5Improving delivery of the 2017 plan
Charging Clean Air Zones
48.One of the 2017 plan’s key proposals was the establishment of charging Clean Air Zones (CAZ). These would require vehicle owners pay to enter or move around the designated area if their vehicle did not meet a required standard. The plan proposed four types of charging zone categories which councils could implement, depending on their assessment of local need:
- Band A - Buses, coaches and taxis
- Band B - Buses, coaches, taxis, and heavy goods vehicles (HGVs)
- Band C - Buses, coaches, taxis, HGVs, and light goods vehicles (LGVs)
- Band D - Buses, coaches, taxis, HGVs, LGVs, cars, motorcycles and mopeds
49.The 2017 plan was preceded by the publication of a Draft Technical Report, which examined the expected impact of various potential air quality improvement measures.117 The results showed that establishing Clean Air Zones would be “the most effective way to bring the UK into compliance with NO2 concentration levels in the shortest possible time”.118 The recommendations in the final 2017 plan however did not appear to reflect this finding. The plan proposed that local authorities should introduce charging Clean Air Zones only if other non-charging measures were shown to be insufficient, and “for a limited time period and should be lifted once legal compliance is achieved”.119
Charging zones and mandation
50.Stakeholders expressed mixed views on the 2017 plan’s charging zone recommendations. Some were sceptical about the merits of charging and said it was critical for local authorities to exhaust all possible options before resorting to charging Clean Air Zones.120 The Society of Motor Manufacturers and Traders (SMMT) believed the requirement to first identify alternative measures “provides a good basis for the assessment of options by local authorities”.121
51.Proponents of charging zones were critical of the apparent contradiction between Defra’s technical findings and policy recommendations.122 The Chartered Institution of Water and Environmental Management believed the 2017 plan “ignores its own technical evidence that identifies charging Clean Air Zones as the most effective way to reduce air pollution in towns and cities”.123 The Institute of Air Quality Management highlighted that the requirement to exhaust ‘non-charging measures’ would involve similar methods to those taken under the existing Local Air Quality Management (LAQM) framework, which has “largely been ineffective at reducing NO2 concentrations”.124 The Institute believed it was “essential that national governments take the lead and mandate the necessary action (based on the local assessment) to protect human health, as they have for other politically sensitive public health issues, such as smoking”.125
52.Introducing charging zones would be politically contentious for many councils, particularly if they opted for Band D Zones, which would charge private vehicles. The British Lung Foundation believed that Clean Air Zones would be “difficult to implement locally without leadership from national government and a persuasive, evidence based, compelling argument”.126 The Mayor of London told us, however, that the T-charge indicated the political acceptability of charging zones, and that this scheme had reduced diesel sales and changed people’s travel behaviour.127
53.We asked witnesses whether the Government should mandate charging zones where necessary. ClientEarth endorsed such a move, saying it would provide clarity and national leadership.128 The LGA was clear however that local authorities “do not want to be mandated” and would prefer to find “local solutions that work for them”.129
54.The LGA was nevertheless critical of the “onerous new requirement on authorities to demonstrate that they have considered the impact of all possible measures” before opting for charging, saying this would mean local authorities would have to “demonstrate the ineffectiveness of measures that they are legally obliged not to carry out. Councils will have to demonstrate the ineffectiveness of measures that Defra’s own technical report clearly indicates will not achieve the required improvements to reach compliance”.130 The requirement to assess ‘other measures first’ is thought to have added a six month delay to the first five cities required to produce clean air strategies under the 2015 plan.131
55.We asked Ministers why the 2017 plan did not mandate, or indeed appear to prioritise, the implementation of Clean Air Zones. Dr Coffey suggested such a move would not be welcomed by local authorities, which she believed were “desperate to try to find other ways to improve the air quality”. She stated that the Government would work with local authorities if charging zones appeared to be the only way to improve air quality as quickly as possible.132
56.The Government is failing to provide clear messaging and national leadership on the issue of charging Clean Air Zones (CAZ). Defra’s technical report found that charging zones offer the fastest and most effective route to air quality improvements, yet the 2017 plan requires councils to demonstrate that all other measures will fail to achieve the necessary results before introducing a charging zone. This lack of clarity is causing confusion and hampering councils’ ability to tackle air pollution as quickly as possible.
57.Defra’s modelling already shows that, in many cases, non-charging options will not be as swift or effective as charging Clean Air Zones. If local authorities are regularly exceeding NO2 concentration limits and identify a charging Clean Air Zone as being the most effective mitigation strategy, they should be able to receive Government support for implementing a CAZ without having to go to onerous lengths to demonstrate the inefficacy of other options. If this approach fails to deliver the required improvements as quickly as possible, the Government should consider mandating charging zones in hotspot areas.
58.There is a risk that, if not supported with additional measures, Clean Air Zone charges will disproportionately affect low-income drivers. We recommend that all Clean Air Zone proposals are accompanied by mitigating measures to reduce the effect on low-income motorists.
Aligning Clean Air Zones with public transport and active travel goals
59.Our evidence suggested that reducing private vehicle use through improving public transport and encouraging active travel should lie at the heart of any clean air strategy.133 This would help address problems that are not likely to be entirely solved by Clean Air Zones, since low emission vehicles will still be linked to problems including harmful particulate matter from tyre and brake wear; congestion; and wider health issues such as obesity.134 The evaluation of public transport solutions should also give appropriate weight to the effects of tyre and brake wear from buses and other vehicles which use rubber tyres and braking mechanisms. Particulates emissions from these, known as the ‘Oslo effect’, can be as significant a contributor to poor air quality as tailpipe emissions. Rail based public transport options, such as trams, can often have a more beneficial air quality impact. We were told that the introduction of Clean Air Zones needed to be accompanied with a suite of complementary policies to address these issues and ensure maximum benefits are gained from investments in air quality.135
60.Some witnesses were sceptical about the level of joined up thinking and additional support accompanying the introduction of Clean Air Zones.136 Campaign for Better Transport argued that “Much greater weight needs to be given to the advice from the health profession to steer public investment in active travel and public transport”.137 The LGA agreed that the “primary focus” of local authority policy should be “focused on demand management, and enabling active and public transport travel as a first priority where that is feasible”.138 It criticised the support for enabling active travel and local transport, saying that funding mechanisms were fragmented, unconducive to long-term planning, and subject to bidding processes that created a “patchwork” of infrastructure coverage.139
61.Local authorities and industry bodies were also concerned that Clean Air Zones could discourage bus use. While buses may be amongst the largest contributors to NO2 per vehicle, on a per passenger basis they can have a far lower NO2 footprint.140 The LGA noted that buses were likely to be targeted by Clean Air Zones, which could lead to higher costs for operators and passengers, and precipitate a decline in services.141 This would be particularly problematic if a council decided its Clean Air Zone would not charge private car users, as the incentive to use public transport would further decline. Fleet operators and industry bodies told us there was not enough funding available to upgrade the non-compliant buses likely to be affected by Clean Air Zones.142
62.We asked Ministers how they were ensuring that action on air quality included appropriate support for improved public transport and active travel. Parliamentary Under-Secretary of State for the Department for Transport Jesse Norman told us that a variety of measures would be introduced at the local level supporting “the reconfiguration of local transport” and providing cleaner modes of travel.143 We put it to the then Exchequer Secretary Andrew Jones that increases in public transport were unlikely when costs for public transport are projected to rise whilst those for private motorists are falling.144 Mr Jones maintained the Government was “encouraging people to use public transport with the greatest period of investment in public transport in generations”,145 but acknowledged that there was “fairly flat or gently declining bus use”.146
63.We also asked Ministers about the number of non-compliant buses in air quality hotspots, how much money was needed to upgrade them, and how this related to the level of available funding.147 Dr Coffey told us she was “not aware” of the relevant data.148 The Government subsequently provided details on the extent of its data on the number of clean buses and the various funding mechanisms supporting this, but noted it did “not hold data on the proportion of the current UK bus fleet that has been retrofitted to Euro VI-equivalent emissions standard” as funding streams “did not set outcomes in terms of Euro standards equivalence”.149
64.Reducing the need for private vehicle use within our metropolitan cities should be a key aim of air quality policy. There is not enough urgency in the Government’s current strategy to achieve this. Defra and the Department for Transport must work closely with local authorities to ensure that councils introducing Clean Air Zones receive the support they need to implement complementary measures which encourage car drivers to switch to public transport, active travel or electric vehicles. This may involve granting local authorities greater powers, for example over lane rental schemes and new development. Defra and the DfT should also urgently evaluate whether there are sufficient resources to ensure enough clean buses can be introduced in air quality hotspots to reduce NO2 concentration levels as fast as possible. The Departments should inform us of the outcome of this assessment in response to this Report.
Avoiding displacement and maximising CAZ benefit
65.We heard a number of complaints about the lack of clarity over displacement. Councils were concerned that charging zones might simply encourage polluting vehicles to be deployed to areas outside a Clean Air Zone. As Sandwell Metropolitan Council told us:
Displacement is a major concern for those local authorities who border Clean Air Zones (CAZs) as older vehicles may be diverted through surrounding areas and displace the problem. Specific consideration needs to be given to addressing how new impacts will be assessed, managed and controlled and whether bus operators should be permitted to simply divert old bus stock to other areas, particularly if they already show compromised air quality.150
66.The Chartered Institute of Environmental Health highlighted the issue of health inequality, arguing that Clean Air Zones:
may remove “dirty vehicles” from a city centre but they will not be removed from the road. There is the potential over time for this to encourage older more polluted vehicles to become condensed around lower socio-economic areas thus increasing air pollution and inadvertently increasing health inequalities.151
The organisation called for clearer guidance to ensure that local air quality schemes will not negatively affect neighbouring areas.152
67.Defra and the Department for Transport must clarify in response to this Report how they will ensure that Clean Air Zones will not simply displace polluting vehicles to areas where monitoring is more limited, and what systems will be implemented to verify this accurately.
Charging zones and economic impacts
68.The 2017 plan advised local authorities implementing air quality measures to “minimise their impact on local residents and businesses”.153 If councils introduce charging zones, the plan stated that “support should be available to the owners of affected vehicles”.154 The Local Government Association highlighted the likelihood of “conflict” between the need to reduce pollution as quickly as possible and simultaneously ensure the impact on affected populations and businesses was minimal.155
69.Stakeholders expressed a number of concerns about the local economic impact of Clean Air Zones, including:
- The burden on SMEs: The Freight Transport Association believed the 2017 plan “will place far too great a burden on businesses in our towns and cities, especially SMEs” which often rely on vans and HGVs.156 The Federation of Small Businesses cautioned that air quality interventions might lead to SMEs and trade services being deterred from entering city centres to avoid charging fees, which would unfairly advantage larger businesses better able to bear the costs.157
- Insufficient adjustment time: The Builders Merchants Federation warned that the current timescales for Clean Air Zones will leave insufficient time for small businesses to adjust, as they may be unable to replace vehicles quickly enough to comply with the new Clean Air Zone standards. The organisation said more time was needed for small businesses to adjust their vehicles.158
70.We asked Ministers how the Government was addressing concerns from small businesses and local communities. Dr Coffey told us that councils will be able to access the £220 million Clean Air Fund to mitigate some of the impacts of new air quality measures on affected residents and businesses.159
71.Defra and the Department for Transport must ensure Clean Air Zone plans include robust economic impact assessments, and work with local authorities to ensure affected communities and businesses are made aware of the support measures accompanying clean air plans. To ensure small businesses are not disproportionately affected by the new measures, Defra and the DfT should also investigate the feasibility of providing small businesses with more time or resources to upgrade their vehicles.
119 Defra, UK plan for tackling roadside nitrogen dioxide concentrations - an overview, July 2017, p.8
127 Q76
128 Q28
129 Q112
132 Q153
143 Q145
144 Q143
145 Q142
146 Q144 [Andrew Jones]
147 Qq272–274
148 Q274
153 Defra, UK plan for tackling roadside nitrogen dioxide concentrations - detailed plan, 2017, para 117
154 Defra, UK plan for tackling roadside nitrogen dioxide - an overview, 2017, para 26
159 Q155
Published: 15 March 2018