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Calderdale's air pollution crisis remains unsolved

From Anthony Rae

Wednesday, 14 December 2016

Friends of the Earth has been working on the issue of air pollution in Calderdale for years, and we waited patiently for the West Yorkshire Low Emissions Strategy (WYLES) to eventually emerge, as this we thought this would be the best opportunity to create an effective framework to tackle a really serious problem – in excess of 100 premature deaths per annum in Calderdale. Hebden Bridge has an air quality management area (AQMA) because the pollution here exceeds the legal limit set by the Air Quality Directive and which should have been complied with no later than 2010.

In December 2015 we made a substantially critical response to the first version of WYLES, because it was far too weak, and we said that it needed to be comprehensively revised if it was going to be effective. Then last Thursday I found out by chance that the revised version was being submitted to Calderdale’s Cabinet on Monday (12th). The strategy wasn’t on any website it should have been, which meant that no one could have seen it. When I eventually tracked down a copy I found that it was just as bad as the 2015 version.

Well, actually, worse, because in the meantime our fellow environmental organisation Client Earth had taken the government back to court and on 2nd November the Supreme Court threw out the government’s national air quality plan on which the West Yorkshire strategy has been based. Except that the WYLES strategy hasn’t bothered to tell anybody this. The judgement of the Supreme Court was comprehensive: it overturned the national plan as a whole, the timetable by which the UK had to achieve compliance with the AQ directive, the attempt to financially constrain programmes to achieve compliance - and therefore in combination these two determine the range of measures to be deployed to achieve all the required improvements - the modelling approach it used to measure the amount of air pollution, and the strategy's failure to allow for the difference between real world and theoretical emission standards. What the the WYLES strategy should have done is to have just waited for a few months for the government to bring forward a new much stronger national plan. But it didn’t.

West Yorkshire has 29 air quality management areas like the Hebden Bridge one so what the strategy had to do was to analyse what needed to be done each of these AQMAs and then identify an emissions reduction trajectory towards compliance with legal levels. But it didn’t. The Supreme Court judgement seems to indicate that ‘clean air zones’ are the mechanism it wants to see the government bring forward in its new plan, so maybe we might see more CAZs e.g in cities such as Bradford, as well as the one originally proposed for Leeds, but where does that leave Calderdale and its dispersed pattern of AQMAs? Consequently any revised national plan or WYLES based upon extending the CAZs mechanism still won’t help Calderdale, and we’ll be no further forward. The WYLES hasn’t noticed that.

This is beyond disappointing. People will be misled into thinking that Calderdale Council has supported a solution to our air pollution problems but which actually isn’t one. Here in Hebden Bridge the unlawful levels of air pollution will remain. We’ve told the Council that we don’t accept the WYLES strategy and will campaign against it. If the proposed Calderdale air quality strategy which they are proposing to bring forward in March has the same weaknesses we will campaign against that as well. The groups and communities in Calderdale that have long fought for an effective strategy to tackle air pollution (as against an ineffective one) have been let down.

But you can do something. The Cabinet decision to approve the strategy can be called in for further examination by the Economy & Environment scrutiny panel. Any of our ward councillors can ask for this to happen, so please do contact councillors Josh Fenton-Glynn, Ali Miles and Dave Young to to ask them to do this.
Anthony Rae

From P. Marshall

Wednesday, 14 December 2016

I'm not sure whether Anthony Rae is aware of this NICE draft consultation "Air pollution--outdoor air quality and health". I only came across it by accident when searching another subject.

The consultation is open until 25th Jan 2017 provided you are a registered stakeholder. The publication date for the subsequent report will be June 2017.

From Gideon Foster

Thursday, 15 December 2016

Whilst I am no expert on these matters, as an observer it would seem to me a lot of the problem in Hebden Bridge is related to traffic crawling through the Town Centre and that maybe a "back to basics" common sense approach would help.

The main obstacles to the flow of traffic would appear to be the fact that when cars are waiting to turn right into Albert Street there is insufficient room for traffic to pass in the same direction leading to a queue which when released engulfs a point further down the road. Maybe the junction could be re-designed to allow free flow?

Secondly, the two pedestrian crossings on Market Street, make these traffic light controlled or, in fact, replace the two with one traffic light controlled crossing at a strategic point. This would reduce the stop start nature of traffic again rather than the current situation with people constantly appearing from the Co-op and cars stopping as they cross.

I hasten to add I am not a champion of motoring at any cost. I have used public transport for many years now as, despite the conditions Northern Rail subject their passengers to, it's preferable to sitting in a traffic jam. However, we live in a world where traffic does exist and many of us, even those who don't own cars, rely on road transport indirectly so we have to find solutions.

Just an idea, but maybe the above would help the flow of traffic even at the 20mph limit?

From Tim M

Thursday, 15 December 2016

It's not just Albert Street, but also traffic turning into Commercial Street, as well as rush hour parking on Market Street - or indeed badly parked deliveries anywhere in town. Whether this impacts on air pollution I don't know - but it makes for a slow crawl through Hebden Bridge.

From Graham Barker

Thursday, 15 December 2016

Exactly how bad is Hebden Bridge’s air quality from day to day? I’ve just checked the Weather Network’s air pollution report for Hebden Bridge - the only source I could easily find - and the report for today and forecast for the next four days is Low. By contrast in Leeds, from where I’ve just got back, air pollution today is High. I’m not trying to deny that pollution is a bad thing but where’s the data that tells us we’ve got a significant problem?

From James Baker

Friday, 16 December 2016

To answer Graham's question the Council monitors air pollution in Hebden Bridge as it's one of seven areas in Calderdale with high air pollution that have been classified as Air Quality Management Areas. Data is collected through things like No2 diffusion tubes.

In April 2015 a scrutiny review I chaired made a series of recommendations on tackling air pollution. To the best of my knowledge none of these recommendations have been acted on by the Labour administration on Calderdale.

See report

Recommendation 5
That Cabinet’s agreement and support be sought for the early revision of the Calderdale Air Quality Action Plan (AQAP), which was written in 2009 and is in need of updating.

Recommendation 6
That Cabinet’s agreement and support be sought to the undertaking and promotion of a targeted campaign of awareness of the on-going West Yorkshire Low Emissions Strategy (WYLES) work from a public health perspective, with the primary delivery method to be through low cost
platforms such as social media (Facebook, Twitter etc.)

Recommendation 7
That Cabinet is asked to endorse and support more direct enforcement work being undertaken by external partners of the Council, such as the police, through the use of legally enforceable powers to tackle unroadworthy vehicles with high emissions.

Recommendation 8
That Cabinet is asked to look into the possibility of undertaking a feasibility study into the possibility of introducing designated Low Emission Zones (LEZs) in Calderdale.

From Graham Barker

Friday, 16 December 2016

I appreciate James Baker’s prompt response but it doesn’t answer my question. What are the actual figures per day, and where do we find them for ourselves? If a daily data stream isn’t possible, how about daily figures for, say, a sample month in summer and a month in winter? Importantly, how do Hebden Bridge levels compare with typical levels elsewhere? I ask because I find it difficult (though not impossible!) to believe that Hebden Bridge has a significant pollution problem compared with Leeds, Manchester or even Halifax.

From Andy M

Saturday, 17 December 2016

2015 data here

From Gideon Foster

Saturday, 17 December 2016

Tim M, you're right, especially about the parking. I missed that. Sadly, I think we will find we are banging our heads against a closed door with such simple solutions. A cynic may say that people seem far more interested in arguing about how bad the problem is, who caused it and if this really is solvable by simple solution then what the hell are we going to argue about tomorrow! All hell would ensue.

Probably better to keep quiet. Confucius had to go into exile for expressing such ridiculous ideas.

Merry Christmas

From Anthony Rae

Sunday, 18 December 2016

I’ll bring you up to date with what’s happened since my original post on Wednesday, and also answer some of the points raised in this thread.

Graham Barker in his two posts says ‘I find it difficult (though not impossible!) to believe that Hebden Bridge has a significant pollution problem compared with Leeds, Manchester or even Halifax’, and then ‘I’m not trying to deny that pollution is a bad thing but where’s the data that tells us we’ve got a significant problem? … What are the actual figures per day, and where do we find them for ourselves? If a daily data stream isn’t possible, how about daily figures for, say, a sample month in summer and a month in winter? Importantly, how do Hebden Bridge levels compare with typical levels elsewhere?’

Andy has already provided the link to the Council webpage where the air quality reports are provided, and on that page you will find the 2011 air quality progress report, and then the most recent updating and screening assessment 2015 report. Now on pages 16-17 of the 2011 report, and then again on page 10 of the 2015 one, you’ll find some complicated data tables where you will notice that the figures over 40 are marked out in bold. But a member of the public accessing these documents (assuming they can find them) would still be left asking: what’s the significance of this ‘40’ number? Well, it’s the threshold (40μgm-3) for nitrogen dioxide established by the 2008 EU Air Quality Directive , which if exceeded after 1st January 2010 constitutes unlawful air pollution - as you can see set out on page 25 of the new West Yorkshire air quality strategy I provided the link to, because it’s not accessible anywhere else.

The problem of air pollution in Calderdale is that it’s not just located in one central zone. A council briefing note this month states: ‘Calderdale has 7 Air Quality Management Areas all declared for an exceedence of the annual mean air quality objective for NO2 of 40g/m3: A646 at Hebden Bridge and Luddendenfoot; A58 at Sowerby Bridge; A629 at Salterhebble; A58 at Stump Cross and Hipperholme; Brighouse Town Centre.’ Clearly a ‘clear air zone’ solution increasingly favoured in big cities won’t be applicable in our district.

So this nicely illustrates just one of the complexities with finding a solution to air pollution. The data about air pollution breaching the AQ Directive is difficult to find, and then equally difficult to understand; but when you’ve done that the question occurs: if a number of locations across Calderdale (not just in Hebden Bridge) had and still have unlawful levels of air pollution, why haven’t they been reduced as the law required they should have been by the start of 2010? And it doesn’t matter whether the air quality in Hebden Bridge specifically is more or less worse than Leeds etc; if it’s above the threshold it’s causing damage to health and we have a right in law to require it’s made compliant.

And that’s what the pioneering Client Earth cases before the Supreme Court in April 2015 and November 2016, were all about. On both occasions the government’s national air quality strategy was found to be inadequate because it would fail to deliver compliant standards of air quality across the country - including in Hebden Bridge. And the argument that Friends of the Earth is having with both the new West Yorkshire strategy, and Calderdale Council who are recommending its approval, is that it still won’t reduce air pollution below the compliance threshold by dates, now to be enforced by the Supreme Court judgement, between 2018 and 2020 - for a lot of complicated reasons. Having procrastinated for political reasons way beyond 2010, time has definitively run out. Since a looming legally enorceable deadline of 2018-20 is enormously difficult to achieve, if a strategy at whatever level continues to come out just with vague promises about possible future compliance they must be challenged right now!

Last Thursday Calderdale Council’s Economy & Environment scrutiny panel, in response to our request, agreed to hold an inquiry into this issue in March 2017 - that is, after the date at which the Council will have formally adopted the new West Yorkshire strategy, but in the same month that Calderdale will be bringing forward its own air quality strategy and action plan. So the questions we have been asking about the inadequacies of the WY strategy have not been answered, but have only been deferred for a few months. In July 2017 a much strengthened national air quality plan that the Client Earth legal victory has forced the government to prepare will be published. Since this new national plan will have to change the ‘rules of the game’, how can West Yorkshire and Calderdale strategies approved just a few months before - under a national AQ framework already thrown out by the Supreme Court - possibly be effective? When the draft Calderdale strategy becomes available in February-March 2017, we’ll let you know the answer to that question.

Finally, in answer to the detailed points about smoothing the flow of traffic through Hebden Bridge - but please do bear in mind, we’re trying to find solutions that will work everywhere, not just here in our town - yes, all such options should be considered (and as it happens, I have been raising them for the last decade) but whatever the fixes that could be introduced at any particular location, the priority now has to be to insist on strong strategies that will guarantee compliance everywhere. The primary responsibility for this rests with the government; the West Yorkshire authorities ought to be threatening the govt with legal action themselves, which is precisely what London Mayor Sadiq Khan did when he joined Client Earth legal case; and Calderdale Council need to be more honest with the public in acknowledging that they simply do not have the powers or resources at present to reduce air pollution below the legal threshold. To pretend otherwise is simply to mislead.

From Gideon Foster

Sunday, 18 December 2016

Anthony, thanks for the update. I know you campaign tirelessly for change and the answer, as you say, is probably a combination of solutions.

I do think, however, too much emphasis is placed on the negative effects of car driving as opposed to the positive benefits of alternatives, and the alternatives need to be improved by government but that's a story for another day, but positives do exist.

So to any disillusioned car commuters reading, I catch the train into Manchester. Yes its busy and sometimes you have to stand, but you can clear your head, listen to music, read and, a bit old fashioned I know, but have a conversation with someone face to face! I've actually met good friends on there.

From Graham Barker

Sunday, 18 December 2016

Thanks Andy but blimey, what a ragbag of lazily organised data those reports are. For easy reading, stick with Finnegans Wake. I found more useful information on the Air Quality Management Areas page, where there is a PDF, albeit from 2007, relating to Hebden Bridge.

Access to daily data now seems not just a dead duck but probably also pointless. On my admittedly non-expert reading of several reports, the gist of it is that Hebden Bridge - unsurprisingly, mainly Market Street and Bridge Lanes - is one of a handful of areas in Calderdale where high volumes of bottle-necked traffic plus a canyon effect from buildings cause NO2 levels to rise.

However, those levels go up and down like a yo-yo and NO2 disperses rapidly only a few metres away from the tailpipe level where readings are taken. I don’t want to belittle the toxicity of NO2 but you’d probably have to be asthmatic and tied to a Market Street lamp-post all day to suffer any ill effects from NO2. A further complication is that NO2 is only one ingredient of air pollution, a lot of which is also found indoors.

Thus, while it’s desirable to have less NO2, the levels in Hebden Bridge do not appear to be alarming. It’s also difficult to see what measures would permanently reduce them given the vagaries of traffic flow, which is probably why Calderdale is reluctant to commit to remedies that might not be cost effective.

For example, the reports recognise that traffic - and thus NO2 - may increase greatly at unpredictable times when the M62 is blocked by an accident and drivers seek other routes. Should Highways England therefore speed up M62 accident management in order to reduce NO2 emissions in Hebden Bridge? A yes would be good but a no seems more likely.

Interestingly, in none of the air quality documents that I read was there any mention of two probable causes of NO2 spikes that could be managed better - roadworks, and stationary buses backing up traffic (and emitting diesel exhaust) while the drivers deal with fares. Throwing every efficiency measure possible at roadworks may help, and employing bus conductors at least during rush-hours may help.

My guess is that there would be no enthusiasm for either measure, putting the onus back on poor old Calderdale to find some overlooked magic wand. What can Calderdale practically do to significantly reduce NO2 levels at an acceptable cost? In all probability, very little. It may be better to pin hopes on changing trends - for example more electric vehicles, more working from home - than on anything imposed.

From Julie C

Monday, 19 December 2016

Writing as a non-driving asthma sufferer who has to spend ages waiting at bus stops right next to the busy road I can tell anybody who doubts the importance of this issue, they are wrong.

On loads of days recently, it's been cold, damp and misty, and the murk has been held in the bottom of the valley. It's not healthy stuff for anyone to breathe, think pushchairs at exhaust pipe level waiting to cross the road. I, and a number of other chesty folk I know, have been struggling to breathe and pumping a lot of ventolin! It's a horrible feeling, and anything that can be done to help would be great.

In the same way as cities like Paris have bought in vehicle restrictions, how about closing the valley to everything apart from emergency vehicles, taxis, disabled drivers and buses for a day. It would clear the air for sure. It needs law changes from above to make something happen.

I recollect Hebden just prior to the Smoke Control legislation in 1972, early mornings it could be clear and bright first thing and then everybody opened up their coal fires that had been banked up overnight - in a few minutes the bottom of the Valley would disappear in a yellowish black smoggy cloud of smoke and fumes. The law changed, the sky cleared, but now with increased vehicle use its bad again, and very dangerous, full of diesel particles. Help!

From C. Mullen

Tuesday, 20 December 2016

I would like to thank Anthony Rae for his work on this, and I completely agree with him on the importance of properly dealing with outdoor pollution in Calderdale, and I hope our councillors listen to that.
Transport is a major cause of outdoor air pollution, and is the largest source of nitrogen dioxide. (Defra)

It is too easy to overlook the severity and scale of harm that outdoor air pollution causes – the Royal College of Physicians report estimates 40,000 deaths each year attributed to it (Royal College of Physicians).

Among the health problems with this pollution, are deaths from cardio-vascular illness (World Health Organisation report - see p. 69), evidence of increased risks to children of developing asthma (Institute for Transport Studies, University of Leeds) and lung cancer (World Health Organisation).

I suspect outdoor pollution gets overlooked because it is not usually visible, and like other causes of disease and illness, its effects are not always immediate.

Concentrations of nitrogen dioxide and other pollutants do reduce away from the road, but that does not mean people are safe – the deaths and illness from this pollution indicate that. The WHO report states ‘even at relatively low concentrations the burden of air pollution on health is significant’ (WHO p. 1). Also, most people spend time on or by roads, and some live on busy roads – and people in cars suffer high levels of pollution (BBC).

Measures designed to prevent stop-start driving along the main road might reduce spikes in pollution, but they might also be counterproductive as a means of dealing with outdoor pollution (and might bring other health problems if they reduce active travel).

The big picture is that the pollution comes from combustion engines and it would be a mistake to have measures which reduce pedestrian crossing or which do anything to mean it is more likely that people (who can) will drive because the alternatives are unviable/ feel unsafe because of traffic etc. Part of the solution might be the (often slow) progress to cleaner vehicles, perhaps including a push to get some cleaner buses, but I cannot see that being enough - not least as it will not happen for years - I expect the solution is going to be complex, and would welcome opportunity to see and comment on plans by the council.