Air Quality Action Plan – Just not good enough

This is the Richmond Cycling Campaign Response to the Council’s Air Quality Action Plan.

You can see the consultation here – you have until October 30th to respond. The actual plan is a PDF, here


(Pollution in Richmond. Image courtesy )

The council correctly identifies that the primary source of air pollution in the borough is motor transport but, unlike the Mayor’s Transport Strategy, or TfL’s Liveable Neighbourhoods plans, or Greenwich and Camden’s Air Quality Plans, our council doesn’t think that persuading people to use other modes of transport is a good way to deal with this.

Early in the document, we’re told that the most polluted place in the borough – George Street in Richmond – would need traffic reductions of up to 75% to bring its air into line with the required threshold. The problem is that virtually none of the actions identified in the document would help to achieve this.

We think the document has a number of problems.


Other councils haven’t allocated specific budgets for specific activities, but Richmond attempts to do this. Which means that there are an awful lot of actions which require people to do things, but include budgets of £0. Since there’s no commitment to increase staff numbers to support the plan, we must assume that the dozens of £0 actions will fall on the shoulders of either the Director of Public Health, or the Air Quality Manager.

We think that the proposal needs to include a proper allocation of either money or staff time for each proposal.


Not a single proposed action has any attempt to measure the effect that it may have on air quality in the borough. Whilst we understand that some things are going to be quite hard to quantify, such as ‘Consider further local restrictions on bonfires’, we must surely need to understand where the worst problems are, in order to actually address them.

As an example, there are actions on the fleet of vehicles used and own by the borough. We know how many vehicles there are, we know what their emission ratings are, and we know what the emission ratings are for newer/different vehicles.

We think many of these actions need meaningful measures. In order for people to be able to reply in a useful fashion to the consultation, we also believe that the actions could at least show relative value to Air Quality changes. (For example, if people knew that campaigning on Heathrow would make more of an impact than putting up electric charging stations, they would be able to choose the former over the latter with some evidential backing.)


Very few of these actions discuss the incentives that parties have in order to comply with them, and much of the monitoring involves items which fail to measure the actual changes involved. For example, the plan wants to ‘encourage’ local HGV, coach, van and taxi operators to sign up to FORS or other schemes, but the whole activity has £6,000 allocated, and has no proposal how this encouragement might happen.

Missing Ideas

Section 2 (p4) describes how boroughs have an important role to play in dealing with air quality, and mentions five key policy ‘levers’ available to the council:

  1. Emissions based parking charges
  2. Reducing pollution from new developments
  3. Improving the public realm for walking and cycling
  4. Targeted measures at pollution hotspots
  5. Supporting infrastructure for zero-emission vehicles

Of the five, (a) is completely ignored, and (c) and (d) appear to have no meaningful action associated to them.

Inspection of plans from Camden and Greenwich as examples, shows a slew of activities which they’re planning, that most people would be able to look at and say “I can see how that would improve air quality in my area.”

These include:

  • enforcing anti-idling. (i.e. requiring people to switch their engines off when stopped in traffic, at level crossings, etc.)
    Richmond’s proposal for this at least has some teeth, with an apparent plan to actually begin enforcement
  • Persuading people not to drive
    In both plans, there is a stated aim to persuade fewer people to use cars for some of their journeys in the borough. Richmond, although recognising the contribution of motor transport to air pollution, has no plans to do this, either directly or in-directly.
  • airtext service. Promotion at doctors’ surgeries
    Both boroughs suggest more active ways to warn people about pollution. This includes more substantial communications – like at doctors’ surgeries – that does not rely on poorly used websites or passive notification
  • encourage mode shift from diesel with parking charges
    Camden and Greenwich envisage using their car parking zones to encourage people not to have diesel cars through higher charges for owners of the most polluting vehicles. We recognise council claims that this may weigh unfairly on the owners of such vehicles, but it is at least a policy which has identifiable benefits which can be quickly realised. Perhaps, though, when we worry about the owners of these vehicles, we could also worry about the 25% of the borough who don’t even have a motor vehicle, or the majority of children and young people required to pay with their lungs for our lack of action.
  • explore emissions based parking charges
    Both boroughs propose using parking charging at council car parks, etc., to persuade people not to bring highly polluting vehicles into the borough. Richmond has no plans at all n this area
  • Car free / pedestrian priority days
    Greenwich and Camden are both planning to trial these as ways to improve air quality in key areas. No such ideas are present for Richmond.
  • 20mph
    Greenwich and Camden correctly identify that increasing the areas with 20mph limits will reduce pollution. Why isn’t Richmond doing the same?
  • LBCC “London Borough Consolidation Centre” … supporting this. Are we? Don’t know

Good Stuff

There is good stuff in the proposal, in our opinion.

The document highlights the objective ‘to enhance travel choice and reduce congestion’. We’d like to see this even more clearly as an aim in the AQAP, as providing this has benefits for wider public health, as well as air quality.

The document identifies (p4) that ‘road transport [contributes] more than 50% of the overall emissions of nitrogen dioxide and particulate matter within the borough.

We welcome the interest in the TfL STARS project (on school transport, p6), as anecdotal evidence suggests that travel to and from school has a significant effect on borough congestion and air quality. We would like to see more concrete council action on this: every school in the borough has a transport plan, and almost all have asked for specific measures which will make active travel safer and more attractive. The council needs to act on these. (Examples include 20mph zones outside schools, providing proper cycle routes outside schools, improving pedestrian facilities, etc.)

Not So Good …

Page 6 has nine ‘key priorities’ for the five years of the new Air Quality Action Plan. It is very disappointing that not a single one of these priorities is to actually improve air quality by a measurable amount. Unfortunately the priorities, like many of the proposed actions, involving talking, meetings, or measuring / documentation. Whilst all of these are key elements, the absence of concrete actions is worrying, because it implies that there is no ambition to actually improve air quality in the borough to at least the current standards.

There’s not much talk about ‘Active Travel’. We would like the AQAP to follow the draft guidance from the Mayor of London on promotion of active travel, and discouragement of motor vehicle use.

Electric vehicles: much store is set by encouraging greater use of electric vehicles. While this will make a significant difference to the level of exhaust pollution, there is a growing body of evidence that air and particulate pollution comes not merely from exhaust gases but from brake, tyre and other wear and activity.

Combined with the fact that an electric car takes up just the same space as a normal car – and therefore causes the same level of congestion – we would expect to see an Air Quality Action Plan providing more imaginative and useful proposals for the most congested roads, and the worst pollution areas.


This isn’t good enough. Richmond Cycling Campaign does not support this document as an acceptable response to the current public health crisis, for all the reasons detailed above. The council should be ashamed not merely of its failure to take action thus far, but also of its basic proposals to do virtually nothing of any substance for the next five years, unless someone else does it for them (TfL and buses, for example).