Air Pollution from Small Particulates

The Mayor of London, Sadiq Khan, has released new research giving the emissions of toxic particles known as PM2.5. He claims most Londoners are exposed to levels that exceed WHO guidelines. Here’s a summary of the report:

The research, based on the latest updated London Atmospheric Emissions Inventory, shows that 7.9 million Londoners – nearly 95 per cent of the capital’s population – live in areas of London that exceed the guidelines by 50 per cent or more.

PM2.5 are small toxic air particles which are alleged to have the greatest impact on health with both short and long-term exposure increasing the likelihood of respiratory and cardiovascular diseases. Children are particularly affected and may develop reduced lung function and asthma.

Around half of PM2.5 emissions in London are from external sources outside the city, however, the main sources of PM2.5 emissions in London are from tyre and brake wear, construction and wood burning.

The Mayor is clear that he wants to reduce emissions from wood burning through improved education about the types of fuel that should be used and when they should be used. He also wants a stricter set of emission standards on future sales of wood burning stoves to tackle this problem.

Comment: Why anyone should be permitted to use a wood-burning stove in central London when most people think such usage was banned under the Clean Air Act rather surprises me. But a lot of the particulate emissions are from construction in London, or are blown in from outside – and much of those are from agriculture, or even pollution from other countries. It is not at all clear how the Mayor is going to tackle these, but dust from tyre and brake wear is more easily controlled. Whether this would have a significant impact overall, or are cost effective measures, is not obvious though. Unfortunately this looks like political posturing by the Mr Khan, using children as his cheer leaders in this campaign.

Regrettably such pollution is mainly a symptom of over population, which Mr Khan and his predecessors seem not to want to do anything about.

Roger Lawson


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Opposition to Mayor’s Air Pollution Plans

I have covered some of the dubious aspects of the Mayor’s approach to tackling air pollution in London before. The T-Charge and ULEZ plans will be very expensive for Londoners, may have little effect and will target private car users unnecessarily when they are very minor contributors to emissions.

Campaign group FairFuelUK have launched a fund-raising to finance a judicial review of the T-Charge. The Toxicity Charge is a £10 penalty to be paid from October by older vehicles that do not meet newer emission standards if they are driven into the central Congestion Charging area. In summary they argue that even TfL concede it will have little impact on air pollution so it’s another of those “political gestures” that will impose major costs on some of the poorer road users. Go here for more information and to help fund the case:

Their arguments are backed up by a recently published report from the GLA Conservatives under the title “Clearing The Air”. This is a comprehensive analysis of London’s air pollution problems, and Mayor Sadiq Khan’s proposals. It also makes some alternative suggestions which would lessen the financial impact of the plans.

They also argue that the T-Charge should be scrapped and plans to bring forward the ULEZ by a year and then extending it across most of London should be abandoned. They point out that just implementing the latter could cost as much as £810 million, i.e. £220 for every household in London.

Make sure you read their full report if you want to get a good understanding of the issues around transport and air pollution in London. See:

Roger Lawson


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How Many Deaths from Air Pollution in London?

How many deaths from air pollution in London each year? You might think that is a simple question to answer because you have seen the headlines in the media – it’s 9,416 according to a report published by Kings College which is of course a nice exact figure. The press have abbreviated it to “nearly 9,500”.

The first problem though is that 9,416 is “premature deaths”, i.e. their lives were shortened to a greater or lesser extent. There were no actual deaths directly attributed to air pollution, i.e. present on the death certificate. Even the 9,416 is not a correct figure because there are a range of “shortenings”, which may stretch from hours to years. The estimated distribution of shortenings has been converted to a single figure of deaths so that the ignorant readers of the popular press, or those reading internet blogs, might understand it.

Yes this is an exceedingly complex topic which I won’t even attempt to explain in full in this brief article. But the latest news is that even the estimates used to calculate this number are dubious to say the least. New advice from the “Committee on the Medical Effects of Air Pollution” (COMEAP) set up by DEFRA is that the uncertainty about the evidence is growing. Although there appears to be a statistical association between air pollution factors and mortality, in the case of NO2 COMEAP have now said: “The Committee has not been able to come to a consensus view on how the epidemiological associations between NO2 and mortality can be used to either predict the benefits of interventions to improve air quality or to estimate the current mortality burden imposed on the UK population by air pollution. Some members are doubtful that the evidence is sufficient to allow a robust recommendation for quantification to be made. This is particularly the case for effects likely to be caused by NO2 itself.”

Regardless of that opinion, they still came down in support of giving specific recommendations on the likely impact of air pollutants on mortality.

Now this writer is not going to argue that cleaning up London’s air is not necessary, and it’s already happening of course. The key question, is by how much and what should be spent on doing it. What is the cost/benefit ratio of extending the ULEZ is one key point that needs to be answered.

If nobody has an accurate figure of the current disbenefits, how can we know what the benefits of cutting pollution are likely to be? Also TfL have been remarkably evasive in answering some simple questions about the costs of implementation of their proposals. They have refused to provide the data in response to an FOI request. Why are there no budgets that they are willing to disclose so we can attempt to work out the answers for ourselves.

One has to suspect that the case for really tough measures, such as effectively removing all diesel cars from London’s streets, is not as strong as it should be. When the costs imposed on car users can run into very substantial figures, we should be told the truth.

Making up policy based on guesstimates is not good enough.

Roger Lawson

The Social Costs of Air Pollution

A very good paper on the costs of air pollution in the UK, and the costs likely to be imposed on the public by the proposed measures nationwide, particularly in London, has been produced by Neil Lock. It is entitled “The Social Costs of Air Pollution from Cars in the UK” and is available here:

Mr Lock in his Conclusion to the note says the following: “If my figures are right, then on the specific issue of air pollution from cars in the UK, there may be a case for charging drivers of Euro 3 and perhaps Euro 4 diesel cars to enter certain very limited areas like central London. There is no social cost case for any such charges for Euro 5 or 6 diesels, or for any petrol cars. There is a case for charging drivers of diesels, and of petrol cars which do not meet the latest standard, an amount equivalent to the social cost of the pollution they cause (excluding the part of the pollution from diesels which is the manufacturer’s fault). There is no case for charging any more than this.”

He also says: “It is high time, I think, for the good people of the UK and of the world to wake up. To see the deep green agenda for what it is. To reject it and its proponents. And to seek to set up in its place just measures based on good science, honesty and common sense.”

The paper is well worth reading, particularly by those who live in London and who will be affected by Sadiq Khan’s plans. More technical data is available to support his case if you need it. Mr Lock can be contacted at e-mail:  Mr Lock is a software consultant, with a degree in mathematics. He lives in Surrey and drives a diesel car, which he says he would not have bought if he could have found a petrol one of the model he wanted at the time.

Roger Lawson

Media Coverage of Air Pollution and Electric Vehicles

With the Mayor of London’s plans for the ULEZ, his new Transport Strategy and the Government about to publish their air quality plans for cities, the issue of air pollution has been getting a lot of media coverage of late.

The Evening Standard ran an article by David Williams on the 28th June headlined “Don’t punish the car drivers for air pollution when other causes are worse”. The article said that making motorists pay punitive charges will fail to achieve major cuts in London’s pollution. This is the argument put forward by campaign group FairFuelUK who say it is more about raising cash as the revenue raised is not ringfenced to tackling emissions or congestion. One cannot but agree with them.

They also suggest that politicians are aiming for the wrong target by focussing on private cars which contribute only 11% of NOX emissions when 16% comes from gas central heating, 14% from diesel machinery and a lot from LGVs. Other sources are air traffic, air conditioning and HGVs. They also complain that local authorities have failed to cope with particulates that are left on roads by tyres and brakes.

FairFuelUK are asking people to write to Michael Gove and Theresa Coffey on the prospective additional taxation of diesel cars while promoting alternative solutions. For example, instead of an expensive diesel vehicle scrappage scheme they suggest retrofit devices can solve the problem on most vehicles. In addition, they push for the adoption of E10 fuel (an ethanol/petrol blend) which most cars can run on perfectly well and is widely available in other countries. They also promote the use of additives to reduce diesel emissions as is mandated in Texas. This can cut NOX emissions by 67%, and reduce other pollutants also. It does seem there are a number of other possible solutions that would be both cheaper and more effective than taxing motorists or forcing them to replace their vehicles – as Sadiq Khan is doing in London.

You can read about the FairFuelUK campaign here: .

I would encourage you to support it.

In the Financial Times on the 8th July there was a good article by Neil Collins on the unforeseen consequences of the push for electric cars. It was headlined “Electric cars are a pain in the wallet for those who don’t drive them”, and it spelled out the wonders of such vehicles.

But the downside is the loss of fuel tax to the Government (£28 billion per year and rising), while electric vehicles are subsidised by the Government. In addition, there are major problems in developing the electricity supply grid to cope with future demand. He says “The energy transfer at a busy filling station is about equivalent to the output of a mid-sized power station” and goes on to explain the energy inefficiency of electric cars due to high distribution and storage costs. He notes that: “Electric cars are gathering speed thanks to politics rather than economics”.

This writer has so far avoided the lure of electric or hybrid vehicles simply because the economics did not stack up. A Prius might work well for a high mileage Uber driver and all electric vehicles have historically had problems of range, recharging time and cost. But they are getting better. I am having a test drive of Tesla Model S next week so I may be able to report my impressions in due course.

Roger Lawson

UK Air Quality Plan

On the 5th May the Government published a Revised Air Quality Plan to tackle NOX emissions, in response to breaches of EU legal limits. London Mayor Sadiq Khan promptly slammed it in the Evening Standard as being “woefully inadequate”. He argued it was a public health emergency and criticised the Government for being unwilling to take bold action. He is of course moving aggressively forward himself with the ULEZ plans.

What does the Government’s document actually say? It correctly argues that air pollution can come from a range of different sources, not just transport. However as regards NOX it does exceed legal limits on some roads and diesel vehicles are one of the main causes. It points out that although emissions have been falling, driven by Euro Standards for new vehicles, these measures were side-stepped by the fact that “real world” emissions did not match the test figures. In some cases, e.g. Volkswagen, they were deliberately manipulated to give erroneous data for diesel emissions. This is why there is still a major problem with diesel vehicles and high air pollution.

As it says: “None of this is the fault of those who chose to buy diesel vehicles and as we tackle this problem, these same people should not be penalised for decisions they made in good faith”. Mr Khan is ignoring that though.

The Government is committed to provide incentives and the adoption of policies that will clean up the vehicle fleet. It also argues that as air pollution is often a localized problem one approach should be the introduction of Clean Air Zones that could introduce control of the worst polluting vehicles (in essence HGVs and buses). They also want to encourage the take up of Ultra Low Emission Vehicles (e.g. electric ones).

One measure they suggest would help in addition to generally improving and smoothing traffic flows, might be the removal of road humps. Now that would be a great step forward so far as this writer is concerned – I have repeatedly campaigned against them for the last twenty years. They have no real road safety benefits if you take into account traffic diversion while they have a number of disbenefits – increased air pollution is one well known aspect.

The Government argues that Clean Air Zones should only include charging arrangements where there is no other alternative – again Mr Khan is not taking much notice of this.

The Government mentions the possibility of a diesel vehicle scrappage scheme but suggests that it would need to be closely targeted, limited in scope, provide value for money and minimise the risk of fraud. Author’s comments: Somehow I don’t think my 4 year old diesel Jaguar XF is going to be covered under any such scheme. And I won’t be able to claim dire poverty or some other excuse for a Government subsidy. So I might have a very hefty bill to replace it well before I otherwise would due to the ULEZ impact.

Motor manufacturers welcomed the Government’s proposals – perhaps because they see the opportunity to sell more vehicles to those being forced to replace them. Others were more critical and an RAC spokesperson said it possibly gave the green light to enable lots of local authorities to introduce charging schemes.

In summary, it seems diesel vehicles will be discouraged by higher taxation and discouraged in other ways also. The day of the all electric vehicle is surely coming closer, while even petrol car sales may start to decline.

Roger Lawson

Air Pollution and the ULEZ – More Information

The revised ULEZ proposals are subject to a public consultation which closes on June the 25th. I made some initial comments on it here:

The intention was to provide some more comments after I have obtained more information on the costs and benefits of the proposals from Transport for London (TfL). So after no initial response from TfL I submitted an FOI ACT request which included this question: “Could you please also provide the costs of implementing the ULEZ (i.e. the capital cost) and the other proposals and the revenue and profits, i.e. surplus over operating costs in future years, forecast to be obtained by TfL as a result”. This request was refused on the grounds of commerciality sensitivity. I have disputed that rejection on the basis that it is of major public interest to know that information before people respond to the consultation, and also that as this request was handled under the Environmental Information Regulations it is not a valid cause for rejection. It will now go to an internal TfL review and after that probably to a complaint to the Information Commissioners Office. But the outcome of these appeals will not probably be known until after the date of the consultation is closed. Certainly that is likely to be too late to educate the population of London on the facts before they respond. In effect, we have a very dubious concealment of the cost/benefits of the proposals and how much profit the Mayor and TfL might generate from this new regime.

But here are some further comments based on what information is available in the current consultation documents.

It suggests that there would be a 30% saving in NOX emissions in central London in 2019 by bringing forward the ULEZ proposals. Most of the savings would come from HGVs and buses, plus to a lesser extent from vans. Emissions from cars would only reduce by 8%. The major reduction would be in central London, but there would also be benefits in inner and outer London due to trips extending to/from those areas and the change to the vehicle fleet encouraged by the ULEZ rules.

There would also be reductions in PM10 and PM2.5 (particulate) emissions, particularly the latter. But these are still relatively small – for example a 7% reduction from cars in central London, and only 2% across the GLA area.

The document does give some indication on the “damage cost savings” that might result. This is the savings on the calculated costs of the current level of pollution. These could be as high as £15.8 million in central London to as low as £10 million. They give a mid-point estimate of £28 million for the whole GLA area. They provide very little information on how those figures have been calculated. But without knowing the cost of the ULEZ scheme to the road users and the required TfL infrastructure, plus their running costs, it is impossible to say whether there is any overall benefit to the population.

In addition, please note the relatively low benefit from including cars of any kind within the ULEZ proposals.

In my view, these proposals are out of proportion to the benefit to be obtained, at least so far as the impact on car owners and drivers are concerned. The fact that TfL are apparently reluctant to disclose the financial budgets for this scheme suggests to me that it is more about tax raising than simply tackling the air pollution health issue.

So if you will be affected, please respond to the consultation which is here: . PLEASE MAKE SURE YOU RESPOND AS SOON AS POSSIBLE

Roger Lawson