Low Emission Strategy Consultation

The following comments have been gathered for the consultation on the Scottish Low Emissions Strategy available at: http://www.gov.scot/Publications/2015/01/3287

Q1 Do you think the Mission, Vision and Objectives for the Low Emission Strategy are appropriate? If not, what changes would you suggest?

The proposed vision in the consultation document needs to be amended to reflect the scientific evidence on the impact of health by being more specific and stating the time when the vision will be realised.The current form of the vision determines success by comparison with the rest of Europe. However, this does not reflect the scientific evidence that clearly shows that it is levels of and time of exposure to harmful emissions that affect health.Therefore the vision needs to based on absolute levels of emissions that will be allowed.  

It is strongly suggest that the strategy  commits to never having emissions above the harmful limits as prescribed by the World Health Organisation.

The vision also needs to state when it will be realised.  Given the developments made elsewhere such as London, we suggest that our proposed vision can be realised by 2020.

The proposed objectives place empowerment under the theme of communication.   However, empowerment across all levels of society will be a important instrument in itself to deliver the Low Emission Strategy.  Therefore it is vital that this consider as a separate objective.

Q2 Do you think the proposed actions will deliver the Mission, Vision and Objectives? If not, what changes to the actions would you suggest? Are additional actions required? If so, please suggest what these might be.

The proposed actions are based on tackling the sources of harmful emissions and not the actual causes of them.   Without tackling the causes, this will render the proposed actions impotent. 

It is clear buses are a significant cause of harmful emissions in urban areas. However, the proposal for issuing grants to Bus operators to obtain low-emission vehicles ignores the wider economic and regulatory drivers which mean operators choose not to apply from the grant.  For example, in Glasgow, no bus operator has chosen to apply for the grants available.

Due to deregulation, buses operators adopt a short-term view to routes and their fleet.   While grants can help to sway an operator’s decision to adopt low emissions, often the grant has to be much more than the simple difference in cost of a standard and low-emission vehicles as operator seeks to achieve the pay-off in a much shorter time period.  It is evident the power to regulate and mandatory standards is much more effective.  For example, the policy of mandatory standards has been successful in Glasgow, where low emission vehicles have been adopted on routes designated as Quality Bus Corridors.

A number of proposals rely on the local authorities to implement, monitor and enforce the Strategy.   The way forward document does not mention what and how additional resources, particularly know-how, will be provided to local authorities to ensure they can deliver their duties effectively. Behavioural change will be key, yet the Strategy relies on communication campaigns; which have been shown to of little value except for immediate life-threatening issues.  There are no proposals on how to ‘nudge’ people to using their cars more appropriately and ultimately less often and use cleaner forms of transport, for example ensure offices in city centres have adequate levels of provision of cycling parking and changing facilities. There has to be acknowledgement of the cumulative effect of breaches. Reference is needed to importance of not just planning policy but also, building control.  There is a need for enforcement action on building standards. 

Q3 Does the Setting the Scene section accurately summarise the current policy situation? Please suggest changes if not.

Setting the Scene document section has a number of significant omissions and is based on a very simple narrative of cause of emissions.  The section ignores many historical, economic and cultural drivers that are root cause of high levels of harmful emissions especially in city centres. The section places significant importance of the Scottish Planning Policy lever to deliver the Low Emissions Strategy.   However, the SPP can only influence future developments.  Since 90%+ of stock of developments are already in place, the SPP can only influence a minority of the total stock development by 2020.

In Glasgow, the deliberate policy of moving a significant population from the city to the surrounding new towns, caused an immediate increase in the use of cars and buses for commuting and journeys back and forth the City.  Inadequate improvement was made in the quality and capacity of train services to make them an attractive alternative to cars.  Cars became the main way to travel in them, even for very short distances. The scene setting also fails to highlight powerful economic drivers such as bus deregulation that mean private bus operators have very short time horizons, as they only have to give 56 days notice to alter or cancel a route, which mean they have to offered very large subsidies to switch to cleaner vehicles.  Also, it fails to mention that the current taxation regime positively discriminates diesel domestic cars, a big source of the harmful emissions in urban environments.

The section also fails to mention the powerful social drivers but result in the  overuse of cars.   

For example, the stigma of bus travel plus the ability of cars users to able to display social status (http://www.researchgate.net/post/Can_social_stigma_negatively_affect_the_choice_of_public_transportation) fuel the increasing trend in the use of cars, even when entirely unnecessary in a city with plenty of public travel provision.Without addressing these historical, economic and social drivers, the Strategy will make the same mistakes as previous initiatives and fail to make a significant impact on reducing harmful emissions.

Q4 Does the Way Forward section give a reasonable outline of what further action is needed to deliver an effective Low Emission Strategy? Please suggest changes if not.

The ways forward section effectively proposes to only modestly ramp-up policies and measures which have had a small impact so far.  We propose more innovative and holistic thinking is required to have a big reduction in the emission of harmful emissions and to give a clean, safe environment to all in Scotland.The strategy relies heavily on the local authorities to implement, monitor and enforce the Strategy.   The way forward document does not mention what and how additional resources, particularly know-how, will be provided to local authorities to ensure they can deliver their duties effectively. The way forwards outline for transport are very reliant on operators of high-emissions switching to low-emission vehicles.  As outlined in the previous sections, the current proposals will be ineffective especially for buses given the economic and social drivers that currently in place.  There are plenty of innovative solutions already in place elsewhere that can implemented in Scotland to reduce the emissions of harmful emission.  For example, proposed levels of freight traffic in areas that suffer from high levels of emissions can be lowered by operating a consolidation freight delivery scheme as the ones operating in Bristol and Bath (http://postandparcel.info/58122/news/innovation/dhl-boosts-retail-delivery-efficiency-in-bristol-and-bath/).   Such a scheme means businesses can continue to operate and thrive in city centre locations while reducing emissions by minimising the number of partially-filled freight vehicles clogging up congested roads.  This should be in addition to re-introducing bus regulation, so that local authorities can control the number of buses especially in high emission areas.

Planning consideration could take note of English Code for Sustainable Homes requirement for all new residential developments to include  provision for a home work-space. Building Control could set energy targets for conversions and major renovations, moving beyond current principle of 'betterment'. Building Control energy section could take note of Code for Sustainable Homes targets to reduce / monitor site traffic, waste and travel distances of materials to site. Planning should seek to reduce insistence upon 100 - 150% parking provision to new developments to encourage and support use of public transport infrastructure. Planning to ensure that large / major scale master plans allow for community facilities and amenity provision to reduce necessity for car journeys.

Funding for electric buses could be developed, extending two buses operating to/from city centre and Riverside Museum, with support from Glasgow City Council.   Cycling initiatives could be developed eg. segregated cycle routes, cycle to work schemes, more showers in office buildings as part of Breaam excellence building standards. Budgets for local authorities need to provide 8-9% of overall funds to cycling and walking annually as has been achieved in Edinburgh, Clackmannanshire. Cycle hire projects could be rolled out, with electric bikes made available.

Q5 What are your views on the proposals for the National Modelling Framework?

The air quality model only concentrates on urban areas which is fair enough for small to medium-sized developments in those areas but it does not appear to demonstrate what the cumulative effects of developments will be on rural areas outside the modelled areas. 

Granted the most severe concentrations of pollution will be in those areas, but the issue is raised in the introduction to the consultation.

Q6 What are your views on the proposals for the National Low Emission Zone Framework?

As Strategy shows, Low Emission Zone Frameworks are not new and well tested models already exist.  Although we need to ensure suitability for Scotland, valuable time and resources should not be spent on re-inventing the wheel.   If we acted now, a Low Emission Zone Framework should be in place by start of the next Parliament.   The framework is fair enough as applied to vehicles, but it does not address emissions from buildings or mitigation of emissions by road planning and traffic flow optimisation. A large amount of the consultation document addresses the need to include emissions in the planning process, but the implementation of the framework appears to only be regulation of vehicles.

Q7 What are your views on the proposed Key Performance Indicators? Are any different or additional Indicators required?

The KPIs as set are good and we would not change them.  We would add possible indicators of economic impact, e.g. footfall in shopping districts and turnover of businesses in the LEZ.  It could also add another health indicator, regarding illnesses and time off work attributable to particulate air pollution.