Ealing Council’s draft Air Quality Strategy is a 64 page document together with a 40 page Action Plan, and the consultation period runs until 30 January 2023. It’s taken me the best part of six weeks, all my spare time over Christmas and New Year, to get through it all, make notes and cross-reference to try to make sense of it all and offer some feedback.

Really, there must be a much longer consultation period if Ealing Council is genuinely interested in residents' views.

The following is a summary of what the key points of interest are for me, and in particular in relation to Southall, where I live and work. My additional suggestions are in bold, and my comments and questions in italics.

Warning

This is a LONG post. I’ve tried to break it into sections to make it easier to read.

Disclaimer

I don’t claim to be an expert, other than through experience. I am just an ordinary resident living in the midst of four major industrial and construction site polluters for several years. I have campaigned alongside my family, neighbours and friends for clean air after my then nearly four year old said he wanted fresh air not stinky air. He’d been hospitalised three times when he was two and diagnosed with asthma. We soon discovered people who had lost loved ones, had heart attacks, ectopic pregnancies, cancer, all attributed to the foul petrochemical stink.

I welcome any corrections.

My Summary

If Ealing is serious about “fighting” inequalities, action must be targeted to protect vulnerable people in Southall to reduce air pollution and its impact on the health of its large, mostly economically deprived and non-white population.

The Strategy and Plan must target children and older people, people with lung conditions, and pregnant women: outside schools and school run hours. The Council must question if it is ethical to promote active travel in Southall when it knows that it is a high pollution area and that most of its population is particularly vulnerable to its adverse health impacts.

The draft strategy and action plan don’t do this at all.

Clean Air for Ealing!

To begin, I think it’s fantastic that Ealing Council has stated its vision for clean air for all Ealing residents, in alignment with that of local residents’ campaign group Clean Air for Southall and Hayes (CASH).

CASH has been asking for clean air for residents in Southall and Hayes since 2018.

Summary of the Strategy and Action Plan

Ealing’s draft air quality strategy’s five stated priorities are to:

• Reduce road traffic emissions
• Improve indoor air quality and reduce emissions from wood-burning
• Reduce emissions from construction of new developments
• Invest in green infrastructure
• Raise awareness of air quality

It would be useful to see the strategy and action plan follow the same structure with clear definitions of terms, and specific and detailed aims and objectives for each priority, along with baseline air pollution levels and equalities data for each in order to monitor and measure impact.

Somewhat confusingly, the action plan groups its actions into six categories:

• Emissions from Developments and Buildings
• Public health and awareness raising
• Delivery servicing and freight
• Borough fleet actions
• Localised solutions
• Cleaner transport

This maybe because they are copied and pasted from the previous 2017-22 action plan.

It would be better for understanding, monitoring and evaluation to have consistency and coherence between the two documents, updating the action plan where necessary to reflect this.

Also somewhat confusingly, Ealing’s draft air quality strategy has nine stated goals, starting with the obvious. I’ll say more on these later:

1. Improve air quality
2. Tackling the climate crisis
3. Fighting inequality
4. Protect biodiversity
5. Protect health and wellbeing
6. Raise public awareness
7. Promote sustainable infrastructure
8. Support the transition to clean energy
9. Creating good jobs

Inequalities

There’s a lot of talk in Ealing’s air quality strategy about being inclusive and “fighting” (“reducing” would be better?) inequalities, and recognising that not everyone will be able to reduce their own air pollution “footprint” (“exhaust trail” might be more apt?). I’m not convinced that the strategy actually does this consistently, if at all. More on this later.

Public Health Policy

The strategy sets out how it fits into national, regional and local policy frameworks.

When I first read the strategy, I felt it fell very much within an environmental policy framework (which in Ealing seems to come under the Cabinet portfolio for Climate Action), with its focus on reducing air pollution, and as we’ll see later, promoting active travel.

In contrast, the draft action plan is explicitly a legally required document that falls directly within a public health policy framework (Ealing’s Healthy Lives cabinet portfolio).

*There’s obviously a good deal of crossover between the two, and other policy frameworks and cabinet portfolios, too, not least of which is housing policy (or Good Growth), and social policy (Tackling Inequalities).

It would be useful to see this joint responsibility formally recognised in both the strategy and the action plan, too. This work is important, and there needs to be joint working and accountability.

The strategy goes on to make the case for why air pollution is bad and needs to be reduced. The headline figure that around 150 people die every year in Ealing due to long-term exposure to toxic air is not insignificant.

Ealing’s Health Profile from 2019 puts that figure in some context:

Air Pollution in Ealing

Pollution Sources

The strategy states that the two worst air pollutants in Ealing are nitrogen dioxide (NO2) and particulate matter (PM10 and PM2.5). Short and long-term and/or frequent exposure to high levels of both can cause irritation to eyes, nose, and throat, and cause or worsen heart and lung disease in children and adults, and reduce life expectancy.

Those most vulnerable to the adverse health effects of toxic air are children, older people, people with pre-existing lung disease (e.g., asthma), and pregnant women.

It would be sensible and ethical for the strategy and action plan to focus on reducing air pollution in and outside schools, sheltered housing, residential and nursing homes, and in and around identified local air pollution “hotspots”, especially where these are located in areas of known multiple inequalities (e.g., Southall).

I don’t believe the strategy or the action plan really does this at all.

The strategy explains in further detail what the main sources of NO2, PM10 and PM2.5 are in the borough.

Again there is what appears to me, to be some inconsistency about sources and their health effects within the same document. For example, on page 19 there is a graphic showing that wood burning is a source of particulate matter (PM2.5 - 20%, data from 2019).

On page 11, another graphic suggest that wood burning is a source of nitrogen dioxide (but not particulater matter):

In the graphics from the 2017-22 action plan, wood burning doesn’t get a look-in at all, data from 2013.

It would be useful for the strategy to have clarity and consistency on air pollution sources.

The good news is that road traffic emissions, the council’s key action area for 2022-30, reduced significantly in Ealing between 2013 and 2019.

It would be useful if the strategy could make clear and explain how the reduction in road traffic emissions between 2013-19 happened.

Air Quality Monitoring

The strategy notes the air quality targets set by European Union, United Kingdom and World Health Organisation (WHO) guideline limits.

It’s worth noting here (and in the strategy), that, as things stand, the background levels of PM2.5 in London (i.e., particulate matter that comes into the borough from outside Ealing and even from abroad) is around double the WHO’s target.

The draft strategy document continues by identifying the areas in Ealing worst affected by air pollution from nitrogen dioxide and particulate matter. There are eight Air Quality Focus Areas, including one in Southall covering South Road (remember the name), The Green, King Street and Western Road.

Ealing has 67 air quality monitors acrosss the borough, all recording levels of notrogen dioxide, but only four measure particulater matter (PM10 only).

It seems remiss not to have more PM10 monitors, or to have any PM2.5 monitors (although their are three NO2, PM10 and PM2.5 monitors around the Southall Gasworks site, rather erroneously remarketed as The Green Quarter.

Ealing publishes annual air quality status reports.

Ealing also has an interactive map showing all its NO2 diffusion tube monitoring sites where you can see graphical annual data summary charts. Unfortunately, none seem to have been updated since 2021.

It would be useful to have more monitors for particulate matter, especially PM2.5, across the borough, and in Southall, and for published data from all air pollution monitors to be kept accessible and up-to-date.

Priorities for Action

Back to the strategy’s priorities for action, and my comments and questions, and suggestions.

• Reduce road traffic emissions.

The biggest reduction in road traffic emissions came during 2020 covid lockdowns, and while it’s not practical, feasible or desirable to replicate that going forward, it might be worth promoting the idea that employers should encourage and support an increase to the 36% of Ealing’s working age population already mainly working from home whenever possible, as opposed to the current political groupthink that everyone must return to the office in order to be productive.

• Improve indoor air quality and reduce emissions from wood-burning.

There are two wood-burning incinerators close to my home, which frequently create disgusting burning plastic odours forcing us to stay indoors and close all our windows. Not very good for healthy lives or improving indoor air quality, and the Council’s response to mine and my neighbours’ complaints has been infuriatingly slow and unhelpful. It doesn’t give me much confidence that the council really believes all these fine words about reducing air pollution and improving health outcomes when it comes to enforcement action.

• Reduce emissions from construction of new developments.

Wouldn’t this be fantastic?! Again, the Council’s response to the Southall Gasworks poisoning has been shameful, and bears no resemblance to its 2017-22 Air Quality Action Plan pledges to reduce emissions and enforce construction management plans. How can we have any confidence that the council will put residents' needs for clean air first, and above developers' desires to enrich themselves and their shareholders by cutting corners by compromising the health and quality of life of the most vulnerable population in the borough already faced with multiple inequalities?

• Invest in green infrastructure.

Southall has the least tree canopy cover in Ealing, yet is subjected to massive overdevelopment. This almost entirely terraced town is being transformed into a new Manhattan.

The one concession negotiated hard for by our elected representatives, and granted by the London Mayor for overruling local democracy to allow the Gasworks development, was to widen the South Road bridge by the train station to ease the often gridlocked road. Now, the Council Leader has undemocratically pressed the ‘reset’ button. Having sat on the Mayor’s money and done nothing for so long it’s no longer nearly enough to do the necessary work. We are promised £9.5m worth of cycle lanes, a tiny new ‘pocket park’ outside Lidl on the High Street, and a couple of mini-‘orchards’ planted in existing parks, instead. And we have the ‘Poison Park’ to look forward to, the ‘green space’ crafted by Berkeley Group from the contaminated old Gasworks land.

If the council’s air quality strategy is to have any real meaning and intent to address air pollution and multiple inequalities in the Southall Air Quality Focus Area and beyond, it must surely include a vast tree-planting project, and proper maintenance of our existing parks if no new ones can be created on non-contaminated land.

Instead, the council Leader has undemocratically proposed a ‘compromise’ to destroy most of the already re-wilded Warren Farm Nature Reserve in Southall in order to build new sports pitches that the vast majority of local people he consulted don’t want. I don’t understand how the Leader’s desires complement the Council’s stated strategies to reduce air pollution, tackle the climate emergency they declared, and to protect and promote biodiversity and our ecosystem.

• Raise awareness of air quality.

The council also wants to (and must) lead by example.

If the council really wants to lead by example on reducing air pollution, then the council Leader cannot accept or request car rides to or from meetings in Southall, councillors cannot park in cycle lanes in Southall, nor fly to the property developer festival in the south of France. They must engage with Southall residents suffering the worst of the air pollution from multiple sources, and stop denying or minimising the existence and extent of the problems, and proactively and collaboratively work to reduce or stop such pollution episodes continuing.

Otherwise, the council’s strategy isn’t worth the virtual paper it’s printed on, and is just more hot air.

What we have in the draft plan, however, is largely a copy-and-paste of the previous 2017-2022 plan, which was, at worst, a demonstrable failure of ambition, leadership and political will, and, at best, a simple failure of the council to do what it said it would do.

Strategy Goals

1. Improve air quality. Protect the health and wellbeing of Ealing residents from the harmful effects of nitrogen dioxide (NO2) and particulate matter (PM) air pollution.

The strategy MUST have the inclusive goal of protecting residents from the harmful effects of ALL air pollutants (not just nitrogen dioxide and particulate matter)..

2. Tackling the climate crisis…. by aiming for the highest environmental standards.

The “highest environmental standards” must be clearly stated and defined.

3. Fighting inequality…. to ensure that no-one is left behind… [and] residents feel safe.

The strategy must ensure that inequalities are reduced, that ALL residents are included in this process, and that their concerns for the safety of their air are taken seriously and acted upon. Promoting the uptake of expensive electric vehicles and discounting parking spaces for them is discriminating against economically deprived mostly non-white people who suffer most from air pollution.

4. Protect biodiversity. Ensuring our parks, open spaces and nature are protected and enhanced.

This is particularly relevant right now, as the Council Leader pushes on with his undemocratic desire to destroy much of the already rewilded Warren Farm Nature Reserve in Southall, and killing off a quarter of London’s endangered skylarks, in order to build new sports pitches and/or a football stadium.

5. Protect health and wellbeing. Protecting and enhancing the physical and mental health of all.

Except in Southall? Public Health England’s four risk assessment reports into the Southall Gasworks poisoning clearly stated that “Odours can cause nuisance amongst the population possibly leading to stress and anxiety. Some people may experience symptoms such as nausea, headaches or dizziness."

6. Raise public awareness. Promoting awareness of the causes and impacts of air quality issues, as well as the available local solutions…. encouraging community activism….

Except in Southall? At every opportunity, Ealing Council has sought to erase, deny or minimise the the causes and impacts of air quality issues related to Southall Gasworks, refused to enforce any local solutions, and actively discouraged and attempted to prevent community activists' voices from being heard.

7. Promote sustainable infrastructure. Ensure local transport and development planning supports investment in sustainable infrastructure, that limits impact on air quality, enabling a shift to low-emission transport and energy options.

Except in Southall? The Council recently decided NOT to widen the South Road bridge in Southall. Widening the bridge, as promised, would ease congestion, and improve air quality, public transport and active travel options. The bridge widening was the one concession granted to the Southall community when the London Mayor overruled local democracy to give the go ahead to developement of the highly contaminated Southall Gasworks site.

8. Support the transition to clean energy. Supporting the uptake of low-emission energy technologies and improvements in efficiencies, and reducing reliance on the consumption of fossil and solid fuels.

Like in Chile? Simply promoting and encouraging more (low emission) cars isn’t going to reduce congestion, emissions from brake and tyre wear, or help to reduce our “reliance on the consumption of fossil fuels”. Ealing reportedly doesn’t have enough power on the electricity grid for new homes until 2030.

9. Creating good jobs. We want to… deliver an ambitious programme of building more genuinely affordable homes.

Ealing is building fewer genuinely affordable homes than ever, and making the housing crisis in Ealing worse by demolishing more social rent homes than it is building.

Spotlight on Southall

These are all my comments, so I’m not putting it all in italics.

My suggestions and questions for the strategy are still in bold.

Southall cannot be used as a good example of how Ealing Council takes air pollution seriously.

Inequalities

Southall has a BAME population of more than 90%.

Southall Broadway/West and Southall Green are the two council wards that border the old Gasworks site, and which are downwind from the FM Conway asphalt and Tarmac plants, and the two wood-burning incinerators, depending on wind direction. They are connected by the Gasworks site and by the Air Quality Focus Area from South Road to The Green, King Street and Western Road.

Southall is already a high pollution area (and an Air Quality Focus Area as a result), but has several additive sources of unmitigated, uncontrolled air pollution.

Economically poorer, BAME people, children, older people and pregnant women are the most vulnerable to the health impacts of toxic air pollution. Certainly not a fairer start for Southall’s children.

We know from bitter experience over the last six years in Southall that the council has failed in its duty to protect some of its most vulnerable residents from harm.

Raising Awareness

To add insult to injury, the council failed to raise public awareness of the risks and the air quality monitoring data in an open and transparent manner before work on the site began, and while the work was in progress. It was only thanks to local residents and CASH campaigners that a Public Meeting was held in 2019, and it was only then that Public Health England (PHE) acknowledged that some people with African and South Asian heritage are genetically vulnerable to naphthalene poisoning. PHE stated that “levels of naphthalene [at the Gasworks site] must be urgently reduced”. Residents were never informed if, when or how levels of naphthalene were urgently reduced.

It’s noteworthy that the Council claims it asked PHE to get involved only “following concerns raised by local residents” and not because the Council itself carried out an Equalities Impact Assessment prior to works starting in 2016, knowing that the Southall population was significantly more vulnerable to air pollution due to high pre-existing levels and multiple inequalities.

Similarly, the council says it responded to residents' concerns by installing “independent” air quality monitors on site in 2021, but this is five years after the work started, and two years after the main source of air pollution and odour complaints (the so-called soil “hospital”) was decommissioned. The monitors now installed record near-real time data for “urban background” emissions of odourless particulate matter, nitrogen oxides and carbon monoxide.

The odours and air pollution that residents are concerned about originate from polyaromatic hydrocarbons and volatile organic compounds (i.e., the hundred years’ of toxic waste from town gas, coal tar and petrochemical work sites). We are told that there are diffusion tubes monitoring these emissions, but there is a total lack of openness and transparency as to their locations and the data they have recorded. The council has refused to answer the most basic questions (e.g., what chemical or chemicals causes the odour of petrol? What level of this chemical or chemicals in the air is detectable by the human nose?) So much for raising public awareness!

Public Health

We are also told that the emissions from the site are not harmful to health (this despite hundreds of residents reporting that they have suffered ill-health as a result), so it is surprising that the council then spent £200,000 (albeit paid for by Berkeley Group) on these monitors. Is the air pollution from Southall Gasworks harmful to health, or not? The money would have been better spent on statutory nuisance enforcement. Why did Berkeley Group agree to pay for these monitors?

Moreover, the council must have known in 2016 that the economically poorer, mostly BAME population of Southall carried a higher burden of risk to the potential ill-effects of a hundred years' of highly contaminated toxic waste being dug up and “cleaned” in the open air in the middle of a densely populated residential area. Why wasn’t truly independent (i.e., not paid for by the perpetrators Berkeley) air quality monitoring put in place before work started (to record a baseline), and open and transparent near-real time data published so that residents could see for themselves the reality of what they were forced to breathe night and day for the best part of two and a half years?

Enforcement

Why didn’t the council force Berkeley Group to stop work and make the site safe in the three month heatwave of 2018 when residents pleaded with the council leader, local councillors and Member of Parliament to do so?

The council failed to act on enforcing the construction management plan (CMP) at Southall Gasworks. Indeed half of the plan was missing from the planning portal and the council admitted that it didn’t have a full copy of the original CMP.

How on earth was the council planning to enforce a CMP it wasn’t in possession of? This was a gross dereliction of duty to care for the health and wellbeing of (by its own definition) the most vulnerable residents in the borough.

The Council was committed to full enclosure of waste sites in its 2017-22 Air Quality Action Plan. Why wasn’t the one hundred years of petrochemical waste “soil cleaning hospital” enclosed?

National Grid have enclosed their enclosed their soil remediation work specifically to avoid causing odour nuisance to the local community (and thanks no doubt to campaigning by local residents and activists at Clean Air for Southall and Hayes).

On Whose Side?

Why did the former and current council leader accept over £30,000 in gifts and hospitality from developers including Berkeley Group to fly (!) to the south of France for what Private Eye Magazine describes as a booze and hookerfest?

The new council leader claims he went there to negotiate hard. If that’s the case, what did he negotiate? He also claimed that it wasn’t what he expected and that it was a mistake to go. If that’s also the case, why was it a mistake?

How can we be sure that the new council leader and his administration won’t continue making these mistakes and taking the side of developers rather than standing up for the residents they are elected to represent?

Local Action

If the soil is now clean and the air is safe to breathe, why would stopping works during hot weather (which didn’t happen in 2018), and covering stockpiles (why weren’t they covered already?) be given as examples of possible mitigating actions?

There must be a new commitment to work with and for residents where these are issues. Air pollution and odour nuisance reporting and investigation procedures need to be overhauled as they are currently not fit for purpose (reporting process too convoluted, each one investigated as a single, isolated incident rather than as part of an ongoing problem, residents are simply not believed and our reports are minimised and invalidated).

Work on the Gasworks site is due to complete in 2038. Why is the date for net-zero emissions set for twelve years after this date in 2050?

There’s a similar commitment to target zero-emissions for construction vehicles by 2040, which is two years after the new draft local Plan period for new developments ends.

What has Ealing Council done to date to campaign for greater regulatory powers and for a Clean Air Act? Please give examples.

This draft Air Quality Strategy is fine in many respects in terms of the words it contains, but what concerns me is that these are empty words if they are not acted on and enforced.

Recent history strongly suggests the council doesn’t have the leadership, organisational culture or political will to act in the interests of its most vulnerable residents in Southall.

Active Travel

There’s a lot of talk about active travel and Ealing Council’s multi-million pound Let’s Go Southall campaign in the draft Strategy, but very little on its real cost and impact. They seem to have about 50 regular weekly activity groups. Over two years that’s 5,000 sessions. 30,000 attendances (not individuals). So average of six people per session? 1,000 people attended at least two sessions (repeat attendances). My guess would be not many more than 1,000 in total, most will be repeaters (thinking GP referrals, lots of organisers?). If it’s helped 1,000 individuals, that’s £5,400 per person. If 10,000 it’s £540 per person (still seems like a lot of money). And there’s no evidence that it’s helped anyone!

The council must be open and transparent with residents that Let’s Go Southall is a top-down neoliberal behavioural change (“nudge theory”) programme led by a retired stockbroker, and not the “grassroots social movement” of the council’s Orwellian publicity.

If the Council is serious about improving safe active travel options in Southall, then it must improve road and pavement conditions and safety first. Many of the roads and pavements are not fit to cycle or walk on, especially for children and families, older people, and people with disabilities.

Air Quality Action Plan

The 2017-2022 Action Plan

a. Included a number of no-or-low-impact schemes such as Low Emission Neighbourhoods (LENs), implemented in 2021 as Low Traffic Neighbourhoods (LTNs). The Action Plan itself states that there is no (or, elsewhere, conflicting) evidence that LENs/LTNs reduce air pollution within the designated area, and that there is evidence that they increase air pollution outside it. The Action Plan also states that LENs/LTNs are often implemented in areas of relatively low air pollution. Surely it would be better to reduce traffic in areas with high levels of air pollution?

b. Similarly, a 20mph zone was implemented borough-wide, yet the Action Plan states there is no evidence that speed reduction zones produce a reduction in emissions. The Plan states that there is a perception that road safety is improved. Perhaps the Council will reflect on the road safety issues associated with its promotion of the uptake of much heavier electric vehicles while reducing road space for vehicles.

c. Another low impact scheme was Play Streets. How many Play Streets are there now? How often do they run? Where are they?

d. How many Pocket Parks are there? Where are they?

e. How many Green Screens are there? Where are they? Why were green screens not erected at Southall Gasworks even after residents complained of dust from the site in their homes?

f. How are these schemes evaluated in terms of reducing air pollution? Where are the air quality monitors located to record baseline measurements to compare against air pollution levels during or after the scheme is in place?

g. Enforcement of anti-idling laws was deemed “not cost-effective”. Smoke control was not deemed a problem and therefore not promoted or enforced. Who made these decisions?

h. What is the wider ‘cost’ to residents in not taking enforcement action against these criminal behaviours?

The 2022-2027 Action Plan (AQAP)

If air pollution monitoring data cannot inform the efficacy of individual actions, how can it be used in combination with secondary data to do so? I’m sure there must be a sensible explanation, but to most people I suspect this statement makes little sense. In Southall, we have continuously been asked to ignore our own lived experience of health and quality of life problems attributed to the open-air ‘cleaning’ of a hundred years of petrochemical waste at the Gasworks site, in favour of the developer Berkeley’s assurances that it’s own monitoring of air quality is ‘within acceptable limits’ and harmless to health. Public Health England published four risk assessments based on Berkeley’s data, and came to similar conclusions, although neither looked at any secondary data. The air pollution data has still to be published so that the public can make up their own minds.

I’m not sure how imperceptible changes that cannot be detected by monitoring or modelling can be interpreted as Low Impact or a step in the right direction.

The Action Plan here seems to contradict the Strategy by stating that changes in the levels of air pollution above a certain level can be attributed even to individual actions (although more likely to be due to multiple actions).

If the council is serious about using air pollution data and secondary data to establish efficacy of its air quality strategy and action plan, (which sounds sensible enough), then it must explain what measures it will use, and publish baseline data and regular updates.

Like it does with its performance dashboard.

Looking at the Council’s own evaluation of it’s 2017-22 Action Plan, I would suggest that it’s achievements are minimal, and misleading.

Electric Vehicle charging points (p. 30 of 2022 AQAP) were not actually a specified target in the 2017 AQAP, so I’m unsure how this can be claimed as an achievement? Similarly with School Streets and specific cycle lanes. LENS/LTNs were specified as a target, but there is no mention of that fiasco here. Air quality monitoring data must be used to locate pollution hotspots for any future implementation of LENs/LTNs

The 20 mph speed limit was implemented borough-wide, but only since December 2021. Why did it take so long? What is the use of it if it isn’t enforced, especially in Southall?