SUBMISSION TO THE MAYOR OF LONDON ON AIR QUALITY
The Chelsea Society supports the Royal Borough of Kensington and Chelsea’s Response to the Mayor’s New Proposals to Improve Air Quality consultation. We share their concerns regarding poor air-quality, and we welcome the Mayor’s proposals to achieve improvements to the quality of London’s air.
Poor air-quality is linked to around 9,400 deaths per year in London, and air-pollution causes more than twice as many deaths as road traffic accidents. Two pollutants of particular concern are nitrogen dioxide (NO2) which aggravates symptoms in asthmatics, causes inflammation of the airways and reduces lung development and function; and particulate matter (PM) which contributes to the risk of cardiovascular and respiratory diseases such as lung cancer. There is also evidence that exposure to traffic fumes contributes to dementia.
Most of the air-pollution in Chelsea is caused by exhaust from motor vehicles, and in particular from buses, taxis, and delivery vehicles. Three major east-west roads run through Chelsea – the Embankment, the King’s Road and the Fulham Road, and they are often heavily congested, producing high levels of pollution from stationary and slow-moving vehicles. The BBC website identifies the King’s Road as one of the most polluted streets in London based on 2016 figures.
Congestion (and consequent pollution) is also a problem in localised areas such as the north end of Sloane Street at its junction with Knightsbridge, and we are seeking measures with RBKC and other stakeholders to improve these. It is essential that improved traffic management schemes are introduced to keep the traffic moving, and the hours during which commercial vehicles can make deliveries in busy streets should be restricted. We note that there are proposals to relocate the long-distance coach terminal from Victoria to outer-London, which should reduce air-pollution in Chelsea.
Parking and waiting restrictions at busy times must be strictly enforced – occasional visits by traffic wardens are not enough.
Substantial traffic congestion can be caused by road-works, which need to be much better co-ordinated so that the same stretch of road is not excavated sequentially by more than one utility company. Highway authorities should give much more notice of intended roadworks, and provide clearly signed advice a long way back as to alternative routes where possible. The duration of the work should be clearly indicated and enforced. In other countries it is possible to carry out roadworks much more quickly, and it could be done here if the works were properly planned and sufficient manpower and equipment were made available, together with late night and early morning working where acceptable to local residents.
Much of the traffic we have to endure in Chelsea is not local private-car use but vehicles in transit. We believe nevertheless that RBKC should progressively increase the cost of residents’ parking permits for vehicles with large capacity engines and/or diesel engines and/or for households wanting more than one permit. RBKC has sought to remove car-club permit eligibility for diesel cars in order to incentivise car club operators to move towards cleaner fleets. They have also introduced a campaign against drivers who run their engines while parked, but this needs to be enforced. With regard to road humps, there is evidence that by forcing drivers to slow down before speeding up again, road humps cause vehicles to produce a greater amount of harmful emissions from their engines, and particulate matter from their brakes.
The Mayor has proposed an Ultra-low Emissions Zone whose western boundary is Grosvenor Place and Park Lane, but we consider that an expansion of the ULEZ to include RBKC will be necessary in order to deliver a significant reduction in air-pollution in Chelsea from motor vehicles. We would like to see this implemented by 2019 instead of 2020. Measures need to be devised to prevent non-compliant heavy-goods-vehicles (especially from abroad whose drivers may not be familiar with the restrictions) entering the zone.
Incentives should be given to use electric vehicles, but consumers need to be protected from excessive costs for the vehicles and for the electricity to charge their batteries. RBKC is already planning for battery-charging points in the Borough.
Major efforts also need to be made to curb any more large scale building developments in RBKC and in the eastern part of Hammersmith & Fulham, which serve to aggravate levels of congestion and pollution, and further overload not only the roads but the essential infrastructure. Major projects to increase the capacity of the water, gas, and sewage infrastructure will cause massive traffic disruption over the next few years and we believe it will be of crucial importance for the existing road system to be managed more effectively to avoid the already alarming air-pollution levels deteriorating still further over the coming years.
In addition to motor vehicles, pollution is caused by gas and oil boilers, and all new or replacement boilers must meet stringent emissions standards. Building owners should also be encouraged to install solar panels for heating water and generating electricity, in places where they would not impair the visual amenity of the locality. Air pollution is also caused by the hundreds of airliners which fly low over Chelsea every day emitting spent aviation-fuel, and this is one reason why air traffic capacity should not be increased at Heathrow.
Major pollution is also caused by dust and other particulate matter produced by building works, much of which is abrasive dust which is very damaging to paintings and furniture. Construction Management Plans and Construction Traffic Management Plans must pay particular attention to air-quality and must be strictly enforced.
For many years, RBKC has experienced high levels of NO2 and PM. The “Understanding the Health Impacts of Air Pollution in London” report (King’s College, 2015) estimated that in 2010, 8.3% of early deaths in the Borough were attributable to fine particulate air-pollution (PM2.5) along with a further 16.6% of early deaths attributable to NO2. This figure is the highest in London together with Westminster. The impact on children is of particular concern as there are a number of schools sited close to roads exposing pupils to elevated concentrations of NO2 and PM.
We share the concerns of RBKC about real-world diesel emissions of Euro 6 vehicles in light of findings on Euro 4 and 5 vehicles, and propose that the ULEZ standards and all other measures should be reviewed regularly to take into account actual emissions. Diesel engines have much lower emission of CO, but the main air-pollution issue is NO2 and particulates. The high rate of NOx from diesel engines comes from the high temperature in the combustion chamber which favours the oxidation of N. Particulates come from the diffusion flame that diesel engines use.
Planning Committee of the Chelsea Society
7th January 2017