Bath Clean Air Zone Consultation, DEFRA’s failure to understand the problem

As people are very aware I am not just somebody that campaigns for cycling but spend a significant amount of time working on policy and, with my systems analyst hat on, how we create better cities and towns.

The council are currently consulting on the Clean Air Zone here and I’ve written my 25 page response here: CAZ Response.

The TL;DR is to implement:

  • Workplace Parking Levy
  • Citywide Parking Control with inner and outer zones based on CO2 g/km, car length, and a 50% diesel surcharge
  • Low Traffic Neighbourhoods (LTNs)
  • Sustainable Transport Levy on all parking fees
  • Free/cheap public buses

However it is in the last couple of days where I have begun to understand some of the fundamental problems with the way the Clean Air Zone has been designed and resulted in this graphic being added to the response:

Screenshot 2019-10-12 at 17.53.59


Car centric design

If you look at the map, you can see various iterations as people realised the CAZ would create rat running through residential areas.fbc_finalboundary_map_130819_sm_web

The council has designed a CAZ, not around walking, cycling, and public transport, but the continued use of the car as the primary way to get around the city.

Given that the CAZ will only be effective for less than 5 years as people replace their cars for newer cars, we pretty much end up with the same city, now with less NOx producing vehicles, but still choking on PM2.5/10 particulates (tyre, brake and road dust), with hostile roads where parents still won’t let their children walk or cycle to school on their own and feel the need to drop them at school by car.

Getting rid of NOx is not the answer

The reality is a 95% reduction in NOx can be achieved by shifting all HGVs/Buses to CAT6 diesel and banning all diesel vans and cars, no matter what their age. But your children would still be breathing in a soup of brake, tyre (18% of ocean micro-plastics), and road dust linked to dementia, learning difficulties, cancers, and heart disease.

Screenshot 2019-09-25 at 12.20.51.png

We need to change the way we think

If we look at the changes to the Clean Air Zone boundary it is about trying to prevent people circumventing the CAZ by rat running through residential streets.

Rather than expand the boundaries of the CAZ, they could use Low Traffic Neighbourhoods to prevent the ability to rat-run through our residential streets. This would allow the CAZ boundary to be significantly reduced while creating some big benefits for the city of Bath and the longevity of people living in the city.

Screenshot 2019-10-12 at 18.23.53

Low Traffic (Active_Filtered_Healthy_Liveable_) Neighbourhoods Crib Sheet (1)

The impacts would simply be profound.

The problem with Highways Department

Whether we like it or not the expansion of the CAZ to capture rat running is a car enabling, car centric, road miles inducing design decision that is the complete opposite of climate action by a council that has declared a Climate Emergency.

The CAZ should be made small and the city should implement Low Traffic Neighbourhoods to keep all through traffic to main roads and remove the ability to use residential streets as rat runs.

Given that the CAZ was designed and commissioned under a previous administration that wanted to make it easy to drive your car around Bath, these changes are now hard, if not legally impossible, to make.

The councillors and council’s environmental officers must take the Highways department to task and bring the Highways Department into the 21st century to bring a focus on maximising the movement of people, not vehicles, with a target to reduce road miles driven by 60%.

We are living through a Climate and Ecological breakdown and we need to fundamentally change the way Highways does business.

Your response to the Clean Air Zone

Although we cannot do much about the shape of the CAZ, we should be asking the extensions to be replaced by Low Traffic Neighbourhoods to prevent circumvention by rat running through residential areas of the city. We do not need expensive enforcement cameras when a simple set of bollards would do the same job and actually provide other benefits.

It is important to recognise that the CAZ is an expensive sticking plaster with an extremely short shelf life that leaves Bath with increased levels of traffic. 5% more by 2025.

Reducing the boundary of the clean air zone and using Low Traffic Neighbourhoods throughout the whole city would have a profound beneficial impact on your life and the lives of your friends and family. LTNs are a holistic approach to reshaping cities at a humane level using very simple cheap tools.

Screenshot 2019-10-12 at 18.24.50

Show me the money

I think there is no money in the CAZ for delivering a comprehensive set of Bath LTNs. However West Of England Combined Authority has sat on £76.5 million of Transforming Cities Funds for the last 2 and a half years. A basic LTN without public realm improvements usually costs between £70k-£100k. We have 14 LTNs and the central Living Heart.

A £5 million grant from WECA’s TCF should enable the complete transformation of Bath forever into a city where walking, cycling, and public transport is easy and driving is hard but not impossible.

To respond to the CAZ and to find out more click here





One comment

  1. What a fantastic and insightful article. We now live in a city dominated by traffic, congestion and pollution which will only get worse without intervention. This has to change for the health and well-being of all Bath residents. An initiative such as this needs to be implemented by a bold and decisive council but the benefits are widely recognised and evidenced by schemes such as Waltham Forest. Things can change and the city could be drastically improved by this shift away from car dependency.

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