<<

Environmental Protection Room 3, Caledonian Suite, 70 West Regent Street, , G2 2QZ Tel: 0141 333 6655 Fax: 0141 333 1116 Email: [email protected] www.ep-scotland.org.uk

Environmental Protection Scotland is a Scottish Charitable Incorporated Organisation SCIO Scottish Charity No. SC 043410

“WE WANT TO BE AN ATTRACTIVE PLACE FOR PEOPLE TO LIVE, WORK AND VISIT AND THAT MEANS HAVING GOOD AIR QUALITY”

TOM , DUNDEE COUNCIL

By John Bynorth

THE consultation on Dundee’s Low Emission Zone, which closed earlier this month, attracted 1,336 responses.

Two main proposals focus on the city’s ‘inner ring-road.’ Options to include or exclude certain car-parks, have bus- only routes or keep Seagate bus station in or out of the zone were put to elected members in late September. This process followed extensive modelling that whittled the options down from around 35 potential proposals.

The city council are continually striving to improve air quality through the introduction of multi-vehicle electric vehicle charging hubs, improved active travel infrastructure, such as a soon to be introduced eBike scheme and the largest fleet of EV council vehicles in the country.

So what sort of Dundee can we expect to see and how will it affect vehicle owners once the final plans for the LEZ are finalised and confirmed in 2020?

We met Tom Stirling, left, the council’s Head of Community Safety and Protection, which is part of the wider Neighbourhood Services Department, at his offices in City Square to discuss the proposals.

DUNDEE is the smallest of the four Scottish that have so far been earmarked for LEZ’s.

Around 148,000 people live in the City of Discovery which has been rejuvenated in recent years by the pedestrianisation of the city centre, the new train station, Waterfront development and the V&A Museum that opened in 2018.

Despite having a smaller population than Glasgow, or , the city’s compactness posed challenges for the team involved in drawing up the LEZ.

Steep hills in the city can be gruelling for cyclists and pedestrians and NHS staff, patients and their families require constant vehicle access to . In addition, the city centre lies within two-rings road with tens of thousands of vehicles passing the city each day enroute to the north-east or the . Dundee has good overall air quality, but also some pollution hot-spots, including Dock Street, Seagate and the Lochee Road corridor to the north-west. The former lies near the exit slip road of the A92 and is on the

outskirts of the proposed main inner-ring route. Air quality modelling work in Lochee Road suggests pollution would be reduced considerably by a bus-only route.

The Community Safety and Protection department includes the air quality unit and is part of Neighbourhood Services (NS). NS and the City Development directorates were remitted to deliver the LEZ, which emerged from the National Low Emission Framework (NLEF), and an internal strategy group was set up within the council to achieve this.

After the Scottish Government’s Programme for Government (PfG) laid out plans for LEZ’s in Dundee, along with Glasgow, Edinburgh and Aberdeen two years ago, the city council’s senior officers worked closely together to take the project forward working with a range of external organisations.

Co-chaired by Mr Stirling and Neil Gellatly, the council’s Head of Transportation, the LEZ delivery group included representatives from Transport Scotland, SEPA, which carried out air quality modelling exercises in the city, and Central Scotland Transport Partnership (TACTRAN), City Development, the council’s air quality monitoring, team, City Centre Manager Sarah Craig and Dr Jackie Hyland, until recently a consultant in public health medicine at NHS Tayside.

SYSTRA, the transport and traffic private consultancy, modelled numerous options for an interim stage two assessment which was published recently. The 90-page report made a series of recommendations centred on an inner ring road approach to the proposed LEZ. This included options for a buses-only LEZ area to include the bus station and an option for buses-only, but without the bus station option.

The other three options were for an inner ring-road LEZ for all vehicles that included all of the car-parks or one that excluded the public car-parks at Bell Street and West Marketgait. The final part of the second LEZ option was for an all-vehicle LEZ that did not place restrictions on certain types of vehicles using the car-parks at Bell Street, West Marketgait or Wellgate.

These have gone out to public consultation and once the responses are returned and fully analysed, the results will be presented to the council’s Community Development and Safety Committee in mid-February 2020.

Mr Stirling said the process had taken into account the nine-year City Plan for Dundee which runs until 2026 and which presents a vision of a strong and sustainable economy, more choice and opportunities and healthy communities and a vibrant and attractive city with an excellent quality of life.

Mr Stirling said: “We took that into account when setting the objectives for the NLEF process and they are compatible. We want Dundee to be an attractive place for people to live, work and visit and that means having good air quality. Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 2

“The objectives we set out for the SYSTRA report included compliance with the air quality objectives, but also to promote active travel, to make the city a desirable place to do business, and to live in, and travel to.

“We have a small number of hot-spots to address and the LEZ will certainly be a tool to help us deal with those issues.”

Seagate and Dock Street, pictured below, were two streets which had exceedences of annual mean NO2 in 2017, on which the modelling is based.

The majority of road transport emissions currently come from buses. Cities such as Dundee need the cooperation of the bus firms if they are to achieve their LEZ targets and with one double decker potentially able to take up to 75 private cars off the road, they have an important role to play.

Mr Stirling said that both the main local operators, Xplore Dundee, which is owned by , and Stagecoach had been ‘receptive’ to the LEZ proposals and that fleet changes were being accelerated by the companies. There will also be further discussions with the companies over the ‘grace periods’ required to ensure their fleets comply with the minimum Euro VI emissions standards.

The final LEZ proposal may also exclude the main route in and out of the Seagate terminal for buses, pictured below. This street has relatively good air quality and such a plan would be similar to the exclusion zone deployed by Glasgow City Council within its LEZ for buses entering and leaving Buchanan Street bus station from the M8 corridor.

Mr Stirling said: “The single most significant contributor of poor air quality is emissions from buses so we are looking at a city centre based zone.

“All of the bus journeys end up in the city centre. One option could have been looked at was controlling (the number) of buses that enter and leave the city centre, but that impact would be felt across the city because of the geography of Dundee. There has been a lot of discussion and consultation with the bus operators since the LEZ delivery group was set up and for a long time in advance of the consultation.

“We know, for example, that a fleet of Euro VI buses would achieve over and above compliance for air quality in Seagate. We have asked for their (the bus companies) views on ‘grace periods’ and I think we will need to allow an (extension) period of some kind to enable the companies to prepare for the LEZ. We’ve not reached a decision and will need to consider and take a recommendation back to committee.”

“However, we are seeing changes to the bus fleet before the LEZ is finalised. Xplore Dundee and Stagecoach have been very positive and want to be seen as part of the solution. There are some hybrid buses operating in the city centre and over the last year or so there’s been an increase in compliant Euro VI buses. Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 3

“We have to listen to the bus companies, but we also need to be reasonably challenging in terms of the objectives that we set.

“One of the issues is that, with all the air quality issues over the years, we know that (some pollution) levels have come down, but that they are not coming down fast enough. We can’t just leave it to the natural turnover (of the bus fleet) and we need to speed up that rate of change. “

“As well as having cleaner engines, new buses are more attractive and better equipped which will encourage passenger numbers.”

Businesses have expressed concern about the impact the LEZ will have on trade, particularly as a number of high street chains have shut their doors as traditional shopping models move online and shoppers have tightened their belts amid the uncertainty of Brexit.

Mr Stirling said the issue of how people can still drive into certain Dundee car-parks without impacting on congestion and air quality was being looked at by the council.

The Greenmarket and Olympia car-parks lie just outside the inner ring road LEZ zone allowing people to walk to the city centre.

In particular, there are concerns about how shoppers with disabilities with older diesel or petrol vehicles will still be able to access Shopmobility services in the main Overgate , pictured below.

Mr Stirling said this was a ‘difficult balancing act’ and the views of these groups would be carefully considered.

He said: “The Overgate shopping centre car-park includes the Shopmobility service. If you have a non-compliant vehicle and want to come into town, then it could be an option that ‘Blue Badge’ holders still can drive into the city and access those facilities.

“One of the difficulties is that the ‘Blue Badge’ is registered to a person, not a vehicle.”

City council stakeholder meetings with local businesses have also encountered some opposition to the LEZ concept.

He added: “There’s an (environmental) lobby that will tell us we are not going far enough with the LEZ and another which says we are impacting on things like accessibility and businesses. We are aware that we need to find the right balance.”

“Some voices (in the business community) are saying that the LEZ should not be an option and others have expressed concerned about the impact on business. They say that businesses are suffering for a multitude of reasons already and the LEZ will be another thing to impact on that.”

The Scottish Government has made a commitment to introduce LEZ’s so that is not an option, said Mr Stirling. He added: “It is a given that emissions and traffic pollution impact on people’s health. Equally, if we reduce the relevant pollutants then that will reduce those impacts with more and more studies telling us this.

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 4

“There are also health benefits from people making active travel choices irrespective of the emission levels.”

Mr Stirling pointed to the city council’s innovative efforts to encourage EV ownership. It recently opened the latest of several solar-powered EV charging hubs, with 20 reserved spaces for EV’s at the top storey of the Greenmarket car- park.

Meanwhile, the Princes Street hub, one of the first to be installed, pictured right, is continuing to prove popular.

On November 1st, the council introduced a small levy of 15p per kWh and a 38 pence connection fee, to be collected via the ChargePlace Scotland network, from EV owners who use the council owned facilities. However, there’s a discount on the charges for residents and the charges have generally been accepted by the EV community.

Dundee boasts the highest number of rapid- chargers of any Scottish city and almost 140 electric taxis are on the streets. The council has the highest total number of electric with either 170 already in use or in the process of being bought, including road sweeping and bin lorries with less polluting alternatives.

He said: “Dundee is seen as one of the leaders in encouraging EV uptake and people are encouraged to use them. My colleague Neil Gellatly was one of the key people behind that and they bring a huge benefit in terms of local air quality.”

There are plans for 350 eBikes for rental from strategically placed hubs which Mr Stirling said would be a ‘game- changer’ for active travel locally. He said: “If you are heading from the north or to the south of the city you are going to come across a rather steep hill at some point and I hope the eBikes will encourage cycling…”

Despite around 20% of Dundee’s taxis being electric, the majority of the 650 vehicles on the streets are privately owned mini-cabs. These owners are unlikely to be able to access some of the £1 million in funding for the retro-fitting of Hackney Cabs and other vehicles that was recently announced by the Cabinet Secretary for Transport Michael Matheson. Mr Stirling said widespread consultations were continuing with the taxi community, but that one potential option to would be for the drivers to purchase a used vehicle, registered after September 2015, which would be LEZ compliant.

He said: “If the vehicle met the licensing requirements, then I don’t think it would need to be brand new.

“Everyone will get the opportunity to have their say and feed their views into the proposals to be taken forward for elected members to make their decision.”

Mr Stirling said one of the concerns when designing the LEZ was to prevent the displacement of traffic from main routes to quieter, residential routes, especially as many more people, including families, are boosting the city centre’s population by living in areas such as the redeveloped Waterfront, pictured above.

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 5

He said: “If you look at a map of Dundee, taking into account the topography and the options for using side-streets and other streets, you would need to be very careful to not design a scheme that included the one corridor and put people around roads.

Mr Stirling added: “The LEZ must not displace (poor) air quality by putting more vehicles onto roads that are not designed for traffic, that already have parked cars on them and are designed primarily for pedestrians. Although the city centre is an urban area, there are some roads that are slightly more residential. We can’t take traffic off arterial routes and put the vehicles onto other streets that could have an adverse impact on people living there.

“We will model some of these options to ensure this kind of problem does not emerge.”

Mr Stirling also said that extending the LEZ to cover all of Dundee from the main arterial ring-road of the Kingsway was not practical from an enforcement viewpoint. This is due to the high levels of traffic that use it as a route out to Angus and onto Aberdeen or down to Perth and the central belt without actually entering the city centre.

He said: “Most of the area between the Kingsway and the inner ring road is compliant in terms of air quality. If you require everyone who had a vehicle in that area to be compliant, it would affect potentially thousands of vehicles including people who don’t actually come into Dundee.

“In between these two roads, there is not an obvious route that you can draw a line around to control air pollution. You wouldn’t want to have to put enforcement cameras on scores and scores of streets.”

All of the households within the inner ring road were individually leafleted during the public consultation.

Shops are had leaflets and the city council utilised social media to raise awareness of the consultation. In addition, the council contacted Fife and Perth and Kinross councils to ask them to encourage people living in their communities – some of whom work or travel to Dundee for leisure or shopping purposes – to provide feedback. NHS Tayside have also informed the public about the plans through social media.

A report detailing the consultation responses will be submitted to Dundee City Council’s Community Safety and Protection Committee in February.

This report will not recommend a particular proposal as further discussions will be needed on ‘grace periods’ and other elements of LEZ’s contained in the new Transport Bill.

There will be additional briefings for elected members before the final version of the proposed LEZ is submitted to the Scottish Government by the summer of 2020. Mr Stirling said: “It’s an interesting project and everyone has got a view on the LEZ, one way or another.”

FURTHER LINKS: SYSTRA Stage 2 assessment of Dundee’s Low Emission Zone options (including maps). https://www.dundeecity.gov.uk/sites/default/files/publications/cspp300919.pdf

The Programme for Government LEZ announcement & the Low Emission Zones Scotland website. https://www.transport.gov.scot/our-approach/environment/low-emission-zones/ https://www.lowemissionzones.scot/

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 6