Pollution threat to our children from London Plan
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On 16th of December 2020, Philip Barlow, the assistant coroner at Southwark Coroners Court concluded in a landmark ruling that exposure to air pollution was a major contributing factor to the death of 9-year old Ella Adu-Kissi-Debrah. Ella lived near the South Circular Road in Lewisham and died in 2013 after having been admitted to hospital on numerous occasions over the previous three years
The Mayor of London responded to Mr Barlow’s conclusion, stating that “tackling the scourge of air pollution is a priority”. This is inconsistent, to say the least, given that Mr Khan explicitly removed air quality as a constraint on the amount of residential development permissable on sites in boroughs across London in the soon-to-be-published London Plan.
The new London Plan also sets out extremely high requirements for office development in euphemistically-named "opportunity areas" across London, the air quality impact from which also appears not to have been taken in to consideration
I have written to Sadiq Khan asking him not to publish the London Plan and to recalculate borough targets in all our neighbourhoods, taking air quality in to account.
My letter highlights the lack of environmental evidence and analysis supporting growth plans for Kingston, a concern which I believe can be applied to areas designated for large-scale growth all over London. You can read my letter here.
Despite recent improvements in air quality, mainly in some areas of central London, pollution levels across Greater London currently significantly exceed national, European Union and World Health Organisation (“WHO”) requirements, especially in town centres and on arterial roads. Mitigation measures to reduce pollution that focus on inner London are simply not bringing the necessary improvements to air quality in all of our communities.
How then can a massive development programme over the next decade in areas where pollution is already too high be justified without considering its impact on air quality?
It is shocking to learn that at least 29 London boroughs, in their entirety, are currently designated as Air Quality Management Areas ( “AQMAs"), areas where national air quality objectives are not likely to be achieved, and that this situation has been continuing in some boroughs since as long ago as 1999.
Borough-wide AQMAs cover, among other London boroughs, Barking and Dagenham, Brent, Croydon, Ealing, Enfield, Hounslow, Kingston, Lewisham, Newham, Redbridge, and Tower Hamlets. All these boroughs sit outside the soon-to-be-extended ultra low emission zone and are targetted for massive residential and commercial development in the new London Plan as "opportunity areas".
Sources of pollution that affect air quality and which have therefore not been considered in establishing growth targets in the new London Plan include gaseous and particulate emissions from road traffic which are likely to increase as populations soar in outer areas of London where trains services are limited, and as freight movements to service the increased population rise.
Sources also include emissions from construction sites. These already make a significant contribution to air pollution. The Centre for Low Emission Construction estimated in 2016 that the construction industry contributed 7%, 34% and 15% respectively to NOX, PM10 and PM2.5 emissions within London (London Atmospheric Emissions) and that, as people migrate to urban areas "emissions from the construction industry will continue to increase in importance and therefore require further quantification and regulation by local and national governments". And yet there is no sign of this happening.
One type of pollution that is most dangerous to human health is small particulate matter, known as PM 2.5. This exceeds national limits in most of London. Around 25% of PM 2.5 pollution in London comes from dust and exhaust emissions generated on construction sites and from wood-burning stoves. The Mayor of London makes the following comment about PM 2.5 in his report Air pollution monitoring data in London 2016 to 2020:
"PM2.5 is thought to be the air pollutant which has the greatest impact on human health. Both short and long-term exposure to PM2.5 increases the risk of mortality from lung and heart diseases as well as increased hospital admissions. Children growing up exposed to PM2.5 are more likely to have reduced lung function and develop asthma."
Meanwhile, despite recent changes, emission limits for off-site machinery across London are less stringent than those applied across the European Union, and measures to control emissions from off-road machinery in London are based entirely on a system of self-certification by developers. Exemptions are also applied if the cost of compliance is considered too high, and compliance is audited by local authorities who, according to some boroughs' annual status report on air quality, appear to lack the clout and resources to do the job properly. There are also no defined penalties for situations where a developer has breached emission limits.
Development on a huge scale as a result of the London Plan is about to cause the proportion of pollution generated from construction sites in London to shoot up in relation to traffic-related pollution with no effective safeguards for public health.
In addition, pollution from gas boilers in London is an increasing problem as noted in the recent report by the Energy and Climate Intelligence Unit which states that:
“Gas combustion in buildings, from boilers and cookers, is a major source of local pollution, accounting for approximately a fifth (21%) of total NOx emissions across Greater London. Modelling predicts that boiler use will rise by 56% this winter due to the coronavirus pandemic changing work patterns. New analysis from the Energy and Climate Intelligence Unit (ECIU) shows that this increase in energy use has implications for urban air quality, driving up NOx emissions by approximately 12% in towns and cities – enough to offset the last two years’ worth of progress on reducing traffic emissions”.
Imagine the emissions from the 520,000 extra gas boilers required for the new homes to be built in the next 10 years, added to the pollution from heating the similarly large amount of commercial and other development planned across London.
Then there is pollution associated with aviation which includes emissions directly from aircraft and also from the road traffic associated with passenger and freight movements.
To make matters worse, local authorities lack the ability – and often the willingness – to identify whether a proposed development will have significant environmental effects – both on its own and in combination with other developments. This has been commented on by Friends of the Earth in their September 2020 briefing on “Environmental Impact Assessments ("EIAs") and on the Environmental Statements ("ESs") on planning applications written by local authorities”:
I am not the only person to have expressed concern about the harm that we will suffer from the Mayor’s decision not to consider the effect on air quality of the development of more than 52,000 dwellings in just 10 years across London, much of which will be in areas that are already designated as AQMAs.
as did Bexley Council:
and Islington Council:
and the London Forum of Amenity and Civic Societies:
The Mayor ignored all these comments and is still choosing to do so but, in the face of Philip Barlow's conclusions, Sadiq Khan must surely now choose not to publish the London Plan?
Please donate to my fundraising to take the London Plan to judiciai review here