Department for Environment, Food and Rural Affairs
Defra Atmosphere and Local Environment
Area 5F Ergon House
17 Smith Square
London
SW1P 3JR
Telephone 08459 33 55 77
Website www.defra.gov.uk
Telephone 08459 33 55 77
Website www.defra.gov.uk
Our ref RFI 00003349
Mr Tim Henderson
Date 14 June 2010
Email
: request-35824-
[email address]
By e-mail
Dear Mr Henderson
REQUEST FOR INFORMATION: Update on PM10 Air Quality Compliance - London
2011
Thank you for your request for updated information which demonstrated compliance with
the EU daily limit value for particulate matter (PM10) in London in 2011, which we received
on 24 May 2010. We are dealing with your request under the Environmental Information
Regulations 2004 (EIRs).
The information you requested was submitted in May 2010 to the European Commission
(as an application for additional time (to 2011) to meet the PM10 daily limit value in London)
and has been published on their web site
(http://ec.europa.eu/environment/air/quality/legislation/time_extensions.htm). This
additional information was submitted following the Commission’s Decision in December
2009
(http://ec.europa.eu/environment/air/quality/legislation/pdf/uk_en.pdf) and show that
compliance is expected to be achieved in 2011.
In your request you specifically asked for confirmation on whether the projections included
(a) the continued operation of the Western Extension to the Congestion Charge Zone
(WEZ) in 2011; and (b) the introduction of Low Emission Zone (LEZ) controls for light
goods vehicles in 2010
WEZ
The WEZ was included in the projections used to inform our submission of additional
information to the Commission. The Mayor of London has announced plans to remove the
WEZ, but this does not affect our conclusion that compliance will be achieved by 2011. A
detailed explanation is below:
In compiling the latest national projections in early 2009, TfL provided Defra with London
specific traffic growth forecasts which included the WEZ, which at the time was reasonable
as WEZ withdrawal was not confirmed policy. These projections informed the PM10
resubmission, which concluded that compliance would be achieved in 2011 at the highest
monitored location (Marylebone Road). This conclusion has been validated by the more
recent modelling undertaken in support of the Mayor’s draft Air Quality Strategy. This did
not include the WEZ in its list of policies but also projected compliance by 2011 (with
appropriate priority location measures as necessary).
The single most important feature which determines the concentrations of PM10 alongside
individual road links is the traffic which that road link carries (speed, volume and
composition). The WEZ could affect our assessments of compliance for 2011 if it were to
impact on the traffic along the road links with highest concentrations of PM10 or if its
removal revealed road links which had otherwise been deemed to be in compliance with
the limit value, i.e. revealed new hot spot locations. No such impacts have been identified.
Of the 15 road links with the highest predicted annual average concentrations of PM10 in
London, six are along the Marylebone Road/Euston Road – the northern boundary of the
WEZ and Central Charging Zone (CCZ) - four are along the “free passage route” running
between the WEZ and CCZ, and the remaining five are either within the CCZ or to the east
of the CCZ. Evidence from extensive TfL traffic count data shows that the WEZ had no
significant impact on the traffic volume, speed or composition along any of these road
links. It is therefore reasonable to conclude that the presence or absence of the WEZ
makes no material difference to the predicted concentrations of PM10 along these links and
so is not relevant to the predicted compliance date for the PM10 limit value. Furthermore,
none of the road links within the WEZ have been shown to have a higher concentration of
PM10 than those listed above before the WEZ was initiated. It would be unreasonable to
assume that the removal of the WEZ increases emissions along links within its boundaries
to levels quite significantly above those seen before its initiation – none of the roads in the
WEZ area carry the level of traffic seen on the Marylebone Road, for example. It is
therefore reasonable to conclude that the removal of the WEZ does not reveal any
unforeseen hotspots with regard to PM10.
London LEZ
Our submission to the Commission referred to above makes clear on page 10 and in the
Executive Summary that the expected impact of Phase 3 of the London LEZ (for LGV’s
planned for October 2010) has been removed from the projections..
Please note that in keeping with the spirit and effect of the EIRs, all information is
assumed to be releasable to the public unless exempt. The information released to you
may now be published on our website together with any related information that will
provide a key to its wider context.
If you have any queries about this letter, please contact me. I also attach an annexe
giving contact details should you be unhappy with the service you have received.
Yours sincerely
Del Akinola
Bamdele(Del) Akinola
(Atmosphere and Local Environment Programme)
Direct Line 0207 238 4458
Email [email address]
Annexe A
Copyright
The information supplied to you continues to be protected by the Copyright, Designs and
Patents Act 1988. You are free to use it for your own purposes, including any non-
commercial research you are doing and for the purposes of news reporting. Any other re-
use, for example commercial publication, would require the permission of the copyright
holder. Most documents supplied by Defra will have been produced by government
officials and will be Crown Copyright. You can find details on the arrangements for re-
using Crown copyright on OPSI (Office of Public Sector Information) at:
http://www.opsi.gov.uk/click-use/index.htm
Information you receive which is not subject to Crown Copyright continues to be protected
by the copyright of the person, or organisation, from which the information originated. You
must ensure that you gain their permission before reproducing any third party (non Crown
Copyright) information.
Annexe B
Complaints
If you are unhappy with the service you have received in relation to your request you may
make a complaint or appeal against our decision within 40 working days of the date of this
letter. Please write to Clive Porro, Head of Defra’s Information Rights Team at, Area1B
Ergon House, Horseferry Road, London SW1P 2AL, (email:
[email address]) who will arrange for an internal review of your case.
Details of Defra’s complaints procedure can be found at:
http://www.defra.gov.uk/corporate/policy/opengov/complain/info.htm
If you are not content with the outcome of the internal review, you have the right to apply
directly to the Information Commissioner for a decision. Please note that generally the
Information Commissioner cannot make a decision unless you have first exhausted
Defra’s own complaints procedure. The Information Commissioner can be contacted at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
