MTS Campaign Meeting Report

On Saturday the 28th April we held a meeting for supporters of the ABD’s campaign against the Mayor’s Transport Strategy (MTS) in central London. I chose to drive to the venue as I was carrying quite a weight of equipment and papers, but it turned into a typical nightmare trip on London’s roads. It ended up taking 2 hours to drive the 15 miles there. We were doing well until we hit a closure of Upper Thames Street and The Embankment with all traffic being diverted across Southwark Bridge south of the river – the exact opposite direction to where we wanted to go. So I turned round and aimed to take a route around to the North via City Road and the Angel, Islington. But that route was also closed by apparent crane work. There was no advance notice or signs of these closures on two of the key routes in London. Even on a Saturday they are now very busy. What a dreadful way to run a transport network of a major world city!

I did eventually manage to get there in time to give my presentation, but one or two people didn’t make it perhaps because of the traffic congestion. Here’s a brief summary of what was said at the meeting. The Powerpoint presentation slides are available here: http://www.freedomfordrivers.org/MTS%20Meeting%20Presentation%202018-04-28.pdf

After a brief explanation of the objectives and background of the Alliance of British Drivers I explained the key themes of the Mayor’s Strategy. These are to turn streets into places for “active travel and social interaction”, and to reduce “car dependency”. The latter is of course an emotive phrase when nobody talks about “cycle dependency” or “public transport dependency”. Why should it be used to describe people’s rational choice of transport mode? Such phrases are just part of the “spin” put on these policies and the graphic I showed taken from the Mayor’s document demonstrates how unrealistic are the depictions of London in the future. Such graphics often ignore the needs for local transport deliveries of goods and services in London. In addition the Mayor has ignored the needs of the growing proportion of elderly and disabled people in London, many of whom have responded to our campaign as they are dependent on private cars or PHVs.

I talked about the Mayor’s problems which the Strategy aims to counter. This includes a rapidly growing population in London which is putting a stress on public transport capacity and road congestion, and also leading to higher air pollution (and not just from traffic). These of course result from past policies adopted by London Mayors. But one of his key problems is shortage of money with a massive budget deficit looming. This results from public transport fare freezes which he promised to get elected, increasing subsidies and general financial mismanagement.

I explained that the answer from the Mayor are policies that will extract more money from Londoners (and those who visit London from outside) and restrict private travel in the name of making the population healthier. There are a number of ways the Mayor can implement these policies, via the encouragement of the London boroughs if not directly.

What alternatives could the Mayor have proposed? Obviously one of the key factors has been the growing population of London and he could have reduced that by encouraging redistribution of business activity and population as was done in the 1960s via New Towns, or by not promoting it as “more open” to immigration as he has done recently. The implementation of cycle superhighways in the manner done, road space removal (road closures, removal of gyratories, etc) and other detail policies emanating from TfL have also contributed. I suggested that it was possible to improve the road network for cyclists and for road safety without such damaging impacts on the road network.

There was a brief explanation of the Ultra Low Emission Zone (ULEZ) and the misleading claims made about deaths from air pollution in London (as one member of the audience put it: “40,000 deaths a year in London”, which shows how spurious statistics are being propagated). There is no major health crisis, Londoners are living longer and air quality is improving! We then had a session from Howard Cox of FairFuelUK. He explained what his organisation has been doing to obtain 1.7 million supporters for a campaign that is well worth supporting. He has been good at obtaining both media and political support as a result. He questioned why the Government have not looked at alternative ways of improving air quality and looked at other sources of emissions rather than just focussing on vehicle owners. FairFuelUK are working with others to produce better scientific evidence on the real health impact of emissions and the cost of ignoring alternative solutions to reducing emissions.

I explained what the campaign against the MTS had been doing and what we will do going forward. The audience was encouraged to support us in several ways to enable us to generate more supporters and more funds to fight the campaign.

Lastly there was a session on how to defeat the MTS. This can be done in local boroughs (for example I explained earlier how the ABD had defeated a proposed congestion charge in Greenwich promoted by Ken Livingstone over ten years ago), or perhaps by ensuring Sadiq Khan does not get re-elected as Mayor in two years’ time. As he is doing a good job of becoming unpopular for other reasons, just like Ken Livingstone at the end of his reign, perhaps the slogan should be similar to the popular one in that era – namely “anyone but Khan” for Mayor at the next election.

It was noted that the ABD can give assistance with local campaigns in several ways – you just need to ask for it.

We covered how supporters can help the campaign. Recruiting more supporters is one key aspect over the next few months, ensure that people find out what is being done in their local boroughs (a member of the audience suggested that people ask if there are any proposals for a local congestion charge) and provide funds to fight the campaign. It is important to ensure that more London residents, and those in surrounding areas, know what is being proposed because there is general ignorance on the subject – few people have actually read the Mayor’s Transport Strategy document but it will dictate many aspects of travel and parking in London over the next few years.

There was plenty of time for questions from the audience. Two particular subjects that arose was the status on Cycle Superhighway 11 (CS11) and Bank Junction closure in the City. On the former, which was proposed to result in the closure of Regent’s Park to vehicles, it seems that it may be being held up by objections from affected borough councils after all. CS11 is a good example of how local opposition can delay or thwart unreasonable proposals. On Bank this is an experimental scheme but will be subject to a review in a few months’ time and I explained what representations the ABD had made on this topic.

The key as always if you want to have an impact on politicians is not just to moan in private or on social media, but to directly contact the political decision makers – the Mayor London, London Assembly Members, your local M.P, local Councillors, et al. It is also necessarily to respond to relevant public consultations and get the vote out when necessary.

In my experience politicians do listen, particularly when it seems they might be at risk of losing an election by pursuing unpopular policies! Please bear that in mind. That was perhaps one of the most important points communicated at this event.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

You can “follow” this blog by clicking on the bottom right.

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Press Release: Mayor Sadiq Khan Ignores Objections to his Transport Strategy

The ABD has issued the following press release:

The response of the Mayor of London, Sadiq Khan, to the public consultation on his Transport Strategy has been announced today. The Alliance of British Drivers (ABD) has been actively campaigning against certain aspects of his proposals.

We suggested that his proposals were a direct attack on the use of cars or indeed private transport in general and that not only were his proposals unrealistic but would not work. Our campaign attracted more responses to his proposals than any other campaign group.

Has he made any significant changes to his proposals? In reality NO. The response document (see below) is full of comments that say “no change” is proposed.

A Brief Analysis of Responses to the Public Consultation

The Mayor claims “broad support” for his Healthy Streets approach and the 80% mode share target for cycling, walking and public transport use. But then goes on to say “there were sometimes divergent views across issues”. Indeed, if you look at the details of the comments TfL received there was substantial opposition to many points, including much opposition to road user charging or congestion charging schemes.

There were clearly lots of opposing comments from outer London residents and although the Mayor has committed to respond to them by improving the bus network and surface rail in outer London, this is hardly likely to placate many objectors. Our experience is that many of those objecting are disabled or very elderly who often rely on private vehicles and who would have difficulty with public transport (most of them consider the suggestion that they should cycle as laughable). You can see some comments from our campaign supporters on our web site.

This is also evident from the Consultation Response Document where it says “there was a notable level of disagreement with the aim that by 2041 Londoners should be doing 20 minutes of active travel each day” (page 30 of the Consultation Report).

Opposition to road charging was evidenced by 566 “comments of concern” versus 250 supportive comments (see page 103). That’s good evidence of the level of opposition. That’s despite the repeated claims by the Mayor that the Congestion Charge system reduced congestion (see page 106), which is simply not true. But it is “no change” for his strategy to support charging schemes. His only concession is that it will be up to local boroughs to consider how or whether to implement them (see page 109). The ABD is likely therefore to be fighting these in individual boroughs in future as we successfully did in Greenwich when this was last proposed.

Even the Mayor’s environmental policies received a lot of negative comments (see page 110) and there were also many against “densification” of London which is a major concern in outer London boroughs (see page 162). The Mayor again proposes “no change” to his strategy on those.

In summary a disappointing outcome, with consultation responses minimised by the short timescale allowed. The outcome is much as one might expect when you have a Mayor who has dictatorial powers and who does not seem to understand the diverse population of London and those who live in outer London.

More Information

The ABD’s campaign against the Mayor’s Transport is described here: http://www.freedomfordrivers.org/against-mts.htm

The Announcement from TfL and the Consultation Report document can be obtained from here: https://consultations.tfl.gov.uk/policy/mayors-transport-strategy/?cid=mayors-transport-strategy

For more information, contact Roger Lawson on 020-8295-0378.

Traffic Speeds in London – They Are Getting Worse

I was having a clear out today of my office, and I happened to notice a copy of Ken Livingstone’s Mayor’s Transport Strategy dating from July 2001. It made for both amusing reading and anger at the lack of progress made since.

This is the first sentence in his Foreword to that document: “The single biggest problem for London is the gridlock of our transport system. At the start of the 21st Century, traffic speeds in central London have fallen to less than ten miles an hour with knock-on effects on the speed and reliability of the bus system. Congestion is growing in outer London town centres. Rail services are in unprecedented crisis. The Underground is more over-crowded and unreliable…..”. He said the transport crisis threatened London’s economic prosperity and suggested London needed a “world class transport system”.

Have we got one now? Not exactly and traffic speeds have actually fallen below what they were in 2001. In central London traffic speeds were reported as being less than 9 mph in central London last year by various sources, and as low as 7.3 mph in one quarter in 2017.

The Underground is more crowded than ever with some stations having to be closed at peak times. Surface rail has improved in some regards on some lines, but certainly not if you are a Southern Rail user.

What did Mr Livingstone plan to do to improve the dire state of affairs he commented upon? Apart from the fine words about improving the capacity of the public transport network as in Sadiq Khans recently published Transport Strategy, he proposed to implement a Congestion Charge “to deter unnecessary vehicle journeys in central London”. That obviously did not work. You can find a lot more analysis of why on this web page: http://www.freedomfordrivers.org/congestion.htm .

Excuses from the Mayor and Transport for London as to why it did not work are numerous but are false. It failed simply because London has such high unsatisfied demand for road space and lots of people willing to pay for it, that they simply soaked up the space. The Congestion Charge (a.k.a. Tax) has more than doubled since Ken Livingstone introduced it, and still it did not work. In addition, more road space has been taken up by buses which are massively subsidised and their numbers expanded under Livingstone (they are still high) and by the modern fashion for PHVs (Uber etc). The growth in the population of London, and of businesses in central London, have created major headwinds in addition while cycle lanes have taken up valuable road space but are often relatively little used.

Mr Livingstone, and his successors Boris Johnson and Sadiq Khan have persisted with irrational and unproductive gestures without getting to the nub of the issue and producing policies that might actually work. Boris Johnson seemed to try to solve the problem by encouraging cycling, and Sadiq Khan’s added walking as a solution to both our transport and health problems. He also suggests road pricing or more congestion charging might help when we know from experience that those policies will not improve matters.

I suggest readers tell Sadiq Khan that a totally fresh approach is needed. Not more of the same regurgitated policies that emanate from Transport for London.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

You can “follow” this blog by clicking on the bottom right.

Mayor’s Transport Strategy – Feedback

We have received a lot of comments from the general public on our campaign against the Mayor’s Transport Strategy. Many were not aware of what was proposed and those particularly concerned were the elderly and disabled. This is a typical example recently received:

“I’ve just received your leaflet re the above and I’m aghast at the mayor’s proposals you’ve listed.  I rarely use my car to pop to the local shops, preferring to walk, for the exercise.  However, it’s much more convenient and quicker to drive to the nearest swimming pool (for more exercise!) than it is to get the bus (which I know I could do).  I also do the weekly shop once a week after swimming and this would not be possible without using my car.  I know I could do it online but I prefer to choose my own products – and anyway it still requires a vehicle to do the delivery! 

I certainly don’t see why I should pay more than I already do for this!  

We also get frequent visits from carers who help look after my wife – a lot of them use the bus but some of them use cars and I think it would be unfair for them to have to pay more. 

Perhaps you would be kind enough to send me the link to the relevant detail and proposed timetable for implementation and also details on how to object please.”

There are of course enormous numbers of elderly and disabled people living in London who often rely on cars and PHVs (minicabs) for day to day transport. Suggesting most of them can walk or cycle is simply nonsense and even using buses can be impractical for them due to the instability of such vehicles.

In addition, there are large numbers of ladies who feel insecure walking the streets at night and using public transport can be seen as risky.

Another group of objectors are those running small businesses who have to transport goods and those with large families who do a “bulk” shop at a supermarket once per week. The load that results is too large to carry other than in a vehicle.

The Mayor’s Transport Strategy focuses on the young and healthy who have office jobs in central London to which they commute via public transport, or those fit enough and willing to cycle in all weathers, while it ignores a very large proportion of the population. It needs to be scrapped and a new plan put forward!

Roger Lawson

 

Twitter: https://twitter.com/Drivers_London

 

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Press Release: TfL Forced to Disclose ULEZ Costs

The Alliance of British Drivers (ABD) has issued the following press release:

Back in April 2017 the ABD responded to a public consultation on the proposed extension of the ULEZ. However we criticised the lack of information on the cost/benefit of the scheme, indeed of any information on costs and likely revenues at all, which made making an informed response to the consultation difficult.

As Transport for London (TfL) refused to provide such information when requested we submitted a Freedom of Information Act request. TfL refused the request on the grounds of “commercial confidentiality” so we asked for a review and subsequently appealed to the Information Commissioner’s Office (ICO).

They have upheld our complaint and so we should get the requested information after all (unless they appeal to the First Tier Tribunal). But is it not disgraceful that TfL can obstruct and delay this legitimate need for such information?

TfL claimed it was commercially sensitive because they were already talking to possible suppliers but the ICO judged that there was insufficient evidence that such disclosure would result in specific harm to TfL that would justify refusal.

In our view the ULEZ proposals are out of proportion to the benefit to be obtained. The fact that TfL are apparently reluctant to disclose the financial budgets for this scheme suggests to us that it is more about tax raising than simply tackling the air pollution health issue.

In addition the costs of the scheme may be so high that even with the additional taxes raised from vehicle users, it may be unaffordable. BUT WE DON’T KNOW BECAUSE TFL REFUSED TO TELL US.

It is unfortunately typical of late for the Mayor of London, Sadiq Khan, to issue public consultations in his name that are biased polemics of the benefits of his proposals while not disclosing the facts. Democracy is undermined when a public authority acts in this way.

It is further undermined when TfL refuse to disclose information and by doing so delay its release past the consultation due date when they know any appeal process will take many months.

There is great public concern about the costs imposed on London residents by the ULEZ proposals, often on the poorest residents. It needs to be clear that the benefits are justified by the costs and that more cost effective solutions to tackle London’s poor air quality cannot be found.

More information will be published when we get the requested data; in the meantime you can read the ICO’s decision notice here: http://www.freedomfordrivers.org/ICO-Decision-ULEZ-Request.pdf

More Information

The ULEZ proposals are part of the Mayor’s Transport Strategy which the ABD is vigorously campaigning against – see this web page for more information: http://www.freedomfordrivers.org/against-mts.htm

There is also an attack on vehicle usage and parking provision in the “London Plan” which the ABD is also opposing on the grounds of irrationally and the use of emotive phrases such as “car dependency” to describe people’s rational choice of transport mode. See the above web page for our recent submission to the public consultation on the London Plan.

For more information on this issue, contact Roger Lawson on 020-8295-0378.

Sadiq Khan Plans Your Life

If you live in London, you should pay attention to the “London Plan” that Mayor Sadiq Khan has recently published. Indeed if you live in other large conurbations you might wish to review it also because the policies he is promoting might spread elsewhere.

What’s the London Plan? It’s a document that sets the “spatial development” strategy for London over the next few years and has legal implications for planning developments, housing construction, transport infrastructure, and many other aspects of our lives.

The Mayor makes it plain that London needs to cope with the rapidly expanding population and business activity. The population of London might reach 10.5 million by 2041 he says (currently 8.8 million). That means a lot more houses have to be built (66,000 per annum he says) and support for more workplaces.

In addition it has major implications for transport infrastructure while at the same time he wants to clean up London’s air. He wants to make London a “zero carbon” city by 2050, although no doubt he will be long gone by then. As part of this he aims to reduce “car dependency” (an emotive and inaccurate phrase disparaging people who have made a rational or personal choice about how they travel when you don’t see this said about those who rely on cycles for their daily travel needs).

Why has the population of London grown so rapidly in recent years and continues to do so? Page 12 of the Plan explains why. It says 40 per cent of Londoners were born outside the UK, and the city is now home to 1 million EU citizens, no doubt attracted by the vibrant London economy. This has put a major strain on housing, transport, social services and other infrastructure (incidentally an unbelievable 1.2 million Londoners are apparently “disabled”).

This state of affairs has come about because of national policies on immigration with no effective policies to distribute that more widely across the country compounded no doubt by a desire by some politicians to improve their chances of being elected.

Specifically looking at transport, the Mayor’s target is for 80% of all journeys to be made by walking, cycling and public transport (that of course includes the 14% of Londoners who are disabled!). It’s currently 64%. This is going to mean an aggressive set of policies to reduce car use – hence our campaign against the Mayor’s Transport Strategy which supports the London Plan – see http://www.freedomfordrivers.org/against-mts.htm

The Mayor highlights the health inequalities in London, with deprived areas of London having reduced life expectancies (as much as 15 years for men and 19 years for women) surely an astonishing statistic. What is the reason for this? Poor housing conditions are certainly one, but lack of daily activity is allegedly another so the Mayor wants us all to be walking and cycling.

The Mayor does have plans to improve public transport including proposals for Crossrail 2 and extension of the Bakerloo line but these proposals will do relatively little to soak up the increased demand, and with no proposals of significance to improve the road network, hence no doubt the need to encourage us all to walk or cycle.

The Mayor’s plans to support the need for more housing include targets for every London borough (for example over 2,000 new homes every year in Barnet, Brent, Ealing, Greenwich, Hounslow, Newham, Southwark, and Tower Hamlets). This includes high concentration developments in locations with good public transport access levels (PTALs), particularly inner London boroughs. Outer London boroughs might see a relaxation of planning regulations to allow more “in-fill” developments including building on back gardens as the Conservatives promptly complained about. There will be more encouragement for smaller builders, more efficient building techniques and “proactive” intervention in London’s land market (more “compulsory purchase” perhaps).

One aspect of transport infrastructure that the London Plan covers is that of parking provision for new housing, office or shop developments. It wants most developments to be “car free” (i.e. no parking provision), particularly those with high PTAL levels. The details of what this means in practice are not clear, but it looks like the intention is to reduce parking provision substantially, thus resulting in more on-street parking and obstruction.

The Mayor concludes his near 500-page tome on the subject of the “Funding Gap”. By this he means the gap between the public sector funding required to support London’s growth (and his plans) and the money currently committed. In other words, he wants more money, including a bigger share of taxation collected from Londoners. For example, he repeats his call for control of Vehicle Excise Duty (VED) which any right-thinking person should surely oppose. Yes the Mayor wants more money and more power. Unfortunately the establishment of directly elected Mayors such as Mr Khan has resulted in empire building of the worst kind. They are effectively dictators within their realms with no effective democratic constraints on their policies and negligible public accountability.

In summary, it is not clear that the building of lots of new homes (which of course will emit more pollutants, particularly during constructions, more than offsetting any reduction from restraining car use), of a fairly low standard in dense conurbations, is going to improve the quality of life for Londoners. It is undoubtedly the case that more new homes are needed in London but building new homes without complementary improvements to the transport infrastructure, which has consistently lagged behind the growth in London’s population, does not make much sense.

As is already seen in the statistics, older London residents are moving out and being replaced by immigrants. Some readers might wish to consider doing the same given the outlook for the quality of life in London. Simply reacting to the population growth in London without trying to constrain it, or divert it elsewhere, is surely a mistake.

You can submit your comments on the London Plan to the public consultation by going here: https://www.london.gov.uk/what-we-do/planning/london-plan/new-london-plan/comment-draft-london-plan . Please be sure to do so.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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Does Air Pollution Cause Asthma?

One response to the ABD’s campaign against the Mayor’s Transport Strategy is that we should not oppose it because it might stop their kids getting asthma. Children have been widely used in Sadiq Khan’s publicity over his plans to reduce air pollution and there is a strong emphasis in the Transport Strategy on the potential environmental benefits. But unfortunately, a lot of the arguments put forward are simplistic and show little understanding of the causes and prevalence of asthma.

Like the Mayor, this writer has suffered from asthma, so I have a personal interest in this issue. Note also that the ABD does not oppose cleaning up London’s air because one does not need a scientist to tell you that air quality in central London, and in some outer London “hot spots”, is appalling bad and not just makes walking or cycling unpleasant but probably exacerbates some medical conditions (including pre-existing asthma of course). The ABD’s opposition to the Mayor’s Transport Strategy is based on other factors and the irrational, ineffective and uneconomic approach to the environmental issues.

Let’s cover some of the basics about asthma:

  • Does air pollution cause asthma (in children or others)? As far back as 1995, a Committee on the Medical Effects of Air Pollutants (COMEAP) looked at this issue and came to the conclusion that although air pollution may provoke asthma attacks or aggravate existing chronic disease, the effect is generally small with other factors such as viruses, cigarette smoke, diet and house dust-mite droppings more important. They also noted that there had been a general increase in asthma in the last 30 years so it was now a very common disease. Was this down to more urbanisation and are city dwellers more likely to suffer from it because of air pollution? The answer is no. Indeed, a study in the Isle of Skye, where air pollution was believed to be minimal, showed as high a prevalence of asthma as anywhere else. See this report in The Independent for more information: http://www.independent.co.uk/news/air-pollution-is-not-the-cause-of-asthma-epidemic-1578437.html . Very heavy air pollution may reduce lung function in children according to more recent studies, but it is not the cause of the asthma epidemic in the last 50 years.
  • Why are allergies, that drive asthma, more common? There have been many possible causes put forward for this. It seems to relate to the exposure of very young children, or their mothers, that condition the immune system to over-react. For example, it has been argued that excessively clean houses are one cause. Smoking by mothers, or in houses, may have been another cause. Or a general increase in pollutants in the home. As we reported in the ABD London newsletter in June 2017, the concentration of some air pollutants can be five times higher indoors than outdoors. This is due to gas stoves, food cooking, dog/cat hairs, dead skin, lint particles from tumble dryers, deodorant spays, scented candles and air fresheners. The desire to minimise heat loss from homes, and reduce drafts (and hence fresh air) along with smaller homes might have contributed to these problems. Obesity is also a factor in asthma risk and we all know that has been rising. 
  • Are diesel vehicles a cause of worse air pollution and asthma? Diesel vehicles became popular for cars, and always have been for HGVs and buses, because of reduced fuel consumption and a desire to minimise carbon emissions. However that did not take account of the large emissions of NOX and particulates from such vehicles. But removing all diesel vehicles would not likely have much impact on overall air pollution levels in London. The reason is that much of the air pollution is from other sources such as home/office heating, industrial activities, or simply blown in from the countryside around. Even with vehicles, much of the particulates come from tyre and brake wear so converting all vehicles to electric ones will only reduce the emissions, not eliminate them. And removing private cars will have minimal impact when taxis, PHVs, LGVs, and HGVs continue to increase in number and are much bigger sources, as are trains, planes, river traffic and other transport modes. To reduce air pollution needs a much more “holistic” approach rather than focussing on one or two perceived evils alone. It seems very unlikely that attacks on diesel vehicles will have much impact on the causes or prevalence of asthma in any sensible timescale and the latest diesel vehicles are now very clean.

The above is a simplification of a very complex topic, but I hope it explains some of the key points. Does Mayor Sadiq Khan believe he is doing good by his aggressive environmental policies that will get us all walking and cycling (other than the disabled presumably)? Is he simply ignorant of the real issues? Or is he promoting these policies for other reasons, such as the financial problems of Transport for London, his desire to raise more funds and his desire to be seen as “doing good” to help his re-election?

Lastly, it’s worth mentioning that although asthma has become a lot more prevalent, the medical treatments for the disease are now quite effective in other than the worse cases. Certainly, much better than when I was a child. The high prevalence of asthma in the UK has been given as one reason why the UK became a centre for the medical research into treatments. But it seems to be a worldwide phenomenon that asthma levels have increased.

My conclusion is that cleaning up London’s air might make it a more pleasant place to live and work, but it won’t have much impact on the prevalence of asthma.

Incidentally a great article on the scare-mongering associated with air pollution is present here: https://notalotofpeopleknowthat.wordpress.com/2017/08/15/claims-of-40000-deaths-from-air-pollution-debunked-by-death-statistics/

Roger Lawson

Twitter: https://twitter.com/Drivers_London

You can “follow” this blog by clicking on the bottom right.