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Manchester Friends of the Earth response to the DEFRA Clean Air Zone consultation…

The Government is consulting on plans to introduce Clean Air Zones in 5 cities in England (Birmingham, Leeds, Nottingham, Derby and Southampton) to reduce air pollution.  Unfortunately, Greater Manchester is not currently included – despite estimates that air pollution causes nearly 2000 people to die prematurely in Greater Manchester each year

Please see below for Manchester Friends of the Earth’s response to the DEFRA consultation.  See Demand Clean Air Zones in Greater Manchester for more details on Air Quality and how to repond. You have untill midnight on Friday 9th December to get your comments in !

Our response in full.

Q1. In the Draft Clean Air Zone Framework, are the right measures set out in Section 2?


Section 2 contains some good, useful and positive measures. However Manchester Friends of the Earth do not consider fossil-fuel based ‘alternative’ fuels such as LPG to be appropriate to promote-  the move must be to genuine clean powered vehicles.

A Parliamentary Answer (Hansard 19th October) indicates that all 10 Greater Manchester Local Authorities were observed to have exceedances of the annual mean NO2 limit value in 2015.  Eg they failed to meet the EU NO2 legal limits and some are failing to meet the World Health Organisation Particulate Matter (PM) pollution Air Quality Guideline levels.

The World Health Organisation has also found that air pollution causes health effects below current EU legal limits.

2. Are there additional measures that should be highlighted under each theme? Please give evidence of impact if possible.


supporting local growth and ambition (decoupling growth and pollution).
accelerating the transition to a low emission economy.
immediate action to improve air quality and health. ]

Local Authorities should set Road Traffic Reduction targets (under powers from the 1997 Road Traffic Reduction Act) so that NO2 legal limits would be met by 2018 using a Clean AirZones – this would help ensure policy development and development control were aligned with the air quality needs.

There would be further benefits from traffic reduction as reduced congestion benefitted business.

The Framework must make clear that new road building and road-widening schemes  which would generate new traffic, and worsen congestion, cannot be allowed to worsen the air pollution problem.

Question 3: In addition to the draft Framework, are there other positive measures that (a) local or (b) central government could introduce to encourage and support clean air in our cities?

(b) The government must review and revise its National Networks National Planning Statement (NPS). This currently permits a scheme to worsen air pollution already over EU legal limits as long as it does not delay the compliance with EU legal limits of the Air Quality Management Area  it is located in.  For example,  as long as some where else in the Air Quality Management Area has even worse air pollution

The government must also review its planned road-building schemes and abandon any which would worsen air pollution where it was already over limits, whether or not the scheme would delay compliance.

We would highlight the clarification provided by the European Commission relating to
provisions contained within Directive 2008/50/EC namely that:

a) limit values must indeed be complied with throughout the territory of any given air quality zone, and compliance should not be determined nor assessed as an “average” of concentrations measured in different locations within the same zone.” (Emphasis added).

b) Unlike target values, which create an objective to be achieved “where possible” or “where not entailing disproportionate costs”, limit values create an obligation of result which is unconditional and absolute, irrespective of costs (Article 2, paragraphs 5 and 9). (Emphasis added)

The recent High Court ruling on the case brough by Clientearth made it very clear that the route to NO2 compliance must be via policies and action that reduce exposure to air pollution,

The government must also take measures to phase out diesel, and indeed ultimately all combustion engines.

Measures such as those which are being proposed for the Netherlands and Norway by 2025, as well as Germany by 2030, to make diesel and petrol cars not available for sale will be essential.

A reversal of the current diesel incentive in VED/road tax is essential to discourage purchase of the dirtiest vehicles, and is long-overdue.

A carefully-designed scrappage scheme will be essential to help people with diesel vehicles (many of which were purchased in good faith as being better for the environment) get rid of them – and they must be offered alternatives of zero-emissions vehicles or preferably car club membership, and better still alternatives to driving such as rail season tickets or cycle purchase schemes.

National government also needs to provide long-term and consistent funding via the Cycling & Walking Investment Scheme to enable local authorities, such as Greater Manchester Combined Authority to develop safe, attractive, comfortable and cohererent cycling networks.

See Getting moving: a cycling manifesto for Greater Manchester

4. Are the operational standards and requirements set out in Section 3 of the Framework acceptable? Please provide supporting evidence for your views.


The government’s current Air Quality plans from December 2015 have been deemed inadequate by the High Court ruling on the Clientearth court case.

The 2015 Air Quality Plans only required 5 cities to introduce charging Clean Air Zones  (as well as arrangements for London).  All of these 5 cities were only required by 2020, and none of them would include cars, and 3 not even Light Goods Vehicles.

As a Clientearth memo identified there were another 10  cities  proposed.  Although, as we have highlighted above, a Parliamentary Answer (Hansard 19th October) indicates that all 10 Greater Manchester Local Authorities were observed to have exceedances of the annual mean NO2 limit value in 2015.

New Air Quality plans are now required by the end of July 2017. These must include plans for many more mandatory charging Clean Air Zones with funding (to cover development and implementation).

Manchester Friends of the Earth believes that any local authority in Greater Manchester that is failing to meet EU air quality limits should be required to introduce Clean Air Zones in the areas affected.  National government must provide the relevant funding (to cover development and implementation).

While Local Authorities must take immediate action to cut NO2 levels as soon as possible,  Clean Air Zones must be in place by 2018 to ensure compliance by then.  We understand that Birmingham and Nottingham believe that they can introduce their  Clean Air Zones by that date.

Clean Air Zones must be by default at least type D ie to include all vehicle types including cars, and a stronger category must be considered.

Clean Air Zones should be comprehensive in extent ie city/town wide to get the maximum benefit.

5. Do you agree that the requirements in Clean Air Zones for taxis and for private hire vehicles should be equivalent? Please provide supporting evidence for your views.

Yes, The emphasis should be for pre-compliance via licencing etc.

6. Question 6: Do you agree the standards should be updated periodically? Yes

7. If yes, do you agree that the minimum vehicle standards set out in the Framework should remain in place until at least 2025? Please provide supporting evidence for your views.

No – sooner date.

The High Court ruling on the Clientearth court case will require stronger and more urgent action.

The date for any first revision must depend on what the final framework requires. For example, if the framework requires Clean Air Zones that are adequately strong from the outset,  including being Class D (to include cars) this would require a different revision date compared to any framework that mandated less strong Clean Air Zones.

8. Do you agree with the approach to Blue Badge holders?


9. Is the approach set out in Section 3.9 suitable to ensure charges are set at an appropriate level?


Clean Air Zones should not be revenue raising as such,  however any revenue must be ring-fenced for air quality improvement measures.

Charges should be set to ensure that traffic levels are reduced – as well as cleaner vehicles it is imperative that there are also fewer vehicles.

Even “zero-emission” vehicles produce particle air pollution ie PMs from brake lining and tyre wear – many of which are Group 1 Carcinogens.

Question 10: Do you have any comments on the secondary legislation as drafted?

No comment at this point

Question 11: Do you agree with the approach undertaken in the impact assessment? If no, please provide supporting evidence.

No comment at this point

Question 12: Do you agree with the conclusions of the impact assessment? If no, please provide supporting evidence.

No comment at this point

Question 13: Are you aware of any additional data that could inform the impact assessment? If yes, please give details.

No comment at this point

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