Councillor Consultation on Draft Air Quality Action Plan (post-public
consultation) – Summary of consultation responses.
ID
Councillor
Specific points/comments
Response
1
Cllr Heather
Acton
(Email of 31
August 2012
13:02)
(Comments
regarding
AQAP)
Typos and grammar in
foreword:
Amended.
Foreword, line 2 "a" vast array.
Foreword, last sentence rather wordy - split to
two sentences? change "must
collectively achieve"?! )
p33, bullet points grammar:
p33 last three bullet points
should be supported, removed,
provided
p33, Add ‘Supporting car-free
developments in appropriate
locations’ as bullet point. This
could also be mentioned in
paragraph 7.5.3 re car clubs:
Add a bullet point "supported
car free developments in
appropriate situations"?!
Controversial I know, but there
have been a couple. This
could also be mentioned in
paragraph 7.5.3 and linked
with car club membership
(often required as a
concession from developers
through the planning process)
P38, Addison Lee comments
re private hire vehicles (PHVs)
idling and encouraging PHV
company incentives.
Last sentence of foreword divided in to two
for clarity; “I would like to thank all those
involved in the production of this important
document, particularly our key stakeholders,
partners and local communities who we will
continue to work with over the coming
months and years. Delivering improvements
to our local air quality to help
create a healthy city is a goal that we will
endeavor to achieve”
Corrected
Sentence not included re ‘support of car-free
development proposals’ due to this not being
supported by planning policy (checked with
planning department). Car clubs are one
alternative to ‘car-free’ developments and
have full mention under separate section
(paragraph 6.4.1) and separate action;
TRAN 3.
Bullet point on p38 is a Mayor’s AQ strategy
measure. Comment fed into p55 paragraph
6.8.11; “The Council will also encourage
private hire vehicle companies to implement
low emission initiatives or measures with
respect to their fleet operations and
services”.
Cllr Heather
Acton
(continued)
P39, suggested heading
change to ‘buses and
coaches’. Discouraging
coaches into central London
comment; should heading be
buses and coaches? There
does not seem to be much
about coaches - is it too
controversial to talk about
discouraging coach entry into
the centre of London?
P43, paragraph 6.3.10:
clarification of whether this
section is saying that we do
not want to pedestrianise;
I did not understand the last
sentence - is it saying do not
pedestrianise? Needs to be
clearer. Also not so sure about
the "emerging BID" comment does Paddington BID achieve
in this way?
P45-47, paragraphs 6.4.9 6.4.12 and Action Tran 4
(Electric Vehicle charging
costs): I think we are rather
skipping over the fact that the
scheme could become very
expensive if lots of people take
up electric. Surprised no
mention of costs.
Coach access is restricted by strict LEZ
controls. Any such vehicles not capable of
meeting the LEZ emission standards has to
pay an exceptionally high daily charge to
enter the Zone (c.£1,000 a day for HGVs)
which is so prohibitive that a very high level
of conformity with the standard is achieved.
No Idling campaign focused with coaches
primary target, see para’ 6.8, objective 7,
and actions TRAN 13 and TRAN 14.
Last sentence of paragraph explains that
any measure to improve air quality or reduce
exposure will be commensurately delivered
in balance with other various public highway
matters. Any plans to implement initiatives
aimed to improve AQ in emerging BID areas
will be subject to internal and external
stakeholder consultation.
Free electric vehicle charging is presently
offered to stimulate uptake and use of
electric vehicles. Costs of scheme to
Council (electricity and other) are currently
covered by sponsorship agreement with
EDF and scheme membership fees. With
these costs covered it allows the Council
time to develop a longer term strategy for EV
charging incentives. The scheme is always
subject to review.
ID Councillor
Cllr Heather
Acton
(continued)
Specific points/comments
Response
p48, paragraph 6.6.1 and Action
TRAN 6; not include
businesses?; should this not
include businesses? Vans are
mentioned and they are very
guilty parties in this regard.
Included business into paragraph
6.6.1 and Action TRAN 6; this
measure shouldn’t be solely to
residents but businesses also.
Dissemination of information
regarding efficient driving training
for businesses is to be conducted
as part of the business
engagement project (Action
COMM 7).
P50, paragraph 6.6.11; does the
figure of 88 schools include
private schools?
Yes, 88, includes private
schools. The Transportation
Department is responsible for
their implementation and with the
Does 88 include private schools? employment of a new
There has been one case of a
Commissioning Officer Road
private school getting planning
Safety Education with
permission subject to requiring its responsibility for school travel
parents NOT to use cars to drop
plans they will be reviewed and
off and collect their children. This updated in 2013. Initiatives to
is monitored by residents. In
improve understanding of air
another case (state school
quality - and what school children
primary) officers have liaised with can do to reduce exposure to,
parents on the travel plan and
and improve air quality - are
looked at improved crossings as
embedded within STPs.
well as more bike racks - perhaps
this sort of initiative could be
mentioned.
P67, Action DEV 1 and DEV 2.
Include comments on
encouraging greening?
Despite the comments in 7.2.7,
can we not put in some
encouragement for greening, and
resistance to loss of gardens
A number of draft planning
policies with respect to this point
have been included into the
existing Core Strategy and the
emerging City Management Plan.
It is for planning committee to
decide these policies/actions.
(mentioned as important for
ecosystem in 10.2)
ID Councillor
2
Cllr Heather
Acton
(Email of 31
August 2012
13:02)
(Comments
regarding
Cabinet
Report)
Specific points/comments
Response
Paragraph 1.4:
Amended.
First sentence does not make
sense - think there is a redundant
"is"
Para’ 1.5:
third line "having been"
Para’ 4.3:
include "working with schools to
produce School Travel Plans"
somewhere in the bullet points?
and maybe "encouraging
residential development to
provide car club
membership rather than car
ownership"?
Amended
Para’ 5.22:
See points above re Addison Lee
- may want to mention private
company initiatives re idling and
empty running
(also I thought that we had put
some no idling signs on taxi
stands and this does not seem to
be mentioned)
Para’ 5.31:
do you want to mention the
potential costs of electricity
provision as well as capital costs
should there be a boom in
electric car use?
See response No 1
Noted. Sentence included;
‘Working with schools to produce
tailored School Travel Plans to
help increase the understanding of
and implications of air quality on
health, and to increase sustainable
transport options (walking,
cycling).’
See response No 1
See response No 1
Para’ 5.41:
see my points above about
strengthening the Action DEV 1,
2
Para’ 5.44:
See response No 1
position statement on Oxford
Street - I think we need to be
careful we are not unknowingly
moving towards pedestrianisation
8.6/8.7:
See Response No.3.
I would query whether the report
meets all the desires mentioned
by the P&SC - eg bullet point one
more direct action, point two capitalising on the LEZ, point four
"greening on new developments",
bullet point five, only partial
incorporation - this could be
strengthened for actions across
the Council, bullet point seven not sure if road crossings have
been incorporated? - maybe met
by traffic light discussion and TfL
lobbying?
ID Councillor
Specific points/comments
Response
2
Questioned/assumed that the
AQAP will be passed to Matthew
Pencharz at GLA for comments?
The GLA were included in
consultation of the draft AQAP.
Comments received were noted
and responded to within
consultation responses of May
2012. Once AQAP is approved
by cabinet a copy will be sent to
Matthew Pencharz at GLA for his
information.
Paragraph 1.4:
Amended.
Cllr Edward
Argar
(September
2012)
Typo’s in line 1
Paragraph 5.2:
But also additional cost to
business?
Paragraph 5.28:
We should also consider an
action around TfL/ traffic light
phasing to reduce stop-start.
Any plans to implement a new
inner-London Low Emission Zone
will be subject to extensive
stakeholder consultation involving
all London Local Authorities, the
GLA and other relevant bodies.
The Cabinet Member for Public
Health and Premises has taken
note of this comment and will
include it in further discussion
with TfL.
See also Response No. 3.
Paragraph 5.46:
(and this is also actually a
general point that should
underpin our overall approach)
broadly ok, but we need to
remain cogniscent of the costs to
trade/ businesses, and indeed
private individuals, and the need
Any plans to implement
regulatory controls which could
have financial implications for
businesses and residents will be
subject to extensive stakeholder
consultation.
to avoid further regulation at this
tough economic time, which
impose additional costs without
that cost being met by grants etc
- while tackling air quality may
involve additional costs, I would
be very reluctant to see any
such additional costs simply
imposed on/ transferred to hardpressed businesses at this time
without relief/ transition funding.
3
Cllr Heather
Acton
Email of
20/12/12,
regarding
clarification
of points
given in
email).
Perhaps 6.39 could include the
phrase "and has agreed with TfL
a priority list of traffic light
junctions where light removal
could be trialed"
The content is correct in principle;
complications in traffic light
removal have been encountered
by the Council and TfL. The
measure has not been stopped
due to this however and many
sites are still under assessment.
Other similar traffic light/public
crossing measures such as the
pedestrian ‘count-down’
crossings are planned for further
implementation.
I think 7.2.8 is too negative.
Whilst there may be uncertainty
about the effect of trees on
dispersion, and the chemical
reaction may be complex, I
thought there was clear proof that
they are absorbent of most
pollutants. The final sentence is
more positive, but it does not
follow the introductory sentence
very well! Furthermore, green
walls are thought to have been
effective and are being monitored
at the moment - could a sentence
be included to at least mention
the potential contribution of green
Amended to include statement
that WCC will implement effective
policy based on latest research
and information on green
infrastructure. Reference made
to Edgware Road tube station
green wall and the monitoring
being completed by Imperial
College London which could help
inform policy direction.
walls (and green roofs) and say
that WCC will keep itself
appraised of the latest research
on these matters. Our planning
committees do need clear
guidance to encourage the
incorporation of greening within
new developments (and a
reduction of mechanical
ventilation).
On bullet point five (of cabinet
member report) , could the report
suggest that there is a twice
yearly assessment of whether all
departments in WCC are
considering the impact of
operations on air pollution, so as
to increase general awareness?
Partial incorporation is in place
for some departments to consider
their operational impacts on air
quality (e.g., see Section 6.7 of
AQAP; fleet services operate
within a contract whereby all
service vehicles have to comply
with set emissions limits). A
desk-top analysis of suggested
bi-annual internal department
assessment on the integration of
air quality will be required prior to
including a statement and
commitment on this matter into
the AQAP. Further internal
department incorporation will
need to be initially assessed for
feasibility.
What actual suggestions are
made in the report about direct
action and capitalising on the
LEZ?
Direct action and capitalisation on
the LEZ is described in Section
6.2 under ‘London Low Emission
Zone’, and also noted within
paragraphs 4.7.2 and 6.1.2.
Specific actions that the Council
undertake to capitalise on the
LEZ are given in transport-related
Actions of the AQAP. These
actions complement the LEZ and
encourage cleaner, more
sustainable transport options.
Can our traffic wardens be give
specific instruction on engine
idling? They do not take action.
Parking Services are exploring
the feasibility of enforcement
using Penalty Charge Notice
(PCN) Codes issued by London
Councils but parking services
concluded that enforcement
mechanisms were unfeasible.
Assessment of feasibility of future
enforcement schemes will be
continued.