It is estimated that nearly 9500 persons die prematurely every year due to high level of air pollution in London [1]. Deprived communities and notably the Black populations in Lambeth are also disproportionately impacted by illegal levels of air pollution [2]. In the light of these scientific reports, Lambeth Council should take a strong line and use all its powers to be a force for change.
The draft plan currently published for consultation is lacking in both ambition and scope. No plan is made to stop or even reduce the incineration of collected household waste, no commitment is made to develop cycling infrastructures, no concrete action to encourage modal shift is proposed, and no resolution is taken to use the policing powers given to local authorities to stamp out engine-idling.
Air pollution is a massive threat to our health that requires public action at all levels. While we recognise that our council alone cannot solve the issue, the council should fully acknowledge the shortcomings in our borough and start pulling its weight. The draft Air Quality Action Plan falls short on this account.
Lambeth Green Party was not consulted on the content of the draft prior to its publication by Lambeth Council. We have, however, responded to the consultation questionnaire as an organisation, with the full text of our response reproduced below.
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| Green Party activist, Chris Holt, installs an air quality monitor outside a school in Streatham |
Topic 1: Emissions from developments and buildings
Question 1: Looking at Topic 1: Emissions from developments and buildings on pages 17-19 of the draft Air Quality Action Plan do you, generally speaking, agree or disagree with the proposed actions?
Lambeth Green Party Response: Tend to agree
Question 2: Looking at individual actions listed in 1: Emissions from developments and buildings on pages 17-19 of the draft Air Quality Action Plan what, if anything, would you say is missing, should be removed or should be amended, and why?
Lambeth Green Party Response: Whilst the intentions set out on the topic point in the right direction, educating and raising awareness among property developers alone cannot make a serious impact on the pollution levels created by building sites. The Council should take stronger leadership by using its planning prerogatives and legal powers to enforce the highest standards defined by the Great London Authority. At a time when the borough is already suffering from alarming levels of pollution, it is particularly disappointing that the Council is allowing developers to financially compensate the pollution they create, through s106 agreements.
Topic 2: Public health and awareness raising
Question 3: Looking at Topic 2: Public health and awareness raising on pages 20-23 of the draft Air Quality Action Plan do you, generally speaking, agree or disagree with the proposed actions?
Lambeth Green Party Response: Tend to disagree
Question 4: Looking at individual actions listed under Topic 2: Public health and awareness raising on pages 20-23 of the draft Air Quality Action Plan what, if anything, would you say is missing, should be removed or should be amended, and why?
Lambeth Green Party Response: The list of proposals to improve awareness lacks two key aspects to make an efficient public health plan. Firstly it fails to involve the local GP surgeries. Medical professions are in regular contact with the most vulnerable people who are also the primary sufferers of air pollution. Nurses and doctors are best placed to implement effective measures and report health issues. Secondly, the plan is extremely limited in terms of monitoring actual air pollution levels in Lambeth. Residents have a right to know the level of air pollution they are exposed to. In particular, plans should be made to assess air quality scientifically around nurseries, schools and care homes as young people and the elderly are among those that suffer the greatest health consequences as a result of poor air quality.
Topic 3: Delivery servicing and freight
Question 5: Looking at Topic 3: Delivery servicing and freight on pages 23-24 of the draft Air Quality Action Plan do you, generally speaking, agree or disagree with the proposed actions:
Lambeth Green Party Response: Tend to agree
Question 6: Looking at individual actions listed under Topic 3: Delivery servicing and freight on pages 23-24 of the draft Air Quality Action Plan what, if anything, would you say is missing, should be removed or should be amended, and why?
Lambeth Green Party Response: The Council’s plans to provide preferential scoring to bidders delivering goods and services with zero or low emission vehicles has the potential to make good use of the Council’s buying power to influence its wider stakeholder network. However, the Council will have to ensure that scoring systems are designed in such a way that the air quality credits of different bidders actually make a material difference to the final score of bidders and therefore the procurement decision.
Furthermore, the Council should review whether FORS Silver Accreditation delivers any real air quality benefits. As presented, the requirements for FORS silver accreditation do not seem to provide air quality benefits as it does not ask for the vehicle fleet of accredited companies to meet targets on engine standards (i.e. Euro 6), fuel use or air pollutant emissions.
Topic 4: Borough fleet actions
Question 7: Looking at Topic 4: Borough fleet actions on pages 24-25 of the draft Air Quality Action Plan do you, generally speaking, agree or disagree with the proposed actions?
Lambeth Green Party Response: Tend to disagree
Question 8: Looking at individual actions listed under Topic 4: Borough fleet actions on pages 24-25 of the draft Air Quality Action Plan what, if anything, would you say is missing, should be removed or should be amended, and why?
Lambeth Green Party Response: The Council should stop investing in diesel vehicles and favour low emission technologies. It is paradoxical to request the expansion of the ULEZ or to welcome the introduction of clean buses on the A23 routes while planning to continue to buy and use diesel engines. The Office for Low Emission Vehicle, part of the Department for Transport provides grants to Councils to help them transition to cleaner vehicles.
The Council is also one of the major employers in the borough. As a public authority it should lead by example, and incorporate plans to incentivise modal shift among its employees. The use of cars to come to work should be discouraged.
Topic 5: Localised solutions
Question 9: Looking at Topic 5: Localised solutions on pages 25-26 of the draft Air Quality Action Plan do you, generally speaking, agree or disagree with the proposed actions?
Lambeth Green Party Response: Strongly disagree
Question 10: Looking at individual actions listed under Topic 5: Localised solutions on pages 25-26 of the draft Air Quality Action Plan what, if anything, would you say is missing, should be removed or should be amended, and why?
Lambeth Green Party Response: Lambeth is home to the successful Brixton Energy, a social enterprise which installed solar panels on 3 estates of the borough (and counting). The council should build on this experience and encourage more initiatives aiming at developing the production and use of renewable energies in the borough. The fact that the terms “solar” or “renewable” don’t appear once in the plan document is staggering.
Brixton tube station, at the end of the Victoria line is crying for bike infrastructures, with the few bike racks there are constantly overcrowded. The aims to roll-out the London bike-hire scheme in the south of London in 6 years demonstrates a distinct lack of in ambition.
Topic 6: Transport & Highways
Question 11: Looking at Topic 6: Transport & Highways on pages 26-28 of the draft Air Quality Action Plan do you, generally speaking, agree or disagree with the proposed actions?
Lambeth Green Party Response: Strongly disagree
Question 12: Looking at individual actions listed under Topic 6: Transport & Highways on pages 26-28 of the draft Air Quality Action Plan what, if anything, would you say is missing, should be removed or should be amended, and why?
Lambeth Green Party Response: In 2015, Local Authorities received new powers to fine idling motorists. In combination with the actions of information and prevention, actions should be taken to use the fining powers in sensitive areas, such as around schools, to end idling for good.
Whilst promoting cycling use is necessary, it will remain inefficient if cycling is not made safer and more accessible. The plan makes no commitment to develop the much-need cycling infrastructure to encourage the modal shift.
One annual car free day is a token event unlikely to change transport habits and make any significant impact. We urge the Council to organise regular car free days across the borough. We disagree with the idea to devolve this responsibility to BIDs, when business are traditionally opposed to motor traffic reduction; other stakeholders such as cycling groups and resident forums need to be included for a better balance of opinion.
Lambeth Council should also make clear its opposition to the expansion of both Heathrow and City airports. An increase of traffic at any of those airport would affect negatively the air quality in our borough.
Three main priorities listed on page 15:
Question 13: Looking at our three main priorities listed on page 15 of the draft Air Quality Action Plan do you, generally speaking, agree or disagree with them?
Lambeth Green Party Response: Tend to disagree
Please tell us more if you wish:
The focus of the plan should be on areas over which the council has directly responsibility. The first priority of the plan should be to transform the Council as a leader by example, with a clean fleet of vehicles and a strong plan to avoid waste incineration.
Question 14: Is there anything else that you would like to add to the feedback you have given us so far:
Lambeth Green Party Response: No mention is made in the plan of Lambeth’s policy of waste incineration. Actions should be taken to improve the recycling and composting rates, to reduce the amount of waste sent to Belvedere incinerator in Bexley. Although this incineration takes place outside the borough, it clearly has an impact on air quality in Lambeth as well as in other boroughs.
We also worry about the governance of this plan. It contains no clear metrics to measure the impact that various activities will have. This makes it very difficult to assess the efficiency, effectiveness and adequacy of the plan efficiency. We will advise the steering committee to set clear and transparent targets that will consistently measure progress and impact of actions throughout execution.
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| Bruno putting up a pollution monitor outside Effra nursery on Barnwell Road. |
[1] Understanding the Health Impacts of Air Pollution in London:
https://www.scribd.com/document/271641490/King-s-College-London-report-on-mortality-burden-of-NO2-and-PM2-5-in-London
[2] Analysing Air Pollution Exposure in London
https://www.scribd.com/doc/312760725/Analysing-Air-Pollution-Exposure-in-London?secret_password=UjnUA1OxDIURIebGARhZ
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