The Chelsea Society organised a zoom meeting on 9 November 2020 to discuss Pollution and Congestion. Over 20 members participated plus Cllr Johnny Thalassites and Cllr Cem Kemahli.
Many residents are concerned about the level of congestion in Chelsea and the resultant pollution from standing or slow moving traffic which affects many streets. The meeting was called to assess workable solutions which will be acceptable to residents and local business.
Chris Lenon set out the form of the meeting involving a brief summary of the issues and then a series of open questions to frame a discussion regarding parking permit policy (which is currently under review) and then roads.
Summary of Issues
Congestion and pollution are particularly acute now (aggravated by bridge closures and greater traffic from COVID). Congestion and pollution are London-wide issues which Chelsea alone cannot solve. TfL have targets of acceptable air quality but are not achieving them.
Congestion is caused by commercial traffic through and into Chelsea, shopping traffic, school runs and local residents.
Congestion will only reduce with fewer vehicles on the roads in Chelsea or phasing that spreads out journeys. Road pricing to achieve this (congestion zones, etc) affects poorer residents more.
Pollution from brake and tyre wear is caused by all types of vehicles.
In addition, particulate pollution is worst for diesel, then petrol and then hybrid vehicles. Electric vehicles cause no particulate pollution from their motors.
Particulate pollution from emissions can be decreased by reducing the number of polluting cars and increasing the number of electric vehicles (although this does not affect congestion per se).
In looking at road transport specifically, consideration should also be given to the wider impact of the present ECOWS gyratory system, which Martyn Baker has addressed consistently as an area requiring review. It requires detailed survey and assessment, but it seems clear for example that the frequent one-way backlogs in the system, as well as the complex, indirect and possibly nugatory movement of coaches, including the informal holding-pen arrangements in Royal Hospital Road, are likely to generate excessive pollution.
There are plans to introduce the extended London ULEZ that will include RBK&C from 24 October 2021. There is also a subsequent objective of Zero Emissions in London and some other city centres by 2025. These need to be considered in developing policy.
The key is to find policies which can be used to reduce congestion and pollution which are acceptable to local residents and businesses.
Should there be a limit of permits per household? Some advocate a maximum of two per household with a higher charge for a second permit.
If so, what is the limit on permits per household?
What should the higher charge be for more than one vehicle – which multiple?
Should pricing of parking permits be based on co2, particulate emissions or size of vehicles (or a combination of all three)?
Should size be length or length and width?
Comments included, how were multiple person households dealt with? Are local residents the cause of congestion or is this caused by through traffic and commuting so does the parking permit regime affect pollution and congestion?
The consensus was that through traffic is the primary cause. Many thought that local residents did not use their cars much for local journeys.
A member said that 3 or more permits were excessive so 2 seemed a sensible limit. Another member said that there should be one permit per household which could be used for any car registered as belonging to the household but not more than one car at the same time.
Cllr Kemahli said that the number of permits being issued was decreasing by roughly 2% per annum. In reply to the concerns about through traffic he said that data on the origin of traffic was not good.
The council were considering moving the pricing from CO2 emissions to a hybrid of CO2 emissions and size of vehicle.
The questions posed were:
Should some roads and/or areas be limited local residents’ vehicles (eg Sands Road, Fulham).
Should some roads only be accessible on alternate days (odd and even number plates – eg Paris)
Should some roads ban diesel vehicles to reduce particulate pollution?
Should some roads be usable by electric vehicles only?
Should restrictions apply only in rush-hour periods?
Should entry to some roads be restricted from certain directions (Kings Road east bound into Beaufort Street) Proposal for pedestrian safety.
It was important to consider the displacement consequences of each proposal (is traffic just moved to other roads? Or is congestion and or pollution reduced overall)
Everyone agreed that we needed more data on where the traffic came from. Some thought that there was confusion over who was responsible for solutions between RBKC and TfL (with government interference also cited). Members commented on the effect of road works, cycle ways, bad parking, bridge closures and lax enforcement of delivery loading and unloading.
Some felt that TfL modelling was misleading (eg Beaufort Street/ Kings Road) and that local knowledge was needed. Some advocated traffic police to address obstructions.
The current proposal to remove the left turn from Kings Road eastbound into Beaufort Street (to improve pedestrian safety) would have major diversionary traffic consequences as drivers sought to avoid it by using The Vale instead to get to Beaufort Street. Some complained about the ban on non local traffic in Sands End in Fulham and the traffic displacement resulting.
Cllr Thalassites said that RBKC controlled all the roads in Chelsea except the Embankment and Earls Court gyratory. Concerning the Embankment/ Beaufort Street junction, the council have been pressing TfL to improve the safety of pedestrians and cyclists, and hope this work will start soon, (this has been a Chelsea Society objective).
RBKC has allocated funds to maintain Albert and Chelsea bridges and complained that other Boroughs were not doing the same.
The Council has installed electric-car charging points to encourage uptake of electric cars. It now has the largest number of charging points for a local authority in England and 90% of residents are within 200 yards of a charging point (the objective is for 90% of residents to be within 100 yards of a charging point.)
The Council are proposing that the speed limit on all roads in the borough will be 20 mph (TfL are implementing this on the Embankment). This will also be policy for all London boroughs. The Chelsea Society were not consulted, but have arranged a Zoom meeting with the Council to understand the proposal.
Cllr Kemahli then responded on environmental issues. In terms of understanding traffic movements, there will be data from TfL, and the ULEZ (Ultra Low Emission Zone) will provide ANPR data as part of the enforcement infrastructure. Going forward, we need to work out the best way to access the data and analyse it in formulating a congestion strategy.
The ULEZ will start in April 2021 covering the area within the North Circular and South Circular roads and given the charge for diesel vehicles older than 2016 the level of diesel pollution is expected to reduce.
The Council have partnered with two organisations to address pollution. Imperial College will be using RBKC as a test area for monitoring (funded from Imperial College). As brake and tyre pollution are a problem with all vehicle types, the Council are partnering with a company which is developing a lifetime tyre which will reduce particulate pollution from tyres.
Conclusions and Actions
The key issue identified is the lack of information and data on traffic movements. The Chelsea Society will work with the Council on this issue to improve our understanding.
The Society will comment on the parking permit review.
The Society will meet with the Council on the 20 mph borough-wide proposal.
The Society will work with residents to ensure that proposed road changes are always examined (with local knowledge) to understand traffic displacement issues.
THE CHEYNE WALK TRUST has commented as follows:
The Cheyne Walk Trust (CWT) is the Residents’ Association for the River Thames area of Chelsea with some 200 members by subscription and represents their interests in maintaining and improving the quality and heritage aspects of the area in which they live.
Our members are very concerned by pollution levels in South Chelsea and strongly support measures to promote a healthier atmosphere and enhance our environment.
At the outset it would be helpful to understand clearly the present status of data and broad objectives for local conditions as well as the wider metropolitan context in which these need to be considered. The first step in designing a future vehicular control scheme should be to develop a clear understanding of existing and developing pollution factors including how these may be diminishing already through present trends and controls.
From the RBKC website, recent work would appear to be based on the GLA Air Quality in RBKC (GAQ RBKC) paper dated November 2012, which seems to be the basis of the RBKC Air Quality Action Plan 2009 -2014. Given Govt and GLA initiatives, these sources are clearly somewhat out of date and it would be helpful to know how far they have been reviewed or updated to reflect present monitoring and objectives, both agreed and emerging.
Sources of Pollution
Data on the causes of pollution are, it seems, somewhat historic and quite confusing. The most significant cause of pollution by PM appears to be that introduced from outside London, given as 54% – 62%. For direct Borough generated pollution, the first source is Commercial and Residential Heating Systems (40/50% and forecast to rise further) with Buses/LGVs/HGVs the next. Cars come some way behind as a group; motor cycles not being identified it seems (although included in the Residents’ Permit scheme), despite the substantial growth in MC delivery services. There are also significant contributions from work and construction sites as well as vehicle brake and tyre wear. It would be helpful to understand what proportion of vehicle engine pollution can be attributed to residents’ vehicles. The quoted estimates are rather dated but any plan should require a current, comprehensive and informative data set as its start point and to provide a current baseline for reference. Not least, it is perhaps too easy to pursue simplistic resident penalising systems not favoured by most of those who live in the Borough and create very little of the actual pollution that is of concern.
The present state of pollution monitoring seems to be both patchy and inadequate. For example, there appear to be only three PM10/2.5 monitoring sites in the Borough: Earls Court, North Kensington and Cromwell Rd. There would seem to be nothing in South Chelsea, either in the Kings Rd or on the Embankment with the exception of a residents’ monitoring station at Oakley St/CE. There are rather more CO/NOx sites, clearly also important. We welcome advice by Cllr Kemahli that the Imperial College Inhale Project will use the Borough as a test bed, together with plans to digitize recording systems enhanced by access to DVLA data enabling more comprehensive understanding and modelling of traffic activity.
Taking road transport specifically, we consider the wider impact of the present Earls Court One Way System (ECOWS) is an area requiring review. The gyratory system is a relic of the long-abandoned scheme for a bypass along the River Thames. The present and potential impact requires detailed survey and assessment, but it appears likely, for example, that the frequent one-way backlogs in the system, as well as the complex, indirect and possibly nugatory movement of coaches, including the informal holding pen arrangements in Royal Hospital Road for the Victoria Coach Station in Westminster, are likely to generate excessive pollution.
It might also be helpful to seek an update on the impact, relevance and current management of the London Boroughs Lorry Ban (LLCS) that is designed to control the movement of HGVs above 18 tons into and through London in quiet hours in order to minimise noise and disturbance. It appears there are only 5 wardens to police this Scheme across the whole of London. There is no use of CCTV or ANPRS monitoring. It was last surveyed in May 2017 when no mention was recorded of any pollution considerations or objectives. It perhaps justifies review in the context of current pollution and congestion concerns. A one-time monitoring exercise in the early nineties indicated that some 60% of HGVs entering London during controlled hours were ignoring the LLCS.
Pollution is caused by moving traffic including vehicles in traffic queues, not by parked vehicles. This suggests that improving traffic flow should be a priority. A major cause of pollution would seem to be the actions of TfL that have effectively reduced the average speeds of traffic through London by a policy of seeking to restrict rather than promote traffic flow. This is a matter that might be addressed in the data studies called for in the data background paragraphs of our submission.
Regardless of present conditions, it would seem that the most significant pressures on residents to dispose of polluting combustion engine vehicles will be (as noted in the Council’s consultation paper) the progressive increase in costs of vehicle licencing of older more polluting vehicles and the extension of the London ULEZ with its zone movement charges to RBKC from October 2021, followed possibly by a subsequent objective of Zero Emissions in London and some other city centres by 2025. Apparently, it is already the case that the overall number of Residents’ car permits is decreasing. In view of ULEZ and Zero Emission plans It may be prudent to consider delaying any new scheme at least to October 2021. This would also provide scope better to establish and assess present and emerging pollution data. The point has also been made that seeking to accelerate the conversion to electric vehicles is itself a net carbon generating activity as compared with running on older vehicles.
- CWT members, as stated, broadly support pollution reduction initiatives but their views on detail measures vary widely:
- Greater provision of cycle lanes. Some support for this but highly contentious, many consider increasing cycle lane provision a direct factor in increasing traffic problems and pollution through resultant greater road congestion and not justified by the minimal use of cycle lanes frequently noted as well as the traffic dangers that often prove adverse in narrow residential streets with little road-space.
- Both road excavation works and the prevalence of potholes generate significant traffic hold-ups and pollution. There is a clear need for more effective co-ordination of excavation works and the use of penalties for delay. These may serve to encourage more efficient 24/7 work and better management of linked supply chain problems frequently quoted in defence of delayed excavation completions.
- The progressive switch to electric vehicles clearly is inevitable but the provision of charging facilities may well be inadequate in the urban residential area of the Borough. At present it appears that despite the well-intentioned plans of the Council to accelerate such provision only a very small number of vehicle charging points exist and a number of these (lamp-post models such as Ubitricity) are not reserved for electric vehicles. It will no doubt prove extremely difficult and costly to increase the number of charging points from the 700 or so now in place to anything remotely approaching the number of some 30,000 permits presently in issue.
- There is an argument that more vehicle parking spaces should be introduced, such as by the provision of echelon and perpendicular parking where practical.
Members of the Cheyne Walk Trust share the concern to reduce atmospheric pollution in the Borough and welcome the Council’s initiative to address this, in part by proposing a residents’ parking scheme based directly on a vehicle’s emissions.
The CWT considers that a significant first step in this matter should be to understand clearly what the present patterns, causes and developing trends are in generation and control of atmospheric pollution and the ratio of this generated by residents’ vehicles. This should provide a base line against which specific proposals may be evaluated in terms of gain, practicality and cost effectiveness.
Traffic generated pollution reduction should be considered in the context of the Borough’s location in the Metropolis and as part of the wider national and Mayoral transport and environmental improvement policies, as well as those of other London (in particular adjacent) urban boroughs. Review should therefore assess wider policies that may affect traffic reduction through and in London, including Tfl management and legacy schemes such as the ECOWS and the LLCS.
Recognising that current data capture capability is probably inadequate, the initial stage should address the need for useful data and how best to obtain this. It may therefore be beneficial that introduction of a new regime should be delayed to align with GLA plans for the extension of the ULEZ to include RBK&C in October 2021.
A significant number of Minor Improvements should be evaluated, reviewed and trialled and as far as possible be put to consultation with the residents of the Borough for practicality, impact and acceptability.