[4]
Our experiences suggest that they are worried about one of two
things both of which they would find equally disconcerting-apathy
or antipathy. Whilst the Dome may always struggle to win friends
what follows are proposals to make the Dome an acceptable neighbour.
THE TRANSPORT
STRATEGY
The Jubilee Line Extension
We share the Committee's frustration over the
delays to the construction of the Jubilee Line Extension. It is
our belief that the deadline of 22 December for the connection
from Stratford to Green Park is so close to New Year's Eve that
the line if it opens at all will be subject to teething problems.
Though parts of the Jubilee Line may well operate smoothly the
problems will occur for those trying to access the Dome from the
north-west quadrant, some 1,486 car spaces during weekdays and
3,433 car spaces at weekends.
The prospect of the Jubilee Line Extension being
unavailable has led to London Transport developing contingency
plans in collaboration with the New Millennium Experience Company
but once again the feeling that the Dome is something that is
being done to Greenwich rather than for Greenwich persists; to
date there has been no public consultation with local residents
on what will be in these plans. There is enormous local anxiety
that the bus lanes being put in place are to allow coaches visiting
the Dome to be able to use them to exit the penninsula, the coach
operator's dual licence which would enable coaches to visit both
the Dome and Greenwich town centre may make the coach routes impossible
to enforce.
We are not prepared to countenance a situation
where hundreds of buses or coaches, which would be unlikely to
be zero emission vehicles, are used to ferry tens of thousands
of people through the already congested and polluted roads of
Greenwich. Our message is simple, if the Jubilee Line Extension
fails, the road network must not take the strain.
The park-and-ride strategy
We recognise that NMEC. are now increasing their
efforts to locate the park-and-ride sites at or near the interchange
points of the M25 and the rail network but feel that the further
support of your committee will be required to achieve the optimum
situation. G.A.S.P. are delighted by NMEC's retreat from their
original target for car parking spaces and in view of the continuous
reviews of their needs over a two year period we suspect that
further reductions may be possible. Have NMEC. proved the case
for the Woolwich Arsenal site?
The Woolwich Arsenal planning application ref
99/1469/F refers to the need for 1,000 car parking spaces but
page 3-3 calls for 725 car parking spaces. The public require
clarification of the exact numbers.
It is a distinct possibility that the Woolwich
Arsenal site will be a magnet for traffic drawn across South London
only to make the reverse journey (albeit on shuttle buses) back
across the Borough to reach the Dome. The 725-1,000 car parking
spaces represents between 725 and 2,000 cars arriving and leaving
each day, (depending upon whether there is an evening event).
In addition the shuttle buses could represent between 37 and 100
one way trips to the Dome assuming that each car is carrying an
average of three occupants and that each mini bus is actually
a 60 seater coach. It cannot be stressed too highly that in view
of the congestion and environmental impact of the already unacceptable
levels of traffic on the local roads, a park-and-sail rather than
a park-and-ride option is the only sane alternative.
Kiss-and-drop
Since the Committee's last report the proportion
arriving by this means has been very fluid, it was originally
put at 5 per cent by NMEC. rose to 8 per cent in the June environmental
statement and has now returned to 5 per cent. This represents
a considerable number of taxi trips and car trips. We are concerned
that the taxis and the coaches have a very poor environmental
profile and that these vehicles should be licensed to serve the
site. A condition of their licence would be at least Euro 3 standards
for their exhaust emissions. Coaches should similarly not just
comply with the Coachmark standard but Euro 3 standards. There
should be emission testing on the peninsula to help enforce this.
We would refer the Committee to the fact that commercially manufactured
zero emission vehicles (at street level) do exist and that we
would be pleased to provide further details.
Kiss-and-drop should be discouraged by limiting
the space available for disembarking and by congestion charging
on the peninsula itself.
An air quality strategy for dealing with a pollution
episode at the Dome
Air quality is a highly complex and scientific
issue but to many residents of Greenwich it is something you can
see, taste and smell all too regularly. G.A.S.P. first became
aware of the numbers of residents who were leaving the Borough
as a result of the physical discomfort of the high levels of pollution
from the survey work of Alfred Banya for Deptford Public Health
group and since his report we have accumulated the names of other
parents who have taken their children out of Greenwich. Though
the court case brought by the children with asthma against Greenwich
Council collapsed on a legal technicality in December 1995, their
cause remains unanswered. The judge who recommended that parents
should move from the vicinity of Trafalgar Road, Greenwich would
probably say the same today.
A recent analysis of the trend in Nitrogen Dioxide
and particulate levels during the last year indicates that these
pollutants are increasing, and are above E.P.A.Q.S. standards
as set out in January 1999. Greenwich Council's stage two review
of their Local Air Quality Management recommends that stage three
is proceeded with for these pollutants and Sulphur Dioxide. This
trend is not surprising perhaps in view of government released
figures which recently revealed a 9.3 per cent growth in traffic
since May 1997.
Unless an air quality strategy is agreed in
advance by all concerned, commercial pressures will mean that
nothing will happen to prevent the asthmatic attacks and the hospital
admissions for respiratory diseases that the Dome's car borne
visitors could trigger.
The D.E.T.R. guidelines as to what constitutes
low, moderate, high and very high levels of pollution for Nitrogen
Dioxide, Sulphur Dioxide and particulates should act as thresholds
which are linked to specific actions to further reduce traffic
on approach roads to the Dome.
There is a model of good practice for this situation
in a major tourist destination which can be adapted and then applied
to the Dome. On 1 October 1997, new laws were enforced in Paris
to restrict traffic movement during a pollution episode. The same
weather conditions which led to the traffic restrictions in Paris
have often occurred in Greenwich; sunny conditions with high pressure
air over low pressure air and low wind speeds at ground level.
G.A.S.P. would recommend the following strategy:
| Pollutants | Threshold
| Action |
| Nitrogen Dioxide | 150 ppb 1 hour mean monitoring at least two points
| Stage 1 alert
NMEC and Dome tour operators along with public transport operators informed.
|
| Particulates | 50 mcg/m3 |
|
| Nitrogen Dioxide | Exceedence beyond 300 ppb
| 1 hour mean Stage 2 alert |
| Particulates | Exceedence beyond 75 mcg/m3
| 1 hour mean public and authorities informed. Congestion charging. Increased public transport provision. Car parking reductions at peninsula developments.
|
| Nitrogen Dioxide | Exeedence beyond 400 ppb
| 1 hour mean Stage 3 alert |
| Particulates | Exceedence beyond 100 mcg/m3
| Ban on cars with even or odd number plates on alternate days and free public transport. Euro 4 or zero emission coaches or taxis only allowed on the peninsula.
|
In Paris similar measures brought about a 10 per cent increase
in the use of public transport and reduced the volume of traffic
in central Paris by 17 per cent and on the ring roads by 6 per
cent. The emissions of Nitrogen Dioxide and Carbon Monoxide were
reduced such that the level 2 threshold was not triggered.
To date the only report that our organisation has seen regarding
air quality is contained in the original planning application,
an environmental statement referred to in our first submission
which admitted that air quality would deteriorate and at that
time offered no mitigating measures. In concluding our third submission
we urge the New Millennium Experience and the government to do
more to safeguard our quality of life.
Previous reports
Many people and organisations have examined the organisation
of the Dome and brought their researches to the attention of your
Committee, the last set of appendices in particular raised an
enormous range of issues that the New Millennium Experience Company
have so far not answered. We hope your Committee will manage to
obtain these answers. We are particularly keen to see a sustainable
millennium festival with a lasting legacy in terms of the jobs
created and would urge your Committee to examine this last aspiration
in your next report.
October 1999
4
HC (1997-98) 340-1, para 56; HC (1997-98) 818-I, para 48; and
HC (1998-99) 21-I, para 31. Back
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