OHSA response to ZEZ Scheme Pilot Zone consultation

17th January 2021

FAO Mr Stewart Wilson

Dear Mr Wilson and team,

I write to you on behalf of the Oxford High Street Association, a group of businesses and colleges based on the High Street and side streets of Oxford’s historic city centre. While we recognise the need to reduce air pollution in the city - especially in areas the formal consultation document recognises as having excessive levels - we are concerned by a number of aspects of both the pilot scheme proposals and those of the full roll out. We would appreciate feedback on a number of points, which I have highlighted for ease of reference.

In your formal consultation document, you state in the summary that “[t]he ZEZ Pilot would allow the scheme to be tested out in a small area first before being expanded to a larger area.” In summary section 1.6 you expand, claiming the pilot scheme will achieve two things: firstly, that it will “reduce air pollution levels, tackle the climate emergency, [and] improve the health of residents, workers and visitors in Oxford and beyond” and secondly that it will “allow the councils to gain useful experience and information to inform the ZEZ.” On both counts this is flawed:

- In the first case, consider the streets affected: Cornmarket is pedestrianised for the majority of the day; the part of Market Street highlighted is currently under construction so sees no traffic at all (and when construction finishes it will still meet Cornmarket Street at one end so is essentially a dead end for car traffic anyway); St Michael’s Street and Ship Street both see minimal traffic as they have one end meeting Cornmarket and so are likewise essentially dead ends to car traffic; and New Inn Hall Street and Shoe Lane are totally inaccessible from one direction and so similarly see minimal traffic. Queen Street is the only street that sees meaningful traffic pass through it... but that traffic is for the vast majority of the day exclusively buses and taxis - and those are exempt from the scheme! With this in mind, the scheme will make a negligible difference to pollution levels.

- In the second case, consider that if such streets are largely car-free anyway, they will also not “allow the councils to gain useful experience and information to inform the ZEZ”. An effective pilot scheme should be implemented in an area that serves as a representative sample of the full roll out area, yet the area chosen will not do that. We would welcome clarity on this: what research was done to inform the decision to choose this area in particular? In section 1.14 of your summary, you rightly mention that the pollutant of most concern in Oxford city centre is nitrogen dioxide. So why does the pilot scheme not focus its attention on the worst offenders, namely the High, George Street and St Aldates? Furthermore, given that all three of these streets are covered by bus gates most of the day, their pollution is patently thanks to bus emissions, not car emissions. So why are buses being overlooked here? Relatedly, in your documentation you mention that a separate arrangement has been reached between the council and local bus companies: please could you provide detail on this?

Buses and taxis should be included in any such scheme

It seems bizarre that buses and taxis should be exempt from such a scheme: we would appreciate an explanation for this choice. You say that “during the national lockdown introduced in March [...] in Oxford city centre pollution dropped by 64% to a level not likely to have been seen since the early 20th century.” Yet since there were barely any cars on the road during this time, this surely amounts to attributing 36% of all traffic in Oxford to bus traffic. The City Council’s own Source Apportionment Study also showed that buses are a huge contributor to pollution in the city. Electrification of all buses should be the most pressing priority, especially if the green zone ZEZ or similar is rolled out, encouraging further uptake of bus travel. Why is it not? This would have an incredible impact on pollution levels in the city. It is totally nonsensical to exempt such polluting vehicles from ZEZ charges in the meantime.

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Trade vehicles

As a side note, the ZEZ Pilot Zone charges essentially amount to a business tax: the vast majority of vehicles likely to be affected in the initial red zone phase are commercial: tradespeople, suppliers and so on - those not afforded the discount you currently propose, which it seems is only available to local businesses with fixed premises (though this is of course welcomed), but not their suppliers, despite many of these also being local businesses that surely deserve consideration. Many suppliers and couriers, contractors, service traders and those providing a wide range of other services are unlikely to be able to afford to buy an electric trade vehicle - all the more so in the current climate - having been badly hit by the current Covid-19 pandemic. As such, in many cases it is surely likely that such businesses will incorporate ZEZ charges into their fees - essentially passing them on to local businesses. Has the council considered this?

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Potential impact of the second, far more far-reaching green zone:

We welcome the prospect of an additional future consultation in summer on the larger ‘green zone’, but for the moment our primary concerns are:

- The area chosen for the pilot scheme is inappropriate as it will yield no scalable data on the likely impact of larger roll-out, especially if buses are to be exempt from the scheme. What analysis is planned and how will success be quantified before moving forward with the green zone roll-out? How will you measure a successful pilot scheme?

- Until a large proportion of businesses and individuals have the funds to acquire electric vehicles, the roll out will have a huge negative impact on the economic activities of the city at a time when we are already struggling. How does the council plan to help local city and rural residents make the switch to an electric vehicle, given how prohibitively expensive they are at the moment? This does not appear to have been addressed in any detail.

- What plans does the council have to introduce sufficient numbers of electric charging points by the time of the scheme’s proposed introduction in spring 2022? There are currently grossly insufficient numbers of charging points available across the city for such a scheme to encourage meaningful uptake of electric car use.

- The implementation will likely push huge numbers of car drivers to take circuitous routes around the zones: pollution levels will thus be relocated (and possibly increase with the extra distance travelled), not removed. The choice of pilot zone location is such that this hypothesis cannot be proven (or disproved, crucially). The pilot, if it is to take place at all, should take place elsewhere to provide useful data. At the very least, since the area chosen for the pilot scheme is in no way representative of the larger area proposed for inclusion in the second ZEZ green zone, if the decision is still made for the pilot scheme to go ahead, there should surely at least be introduced a further intermediate zone that covers a small part of the green zone - ideally frequently used (by cars that is) city centre streets, to provide a representative impression of how travel patterns and pollution levels are likely to be impacted, before any full roll out is implemented.

In Section 1.21 of the formal consultation document summary, you mention that “[h]aving considered and consulted extensively on a number of different approaches to the ZEZ, the councils consider that a charging scheme represents the fairest balance between accelerating the transition to a zero emission transport system and maintaining access for residents, businesses and visitors. [...] The use of charges allows us to gradually increase the requirements over time, as the availability and affordability of zero and low emission vehicles improves.” We absolutely agree, in principle. The council’s aims to reduce air pollution levels, tackle the climate emergency, and improve the health of residents, workers and visitors in Oxford and beyond is laudable... but by no means will adequately be met by the current proposals, which require serious reconsideration, especially of location and bus company inclusion.

Finally, in the summary you mention a “commitment to work with ZEZ residents and businesses to develop supporting measures in the context of the extra pressures of COVID-19.” Our members welcome the commitment and we would welcome an opportunity to discuss our concerns further and contribute to the scheme’s improvement at your convenience.

With very best wishes,

Emily Scaysbrook

Secretary, OHSA

OHSA response to City Council's bus gates proposal

The following was delivered verbally at the City Council’s Cabinet meeting on November 18th 2020 by OHSA Secretary Emily Scaysbrook

The Oxford High Street Association absolutely agrees with the primary aims of the bus gate; that is, to assist Oxford’s recovery from the coronavirus pandemic. However, we believe there are a number of far preferable alternatives to bus gates in achieving this: ways to positively encourage cycling that do not negatively impact those who need to make journeys for whatever reason across the city centre by car. 

Irreparably damaging for local businesses: these proposals would also be damaging to already decimated footfall levels for local businesses. Many would-be visitors to Oxford might quite reasonably decide to travel to a more car-friendly city or town centre instead, rather than use public transport (whether out of covid-related concern or otherwise) or a more circuitous route to travel into Oxford. All modes of travel into and around any city centre at a time like this should be encouraged to help support local businesses. 

These proposals would have no positive impact on cycling safety, perception of safety or uptake. They would increase total emissions, increase congestion on the ring road and remaining arterial roads into the city centre, and be incredibly damaging to those who for whatever reason are not afforded exemptions: local businesses, tradesmen, rural local residents, residents with complex needs not meeting blue badge requirements and informal caregivers, amongst others. City centre access for the elderly, those with immuno-suppressing conditions requiring more care to be taken in the current climate to avoid public transport etc. would also be made much more difficult by the introduction of bus gates. Assertions that city centre transport would see any meaningful level of ‘modal shift’ rely on pre-covid data for such beliefs. It is irresponsible to make such an assumption now. 

Bus services are currently running in fine time and there is negligible congestion. We also do not know when meaningful congestion levels will return! The city’s cycling infrastructure is actually poor considering how many people already cycle here, but this is what council funds should be spent on improving, not on punitive bus gates. Encourage people to cycle by making cycling more attractive, not by blocking other means of transport. 

Improve the existing infrastructure first! Repaint the current cycle lanes, resurface where necessary and where possible segregate them. Extend them at least to the various Park and Rides. What has been done in recent weeks at Magdalen Bridge is an appalling example of what not to do. The cycle lanes have been widened on both sides such that two buses cannot now pass one another without both encroaching into their side’s cycle lane. These are dangerous and need to be reconsidered. 

Cycling infrastructure is only as good as its weakest link, so if commuters and school runners are to be encouraged to make cycling their ‘last mile’ solution, cycling infrastructure from all Park and Rides needs to be improved, making it more similar to the brilliant route down Marston Ferry Road. I have no doubt that doing so could see increased numbers of children cycling to school, their parents gladly dropping them off, knowing they’ll be safe. 

On the ‘last mile’ solution note... 

● Provide far more space on trains for bikes. Make reserving bike spaces possible online too. 

● Provide safer bike parking at Park and Rides and around town. 

● Provide secure lockers at Park and Ride sites for bikes that users intend to leave for >24hr periods. 

At the same time, fix instances of poor city planning: there are a number of cases across Oxford and the wider county of urban planning poorly designed, implemented or both that could easily be rectified to great effect. To name just a few examples: the Westgate centre lacks sufficient bicycle parking and the new Great Western Park neighbourhood has negligible cycling facilities. Surely these failures should be addressed as a matter of urgency. I have included details in this summary’s addendum. Please do read. 

There are also many small improvements that could make a big difference to cycling uptake in the city centre:

● Subsidised cycling proficiency lessons for any Oxfordshire resident wanting them! Not just the NHS and students.

● Help for lower-income families and individuals to buy bikes and accessories with grants, not just loan schemes.

● Bike theft being punished more severely: help the public feel more confident investing in their cycling. 

● Subsidised electric bikes for elderly and less able people: Oxford isn’t flat and hills make a difference! 

● Making Exchanging Places training mandatory for all HGV drivers coming into Oxford to reduce accident rates.

● Introduction of harsher penalties for cars parking in bike lanes. 

● Slowing speeds down on roads: even down to 10mph in some areas if it would make a difference. 

● More bike parking! With 24,000+ students at the University alone, there is a huge need for more parking and it wouldn’t be hard to implement. 

And if congestion does return to the city centre? 

● A congestion charge between certain hours would surely be fairer than a total ban. You could charge all vehicles travelling 7:30-9am say, and again 5-6:30pm, with a reduced (or no) charge for electric and other ULE vehicles. This would encourage delivery vehicles, local residents and visitors who aren’t constrained by the time of day to travel at cheaper, less congested times, but still give them the option of travelling in peak times if necessary. Doctors, caregivers and so on could still be provided exemptions. 

PS. Many pro-bus gates people keep mentioning the city of Ghent as a success story comparator. To those, I would say that Oxford does not have a single, consistent and coherent tram offering across the city centre. Oxford is not flat, it does not have brilliant cycling infrastructure, or a fast, broad ring road. Studies on Ghent have also been done pre-Covid. It is not a like-for-like comparison and should not be treated as such.

Addendum: poor planning across Oxfordshire to fix 

● The Centrica office opened only in 2013, part of Oxford Business Park, has been described by council officers as “chronic” and a “case study in bad planning” with almost no provisions made for bikes or public transport. Surely this should be addressed. 

● Nearby, the redevelopment of Templars Square shopping centre in Cowley received planning permission in July this year even though it includes almost no provision for cyclists or public transport users. Could permission be retracted until provision is made?

● Outside the city, in the South Oxfordshire district, a new 3,300-home neighbourhood called Great Western Park is now under construction at Didcot. There are no facilities for cycling, beyond a few racks. Even though the development is little more than a mile from the town’s mainline railway station, it is not possible to walk or cycle directly to it. Could cycling infrastructure be introduced before construction is complete, to encourage good cycling behaviours for new residents from day one? 

● In central Oxford, the new Westgate shopping centre is a textbook example of the failure of planning policy. It was opened with virtually none of the new cycle parking spaces promised by the developers (and which were a condition of planning permission.) Eight months on, cycle parking is still not what was promised, much is inconveniently located and some is actually charged for. Perhaps the council could take up the issue with the developers, since cycle parking was a condition of permission granted?