WHEN an article headline asks a question, one can be 90 per cent certain that the answer is ‘no’. This week’s Spectator article on London Mayor’s Sadiq Khan, ‘Is Sadiq Khan really taking air pollution seriously?’ is a case in point.
The Spectator was reporting the launch of Mr Khan’s book Breathe: tackling the Climate Emergency, a feeble virtue-signalling exercise to justify his proposed Ultra Low Emission Zone (ULEZ) extension to outer London boroughs in August. The audience at the event barracked him, particularly when he used the death of a nine-year-old girl from pollution to justify his intended money grab and repeated the myth that ‘scientists say that thousands of Londoners, including vulnerable youngsters, are at risk from lethal exhaust fumes’, something I debunked in my previous article on the subject here.
The London Mayor is distributing a booklet to libraries extolling the supposed benefits of the ULEZ extension. It may not yet happen as councils have launched a judicial review into the process by which residents were consulted, with the High Court finding that there is a case to be heard.
Rather than being negative, let’s offer some solutions to pollution in London. One can begin with the case of Ella Adoo-Kissi-Debrah, the girl to whom Sadiq Khan referred. Hers is the only death in the UK officially attributed to pollution. The Office for National Statistics stated that the death ‘was attributed to environmental air pollution, however we are unable to determine whether this involved car emissions’. Southwark Coroner’s Court found that air pollution ‘made a material contribution’ to Ella’s death, though was not the only factor. Ella lived in Lewisham, South London, where there is a pollution hotspot called Loampit Vale. In 2013, the pollution monitoring site there recorded nitrogen dioxide levels in excess of the two threshold levels set for it. Even in 2023, one of these two thresholds is still being breached.
There are two major problems for Sadiq Khan using this case to justify the ULEZ extension. Firstly, pollution levels are highly localised. Whilst Loampit Vale continues to exceed target pollution levels, all nearby monitored sites show pollution levels within thresholds (see map below). Most pollutants don’t travel very far from their source. Dust particles are largely washed back into the soil by rain. Nitrogen dioxide is unstable, sometimes breaking down into unpleasant substances such as ozone and acidic rain, but it need not accumulate in the air, hence why its presence has fallen over the last 30 years. Yet Mr Khan has no plan to address the pollution hotspots in London, areas where health is most likely to be affected and likely to be inhabited by the poorest Londoners. The Mayor has not used his planning powers to block a multi-story development of 500 student units at Hanger Lane gyratory in west London, one of the worst pollution spots in London, seeming unconcerned that so many people should live in such a dirty location.
Performance against air quality objectives in London (2023 to date)
(Green ticks indicates compliance with all air quality standards, red crosses show at least one area of non-compliance)
The second problem with Sadiq Khan’s use of a human shield for his ULEZ policy is that Loampit Vale (shown in the bottom right of the map above) is within the existing ULEZ, so it’s implausible the scheme’s extension will have a noticeable impact on air quality there. The Mayor’s own forecast, buried in ULEZ consultation documents, is a reduction in current nitrogen dioxide levels from the expanded ULEZ in Lewisham of 1.2 per cent.
Most embarrassing for the London Mayor is the resurfacing of the semi-secret that one of the worst places for pollution in the capital is the London Underground. Guido Fawkes has pointed out that in 2019, King’s College found pollution on the London Underground was around 15 times greater than at street level. The Committee for Medical Effects of Air Pollution (COMEAP) estimated a one-hour Tube ride was as harmful to health as a full day above ground in London.
Most of the two million people a day using the London Underground will have little awareness of this although pollution on the Tube is not news. COMEAP produced a report in 1998 that people using the Underground might acquire a large proportion of their daily exposure to particles whilst travelling by this means and that this exposure ‘might have significant adverse health effects’. The worst lines on the Underground for pollution are the deepest ones, as dust particles are more likely to be trapped where ventilation is poor.
Transport for London (TfL) have tried to deflect criticism by arguing that Underground particulates are a different kind of dust. Subterranean air has a relatively high concentration of iron oxide. TfL have claimed that ‘iron oxide is not currently known to be a carcinogen or have other significant health impacts’. This is debateable and is misleading as there’s no reason to suppose iron oxide dust particles are less dangerous than other micro particles; it’s their tiny size (roughly 25 times less in diameter than a human hair) that allows them to post a risk to human health.
COMEAP, on whose work the widely touted estimate of 4,000 pollution related deaths a year in London is based, has produced no modelling to guess at the number of lives lost or shortened by particulate matter (PM) on the Tube. They have reported on studies of workers on subway systems elsewhere that found no or minor increase in inflammation and cardiovascular disease and no effect on the incidence of lung cancer. Noting that pollution levels on these subways are several time lower than the London Underground, COMEAP state it is not clear how applicable these findings are to the London Underground. Trade unions have raised concerns.
In their 2017 review of particulate matter on the London Underground, COMEAP state that ‘much work is still needed to understand the relationship between subway PM exposure and any health effects’, yet the London Mayor has commissioned no studies to examine the health impact of pollution on Tube workers. A recent study called for TfL to publish a ‘clean line index’ of Underground lines. However, whilst the London Air Quality Network website lists more than 100 sites at which pollution levels are monitored, not one of them is on the Tube network.
Health and safety requirements don’t clarify matters. The UK adheres to European Union legislation that requires annual average population exposure to particulates to not exceed 25 micrograms per cubic metre (μg/m3). These are higher than the guidelines set by the World Health Organization, who changed their target in 2022 to an annual average exposure not exceeding 5 μg/m3. Previously, the threshold was 10 μg/m3. The Health and Safety Executive set the maximum particulate exposure level for employees at four milligrams (mg/m3) averaged over eight hours. TfL state that train operators and station staff are exposed to levels less than four times the legal limit. But one milligram is 1,000 micrograms; exposure levels for workers and the general population are grossly inconsistent.
So here’s how to start improving air quality in London: focus on the known pollution hotspots and ban all new housing at these locations until air quality improves, and publish data on Underground pollution levels. Perhaps Tube passengers should try to protect themselves by wearing the masks that did them no good during Covid lockdown. However, there’s no money to be made in any of this, no motorists to be fleeced, no easy tubs for politicians to thump. Don’t hold your breath waiting for any of this to happen.