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: http://www.freedomfordrivers.org/Social-Cost-Cars.pdf

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: neillock@aol.com.  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: http://act.fairfueluk.com/lobby/Defra-Plan .

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: https://abdlondon.wordpress.com/2017/04/04/mayors-latest-announcements-on-ulez/

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: http://www.tfl.gov.uk/airquality-consultation . PLEASE MAKE SURE YOU RESPOND AS SOON AS POSSIBLE

Roger Lawson

Air Pollution, Oxford Street Buses and Nanoparticles

The Government wished to delay publication of its revised UK Air Quality Plan until after the General Election but after a legal challenge it was forced to publish it. See https://consult.defra.gov.uk/airquality/air-quality-plan-for-tackling-nitrogen-dioxide/ on how the Government plans to improve nitrogen dioxide emissions in particular.

London Mayor Sadiq Khan promptly slammed the proposals as “woefully inadequate” before he could have barely had time to read the full document (air pollution is a technically complex matter and it is necessary to read the whole document and the supporting evidence). In the Evening Standard he said: “I welcome that the government has agreed to consult on introducing a targeted diesel scrappage fund, as I have modelled, to help drivers who bought diesel vehicles in good faith. However, the government has failed to give a firm commitment and, even if it goes ahead, this alone would go nowhere near fixing the problem. City Hall analysis shows that the proposals still mean air quality will be at illegal levels until at least 2026.”

I will provide further and more considered comments on the proposals at a later date.

Meanwhile I am still awaiting a response to my FOI Request on the ULEZ proposals so as to enable a properly considered response to be made to that. It should arrive by the 10th May, but we will see.

In the meantime Transport for London (TfL) has taken steps to reduce pollution on Oxford Street (which is one of the worst locations in London) by introducing proposals to cut the number of buses by 40%. TfL says bus numbers can be reduced because of higher underground frequencies and the new Crossrail service which will open in December 2018. The consultation is present here:

https://consultations.tfl.gov.uk/roads/oxford-street/?cid=oxford-street . Comments: it is undoubtedly the case that the number of buses on Oxford Street not only makes it a very unpleasant street for pedestrians but also creates road safety dangers. Current diesel buses are of course some of the worse emitters of air pollution. Whether the proposals will improve matters substantially is not at all clear.

Another step to improve air pollution in London is the introduction of rapid electric vehicle charging points. TfL has appointed five suppliers to build such a network. These charge points can recharge a vehicle battery in 30 minutes and the plan is to have 300 installed by 2020, although some will be dedicated for use by taxis. All new London taxis must be zero-emission by January 2018.

The latest environmental scare story is the impact of nanoparticles on human health. An article in the New Scientist reported that these microscopic particles can enter the blood stream and they can remain there for over 3 months. The impact they have on health was unknown but the hypothesis given was that they could be having a major impact. In effect the article suggested that we might need to worry not so much about Nitrous Oxides or larger particulates, but about nanoparticles from vehicle pollution.

Nanoparticles are quite difficult to detect, but it is known that they are present everywhere. Indeed normal activities in the home, business activities and certainly industrial activities give off large amounts of nanoparticles which are simply invisible.

A very interesting article in the Financial Times on the 29th April explained how our homes can actually be one of the most polluted locations, often worse than the air outside even in the worst polluted cities. It said “A study published in the European Respiratory Journal in 2012 showed that concentrations of some air pollutants can be up to five times higher indoors than outdoors“. As we spend 90% of our time indoors, versus 10% outdoors, this is of concern. Cooking on gas, food cooking emissions, dog hairs, dead skin particles, lint particles from tumble dryers, deodorant sprays  and scented candles were all named as culprits. Log burning stoves are a particular problem which have become popular even in London of late. The solution is apparently to purchase an electric air purifier.

In summary, pollution is everywhere and always has been. Even green fields and trees can be a menace because of pollens and dust. Indeed I do recall reading a study many years ago that showed the prevalence of asthma was more common in rural areas than in cities.

So it’s easy to become paranoid about air pollution. It’s necessary to separate fact from fiction so that the picture is clear about which pollutants are of real concern and which are not. Otherwise we will get lost in a fog of hysteria.

Roger Lawson

UK Air Pollution – The Facts

The BBC have published several articles recently on air pollution under the emotive headline “So I can breathe”. But one by BBC Environment Analysis Roger Harrabin is actually quite accurate. It’s title is “How bad is air pollution in the UK?” and his answer to that is “Air pollution is a major contributor to ill health in the UK, but it’s hard to say exactly by how much”.

He says that dirty air does not kill people directly but reports that it is estimated that it shortens the lives of around 40,000 people every year – mainly those who already have heart or lung problems. How accurate are the media headlines about this he asks? He says that claming that pollution kills 40,000 people is just wrong and it’s also wrong to say pollution is rising. The 40,000 is also a statistical construct with a lot of uncertainty involved – it might a sixth as big – or twice as big.

Air pollution in the UK has been dropping, but in London recommended NOx levels are still regularly breached and levels at the roadside have barely dropped at all.

He says diesel cars are portrayed as the main villains and the biggest proportion of pollution does come from road transport in general. But if you look at Greater London, private diesel cars only contribute 11% of NOx. Lorries produce a similar amount and in central London only 5% of NOx comes from diesel cars while 38% comes from gas used in heating homes and offices.

Mr Harrabin does suggest some solutions to the problem which you can read in the full article here: http://www.bbc.co.uk/news/science-environment-38979754. It’s well worth reading as it debunks many of the myths spread by the Mayor of London, TfL and others.

If the Mayor persists in attacking diesel cars and other smaller vehicles while doing little about air pollution from heating, industrial processes and other big transport emitters such as HGVs, LGVs, buses and planes then he will be wasting our money.

Roger Lawson

Air Pollution and the ULEZ

The EU Commission has given the UK a final warning over air pollution in the country. That particularly covers London but also 15 other cities. Similar warnings have been given to Germany, France, Italy and Spain. There are persistent breaches of NO2 limits and the European Commission may decide to take legal action if they fail to act within two months. If not the UK could be taken to the Court of Justice of the EU, although that is one Court that will be affected by the UK departing from the EU. The UK Government is to publish a revised plan to deal with the problem in April.

Meanwhile London Mayor Sadiq Khan is not waiting for that. He has published the results of the public consultation on a new Emissions Surcharge and extensions to the Ultra Low Emission Zone (ULEZ). The proposals were covered in our last newsletter (Dec 2016) and would impose major extra costs on road users of many kinds in London. The consultation was done without any data on the likely benefits in terms of reduced pollution, and without any cost benefit analysis. TfL neatly summarised our response to the consultation in this paragraph:

“The Alliance of British Drivers (ABD) is opposed to the implementation of the ULEZ. The ABD believes the consultation is fraudulent and that the ES/ULEZ may be a money making scheme for TfL.”.  

Well they at least got that right, but of course with such biased information being provided, one might expect that the result would be as the Mayor desired. Here’s a brief summary of the results (go here for the full data: https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-2/?cid=airquality-consultation ).

  1. From 23 Oct 2017 some older vehicles will be required to pay a surcharge of £10 to enter the Congestion Charge (a.k.a. Tax) zone. This is called the Emission Surcharge (ES or “T”-charge). They have provided a web site to enable you to check your vehicle for compliance with this and the ULEZ. This is now definitely proceeding as it was a statutory consultation. 63% of respondents supported it, with 30% opposing. Most also supported the proposed start date.
  2. Other consultation questions were non-statutory and there will be another consultation on these soon. One question was on the proposal for an earlier implementation of the ULEZ to 2019. This received 63% support versus 29% opposed.
  3. A third question was on expansion of the ULEZ to within the North and South Circular. This received support from 59% of respondents versus 34% opposed. There was similar support for bringing that in during 2019.

Lastly the latest document from TfL repeats the very dubious claim that “The equivalent of around 9,400 deaths per year in London are attributed to air quality related illnesses”. This is simply wrong and exaggerates the scientific research that has been reported. It confounds possible contributory factors with actual “causes” of death. There is probably some impact on life expectancy from living and working in higher air pollution in London, but the impact is not nearly as clear cut as that and may simply mean some shortening of life in heavily polluted areas.

Note: there are about 48,000 deaths per year from all causes in London. Not a single one has air pollution assigned as a cause of death.

For example this is contained in a report from Clean Air in London: “The Department of Health estimates Bromley (6.1%) has the lowest death rate in London attributable to air pollution and Westminster (8.3%) has the highest” but that is based simply on categorising illnesses and causes of death as being affected to a lesser or greater extent by air pollution. So lung cancer is included even though the vast majority of deaths from it are undoubtedly caused by smoking. There could of course be other reasons from the differences between Bromley and Westminster related to life styles and the demographics of the two populations.

Even if all cars were banned from London, there would still be very considerable air pollution from buses, taxis, HGVs, domestic heating, commercial activities, rail transport, etc, as you can see from the chart below.

air-pollution-sources-london

The message though from these facts is that cleaning up the rest of London’s air to be as good as Bromley’s could only reduce the health impact of air pollution to a limited extent at best and the other demographic factors might mean there is no improvement in mortality . The cost of doing so may be outweighed by the other benefits on which money could be spent to improve the health of the community. For example on the NHS which is clearly desperately short of money as the national media keep telling us of late.

Roger Lawson