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