| The World Health Organization named Southampton amongst the worst cities for air pollution in UK. Here’s our response to the consultation run by NFDC and Southampton on Southampton’s Clean Air Zone. From 1 June – 13 September 2018 NFDC and Southampton have run a consultation on Southampton’s Clean Air Zone.
As is often the case, we’ve sidestepped the constraints of the online survey, which narrowly addressed a congestion charge type proposal, and prompted levels of agree / disagree to various elements. To its credit, the survey did take pains to explain its proposals within the survey (unlike the two recent National Park Recreation surveys). We did feel the need to comment beyond the proposals in the survey, particularly on the role of the New Forest District Council. |
Our Response
Consultation Limitations
Whilst clearly the policies and conditions which have triggered this Clean Air Zone consultation demand a pro forma consideration of options which include the DEFRA Charging Clean Air Zone classes and how measures related to the proposed options could be implemented – this unhelpfully limits discussion of the clean air issue to vehicle journeys that may be limited or mined for potential mitigation by a congestion charging model. By structuring this consultation almost entirely around these narrow solutions, and there circumscribing response to levels of approval or disapproval, the consultation is skewed towards a rubber stamping exercise.
Southampton should also be considering how other industrial sources of pollution, including port activities and cruise liners running engines for generation in dock. Broadly speaking we’d favour measures that Southampton might take, including the charging options in the consultation, but we’d consider further comment on this outside our remit.
However, New Forest District Council should have a broader scope in this, as many of their plans to allow development in the District will negatively impact air quality by increasing housing provision with its influx of cars, and allowing growth and creation of ports with an obvious uptick of HGV traffic. Neither the NFDC, nor Southampton are taking into account their duties to the National Park, which should garner higher levels of protection.
Wider View of Clean Air for the District
There needs to be joined up thinking here. To have this consultation about air quality at the local city and district level, and a Government launching its 25 Year Environment Plan, promising greater protection to National Parks and both designated and undesignated habitats, is well and good, BUT to have that same Government dictating housing targets to the District and Park where more strategic planning should abide to achieve the Park’s Statutory aims, is senseless and inconsistent.
NFDC plans for housing targets set to 10,500 homes in the next ten years, including the Fawley Development proposed to provide 1500 homes (within NFDC and the National Park) at the bottom of the A326, as well as the ongoing developments at the ports at Eling, Marchwood Military, and the ABP proposal for a deepwater container port at Dibden Bay, all of which the NFDC local plan welcomes with no quibbles for impacts.
10,500 new homes will produce a minimum of 13,650 more cars in the district, each making daily journeys. The growth and establishment of a new port will have a significant impact on HGV movements. All of this severely compromising the A326, with knock ons to the A35 and other local trunk roads. The additional traffic on the already congested A326 would lead to demand for extending dual carriage way for much of its length, however, as NFDC have allowed a hard edge of development against the road from Marchwood to Blackfield, the only room for widening would encroach onto the Crown Lands and the New Forest SSSI which should be unacceptable.
NFDC should not duck their responsibilities for clean air by limiting, as this consultation does, their part in it to merely improving the stretch from Rushington to Redbridge. Their responsibility and remit is wider, and they should ensure their plans do not damage or undo any strides made in the narrow tranche of congestion charge consideration within this initiative.
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