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ULEZ

The case in support of the Ultra Low Emission Zone

A contribution by @tonyofsidcup

8 January - Thinking about ULEZ, Part 1 - Men of Honour

When Bonkers started in 2009 it tried to present the facts and where appropriate both sides of the argument and leave readers to draw their own conclusions. Bexley Council was then at the height of its dishonest phase and there wasn’t really any need to point out the obvious with opinions. Over the intervening years BiB’s original tagline of Dishonest, Incompetent, Vindictive; stolen from The News Shopper, has become less appropriate than it used to be.

One subject upon which Bonkers has not been fence fitting is Sadiq Khan. Councillor John Davey (Independent, West Heath) once said that Khan was doing more damage to our capital city than the Luftwaffe in 1940. In the sense that London was able to recover from the Blitz but is unlikely to survive the Khanage of the past few years, the former Conservative Councillor was right.

Roy Castle Roy CastleHowever there is a minority view (the disregarded ULEZ consultation confirms it) that Khan is some sort of Super Hero for his blinkered attack on the city’s economy which ignores various reports that he will do almost nothing for air pollution. The reductions have come and will continue to come naturally. There was a 94% reduction in pollution between 2016 and 2020 (Imperial College figures) as older vehicles are replaced.

Because I am interested in how contrary views are justified the first of a multi-part analysis by @tonyofsidcup is published below. It is unedited although I personally feel some discomfort at the way the premature death of James Brokenshire from lung cancer has been used as supporting material.

His loss cannot sensibly be used to justify ULEZ in the way that smoking was restricted following the death of entertainer Roy Castle whose demise was blamed on performing in smoky environments. Polluting vehicles will be gone within a very few years with or without Khanage. Smoking is still killing people 29 years after non-smoker Castle died from lung cancer.

Note: Photos above from my own collection.


The premature death, from lung cancer, of the Old Bexley and Sidcup MP James Brokenshire shocked his friends and acquaintances among Bexley Conservatives. So it came as no surprise that when in 2022 London’s mayor Sadiq Khan proposed to expand the capital’s Ultra Low Emission Zone to include Bexley, the local party rallied behind the plan. “I welcome the mayor’s efforts to clean up London’s air”, Brokenshire’s successor Louie French stated, “We simply cannot tolerate avoidable deaths from respiratory disease”. Sidcup Ward councillor Richard Diment reminded his colleagues that a 2021 study by Imperial College London named his ward London’s worst-affected by air pollution in terms of lives lost. “As the Cabinet Member for Education, I regularly meet with the borough’s parents. I simply could not look them in the eye if I failed to support ULEZ”, he said.

Falconwood and Welling councillor Frazer Brooks agreed: “Living next to A2, my constituents suffer from the borough’s highest levels of NO2 pollution, and it would be unthinkable for me to oppose ULEZ expansion”. Councillor Smith of St Mary’s and St James Ward mentioned his post as the communications director of the national Conservative Environment Network, and said: “We may disagree with the mayor on many things, but protecting Londoners’ health is our common priority. Yes, times are tough and everyone is feeling the pinch, but you cannot tell an asthmatic child “Sorry, it was too expensive to give you clean air”.

“For me, it is a matter of Conservative principles”, Council Leader Teresa O’Neill remarked, “A true Conservative is serious about personal responsibility. If your vehicle pollutes the air that other people breathe, you accept your duty and pick up the bill. I would do this readily”. Councillor O’Neill recalled that back in 2007, the council declared the borough an Air Quality Management Area, citing high levels of nitrogen-dioxide and particulate-matter pollution. “Air quality has been Bexley Conservatives’ priority since day 1”, she said, “Every year, the Cabinet debates the annual Air Quality Action Plan, and we always ask: What more can we do to make our air cleaner?”

Ok, let’s snap out of this daydream. All of the quotes above are made up. Without exception, Bexley Tories have toed the party line and opposed ULEZ expansion, not once acknowledging Bexley residents living with respiratory disease. (Clearly, Brokenshire was an exception). The “green” Councillor Smith read out an anti-ULEZ statement in the council chamber. After Mayor Khan announced, in November 2022, that ULEZ expansion was going ahead, Bexley joined Tory-run Outer London boroughs of Croydon, Harrow and Hillingdon in opposition. In her statement, Teresa O’Neill insisted that the “decisive” victory of Bexley Conservatives in the May 2022 local election - Tories’ 51% of votes vs. Labour’s 44% - gave the council the mandate to oppose ULEZ.

(In the following month, the “rebel alliance” indicated that it was going to block TfL’s installation of ULEZ camera equipment on borough-managed roads. One wonders if, defying TfL, the councils would be able to keep the money they receive from TfL. Each year, Bexley receives hundreds of thousands of pounds from the City Hall, to fund things from bridge repair to the salaries of lollipop people. In 2020, in a Covid-related development, TfL funding went away, for six months. So did the lollipops, as Bexley failed to pony up).

Pollution map AQMAA late-2022 Freedom of Information request for Bexley’s latest Air Quality Action Plan was met, incredibly, with “We don’t have one yet”. Why “incredibly”? The Bexley Air Quality Management Area has been in place for 15 years, and devising and maintaining an AQAP is, to all appearances, a legal requirement. One can only wonder if Bexley is breaking the law (and Defra doesn’t care), or if the senior officer who responded to the FOI did not have a clue. Either way, it tells you something about the council’s - and its Conservative leadership’s - attention to air quality. Asking these people to react to the ICL study that put Sidcup, Bexleyheath, Crook Log and Blackfen and Lamorbey in the top 20 of London’s wards most affected by air pollution seems to be a pointless exercise.

As confirmed by another FOI request, Bexley did not carry out a formal analysis of the impact of ULEZ expansion before publishing anti-ULEZ articles in The Bexley Magazine, and did not even ask TfL how many Bexley-registered vehicles would be caught out by ULEZ. (I did - and was shocked to find that just over half of Bexley vans were non-compliant).

Fluke Fluke FlukeTwo Sidcup residents and stars of the Bexley Conservative scene, Louie French MP and Gareth Bacon MP, made YouTube speeches against ULEZ expansion, and ran HQ-supplied anti-ULEZ petitions on their HQ-supplied web sites. Louie never answered an email question about a claim in one of his anti-ULEZ videos. In fairness, he never answered any question I have emailed him - while a made-up “Fluke Kelso” received a prompt response to his adoring email. Our MP appears to operate a “black list” of undeserving constituents. If I weren’t on it, I could ask Louie about AQAP - after all, as Bexley’s Cabinet Member for Growth, he was likely responsible for it before moving to Westminster.

Most of the anti-ULEZ noise has appeared to originate with the Conservative members of the London Assembly. There is a Russian expression about someone “getting fired from the Gestapo for cruelty”; adapting this saying to British realities, I could say that most Tory Assembly members could be fired from Boris Johnson’s cabinet for lying. The small group spent months inflating what they called #ULEZScandal, based on a set of falsehoods which spread across the Tory anti-ULEZ discourse. In the next post, let’s look at some of these lies.

ULEZ compliance Pollution levels Pollution levels

55% of light commercial vehicles registered in Bexley are not ULEZ compliant.
Seven years ago pollution levels on Bexley were not especially good.


I promised myself that I would avoid further comment so will confine myself to saying that Louie French should seriously consider firing his office assistant.

 

25 January - Thinking about ULEZ, Part 2 - Soldier of Fortune

Green and pleasant landBelow is the long awaited Part 2 of @tonyofsidcup’s continued defence of the imposition of the ULEZ Tax on our green and pleasant outer London boroughs.


Two things have happened in the ULEZ Universe since the previous post.

First, the Tory-controlled Harrow council and the LibDem Sutton announced that they formally declined TfL’s request to facilitate installation of ULEZ cameras on borough-managed roads.
Leader's comment Evening StandardBexley promptly joined the group. “We have withheld permission for the Mayor to put his ULEZ cameras on our street furniture or work on our roads”, Teresa O’Neill wrote on January 23.

On the same day, however, an Evening Standard article suggested that TfL did not need councils’ permission to install cameras alongside existing TfL equipment, the case for two thirds of all planned sites, according to TfL.

Meanwhile, TfL reminded the boroughs that it was their legal responsibility to comply with the mayor’s Transport Strategy, now including the expanded ULEZ. (Ever polite, TfL did not say that it was “local implementation” of that Strategy by London boroughs that got them TfL funding). The independents of Havering, though unhappy with ULEZ, accepted the point and promised their co-operation; the Conservatives of Hillingdon, Croydon and Bromley stayed put, muttering about blocking cameras and suing the City Hall, but not doing anything visible.

In a second ULEZ-related development, that unique group of people who make Bexley Conservatives look competent and honest, the Conservatives of the London Assembly, had a second go at inflating #UlezScandal. Recall that in September 2022, The Torygraph reported allegations of anti-ULEZ responses being excluded from the results of the Mayor’s consultation.


Daily TelegraphBy January 2023, the GLA Tories, led by “our own” Peter Fortune, the Assembly Member for Bexley and Bromley, used FOI to obtain a 200-page trove of City Hall emails related to the consultation. They used it to construct a story of Sadiq Khan anxiously watching the percentage of anti-ULEZ consultation responses (all the while feigning ignorance of it), seeing the public opinion go against him, trying to turn the tide by boosting participation of pro-ULEZ groups, and in the end manipulating the percentage by removing a chunk of anti-ULEZ responses on a flimsy pretext. This is essentially the description provided by Peter Fortune himself at the end of his 32 minute questioning of Sadiq Khan at Mayor’s Question Time, available on YouTube. I don’t buy it.

It helps to remember that the consultation was run by TfL, but the responses were analysed by an outside consultancy, AECOM. When Fortune insinuates that Sadiq Khan threw away anti-ULEZ responses, one can simply counter that neither the City Hall nor TfL handled the process, and no “smoking gun” email from a Khan henchperson to AECOM, directing them to take a particular approach, has ever been produced. AECOM made their own decisions - as they were supposed to, since avoiding perceptions of bias was the reason for TfL not doing the work in-house in the first place.

It also helps to remember the consultation’s timeline. The public was consulted for ten weeks, from May 20 until July 29. When Fortune alleges that Khan was aware of intermediate results in August or September - but refused to admit it - one answers “So what? The consultation was closed by then, and Khan could not have influenced it”.

What about the July publicity push for youth participation, Khan’s alleged manipulation? I accept the Mayor’s explanation that the youth outreach was appropriate, and see no evidence of it being either special - an AECOM report referenced later gives a long list of ULEZ-consultation publicity campaigns - or a panicked response to the public’s rejection of ULEZ, as insinuated by Fortune. (Fortune’s implicit admission that young people support ULEZ might sound awkward for him, but hey, we already knew the Conservatives favour a different demographic).

Khan’s explanation for why he did not disclose seeing the intermediate analysis results was that only the final report, presented to him on November 18, was “results”. A sensible answer or evasive word games? I would cry foul if “intermediate results” were explicitly queried, but if Fortune et al. had just asked for “results”, I am ready to give Khan a pass. Fortune may be right, he just does not lay out enough evidence to prove his claim - and lacks the credibility to be trusted without it.

What about those discarded anti-ULEZ responses, the stuff of the original #UlezScandal? Let’s understand what it’s about. Imagine that you run an online survey. You build an online form with, say, twenty questions, including questions about respondents’ backgrounds, and ask people to fill it out. You also allow people to email you - and end up with a bunch of emails that skip all the questions, including the demographic ones, and answer just one. Now, you need to summarize the responses to your survey. The “proper” survey responses are “nice and clean” - but how do you handle those emails?
Consultation
A reasonable approach is to use the information in them where possible: count the emails with regard to the question they answered, and ignore them on the questions they themselves ignored. Now, you need to tell people how many responses you received for each question, and what the split was. Easy for all but that one question, but what do you do there? To be safe, just give the reader the full information: tell them how many survey responses and emails you received, and what the split is if you exclude or include the emails.

… and this is exactly what AECOM did. You can see the details in Section 4.13 of the clunkily-named but extremely interesting “Report to Mayor on ULEZ expansion and future Road User Charging proposal”. Note that the percentage of responses choosing “ULEZ should not be implemented” is *higher* (68% vs. 59%) when those “organised responses” are excluded. That’s some “manipulation”! In my opinion, only people devoid of any integrity could look at this and allege wrongdoing. Have I mentioned that GLA Conservatives make Bexley Conservatives look good?

“Well, 59% or 68%, no matter - clearly, majority of Londoners oppose ULEZ, and that’s why Khan ought to cancel ULEZ!” No, and no. This is actually the key point in the whole ULEZ consultation business, and one that Fortune and Friends try hardest to avoid. Let’s hit it on the head in the next post.
Consultation

AECOM Report.

P.S. One more thing. Section 4.3 of AECOMs report mentions five petitions (not to be confused with organised email campaigns) submitted to TfL. Not one, but two of them come from Bexley! The first one, with 245 signatures, appears to be by Bexley Tories. However, there is a second petition, with just 36 names, saying simply: “Objection to the Mayor of London’s proposal to extend the Ultra Low Emission Zone London-wide. We support Bexley Council!” Good for you, folks.
Petition
Links
Councils refuse camera installation
https://www.mylondon.news/news/east-london-news/ulez-full-list-london-councils-26018487
Evening Standard: no council permission needed
https://www.standard.co.uk/news/london/ulez-expansion-council-challenge-cctv-cameras-sadiq-khan-tfl-powers-b1054878.html
Statement by Bexley
https://twitter.com/LBofBexley/status/1617482534530564097
Peter Fortune’s GLA profile
https://www.london.gov.uk/who-we-are/what-london-assembly-does/london-assembly-members/peter-fortune
GLA Conservatives’ YouTube video 1
https://twitter.com/GLAConservative/status/1615319861088980993?s=20&t=Yl6xDA5WskOLnKB61uwgYQ
(Note the email shown at 1:17)
GLA Conservatives’ YouTube video 2 (Fortune vs Khan)
https://www.youtube.com/watch?v=iSkSuukO6SU
#UlezScandal 1.0
https://www.telegraph.co.uk/business/2022/09/30/leak-reveals-two-thirds-londoners-oppose-expansion-ultra-low/
AECOM “Report to Mayor on ULEZ expansion and future Road User Charging proposal”
https://haveyoursay.tfl.gov.uk/15619/widgets/58629/documents/34558


More to come.

 

7 February - Thinking about ULEZ, Part 3 - People Will Talk

Another guest post from @tonyofsidcup.


The last paragraph of my previous post said:

“Well, 59% or 68%, no matter - clearly, majority of Londoners oppose ULEZ, and that’s why Khan ought to cancel ULEZ!” No, and no. This is actually the key point in the whole ULEZ consultation business, and one that Fortune and Friends try hardest to avoid. Let’s hit it on the head in the next post.

This is the next post, and this is the big, two-pronged lie: the average Londoner opposes ULEZ, and Sadiq Khan improperly overruled the public opinion to push through his unpopular policy. In reality, the average Londoner favours ULEZ - the average Inner Londoner, already within ULEZ so unaffected by the expansion, favours it, while the average Outer Londoner gives you a different answer depending on how you ask - so Mayor Khan is going with the public opinion, not against it.

If you watch on YouTube the exchange between Sadiq Khan and Peter Fortune at Mayor’s Question Time (see Links below), you will hear the mayor repeatedly say: “A consultation is not a referendum”. To me, it means three things.

First, it is about the decision-maker. With a referendum, the voters decide: before votes are cast, people agree that the choice with the most votes will be implemented. With a consultation, it is the body that sponsors the consultation that makes the call. There is no commitment to go with the most popular choice.

Second, it is about the purpose. A referendum aims to reveal the most popular choice and to produce a decision. A consultation aims to draw out the arguments “for” and “against” and to inform a decision. Recall those group emails, the subject of #TheUlezScandal version 1. 5,000 people saying “no” in a referendum is 5,000 votes. 5,000 people emailing identical text to consultation organisers is merely one set of arguments repeated 5,000 times. (If there are any arguments advanced at all).

Third, it is about representativeness. A typical referendum captures a large fraction of the voter population, and is accepted as representative. If, for example, Bexley Conservatives get 51% of the votes in the 2022 election - “decisive victory”, according to Teresa O’Neill - we accept that the share of voting-age Bexleyites favouring Tories is close to 51%. A typical consultation involves a much smaller fraction of eligible voters, and tends to attract people with strong views (enough motivation to complete a questionnaire), leaving out the crucial, broad middle. For this reason, “projecting” the consultation-produced percentages of “ayes” and “noes” on a particular yes-or-no question to the entire population is a terrible idea. You want to gauge whole-population “for” and “against” percentages, but a consultation gives you those for “strongly for” and “strongly against”. The two sets are completely different, and may point in opposite directions.

(Statisticians talk about “self-selected” surveys, and “self-selection bias”. The self-selection bias is distinct from the normal statistical uncertainty, when you estimate “population” quantities based on a sample. The latter is less of a problem: the wonder of statistics is exactly that you *can* reliably extrapolate from a sample. The catch is that your sample needs to be representative, or “unbiased”. A “good” sample of 1,000 people will let you make decent predictions about a population of millions. A “bad” sample with 100,000 people will be worthless).

With this in mind, let’s have a look at the ULEZ consultation. First, Mayor Khan never promised to follow the majority opinion. One can accuse Khan of not making “Do you support ULEZ or not?” the consultation’s question 1, but maybe that’s a difference between a single-question referendum and a many-questions consultation. A respondent could express their rejection of ULEZ in Question 13 - “We are proposing to expand the ULEZ London-wide on 29 August 2023. What do you think of the implementation date?” - by choosing “Should not be implemented”. Discussion of feedback received through the consultation is presented in AECOM’s report to the mayor and runs to dozens of pages, with a number of specific ULEZ plan changes linked to that feedback. To claim that the City Hall dismissed the consultation input would be disingenuous.

Finally, the question of how representative the consultation sample was of London’s population - and just to clarify, a fair proportion of responses came from outside London - can be answered with a single chart from that report, showing that 42% of respondents were owners of non-compliant cars from Outer London.
Status Types
Figuring out this group’s share in London’s population is tricky, but it is abundantly clear that it is not close to 40% - my guess, based on Bexley data, would be 10-15%. (Note the distinction between individuals and households, and remember the households without cars). It is accurate to say that 68% of ULEZ consultation respondents opposed ULEZ. It is, however, grossly misleading to say - as GLA Conservatives did - that 68% of Londoners voted against ULEZ.


Types To gauge the average Londoner’s stance on ULEZ, you need proper surveys. Only two have been done, both by YouGov, the market-leading polling agency established by the former chancellor of ill repute Nadhim Zahawi.

The first survey was commissioned by the GLA (i.e. the City Hall, or Khan if you like), ran in July, and repeated the consultation’s Question 13:
We are proposing to expand the ULEZ London-wide on 29 August 2023. What do you think of the implementation date?


● It should be implemented, but at an earlier date
● It should be implemented at the proposed date
● It should be implemented, but at a later date
● It should not be implemented
● Don’t know


The second survey, done in November, was commissioned by GLA Conservatives and had this text: To generate additional revenue for Transport for London, the Mayor of London is proposing to expand the Ultra-Low Emission Zone (ULEZ) to a wider area than it currently is. This means non-compliant vehicles have to pay a £12.50 daily charge for driving within Greater London. Do you think the Ultra-Low Emission Zone (ULEZ) should or should not be expanded?


● It should be expanded
● It should not be expanded
● Don’t know


The Tory-commissioned survey employs a “leading question”, suggesting a specific motivation for ULEZ expansion: “to generate revenue”. This is not an honest polling practice, but it is a very effective one, which is why it is used.

 SurveyThe two polls have produced very different results. In the Tory poll, 51% oppose ULEZ (“Decisive victory!”, says Teresa O’Neill), and 34% support it. In the GLA poll, 51% of Londoners support ULEZ (“Decisive victory!” says Teresa O’Neill again, looking a little confused), while 27% oppose it. In essence, you get opposite results. For Outer London only, the GLA poll has 46% “for” against 34% “against”; the Tory poll has 59% “against” and 29% “for”. The truth is somewhere in between.

Personally, I think that it is closer to the GLA numbers - because the Tory poll was so manipulatively worded, it should be “down-weighted” - but you may disagree and move the mark closer to the middle. I think we both will conclude that ULEZ is the winner in Inner London, and in Outer London the split is near 50/50.

So there you have it. GLA Tories’ allegations of #TheULEZScandal are worthless - a ”smokescreen”, as Sadiq Khan put it, a deception aimed at the vast majority of people with zero interest in learning the details. The percentage of anti-ULEZ responses to the consultation’s Question 13 was predictable in advance, and, because of this, irrelevant to the decision-maker, i.e. the mayor. Limited polling showed support for ULEZ in Inner London, and neutral or moderately anti-ULEZ sentiment (concentrated among older and less educated voters, already undisposed towards Khan) in Outer London. Under the circumstances, both an idealist and a cynic would advise the mayor to proceed with his plan, and so he did.

What would a scientist say, though? Never mind the prone-to-manipulation public opinion - is ULEZ expansion a good idea on public-health grounds? Before we tackle that million-dollar question, let’s devote the next, short post to a falsehood that has circulated within the anti-ULEZ discourse and was recently shared, on the pages of The Telegraph, by one of Sidcup’s finest minds, Gareth Bacon MP.


Links
A good article discussing ULEZ consultation and polls
https://bylinetimes.com/2023/01/23/driver-lobbyist-group-targeting-sadiq-khan-over-clean-air-plans-is-funded-by-road-haulage-industry/
AECOM “Report to Mayor on ULEZ expansion and future Road User Charging proposal” (analysis of consultation responses)
https://haveyoursay.tfl.gov.uk/15619/widgets/58629/documents/34558
ULEZ survey commissioned by GLA, July 2022
https://ehq-production-europe.s3.eu-west-1.amazonaws.com/1756f85d90ec076d413af3d3c7132d9f
ULEZ survey commissioned by GLA Conservatives, November 2022. (Summary only)
https://docs.cdn.yougov.com/n7yjacvt7e/GLAConsResults_221115_LondonULEZ_W.pdf

 

15 February - Thinking about ULEZ, Part 4 - A Beautiful Mind

Trabant 2 stroke engineN.B. There is a composite of all four (so far) of @tonyofsidcup’s ULEZ articles available here assembled into chronological order.

I have always believed in giving both sides of every story whenever possible which may explain why BiB has never been totally Labour or Conservative supporting. As my MP said to me once, “you a more a plague on all their houses sort of bloke” and she was right. Having said that I find it impossible to see any merit in Sadiq Khan’s plan to extend the Ultra Low Emission Zone to the country lanes of Bromley and in some places beyond the M25. I know all politicians lie but the Mayor takes things to extremes, misquoting and cherry picking the Imperial College findings for example.

But a promise is a promise, here is the penultimate and unexpurgated episode of @tonyofsidcup’s eulogy to London’s worst ever Mayor and you can safely assume I agree with very little of it. I nevertheless found it interesting and learned some things I didn’t previously know. It is certainly a well researched piece from someone who may once have aspired to drive a Lada or a Trabant but he appears to totally ignore the fact that vehicle pollution pollution is rapidly disappearing anyway and the cameras can only be justified if the plan is London wide road pricing, something predicted on Bonkers a long tIme before it became mainstream thinking.


A faint memory of my past life as an American PhD student is attending lectures by three economics Nobel laureates. Even in the field of Nobelists, the three were genuine titans who transformed their fields and had a far-reaching impact on the world. Robert Merton was a founding father of quantitative finance, celebrated by academics and by Wall Street “quants” driving the world’s financial-derivatives industry. Robert Lucas was the world’s pre-eminent macroeconomist, who changed the way economists model the economy as a whole, and the way governments and central banks think about managing booms and recessions. Finally, John Nash made a crucial contribution to game theory - the science of repeated negotiation - and, even more impressively, was played by Russell Crowe in the 2001 Hollywood movie “A Beautiful Mind”. The film told the true story of a brilliant scientist struck in his prime by mental illness (schizophrenia), and overcoming it after a long, heart-breaking struggle.

Beautiful MindI thought of “A Beautiful Mind” when reading a Telegraph article penned by a fellow Sidcup resident, Mr Gareth Bacon, the Member of Parliament for Orpington. As some readers will know, before becoming an MP for a Bromley constituency in 2019, Mr Bacon had been a councillor for Sidcup’s Longlands Ward - not just a councillor, but a Bexley Cabinet Member and the Deputy Leader. I moved to Sidcup in 2017, and did not start paying attention to local politics until 2020 - there was a local issue, the local councillors (including Mrs Bacon!) seemed uninterested, I became frustrated but also curious about the Bexley council, and it snowballed from there - so Mr Bacon’s Bexley period passed me by. Now, I see occasional, favourable references to him on the Bonkers blog - for example, he is credited for Bexley’s recycling prowess. A Google search finds a 2015 Evening Standard article that names Mr Bacon “the capital’s highest paid councillor”, collecting £108,000 from four (!) public posts, including his roles at Bexley and the London Assembly, and being Mayor Boris Johnson’s (oh, the happy days!) appointed person on the London Fire Brigade.

(The link says “I am worth every penny”, says a £108,000-a-year politician”, but I don’t see that line in the text. Interestingly, the 2015 article is by Pippa Crerar, who became Britain’s most-talked-about journalist in 2021, when she ushered in Partygate with a report of a lockdown-breaking Christmas Party at Downing Street. For good measure, she also brought down GLA Conservatives’ Shaun Bailey, with a lockdown party of his own. Standing next to Bailey in an infamous photo was Bexley councillor Adam Wildman).


Shawn's party Gareth BaconAllowances ExpensesIt rubbed me up the wrong way when in 2021 Mr Bacon showed up in The Private Eye’s list of councillors who continued to claim their allowance after election to Parliament - note whose name comes before his! - while, according to Bexley Labour, failing to attend council meetings.

These days, I am not overly enthused about Mr Bacon spending £550 of taxpayer money every month on an assistant to watch his web site and social media. (Sadly, I was banned by said assistant on Twitter, after jokingly suggesting that Mr Bacon’s endorsement of Kemi Badenoch in the Conservatives leadership contest could be a hostage situation, given Mrs Bacon’s employment in Badenoch’s office). To be perfectly frank, I feel that Mr Bacon could show a little more restraint when reaching into the taxpayer’s pocket. At the same time, he strikes me as a highly intelligent man, quite distant from the Neanderthal wing of Conservative Party, represented by people like Jonathan Gullis. (Seen sitting next to Mr Bacon and our own Mr French - patriotically masked - on the image below). This is why what I read in The Telegraph was worrying.

Bacon and FrenchAs far as I know, there are now two Telegraph articles published by Mr Bacon, with the later one out just yesterday, on February 13. It was the earlier article from December 27, 2022 that caught my eye. It opened with this:

“Sadiq Khan’s latest plan to make it harder to drive should worry us all. It’s the worst assault on motorists we’ve ever seen. The London Mayor is determined to price working people off the roads and has ignored their overwhelming objections, giving them no choice, time or opportunity to avoid a ruinous bill. If Mr Khan gets away with this, any other city or regional mayor can impose reckless driving charges across the country. It must be stopped”.

Let’s look past the “overwhelming objections” bit, the false Tory claim addressed in the previous post. (It is true that lower-income respondents in the TfL ULEZ consultation were more opposed to ULEZ than higher-income ones, but consultation respondents were strikingly unrepresentative of London’s population in the first place. Mr Bacon is putting his words in the mouth of the average working-class Londoner). It is the next sentence that worries me. “If Mr Khan gets away with this, any other city or regional mayor can impose reckless driving charges across the country”.

What’s wrong with this proposition? Why would the ULEZ expansion open the floodgates? After all, it is an expansion of an existing ULEZ - a second expansion, even. Recall that efforts to “price working people off the roads”, as Mr Bacon puts it, have been made for a long time. The “congestion charge” was introduced, by Mayor Ken Livingstone, on February 17, 2003, almost exactly 20 years ago. In 2017, after a record air-pollution spike in January, Mayor Sadiq Khan enacted the “toxicity charge” in October. Finally, in 2019, the toxicity charge was replaced by ULEZ. (Wikipedia says that the plans were made by Mayor Boris Johnson, but I will let you verify the claim). Who was the leader of GLA Conservatives when T-charge and ULEZ were introduced? A certain Mr Gareth Bacon. By the time of ULEZ’s first extension, in 2021, he had vacated his leadership role, but remained an Assembly Member. Without a doubt, he played an active role in these developments. Does he not believe those changes to be “the worst assault on motorists we have ever seen”? Or does he simply not remember?

It is not just events before his move to Westminster that Mr Bacon seems to have forgotten. The Orpington MP appears to be unaware of high-profile, controversial policies pursued by his own party.

One can begin the story with the Environment Act of 1995, which committed the UK government to develop the Air Quality Strategy, last updated in 2007. (To recall the first post in this series, 2007 is when Bexley Air Quality Management Area was declared). In 2008, the European Parliament issued the Ambient Air Quality Directive, imposing binding air-quality limits on EU member states. UK, alongside some other countries, consistently breached the nitrogen-dioxide limit, in multiple areas including Greater London, and in 2014 the European Commission began “infringement procedures” against the UK government, with the case progressing to the European Court of Justice in 2018. In 2021, already after Brexit, the court found that the UK government had failed to fulfil its obligations.


EU EUBy that time, the government had a legal setback at home as well: in 2015, the Supreme Court told Whitehall to urgently develop a plan to achieve compliance with EU’s limits, which became part of the British law. Maybe this is why in the mid-2010’s, the UK government finally got serious about air pollution. In 2019, the Clean Air Strategy and the National Air Pollution Control Programme were published, and year 2021 saw the Environment Act, which set a number of quantitative targets in areas including air quality, with particular attention given to the particularly hazardous (pun intended, though the subject is genuinely grim: this is the stuff that causes cancers and heart attacks) particulate-matter pollution. The Office for Environmental Protection was set up - they are the people who will hopefully be asking Bexley about the missing-for-16-years Bexley Air Quality Action Plan!

Manchester NewsFinally, the Clean Air Zone framework was developed, allowing - indeed, requiring - councils with high levels of air pollution (mainly NOx, as it is mainly produced by cars and “stays local”, unlike PM, which comes from different sources and travels far and wide) to limit polluting car traffic. One can find online references to “charging” or “non-charging” Clean Air Zones, but the current CAZ legislation refers only to “charging” CAZs, where owners of particular vehicles are asked to pay for entering the zone. (A “non-charging”CAZ is when a council tries to clean up the air without asking drivers to pay). Within “charging” CAZes, there are different classes, depending on what types of vehicles are charged. Class D is the one where “regular” cars, i.e. not taxis, have to pay. Since 2021, a Class D zone covers much of Birmingham. Since 2022, a Class D zone applies in central Bristol. Class C zones, “forgiving” to non-taxis, exist in Newcastle, Sheffield, Bath and Bradford. Notably, in Bristol, the local council tried to “water down” the CAZ but was overruled by the government! The same thing is now happening in Manchester (led by Labour’s Andy Burnham) where the local council has pointed to the cost-of-living crisis and tried to reject a CAZ, replacing it with a “non-charging” zone. The government has pushed back, arguing that it wasn’t good enough! The Manchester CAZ did not go ahead for now, but it is definitely happening.

If the news from Manchester makes you think “If Manchester managed to postpone the CAZ, why can’t London postpone the ULEZ expansion?”, I am fine with that. I would like to draw your attention to a different takeaway. The UK government - for 13 years now led by the Conservatives - is at long last serious about air quality and is working to cut car emissions across the nation. London is leading the way, but is moving as part of a national trend, a national policy, guided by national targets, some of them distant (2050), some close (2040), some very close (2030). When Gareth Bacon MP tells you about Sadiq Khan waging a war on motorists, politely ask him “Are you forgetting something, Gareth?” and tell him about what you just read.

PS. And do watch “A Beautiful Mind”: Russell Crowe is Australia’s national treasure.


Links
“I can juggle four public posts, says £108,000 a year politician”
https://www.standard.co.uk/news/politics/i-m-worth-every-penny-says-ps108-000ayear-politician-10069317.html
Gareth Bacon’s Wikipedia profile
https://en.wikipedia.org/wiki/Gareth_Bacon
London Congestion Charge (Wikipedia)
https://en.wikipedia.org/wiki/London_congestion_charge
London Ultra Low Emission Zone (Wikipedia)
https://en.wikipedia.org/wiki/Ultra_Low_Emission_Zone
UK Air Quality Strategy for England, Scotland, Wales and Northern Ireland
https://www.gov.uk/government/publications/the-air-quality-strategy-for-england-scotland-wales-and-northern-ireland-volume-1
UK infringes on EU air-quality limits, 2014
https://ec.europa.eu/commission/presscorner/detail/en/IP_14_154
Supreme Court tells the UK Government to act on air pollution, 2015
https://www.theguardian.com/environment/2015/apr/29/supreme-court-orders-uk-to-draw-up-air-pollution-cleanup-plan
Clean Air Strategy
https://www.gov.uk/government/publications/clean-air-strategy-2019
UK National Air Pollution Control Programme
https://www.gov.uk/government/publications/air-quality-uk-national-air-pollution-control-programme
Clean Air Zone framework
https://www.gov.uk/government/publications/air-quality-clean-air-zone-framework-for-england/clean-air-zone-framework
Clean Air Zones in UK (Wikipedia)
https://en.wikipedia.org/wiki/Clean_Air_Zone
Manchester Clean Air Zone postponed
https://www.manchestereveningnews.co.uk/news/greater-manchester-news/clean-air-zone-charges-highly-26212421

 

1 March - Thinking about ULEZ, Part 5

No one can doubt the amount of work that has gone into @tonyofsidcup’s contribution to the ULEZ debate but I feel that it is a little short on democracy.

The extended ULEZ was not in Khan’s manifesto. He said he would be mindful of the consultation but he wasn’t, even if you overlook the disappearance of 5,000 probably dissenting voices.

The timing isn’t right. There is a cost of living crisis and car pollution levels are rapidly declining. It is a money grab and the expenditure can only be justified if it is the precursor to road charging which we now know it is.

It wouldn’t be fair to attempt to systematically destroy Tony’s input after offering him the opportunity to make his research more widely available but even if I accept everything he says it still comes across as something that might have been written by someone who was schooled in the U.S.S.R. rather than what used to be a Western democracy.

My own view can perhaps be most simply made clear by this photo montage.

All five of Tony's essays are available here.

Spray string Spray painted Cut down Sadiq Khan Shit Hole


Thinking about ULEZ, Part 5 - Gone Girl
Meet Geoff, an up-and-coming YouTuber who has found an enthusiastic audience - 34,700 subscribers and counting! - by recording videos against ULEZ, road charging, LTNs and all that woke nonsense. In his recent video, Geoff holds out an article by the Centre for London, “London’s independent think tank”, alluding to the dangers of air pollution. Geoff is not impressed. “As we well know from Sadiq Khan’s recent actions, he just makes the numbers up as he goes along”, says Geoff, “If he wants to think that 40,000 people have died from air pollution, then that’s what he says. But there is no evidence to back it up!” Geoff has evidence of his own, an official document which says, in black and white: “There was 1 death registered in London in the period 2001 to 2021 which had exposure to air pollution recorded on the death certificate”. Khan’s lie is spectacularly busted, and Geoff moves on.
Geoff Geoff
We shouldn’t. One thing we can do is put a face on the “one death” statistic. It is the face of a nine-year-old child, Ella Kissi-Debrah, who lived in Lewisham - five train stops from Sidcup - and died in 2013, after thirty hospital admissions, where her lungs would fill up with fluid and, on five occasions, collapse.


EllaIt took seven years and two inquests - not to mention incredible perseverance by Ella’s mother Rosamund - to officially establish the reason for Ella’s deterioration and death. The following paragraph comes from the coroner’s “Report to Prevent Future Deaths”:

“Ella died at the age of 9. She had severe, hypersecretory asthma causing episodes of respiratory and cardiac arrest and requiring frequent emergency hospital admissions. On 15 February 2013 she had a further asthmatic episode at home and was taken to hospital where she suffered a cardiac arrest from which she could not be resuscitated. Air pollution was a significant contributory factor to both the induction and exacerbations of her asthma. During the course of her illness between 2010 and 2013 she was exposed to levels of nitrogen dioxide and particulate matter in excess of World Health Organization Guidelines. The principal source of her exposure was traffic emissions. During this period there was a recognized failure to reduce the level of nitrogen dioxide to within the limits set by EU and domestic law which possibly contributed to her death”.

Ella’s was a landmark case: air pollution was recorded on a death certificate for the first time in the UK, and possibly for the first time in the so called “developed world”. This happened in 2021, the latest year mentioned in Geoff’s document, so we don’t know if any more air-pollution-linked deaths have been recorded since. I think we can be pretty sure that deaths like Ella’s had happened before - we just don’t know about them.

It doesn’t particularly matter. Ella’s case was extreme, with a fast, terminal decline of a happy child living in London - next to a busy road - and a medical history showing correlation between asthma attacks and Lewisham’s air-pollution levels. In the vast majority of cases, air pollution - especially particulate-matter pollution, which can pass through the lungs into blood - steals life slowly, sometimes affecting victim’s respiratory tract - think asthma and respiratory cancers - but as often producing disease not obviously linked to breathing, such as non-respiratory cancers, heart attacks and strokes.

In 1992, UK’s Department of Health established a scientific advisory panel named Committee on the Medical Effects of Air Pollutants, or COMEAP. Over the years, COMEAP has investigated toxic air’s links to specific conditions (for example, bronchitis and dementia), and attempted to quantify its health impact, focusing on the two key air pollutants, nitrogen dioxide and particulate matter. Several reports published by COMEAP have suggested the UK-wide annual “mortality burden” (we will discuss this later) of about 40,000 deaths.


Comeap Comeap mortality estimate
This is where Geoff gets his “40,000 deaths” number. However, it is an estimate for the whole of the UK, not only for London. The latter can be found in a 2021 study by scientists from Imperial College, who applied the latest COMEAP methodology to 2019 data for Greater London’s 600-plus wards.

The ICL study has a special significance for Sidcup, as it named Sidcup Ward, jointly with the neighbouring Bickley Ward of Bromley, London’s worst in terms of mortality burden. (To the relief of local estate agents, Sidcup is not explicitly named in the paper. I made a FOI request to TfL to get ward-level numbers, which identified Sidcup and Bickley as the joint Number 1). Three more Bexley wards - Bexleyheath, Crook Log, Blackfen and Lamorbey - made it to Top 20. (One would think that the esteemed News Shopper takes note. Nope. Maybe it’s the estate-agent lobby after all).


Mortality Mortality
The first bullet point in the study’s “key findings” says: “In 2019, in Greater London, the equivalent of between 3,600 to 4,100 deaths […] were estimated to be attributable to human-made PM2·5 and NO2, considering that health effects exist even at very low levels. This calculation is for deaths from all causes including respiratory, lung cancer and cardiovascular deaths”.

The calculation hangs on estimated “hazard rates”. Broadly, a hazard rate answers the question “How much more likely is one to die if exposed to bad thing X?” A hazard rate “embeds” a specific time horizon (e.g., one year), and, in the case of air pollution, is defined with regard to a specific concentration of a specific pollutant. (Things get tricky when two or more pollutants “overlap”). Notably, a hazard rate deals only with life and death; a temporary or permanent impairment of one’s quality of life - consider living with asthma - is out of the picture, as long as one is alive.

What Geoff wants you to believe is that for air pollution, that hazard rate is essentially zero: with a single death in two decades, in a city as big as London, there is really nothing to worry about! Scientists have a very different view, and guess an about 05%-2% boost in one’s “natural” risk of death over 1 year per 10 micrograms-per-cubic-metre (let me abbreviate this to “mgcm”) of nitrogen dioxide, and an about 4-8% (6% is a popular number) boost in one’s “natural” risk of death over 1 year per 10 mgcm of fine particulate matter (PM2·5). The numbers come from several large international (mostly American) epidemiological studies, and this is the closest we come to “evidence” demanded by Geoff. It is not the kind of evidence that one can touch, but in science, this is not unusual.

(Is 10 mgcm a realistic level experienced by a Londoner - in particular, an Outer Londoner living far from Zone 1? Consider Bexley’s Belvedere, where an air-quality monitoring station located in a residential area registered on average 8 mgcm for PM2·5 and 23 mgcm for NO2 for 2023. So yes, 10 mgcm of PM2·5 or NO2 is not a high bar for London, Inner or Outer. It can be double, or triple, or quadruple that - and that means multiplied risks!)


Belvedere With hazard-rate estimates in hand, one can estimate the expected number of deaths assuming a particular air-pollution level. Consider two points: the current air-pollution level, and the air-pollution level assuming no human-made air pollution. Say, 200 Sidcup Ward residents are expected to die in the “high pollution” scenario, and 190 people are expected to die in the “low pollution” scenario.

The difference (10) is the estimated mortality burden. Summed across London wards, one gets 4,000 premature deaths. (Not all of them are preventable. To calculate how many deaths a particular clean-air policy can prevent - or rather postpone to their “normal” times - one needs to make a forecast of the policy’s impact on air quality and use the resulting air-pollution level for a separate calculation).

In the end, there are no 4,000 death certificates with “air pollution” written on them. “4,000 deaths” is an estimate made by a scientific study that used an accepted national methodology and mainstream quantitative assumptions. As any estimate, this one can be off the mark, in either direction. However, it is scientists’ best guess. Sadiq Khan and clean-air campaigners do not mislead the public when they talk about 4,000 Londoners dying every year due to air pollution. Geoff and people like Geoff - sadly, including Conservative politicians on the Bexley council, on the London Assembly and in Parliament - do mislead the public when they discount the danger that air pollution presents. Much worse, they (excluding Geoff this time) fail to act when inaction costs lives.

And speaking of Parliament… Ten years after Ella’s death, the Clean Air (Human Rights) Bill, nicknamed Ella’s Law, sits on the waiting list at the House of Commons, after approval by the House of Lords. It may get to a vote in late March. Which way do you think our MP Louie French, who records anti-ULEZ videos and declares that “ULEZ is not about air quality” - and was Bexley’s Cabinet Member for Growth while the council ignored its responsibility to develop and act on an Air Quality Action Plan - is going to vote? I encourage you to email Louie at louie.french.mp@parliament.uk and ask, before he jets off on another expenses-paid fact-finding journey. Some facts worth finding, like Sidcup’s top spot in a grim league table, are right here.
Louis French
Louis French Health impact of air pollution is a complicated subject, and this essay could only scratch the surface. If you wish to learn why the World Health Organisation and the British government agree on air pollution being the top environmental health hazard of our time, you can Google COMEAP and WHO reports. In the next post, we will look at ULEZ’s ability to improve the situation.


Links
Ella Kissi-Debrah
https://www.theguardian.com/environment/2020/dec/16/ella-kissi-debrah-mother-fight-justice-airpollution-death
Rosamund Kissi-Debrah
https://en.wikipedia.org/wiki/Rosamund_Kissi-Debrah
Coroner’s “Report to Prevent Future Deaths”
https://www.judiciary.uk/wp-content/uploads/2021/04/Ella-Kissi-Debrah-2021-0113-1.pdf
Committee on the Medical Effects of Air Pollutants (COMEAP)
https://www.gov.uk/government/groups/committee-on-the-medical-effects-of-air-pollutants-comeap
COMEAP again
https://ukwin.org.uk/resources/health/committee-on-the-medical-effects-of-air-pollutants-comeap/
COMEAP, “The mortality effects of long-term exposure to particulate matter air pollution in the UK”, 2010
https://www.gov.uk/government/publications/comeap-mortality-effects-of-long-term-exposure-to-particulate-air-pollution-in-the-uk
Imperial College London, “London Health Burden of Current Air Pollution and Future Health Benefits of Mayoral Air Quality Policies”, 2021
http://erg.ic.ac.uk/research/home/resources/ERG_ImperialCollegeLondon_HIA_AQ_LDN_11012021.pdf
Ella’s Law
https://ellaslaw.uk

 

13 April - Thinking about ULEZ, Part 6 - Valley of Decision

Part 6 of @tonyofsidcup’s Magnum Opus on why he thinks ULEZ will be good for London. I think I might be more inclined to support ULEZ if the Mayor and his acolytes didn’t have to resort to lies to justify it. 4,000 deaths in London due to exhaust fumes turns out to be “contributed to” and that in turn may mean ‘died three weeks earlier than might have been the case’.

Why do they find the need to falsify the evidence? As an occasional photographer one look at the propaganda photo (below left) had me asking why is the visibility of the background not far worse than the foreground? If the fog was that bad near at hand you wouldn’t be able to see into the distance at all, but it is equally obscured.

One click in PhotoShop removed the filter and revealed the rather poor photograph beneath it. Why the need to resort to lies all the time?
Doctored photo Fog filter removed
And now for @tony…


Imperial College ULEZ ExtensionI would like to apologise to readers for the long wait since Part 5. In Part 6, I wanted to tackle the big question - “Is ULEZ expansion to Outer London a good idea?” - and I found it much harder than debunking the various ULEZ-related falsehoods, examined in Parts 1-5. To get to a view that I was comfortable with, I have looked at air-pollution data for Bexley, reviewed a scientific-looking paper by ULEZ opponents, had an email exchange with UK’s top air-pollution scientist - and liberally procrastinated.

As part of this procrastination, I asked Bexley how much money they committed to the legal challenge to ULEZ, pursued by the Tory-run councils of Bexley, Bromley, Hillingdon, Harrow and Surrey. Earlier, it came to light that Bromley had reserved £140,000. It turns out that Bexley has set aside £100,000, and already spent £18,000.

I think of £100,000 as money that could have built 5-10 pedestrian crossings to protect the borough’s children, and see the council’s decision as Bexley Tories doing their party’s bidding at our expense. Naturally, if you oppose ULEZ, you probably approve of the legal challenge: its merits and chances are hard to judge. Which view is more common? It looks like a borough-wide poll would be fairly inexpensive - but neither Bexley nor any other litigant council chose to spend a pound to consult voters before committing hundred pounds to their own preferred action.

Belvedere Crash YouGov PollIt may be because the poll wouldn’t have produced the answer that Teresa and Co. wanted. Recall that ULEZ opponents’ best poll showing was 51% - Part 3 explained why the higher percentage seen in the ULEZ consultation would be grossly misleading as an indicator of the popular opinion, and anyone pushing it as such must be, to use a colourful Russian expression, “slapped with urine-soaked rags” - and this was achieved with a manipulative wording that was fair game for a partisan group that commissioned the poll (the City Hall Tories), but beyond the pale for a council. However, I suspect that the thought to consult with Bexley residents simply never occurred to Baroness O’Neill, and the decision to spend £100,000 of Bexley taxpayers’ money on a publicity campaign to damage the Labour mayor was effectively made at the Conservative Central Office.

“Even if the majority is for ULEZ - a big if - public policy isn’t simply about what the majority wants”, Baroness may scoff. “We do want policies that benefit the majority, but the minority must be protected. ULEZ fails this test”. I see merit in this argument. While I do not accept that tax-free air-pollution - or even tax-free car travel - is a human right, l cannot dismiss the fact - and some ULEZ enthusiasts unfortunately do - that for many low-income owners of non-compliant cars, ULEZ is going to mean genuine hardship.

The Greater Good Imagine a care worker, driving a non-compliant car for work, struggling to feed her household after £300 more comes out of her household’s monthly budget to pay ULEZ charges. Hunger, or inferior cheap food, damages a child’s health a lot more visibly than nitrogen dioxide or particulate matter.

For some reason, people facing real distress in August do not get much attention from the press. The “journalists” of The News Shopper and similar outlets appear to be more at ease with middle-class characters like Sue, 65, who favours her sporty Mercedes over the “bloody inconvenient” tube, or a mechanic specialising in cars like Sue’s.

Builder Sue The most down-to-earth character of anti-ULEZ discourse is the tradesman in a non-compliant van who tells The News Shopper that ULEZ is going to drive him out of business. The journalist never asks the tradesman what kind of rates they charge and what kind of hours they work if extra £12·50 a day makes that much of a dent. As a homeowner, I am very aware of the high rates charged by the Checkatrade brigade, and I am 100% confident that a £12·50 daily charge can be, and will be, passed on to customers, without much impact on demand.

And then you hear, for example, Bexley Cabinet Member Seymour report ULEZ-linked difficulties of workers at Queen Elizabeth Hospital. I sympathise with QEH nurses - but then ask what party has made it so that an NHS nurse cannot afford extra £300 pm, or a better car. More recently, what party refused to fund a ULEZ scrappage scheme in the same way it funded scrappage schemes for other English cities? Of course, it’s Cllr Seymour’s Conservatives, cruelly inflicting pain on Londoners to turn them against the Labour mayor. But it is what it is, and the choice is not between a “perfect”, scrappage-scheme-supported ULEZ and no ULEZ, but between the imperfect, underfunded ULEZ and no ULEZ.

Let’s look at Bexley. According to the Society of Motor Manufacturers and Traders, in late 2021, 27% (or just under 27,000) of Bexley-registered cars and 55% (or about 5,500) of Bexley-registered LCVs were non-ULEZ-compliant.


Bexley Registrations (This was over a year ago, and the non-compliant numbers have fallen by now). I am going to ignore LCVs - one in twelve Bexley vehicles - and focus on cars. With 78% of Bexley households owning a vehicle, per 2021 Census data, I will guess that 20% of Bexley households own a non-compliant car. Without dismissing pensioners or workless households, I want to focus on working people, who need their car to get to work, every weekday, and ballpark 15% of those. In 2021, 35% of Bexley residents worked from home - note that the post-Covid year was not a usual time - but it would be wrong to take 35% off 12%: we don’t know how to “distribute” the home workers across households. We have the same problem when we want to exclude people who travel to work without driving - the majority even in Bexley - as we have the percentage of residents, but not the percentage of households. One has to make another guess. I go with 7·5% - meaning that 7·5% of Bexley households will have to pay ULEZ charges for their commute to work. Now, most of them will be able to afford £300 pm, but some will find it hard. How many? More guesswork. I will say a fifth will be poor, giving me 1·5%, or about 1,500 households. They are Bexley’s “ULEZ victims”.

(This back-of-envelope calculation may well be more than Bexley has done to date. The council has set up a bipartisan “task force”, chaired by the “environmentalist” Cllr Smith, to develop Bexley’s “coping strategy”. Nothing has come out of this yet, but stay tuned for bright ideas and bold proposals from this A-team).

BromleyNow, let’s talk about Bexley’s air - and counterintuitively start in Bromley. Bromley politicians have been very active in the anti-ULEZ movement. Sidcup’s gift to Orpington - and Boris Johnson’s man in the London Assembly when Mayor Johnson announced plans for ULEZ - Gareth Bacon MP has become a regular contributor to The Telegraph, lamenting Zone 1 Khan’s disregard for the bucolic, and car-dependent, areas like Biggin Hill. Bromley’s answer to Teresa O’Neill, Council Leader Colin Smith has persuasively argued against ULEZ via interviews and official statements. Both Bacon and Smith have spoken of Bromley’s clean air. How do they know it’s clean? How many air-quality monitoring stations does Bromley have? Let me give you a hint: Bexley has 3. Maybe we can make a guess based on the borough land area. #BrilliantBexley covers 61 square kilometres. Bromley, London’s largest borough, has 150. 3x150/61 = 7·5. Shall we say 7? How about 1. As of now, London Borough of Bromley has a single air-quality monitoring station, located near the Glades shopping centre. You can see the problem. You can only evaluate what you measure, and if you don’t measure much - and it is you who decides how much money to spend on air-quality testing - there’s less chance of an uncomfortable finding. In very simple terms: no measurement, no problem.


Positively, Bexley has done better in this regard than its richer neighbour, although you will not enjoy learning the reason. Riverside Energy Park may have “park” in its name - “river” too - but in reality it’s a giant waste incinerator in Belvedere, burning rubbish brought to it on the Thames. Waste management company Cory built the facility in 2012, and in 2020 gained Bexley’s permission to expand it.

Monitoring Sites RiversideKeen to demonstrate the incinerator’s cleanness, Cory agreed to finance air-quality monitoring stations around its site. And so we have Belvedere, Belvedere West and Slade Green sites in the northeast of the borough.

In addition to the three owned-by-Bexley, paid-by-Cory sites, Bexley “piggybacks” on two monitoring stations that belong to Greenwich and sit on two major roads as they cross into Bexley. The Falconwood site “watches” A2, while the Sidcup Fiveways site records air-pollution levels on A20. In total we get five monitoring stations, two on busy motorways (Sidcup and Falconwood) and three in residential areas (Belvedere and Slade Green). What numbers do we see? Read Part 7 to find out. [Collective groan]


Links
London Air
https://www.londonair.org.uk/LondonAir/Default.aspx
WHO Global Air Quality Guidelines 2021
https://apps.who.int/iris/bitstream/handle/10665/345329/9789240034228-eng.pdf
“Damning New Report Shatters 'Scientific' Claims Made By London Mayor Khan”
https://togetherdeclaration.org/ulez/
“Rainham MP ends campaign against Belvedere incinerator plans”
https://www.romfordrecorder.co.uk/news/21478258.rainham-mp-ends-campaign-belvedere-incinerator-plans/
Bexley council: “ULEZ - Member Task and Finish work”
https://bexley.public-i.tv/core/portal/webcast_interactive/743567/start_time/9752000
“ULEZ: West London garage owner fears expansion of £12.50 zone will reduce value of his 27-year-old business by £300,000 and ‘financially ruin him’”
https://www.mylondon.news/news/south-london-news/london-ulez-west-london-garage-26284874
“Builder says he’ll lose £3,000 over Ulez which ‘tradesmen can’t afford’”
https://metro.co.uk/2023/02/27/builder-says-hell-lose-3000-over-ulez-that-tradesmen-cant-afford-18355914/
ULEZ Protest in Orpington, by Brown Car Guy
https://www.youtube.com/watch?v=twGjux08IMg
ULEZ Protest in Bromley, by Brown Car Guy
https://www.youtube.com/watch?v=NaiAH7Gq4yI&t=1035s

 

5 May - Thinking about ULEZ, Part 7 - The Endgame

Before Part 7 of @tonyofsidcup’s dissection of the opposition to Khan’s new car tax the usual word of dissent…

I am quite pleased to know one of the ULEZ rebels who a couple of months ago asked me if there was any danger of electrocution from snipping a cable or two. I was able to give reassurance that professional grade security cameras operate on 48 volt DC, so wear gloves but the worst you would get is a not too severe jolt.
Blade Runners Blade Runners Blade Runners Blade Runners

In the end of the previous post, we talked about Bexley’s air-quality monitoring stations, and were going to check just how clean Bexley’s air is. Before we do that, let’s think about what “clean” means.

Recall that discussions of air quality tend to focus on two pollutants - nitrogen dioxide and particulate matter. The two “villains” are very different in their origin, behaviour and impact. Nitrogen dioxide is mainly produced by combustion engines, “stays local”, and hits the lungs. Scientists’ best guess is that long-term exposure to NO2 increases one’s chances of dying in the next year by 1-2% for every 10 micrograms-per-cubic-metre (“mgcm”) of NO2 concentration. Particulate matter has more sources - motor vehicles are an important one, but not as dominant as with NO2 - travels far and wide, and affects both respiratory and cardiovascular health, as smaller PM particles (2·5 microns is the established cut-off, hence “PM2·5”) can pass from the lungs into the bloodstream. Scientists think that every 10 mgcm of PM2.5 exposure raises one’s “hazard rate” by 6-8%. (To provide some reassurance after this morbid talk, one’s “baseline” hazard rate - the chance of dying in the next year - reaches 1% only after 70. That tiny number gets multiplied by 1·02 or 1·06, etc.)

In 2005 and again in 2021, the World Health Organization published a set of “guidelines” for NO2 and PM pollution levels. They are 10 mgcm for NO2 and 5 mgcm for PM2·5. A guideline level answers the question: “Based on what we know, what is the lowest pollution level that, with long exposure, affects health?” To clarify, a value below a guideline level does not mean that “everything is good”, it just means “We don’t have enough proof that it is bad”. Likewise, a value above the limit does not mean that “everything is bad”: the higher the pollution level, the higher the hazard rate. In the end, there is no “clean” and “not clean”, only “less clean” and “more clean”.
 Guidance Air Quality Guidance
And now, finally, the Bexley numbers. Please review the charts below. Note that red lines stand for roadside monitoring sites, and green lines denote residential settings. What are we to make of this? I see two main take-aways.
Nitrogen Dioxide Particulates
Everywhere we look, measured NO2 and PM2·5 pollution levels exceed the WHO guidelines - about 10 mgcm too high for NO2, and about 5 mgcm too high for PM2·5. (It sounds more dramatic if we express the gap in relative terms: for both NO2 and PM2·5, the Bexley levels are double the WHO guidelines). If these values were fixed long-term, this would mean a Bexley resident’s hazard rate to be elevated by about 5%. However, they definitely haven’t been fixed - and so we get to the next finding.

(Someone like Gareth Bacon, waxing lyrical about the meadows of Biggin Hill, ought to notice that PM2ܕ5 pollution levels are essentially the same next to a highway and in a residential neighbourhood. As noted earlier, particulate matter travels far and wide. There’s a very good chance that if PM2·5 were measured in Biggin Hill - it hasn’t; as we know from Part 6, London’s largest borough has a single monitoring site - the reading wouldn’t be particularly low).

Both NO2 and PM2·5 charts display a clear downward trend. Should it continue, it looks like WHO guidelines will be reached within a few years, maybe by 2030.

“Will they, even without ULEZ?” is the million-dollar question. Here, we get into guesswork territory. My guess is that they will. On the other hand, I believe that the ULEZ expansion will *ensure* that they do, and drive pollution to an even lower level. (What about the Independent Impact Assessment commissioned by TfL, which forecast only a negligible air-quality impact? The forecast applied only to the first 12 months, whereas the policy’s effect will develop over many years).

If the trajectory of pollution levels is permanently shifted downward, and not just short-term but long-term exposure to NO2 and PM2·5 is reduced, we “slide down” the hazard-rate curve and save lives. Importantly, we save them year after year, whereas the costs of ULEZ expansion are largely transient. Accumulated over many years, even a tiny public-health improvement eventually compensates for the initial pain.
The Greater Good
“Easy for you to say - it’s not your pain. You are not an already-struggling low-income worker facing an extra £300 pm expense”. I have no comeback to that, and pointing to the Tories who refused to fund a bigger scrappage scheme (or develop public transport and “active travel”, or generally promote the clean-air agenda - looking at you, Bexley Tories) would be a deflection tactic. It is what it is. ULEZ creates winners and losers. If you are on the winning side, you want the blow on the losers to be softened. Unfortunately, the Tory politicians in charge have opposite incentives, hoping to convert suffering into votes.

So that’s my “defence of the Red Dictator”, as the gracious host of this series introduced it, done. We may have reached the end with our views unchanged, but we definitely have learned something new.

Links
World Health Organisation, Global Air Quality Guidelines, 2021
https://apps.who.int/iris/bitstream/handle/10665/345329/9789240034228-eng.pdf
COMEAP, “Mortality Effects of Long-Term Exposure to Particulate Air Pollution in UK” https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/304641/COMEAP_mortality_effects_of_long_term_exposure.pdf

 

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