Edinburgh Low Emission Zones consultation – Response from New Town & Broughton Community Council

Main points

  •  Edinburgh should raise its sights and offer residents and visitors the highest levels of protection against air pollution – not just the minimum set in legislation.
  •  The present proposals may only move emissions from the city centre – with its largely transient population – to areas with more permanent residents.
  •  The proposed “central” zone should be widened to include the Northern New Town and other residential areas, and to bring diesel cars into the regime with an extended grace period to mitigate any financial consequences for owners.
  •  Making central streets like Queen Street and York Place “alternate routes” for non-compliant traffic is likely to increase pollution there, undermining the purpose of the exercise.
  •  The policy aim should be to encourage all vehicle owners to adopt cleaner engines as quickly as possible in the interests of public health and sustainable economic growth.

1 – Levels of protection

The Council proposes two zones with different emission regimes and timescales. The proposed “central” zone offers a good level of protection, which will benefit city centre workers, visitors, shoppers and students. But some of the most polluted areas of the city, and most of its permanent residents, are in the proposed “city-wide” zone, which offers lower levels of protection - buses and commercial vehicles have longer to conform, and it is proposed that diesel cars are excluded.

We welcome the Council’s aim to improve air quality across the city, but believe it should go beyond minimum standards set in the Transport Bill to offer as many people as possible – including residents - the highest possible levels of protection.

2 – Boundaries

Evidence from the SEPA Edinburgh Air Quality report, cited in the T&E committee paper, suggests significant pollution from diesel cars. The report shows good progress but says “a significant number of roadside locations … are still likely to exceed the [NO2] limit” especially “in and around the Central Air Quality Management Area (AQMA)”. The proposed “central” zone actually excludes some streets in the Central AQMA (eg Queen Street and York Place).

However emissions on these streets are actually likely to increase in the immediate future if they are designated as an “alternate route” for non-compliant west/east traffic, as the Council proposes.

We believe the proposal should seek to protect residents in the Northern New Town from these emissions, and that the proposed “central” zone should at least include the whole of the AQMA.

There is a clear possibility that the present proposals move damaging emissions away from the more transient population of the city centre towards areas inhabited by permanent residents.

3 - Traffic flow vs. public health/sustainable economic growth

We acknowledge the importance of keeping traffic “flowing” so that the economic and social life of the city is not constrained by measures to reduce NOx and NO2 emissions. However this needs to be balanced against the constraining effects of emissions on public health and sustainable economic growth.

The Queen Street/York Place artery is on the very edge of the proposed “central” zone and will clearly compromise the integrity of that zone. Its use as an “avoidance” route will increase emissions there at least in the medium term, and does not contribute to sustainable growth – the kind which delivers the greatest long-term value and which is one of the underlying policy objectives of the Transport Bill.

4 – Diesel cars

The current proposals target the sources of the heaviest emissions (buses and non-bus commercial vehicles) across the city, albeit on different timescales; but exclude cars, including diesel cars, outside the central zone.  However the SEPA report notes that “analysis of model output shows that emissions from Diesel cars appear to be a city-wide problem”, are “the single biggest source of Nitrogen oxides (NOx) on many roads”, and that “the majority of Car NOx comes from Diesel cars”, creating a similar level of air quality impact as non-bus commercial vehicles “particularly within the Central AQMA”. The report concludes that standard Euro 6 Diesel Cars (sold since December 2015) will bring little improvement (assuming traffic levels remain as they were in 2016) and that although the newer Euro 6c and 6d Diesel vehicles may bring greater benefits, this is as yet not proven.

The SEPA evidence suggests that diesel cars remain a significant pollutant so we urge that more be done to bring them into the low-emission regime, and across a wider area of the city – in particular that inclusion of the designated “town centres” should be considered.

5 – The “town centres”

Responding to the City Transformation plan, we welcomed CEC’s ambition to “nurture” Edinburgh’s “town centres” including Gorgie, Dalry, Leith Walk, Bruntsfield, Stockbridge, Tollcross and Corstorphine among others.

Most of these areas are excluded from the proposed LEZ “central” zone.

Under the present proposals it will be end-2023 before bus and commercial vehicle implementation is complete in these areas, with no plans for diesel cars to be included at all. We suggest that these areas should expect the same standards of air quality as the centre.

We agree that the “hot spot” approach is impractical and likely to be ineffective. We suggest that the “city centre” zone could be widened to include the northern New Town (as far as the Water of Leith), Broughton, and the Eastern New Town including London Road, Picardy Place and Regent Road (see map). These areas include a number of “canyon streets” whose design makes them more vulnerable to retention of particulates in the air.

map showing NTBCC's proposals for city-centre low-emissions zone

Click the map to see it full-size in a new window,

They may also be affected by CEC initiatives on parking, and on traffic-free streets in the central zone, which may increase traffic volumes and diminish air quality.  There may be a case to extend the “city centre” zone west to Corstorphine and south to Marchmont.

An extended grace period for compliance by diesel cars could be permitted to minimise adverse financial consequences for owners, at least some of whom were following Government advice in purchasing diesel vehicles, until evidence for the impact of more recent engine designs is clearer.

We also suggest that grace periods for buses and commercial vehicles in the “city-wide” zone be shortened (to be the same as the city centre) otherwise these areas could be exposed to worsening pollution if they become used as “avoidance routes” in the next few years.

We support the proposal that the regime operate 24 hours a day, and believe that reviews should be annual.

Conclusion

We welcome this CEC initiative but urge that the boundary between the two proposed zones should be drawn more widely to encourage more private and commercial vehicles to upgrade their engines more quickly in the interests of public health and sustainable economic growth.

Ultimately, this can only be achieved through cleaner engines and reduced traffic volumes and we urge CEC to use an LEZ regime to progress these as quickly as possible and to deliver benefits for the city’s permanent residents.

CEC should also move quickly to address other sources of air pollution such as diesel trains in Waverley and Haymarket Stations.

New Town & Broughton Community Council

July 2019