Response to Low-emission Strategy and Air Quality Action Plan

Transport for Greater Manchester (TfGM) have consulted on the Greater Manchester Low-Emission Strategy and Air Quality Action Plan (pdf). Manchester Friends of the Earth submitted our response to the consultation (pdf) on 29th April 2016.  See below for the introductory comments and the pdf link above for the full response.

Manchester Friends of the Earth welcomes the opportunity to respond to the consultation on the Greater Manchester Low-Emissions Strategy and Air Quality Action Plan (GMLES).

Our response uses the headings outlined in the consultation form. There are some crosscutting themes and additional issues which we wish to highlight. We have used GMLES throughout our response to refer to the consultation document.

The sections are as follows:

• About Manchester Friends of the Earth and why we are responding (Q1).
• Overall comments on the importance of emissions reduction and air quality (Q2, Q3 and Q12).
• Comments on ultra low emissions vehicles – e.g. electric cars (Q4).
• Comments on the approach to dealing with HGVs (Q5) and goods vehicles (Q14).
• Reducing emissions from buses (Q6 and Q15)
• Changing travel behaviour – including media/communications around air quality (Q7, Q17, Q19).
• Clean Air Zones / Low Emissions Zones (Q8)
• New development and links with the planning system (Q9 and Q13)
• Cycling and walking (Q16)
• Private cars
• Other priorities and feedback (Q11 and Q20)
  a) Aviation / Manchester Airport
  b) Air pollution impact of new road building schemes
  c) A Low Emission Strategy and Air Quality Action Plan for All.
  d) Air quality limits and air quality data.

Manchester Friends of the Earth recognise the regulatory and funding constraints that transport authorities, outside of London, have had to operate under. Underpinning all of the proposals and suggestions outlined in our response is a recognition that Greater

Manchester needs to take the Regulatory Powers that Transport for London has, and use these to develop a properly integrated and affordable public transport system.

Manchester Friends of the Earth believes that Greater Manchester needs to have greater control over the types and quality of buses that operate on our roads. Extending the scope of bus franchising powers will enable Greater Manchester to provide better bus service provision across the region. A properly integrated and affordable public transport system is essential to enable people to make more sustainable travel choices that meets their needs for reliable transport and the ability to get to work, school, shops or leisure facilities across Greater Manchester.

Manchester Friends of the Earth strongly supports the conclusions in the GMLES that to improve air quality in Greater Manchester that “concerted effort, potentially requiring radical actions, is needed by all parties to reduce emissions” and that we need a “significant reduction in the number and length of journeys made by diesel and petrol-fuelled vehicles” and this will not be achievable without “radical action to clean up vehicle engines.”

The estimates are that over 1000 people are dying prematurely each year in Greater Manchester from air pollution. It is also likely that these figures are under-estimates. These figures are far greater than for road casualties and second only to deaths from smoking-related diseases.

On 27th April 2016, the Environment, Food and Rural Affairs Committee report on Air Quality described air pollution in the UK as a “public health emergency”.  Manchester Friends of the Earth strongly supports most of the proposed measures outlined in the GMLES but overall we are struck by what we consider to be a mismatch between the scale of the problem identified and the scope and scale of the proposed responses.

If, as has been suggested by the Environment, Food and Rural Affairs Committee, the UK and Greater Manchester are facing a “public health emergency” from the impact of air pollution – where is the sense of urgency and the bold, innovative solutions required to tackle this emergency?

We hope the revised Low Emission strategy and Air Quality Action Plan as well as any future Implementation Plans will adopt bolder solutions to meet the public health emergency.