Suffolk Coastal Annual Status Report 2017

Consultation results

Annual Status Report 2017 – annual air quality report for the Suffolk Coastal district

During February and March 2018 we undertook a Public Consultation asking for views and comments on the Annual Status Report 2017.  This document provides an annual summary of the district’s air quality for 2016/17 and includes updates on our Air Quality Management Areas (AQMAs).

The Consultation ran for 6 weeks and ended on 19th March 2018.

The Council received a total of 8 responses relevant to the Consultation which are detailed in the table below.  Two responses were specific to the AQMA declared in Woodbridge, 5 responses were specific to air quality in particular parishes – Blythburgh, Easton, Kesgrave, Kettleburgh and Martlesham, and 1 response related to the use of biofuels.

ConsulteeCategoryResponse

Resident of Woodbridge

Member of Public

Thank you for your letter highlighting the consultation draft of the Air Quality Annual Status Report.  I hope to look through the report in more detail but one immediate question springs to mind on which I would appreciate a reply:

-  the AQMA at the Thoroughfare/Lime Kiln traffic lights requires that all efforts are made not to exceed the NO2 objectives.  Was this taken into account in the approval of the Melton Hill development?  Whilst I note that the Objectives have not in fact been exceeded in 2014/15/16 and that a revised Action Plan is being produced, the addition of several hundred local cars will surely result in an increase in emissions and an exceedance of the Objectives, which is contrary to legal obligations.

Grateful for your thoughts.

Resident of Woodbridge

Member of Public

Thanks for your letter of 1st February. Having look at the results to 2016 I see there is a slow improvement in air quality at The Thoroughfare, adjacent to my property. It will be interesting to see the results for the latter half of 2017 and the first three months of 2018 during the ' Woods Lane ' closure times, It is easy to smell the pollution at the moment even in my garden. That would be an interesting monitoring point with the present traffic situation. I trust this will be borne in mind with the proposed traffic light trial at Sun Corner. If this is carried out during the summer my garden will not be a pleasant place to sit it let alone hang out any washing. As to opening windows - well !!

Blythburgh with Bulcamp & Hinton Parish Council

Parish Council

Having noticed that the Air quality report for 2017 has been finalised and a summary is available I remembered this request about the air quality around the corner on the A12 near the Blythburgh White Hart Inn.

Has the screening modelling been undertaken again at this location on the A12?

Resident of Easton

Member of Public

Having recently received the latest Air Quality Report to the parish - please may I request air samples be taken from the Hopkins Build site behind Easton Primary School.  This is now the second summer of moving earth around with heavy equipment and during the week the air reeks of fumes - so much so we cannot sit in our garden.  This site is in very close proximity to a primary school so surely there has to be some legislation governing emissions from build vehicles?

Resident of Kesgrave

Member of Public

It may be opportune to make some comments relating to Kesgrave for the following reasons:

  • With the huge growth in our population in recent years and the significant increase in car use I am concerned that we actually have higher levels of pollution and a more widespread pollution problem than is currently recorded by our pollution monitors. i.e. the problem is under-reported / under-estimated.
  • A call for more pollution monitors was made by KTC on the East Anglian Website  and, the pollution levels referred to in this article have since been exceeded according to later interim monitoring reports. (e.g. at the location mentioned in the article (KSG 9) a reading of  54.6 (raw data) was recorded in January 2017 and at location KSG 10 a reading of 59.8 (raw data) was recorded in January 2017).
  • We have received a proposal by Turnberry for 1300 homes to be built in Kesgrave (Long Strops) and the car use associated with this if it went ahead would generate even more air pollution. Turnberry are also looking to work with adjacent landowners on a bigger development of more than 1300 homes.
  • The Adastral Park 2000 homes application has got the go-ahead and is likely to generate some traffic movement through Kesgrave with associated air pollution.

(1) In my own experience of walking and cycling around Kesgrave I know that we suffer from significant air pollution especially along the A1214 corridor. When waiting for a bus it is particularly noticeable too. But it’s not just pedestrians, cyclists and bus users that suffer - it is motorists and car occupants that suffer too when sitting in traffic queues. See  for example on the Guardian website. The overall quality of life for residents is reduced by air pollution. We know that air pollution contributes to poor health – the statistics are shocking. Air pollution has been referred to as a “health emergency” and a quiet killer. 

(2) Some of the raw data figures in Kesgrave’s interim air quality monitoring reports exceed the recommended safe level of 40 units of NO2. And whilst these peak readings get adjusted in the data streamlining/averaging exercise which SCDC does, the fact remains that at some times of year and in some locations, the readings are higher than the recommended safe limit and air pollution has a real impact on people’s health/lives.

(3) Can we request air quality monitors are fitted at additional locations to help get a better understanding of local air quality:

a) at the two bus stops on the A1214 at Kesgrave High School (either side of the road),

b) at the bus stop on the A1214 adjacent to Bell Lane

c) at the two stops either side of the road at Kesgrave Fisheries

d) outside Heath School

e) outside Cedarwood School

f) on Ropes Drive near to the junctions with the A1214 where traffic often queues

g) outside Penzance Road Shops

There might be other locations which Councillors wish to consider too.

(4) Can we ask for some work to be carried out via a public awareness campaign to draw attention to the fact that it is an offence to leave a car engine running whilst the vehicle is stationary. People don’t seem to realise this and they seem unaware of the pollution they are causing in residential areas, outside shops, schools, bus stops etc.  See: the RAC website for details.

(5) The Air Quality Annual Status Report notes that a “Bus technology Grant” is being investigated to see if it would encourage bus operators to use cleaner vehicles. Can we add our support to this for bus services in Kesgrave.

(6) Can we ask that work is carried out with local employers to encourage them to adopt travel plans that encourage their employees to use buses, to car-share, to walk or cycle where possible. E.g. this could focus on larger employers in the area such as the Police, Tesco and KHS.

(7) Can we ask for some work to be carried out via a public awareness campaign to encourage people to use their cars smartly? E.g. Most car journeys are single-occupancy trips. The pollution generated per person is relatively high in this situation compared to if there were four people travelling together with no empty seats in the car. An educational awareness campaign could include facts and figures relating to the quantity of pollution produced per mile for large, medium small vehicles and encourage smarter travel to reduce pollution and also congestion –  as it seems we are not using our road space very efficiently.

(8) Woodbridge Town Council /SCC are planning to make most of Woodbridge a 20mph zone. Most streets in Woodbridge are included in this scheme including the main road through Woodbridge going past the Swimming Pool and Turban Centre. My understanding is that this will help to reduce pollution, improve road safety and reduce ‘through’ traffic and associated congestion.

Can we consider making Kesgrave / most of Kesgrave a 20mph zone too. Kesgrave is mainly a residential area (including along the A1214). Many towns and cities in the UK have introduced area-wide residential 20mph schemes and the evidence suggests that these schemes can reduce pollution – both air and noise pollution.

Lower traffic speeds could also improve journey reliability/traffic flow especially along the A1214 and Ropes Drive at peak times. Journey times may end up being the same, but instead of the stop / start nature of many journeys, traffic would keep moving and driving may be less stressful.

In 2017 Kesgrave High School’s Head Teacher and Deputy Head both supported a 20mph zone outside the school to help with the traffic chaos at peak times and to improve road safety. 

A 20mph zone may in general encourage more people to leave their cars at home for local journeys and to walk or cycle instead, as walking and cycling could become more attractive.

It has been suggested that the Kesgrave High School underpass may be reaching the end of its safe lifespan. If that’s correct then, as and when that happens, a 20mph zone may make it easier and safer  to install a pedestrian or toucan crossing here.

Local businesses such as Kiln Farm Nursery have raised concerns about vehicles turning in and out of their premises from the A1214 – and the speed of traffic is one of the problems in this location.

Lower speed limits may also help to reduce the number and severity of accidents as the stopping distance of a vehicle travelling at 20mph is around half that at 30mph and the severity of injuries from the impact of a vehicle is less for a vehicle travelling at 20mph compared to 30mph. 

A 20mph zone would also benefit pedestrians who struggle to get across the A1214 and Ropes Drive. It would benefit cyclists who are concerned about traffic speeds.  It could create a higher quality residential area. A 20mph zone may reduce pollution and improve safety for everyone.

Kettleburgh Parish Council

Parish Council

Please find below Kettleburgh Parish Council's comments on the "2017 Air Quality Status Report (ASR)”

  • Large-scale housing developments such as those on Woods Lane in Woodbridge and on the outskirts of Framlingham will inevitably lead to increased traffic. There are no viable alternatives to road transport in Framlingham, and the limited resources (both in Fram and Woodbridge) for schools and doctors will mean that people will have to travel further to access such services. Are there any plans to monitor the air quality around these new developments?
  • There are a number of difficult and dangerous junctions on the A12 (such as the Aldeburgh and Saxmundham junctions), where traffic often queues,  particularly in the tourist season. The provision of roundabouts at such junctions would not only increase safety, but may also keep traffic flowing.
  • In Woodbridge, to encourage walking, it would be helpful to have a few more pedestrian crossings; for instance on Lime Kiln Quay near the Co-Op car park, and near the Leisure Centre.
  • Elsewhere, the A12 is criss-crossed with public footpaths, most of which are no longer used because of the danger involved in crossing the main road. Some kind of assisted crossings (bridges/tunnels) would enable these paths to be used.
  • Many school buses in the area are old and emit large quantities of smelly, noxious exhaust fumes. Would it be possible to encourage schools to insist on higher standards when commissioning their school transport.
  • Are not 20mph speed limit zones self defeating in that a lower speed normally necessitates a lower gear and thus a similar engine speed to that used at 30mph and the lower vehicle speed does not disperse polluted air as efficiently?
  • In terms of editorial comment it would be good to have “AQMA’ described in full on first use on Page i.
  • ‘MOVA' should be explained on page 6.

Martlesham Parish Council

Parish Council

Strategic policy considerations

The current approach to air quality management acts as a disincentive to making improvements for their own sake – i.e. support the assertion that any reduction in pollutant levels is a good thing on the basis that any level of pollution is or could be injurious to health.

A planning system which incentivises an actual reduction is needed. Currently the government is, on the one hand, planning to increase the rate of house building, whilst on the other hand promoting the need for wide ranging measures to improve the environment.  These need to be reconciled within the planning laws.

We are mindful that the NPPF Policy 11: Conserving and Enhancing the Natural Environment, paragraph 109 states that ‘the planning system should contribute to and enhance the natural and local environment by preventing both new and existing developments from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution’.

See para 1) in the Comments on Measures section later on.

Does the District Council have the power to set lower threshold targets (as has been done in Scotland and London)?

Particulate matter

Why has the England target for PM2.5 been omitted from Table E.1 Page 82?  It is now generally agreed that PM2.5 is more dangerous to health than PM10.

It is noted that the WHO Ambient (outdoor) air quality and health fact sheet Sept 2016 sets the following guidelines for particulate matter which are much more conservative than current targets for England.

PM10
20 μg/m3 annual mean   (England currently 40 μg/m3 annual mean)
50 μg/m3 24-hour mean

PM2.5
10 μg/m3 annual mean   (England currently 25 μg/m3 annual mean)
25 μg/m3 24-hour mean

The WHO fact sheet says this about PM:-

There is a close, quantitative relationship between exposure to high concentrations of small particulates (PM10 and PM2.5) and increased mortality or morbidity, both daily and over time. Conversely, when concentrations of small and fine particulates are reduced, related mortality will also go down – presuming other factors remain the same. This allows policymakers to project the population health improvements that could be expected if particulate air pollution is reduced.

Small particulate pollution have health impacts even at very low concentrations – indeed no threshold has been identified below which no damage to health is observed. Therefore, the WHO 2005 guideline limits aimed to achieve the lowest concentrations of PM possible.

The ASK Transport assessment table 6.17 shows that the predicted PM10 levels across the sites listed are below the WHO guideline of 20 μg/m3, being in the range 16-19 μg/m3. 

However Table 6.18 shows PM2.5 levels in the range 11-13 μg/m3 which is above the WHO guideline figure of 10 μg/m3, although below the EU stage 2 2020 target of 20 μg/m3.  However it is expected that lower EU commitments will be set for 2030 and the indications are that the UK government may follow suit.

Given the worldwide concern about the impact on heath of particulate matter (especially PM2.5) the Parish Council suggests that future annual reports should contain a detailed section dealing with particulate impacts.

A12 - Air Quality

There are several factors which give us concern:-

  • Traffic volumes on the A12 will continue to increase as a result of local developments as well as developments to the north of Martlesham all the way up to Lowestoft and beyond.  In addition Sizewell C will have an impact.
  • Although the latest measurements (table A.3 page 44) show that levels along the stretch through Martlesham are much lower than the current England targets, the records available are patchy - the only site for which there is continuous data (MRT1) shows an upward trend in the last four years which is not in line with a general downward trend for most locations (see Fig A.3 Page 48).
  • It is noted that at MRT3 (Lancaster Drive) the 2016 NO2 level is shown as 17 (Page 44),  whereas CEG’s RSK consultant’s Sept 2017 Air Quality assessment shows the 2015 Defra background estimate (Table 6.13, Page 6-20) as 12.7.  RSK’s Table 6.16 shows this rising to 16.2 in 2027, which is actually less than the SCDC measured figure for 2016.  From a lay point of view this suggests that ASK’s 2027 forecast may be significantly understating the real levels.  The same seems to apply to the data at Horseman’s Court.
  • The introduction of partial signalisation on the existing roundabouts plus a new signalised T Junction will result in more stop/start traffic which we believe will increase pollution levels (especially in the absence of computer controlled interlinked signals which could help to smooth the traffic flow)
  • The planned increase in the effective height of the screening on the east side of the A12 with a 5m high bund/sound barrier may reduce the natural dispersion of pollutants.
  • The A12 rises alongside Lancaster Drive so it is at the same grade as the existing housing there, whereas it is lower than the housing north of there.

Taking all the above into account it is our view that the Martlesham section of the A12 should in future be consistently monitored between the A1214 and the Foxhall Rd junctions and a diffusion tube reinstated in the Lancaster Drive area. It is important to ensure that all these planned changes do not have an injurious effect on residents’ health.  We would wish the monitoring of air quality to take place throughout the development of Adastral Park as data collected could help monitor the effects of this large development.

Old Martlesham - Air Quality

As a result of motorists trying to avoid congestion on the A1214 and the A12, old Martlesham has become a major rat run in the last few years and is a regular source of complaint from our parishioners in the area. 

There are two sections where housing is immediately adjacent to the road - 1) opposite the Red Lion, and 2) along Top Street. The former, in particular, would appear to be more susceptible as traffic comes down the Bealings Rd and turns right at the Red Lion to accelerate up the hill immediately outside the windows of the houses which abut the road.

We request that action is taken to establish the air quality in this specific location.

Comments on Measures set out in Table 2.2

1)   Measure 5 (Better integration into planning).

Measure 27 (Assessment of planning applications for impact on air quality)

From our experience this is very much needed.  Planning proposals together with their supporting transport assessment should be required to carry out a human health impact assessment (which should cover air quality and noise generation since these both have a proven effect on human health).  Decisions about the choice of road surfacing should be included within assessments.

At present the planning system seems very much skewed towards the needs of motorists with little regard to the impact on local residents, or pedestrians and cycle users.  Encouraging cycling and walking by making it safer is accepted as being a win win, having a positive effect of health and reducing car usage.  

Better alignment between County Council and District Council roles and objectives is needed.

2)  Measures 6, 24, 30 (Cycling)

We agree with the importance of encouraging cycling.  Although measure 6 refers specifically to cycling in Woodbridge we recommend that this measure is extended to include cycling within Woodbridge and to nearby centres (especially for commuting to Martlesham Business and Retail area and the BT site).  We have been requesting that the old Felixstowe Road be made safer for cyclists (improved lighting and speed limit signage, traffic calming and restoring the width of the cycle lanes which have become overgrown).  We have also requested a 30mph limit on Sandy Lane. Both these roads are part of the national cycle network. We would welcome help with making the case on environmental grounds for these measures which in turn could have a positive effect on Woodbridge.

3)  Measure 14 (MOVA traffic signals)

We agree that this sort of technology can play a key part in reducing pollution levels (and improving a traffic flow).

The Parish Council has very serious concerns that the signalisation proposed for the existing roundabouts and the new T junction on the A12 (from Foxhall Rd to the A1214 junction) will not be controlled by a networked computer system to create a smoother flow through this section.  One of the effects of this decision will be to increase the levels of stop/start traffic on this section which is likely to result in what would otherwise be avoidable increases in pollution levels in this part of the parish. 

We understand that the necessary ducts etc. will be put in place at the outset so that a system could be implemented later if necessary.  This begs two questions  1) why wait to get the benefit, why not deliver the best achievable rather than merely acceptable air quality from the outset,  and 2) will the money be available in the future to implement it.

See earlier comments under headings Medium to long term strategy and Transport related impacts.

4)  Measure 23 (Suffolk walking strategy)

The routes for safe walking between Martlesham and Woodbridge are inadequate.Footpaths along the Ipswich road are narrow in places and require crossing from one side to the other at various points. Sandy Lane needs a 30mph limit to make it safer for pedestrians. We have been lobbying for this for some time.

5)  Measure 29 (Air quality in Local Plan)

We welcome the proposal that air quality will be embedded in the local plan review.

6) Measures for Martlesham

Martlesham has the biggest planned growth of any area in the district, and the A12, which passes through the heart of it, is the busiest section of road (apart from the A14 which does not go as close to housing).  We feel that there should be specific items in the measures list relating to Martlesham, and we would welcome the opportunity to develop these in conjunction with SCDC.

Other comments

Vehicles Parked with engines running

It is very common for drivers to sit in their parked cars with the engine running e.g.:-

  • in supermarket car parks e.g. waiting for their passenger who is in the store, or when eating food they have bought there
  • outside schools
  • on the shared section of Hamilton Road in Felixstowe adjacent to people sat on the benches
  • lorries parked in lay-bys (inc. overnight).  Some of these lay-bys are adjacent to housing.

Can education or by-laws be used to discourage the above?

NB Since drafting the above it was announced that Norwich Council are considering the introduction of by-laws to try and curb the issues above.

Wood-burning stoves

These are a retrograde step in environmental terms although the latest stoves are better when combined with the right fuel.  It is suggested that advice about the cleanest options is made available on the SCDC website, and is given in response to any pre-application discussions or applications which include the provision of a stove and/or flue.

CO2 Emissions

Can more action be taken on checking CO2 emissions?

National Farmers Union

National Organisation

Thank you for the opportunity to comment on the consultation on air quality in Suffolk Coastal.  I would like to offer the following comments on behalf of the NFU.

The National Farmers’ Union (NFU) of England and Wales represents 55,000 members in England and Wales.

The NFU welcomes the opportunity to respond to this consultation on air quality in Suffolk Coastal.. Given our members’ interests and our areas of expertise, we will focus our comments on the roles transport biofuels have in decarbonising our transport sector and in reducing farming’s impact on air quality.

Biofuels are an option to help improve air quality. We make a number of suggestions as to how the biofuel and agricultural sector could be supported to make a greater contribution.

In order to support the biofuel and agriculture industry it is critical that the UK Government:

  1. Sets the crop cap at 7%. A cap set any lower would constrain the UK biofuel industry and the lack of flexibility could prevent the UK from achieving its European and domestic targets.
  2. Sets a clear trajectory for biofuel policy by raising the RTFO (renewable transport fuels obligation) from the current level of 4.75% to 10% by 2020. This will give confidence to all in the supply chain and encourage both domestic and international investment.
  3. Develop ambitious transport specific targets up to 2030.

Transport biofuels

Transport biofuels produced from certified sustainable arable crops, for example under the Assured Combinable Crops Scheme in the UK, offer one of the very few scalable and cost efficient solutions at present to decarbonising the European transport sector.

In addition to its significant contribution to reducing emissions from the transport sector, the biofuel market is a valuable outlet for UK arable production, often putting a floor in volatile commodity markets, providing stability and security to those supplying it. High protein animal feed is a co-product of biofuel production. Defra statistics show that animal feed costs make up the single largest item of expenditure on farm. Given the UK currently imports up to 70% of its protein, often at a premium, it is very important logistically and strategically to strengthen domestic production of this valuable and often volatile commodity.

The results of a major UK research project on ‘Minimising nitrous oxide intensities of arable crop products’ (MIN-NO) has shown that nitrous oxide emissions from fertiliser use in UK arable agriculture are 53% less than estimates currently used. This means that biofuels made from fertilised crops grown in the UK are more effective in reducing greenhouse gas emissions than was previously estimated. These biofuels have an important role to play in tackling certain aspects of air quality, for example they work as cost effective blending agents.

In the 2011 Defra commissioned report ‘Road Transport Biofuels: Impact on UK Air Quality’ the expert group noted that ‘Most evidence suggest that at low strengths bioethanol leads to no change in oxides of nitrogen (NOx) emissions but a reduction in other regulated pollutant emissions (Carbon monoxide (CO), Hydrocarbons (HC), and Particulate Matter (PM)’. The report did find some evidence to suggest that when blending at higher levels, around E85, there may be an increase in certain pollutants depending upon engine tuning and suitability. However, in the UK we currently operate at E5 (5% ethanol) and, even if proposals to increase to E10 are realised, the UK will remain well below the levels suggested in the report. There is much emphasis on the use of electric vehicles to decarbonise the economy. Whilst uptake has been slow the majority of electric vehicles on the road today are hybrids. This means they use both conventional liquid fuels and electricity. In this situation, using higher blends of liquid fuels e.g. E10 would only amplify the impact the hybrid car has on air quality.

We would also highlight that ethanol contains oxygen, hence by including it in the fuel mix it helps the fuel to burn better and therefore increases the efficiency of the engine. This results in lowering the hydrocarbons that are released. Increasing this combustion through the oxygen helping to burn the fuel better also decreases carbon monoxide, which is caused by insufficient oxygen in the combustion process.

In order to support the biofuel and agriculture industry it is critical that the UK Government:

  1. Sets the crop cap at 7%. A cap set any lower would constrain the UK biofuel industry and the lack of flexibility could prevent the UK from achieving its European and domestic targets.
  2. Sets a clear trajectory for biofuel policy by raising the RTFO (renewable transport fuels obligation) from the current level of 4.75% to 10% by 2020. This will give confidence to all in the supply chain and encourage both domestic and international investment.
  3. Develop ambitious transport specific targets up to 2030.

 

Actions to be taken following the Consultation:

  • Specific elements of Consultation responses which are not within the remit of the Environmental Protection Team have been forwarded to the relevant body (Suffolk County Council and the Department for Environment, Food and Rural Affairs – (Defra) in this instance) or the relevant team within the Council (the Planning Department).
  • Any Consultation responses which need to be dealt with under alternative legislation by the Environmental Protection Team have been forwarded to the relevant Officer.
  • The Council’s diffusion tube monitoring program for nitrogen dioxide is continually reviewed and any new relevant monitoring locations of concern are added to the program each year.  Each of the suggestions / sites mentioned in the above Consultation responses will be considered for the 2019 monitoring program.  Defra provide guidance for local authorities with regard to identifying receptor locations for each pollutant of concern - the public must be expected to be situated there over the averaging period of the pollutant.  As an example, for the 1-hour nitrogen dioxide objective to apply a member of the public needs to be present at a set location for 1 hour, this would include residential properties and areas such as cafes or shopping areas.  Longer term exposure is needed for the annual mean nitrogen dioxide objective to apply and so residential properties are relevant in this instance.
  • All relevant planning permissions throughout the district are assessed for air quality impacts by the Environmental Protection team and responses submitted to Planning.
  • The air quality pages on the Suffolk Coastal website were updated earlier this year to make them more user-friendly and include new information with regard to how the Public can help to reduce emissions including domestic burning.  Further promotional work is planned with regard to domestic burning, and anti-idling of road vehicles within the district.
  • The 1 week trial to move the stop lines back at the traffic lit junction of Lime Kiln Quay Road, Thoroughfare and St John’s Street in Woodbridge was undertaken in July 2017.  This trial was undertaken in order to determine whether it was feasible to run for a longer period in order to determine air quality impacts within the Air Quality Management Area (AQMA) and at other locations on the junction.  We are awaiting Suffolk County Council’s report on their conclusions and the viability for the trial to be run for a longer period.  When investigating the results of the 1 week trial, impacts on other residential properties along the junction and its approach outside of the AQMA will be considered fully.
  • All editorial suggestions have been taken into consideration in the recent production of the 2018 Annual Status Report.  It should be noted that the report is produced using the template and guidance provided by Defra and the contents are those required by Defra.  The contents have been scaled down by Defra in recent years in order to reduce the reporting burden on local authorities and free up more officer time to work on air quality issues.